Ethics and Social Responsibility Policy

1- Purpose

HTS Metal established its Code of Ethics and Social Responsibility Policy in order to govern internal relations; to raise service quality by governing the relations of all employees and of the Company with shareholders, investors and other stakeholders; to use resources effectively; to prevent unfair competition; to govern relations with employees; and to increase effectiveness in having competition understood as the delivery of higher-quality service. The Company's activities are conducted within the framework of the ethical principles and rules prepared by the Board of Directors. These rules of ethics have also been published on the Company website.

2- Code of Ethics and Social Responsibility

The rules of ethics are the body of values that governs the Company's relations with its employees and with society, and that shapes the Company's internal culture of conduct, in order to raise the Company's service quality and standing. Within this framework the Company is mindful of its social responsibilities; it complies with regulations concerning the environment, consumers and public health, and with the rules of ethics. The Company supports and respects internationally recognised human rights. The Company combats corruption in all its forms, including extortion and bribery, and acts in all its activities in the interest of society and with respect for the environment. The Company does not engage in political conduct and makes no political donations. The Company does not make “facilitation payments” (payments made through a public official, a political party or a party employee in order to facilitate or secure the performance of routine government action).

3- Ethical Principles and Rules Concerning Legislation and Legal Regulations

The Company ensures the highest level of compliance with all national and international rules — legislation above all — and with internal regulations.
In its relations with investors and shareholders, the Company acts without discrimination and in accordance with all applicable laws, regulations and rules.
The Company ensures compliance with the company-law provisions of the Turkish Commercial Code and with its articles of association, and takes due care to make the updates required by all changing and renewed legislation.

The e-mail address etikkurul@htsmetal.com, published on the Company's website, has been set up so that stakeholders can report the Company's unlawful or ethically inappropriate transactions to the ethics committee established to apply this policy. The Company adopts and makes clear to its employees that no employee will be demoted in seniority or title, fined, or subjected to other retaliation on account of such reports, including reporting a breach of a policy or raising concerns.

4- Ethical Principles and Rules Concerning Corporate Governance Principles

The Company's management protects the rights and interests of all stakeholders and shareholders, in line with the defined objectives, legal regulations and other relevant legislation, the articles of association, internal regulations and the company's rules of ethics.
Corporate values and strategic objectives are established by the Company.

Authorities and responsibilities within the Company are clearly defined and their application is ensured.

The Company's managers and the manager with administrative responsibility possess the qualities required to perform their duties effectively and are conscious of the role they have assumed in corporate governance.

Remuneration policies are kept consistent with the Company's ethical values, strategic objectives and internal balances.

All meetings with investors, financial analysts, members of the press and similar groups are held with the approval of the Company's authorised managers. Giving statements to press and broadcasting organisations, publishing articles in the press and appearing as a speaker at conferences may take place within the rules set out in the Company's internal regulations and with the approval of the General Manager.

In its relations with employees, shareholders and stakeholders, the Company acts on the principles of professionalism, courtesy and — above all — seriousness and reliability.

5- Scope of Application

The principles and rules within the scope of this policy shall apply to all employees and all managers of the Company, and to persons who are not Company employees but are authorised to act on behalf of, or to represent, the Company.

6- Entry into Force

This “Code of Ethics and Social Responsibility Policy” has been in force since 06/07/2018.