It is the policy of Guler & Dinamik Customs Consultancy Inc. to conduct all of its business in an honest and ethical manner. In doing business, neither Guler & Dinamik nor any person or entity associated with Guler & Dinamik, shall offer, pay, promise, authorize or receive any bribe, kickback or other illicit payment or benefit in violation of the relevant Turkish legislation.
This Policy supplements Guler & Dinamik’s Code of Ethics and Business Conduct, which remains fully effective.
- Guler & Dinamik’s Corporate Ethics Officer shall be responsible for administering and interpreting this Policy under the oversight of the Executive Board. The Corporate Ethics Officer and his or her designees shall give directions and maintain procedures to implement this Policy as necessary.
- It is the policy of the Company that all Guler & Dinamik Personnel and Third Parties are to comply with the all applicable law. Guler & Dinamik Personnel and Third Parties shall not corruptly offer, pay, promise or authorize any bribe, kickback, or illicit payment or benefit in money or in any kind, to any government or commercial customer, employee, investor, client, broker, agent, contractor, dealer or any other person or entity. No Company personnel shall receive any bribe, kickback, or illicit payment or benefit of any kind, from any customer, supplier or any other person or entity that has any business relationship with Guler & Dinamik.
- It is the Company’s policy to do business only with reputable, honest and qualified Third Parties. The Company shall have appropriate procedures for conducting due diligence on any Third Party who may have any contact with a Government Official or Other Covered Party in its relationship with Guler & Dinamik.
- It is the Company’s policy to do business only with reputable and honest partners and to maintain appropriate procedures for conducting due diligence on any joint venture partner with whom the Company anticipates doing business.
- Gifts, hospitality and entertainment shall not be given, directly or indirectly, to Government Officials or Other Covered Parties to improperly influence or reward an official act or decision or as an actual or intended quid pro quo for any benefit to the Company.
- Gifts, hospitality and entertainment promised, offered or provided on behalf of the Company or any affiliate to a Government Official or Other Covered Party must be reasonable, in accordance with customary courtesies, related to a legitimate business purpose and lawful under applicable laws.
- No payment or promise of payment for gifts, hospitality, or entertainment to any Government Official or Other Covered Party may be made by or on behalf of Guler & Dinamik or any affiliate on the basis that it is permitted as provided above unless such payment or promise has been approved in accordance with the procedures set forth by the Corporate Ethics Officer.
- Except to the extent explicitly prohibited by applicable law, Guler & Dinamik Personnel are required to report violations of this Policy and other applicable anti-corruption laws, by Guler & Dinamik Personnel or any Third Party. Personnel will not be subjected to retribution for good faith reports of suspected violations. Any violation may be reported to a representative of the Executive Board or the Corporate Ethics Officer.
