GOVERNANCE LEVEL
Suppliers commit to complying with the rules outlined by Borusan under each topic specified for this level, in the Borusan Group Sustainable Procurement Code of Conduct.
Combating Bribery and Corruption, Conflict of Interest, and Unfair Competition
Borusan suppliers pledge to uphold transparency and accountability in their operations, including implementing effective processes and procedures to proactively prevent unethical behavior such as bribery, corruption, conflicts of interest, facilitation payments, unfair competition, and abuse of office. Accordingly, all Borusan suppliers are obligated to disclose to the Borusan authority the rules pertaining to bribery, facilitation payments, corruption, conflicts of interest, and unfair competition within their organizations, considering these issues are addressed at the governance level.
Bribery refers to offering or receiving any gift, loan, fee, reward, or other advantage to or from any person as an inducement to take actions that are dishonest, illegal, or an abuse of trust while conducting the organization's businesses.
Facilitation Payments are payments made to government officials in an effort to expedite or facilitate routine and lawful transactions and services or to secure the processes.
Corruption may take various forms from petty influence-peddling to institutionalized bribery. It is defined as the abuse of entrusted power for personal gain, encompassing both financial and non-financial advantages.
Conflict of Interest arises when there is a conflict between the duties and demands of an individual representing an organization by virtue of their position and their personal or private business interests.
Unfair Competition encompasses deceptive or dishonest behaviors and business practices that impact relations between competitors or between suppliers and customers.
Moreover, the company is expected to conduct training on ethical issues across the organization to ensure all employees internalize the aforementioned principles and promote ethical business practices.
Ethics
Borusan requires its suppliers to maintain an effective governance, monitoring, and internal control system to ensure compliance with the applicable laws and Borusan Sustainable Procurement Policy, and to foster awareness of ethical business practices.
Integrity, transparency, and high business ethics are paramount in all Borusan activities, and Borusan expects all business partners to uphold these values. The Borusan Orange Guide and Borusan Sustainable Procurement Policy outline key aspects of Borusan's approach to ethical business practices. Our objective is for our supply chains to adopt these principles and integrate policies demonstrating compliance with these requirements into their operations. Suppliers are mandated to provide documented evidence of relevant ethical practices to Borusan representatives.
Companies are required have governance, monitoring, and internal control mechanisms in place to ensure adherence to ethical principles within the framework of applicable laws across their organizations and supply chains. As such, Borusan suppliers must have a Code of Conduct/ a set of working principles or an Ethics policy that outlines the ethical, responsible, and honest conduct expected in business dealings, which all company employees and representatives are obligated to follow in their activities.
As per the United Nations Guiding Principles on Business and Human Rights, companies have a responsibility to respect human rights and are expected to offer remedies if their operations lead to or contribute to negative human rights consequences. To facilitate solutions and process enhancements, grievance mechanisms are recommended as effective avenues for individuals potentially affected by business activities to voice their concerns. In this context, Borusan suppliers are required to establish grievance mechanisms allowing affected stakeholders and rights holders to submit complaints and requests for resolution directly to the business.
Moreover, it is expected that suppliers conduct comprehensive training on ethical considerations throughout their organizations to ensure that ethical principles, policies, and codes of conduct are internalized by all employees and ethical business practices are disseminated across the company. Accordingly, Borusan suppliers must have a Code of Conduct/ a set of working principles or an Ethics policy that outlines the ethical, responsible, and honest conduct expected in business dealings, which all company employees and representatives are obligated to follow in their activities.
As per the United Nations Guiding Principles on Business and Human Rights, companies have a responsibility to respect human rights and are expected to offer remedies if their operations lead to or contribute to negative human rights consequences. To facilitate solutions and process enhancements, grievance mechanisms are recommended as effective avenues for individuals potentially affected by business activities to voice their concerns. In this context, Borusan suppliers are required to establish grievance mechanisms allowing affected stakeholders and rights holders to submit complaints and requests for resolution directly to the business.
Moreover, suppliers are expected to conduct training on ethical issues across the organization to ensure all employees internalize the ethical principles, policies and code of conduct and promote ethical business practices.
Legal Compliance
The entire Borusan ecosystem, operating both in Türkiye and abroad, is obligated to adhere to the laws and international legal regulations of the countries where they conduct operations, as well as the legislation, regulations, and other official mandates pertinent to their business activities. This includes compliance with Personal Data Protection Law No. 6698, relevant secondary legislation, and regulations concerning personal data protection in accordance with decisions made by the Personal Data Protection Board. Additionally, adherence to competition law regulations outlined in Law No. 4054 on the Protection of Competition, relevant secondary legislation, and decisions by the Competition Board is imperative. Borusan's suppliers are accountable for full compliance with all corporate initiatives, policies, procedures, and plans pertaining to their work, with particular emphasis on the Borusan Sustainable Procurement Policy.
Data Security and Privacy
Borusan suppliers are mandated to conduct the processing and storage of all data shared with them by Borusan in accordance with the law, and implement all necessary security measures and adhere to the principles, tenets, and procedures stipulated by the prevailing data privacy legislation. Suppliers are prohibited from utilizing Borusan's data and confidential information for their own benefit or for the benefit of other individuals or organizations.
Information stands as one of the most critical asset categories. To ensure the protection of information assets in alignment with their significance, value, and sensitivity, the suppliers are tasked with processing data in a lawful and responsible manner, respecting individuals' privacy, and ensuring that data is adequately protected and utilized solely for legitimate purposes.
Borusan obligates its suppliers to establish the requisite control mechanisms within their own organizations to prevent unethical behaviors referred to under the governance level, pertaining to the sub-topics of Combating Bribery and Corruption, Conflict of Interest and Unfair Competition, Ethics, and Legal Compliance as well as Data Security and Privacy. Additionally, suppliers are required to promptly report any suspected or actual violations to Borusan. In the event of a breach, suppliers are required to communicate the pertinent action plans to Borusan officials for prompt resolution.