Code Of Conduct

HM Uluslarası Proje Taşımacılığı A.Ş. is an international forwarding logistic and transport company specialized in the transportation of industrial investment goods including heavy and bulky machinery and equipment up to complete industrial plants such as cement factories, power plants, iron & steel plants, petrochemical plants and oil & gas equipment etc. on a worldwide basis. This includes local transport in the country of destination up to construction site and if required, delivery on foundation. HM Uluslarası Proje Taşımacılığı A.Ş. works on an international basis for clients in Europe and Overseas.

HM Uluslarası Proje Taşımacılığı A.Ş. counts on about 25 sister and daughter companies in the following areas:

» North, Central and South America
» Near / Middle East
» Central and Eastern Europe, Russia, Ukraine
» Asia, India, Pakistan
» North and West Africa

The management, the employees and the partners of HM Uluslarası Proje Taşımacılığı A.Ş. strictly abide by compliance rules and a Code of Conduct which defines the basic requirements of the company as well as suppliers of services. HM Uluslarası Proje Taşımacılığı A.Ş. herewith declares:

Compliance Standards

HM Uluslarası Proje Taşımacılığı A.Ş.´s compliance standards are operated as compliance at all levels of HM Uluslarası Proje Taşımacılığı A.Ş.´s activities. The corporate policies – Code of Ethics and Compliance (CoEC) and the Anti-Corruption Compliance Policy (ACCP) are basis of our activities. These corporate regulations are mandatory for all the branches worldwide including sister companies, employees, agents and subcontractors.

Compliance Systems

The CoEC and ACCP meet or exceed the legal requirements stipulated in the following acts, among others, and are regularly updated.

HM Uluslarası Proje Taşımacılığı A.Ş.´s management, partners and employees regularly take part in compliance training sessions which are provided in writing respectively face to face in special sessions, subject to the individual risk level.

Business Relationship

HM Uluslarası Proje Taşımacılığı A.Ş. expects business partners to observe the fact that openness and transparency are keys to a trustworthy business practice. This means to observe the following principles:

Avoid Conflicts of Interest

HM Uluslarası Proje Taşımacılığı A.Ş. and their partners make decisions based solely on objective criteria and do not allow themselves to be guided by personal interests and relationships.

Prohibition of Corruption 

HM Uluslarası Proje Taşımacılığı A.Ş. partners and employees do not tolerate corruption. They insure that their employees, subcontractors and partners do not grant, offer or accept any bribes, kickbacks, inadmissible donations or other inadmissible payments or benefits to or by customers, officials or other third parties. This also applies to payments to accelerate administration matters.

Invitations and Gifts

HM Uluslarası Proje Taşımacılığı A.Ş. does not tolerate that any business partners, suppliers and agents offer any form of invitations or gifts which must be considered as inappropriate benefits to unduly influence decisions. Neither do they ask for nor accept such benefits.

Corporation With Authorities

HM Uluslarası Proje Taşımacılığı A.Ş. and their management and employees are not allowed to offer any part of bribery or facilitations to any official agent or government employee.

Agents

Cooperation with agents can only be in line with the laws in force in the country the business is taking place.

Fair Behavior In The Market

HM Uluslarası Proje Taşımacılığı A.Ş. is a fair and responsible participant in the international logistic market and lives up to its contractual obligations. HM Uluslarası Proje Taşımacılığı A.Ş. expects the same from its business partners and especially expects the observation of the following principles:

Free Competition

HM Uluslarası Proje Taşımacılığı A.Ş. complies with the applicable antitrust legislation, especially HM Uluslarası Proje Taşımacılığı A.Ş. does not enter into any anti-competitive agreements with competitors, suppliers or customers.

Restricted Articles

HM Uluslarası Proje Taşımacılığı A.Ş. will make sure that they comply with all applicable legal provisions for exporting and importing goods (especially dual use), services and information.

Anti-Money Laundering

HM Uluslarası Proje Taşımacılığı A.Ş. only conducts business relationships with business partners of whose integrity HM Uluslarası Proje Taşımacılığı A.Ş. is convinced. They insure that the applicable legal money laundering provisions are observed.

Assets and Business Secrets

Confidential data, business secrets and company assets must be protected. HM Uluslarası Proje Taşımacılığı A.Ş. expects business partners to especially observe the following principles:

Know-how, patents, trade and business secrets

HM Uluslarası Proje Taşımacılığı A.Ş. and their business partners respect the know-how, patents, trade and business secrets of third parties as well as those of HM Uluslarası Proje Taşımacılığı A.Ş. This is understood without any explicit prior written consent.

Managers, employees, partners and business partners of HM Uluslarası Proje Taşımacılığı A.Ş. observe all laws in force to protect the personal data of customers, suppliers, employees and other parties concerned.

Legal Compliance

Managers, employees, partners and business partners of HM Uluslarası Proje Taşımacılığı A.Ş. comply with the laws of the applicable legal system(s).

Respect For The Basic Human Rights of Employees

Managers, employees, partners and business partners of HM Uluslarası Proje Taşımacılığı A.Ş. promote equal opportunities for and treatment of its employees irrespective of skin color, race, nationality, social background, disabilities, sexual orientation, political or religious conviction, sex or age;

Respect the personal dignity, privacy and rights of each individual;

Refuse to employ or make anyone work against his will;

Refuse to tolerate any unacceptable treatment of employees, such as mental cruelty, sexual harassment or discrimination;

Prohibit behavior including gestures, language and physical contact, that is sexual, coercive, threatening, abusive or exploitative;

Provide fair remuneration and guarantee the applicable national statutory minimum wage;

Comply with the maximum number of working hours laid down in the applicable laws;

Recognize, as far as legally possible, the right of free association of employees and to neither favor nor discriminate against members of employee organizations or trade unions.

Prohibition Of Child Labor

Managers, employees, partners and business partners of HM Uluslarası Proje Taşımacılığı A.Ş. employ no workers under the age of 15 or, in those countries subject to the developing country exception of the ILO Convention 138, to employ no workers under the age of 14.

Health And Safety of Employees

Managers, employees, partners and business partners of HM Uluslarası Proje Taşımacılığı A.Ş. take responsibility for the health and safety of its employees;

Control hazards and take the best reasonably possible precautionary measures against accidents and occupational diseases;

Provide training and ensure that employees are educated in health and safety issues;

Set up or use a reasonable occupational health & safety management system.

Environmental Protection

Managers, employees, partners and business partners of HM Uluslarası Proje Taşımacılığı A.Ş.act in accordance with the applicable statutory and international standards regarding environmental protection;

Minimize environmental pollution and make continuous improvements in environmental protection;

Set up or use a reasonable environmental management system.

Supply Chain

Managers, employees, partners and business partners of HM Uluslarası Proje Taşımacılığı A.Ş. use reasonable efforts to promote among its suppliers compliance with this Code of Conduct;
comply with the principles of non-discrimination with regard to supplier selection and treatment.

All managers, employees, business partners and partners of HM Uluslarası Proje Taşımacılığı A.Ş. are required to acknowledge receipt of this Code of Conduct as well as any amendments of this Code of Conduct if this is delivered.

If a question arises as to whether any action complies with HM Uluslarası Proje Taşımacılığı A.Ş. policies or applicable laws, you should present this question directly to the below mentioned party. All managers, employees and partners have the commitment of HM Uluslarası Proje Taşımacılığı A.Ş. that these persons will be protected from retaliation. However, HM Uluslarası Proje Taşımacılığı A.Ş. reserves the right to discipline anyone who knowingly makes a false accusation or provides false information.

Any violation or non-compliance with the Code of Conduct must be immediately reported. Reports should contain as much specific information as possible to allow for proper assessment. Any violation of the Code may result in disciplinary action.

The report can be either made to the compliance officer as mentioned below or to the supervisory board of HM Uluslarası Proje Taşımacılığı A.Ş.

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