At CENTRIPLUS, we are always driven by the “True North” values – our unwavering commitment to always do the right thing for our clients, our people, and our communities. We are committed towards social impact and strive for sustainability across every function, including sourcing and procurement.

Through this procurement policy, we intend to make our operations more sustainable by:

• Upholding the laws and regulations of the respective countries we operate in
• Endorsing highest standards of economic, social, ethical and environmental practices
• Identifying and moderating risks associated with our procurement process
• Communicating the policy with stakeholders (internal and external) and raising
• awareness among our suppliers

In accordance with our commitment to the highest standards, we also expect our suppliers to

aspire to the same standards in their business operations, including but not limited to:

Environment:

• Comply and adhere to all the applicable environmental laws in respective countries/jurisdiction
• Undertake initiatives to promote greater environmental responsibility such as:

‒ Responsible waste management and disposal

‒ Reduction of greenhouse gas and other emissions harmful to the environment

‒ Conservation of non-renewable natural resources

Business Ethics:

• Obey all relevant international and domestic laws regarding ethical business practices
• Demonstrate existence of procedures to prevent:

‒ Money laundering

‒ Fraud, bribery, corruption

‒ Conflicts of interest

‒ Data security issues

Labor and Human Rights:

• Comply with all applicable laws, in accordance with the principles of the International Labor Organization, the UN Global Compact and the UN Universal Declaration of Human Rights
• Prohibit slavery and the use of forced, bonded, or child labor across the supply chain
• Prohibit unlawful discrimination and harassment to provide a safe and inclusive work environment

Community Development:

• Provide employees with a living wage, at a minimum
• Partner with the local governments and communities to improve the education, cultural, economic, and social well-being of communities which they operate in
• We understand that procurement performance improvement is a continuous process and recognize the contribution of our suppliers in our journey to become more sustainable.

Detailed guidelines on supplier sustainability are referred to our Supplier Code of Conduct.

• INTRODUCTION

CENTRIPLUS applies sustainable procurement principles in material and service procurement needed to maintain production based on professional and qualified procurement policy and high ethical standards and prioritizes social, economic and environmental issues.  

We set long-term goals in our strategies for Supply Chain and adopt an approach that develops solutions for sustainability challenges and leads to develop solutions. We act being aware that all these approaches guarantee continuity and longevity of our success. We comply with Universal Legal Rules and global ethical values. 

CENTRIPLUS conducts all operations honestly by showing respect to human rights and protecting interests of its employees during and after supplier selection process and throughout the all assessment stages and expects all of its Suppliers to adopt and comply with these principles.

• PRINCIPLES

2-1 COMPLIANCE WITH THE LAW

All Suppliers must comply with the effective laws and regulations. These suppliers are expected to comply with applicable industrial standards, international conventions and internationally accepted industrial standards and agreements related to their own activities.

2-2 COMPETITION

CENTRIPLUS avoids from any kind of behavior damaging free and fair competition and complies with legal and ethical competition rules. It supports and encourages incentives for a fair and competitive structure in the business life.

Suppliers will avoid from any activity, negotiation or violation directly or indirectly hindering fair competition environment and abusing the trust between institutions and persons.

2-3 BRIBERY

We comply with all anti-bribery and anti-corruption legislations and other relevant international standards applicable in all countries we operate in. 

Suppliers cannot act inappropriately to make business or generate financial income, such as accepting or giving bribe. Any employee of the Supplier cannot offer, give or accept any gift or money that may be perceived as bribe.

2-4 MONEY LAUNDERING

Suppliers are not allowed to involve in any activity aiming for money laundering. In addition, they cannot obtain income from any criminal or illegal activity or help any person or organization trying to control the funds invested in favor of a terrorist organization.

2-5 CONFLICT OF INTERESTS

Suppliers must notify any kind of conflict of interest arising from their professional relationship with CENTRIPLUS and enable us to determine and take appropriate action on this matter. Representatives or employees of CENTRIPLUS are responsible for disclosing important property relationships or interests they have in company of any supplier.

2-6 PRODUCT SECURITY

Suppliers are expected to provide goods and services meeting the standards accepted and required legally including those that are related to information on consumer health and safety.

2-7 CONFIDENTIALITY

Provided that all obligations and requirements in the Law on Protection of Personal Data numbered 6698 and relevant regulations are followed;

It is essential that all commercial and personal information of CENTRIPLUS, its employees, customers and suppliers are kept confidential and private life and personal spaces are respected and kept private.

Any kind of information including but not limited to technical, operational or financial information that are not publicly available or made publicly available by CENTRIPLUS are considered confidential.

CENTRIPLUS may access proprietary and confidential information of its Suppliers. This proprietary and confidential information may only be used for professional purposes in required by our business and duty in accordance with the law and regulation and shared with persons authorized in relevant fields.

2-8 EMPLOYEES

Religion, world view and political assessments should be absolutely separated from the working environment and duties and responsibilities fulfilled. Supplier undertakes to create working environments where human rights are respected. They must treat everyone equally and fairly without discriminating any person. Equal opportunities must be obtained for employment and development regardless of language, race, color, nationality, sex, age, sexual orientation, physical disability or other matters that are under protection of the law.

Suppliers hire its employees only based on their competence or skills and show effort to improve them. Suppliers cannot employ children in contravention of the applicable labor regulations and shows no tolerance to human trafficking, forced labor and involuntary servitude. Suppliers take necessary measures for health, security and safety of their employees. No tolerance is shown towards breach of immunity of any employee of the Supplier in any way through physical, sexual, psychological and/or emotional harassment in the workplace or anywhere they go for work.  

Suppliers show respect to right of their employees to establish trade units or become union members, organize in accordance with the law and right to bargain collectively.

2-9 OCCUPATIONAL HEALTH and SAFETY

We expect our suppliers to adopt relevant management practices within institutions of our suppliers in terms of compliance with the relevant health and safety regulations and standards adopted in the sector. Within this frame, our suppliers are encouraged to provide their employees with trainings on occupational health and safety. We recommend our suppliers to analyze and minimize risk exposure and take actions required to prevent possible accidents and injuries.

2-10 ENVIRONMENT

CENTRIPLUS is aware of its social responsibility to protect the environment and expects its Suppliers to undertake continuous improvement and environmental protection in order to enhance the environmental performance in accordance with the relevant national and international legislations and regulations and in line with sustainable development and circular economy principles.

As a part of this commitment, all suppliers of CENTRIPLUS must ensure that;

• Natural resources are used efficiently in all processes,
  
• Their processes are managed in line with circular economy approach,
• Environmental effects and risks are prevented without happening in all processes throughout the life cycle,
• Greenhouse effect and energy efficiency are considered in their investments and machinery-equipment preferences,
• Waste and wastewater formation, greenhouse emission, chemical use and all other environmental effects in products, production, transportation, storage and all other operations are reduced by using reuse, recycling or substitution,
• Wastes are sorted according to types and collected separately and recycled in accordance with the relevant legislations,

• Obligations of compliance of environmental legislations are fulfilled in all activities,
• Environment consent, license and all documents are kept up-to-date and compliance with legislations are followed up while activities are carried out,
• Chemicals threatening the environment are determined and appropriately managed for secure handling, labeling, transportation, storage, use, reuse, recycling and disposal, 

• All applicable laws and regulations on prohibition or restriction of harmful chemicals that can be used in constituent materials, parts and components including labeling containing information about recycling and disposal are considered.

1. IMPLEMENTATION

We accept that our suppliers are subject to different classifications in terms of activity scale, provided products/services, raw materials used, organizational structures and fields of activity. In consideration of these variables, we have prepared this Code to include all suppliers; yet, level and type of implementation will vary depending on supplier quality and standards concerning the supplier. We expect our Suppliers to develop their internal policies, systems and procedures and take other necessary actions for compliance with Sustainable Procurement Policy. Suppliers are expected to share the goals set and measures taken for each of matters mentioned in this Code with us. We undertake to work with our suppliers to determine the issues of breach and help them be solved in case of contrariness to this Code. All employees, representatives, advisors, suppliers and subcontractors are responsible for implementing this code according to Sustainable Procurement Policy.

CENTRIPLUS Inc.; undertakes to comply with the laws and regulations in force regarding environment, occupational health and safety, continuous improvement, and prevention of pollution during the realization of production, services, and activities.

CENTRIPLUS Inc.  purposes;

• To ensure continuous improvement of Environmental, Occupational Health and Safety performance by acting in accordance with the legal legislation and other binding regulations on Environment, Occupational Health and Safety.

 

• Environmental effects, occupational health and safety risks to determine and take necessary measures.

 

• To determine the environmental effects, occupational health and safety risks and to take the necessary measures while performing their activities.
• Minimizing the pollution of air, water and soil by keeping wastes under control,
• To realize the necessary announcement, training and awareness-raising activities in order to ensure that environmental, occupational health and safety awareness is kept alive by all employees.
• During all services offered; to protect employees and people affected by their activities from work-related injuries and illnesses.
• In the activities carried out, controlling the danger at the beginning, continuously monitoring it, making the necessary arrangements, and providing all kinds of protection.
• To announce the environmental effects of the services provided to the public and to share information.

1. Purpose

The purpose of Anti-Bribery and Anti-Corruption Policy (the Policy) is to enumerate the Anti-Bribery and Anti-Corruption Principles of CENTRIPLUS Group (CENTRIPLUS) and to ensure its compliance by all CENTRIPLUS employees.

2. Scope

Anti-bribery and anti-corruption policy covers:

• All CENTRIPLUS employees including the Board of Directors,
• Companies from which we outsource goods and services and their employees, people and agencies working on behalf of CENTRIPLUS including CENTRIPLUS Distributors & Agents, Consultants, Lawyers, External Auditors 

3. Definitions

Corruption is the misuse of the very powerful authority of a position to gain undue or unfair advantages directly or indirectly. (Which includes bribery, fraud, misprision, etc…)

Bribery is an individual’s gaining advantage or providing advantages to others by undue or unfair means in the context of an agreement reached with a third person.

Such individuals act in breach of the requirements of his/her duty by doing or not doing a work, speeding up or slowing down the said work etc.

Bribery and corruption may occur in various ways, among these:

• Cash payments,
• Political or other donations,
• Commission,
• Social benefits,
• Gift, hosting,
• Any Other benefits

which should not be due to the individual/s in the normal course, can be mentioned.

4. Duties and Responsibilities

Implementation and updating of the Anti-Bribery and Anti-Corruption Policy are the responsibility and duty of the Board of Directors. In this context, the following are required:

• The Board of Directors must establish an ethical, reliable, legal and controlled working environment,
• Senior management is required to evaluate risks and establish the necessary control mechanisms in compliance with the principles stipulated of Board of Directors,
• The Board of Directors must periodically evaluate whether operations are carried out safely and in compliance with legal regulations. They must also ensure that CENTRIPLUS employees work within their areas of responsibilities. The activities of CENTRIPLUS employees must be monitored by systematic and diverse reporting conducted by Internal Audit and Risk Department, Financial Affairs Department and/or Legal Department.
• There should be stipulated report, review and sanction mechanisms for noncompliance of policies, rules and regulations. The Board of Directors or their appointed authority should take necessary action and report the same.

Moreover, all CENTRIPLUS employees are responsible for;

• ensuring compliance with established Anti-Bribery and Anti-Corruption Policy as established by the Board of Directors.
• effectively managing the risks associated with their business operations.
• working in a manner consistent with the relevant legal regulations and the applications of CENTRIPLUS
• informing the Board of Directors or their appointed authority. If they encounter a conduct, activity or application which are in breach of the Anti-Bribery and Anti-Corruption Policy 

5. The Companies from/to Which Good and Services are Bought and Sold and Business Partners

The companies from which goods and services are bought and to whom goods and services are sold and Business Partners must comply with the Anti-Bribery and Anti-Corruption Policy of CENTRIPLUS and other relevant regulations. Relations with persons and institutions failing to comply with these conditions shall be terminated.

5.1 Selection of Companies and Business Partners

In addition to criteria such as experience, financial performance and technical sufficiency, Senior Management considers morality and a positive background in their respective field of operation during the selection of the companies from whom goods and services are bought sold and any other Business Partners. 

There should be no collaboration with the companies and the Business Partners who have negative report regarding bribery or corruption, even if they meet other requirements. Responsibility for making necessary research and evaluation within this scope primarily belongs to senior management. Internal Quality Audit and Risk Department should evaluate in its controls regarding the compliance of these aspects.

5.2 Reaching Agreement with Companies and Business Partners

In contracts and agreements to be made with companies and business partners who have no negative reports, remarks and meet other criteria, the following conditions are included:

• Ensuring full compliance with the principles indicated in the policy and other relevant regulations,
• Employees of companies and business partners must internalize these principles and act accordingly,
• Ensuring that employees of companies and business partners receive trainings about the Policy and any changes on periodic basis.
• Reminding the companies and business partners’ employees regularly about notification obligations and encouraging them to notify in case they encounter such situations.

Provisions stating that relations will be terminated in case these criteria are not complied with or in case a situation against the Policy occurs, need to be added in the contracts.

6. Our Policies and Procedures

6.1 Bribery and Corruption

CENTRIPLUS is against all kinds of bribery and corruption. Accepting of bribes or bribing can never be condoned under any circumstances.

Business relationships with 3rd persons wishing to get business from CENTRIPLUS through bribery or corruption must immediately be terminated.

6.2 Gift

A gift is a product generally given by customers or persons with whom a business relationship is established as a means of thanking, or it is a commercial courtesy and which does not require a financial payment. The said gift’s monetary value should be modest/token amount. 

All kinds of gifts offered or given to third persons by CENTRIPLUS must be offered in public, with good faith and unconditionally.

The same principles apply for accepting a gift and gifts that cannot be regarded as commercial courtesy or expression of thankfulness must not be certainly accepted. In addition, even within this scope, gift acceptance must not become frequent, and the Human Resource Department and Senior Management have to be informed about the gift by the employee who accept gift through his/her supervisor.

6.3 Facilitation Payments

The persons and institutions within the scope of this Policy must not offer facilitation payments to guarantee or speed up a routine transaction or process (obtaining authorization and license, obtaining a document, etc.) with Government and other regulatory agencies.

6.4 Donations

Some legal restrictions have been imposed on donations and aids according to the Capital Market Law and relevant legislation which CENTRIPLUS is subject to. The Donations made by CENTRIPLUS employees to the charity organizations with the amounts they collect apart from and independent of their works are out of the scope of CENTRIPLUS. However, the Anti-Bribery and Anti-Corruption Policy is also valid for this aspect.

7. Correct Recording

Issues which CENTRIPLUS must comply with in relation to accounting and recording system are executed and monitored within the relevant legal regulations. Accordingly;

• All kinds of accounts, invoices and documents belonging to relations with third parties (customers, suppliers, etc.) must be recorded and kept in a complete, accurate and reliable manner.
• Falsification and distortion must not be made on accounting or similar commercial records related to any transaction.

8. Training and Communication

Our Anti-Bribery and Anti-Corruption Policy has been announced to employees of CENTRIPLUS.

Trainings are important instruments for increasing awareness of employees. Within this scope, Human Resource Department designs training programs together with Internal Audit and Risk Department, Financial Affairs Department and/or Legal Department.  Attending such trainings is compulsory for all employees.

9. Notification of Policy Breaches

If opinion or suspicion exists that an employee or a person acting on behalf of CENTRIPLUS is acting in breach of this Policy, the issue must be submitted to the Board of Directors.

CENTRIPLUS encourages an honest and transparent approach; supports any employee or person acting on behalf of CENTRIPLUS who expresses his/her sincere concerns with good faith and keeps notifications secret. None of the employee shall be subject to pressure or punishment for his/her notification to the Board about a violation of the Policy. 

The companies and Business Partners from which goods and services are outsourced are also expected to remind their employees about the Ethics Line on a regular basis and they must encourage them to notify in case they encounter such situations. All notifications are kept confidential. Ethic codes and anti-bribery-corruption policies are disclosed in corporate websites of CENTRIPLUS Group Companies.

10. Policy Breaches

In cases which are or could be in breach of the Policy, necessary sanctions are implemented if inappropriate acts are detected.

In contracts made with the companies from which goods and services are bought and to whom goods and services are sold and with persons and institutions carrying out duties on behalf of CENTRIPLUS the provision must be included that if conducts, attitudes, or activities in breach of the Anti-Bribery and Anti-Corruption Policy are detected, business will be terminated. 

Furthermore, those who do not comply with the Anti-Bribery and Anti-Corruption Policy will be liable for possible criminal sanctions.