ETHICAL VALUES REGULATION

1. PURPOSE
The purpose of this regulation is to explain in detail the ethical values and policies that EGEM PACKAGING employees must comply with.

2. SCOPE
The scope covers EGEM PACKAGING employees.

3. RESPONSIBLES
All EGEM AMBALAJ employees

4. RULES OF BUSINESS ETHICS

4.1. Honesty

Integrity and honesty are our primary values in all our business processes and relationships. We act with integrity and honesty in our relationships with employees and all our stakeholders.

4.2. Privacy

Confidential and private information; It covers information belonging to Egem Packaging that may create a competitive disadvantage, trade secrets, information regarding personnel rights and information within the framework of "confidentiality agreements" concluded with third parties.

4.3. Conflict of Interest

As Egem Packaging employees, we aim to avoid conflicts of interest. Taking advantage of our current mission; We do not obtain personal benefits from individuals and organizations with whom we have business relations, personally or through our family or relatives. We do not engage in business activities based on additional financial interest other than Egem Packaging. We avoid using the name and power of Egem Packaging for personal benefit.

4.4. Our Responsibilities

In addition to our legal responsibilities; We take care to fulfill our responsibilities listed below towards our customers, employees, suppliers and business partners, competitors, society, humanity and on behalf of Egem Packaging.
• Our Legal Responsibilities
• Our Responsibilities Toward Our Customers
• Our Responsibilities Towards Employees
• Our Responsibilities Toward Our Suppliers/Business Partners
• Our Responsibilities Toward Society and Humanity

5. POLICIES THAT SUPPORT THE RULES OF BUSINESS ETHICS

5.1. Conflict of Interest Policy

It is essential for Egem Packaging employees to stay away from situations that may create a conflict of interest. It is the most important responsibility of all employees not to use company resources, name, identity and power for personal benefit and to avoid situations that will negatively affect the name and image of the company. The following principles of practice determine conflict of interest situations that company employees may encounter in their private lives while performing their duties or due to their business relationships, and the principles that should be applied in these situations.

5.1.1. Implementation Basics
Company employees are required to fully comply with the situations and principles listed below as activities that may create a conflict of interest. The company takes the necessary steps to encourage its employees to comply with these principles and protects employees who inform authorities about unethical behavior against retaliation.

a. Engaging in Activities That May Create a Conflict of Interest

Employees do not enter into business relationships with family members, friends or other third parties that provide mutual or non-reciprocal benefits. For example, an employee with purchasing authority should avoid doing business with a supplier where a family member works. Exceptional cases are subject to the knowledge and approval of the Chairman of the Company's Board of Directors. In the same vein, Company employees should also be careful about conflicts of interest that may arise due to close family members working for competitors of the Company.
Managers who have to make a recruitment decision cannot employ their spouses, close relatives or relatives of these people.

b. Abuse of Office

It is unacceptable for employees to harm the company by using their powers for their own benefit and/or their relatives' interests and outside of the care expected from them.
Employees cannot derive direct or indirect personal gain from the company's purchasing and sales activities and all transactions and contracts to which it is a party.
Employees cannot engage in acts or behaviors that are contrary to morality, law and company discipline.

c. Use of Resources

When using resources on behalf of the company, the interests of the company are taken into account. Company assets, facilities and personnel cannot be used outside the company, under any name and for anyone's benefit, without the benefit of the company. The principle of "economy in everything" is applied by all personnel.
The correct use of resources for the benefit of the company also requires the correct use of time. During business hours, company employees use their time well and do not spare time for their private affairs. Managers cannot assign employees to their personal work.
It is essential that no private visitors are allowed during working hours. Employees are required to complete interviews for essential visitors within a reasonable period of time, in relation to the subject of the visit and in a way that does not hinder the workflow.

d. Relations with Other Persons and/or Organizations with which the Company Has Commercial Relations

It is not possible to enter into a private business relationship with the Company's customers, subcontractors or suppliers and other persons and/or organizations with which the Company has commercial relations, it is not possible to borrow money and/or goods/services for personal purposes, and it is not possible to borrow bribes, money and/or goods/services to other persons and/or organizations with which the Company has commercial relations. or goods/services cannot be provided.

The following points are taken into consideration in relations with customers: Even if it is in favor of the customer, no transaction can be made without the customer's information, and even if it is in favor of the company, customer weaknesses cannot be exploited and profit cannot be sought by providing incomplete or incorrect information to the customer.

Company personnel cannot request or imply gifts from other persons and/or organizations with which the company has commercial relations; No gifts, bribes, money, checks, property, free holidays, special discounts, etc. that will put companies under liability. cannot accept. Personal aid or donations cannot be accepted from any person or organization that has a business relationship with the Company. Regarding this issue, the Gift Accepting and Giving Policy applies.

5.2. Policy on Accepting and Giving Gifts

It is essential that Egem Packaging employees do not accept gifts or benefits that may affect their impartiality, decisions and behavior, and do not attempt to provide gifts or benefits to third parties and organizations that may have such effects. The principles of practice defined below regulate possible gift exchanges between Company employees and third parties and organizations with which they have business relationships, and determine the principles to be applied in this regard.

5.2.1. Implementation Basics

Company employees are prohibited from receiving any benefits or gifts, whether of economic value or not, that affect or may affect their impartiality, performance, and decision-making while on duty.

Company employees can provide and receive entertainment, treats and meals at acceptable standards in the business world, with the knowledge of senior management. Gifts under 50 USD can be accepted on New Year's Eve, holidays, birthdays, etc.
In cases exceeding 50USD, senior management will be informed and action will be taken.
In seminars and similar organizations attended on behalf of the company, awards, shields, etc., which have symbolic value, are given as a souvenir of the day, in addition to money. gifts can be purchased.

The gifts and promotional materials to be given by the Company to customers, dealers and other third parties with whom it has business relations are approved by the Company's senior management.

5.3. Confidential Information Protection Policy

Information is one of the most important assets that the company will use to realize its vision. In this regard, it is the common responsibility of all our companies and employees to use information effectively, share it correctly, and ensure the confidentiality, integrity and accessibility of information in this process. It is important that the management systems established and the processes implemented in our companies for the management and confidentiality of information are in harmony with each other in order for the Group to obtain the highest level of benefit. The following application principles: It defines confidential information for the company and regulates the principles that employees must comply with regarding confidential information.

5.3.1. Implementation Basics

Confidential Information includes, but is not limited to, the Company's trademark, etc. intellectual property rights, including all kinds of innovations, databases, printed communication materials, processes, advertising, product packaging and labels and plans (marketing, product, technical), business strategies, strategic partnerships and partnerships written, found, developed, made or implemented by the personnel. related information, financial information, personnel information, customer lists, product designs, know-how, specifications, identity of potential and real customers, information about suppliers, etc. It includes any written, graphic or machine-readable information.

5.4. Policy on Creating and Maintaining a Fair Working Environment

Egem Packaging considers creating and maintaining a fair working environment for employees as one of its most important priorities. It is aimed to increase the success, development and loyalty of employees by creating a fair, respectful, healthy and safe working environment that is compatible with all relevant laws and regulations.
Discrimination among employees within the organization based on language, race, color, gender, political views, beliefs, religion, sect, age, physical disability and similar reasons, psychological pressure that will cause stress and anxiety, insults and bad words are unacceptable.

Within the framework of ethical rules, it respects employees' freedom of association and collective bargaining without fear of reprisal, threat and harassment.

5.5. Dress Code

All our employees must dress in accordance with our company culture, general dress code and work environment (suit, skirt-jacket, fabric dress, tie, shirt, blouse, sweater). Shorts, thin straps, transparent or inappropriately short clothing should not be worn.