Our Ethical Values - Kodsan
Over 35 years of experience in manufacturing HVAC equipment

Our Ethical Values

1.1.Respect for Human Rights:

At Kodsan, guided by principles of honesty and trust, we aim to provide human and environment-centric products and services, to expand the business opportunities we develop, and to be among the top 5 companies in our industry worldwide. We demonstrate meticulous care in treating all our employees equally and fairly and expect the same attitude from all our stakeholders.

In recruitment, we seek qualifications suitable for the job without discriminating based on gender, language, religion, race, color, age, nationality, and thought.

We implement legal, fair, and competitive salary policies, rewarding success effectively and objectively.

We aim to increase our employees’ loyalty to the company by ensuring equal opportunities in appointments, promotions, rotations, and rewards.

We provide equal opportunities for our employees’ training, guidance, and development.

We create a working environment that fosters cooperation and solidarity, promotes transparency, and mutual respect.

.We have zero tolerance for any form of discrimination.

.We provide our employees with clean, healthy, and safe working conditions.

.We do not tolerate any form of violence or harassment.

.We have zero tolerance for child labor, slavery, human trafficking, and forced labor.

.We use company resources responsibly.

See. Working Conditions and Human Rights Policy

1.2.A Healthy and Safe Work Environment:

One of our main goals at Kodsan is to create a healthy and safe working environment for our employees and to ensure our Business Partners also establish such an environment. To this end, we take all necessary precautions and provide training on occupational health and safety to raise awareness in this area.

We conduct our activities in a healthy and safe manner without putting our employees, contractors, dealers, and the community at risk. We achieve this by working with competent people in their fields and prioritizing safety in our processes.

At Kodsan, human life is a priority, and no job is so important that it should be done without safety and health measures. Our employees comply with all legal regulations and our policies regarding Occupational Health and Safety, report unsafe working conditions, and immediately report any accidents, injuries, or unhealthy conditions. We do not come to work under the influence of drugs or alcohol.

See. Kodsan OHS Policy

1.3.Fighting Discrimination:

At Kodsan, we respect the diverse cultures, traditions, and business practices we encounter in our areas of operation. In this regard, we acknowledge and value the religious, structural, and cultural differences of the stakeholders we interact with. We treat everyone equally, regardless of religion, language, race, gender, age, or ethnic origin.

At Kodsan, we create a supportive, positive, and harmonious working environment, prevent conflict environments, and ensure people with different beliefs, thoughts, and views work together harmoniously. We respect the private lives and personal spaces of our employees at Kodsan.

1.4.Combating Workplace Violence:

We consider any situation where our employees are exploited, subjected to non-physical violence such as pressure and threats, or where their security and health are at risk, as an element of violence. We tolerate no behavior or action involving harassment, threats, and physical violence; and initiate the necessary legal process when faced with such a situation.

1.5.Preventing Conflicts of Interest:

As Kodsan employees, we take care to avoid any situation that could compromise our impartiality in decision-making related to our roles and responsibilities, benefit ourselves or our relatives, or create the impression of doing so, causing a conflict between our personal interests and our responsibilities towards Kodsan.

In case we find ourselves in a conflict of interest, we share the issue with our managers and the compliance department or responsible person to avoid harm to us and the company. To prevent potential conflicts of interest:

.We avoid using our titles or authority for personal gain or for the benefit of our relatives.

.We ensure that our personal investments outside of work do not prevent us from dedicating the necessary time and attention to our duties at Kodsan and do not create a conflict of interest.

.If we have a familial or close relationship with individuals in a primary decision-making position in commercial activities related to Kodsan, we inform our manager and the compliance department about the situation.

1.6.Protection and Proper Use of Company Assets:

We always protect records, machinery, equipment, fixed assets, and vehicles belonging to Kodsan; we prevent their misuse, damage, waste, and unauthorized lending, leasing, or selling. Additionally, we avoid personal use of communication and transportation facilities provided within the scope of the responsibilities and authority required by our positions.

1.7.Combating Corruption and Bribery:

As Kodsan employees, we do not accept, offer, or solicit bribes under any circumstances. We do not request personal privileges from subcontractors, suppliers, consultants, competitors, or customers.

All our employees are obliged to comply with local and relevant international regulations on combating bribery and corruption and the related Community policies, and we expect all our Business Partners to act in accordance with these regulations.

1.8.Gift Giving and Receiving:

Aware that gift-giving and receiving practices can vary according to local cultural values, we conduct the process of exchanging gifts in a manner that does not contradict Kodsan principles and policies, does not damage our reputation, and is not legally considered a crime, with honesty and transparency. We always refrain from accepting and giving gifts, grants, or hospitality that could influence commercial decisions in a positive or negative direction.

1.8.1.Application Principles:

Kodsan Employees;

can receive and/or give gifts within the framework defined in clause, provided they comply with the conditions specified in clause 1.8. Acceptable and Unacceptable Gifts: Kodsan employees can give and receive entertainment, hospitality, and meals that are within acceptable business standards.

. Awards, plaques, and similar symbolic gifts can be accepted as mementos of the day at seminars and similar events attended on behalf of Kodsan.

. Gifts or benefits that are directly or indirectly tied to a return cannot be accepted.

. Accepting bribes and/or commissions, offering them, or proposing them is under no circumstances acceptable.

. Kodsan employees cannot accept money without compensation or as a loan from subcontractors, suppliers, consultants, competitors, or customers, nor can they have travel expenses, event costs, and similar payments covered.

. Gifts and promotional materials to be given to customers, dealers, and other third parties in business relations with Kodsan are approved by Kodsan’s senior management.

1.9.Compliance with Competition Law:

At Kodsan, we act within the framework of legal regulations and company policies in all the countries where we operate, in a manner befitting our reputation. We do not engage in any practices that violate competition law principles.

Our fundamental principles under competition law:

.To comply with regulations related to competition law.

.To avoid, directly or indirectly, any agreement or behavior with competitors or other individuals or organizations that could restrict, distort, or eliminate competition beyond the limits permitted by legislation.

.To obtain information about competitors only through methods prescribed by legislation and jurisprudence, and to use it by citing sources in all relevant documents.

.To avoid actions that could be considered abusive in markets where we have a dominant position.

.To avoid any discussions and communications that could lead to or be characterized as the situations mentioned above in meetings, councils, chambers, professional associations, conferences, fairs, and other special or professional gatherings that bring competitors together.

.To handle issues that may violate competition law within Kodsan with the same care and diligence.

1.10.Export Control and Prevention of Money Laundering:

As Kodsan, in compliance with local and international regulations, we avoid any commercial transactions that could be perceived as laundering proceeds of crime. Therefore, before entering a business relationship with third parties, we conduct the necessary due diligence to understand the relevant party. As an internationally operating Company, we take necessary measures to ensure compliance with economic sanctions and export controls.

1.11.Protection of Insider Information:

We are aware that it is prohibited to use or share personal, commercial, financial, technical, legal, and/or other confidential information belonging to Kodsan, our employees, or our Business Partners for the benefit of ourselves or third parties. We take the necessary measures to protect confidential information we are privy to due to our roles and responsibilities.

1.12.Supply Chain Transparency:

In our procurement discussions, decisions, and contract processes, we act in accordance with the current laws and regulations; we expect the same fair and honest approach from our suppliers. We ensure that suppliers we collaborate with embrace principles that align with our values and understand our ethical expectations. We objectively evaluate all suppliers’ proposals based on performance, quality, and cost criteria without discrimination and may terminate the business relationship with collaborators who do not meet expectations, considering the contract terms.

1.13.Data Security and Privacy:

We are aware that using or sharing personal, commercial, financial, technical, legal, and/or similar confidential information belonging to Kodsan, our employees, or our Business Partners for the benefit of ourselves or third parties is prohibited. We take necessary precautions to protect the confidential information we are privy to due to our roles and responsibilities.

We use the information we obtain only for tasks we are obligated to perform as per our job descriptions. We comply with relevant legislation and contractual obligations when sharing trade secrets and other confidential information.

1.14.Use of Information Technologies:

Aware of the importance and necessity of protecting information integrity and accessibility, we store our company records in compliance with legal regulations and protect them against unauthorized access. We collect, process, store the majority of our records in electronic form, and transfer them over the network for use by other computers.

.We secure access to company records through personalized encryption,

.We use licensed products,

.We periodically update user passwords,

.We actively use and update antivirus programs,

.We keep our operating systems up to date.

1.15.Social Media:

Recognizing the role and potential of social media in today’s interaction world, we refrain from making statements and expressing opinions on behalf of Kodsan on virtual platforms (such as Facebook, Twitter, blogs, etc.) without the knowledge/approval of senior management. We inform the senior management about any concerns or doubts regarding news we read or see about Kodsan.

2.Communication and Documentation:

2.1.External Communication:

Open communication and honesty towards our customers and business partners are crucial for successful collaboration. Therefore, we transparently convey our financial, social, and environmental results with integrity.

We treat Kodsan, our products, our colleagues, our customers, and our business partners with respect on social media channels.

2.2.Documentation and Records:

We ensure that information, data, and documents related to our documents are always complete and accurate. Especially, we take all necessary measures to ensure our business records meet the highest standards of accuracy and reliability and are always compliant with applicable regulations.

3.Environmental Sensitivity:

We responsibly manage the environmental impacts arising from all our activities. We are committed to identifying and implementing improvements and developments that will minimize the environmental effects of our operations at an appropriate level. Kodsan has an “ISO 14001 Environmental Management System”.

Kodsan aims for continuous improvement with an effective environmental management system by providing the necessary technical, financial, and human resources to achieve our environmental principles and objectives at every stage of raw material selection, production, and service activities.

We expect our employees to go beyond legal obligations and implement the best environmental solutions, assist in the development and spread of eco-friendly technologies, and support all initiatives that will increase environmental awareness.

4.Consequences of Violating Ethical Values and Policies:

All our employees are expected to adhere to our Ethical Values and laws. Violations of our Ethical Values or laws can lead to reputation damage for Kodsan and may result in various consequences depending on the nature of the violation.

Depending on the nature and severity of the violation, disciplinary actions can range up to termination of employment.

Legal violations can be subjected to legal and/or criminal proceedings by a government official or court.

5.Process Officer:

If you have any concerns or questions related to Ethical Values, you can seek support from your supervisor or the Human Resources Department. If the matter cannot be clarified by a supervisor or the Human Resources Department, the Ethics and Compliance Manager is always available. You can contact the Ethics and Compliance Manager at any time.

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