Anti-Bribery and Corruption Policy

ANTI-BRIBERY AND CORRUPTION POLICY

Türkün Holding strictly prohibits all employees from accepting any benefit, gift, or advantage—whether monetary or non-monetary—that may affect, or appear to affect, their impartiality, performance, or decision-making while performing their duties.

If our suppliers and/or employees become aware of, or suspect, any case of bribery, corruption, or misappropriation of company resources by administrative or production staff, they may report such concerns freely and without fear of retaliation. Reports can be submitted in writing via complaint/suggestion boxes, either anonymously or with personal identification, at the discretion of the individual.

In addition, concerns may be raised through email, by requesting a direct meeting with the factory manager, or by calling through company phone lines. Suppliers, subcontractors, or employees may also report such matters to the relevant public authorities.

In cases where an employee or a person acting on behalf of the company is suspected of violating this policy, the procedures outlined in Türkün Holding’s Code of Ethics will apply. These principles are regularly communicated and reinforced across the organization.

Vanelli Tekstil San. ve Tic. A.Ş. is committed to promoting honesty and transparency. The company supports any employee or representative who, in good faith, raises concerns and ensures that all reports are treated confidentially. No employee shall face pressure, retaliation, or disciplinary action for reporting a suspected violation of the Code of Ethics. Without the written approval of the Ethics Committee, no changes may be made to an employee’s job scope or workplace location as a result of a report. If an employee experiences such treatment, they are encouraged to escalate the matter to the Board of Directors.

All reports will be investigated by the Board of Directors. Findings, including written and visual documentation, statements from voluntary or confidential witnesses, and related records, will be presented to the full Board. Based on these findings, the Board will deliberate on potential actions, and if deemed necessary, a formal vote will be conducted to determine the outcome regarding the individual(s) concerned.