Our Corporate Compliance Policy

Doğuş Otomotiv’s Corporate Compliance Policy, designed to ensure compliance with the current legal legislation, Doğuş Otomotiv’s Code of Ethics, global standards and codes voluntary in nature, as well as to prevent possible violations and to take necessary measures, contains inclusive and regulatory policies that include, our employees being in the first place, all our business partners and stakeholders in our entire value chain.

Doğuş Otomotiv’s Corporate Compliance Policy institutes the foundations for realizing Doğuş Otomotiv’s corporate business ethics philosophy. Carried out in line with the legal legislation that we committed to comply with at every stage of our business activities and our Code of Ethics, this policy includes the following basic principles:

• We comply with all legislative regulations with a high level of ethical understanding and manage compliance processes as part of risk management by taking the necessary precautions.
• As a significant representative of the global business community in the world, we support all principles present in the Universal Declaration of Human Rights and declare that we are against discrimination at every stage of our business activities.
• We commit to comply with fair trade principles included in the United Nations Sustainable Development Goals in all lines of our business.
• We comply with all legislative regulations regarding the protection of the ecological environment in regions where we operate, and we make diligent efforts to reduce our environmental impact.
• In accordance with the relevant legal legislation, we protect corporate, personal and asset information we acquire as a result of our activities and take all measures regarding information security.
• While taking necessary precautions concerning the health and safety of our employees, we provide the best working conditions for them, we manage and supervise required processes to prevent unethical behaviors that may put our company’s reputation and assets at risk.
• We declare that all executives of our company are role models in compliance, as well as undertake all responsibilities to ensure that the Doğuş Otomotiv Code of Ethics is fully understood throughout the company internally and externally.
Doğuş Otomotiv Corporate Compliance Policy, together with the Doğuş Otomotiv Code of Ethics to which it is affiliated, are regularly reviewed in line with changing processes, developments, expectations and legislative regulations, and are updated as predicated by those terms and conditions.

Our Economic Development Policy

We apply the following policy in order to sustain the economic prosperity of Doğuş Otomotiv as well as all our stakeholders.

• By applying systems such as lean management, budget management and efficiency cards we use our resources efficiently.
• We accept economic fluctuations and their consequential causes as industrial risks and make necessary agreements with OEMs (Manufacturers) through budget and risk management in to manage (minimize) those risks, take appropriate financial measures, and update them according to market conditions.
• We consider climate change and its related causes as financial risks, and aim to raise awareness of all our stakeholders on these issues.
• To ensure the sustainability of our Authorized Dealers and Service Centers, we set and measure the required standards, make necessary contributions to their development, and provide audits.
• Through our Authorized Dealers and Service Centers, we contribute to local employment in regions where we operate.
• We provide equal opportunities for all our suppliers.
• We adopt and abide by global standards and policies implemented by our most important suppliers, OEMs. We prepare action plans with respect to the conditions considering the current global state of OEMs.
• One of the main indicators of Doğuş Otomotiv’s economic responsibility performance is the economic value it creates for its key stakeholders.

Our Market Presence Policy

• As one of the leading companies instrumental in economic development of the regions where it operates, Doğuş Otomotiv is committed to increasing local employment, supporting economic empowerment of its employees and contributing to the rejuvenation of local economies through its supply chain. In this direction, it continued to contribute to local employment through new investments made during the year.
• Doğuş Otomotiv, within the scope of its human resources policy it carries out in line with the principle of “equal rights for equal work”, does not discriminate in determining the wages of employees. Our full and clear policy regarding the issue has been disclosed to the public in the Doğuş Otomotiv Code of Ethics.
• Doğuş Otomotiv Kocaeli Şekerpınar Central Campus is the area of activity where our Company’s operations are carried out most intensively. Even though located outside of Istanbul geographically, it acts as a central base for our Company due to its logistical proximity to Istanbul and being one of the control points of the Marmara Region. Employment policies in Şekerpınar Campus, which hosts all of the administrative structure and logistics operations, are aimed at providing employment for people coming from areas close to the region. However, our employees, who are based in Istanbul, are also considered within the scope of local employment. In this context, our employees working at the Şekerpınar campus were recruited in accordance with local employment policies.
• Doğuş Otomotiv invested in a new center in 2014 under the name of “Value and Interest Center (DIM)” to listen to customer complaints and wishes, coordinate roadside assistance services, and conduct customer surveys. Recruitments at DIM, which provides 24-hour service to our customers, are also in line with local employment policies.
• The wages of employees at Doğuş Otomotiv are determined by considering the balances of the industry by making regional benchmark studies. Doğuş Otomotiv employees’ wages are generally above legal limits and industry averages.

Our Indirect Economic Impacts Policy

• Doğuş Otomotiv retains a direct economic impact on the society in regions where its operations take place. In addition to contributing to local employment, Doğuş Otomotiv also attaches great importance to the products and services it procures which are needed to continue its operations, to be the products and services provided by local companies. At the same time with its constantly developing and growing Authorized Dealer and Service Center network, it continues to be one of the supporters of development in every region of Turkey in creating new regional employment.
• Doğuş Otomotiv, at the same time, is an active player in cooperation platforms as a supporter of many initiatives and ventures that contribute to the society, the improvement of the business world, the development of the economy, and finding solutions to the problems of the industry.
• Doğuş Otomotiv, together with its subsidiaries and affiliates, is a part of a large supply and economic chain.

Our Environment and Energy Policy

Doğuş Otomotiv aims to carry out activities that will meet the expectations of all relevant parties, prevent negative effects on the environment and manage energy consumption with high efficiency at every stage of the activities it engages and services it renders in the sales and service segment of the automotive industry. In this context, our main goals are;

• To arrange or design our working environments in a way to prevent environmental accidents/pollution,
• To reduce the possible negative environmental impacts of our services and activities,
• To contribute to the reduction of the effects of global warming by increasing energy efficiency,
• To set our waste yield to zero and increase our waste recovery rate,
• To prefer to utilize new methods or technologies with environmentally friendly and energy efficient sets of equipment,
• To increase the utilization rate of renewable energy resources and to reduce their consumption by using natural resources efficiently,
• To make an environmentalist perspective a corporate culture by increasing awareness efforts,
• To steer our stakeholders, from whom we supply goods and services, to carry out their activities with a safe and environmentally friendly perspective,
• To fulfill all national and international legal requirements and obligations that we are under their scope or a party of,
• To continuously improve the performance of our environment and energy management system by ensuring the participation of all our employees and taking their opinions regarding the effectiveness of our activities,
• To ensure that no living thing is adversely affected by our products and business activities.

Doğuş Otomotiv determined its material issues in 2010 in line with its environmental responsibility policy, which was renewed in 2017.

Doğuş Otomotiv’s environmental responsibility policy and its objectives related to this policy are monitored and managed by the Corporate Governance and Sustainability Committee, subordinate of the Board of Directors.

Doğuş Otomotiv is a company that operates in the sales and service segment of the automotive industry. In this regard, it is the company that has published a sustainability report by conducting a materiality study and using global standards for the first time in the world and in Turkey in the field of Sustainability. For this reason, determining environmental priorities specific to our industry, being a role model incidentally, and determining the strategic steps of our industry towards sustainability are among the firsts we have realized as Doğuş Otomotiv.

The environmental impacts of our company throughout its business life cycle are grouped under five main headings:


Doğuş Otomotiv has fully integrated its life cycle into environmental management systems and by performing life cycle analyses, it imports environmentally friendly products that all have been assessed in terms of their environmental impacts; it also engages in sales and renders services in line with processes that are meticulously controlled by OEMs.

Together with the environmental management system that we improve every year, in addition to our Company, we work to increase the environmental responsibility awareness of our Subsidiaries, Authorized Dealers and Service Centers in our value chain, as well as our suppliers of which we assume responsibilities.

At Doğuş Otomotiv, environmental policy and related issues are monitored by our Environmental Specialist, and data collection, improvement and planning studies are carried out in coordination with the Sustainability Council.

We aim to increase our efforts to minimize our environmental impact every passing day, both with the environmental responsibility studies of our brands and with the environmental awareness we try to create in our Authorized Dealers and Service Centers.

Our Sustainable Purchasing Policy

Sustainable purchasing policy evaluates, controls and regulates that its suppliers and business partners have management processes with reduced risks in social, environmental, ethical and economic areas with which Doğuş Otomotiv and Doğuş Oto work with, while purchasing goods and services needed for conducting their activities in accordance with the strategic sustainable principles and guidelines.
The purpose of this policy is to set forth the expectations of Doğuş Otomotiv and Doğuş Oto from their product and service providing business partners in purchasing goods and services, as well as to establish basic principles and guidelines in line with these expectations, and to organize supply chain and purchasing activities in accordance with sustainable purchasing management policies.
The foundation of the Sustainable Purchasing Policy is based on establishing, managing and developing long-term business relationships, in line with the general policies and strategies of Doğuş Holding, Doğuş Otomotiv and Doğuş Oto, in compliance with Doğuş Otomotiv Code of Ethics and Procurement Procedures, based on processes in line with the United Nations Global Compact, and relying on mutual trust and cooperation with existing and potential business partners.
Accordingly, Doğuş Otomotiv and Doğuş Oto request from their suppliers and business partners to;
• Have business processes that are compatible with sustainability principles,
• Regularly monitor their impacts on the ecological environment while conducting their business and to work to reduce this impact,
• Carefully follow the social, environmental and ethical areas in their investment processes and to be responsive in these areas,
• Regulate their working conditions and ethical processes within their establishments in accordance with the principles of sustainability.
During the purchase of goods and services, any action that prevents the fair and impartial conduct of the process is prohibited. If said actions are determined to be carried out by the candidate company/companies, they are excluded from the purchasing process at once. For goods and services, whether there are new company/companies that produce/market the goods or services at regular intervals is thoroughly scrutinized.
In purchases, besides price and payment conditions, the candidate company’s social, environmental and ethical processes are also considered. Following issues are taken into account while choosing among the candidate companies:
• Intelligence collected about the company, its technical and financial competence, its commercial reputation and its standing in the market, its experience, references, its relations with Doğuş Otomotiv and Doğuş Oto,
• Being an institution that is able to provide competitive conditions and attach importance to research and development in order to specialize in its own field,
• The following conditions of the goods or services to be purchased from the company are also taken into consideration;
• Whether or not these goods and services are within the main field of activity of the company and whether they are directly provided by the company,
• Their compliance with quality and standards, technology level with which they are produced and guarantees they have (TSE, ISO, etc.),
• If they are meeting the needs,
• If they are produced in accordance with national and international standards on Environment and Occupational Safety and if they have a service or production process that respects human health and ecological environment,
• If they have short delivery and maintenance times, provide technical support and spare parts, if the offered price and price are kept constant for a certain period, etc.
All correspondence exchanged with companies and offers received during the purchasing process are made in accordance with the corporate correspondence rules of Doğuş Otomotiv and Doğuş Oto; in addition, all purchases of goods and services made by the units performing the purchasing transactions are recorded electronically.
Every employee involved in the purchasing processes of Doğuş Otomotiv and Doğuş Oto is obliged to carry out the purchasing processes in line with the following principles.
They are responsible for conducting the activities of Doğuş Otomotiv and Doğuş Oto in accordance with the principles of sustainability, reducing social, environmental, ethical and economic risks, reducing the risks of its suppliers and business partners in these areas and increasing their awareness. Employees managing the process should investigate whether there are different areas to be evaluated according to the type of product and service, such as the following.
• If that good/service is absolutely necessary to be purchase,
• If the waste generated as a result of the purchase is at a minimum level (and/or contributes to the reduction of waste),
• If they reduce risks related to climate change, provide a positive impact on them and/or are impact-free,
• If they have a positive effect on the productivity (financial or non-financial efficiency),
• If they have a positive effect on the use of natural resources,
• If they are compliant with all laws and regulations related to occupational health and safety, to have their effects evaluated on the health and safety of Doğuş Otomotiv and Doğuş Oto employees.
All processes must comply with Doğuş Otomotiv and Doğuş Oto Code of Ethics, the supplier or business partner must have full knowledge of the Code of Ethics and commit to full compliance.
Establishing long-term business relationships (or working) with companies that produce and provide services in accordance with national and international standards on Environmental and Occupational Health and Safety issues and companies which have a modern management approach is preferred.

Our Product and Service Responsibility Policy

Doğuş Otomotiv monitors social and environmental impacts of its products and services; it is aware of its responsibility towards all social stakeholders and the ecological environment. Doğuş Otomotiv adopts and implements the following policy as a part of its Main Principles of Product and Service Responsibility framework:
• Manages, controls and continuously improves the processes related to customer health and safety.
• For all stakeholders who are directly or indirectly affected by its products and services, applies international standards for their training and discloses accurate information to them.
• To serve beyond expectations, focuses on choosing the right equipment, offering reasonable prices, correct launch, training of Authorized Dealers and Service Center personnel and informing customers accurately.
• Constantly monitors its service standards and aims to reach the highest standards in customer satisfaction by taking special actions on issues that need improvement.
• Adopts, beyond the requirements of laws and regulations, responsible communication principles, observes OEM standards in line with the values and expectations of the brands it represents.
Our Employee and Workplace Policy

Doğuş Otomotiv;
• Uses measurable recruitment tools to be transparent and traceable in recruitment processes. By evaluating them with the relevant department manager, it recruits employees who have competence as stated in the job description.
• The aim of the human resources policy is to increase employee loyalty and to ensure sustainable productivity. To achieve this, stakeholder - priority analysis, employee satisfaction and loyalty surveys are conducted, and improvement programs are implemented according to the results.
• With the zero-incident target, takes lessons from the past experiences and improves the processes. Implements the programs required for the accident results to be traceable and accountable.
• Cares about the development of awareness among its employees regarding social health and safety. For this reason, it organizes informative, consciousness and awareness-raising seminars. These studies are implemented systematically and in a planned manner.
• Implements various programs and sets goals to increase the quality of life and social welfare of its employees and to make the working environment more efficient.
• Prioritizes transparency in all processes of employee practices. Monitors legal processes regarding discrimination and follows the data.
• Cares about communication with its employees, queries their expectations regularly and implements an open-door policy.
• Determines key performance indicators to achieve the “Great Place to Work, Best Employer” targets in local and international platforms.

Our Equal Pay for Equal Work Policy

Believing that the correct remuneration management system is ‘equal pay for equal work’ calculated using job valuation method for each position, Doğuş Otomotiv supports the remuneration system with regional and industrial analyzes, and carries out necessary studies to create a competitive system compatible with the market. As in all processes of Doğuş Otomotiv, the principle of equality is accepted as a prerequisite in remuneration processes.
Assessment of Suppliers in Terms of Labor Practices Management Approach
Doğuş Otomotiv added Sustainability-related areas among its audit criteria in supplier audits in 2014. Our suppliers to provide legal and social rights to their employees is also among these criteria.
Labor/Management Relations Management Approach
Doğuş Otomotiv’s primary key stakeholder is its employees. There are different dialogue platforms at Doğuş Otomotiv and Doğuş Oto where employees come together both within themselves and with managers and senior management. All of these platforms enable our employees to convey their opinions and suggestions directly to senior management and to receive information about the company, targets and strategies from the top management. Sharing changes, strategies and targets related to our activities in our company with our employees is among our internal communication strategies. Furthermore, Doğuş Otomotiv intranet system is actively used for such announcements. Legal notice periods are complied with in Doğuş Otomotiv.

Our Occupational Health and Safety Policy

Health and safety of our employees is considered among the top priorities in our company. Employee health and safety also plays a critical role for our company to pursue its business activities successfully. The basis of our Occupational Health and Safety policy is the principle of “Safety First”. Providing necessary information to our employees, offering the required trainings regularly and continuously, creating a healthy and safe work environment is also an important principle of our “Employees and Work Environment Policy” and is an important element for ensuring business continuity.

As in all policies of Doğuş Otomotiv, stakeholder engagement understanding has an important place in Occupational Health and Safety Policy. The main axis of our policy is to follow the best practices in the world regarding the health and safety of our employees, to carry out improvement studies by consulting our employees’ opinions, and to be “accountable” in all processes.

Occupational Health and Safety issues, which we primarily address to anticipate our risks within the scope of our sustainability strategy, to become the most preferred company and to increase the satisfaction and loyalty of our employees to the company, are managed in line with the following principles:

• We prioritize occupational health and safety aspects at every stage of our activities and manage them with a risk management perspective.
• We comply with health and safety laws and regulations, social norms, generally accepted business practices and safety standards at every stage of our business.
• We implement practices related to occupational health and safety in line with the systems and processes in which our employees are directly involved.
• We provide all the necessary operational support for all our employees and managers to pay maximum attention to the zeroing of work-related accidents and lost day rates and to reduce job-related and occupational diseases by fully complying with the processes related to occupational health and safety.
• To guarantee the health and safety of our employees, we meticulously manage the issues of providing regular trainings, monitoring quality processes, sharing possible accident reports with open communication, exchanging information with sampling, exercise studies, like all our processes.
• We regularly review our Occupational Health and Safety Policy in order to adapt to operational changes in our business and the industry and to improve our processes in line with new needs, and make changes when necessary.
• We run the necessary information and warning mechanisms to ensure that our stakeholders, including Doğuş Otomotiv’s suppliers, business partners and customers, comply with all the aspects of this policy.

The Administrative Affairs Department is responsible for the implementation of Doğuş Otomotiv’s Occupational Health and Safety policy, and the General Manager of Human Resources and Process Management takes part on the Executive Board as a Member of the Executive Board.

Doğuş Otomotiv transparently shares its data on Occupational Health and Safety within the scope of its Sustainability Report every year.

Training and Learning Management Approach

Doğuş Otomotiv considers supporting its employees both professionally as well as personally and socially as a part of its human resources policy. For this purpose, it applies a training and learning policy in line with not only the Company’s priorities but also the expectations of the employees. It regularly questions these expectations and demands and develops education models accordingly.

Our Performance Management Policy

Our Performance Management System consists of 3 periods: target entry period, target revision period and performance evaluation period. The follow-up and coordination of the performance process of all employees is carried out by the Human Resources Unit. Compensation and bonus system management is provided through performance outputs.
Training and rotation requests of employees are taken over the D-İnsan (D-Human) performance system and the plans for training and rotation are made accordingly. After the performance evaluation period, career and succession plans are made based on brand/department with managers, directors, and general managers over the general performance status of people working as their subordinates. Evaluations are made based on these plans for in-house assignments and position changes. Furthermore, compulsory and optional trainings were determined based on the titles and the participation of employees in these trainings was ensured.

Our Human Rights Policy

Doğuş Otomotiv;

• Bases its commitments regarding Human Rights on the United Nations Global Compact it has signed, and the United Nations Universal Declaration of Human Rights.
• An integral part of its Ethical Principles is human rights and expects all employees and business partners to comply with these principles as well as Doğuş Otomotiv Human Rights policy.
• Complies with national and international laws and regulations related with human rights, and expects business partners to do as well.
• Observes the rights of the people living in the regions where it operates, takes measures against rights violations, manages the related risks.

Human Rights in Investments Management Approach

Doğuş Otomotiv pledges to take decisions in line with the United Nations Universal Declaration of Human Rights in all its activities and operations covering these activities, and to organize all its activities accordingly. At the same time, due to the 1st and 2nd articles of the United Nations Global Compact, it has clearly declared its commitment on this issue.

Child Labor Management Approach

As a signatory of the United Nations Global Compact, Doğuş Otomotiv does not allow child labor at any stage of its activities under no circumstances. Service Center Regional Managers are informed and support is provided during the process of recruitment requests of our Authorized Services. This issue is secured in contracts entered with our suppliers, and is considered as an important item during annual audits.
Forced and Compulsory Labor Management Approach
As a signatory of the United Nations Global Compact, Doğuş Otomotiv does not allow forced or compulsory labor under conditions that do not comply with laws and regulations at any stage of its activities. This is also valid for Doğuş Otomotiv’s suppliers and all its subsidiaries and affiliated partners. Our supplier audits contain relevant content.
In our company, every employee is insured as of the day they start working. This issue is controlled by both internal and external audits. Employees are informed about overtime working conditions during their job initiation process and their approval is obtained within the scope of the employment contract. Doğuş Otomotiv also expects the same sensitivity from its Authorized Dealers and Service Centers as well as suppliers within its impact and conducts the necessary inspections.

Security Practices Management Approach

In regions where Doğuş Otomotiv operates, security services are procured from third party companies. As with all our suppliers, Doğuş Otomotiv principles and policies have been shared with our supplier providing security services within the scope of a protocol, and the necessary information has been provided.
Local Community Rights Management Approach
Respecting all the rights of the local community living in the regions where we operate, Doğuş Otomotiv attaches particular importance to the way of doing business called “social approval”.

Assessment of Suppliers in Terms of Human Rights Management Approach

Starting from 2014, Doğuş Otomotiv has added articles that contain social, environmental and ethical concerns, including human rights, to its supplier assessment process.

Our Community Engagement Policy

Doğuş Otomotiv;

• Appreciates the importance of safety in traffic and the value of human life. It is committed to providing necessary services for its products and services to have high standards and to maintain these features throughout their life cycle.
• Its employees set an example for the importance of safety in traffic and behave responsibly.
• Undertakes that the products it sells meet the high standards related to customer health and safety.
• Is obligated to provide high quality and high standards of maintenance and repair services, limited to legislative regulations, in order the products it sells to maintain these standards throughout their economic lives, if its distributorship continues within the scope of distributorship agreements.
• Conducts and manages continuous information and awareness-raising activities on safety in traffic in dialogue and cooperation with relevant institutions and organizations.
• Ethical principles are clear and accessible and are supported by multiple participation. They are approved by the senior management and are one of the main elements of corporate governance principles.
• Continues its efforts to make the ethical principles a comprehensive framework that includes all processes.
• Acts away from unethical concurrences such as fraud and corruption, and provides necessary information for its employees to become aware of this issue and to assume responsibility. Starts studies and sets goals to establish mechanisms to prevent fraud and corruption.

Local Community Management Approach

Doğuş Otomotiv continues to render its services under safe, humane and ethical working conditions. It is equally respectful to the rights of the people living in the regions where it operates. Our company’s environmental and social responsibility policies directly include the principles necessary for the welfare, development and improvement of the society in which they live. In this context, it cooperates with various institutions and organizations and carries out studies to contribute to economic and social development. Social, environmental, economic and ethical expectations of the society from Doğuş Otomotiv are scrutinized through various perception researches and surveys throughout the year and these expectations are integrated into our corporate strategies.
Doğuş Otomotiv does not have a business activity subject to environmental and social impact assessment.
Anti-competitive Behavior Management Approach
Doğuş Otomotiv strictly complies with all laws and regulations that regulate anti-competitive behavior, anti-trust or monopolistic practices.

Our Customer Health and Safety Policy

Doğuş Otomotiv strives to provide the highest quality and reliable service to its customers with the responsibility of being one of the leading automotive distributors and service providers of Turkey. Health and safety of our customers is our top priority in the entire life cycle of our operations. Quality controls performed at every stage of production by the world’s leading automotive manufacturers that we distribute and the sensitivity they display to customer safety bring our company, as Doğuş Otomotiv, the responsibility to organize our business activities with an understanding of superior service. Doğuş Otomotiv’s understanding of “service above expectations” is the most significant reflection of this responsibility.
In line with our customer satisfaction-oriented strategies, by reviewing all our processes, necessary improvements are provided to ensure that our customers are satisfied with the products and services they receive from Doğuş Otomotiv, that they can submit all their suggestions and complaints directly to our Company, and to receive the support they require.
Product and Service Labeling (Information) Management Approach
Doğuş Otomotiv carries out the distributorship and service of brands that have quality control processes at international standards. In terms of informing users about its products and services, processes are also managed in accordance with the standards of the manufacturers. Documents are provided to inform our customers fully and accurately about all our products and services.

Marketing Communication Management Approach

Doğuş Otomotiv complies with laws and regulations in all marketing communication activities, including advertising, sponsorship and promotions.

Our Diversity and Equal Opportunity Policy

Doğuş Otomotiv does not allow its employees being discriminated with the Code of Ethics and discrimination between Employees in line with its Workplace Policy under any circumstances and carefully monitors and manages all processes in this regard.

• As one of the members of the Equality at Work Platform in Turkey, Doğuş Otomotiv contributes to increasing women’s employment and creating equal opportunities for women in the business environment not only within the Company internally but also at national level.

• For Doğuş Otomotiv, the concept of “diversity” means; accepting the religious, structural and cultural differences of employees, customers, suppliers and other social stakeholders and valuing all these diversities.

• Doğuş Otomotiv, in addition to attaching importance to diversity, it also believes that diversity is a significant element is a corporate wealth.

• Doğuş Otomotiv, regardless of their different cultures and origins, is committed to being the most preferred employer for all highly qualified candidates who are devoted to their work, and a company which develops its employees and protects their rights.

• Doğuş Otomotiv implements an “Employee and Workplace Policy” independent of religion, language, race, color, gender, age, ethnic origin, disability, citizenship or other social status protected by legislative regulations. Our company participates in events that comply with its own policies, undertakes sponsorships, becomes a member of institutions and organizations and cooperates only with institutions and organizations with this understanding.

Our Anti-Bribery and Anti-Corruption Policy

The most valuable asset Doğuş Otomotiv has is the trust of its customers, suppliers, employees and shareholders in our Company, and our corporate reputation that we have gained since the day we started business. Maintaining the trust and reputation of our stakeholders are our reasons for existence that we will never allow to be compromised.

Doğuş Otomotiv, in line with its policies and corporate ethical understanding, strongly rejects bribery and corruption.

• Doğuş Otomotiv is committed to complying with the principle of conducting fair and transparent business in its relations with all its stakeholders.

• Doğuş Otomotiv’s managers and employees, as well as its business partners, in their relations with government institutions as with other stakeholder groups, are strictly forbidden to make any payments, give gifts, offer to make payment or give gifts, or to make commitments for similar purposes in order to gain an advantage that is contrary to laws and regulations, or to influence the decisions of individuals or institutions.

• As a representative of Doğuş Otomotiv, donating, giving gifts or making commitments to a political party or a member of a political party or their affiliated institutions and organizations, is also against the Doğuş Otomotiv Code of Ethics.

• At Doğuş Otomotiv, offering, taking or giving bribes or kickbacks that constitute a legal crime is strictly prohibited. All managers and employees who encounter such an offer are obliged to immediately report the situation to the Ethics Line. It is also strictly prohibited to request personal loans from customers, suppliers, Doğuş Otomotiv competitors and other third parties, or to request special privileges or discounts other than those offered to everyone. Doğuş Otomotiv employees are not imposed with a disciplinary penalty for refusing to take bribe or for whistleblowing against a corruption incident, in any way.

• Doğuş Otomotiv Anti-Bribery and Anti-Corruption Policy and the commitments within the scope of this policy include employees, managers, senior management, suppliers and business partners, Authorized Dealers and Services and their employees as well as all third parties within the entire Doğuş Otomotiv value chain.

• Doğuş Otomotiv Board of Directors is responsible for the implementation of anti-bribery and anti-corruption policy within the entire Doğuş Otomotiv value chain.

Doğuş Otomotiv acts in compliance with OEM policies in determining Authorized Dealers and Service Centers and in terms of paying their compensations. Doğuş Otomotiv makes payments to Authorized Dealers and Services only in accordance with these standards and in return for legal services.

Prevention of Laundering Proceeds of Crime and Financing Terrorism Policy

Doğuş Otomotiv’s policy for the prevention of laundering proceeds of crime and financing of terrorism is based on; international initiatives, conventions and regulations to which our country is a party of, internationally accepted approaches, methods and practices on this subject, current legislation concerning this matter, and its belief and determination to protect the reputation and trust of the Company brand.

All operations we carry out as Doğuş Otomotiv, our international business activities (import-export, etc.) must reflect the value of the services provided in real terms, be directed to the right and appropriate purposes, should be carried out with legal service providers and third parties, and comply with the laws and regulations of the Republic of Turkey as well as the countries where we do business.

Regarding the Prevention of Laundering Proceeds of Crime and the Financing of Terrorism, our company acts in accordance with the Law No.5549 of the TR Ministry of Treasury and Finance and the regulation dated 9/1/2008 and numbered 5337; this applies to all Doğuş Otomotiv employees and representatives, as well as all its shareholders, agents and business partners acting on behalf of Doğuş Otomotiv.

Doğuş Otomotiv’s managers and employees at all levels fulfill all their duties and responsibilities accurately and carefully, by acting in accordance with the purpose of this policy and effectively, in order not to expose the company to the risks related to laundering proceeds of crime and financing of terrorism. As a Doğuş Otomotiv employee, you should not make a payment that you suspect will be directed to a different person, institution or organization to third parties located in and/or outside of these regions. You should not use an intermediary for any payment that Doğuş Otomotiv cannot directly make itself. If you have to do business with any intermediaries, you must ensure that this payment is not used to make improper payments to government officials or representatives.

You may contact the Compliance Function to evaluate compliance with company policies and procedures, laws and regulations in doing business with authorities outside the Republic of Turkey or other institutions and organizations.