KARMETAL SAVUNMA MÜHİMMAT SİLAH TEKNOLOJİLERİ SAN. VE DIŞ. TİC. A.Ş. This Code sets forth the ethical rules that all 3 employees, including top management, should regulate their relations with employees, customers, business partners, competitCompany and other stakeholders while conducting the business of Company.

 

1.0Observance of Laws and Social Norms

 

is committed to carrying out all its activities in Türkiye in full compliance with the applicable legal regulations. In addition, the company respects the social needs, expectations, and local values of the regions in which it operates and expects the same sensitivity from its suppliers. Accordingly, the Code of Ethics is incorporated into all purchasing agreements.

2.0Respect for Employees and Human Rights

 

is an organization that supports the Universal Declaration of Human Rights and adopts respect for human rights as a fundamental principle. The company prioritizes providing a healthy, clean, and safe working environment for all employees, respects their rights, and protects these rights.

 

2.1Freedom of Association and Collective Bargaining:

Recognizes that the right to organize and engage in collective bargaining, as guaranteed by national legislation, is a fundamental right of all employees.

2.2Ethical Recruitment and Non-Discrimination:

 

Does not tolerate any form of discrimination in the recruitment or employment process on the basis of religion, language, skin color, race, gender, ethnic origin, age, political opinion, nationality, or physical disability. All recruitment and promotion processes are based solely on professional competence and individual qualifications.

2.2.1Gender Discrimination:

As part of its corporate identity, adopts the principle of “anti-discrimination” throughout all human resources processes starting from recruitment, and aims to promote gender equality both within the company and in society.

Within this scope,

• Provides equal opportunities in recruitment regardless of gender,

• Adheres to the principle of equality in promotion processes,

• Ensures equality in remuneration and benefits,

• Implements equal practices regarding social rights and all other tangible/intangible opportunities,

• Takes preventive measures against any form of discrimination such as sexual harassment, mobbing, or unfair dismissal.

 

The company attaches utmost importance to complying with all legal regulations related to human rights and to upholding its employees’ ethical values, and it prioritizes policies and projects that support equal participation in all areas of life regardless of gender.

1.1Prohibition of Forced Labor:

 

Does not accept forced or involuntary labor under any circumstances. The company strictly prohibits employing individuals against their free will, including through disciplinary practices involving physical violence, threats, or mistreatment.

 

 

1. Prohibition of Child Labor:                                           
   Child labor is strictly prohibited at KARMETAL A.Ş. The company complies with all legal regulations regarding the minimum employment age, employs only individuals who have reached the legal working age, and does not tolerate any form of child labor. Protecting the dignity and rights of children is regarded as a fundamental principle.

  

1.3Prohibition of Human Trafficking:

 

Opposes all forms of human trafficking and smuggling. The company undertakes not to employ any illegal workers and not to be involved, directly or indirectly, in such activities.

 

1.4Wages and Overtime Payments:

 

Determines employee wages and social benefits in line with legal minimum requirements and industry practices. Overtime work is compensated at the rates prescribed by applicable laws and regulations.

1.5Legal Working Periods:

 

Working hours at are arranged in compliance with national legislation. Employees are never forced to work overtime and cannot be compelled to work on weekly rest days or official/public holidays.

 

1.6Occupational Safety and Health Protection:

 

Takes all necessary measures to provide a safe and healthy working environment in line with national standards and supports the development of an occupational health and safety culture.

1.7Prevention of Psychological Harassment:

 

Does not tolerate psychological pressure, mobbing, or harassment that undermines human dignity.

 

1.8Protection of Personal Data:

 

Takes all necessary technical and administrative measures to protect the personal data of its employees in accordance with the principles of “Privacy of Private Life” and “Protection of Fundamental Rights and Freedoms” guaranteed by the Constitution, as well as the provisions of the “Personal Data Protection Law.”

3.0Environmental Protection

 

Since its establishment, has considered the protection of human health, the environment, and all natural resources as one of its core values. The company promotes sustainable development with a sense of social responsibility and is committed to continuous improvement in creating safe and healthy working conditions and in protecting the environmen

3.0Air and soil quality:

 

Fully complies with all applicable legal regulations and local authority requirements regarding the protection of air and soil quality in all its activities.

3.1Combating Climate Change:

 

İs committed to combating climate change by improving energy efficiency and promoting the use of renewable energy sources. The company monitCompany its carbon emissions transparently and sets concrete targets to reduce them.

 

 

3.2Land, Forest, and Water Rights & Opposition to Forced Evictions:

 

İs committed to avoiding any actions that may violate human rights. During new investments or facility expansion processes, the company pays utmost attention to protecting land, forest, and water resources as well as the rights of surrounding communities.

The company avoids practices that could harm forest areas and water sources and takes necessary measures to protect the living spaces of local communities in these regions. Furthermore, does not engage in any activities such as land acquisition or expropriation that could lead to the forced displacement of local communities and aims to act in cooperation with local stakeholders by considering environmental and social impacts.

3.3Rights of Minorities and Indigenous Peoples

 

Regards the protection of different cultural, linguistic, and social identities as an integral part of human rights and accepts respect for the rights of minorities and local communities as a corporate responsibility.

3.4Diversity, Equity, and Inclusion
 

Adopts the promotion of fairness, representation, and equal opportunities for all individuals—regardless of their backgrounds, identities, or personal characteristics—as one of its core principles.

3.5Water Consumption and Quality:

 

Pays particular attention to the efficient use of water, especially in regions where water resources are limited, and is committed to implementing practices that enable the reuse of wastewater.

3.6Waste Management:

 

Takes all necessary measures to minimize the environmental impacts of the waste generated by its operations. The company prioritizes preventing waste, reuses materials where possible, promotes recycling, and resorts to disposal only as a last option. All these processes are carried out in strict compliance with the applicable legal regulations.

3.8. Restricted and Prohibited Chemical Substances:

 

Prohibits the use of mercury and mercury compounds in its production processes and the treatment of mercury waste in line with the Minamata Convention. The company also complies with the restrictions on certain chemicals listed in the Stockholm Convention and does not export Persistent Organic Pollutants or hazardous waste in accordance with the Basel Convention.

 

4.0Avoidance of Conflicts of Interest:

 

Employees of perform their duties with impartiality and in accordance with ethical principles. They shall not use their positions or authorities to obtain unfair benefits for themselves, their relatives, or third parties.

In their relations with existing or potential customers, suppliers, and competitCompany, employees are expected to act in a manner that protects the interests of. and must not pursue personal gain

 

 

 

5.0Relations with Public Officials and Other Representatives:

 

Expects all its suppliers to comply with applicable laws and ethical principles. The company makes its decisions based solely on economic criteria and relevant legal regulations, acts honestly in its business relationships, and fully complies with all anti-bribery and anti-corruption laws and regulations.

6.0Protection of Company Assets and Confidential Information:

 

Employees of are responsible for safeguarding all tangible and intangible assets of the company within the scope of their duties. Tangible assets include products, machinery, equipment, vehicles, computers, software, bank accounts, credit cards, files, and other records.

Intangible assets refer to information developed within the company that has not been publicly disclosed (such as trade secrets, technical data, production methods, and other valuable information). Such information must be used solely for work-related purposes and must not be disclosed to unauthorized persons.

4.0Anti-Money Laundering:

 

Complies with all applicable anti-money laundering regulations and strictly refrains from engaging in any money laundering activities. Any direct or indirect involvement in such activities is strictly prohibited.

 

5.0Giving and Receiving Gifts:

 

Employees of are prohibited from engaging in relationships with customers, suppliers, or third parties that may create the perception of gaining personal benefits.

Except for symbolic or promotional items of low value (approximately €50 or less) that are in line with commercial customs, no gifts may be offered or accepted. Any given or received gift or hospitality must be linked to a legitimate business purpose and must not create a conflict of interest.

In case of any doubt about the appropriateness of a gift or hospitality offer, the matter must be reported in writing to senior management.

 

6.0Anti-Corruption:

 

İs committed to complying with all applicable anti-corruption laws and regulations. The company strictly prohibits its employees, subcontractCompany, or representatives from offering, promising, or providing any benefit to customer employees to obtain a contract or any preferential treatment. The same principle applies to contracts concluded with third parties in connection with a customer contract.

 

7.0Bribery and Improper Business Dealings:

 

Does not tolerate bribes, kickbacks, or any similar improper payments that undermine fair trade and free market competition. The company aims to earn the trust of its customers solely through the quality and competitive pricing of its products.

 

Any personal payments, bribe offers, or similar conduct are strictly prohibited. Employees must immediately report to senior management any improper payment offers made to them or their relatives.

 

Improper payments include any kind of advantage such as cash, cash equivalents, valuables, services, or other benefits.

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8.0Conflict Minerals:

 

Avoids the use of raw materials that could directly or indirectly contribute to the financing of armed groups. The company is committed to complying with all applicable legal regulations concerning conflict minerals.

12.0Woman’s Rights:

 

Recognizes that women have equal rights with men and adopts the principle of positive discrimination in favor of women. The company strictly prohibits any gender-based discrimination during recruitment and throughout all human resources processes.

13.0Fair Competition Approach:

 

All its employees comply with the legal regulations and ethical principles that support fair competition and prevent monopolistic practices within the industry.

No employee may attend meetings with competitCompany to share information regarding the company’s products, materials, pricing, technical capabilities, or capacities without the knowledge and approval of senior management. The collection of false bids or any actions that may violate competition rules are strictly prohibited

14.0Use of Private or Public Security Forces:

 

Strictly prohibits the use of inhumane, degrading, or disproportionate force by private or public security forces while intervening in social incidents on the company premise.

 

 

1. Financial Responsibility and Accurate Records;

 

All financial reports prepared and maintained by as well as financial information provided to shareholders, regulatory authorities, and other stakeholders, must be accurate, complete, and truthful.

 

Records relating to the company’s activities serve as evidence of decisions taken, actions performed, and obligations undertaken. Therefore, procedures and controls are implemented to ensure that all transactions are properly and transparently recorded.

 

Misleading or incomplete recordkeeping is strictly unacceptable as it may lead to fraud, financial misconduct, and legal penalties.

 

Accurate financial recordkeeping is essential for legal compliance, transparency, fraud prevention, corporate credibility, and business continuity. Accordingly, ensures the accuracy and integrity of its financial data through robust accounting systems, effective internal controls, and regular audits.

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16.0Reporting of Violations:

 

Employees of are obliged to report any known or suspected violations of the Code of Ethics to their immediate supervisor or through designated reporting channels.

 

The identity of the reporting individual will be kept confidential, and all investigations will be conducted with strict confidentiality. Reports may also be submitted anonymously if preferred.

 

Knowingly submitting false or defamatory reports will be considered a violation of the Code of Ethics.

 

All reports are recorded, thoroughly investigated by the Human Resources Department and the Ethics Committee, and the results are reported to senior management for appropriate action.

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17.0Prohibition of Retaliation and Hostile Behavior:

 

Strictly prohibits any form of retaliation or hostile behavior against employees who report ethical violations in good faith.

 

18.0Disciplinary Committee Process:

 Upon the Ethics Committee’s confirmation of a violation regarding ethical principles or conduct, the matter will be formally referred to the Disciplinary Board. A subsequent investigation shall be launched against the personnel involved, in strict adherence to relevant statutory regulations.