The Code of Ethics includes the principles that the employees of our company must comply with while
performing their duties and the codes of conduct regarding the working order. The purpose of this
regulation is; To outline the basic rules to be followed and to prevent any disputes and conflicts of
interest that may arise between employees, business partners, customers and ourcompany. Our Code of
Ethics explains universally accepted practice, our commitment to comply with laws and regulations. It
forms our expectations and standards that form the basis of our business relationships and transactions.
All employees; must act on the basis of these general principles in their relations with customers,
suppliers, shareholders and other stakeholders. All employees, including Board of Directors and
managers, must comply with the Code of Ethical Conduct.

Managers and employees; they must behave to keep the reputation of our Company and its shareholders
at the highest level by observing the basic principles contained in this document in all of their
relationships and affairs. Our employees should act on the basis of care and loyalty in situations and
conditions not covered by these rules.

Briefly in this section:
3.1. Company: Döktaş Dökümcülük Ticaret ve Sanayi A.Ş.
3.2. Company Senior Management: Chairman of the Board of Directors and Chief Technology Officer
3.3. Company Ethics Committee: The committee formed with the participation of Chief Technology
Officer, Directors and Human Resources Managers,
3.4. Employee: Company personnel
3.5. Service provider: Refers to the personnel of the company (supplier, subcontractor, etc.) from which
the company receives and / or provides services.

4.1. Company Board of Directors:
Ethical Principles and Rules of Conduct were approved by the Board of Directors and put into effect.
The Board of Directors is responsible for determining the notification, review and enforcement
mechanisms in case of non-compliance with the regulations, and its supervisory oversight.

4.2. Company Senior Management:
The company is responsible for the final approval and implementation of the decisions made by the
Ethics Committee.
4.3. Company Ethics Committee:
Ethical Principle Responsible for the execution and implementation of the Code of Conduct.
4.3. Human Resources and Industrial Relations Directorate
Human Resources Management is responsible for the preparation, development and updating of this
policy. The Department evaluates this policy in terms of up-to-dateness and development needs when
necessary, and makes recommendations to the Senior Management by obtaining the opinions of the
Company Ethics Committee.
4.4. Employees:
– They are responsible for working in accordance with the current legislation.
– Adhering to and complying with company policies, regulations and procedures,

• The company respects all legal regulations, labor laws and the rights of its employees to organize and
join a trade union within the scope of the Constitution.
• The company does not allow any discrimination among its employees based on religion, language,
race, ethnic origin, nationality, gender or age. It provides equal opportunities to employees under equal
• Provides a healthy and safe working environment for its employees.
• The company acts on the principle of equal pay for equal work, in accordance with the value and
management principles. Applies objective measures in recruitment. In promotions and similar decisions,
efficiency, competence and performance of the person are taken as basis.
• Strives for the individual development of its employees, and presents a systematic career plan in line
with their competencies and performances and within the scope of the company organization structure.
• Supports its employees with a wage and reward policy in line with productivity principles.
• Approaches its employees fairly, honestly and objectively.
• Respect for individual integrity is essential in the company. Employees are independent as long as
their private and family lives and lifestyles do not adversely affect the spiritual personality of the
Company. It does not share the private information of its employees with anyone except legal
• Employees act with the utmost care for company expenditures and with awareness of savings and
costs. Employees also make the utmost effort to protect company assets.

• It does not allow harassment and mobbing in the workplace in any way.
It does not employ a child labour or a young worker (worker under 18) and do not allow
anyone to do so also it expects its suppliers and business partners to act accordingly.

6.1. Shareholder Relations
• Protects the rights and interests of shareholders within the framework of laws.
• Announces to its shareholders and the public the matters that need to be disclosed about the company
in a timely, complete and complete manner.
• Always uses the support of shareholders to add value to the company.
• By targeting sustainable growth and profitability, in line with the understanding of adding value to its
shareholders, it aims to use company resources effectively and efficiently without sacrificing honesty.
6.2. Supplier and Dealer Relations
• It aims to create value in its relations with suppliers and dealers.
• Decides based on objective criteria in the selection of suppliers and dealers.
• Communicates openly and directly with suppliers and dealers, and complies with the privacy and
occupational safety rules they demand.
 It expects its suppliers to obey the effectual rules coverd in its ethical regulations.
6.3. Relations with Competitors
• Except for the limits permitted by the legislation, the company does not enter into agreements and
concerted behaviors with competitors or other persons or organizations that have the purpose of
preventing, distorting or restricting competition, directly or indirectly, or that cause or may cause this
• It competes only within the legal framework, does not negotiate with competitors to determine market
conditions, does not exchange information.
• Competitive products cannot be denigrated and misleading advertisements aren’t allowed.
6.4. Customer relationship
• It meets the demands and requirements of its customers at the highest level.
• Does not give misleading or incomplete information to its customers.
• Strives to maintain a long-term trust environment in relationships with customers.
• Directs all kinds of complaints of our customers regarding the products and services of the company to
the required places for a fast and accurate resolution.
• All kinds of serious and unusual complaints that may affect the reputation of the institution are
forwarded to the Chief Technology Officer through the relevant department management without delay.
6.5. Environment and Social Responsibility
• Fulfills all environmental legal requirements and environmental protection obligations in processes..

• It aims to increase awareness of environmental protection, to minimize the need for natural resources,
energy losses and waste by educating its employees and business partners.
• Shows sensitivity to issues related to society. It encourages both as a company and its employees to
participate in social responsibility projects that will contribute to society.
• It pays attention to be sensitive to consumer rights and public health issues and to comply with the
laws on this issue.

Employees abide by the law.
Employees perform their duties in an equitable, transparent, accountable and responsible manner.
Mutual respect, trust and understanding of cooperation are essential in relations between employees.
The employee does not go beyond the framework of human and moral values while performing his
Unless explicitly authorized, employees do not act, make a statement or correspondence that would
put the Company under commitment.
For whatever purpose, it does not gain unfair profit from individuals or organizations, take tribute or
give bribes.
It no way in gets into a conflict of interests, it never cheats and launders money.
It never acts in an intimidation policy by making offensive jokes, insulting people, making physical
assault or

Do not behave in a threathening that will break down the peace at work or disturb the employees.
Protects all kinds of information, documents and the systems in which they are kept, all material and
moral assets of the company against all kinds of damage and abuse.
Does not use time and company resources for personal gain.
Employees are sensitive to the Company's social responsibilities. It complies with the regulations
regarding the environment, consumers and public health.

8.1. Intellectual Property Rights
• Company employees know that the company owns all kinds of intellectual and industrial rights they
arise while performing their duties, and act accordingly. The intellectual and industrial rights owned by
the company cannot be shared with third parties and institutions in any way.
• The employee has to show the necessary attention and care to the use of copyrights.
• Employees refrain from knowingly and illegally using patents, copyrights, trademarks, trade secrets,
computer programs or other intellectual and industrial property rights of other companies.

8.2. Knowledge Management
• All legal records must be kept appropriately.
• Employees do not share confidential information with third parties without the approval of senior
• Maximum effort is shown for the accuracy of the reports prepared for the company.
8.3. Asset Management
• Employees protect company assets and take every precaution to prevent them from being stolen or
• The responsibility of damages arising from personal fault must be taken by personnel during the use of
company assets that are embezzled by the employee.
8.4. Security and Crisis Management
Employees are obliged to protect their colleagues, factories and administrative facilities against possible
natural disasters and extraordinary circumstances. In such cases, business continuity is ensured and
emergency crisis management is supported.
8.5. Privacy
• The employee knows that the company's financial and commercial secrets, personnel information and
agreements with third parties are confidential and does not act contrary to this.
• The employee does not share the information and documents he / she has due to his / her work in the
company with unauthorized persons and authorities inside and outside the company for whatever
• The employee cannot disclose non-public information about the companies he worked for, or does not
request such information from the employees.
8.6. Avoiding Conflict of Interest
Company employees do not provide unfair advantage to themselves, their relatives, friends or third
persons or organizations with whom they have a relationship by using their duties improperly.
8.7. Not Dealing in Favor of Self or Relatives
• It is essential that employees with kinship relationships, including spouses and third degrees, in the
company facilities are not in a reporting relationship with each other in the same organization or are not
involved in decision-making mechanisms together.
• Managers and human resources officials, who are in a decision-making process during the recruitment
process, are in a relationship with a candidate who has applied for a job, including spouse and third
degree kinship, the relevant manager must take measures to eliminate the conflict of interest.
• In a company with which the company has a commercial relationship, if it is known that a first-degree
relative works or has a financial interest, the relevant situation must be notified to a higher manager.

• The employee does not allow his / her personal investments or efforts to prevent him / her from
performing his / her internal duty in any way.
• The person who works or will be employed in the company must immediately notify the human
resources management or manager of the events and relationships that will create conflict of interest in
the future. The same obligation applies to employees who have a shareholding or similar interest
relationship with another institution.
8.8. Receiving and Giving Gifts
• Company employees do not accept gifts, earnings, commissions, special discounts and discount offers
from the relevant authorities for their own benefit.
• Not in any material or moral interest that may be perceived as inappropriate with third parties, whether
in a commercial relationship or not.
• It does not accept gifts from institutions and organizations with which there is a business relationship,
except for gifts that are undoubtedly within a normal business flow and not exceeding 100 Euros.
However, a gift may be accepted provided that it is honest and goodwill.
• Employees may not give gifts to third parties and organizations that will affect their impartiality,
decisions and behavior. It cannot provide benefits.
8.9. Business with the Company by Leaving Employees
Entering into a commercial relationship with the Company by employees whose employment
relationship with the Company is terminated is only subject to the approval of the General Manager.
Adherence to ethical rules is important in such business relationships.
8.10. Insider Trading
Employees may not obtain or attempt to obtain a commercial benefit, including trading on stock
exchanges, by using confidential information of the company or transferring it to third parties, which is
a legally determined crime by law.

• Occupational health and safety is indispensable for the company.
• Employees act in accordance with the rules and instructions set for OHS. They take it as their duty to
contribute to improvements in a participatory manner in this regard.
• Employees do not carry out any substance that is dangerous or prohibited by law to be kept at work.
• Except for a doctor's report, drugs or substances that affect or reduce mental and physical
competencies cannot be used by employees in the workplace.
• The company does not provide any material or moral support to political party or political party
candidates for any purpose.

• Political activities cannot be carried out within the boundaries of the workplace or by using company
• Employees who detect a situation that is contrary to the law, law or legislation in their practices are
obliged to report this situation to their superior supervisor or Ethics Committee (etikkurul@doktas.com)
in writing.
• It should be ensured that this notification is never passed on to third parties.
• The reporting should be in the interests of the company, but not in the personal interest of the reporter.
• Confidentiality and objectivity must be maintained during the evaluation of the notification. It is
imperative that people who notify confidentiality and manage the relevant process pay utmost
importance and attention.
In case of violation of ethical rules;
• In cases of intent or gross fault violations, action is taken in accordance with the relevant articles of the
Labor Law. When necessary, the Management may initiate criminal and legal action.
• Verbal or written warning is given for violations caused by negligence or slight fault.

• Implementation of the Code of Ethics recorded with this document is under the responsibility of the
Company Ethics Committee.
• It can assign people to follow up the activities of the Ethics Committee and decide on various practices
if necessary.
• This Company Code of Ethics and Implementation Principles Regulation has been adopted by the
Board of Directors' decision dated 27.02.2018 and numbered 2018/5 and entered into force as of the
same date.