ALPHA AGE ANTI-BRIBERY AND ANTI-CORRUPTION POLICY
1. PURPOSE
The purpose of the Anti-Bribery and Corruption Policy ("Policy") is to ensure Alpha Age Bilişim, Danışmanlık ve Eğitim Hizmetleri A.Ş.'s compliance with anti-bribery and anti-corruption laws, ethical and professional principles, and universal standards.
2. SCOPE
The Anti-Bribery and Corruption Policy applies to:
• All Alpha Age employees, including the Board of Directors,
• Companies and their employees from whom we procure goods and services, as well as individuals and organizations acting on behalf of Alpha Age Bilişim such as suppliers, consultants, lawyers, and external auditors.
3. DEFINITIONS
Corruption is defined as the abuse of one’s authority for unjust personal gain for themselves or others.
Bribery is defined as any offer, promise, request, or acceptance of an undue advantage—whether directly or through intermediaries—with the aim of influencing a person to act in breach of their duties, including doing, not doing, speeding up, or slowing down a task related to their role. This may also involve benefiting a third party connected to the situation.
Bribery and corruption can occur in various forms and areas, such as:
• Cash payments
• Political or other donations
• Commissions
• Social benefits
• Other advantages
4. AUTHORITIES AND RESPONSIBILITIES
The Board of Directors of Alpha Age Bilişim is responsible for establishing, implementing, and updating the Anti-Bribery and Corruption Policy. Employees and board members who violate these principles are subject to disciplinary action. The authority to investigate such violations lies with the Ethics and Disciplinary Committee appointed by the Board of Directors.
Managers of all company departments are responsible for evaluating potential risks and ensuring that employees, external service providers, and business partners comply with the Policy within their respective areas.
Employees are responsible for complying with the policies set by the Board of Directors, effectively managing risks in their areas of activity, fulfilling their duties in line with relevant legal and internal regulations, working in a cooperative manner, and reporting any conduct, activity, or practice in violation of the Policy to the Ethics and Disciplinary Committee.
5. COMPANIES AND BUSINESS PARTNERS INVOLVED IN GOODS AND SERVICES
Companies and business partners involved in goods and services must comply with the Policy principles of Alpha Age Bilişim, the Turkish Penal Code, the German Penal Code, the U.S. Foreign Corrupt Practices Act, the U.K. Bribery Act, and all applicable anti-bribery and anti-corruption laws and regulations. Business relations with non-compliant individuals or entities will be terminated.
5.1. SELECTION OF COMPANIES AND BUSINESS PARTNERS
In the selection process of companies and business partners, in addition to criteria such as experience, financial performance, and technical qualifications, their ethical standards and positive background in this area are also considered. Even if they meet the other criteria, companies or business partners with a history of bribery or corruption are not engaged. The responsibility of conducting necessary due diligence before entering into any business relationship lies primarily with the Procurement Department. The Quality Department evaluates compliance with these criteria during audits.
5.2. AGREEMENTS WITH COMPANIES AND BUSINESS PARTNERS
In agreements and contracts with companies and business partners that have a positive background and meet the selection criteria, the following must be included:
• Full compliance with the principles stated in this Policy and relevant regulations
• Ensuring their employees internalize and adhere to these principles
• Providing periodic training for employees about the Policy
• Regularly reminding employees of their obligations to report and adhere to ethical principles, and encouraging them to report any violations
It must also be stated that non-compliance or violations of the Policy may result in justified termination of business relations and contracts.
6. KEY RISK AREAS FOR BRIBERY AND CORRUPTION
Alpha Age Bilişim aims for full compliance with all relevant laws, regulations, and principles, and does not tolerate any act of bribery or corruption regardless of its purpose. Business relationships with third parties attempting to obtain services from Alpha Age Bilişim through bribery will be terminated. The main risk areas where bribery and corruption may occur are defined below:
6.1. GIFTS AND HOSPITALITY
The principles regarding gifts and hospitality are outlined in the Alpha Age Bilişim Gift and Hospitality Policy.
6.2. FACILITATION PAYMENTS
Alpha Age Bilişim does not allow its personnel or associated individuals or organizations to offer facilitation payments aimed at securing or accelerating routine processes with government agencies (such as obtaining permits or documents).
6.3. DONATIONS
The rules concerning donations and charitable contributions are set out in the Alpha Age Bilişim Donations and Aid Policy. Employees supporting charities with funds collected independently of their jobs fall outside the scope of this Policy.
Violations or suspected violations within these risk areas or related policies must be reported to the Ethics and Disciplinary Committee.
7. ACCURATE RECORD-KEEPING
Alpha Age Bilişim’s accounting and record-keeping practices are governed by legal regulations. Accordingly:
• All accounts, invoices, and documents related to dealings with third parties (such as clients or suppliers) must be recorded completely, accurately, and reliably, and must be stored appropriately.
• No falsification or misrepresentation should be made in accounting or similar commercial records regarding any transaction.
8. TRAINING
The Anti-Bribery and Corruption Policy has been communicated to all Alpha Age Bilişim employees and made constantly and easily accessible via a shared cloud platform.
In order to ensure that all employees adopt the principles in this Policy and act accordingly, training is provided upon onboarding and to all employees every six months.
9. REPORTING AND SANCTIONS FOR POLICY VIOLATIONS
All Alpha Age Bilişim employees and board members must report any violations of this Policy to the Ethics and Disciplinary Committee. The committee can be reached via the email address etik@alphaage.com.tr. All reports are treated confidentially. Confidentiality is maintained throughout the investigation, review, and reporting process. Based on the nature of the case, necessary sanctions are applied in accordance with the Disciplinary Procedure. Employees who fail to report known violations of this Policy may be subject to disciplinary action, including termination of employment.
