Morten Ethics Policy

Important

At Morten Bilgi ve İletişim Hizmetleri A.Ş., it is essential that the services we provide are excellent and that we conduct our activities with unquestionable independence, integrity and legality. Our success depends to a large extent on the trust our customers and employees place in our independence and integrity. Morten's reputation among our customers, business partners and suppliers is therefore among our most cherished values. Independence, integrity and compliance with the law are the most important principles of the Morten Code of Ethics. It is very important to us that Morten employees and business partners around the world fully adhere to the Morten Code of Ethics

Violating our code of ethics could result in Morten or you are incurring substantial fines, court costs and compliance-related costs or civil liabilities, and imprisonment for those involved. It could also seriously damage Morten's reputation and market value.

With this in mind, we refuse to engage in unfair and/or dishonest business practices and conduct our business free from bribery or corruption. It should be noted that violations of the law will not be tolerated and may result in disciplinary action and legal sanctions.

The principles and explanations regarding our Morten Code of Ethics are explained in the following articles.

Morten Our Code of Ethics

1. Conflicts of Interest

Morten avoids conflicts of interest.

As a Morten employee, your duty is to comply with all applicable laws in relation to the activities within the scope of your duty. The independence, integrity and transparency of our services form the basis for our customers' trust in us. However, conflicts of interest can seriously undermine this trust. A conflict of interest may arise if or when the individual interests of a Morten employee conflict with those of Morten. If a Morten employee holds shares in a supplier, working for a customer or competitor of Morten or a similar third party may create a conflict of interest. All business decisions must be based on objective criteria.

 

2.Corruption

Morten does not tolerate bribery and corruption.

Corruption corrupts competition in business and causes harm to both individuals and society. Corruption affects the Morten employee under criminal and civil law;

It may also lead to lawsuits being filed against Morten. This could include any punishment ranging from imprisonment to a fine. Corruption is strictly prohibited at Morten and therefore any similar violation is against the company's interests. This principle applies to all employees and is binding.

As a Morten employee, you must strictly avoid the following, both domestically and internationally.

Offering, promising, securing or approving financial or other similar advantages to officials or business partners in order to obtain or show preferential treatment in making a decision, making a proposal or providing a service;

Requesting or accepting financial or similar benefits on behalf of the employee or another person, or accepting promises made in this regard, in order to provide or receive preferential treatment for the business partner during the order and/or delivery phase;

Directly or indirectly offering or providing financial or other benefits to officials in connection with any business activity within Morten.

Gifts, Representation and Hospitality

Gifts of little value given for the purpose of developing customer relations or invitations to joint business meals or business events are generally not problematic. However, it should always be ensured that gifts are in accordance with hospitality, courtesy and local customs. The acceptance or giving of gifts should not compromise our independence or that of our business partners. Even the appearance of such a compromise should be avoided in order not to damage our business reputation. Gifts and invitations should also be appropriate to the environment and position of our business partners.

Before giving or receiving a gift or making or accepting an invitation, the manager and/or the board of directors should be consulted to check whether the invitation or gift is acceptable.

Donations

Donations serve to support charitable organizations and are part of Morten's social responsibility. If there is a business relationship between the recipient and Morten, the giving of donations may cause problems. Donations may only be given independently of business transactions and not in connection with a procurement or administrative decision. Where possible, the written agreement of the recipient's supervisor/employer should be obtained before donations are given.

Fair Conduct Principle

As a Morten employee you should definitely stay away from the following;

Illegal activities that eliminate, reduce or destroy competition;

Receiving and giving information about competition,

Discrimination against competitors by abusing a position of market dominance.

Use of Information

Morten uses information in a careful way.

The exchange of information and the use of our know-how are part of our daily business activities. In order to protect information, our company and our customers, it is important that information is handled correctly and transparently.

 

Information Security

Information technologies and data processing play a key role in the execution of tasks at Morten. All important strategic and operational functions and tasks are significantly supported by information technologies. However, information technologies and data processing also carry risks related to the security of data.

Records and Financial Integrity

Internal and external transparency as well as accurate and truthful reporting are the standards of our entrepreneurial activities and approaches.

Confidentiality

Morten protects its own and third-party trade secrets and other confidential information.

As a supplier of technical services, Morten possesses valuable know-how and extensive trade secrets that form the basis of Morten's successful operations. Unauthorized disclosure of or other access to this information could cause serious damage to Morten and could result in sanctions under criminal or civil law and is therefore unacceptable. To prevent unauthorized disclosure of our own and third parties' information, we must take special protective measures when handling confidential information.

As a Morten employee, you must ensure that the company's know-how and non-public information of the company, its customers and other contracted parties are properly protected and not transferred to unauthorized persons.

Morten provides information security.

Information security Information technology and data processing play a key role in the fulfillment of tasks at Morten. All key strategic and operational functions and tasks are significantly supported by information technologies. However, information technology and data processing also carry risks related to the security of data

Confidentiality of Data

Electronic information exchanged via the Internet, Intranet, e-mails, etc. is part of our daily work. This electronic exchange of information may also include personal data such as names, addresses, dates of birth, etc. The use of personal data is governed by data privacy laws in many countries to protect the privacy of individuals and to establish their rights regarding what personal information can be disclosed and when.

Occupational Health and Safety Standards

The protection of our employees is of primary importance to Morten, as they are very important to us as a technical service provider.

Money Laundering

Morten does not support money laundering.

Money laundering occurs when illegally obtained financial resources (criminal activities such as organized crime, bribery, corruption, terrorism, etc.) are put into legal monetary and economic circulation in order to conceal their true source or the identity of their owners.

Morten sadece işle ilgili faaliyetleri yürürlükteki tüm kanunlara uygun olan ve mali kaynakları yasal faaliyetlerden gelen değerli iş ortakları ile iş ilişkilerini sürdürmektedir.

Discrimination

Morten does not tolerate discrimination.

Morten is a company that embraces and respects diversity. At Morten, our view is that individuals of different ethnicity, religion, worldview, race, age, vulnerability, gender or sexual identity reflect the richness of our society.

The Morten Code of Ethics is binding on all Morten employees and business partners.