IKP-01 Social Compliance Policy

As Termo Teknik Ticaret ve Sanayi A.S.;

Our social compliance policy includes the standards which are based on our fundamental principles and values and which we established by carrying out as a team work together with all of our business partners. Our goal is to ensure that the Social Compliance Policy becomes a company culture within the body of our Enterprise. For this reason, the social compliance standards were established and started to be applied. This policy commits to grant all rights of the employees arising from the standards within the framework of the laws, to comply with the occupational health and safety rules, to be sensitive to the environment, to ensure an open and honest communication among the employees and to establish the workplace environment in which the employees see respect and value as well as creating products and services with these social compliance standards. The social compliance policy is announced to all of our employees through the trainings or the communication channels (panel, website, mail group etc.), our suppliers are informed and our suppliers are evaluated in accordance with these criteria.

Within the scope of this policy, no sanction or punishment action is applied against the employees who express their concerns and complaints. For the employees to express these concerns and complaints, the suggestion, request and complaint boxes established are used. The employees can expressly declare all kinds of their opinions, requests, complaints and suggestions to the boxes and they are evaluated by the Senior Management and the necessary improvement activities are performed for the areas open to improvement.

The Social Compliance Policy includes the following components:

  • Forced Labor (Voluntary Work)
  • Child Labor (Minor Employees)
  • Discrimination (Equalitarian Approach)
  • Ethical Business Behavior
  • Working Hours and Salaries (Salary / Wage)
  • Health and Safety
  • Engagement with the Society and the Shareholders
  • Foreign Employees
  • Resting Days and Holidays
  • Recruitment and Employment
  • Employment Contract (Employer Contract)
  • Labor and Workers’ Discipline
  • Protection of the Environment
  • Freedom of Organization
  1. Force Labor (Voluntary Work)

Our Enterprise may not employ any employee by force. The working principles at our Enterprise are based on the principle of voluntariness. In the case that the employee leaves the job, the company may not prevent or suspend this except for any security reason. All kinds of information of our employee is protected and kept confidential to the extent specified by the laws.

  1. Child Labor (Minor Employees)

At our Enterprise, the child labor may not be accepted under any circumstances. The minimum age designated by the national and international laws is taken into account except for the mandatory cases such as intern and trainee.

  1. Discrimination (Equalitarian Approach)

Our Enterprise gives value to all of its employees and to the contributions that they provide. It has an essential commitment about prohibiting the discrimination and ensuring the equality of opportunity. As the management, we are decided to maintain our corporation as a company in which there is no discrimination on the basis of race, gender, color, nationality, social origin, religion, age, disablement, political view or all kinds of values protected by the applicable laws. For our Enterprise, the personnel selection is made by taking as basis the minimum qualifications such as open position, training, areas of interest, ability and work experience.

  1. Ethical Business Behavior

Our Enterprise does not tolerate corruption, fraud, embezzlement or bribery under any circumstances.

  1. Working Hours and Salaries (Salary / Wage)

Our Enterprise gives competitive salaries to its employees according to the sector and local labor market. Our applications are performed in full compliance with the applicable laws on salary, working hours, overtime and salary supplements and the employment contracts. The opportunities are proposed to our employees in order to develop their skills and capacities and these efforts are supported by providing promotion opportunities as far as possible.

  1. Health and Safety

Our Enterprise ensures a safe and health workplace environment is created and protected. The Company minimizes the risk of our employees to be exposed to an accident, injury and all kinds of factors threatening the health, establishes a workplace environment in which the employees can work safely, healthy and efficiently and aims at ensuring the continuity of such workplace environment. At our Enterprise, care is taken to ensure a workplace environment in which there is no violence, harassment, threat, abuse and disturbing conditions. At our Enterprise, all occupational health and safety rules regulated by the legal legislation are applied.

  1. Engagement with the Society and the Shareholders

Our Enterprise gives the commitment to bonding with its shareholders on the basis of good will by listening their opinions, obtaining information from their opinions and taking into account their opinions. In this regard, it determines the employee representatives in accordance with the legal legislation and establishes the environment in which the employees can negotiate their problems with the representatives and allows the employees to notify their problems to the suggestion boxes in written.

It gives the commitment to establish a dialogue with its shareholders in relation to the workplace and about the workplace rights within the impact area when appropriate.

  1. Foreign Worker Employment (Employment of Foreign Workers)

For the foreign workers employed/to be employed at our Enterprise in compliance with our laws, the Employment contracts are issued in the language which they will understand. All personal procedures from the employment until the leave of employment process are carried out in compliance with the legal legislations in force. The worker may not be employed by burdening with debt under any circumstances. The legal rights of the foreign workers about working are protected by our Enterprise. Our Enterprise does not employ illegal worker.

  1. Resting Days and Holidays

Our employees are not deprived of their resting days and holidays within the framework of their legal rights. The personnel who works for five days in a week is given a week holiday of two days.

  1. Recruitment and Employment

The open positions required are determined by the management of our Enterprise and the employment is made by the company management in compliance with the laws and within the framework of specific rules (equalitarian approach, leave, salary, holiday, employment contract etc.).

  1. Employment Contract (Employer Contracts)

“An Employment Contract of Indefinite Duration” which complies with the workplace and the laws and which includes the conditions proposed to the candidate personnel is prepared between our Enterprise and the person who will be employed. The personnel who has accepted to start to work is had signed “the Employment Contract of Indefinite Duration and the Deed of Consent for Overtime”. One copy of the employment contract is given to the employee against signature and all rules and regulations required by our enterprise and the work are transferred to the relevant personnel through the orientation training.

  1. Labor and Workers’ Discipline

The disciplinary rules established by the disciplinary board are applied by our Enterprise for the purpose of being able to ensure disciplined working. The Company may not apply salary deduction sanction in order to discipline its employee under any circumstances. All of our employees carry out their works by acting in compliance with the instructions of working rules.

  1. Freedom of Organization

Our Enterprise commits an open and constructive dialogue with its employees and their representatives. The employees have the freedom of participating in the organizations which they prefer and which will represent them. In the areas where the representatives are absent or the rights of the employees to elect employee representative are restricted by law, Termo Teknik Ticaret ve Sanayi A.S. ensures an appropriate social dialogue between the employees and the management.

  1. Protection of the Environment

We manage the environmental impacts that might arise from all kinds of our activities with the sense of responsibility. We determine and apply all kinds of improvement and development works which will eliminate or minimize the environmental impacts and which will use the natural resources in the most efficient manner in all of our activities.

All principles set forth in this policy document are put into application by the necessary regulations and the level of the applications is inspected by the relevant departments. We take into account the achievement which our Enterprise will show in the social responsibility applications as an important criterion in the evaluation of our company performance. This policy document was prepared in order to share an express commitment that Termo Teknik Ticaret ve Sanayi A.S.will fulfill all kinds of responsibilities on its part for a better world and future with all of our employees, shareholders and business partners.

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IKP-02 Human Rights Policy

  1. Purpose and Scope

Termo Teknik Ticaret ve Sanayi A.S. operates with its efficiency and sustainability-oriented approach. It adopts an understanding respectful to the human rights for its employees and all of its shareholders with whom it is in business relationship in the sector in which it operates, and it aims at observing the fundamental human rights throughout the society. It observes compliance with the United Nations Global Convention Principles. Within this scope, Termo Teknik Ticaret ve Sanayi A.S. established its Human Rights Policy (the Policy).

1.1   The Universal Declaration of Human Rights and International Labour Organization (ILO) Conventions, the United Nations Global Principles Convention, the United Nations Labour and Human Rights Principles and the OECD’s Guidelines for Multinational Companies constitute a basis for the Policy.

1.2   The Policy covers the business partners and the suppliers, mainly the employees. Termo Teknik Ticaret ve Sanayi A.S. transfers the rules set forth in the Policy to its employees through annual trainings. It notifies the Policy and includes it into the contracts in order to encourage its business partners and suppliers as well as its employees to act in compliance with the principles set forth in this Policy.

1.3   The Policy was accepted by the Board of Directors and came into effect as of 01-10- 2019.

  1. Principles, Commitments and Relevant Applications

Under the Policy;Termo Teknik Ticaret ve Sanayi A.S.

2.1  Respect for Human Rights

shows respect for the universal human rights in the country where it operates and aims at preventing the violations of human rights in compliance with the Universal Declaration of Human Rights. In addition to this, it shows respect to the rights of the local people in the countries where it operates by referring to the United Nationals Declaration of Rights of Local People.

2.2   Equality of Opportunity, Respect for Differences and Diversity

exhibits an equal attitude without making any discrimination depending on gender, language, religion, race, ethnic origin, sexual orientation, nationality, age, pregnancy, marital status, union membership, political view and similar issues among the employees within the processes regarding the human resources such as pricing, recruitment, personal and professional development and within the workplace environment and does not show tolerance to discrimination on these issues. While carrying out its approach to the employees with the principle of appropriate person for the appropriate job, it manages the processes depending on the qualification, experience and performance of the employees with transparency. It respects to the diversity which is an essential element of the organizational structuring.


2.3   Collective Bargaining Right and Freedom of Organization

shows respect to the collective bargaining right and freedom of organization of the employees.

2.4   Freedom of Expression

adopts as a principle to prevent all kinds of situations that will disrupt the use of the right of freedom of expression by the employees in the workplace environment.

2.5   Working Healthy and Safely

considers it among its prior issues to provide all employees with the conditions and the work environment under which and in which they can work safely and satisfactorily and acts in line with the “zero accident” target in all of its activities. It observes full compliance with the international principles and the national laws and legislations with regard to OHS and commits to provide good applications beyond the legal obligations.

2.6   Prevention of Maltreatment

gives no quarter to the incidents such as maltreatment, mobbing and harassment in the workplace environment.

2.7   Forced Labour and Human Trafficking

definitely prohibits forced labour and human trafficking.

2.8   Child Labour

prohibits employing child worker in line with the principle of not employing child worker as set forth in the Fundamental Labour Principles and Rights Declaration of the International Labour Organization.

2.9   Criminal Acts

does not make such attempts that might result in the act of crime or right violation in the countries where it operates. It expects the employees show sensitivity on this matter accordingly.

2.10   Feedbacks of the Shareholders

attaches importance to the feedbacks and opinions of the shareholders about the Policy. The feedbacks related to the Policy and the potential Policy violations and non-conformities are notified directly to the management personnel through our open-door policy system via the request and suggestion box and the external complaints, however, are notified to us from the contact numbers Phone: 0 282 685 43 88 – 89 Fax: 0 282 685 43 91, to our address info@termoteknik.com by e-mail or via the complaint information form at our website address www.termoteknik.com.




  1. Compliance, Monitoring, Audit and Reporting

3.1 The responsibility for the human rights policy belongs to the Chairman of the Board of Directors at the top level.

3.2 The Company’s Board of Directors is responsible for the senior observation of the determination and operation of the notification, inspection and sanction mechanisms in the case that the human rights policy, the rules and the regulations are not complied with.

3.3 Termo Teknik Ticaret ve Sanayi A.Ş. identifies the issues regarding the human rights which are likely to arise in its activities and the groups which will be affected from these issues at most and if any adverse effect occurs on the human rights, it tries to mitigate and prevent these effects. In the case that the human rights are under risk, the necessary measures are taken by contacting with the authorities.

3.4 For the notification of the violations about the compliance with the Policy, a system in which the identity of the notifying person will be kept confidential is established.

3.5 The Policy is reviewed by the Ethical Committee once in two years and the implementation of the policy is followed up. In the case that feedbacks are received from the shareholders, the Committee rapidly takes action and reviews the Policy.

  1. Settlement of the non-compliances with the Policy

4.1 For the compensation of the right violations committed by Termo Teknik Ticaret ve Sanayi A.S. under the Policy, the official and non-official complaint mechanisms are developed.

4.2 The Ethical Committee may apply to the expert opinion if it considers necessary and may use experts by taking the measures that will not violate the principles of confidentiality during the investigation. All information and documents requested by the Ethical Committee are given to the committee during the investigation. All employees are obliged to assist the Ethical Committee in this sense.

Any employee who notifies his/her concerns under the Policy is not retaliated against and the notifications are dealt with through the processes protecting the confidentiality. Not complying with the Policy may result in disciplinary penalty or penal application.

  1. Enforcement

The Policy comes into force as of 09 September 2019.

  1. Public Disclosure

It is mandatory for the Policy to be disclosed to all shareholders and the public. The Policy has been shared with all employees, business partners, suppliers and the public. In case of any amendment to the Policy, the same obligations are valid.

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