Our Policies

Policies Approved by Chairman of the Board

Beyçelik Gestamp Policies Approved by the ChairmanoftheBoard

Quality Policy

At Gestamp, we want to become the most renowned automotive supplier for our customer orientation and the quality of our products over their lifetime, while maintaining a sustainable economic, environmental and social footprint.In order to position ourselves at the forefront of innovation in the automotive sector, we make every effort to research and thus develop innovatively designed products and trendsetting technologies.

We aim to facilitate increasingly safer and lighter vehicles in order to reduce energy consumption and environmental impact.In addition to applying our zero defect strategy, we strive to become a benchmark in quality for our customers through continuously improving our products and the efficiency of our processes and systems (quality management system), focused on preventive quality based on risk management.

As a good corporate citizen, we assume responsibility for our products, our employees, the environment and everyone who are affected by our actions satisfying the applicable requirements.In line with our corporate strategy, the following values represent our commitment:

Our Documents

Beyçelik Gestamp IATF-16949

Beyçelik Gestamp ISO-9001

Şasi IATF-16949

Şasi ISO-9001

Environmental Energy and Water Policy

• The client as the center of business;
• Operational excellence as a regular practice;
• Innovation as a means of progress;
• Sustainability to ensure permanence in time;
• People as architects of success.

To fulfill all our legal and other obligations related to environment and energy,

-To manage waste resulting from our activities in accordance with the principles of zero waste and waste management hierarchy.

-To adhere to national and international emission targets in the fight against climate change and contribute value to a low carbon economy,

-To optimize energy usage and transition towards renewable energy,

-To work towards reducing natural resource consumption, monitoring and controlling our greenhouse gas emissions,

-To collaborate with our internal and external stakeholders to increase environmental awareness and contribute to the development goals, leaving a clean environment to our society and future generations,

-To establish measurable goals for reducing our environmental impacts and energy consumption, and to continuously improve our environmental and energy management systems based on these goals,

-Monitoring and reporting water consumption,

-To develop projects to reduce water consumption and take necessary measures to prevent water pollution,

-To continue our work in full compliance with the legislation we are subject to regarding water,

-We aim to systematically manage energy consumption and reduce our carbon footprint. In this regard, we commit to implementing and ensuring the continuity of an energy management system that focuses on energy performance and continuous improvement.

In line with human resources policies; Beyçelik Gestamp aims to protect every individual in our workplaces from accidents and occupational diseases. While meeting all our national legal and other obligations, to continuously improve our performance Beyçelik Gestamp makes commitment;
Beyçelik Gestamp ISO-14001

Beyçelik Gestamp ISO-50001

Beyçelik Gestamp Şasi ISO-14001

Occupational Health and Safety

(1) To provide healthy and safe workplaces,

(2) To adapt the risk-based process approach for eliminating all the occupational health and safety risks  for preventing from the results of hazards and to improve our integrated management system continuously,

(3) To create a common occupational health and safety culture by training our employees, contractors, sub-employers, visitors and internship students,

(4) To use the early equipment management process and modernıze our facilities wıth new technologies by training, planning, auditing, annual targets and review activities as a development opportunity;

(5) To adopt proactive activities as direct and common responsibility of our top management and employees,

(6) To Participate in occupational health and safety activities on all level of our human resources,

(7) To evaluate of risks and opportunities wıth applicable conditions and improve the results wıth consulting our human resources,

(8) To use education, recognition / approval, target determination, monitoring and review processes to ensure implementing the our policy,

(9) To providing timely support to the activies on occupational health and safety in order to reach our goals.

Beyçelik Gestamp Otomotiv ISO-45001

Beyçelik Gestamp Şasi ISO-45001

Laboratory Policy

In the measurement, control, test, verification and calibration processes carried out in our laboratories, we provide the results that are consistent with the national and international standards and consistently provided with reliability by using devices with traceability within the framework of professional and technical principles of application, in line with the customer requirements.

In order to be able to provide reliable results, we apply the principles of quality management system effectively and comply with new up-to-date regulations and standards.

We serve with expert and reliable personnel who know and apply the requirements of the laboratory standards and use the documentation correctly.

Information Security Management System Policy

It aims to ensure the security of information about all activities that are available and will be created under the Authorized Liability Status, provide business continuity with minimum interruption, provide the confidentiality of all information belonging to the company and third parties which is required to be protected and protect all physical and electronic information used in the continuity of business processes and services in accordance with the criteria of Confidentiality, Integrity and Accessibility.

All employees, suppliers, business partners and all other third parties who access and use information assets of Beyçelik Gestamp must fulfill the followings:

• They should comply with the Information Security, Policy, Procedures and Instructions,
• They should inform the responsible units about security and incident violations,
• They should provide the confidentiality of the information belonging to the company and backup the information processed, They should communicate suggestions and developments deemed appropriate by themselves for the development of the system.

Beyçelik Gestamp management; declares that it will prove its commitment to the establishment, realization, operation, tracking, monitoring, maintenance and continuous improvement of the Information Security Management System (ISMS) in accordance with the TS ISO/IEC 27001 Standard by realizing the following issues:

• Determining the objectives of ISMS and making the necessary plan for realizing these objectives.
• By analyzing the risks on Assets and Processes, ensuring risk management within the framework of revealing the risk assessments and risk criteria based on the results of the analyzes.
• Defining the importance of meeting information security objectives and compliance with information security policies, the responsibilities for legal and contractual obligations and the need for continuous improvement.
• Providing adequate resources (financial, human resources, equipment, software, consultancy, training, etc.) to establish, realize, operate, monitor, supervise, maintain and constantly improve the ISMS.

Announcement of all employees and expenditures in innovations, changes and developments within the scope of Information Security Management System in a way that will ensure their economy.

Organizing and managing the necessary actions to determine the criteria for accepting risks and acceptable levels of risk.

Click here to view the Information Security Management System Certificate

Social Gender Equality Policy

Purpose of the Policy:

Adopting sustainable sex equality in corporate work culture and operational processes, primarily raising awareness in work and social lives of employees, creating awareness at next generations, becoming a role model in the industry with the slogan “I Stand for Equality, too”.

1. Respectful for human rights. Carries out activities necessary for formation of work areas at equal conditions.

2. Implements equality action plan, generates projects, makes collaborations and raises awareness at public opinion. Carries out measurement, monitoring and evaluation towards targets.

3. Uses as basis Women’s Empowerment Principles (WEPs) which it is a corporate signatory, implements the same and supports equal opportunity and equal participation in workforce without discrimination of sex.

4. Makes sure no discrimination in recruitment, employment processes, promotion and dismissals (religion, language, race, sex), choice is made on the basis of requirements of job, competencies and capabilities of person.

5. Anti-violence at any field of life. Carries out activities in relation to raising awareness of employees on gender based violence at work, social life and family.

6. Safeguards privacy and confidentiality of any person who suffers from domestic violence, informs about centers of application, refers to non-governmental organisation in respective field.

7. Performs training and awareness activities for creating awareness in relation to gender equality at next generations and in particular for empowering girls in life.

8. Attentive that discriminatory and sexist contents are not used in internal and external communication language of the organisation.

9. Encourages suppliers and organisations with whom it collaborates for performing activities in the field of gender equality.

Sustainability Policy

Contributing to sustainable development, as well as continuously increasing the value we create for all our stakeholders constitute the basis of our sustainability approach. With this approach, we designate our main focuses for sustainability which we set forth in line with a system recognized by international standards, and manage relevant topics through our “Sustainability Policy”. In parallel with our management perception, we show maximum effort to conduct our operations as per the United Nations Sustainable Development Goals. Accordingly, through the Sustainability Policy of Beyçelik Group of Companies, we undertake the following:

• Developing sustainable products and services with quality and safety features that will maximize the satisfaction of our customers by meeting their expectations
• Managing our operations and relations with our stakeholders with a corporate management perception based on transparency and accountability which continuously observes business ethics
• Proactively and continuously assessing risks for our priorities, and taking actions when needed
• Implementing practices that will extend our business ethics, quality and sustainability approach in our entire value chain, particularly our supply chain
• Improving our stakeholders in our value chain
• Maintaining our performance by managing our R&D, innovation and digitalization processes through continuous development and improvement; and contributing to improvement of resources by extending use of artificial intelligence in our business processes
• Uninterruptedly implementing productivity and improvement procedures to reduce / minimize our environmental impact as part of fight against climate change
• Uninterruptedly implementing operational excellence projects to ensure efficient use of resources
• Working in the light of national and international standards to improve our performance of Occupational Health and Safety
• Continuously diversifying our modern human resources practices to become an employer preferred by employees
• Providing equal opportunities for our employees while also giving them the opportunity to continuously develop themselves
• Fighting against all kinds of discrimination, and practices such as forced and compulsory labor and child employment under the guidance of universal human rights
• Fulfilling social responsibility projects that will improve our society and contribute to its welfare.

Human Rights Policy

PURPOSE AND SCOPE

Acting in compliance with internationally valid human rights principles in our relationships with our employees, customers, suppliers, contractors institutions and organizations with which we communicate is our primary value. We aim to provide our employees with a workplace environment that respects people. In the Human Rights Policy, which was prepared on the basis of these values and purpose, Universal Declaration of Human Rights, International Labour Organization (ILO) Conventions and Universal Declaration of Human Rights and SA 8000 have been taken as guide. The Human Rights Policy supports the Beyçelik Holding Code of Business Ethics, which is published on July 1, 2017.

Human Rights Policy applies to all companies within the structure of Beyçelik Group. The Policy internal relations of the company has been created to be a guide for all employees, customers, suppliers in their relationships each other and with other stakeholders.

BASIC PRINCIPLES

Respect for Human, Equal of Opportunity

• We support and respect internationally recognized human rights principles.
• We do not allow verbal or actual harassment in the workplace in any way.
• We do not discriminate between our employees  based on age, race, gender, belief, language, religion, nationality, marital status, sexual orientation, seniority, political opinion, military service, disability.
• We do not discriminate based on age, race, gender, belief, language, religion, nationality, marital status, sexual orientation, seniority, political opinion, military service, disability in all conditions such as recruitment, placement, promotion, termination of employment contract, recall, transfer, leave, wage and training.
• We evaluate the competencies and performances of our employees through the systems created by Human Resources relying on objective criteria, and we offer opportunity for career and development for each employee in a manner to create equal opportunities for everyone.

Working Hours and Wages

• We implement our working hours according to the procedures and principles specified in the labor law.
• We establish our wage policy according to the sector and local labor market without any discrimination for work with equal value.

Occupational Health and Safety

• We provide safe and healthy working environment for our employees.
• We follow and apply all local laws to ensure our employees’ occupational health and safety.
• We regularly inform our employees in order to learn and correctly implement the legislation regarding occupational health and safety.

Training and Development

• We believe that the most important investment is the investment is the one we made in our employees, and accordingly, we support our employees  with continuous training for their personal development.

Forced Labor and Child Labour

• We comply with the Regulation on Procedures and Principles for Employment of Child and Young Workers, and we do not employ any worker under the age of 18 as per our corporate approach for human resource.
• We prohibit practices that violate freedom to engage in business and freedom of labor by the use of force or threats or any other unlawful conduct.

The Right to Establish Trade Unions and Right to Collective Bargaining

• We respect the freedom of our employees to establish trade unions and ensure that the right to collective bargaining is effectively recognized.

Environment

• We manage all our activities and investments with the aim of sustainable growth.
• We act with a sense of responsibility towards our environment and take the necessary precautions during our activities.

Land, Forest, and Water Rights

• Our company respects environmental rights while assessing the impact of our activities on local communities.
• We support the sustainable management of land, forest, and water resources.
• We ensure that our activities do not threaten the livelihood resources of local communities.

The Right to Avoid Forced Eviction and Displacement

Forced evictions or displacement of communities are avoided in any operations.If eviction becomes necessary, the process is carried out in accordance with international human rights standards.

Use of Security Forces

Our company ensures that the use of private or public security forces adheres to human rights principles.

Necessary measures are taken to ensure that security forces operate within international standards.

Data Privacy

• We take measures for protection of the personal data of our employees and apply the standards that are prescribed in the laws and regulations in this respect.

APPLICATION

• We aim that all our employees have a honest and respectful relationship with each other at Beyçelik, and we work to provide the necessary working environments in this regard.
• We expect our employees to adopt and comply with the Human Rights Policy.
• We work to identify and prevent the potential issues in advance that will adversely affect the compliance with human rights and that may arise from our activities.
• We expect our suppliers and business partners to act in compliance with our Policy.
• Beyçelik is obliged to carry out the necessary works to give information on the matter and raise awareness in order for its employees to act in accordance with the policy.
• Feedback or complaints regarding the compliance with the Human Rights Policy are sent to the Ethics Committee e-mail address ([email protected]).
• The written reports submitted to the relevant Ethics Committee with respect to the acts and practices that are not in compliance with the Human Rights Policy is reviewed by the Ethics Committee. The reviews are performed in secret. No retaliation can be in question against the employee who submitted a report.
• The articles contained in the Human Rights Policy are reviewed annually by the Ethics Committee Members and revised when deemed necessary.

Supply Chain Compliance Policy

1. PURPOSE AND SCOPE

The purpose of this Supply Chain Compliance Policy (hereinafter referred to as the “Policy” in the Document) is to share BEYÇELİK GESTAMP Otomotiv Sanayi A.Ş. (hereinafter referred to as “BEYÇELİK GESTAMP”) basic principles and values with our Business Partners and to provide the necessary guidance with respect to the standards we expect them to comply with. This Policy has been prepared by taking also the ethical principles of BEYÇELİK GESTAMP’s Main Partners (Beyçelik Holding and Gestamp Automocion S.A.) ethical principles.

This Policy also aims to be a guideline in the selection and monitoring processes of BEYÇELİK GESTAMP Business Partners.

All employees and managers of BEYÇELİK GESTAMP are obliged to act in compliance with this Policy, which is an integral part of BEYÇELİK GESTAMP Working Principles and Code of Ethics. BEYÇELİK GESTAMP expects all its Business Partners to act in compliance with this Policy to the extent applicable to the respective party and/or transaction and takes necessary steps to ensure this.

2. DEFINITIONS

“Main Partners” means BEYÇELİK GESTAMP HOLDING and Gestamp Automocion S.A., which are the main shareholders of BEYÇELİK GESTAMP.

“BM” means the international organization of the United Nations.

“BM Guiding Principles on Business and Human Rights” 1 is a guiding text for countries and companies in order to examine, prevent and correct human right violations faced in the business life.

“BM Global Compact”2 refers to the convention, which addresses 10 fundamental responsibility areas of the business world in the fields of human rights, working standards, environment and anti-corruption and which is based on UN declarations universally adopted for social responsibility and sustainable implementations.

“ILO” means the International Labour Organization.

“ILO Declaration on Fundamental Principles and Rights at Work” 3 refers to the ILO Declaration stating that all member states, even if they have not ratified the relevant conventions, are obliged in
good faith to respect, develop and support the following four principles:

• Effective recognition of freedom to establish trade union and right of collective bargaining,
• Elimination of all forms of forced labor or compulsory labor,
• Prevention of child labor,
• Elimination of discrimination during employment.

“Human Rights” refers to the rights specific to all people regardless of their gender, race, color, religion, language, age, nationality, different opinion and property, and contains the right to an equal, free and life with dignity.

“Universal Declaration of Human Rights (UDHR)” 4 is a milestone document in the history of human rights. This Declaration, which was drafted by representatives with different legal and cultural backgrounds from all regions of the world, was declared by UN General Assembly in Paris on December 10, 1948 as a common measure of achievement for all people and all nations, and was the first document to emphasize the universal protection of fundamental human rights.

“Business Partners” covers suppliers, distributors, dealers, authorized service and all other third parties with whom we have a business relationship as well as any representative, sub-contractors, consultants, etc. who act on behalf of the company.

“Money Laundering” is the integration of revenues from illegal activities into the financial system as if they were obtained legally, in other words, the concealment of the fact that these revenues are obtained from illegal activities.

“Sanctions Objective”;

• Any person, organization, ship or government that is the target of sanctions (“Listed Persons”);
• Companies in which the Listed Persons directly or indirectly own 50% or more;
• Natural or legal persons residing in countries and regions subject to comprehensive sanctions (“Embargoed Countries”) or legal entities registered in these countries.
• Persons or companies, which are owned or controlled by governments of the Embargoed Countries or which acts as a representative of them.

3. GENERAL PRINCIPLES

BEYÇELİK GESTAMP selects its Business Partners according to the criteria such as technical
competencies, product and service quality, pricing, corporate reputation and financial soundness. BEYÇELİK GESTAMP also evaluates the compliance risks associated with the Business Partners according to a risk-based approach in order to ensure compliance with the principles specified in this Policy. Within the framework of this approach, the following issues are adopted:

Carrying out the preliminary competency evaluation process, providing corporate documentation, conducting financial, technical and fiduciary competency investigations in accordance with BEYÇELİK GESTAMP’s Company Preliminary Evaluation Procedure Before Entering into a Business Relationship (“Preliminary Competency Evaluation Procedure”) before entering a business relationship with Business Partners,

Having the right to audit to be used when necessary in order to establish whether the ethical rules especially applicable legislation, contractual obligations with BEYÇELİK GESTAMP and the “Guiding Principles for Business Partners”, which is described below in detail,

Giving the necessary training to ensure compliance when necessary.

Acceptance Process

Before entering into or commencing any business relationship with a new Business Partner, business and operation units, as a first line of defense, are responsible for:

• Fulfilling the requirements of the Preliminary Competency Evaluation Procedure;
• Prohibited List Inquiry through a third-party scanning tool in order to confirm whether the respective party is subject to any Sanction Obligations,
• Performance of advanced due diligence (Filling out the Information Request Form (KYC), Self-Evaluation Form) in case the respective party is the supplier candidate from whom production will be purchased and a representative acting on behalf and in the name of the company 6,
• Evaluation of whether they comply with BEYÇELİK GESTAMP Guiding Principles for Business Partners (“Principles”), which is set out below in detail.

In case the due diligence results contain a warning sign for any non-compliance and the mentioned Business Partner is a dealer, representative acting on behalf and in the name of the company or a
supplier candidate from which a production is to be purchased, an advanced due diligence is carried out for the respective parties in accordance with the Preliminary Competency Evaluation Procedure. In case the result of the advance due diligence is negative (namely, the party concerned does not act in compliance with the principles and/or does not take the necessary measures to remedy the violation in question), the decision to start or continue the work is subject to the written approval of BEYÇELİK GESTAMP Senior Management.

4. GUIDING PRINCIPLES FOR BUSINESS PARTNERS

BEYÇELİK Guiding Principles for Business Partners has been prepared in accordance with the UN Global Impact. All Business Partners of BEYÇELİK GESTAMP are expected to comply with these Principles.

4.1. Legal Regulations

BEYÇELİK GESTAMP Business Partners are expected to comply with all laws and regulations within the scope of their activities and sectors. Within this scope, all Business Partners such as suppliers, distributors and authorized services are expected to comply with competition laws, legislation on the prevention of Money Laundering and the financing of terrorism, data privacy regulations and laws on the fight against bribery and corruption, as well as all other applicable legislation provisions.

4.2. Fighting Against Bribery and Corruption and Prevention of Money Laundering

Business Partners are expected to comply with the applicable legislation regarding the fight against bribery and corruption and the prevention of Money Laundering while carrying out their activities on behalf of BEYÇELİK GESTAMP. It is unacceptable to give or receive any sort of bribe and directly or indirectly anything of value in order to have unfair advantage and influence impartial decision-making processes. Any activity that may lead to Money Laundering, whether in bad faith or not, is illegal and unacceptable.

All transactions should be recorded in legal books and records in a manner that includes accurate, transparent and adequate explanations.

4.3. Intellectual and Industrial Property Rights

BEYÇELİK GESTAMP Business Partners are expected to refrain from the violation of any intellectual and industrial property rights of third parties such as patent, utility model, industrial design, copyrights, trademarks and similar things or actions that may cause unfair competition within the framework of their activities.

4.4. Human Rights

Business Partners are expected to carry out their commercial activities in accordance with BEYÇELİK GESTAMP Human Rights Policy 7.

4.4.1. Employment

BEYÇELİK GESTAMP’s Business Partners must ensure that their activities are not associated with
child labor, forced labor, and abuse of work. In addition, BEYÇELİK GESTAMPS expects from its suppliers, distributors and authorized services to adopt “zero tolerance” approach against slavery and human trafficking in accordance with ILO Conventions and Recommendations, Universal Declaration of Human Rights and UN Global Compact.

4.4.2. Compliance with Labor Laws

Business Partners are expected to comply with the labor laws of the countries in which they operate. The wage determination process should be determined competitively according to the relevant sectors, the local labour market and in accordance with the conditions of collective bargaining agreements, if any. All wages, including social benefits, must be paid in accordance with applicable laws and regulations.

4.4.3. Prevention of Harassment and Violence

Business Partners are expected to provide a work environment free of violence, harassment, other unsafe and disturbing conditions resulting from internal and external threats. No physical, verbal, sexual or psychological harassment, bullying, abuse or threat of any kind is tolerated.

4.4.4. Discrimination

Business Partners are expected to provide a working environment where no discrimination, especially gender discrimination, is accepted, employees are treated fairly and discrimination (such as race, gender, color, national or social ethnic origin, religion, age, disability, sexual orientation, gender definitions or political opinions) is not tolerated.

4.4.5. Freedom of Association and Collective Bargaining

Business Partners must respect the rights and freedoms of their own employees to join a trade union or enter into collective bargaining without feeling any fear of retaliation.

4.5. Health and Safety

Business Partners are expected to provide a safe and healthy working environment, to comply with all the relevant legal arrangements, and to take and implement all necessary safety measures for all work areas. Business Partners must immediately take the necessary measures to minimize the risk of injury and accidents in case unsafe conditions or behaviours occur.

4.6. Conflict Minerals

Metal trade in politically unstable regions should not be used to finance armed groups, to promote forced labor and other human rights violations and to support bribery and money laundering. BEYÇELİK GESTAMP expects from its Business Partners to comply with the international responsible sourcing Standards8 introduced by the OECD in the supply of mines called “Conflict minerals” such as tin, tungsten, tantalum and gold.

4.7. Environment

BEYÇELİK GESTAMP expects from its Business Partners to show maximum efforts to protect and maintain the environment. Within this scope, BEYÇELİK GESTAMP supports its Business Partners in the following subjects;

• Complying with all applicable environmental regulations, including BEYÇELİK GESTAMP’s Environment and Energy Policy.
• Continuously improving their environmental performance and reducing their environmental impact for climate change, water management, waste management and biodiversity conservation.
• Having effective monitoring systems and procedures against industrial accidents and other emergencies.
• To encourage Business Partners to improve the environmental performance of their business partners and third parties.

4.8. Ethics

BEYÇELİK GESTAMP expects from its Business Partners to carry out all their affairs and actions in accordance with the laws, international conventions to which the Republic of Turkey is a party, United Nations Declaration of Human Rights, United Nations Global Compact and to act within the framework of fairness, integrity, honesty, responsibility, trust, accountability, openness and respect in all their affairs.

4.9. Conflict of Interest

Business Partners that have a business relationship with BEYÇELİK GESTAMP or other persons and organizations that is likely to have a business relationship with BEYÇELİK GESTAMP must not engage in personal relationships that may cause or be perceived as a conflict of interest between BEYÇELİK GESTAMP and themselves (or their relatives) and that may damage the reputation of BEYÇELİK GESTAMP.

The existence of a close relationship such as kinship, friendship or similar relationship between Business partners that have a business relationship with BEYÇELİK GESTAMP or persons or organizations that is likely to have a business relationship with BEYÇELİK GESTAMP and BEYÇELİK employees who employ them, approve their businesses and take decision about them also creates a risk of conflict of interest. Persons, organizations and BEYÇELİK GESTAMP employees, who are, or likely to be, in such a situation are obliged to immediately report the relevant Human Resources and Information Technologies Directorate of the situation.

4.10. Reporting

Business Partners are expected to establish effective communication channels to enable violations to be reported and to take necessary measures in a timely manner. It is required that Business Partners and their employees are able to report their concerns through these communication channels without fear of revenge or retaliation. In addition, it is possible for Business Partners’ employees to convey their concerns through the notification channels that are detailed in the “Powers and Responsibilities” title of this Policy.

4.11. Training and Development

BEYÇELİK GESTAMP encourages its Business Partners for providing their employees with training programs and tools to enable them to gain more skills and competencies.

4.12. Management Systems

Business Partners are expected to have effective and functional managements systems in order to operate in accordance with the laws, regulations and the Principles set out in this Policy.

5. POWERS AND RESPONSIBILITIES

BEYÇELİK GESTAMP’s all employees and managers are responsible for complying with this Policy and implementing and supporting BEYÇELİK GESTAMP’s relevant procedures and controls in line with the requirements in this Policy. BEYÇELİK GESTAMP expects all its Business to act in compliance with this Policy to the extent applicable to the respective party and business and take necessary steps to ensure this.

In case of a difference between this Policy and the local legislation that is applicable in countries where BEYÇELİK GESTAMP operates, the more restrictive one shall be applied, to the extent the application does not constitute a violation of local legislation.

If any action that is thought to be in violation of applicable legislation or BEYÇELİK GESTAMP’s Working Principles and Code of Ethics is learned, Human Resources and Information Technologies Directorate and BEYÇELİK GESTAMP Ethics Representatives (Human Resource Leaders at the Company’s locations) should be contacted.

Your questions or all reports of ethical violations should be sent via [email protected] e-mail address.

BEYÇELİK GESTAMP employees may consult with BEYÇELİK GESTAMP Human Resources and Information Technologies Directorate with respect to questions about this present Policy and its application. Violation of this Policy by an employee may result in significant disciplinary punishments, including disemployment. In case any third party, who is expected to act in accordance with this Policy, acts in violation of this Policy, all necessary legal actions can be taken, including the termination of relevant contracts and collection of damages suffered by BEYÇELİK GESTAMP from responsible persons.

1. https://www.ohchr.org/Documents/Publications/GuidingPrinciplesBusinessHR_EN.pdf
2. https://www.unglobalcompact.org/what-is-gc/mission/principles
3. https://www.ilo.org/declaration/lang–en/index.htm
4. https://www.un.org/en/universal-declaration-human-rights/
5. For details; BEYÇELİK GESTAMP’s Company Preliminary Evaluation Procedure Before Entering into a Business Relationship
6. If deemed necessary, a detailed examination with regard to other third parties may be requested.
7. For details : https://beycelikgestamp.com.tr/tr/hakkimizda/politikalar/insan-haklari-politikasi
8. https://www.oecd.org/daf/inv/mne/OECD-Due-Diligence-Guidance-Minerals Edition3.pdf.

IT Management System Policy

Beyçelik Gestamp aims to increase customer satisfaction by ensuring that all services provided by the Information Technology department to Beyçelik Holding and its subsidiaries are delivered in accordance with Service Level Agreements, Laws, and Standards, measured and reported, and continuously improved in line with technological changes and business requirements.

Beyçelik Gestamp implements the directives and policies listed below in the services it provides and guarantees service management by establishing an IT Service Management System that complies with the requirements of the IT Service Management System (ITSM) standard and our existing processes, thereby ensuring the effectiveness of ITSM and services:

• To utilize capabilities and resources in the most appropriate manner to deliver the right service to meet the needs of Beyçelik Gestamp and its affiliates, and to provide resources with the necessary competence to deliver the service,
• To ensure the continuity of our management system, which is supported by Senior Management and is compatible with the requirements of the IT Service Management System standard and our existing processes,
• Ensuring that services provided to meet customer needs and expectations comply with all relevant legal and other requirements, as well as contractual arrangements,
• To develop and deliver services that meet customer expectations and to support the continuous improvement of these services,
• To provide IT Service Delivery that meets and aims to exceed customer expectations.
• Address and record any issues with the services provided by the Service Desk.
• Ensure that the SLAs for the services provided are consistent with the SLA periods defined for the services in the Beyçelik Gestamp Service Catalog.
• Ensure that all software, hardware, and data communication equipment used in the Release Management Process are monitored, including version and security patches, etc., and updated in accordance with related processes, and that the correct versions are used in units and by customers.
• Establish and maintain good relationships between service providers and customers based on understanding customers and their businesses through the Business Relationship Management Process.
• Monitor system capacities according to defined criteria and take action when needed.
• Control the operation of processes through internal and external audits and take corrective and preventive actions.
• Provide awareness training to employees and third parties on new and changing jobs and processes.

We set our goals for developing IT Service Management, determine the processes necessary to achieve these goals, continuously monitor their outputs and performance, and carry out improvement activities to achieve our goals. We regularly monitor the progress of our goals to ensure the continuity and improvement of IT Service Management.

Beyçelik Gestamp Otomotiv Sanayi A.Ş ISO 20000-1:2018

Beyçelik Gestamp Otomotiv Sanayi A.Ş ISO/IEC 27001-1:2022

Beyçelik Gestamp Şasi Otomotiv Sanayi A.Ş ISO/IEC 27001-1:2022

Çelikform Gestamp Otomotiv A.Ş ISO/IEC 27001-1:2022

Gestamp Beycelik Romania SRL ISO/IEC 27001-1:2022

Anti-Bribery and Anti-Corruption Policy

1. PURPOSE

The purpose of Beyçelik Gestamp Anti-Bribery and Anti-Corruption Policy is to set out the framework of the principles and guidelines on anti-bribery and anti-corruption and to ensure transparent communication. This policy aims to identify, mitigate and manage bribery and corruption risks in compliance with legal regulations, business ethics principles and universal rules of law.

The policy is also integrated with Beyçelik Gestamp Code of Business Ethics, Beyçelik Gestamp Policies and Values and is implemented throughout our own operations and our entire value chain. Our internal practices are based on this Beyçelik Gestamp Anti-Bribery and Anti-Corruption Policy and Beyçelik Gestamp Code of Business Ethics.

2. DEFINITIONS

Conflict of Interest: All kinds of material and immaterial interests that prevent or may be perceived to prevent employees from performing their duties impartially.

Ethics Committee: The Ethics Committee is the committee that reports to the Vice Chairman of the Board of Directors of Beyçelik Holding and decides on the actions to be taken in the event of complaints and notifications regarding violations of ethical rules within the scope of “Beyçelik Gestamp Code of Business Ethics”.

Gifts: All kinds of goods and benefits that affect or are likely to affect the employee’s impartiality, performance, decision or performance of his/her duty, with or without economic value, accepted directly or indirectly.

Business Partners: Suppliers, distributors, dealers, authorized services and all other third parties with whom the Company has a business relationship, and all kinds of representatives, subcontractors, consultants, etc. acting on behalf and account of the Company.

Money Laundering: Integrating the revenues obtained from illegal activities into the financial system as if they were obtained legally, in other words, concealing the fact that these revenues are obtained from illegal activities.

Bribery: Providing material or immaterial benefit, directly or indirectly, to oneself or to the requesting party or to another person to be shown by the other party, directly or indirectly, within the framework of a verbal/written agreement, in order to ensure that a person performs an action contrary to the requirements of the duty or outside the ordinary course of business, directly or through intermediaries, such as doing, not doing, not having done, speeding up, slowing down a job related to the performance of the duty.

Corruption: The misuse of the duties and authorities in order to gain material or immaterial gain directly or indirectly by distracting from the fulfillment of the duties and authorities in accordance with the law.

3. PRINCIPLES AND GUIDELINES

In accordance with the guidance of “UN Global Compact (UNGC) (2000)”, national and international laws and regulations on anti-bribery and anti-corruption and Beyçelik Gestamp Code of Business Ethics, we aim for full compliance with the principles and principles set forth in this Policy; no form of bribery and corruption is tolerated regardless of its purpose. Our employees and managers in the regions where we operate are obliged to act in accordance with this Policy, to implement and support Beyçelik Gestamp’s relevant procedures and controls in line with the requirements in this Policy.

Beyçelik Gestamp Business Partners are also expected to comply with all laws and regulations within the scope of their activities. In this context, all Business Partners such as suppliers, distributors and authorized services are expected to act in compliance with competition laws, legislation in force for the prevention of money laundering and financing of terrorism, data privacy regulations and anti-bribery and anti-corruption laws and all other applicable legislation provisions.

It is envisaged to establish an “Anti-Bribery and Anti-Corruption Compliance Program” within Beyçelik Gestamp and to carry out studies for the follow-up of the said compliance program.

Our main principles and principles regarding the possible risk areas where bribery and corruption acts may occur are detailed below:

3.1. Accuracy and Transparency

It is essential that all records regarding the activities carried out at Beyçelik Gestamp are kept in accordance with the legislation and standards, accurately, transparently, completely and timely, and that they are recorded in legal books and records in a manner to include adequate explanations. Documents pertaining to commercial and financial transactions must reflect the actual situation. No payment to be used for other than its intended purpose may be made or approved. There are effective internal control mechanisms in our business processes to prevent potential bribery and corruption risks.

3.2. Accepting and Giving Gifts

Beyçelik Gestamp employees may not give or accept any gifts to persons or organizations with whom they have a business relationship that have a high material value or that may affect the impartiality of the other party, that may cause or be perceived as causing a dependency relationship. When in doubt about this issue, the opinion of a senior manager is taken. They may not request or accept any discounts, donations, money, checks, goods or property, free vacations, special discounts, etc. from third parties, institutions and organizations that may be perceived as inappropriate.

3.3. Avoiding Conflict of Interest

Beyçelik Gestamp employees may not benefit themselves, their relatives and/or third parties with whom they have business relations outside of the employment contract by taking advantage of their current duties, and may not conduct business that would be contrary to the interests of the company.

Beyçelik Gestamp employees are not allowed to directly or indirectly obtain personal gain from the transactions and contracts to which they are a party through purchasing and sales activities.

Our employees have the obligation to immediately inform their immediate supervisor and/or Beyçelik Gestamp Human, Technology and Innovation Director and/or Beyçelik Holding Ethics Committee in case they detect any conflict of interest or irregularity in their business relations in this context.

Business Partners who are in a business relationship with Beyçelik Gestamp or other persons/organizations that may be in a business relationship with Beyçelik Gestamp should not enter into personal relationships between Beyçelik Gestamp employees and themselves or their relatives that may lead to a conflict of interest or that may be perceived as such and that may damage Beyçelik Gestamp’s corporate reputation.

3.4. Political Activities

Our employees may not directly or indirectly use working time and company resources for personal gain and/or political activities. In the event that employees wish to be active in any political party individually and voluntarily, this must not create a conflict of interest with their duties in the company. The relevant employee also cannot use the company name, position and company resources during these activities. It is also strictly forbidden to donate to any political party on behalf of Beyçelik Gestamp or to contribute in kind or in cash under any name.

3.5. Bribery, Abuse and Misconduct

We refrain from taking/giving bribes and/or commissions under any name whatsoever in the regions and business areas in which we operate, and from engaging in all kinds of illegal and unethical activities that may lead to fraudulent behavior or unfair gain.

None of our employees may, directly or indirectly, offer, promise, give or mediate the giving of money or anything of value to any person with whom they have a business relationship in order to obtain unfair advantage for themselves or third parties.

Our employees must carefully avoid unethical behaviors such as bribery, corruption and misconduct.

3.6. Protection of Beyçelik Gestamp Assets and Data/Information Confidentiality

Beyçelik Gestamp employees cannot use the company’s assets and resources, including intellectual property rights, technology, computer hardware and support, software, real estate assets, machinery and tools, raw materials/materials, company vehicles and cash books, in an inefficient and ineffective manner, and avoid unnecessary expenses. We expect our employees to use company assets in accordance with corporate principles and regulations. We take measures to prevent the use or damage of these assets by unauthorized third parties.

Employees take care of all tangible and intangible assets of the company, including data, information and information systems, as if they were their personal property, protect them against possible loss, damage, misuse, abuse, theft and sabotage, and take necessary measures to prevent unauthorized persons from accessing these resources and confidential information/data.

At Beyçelik Gestamp, commercial and financial information, technical data, product/production data, customer information and personal information, equipment and application information, technical formulas and drawings, designs, projects, system and program information, procurement information, engineering information, regulations, business plans and all information that the company does not disclose to the public, including but not limited to these, are not called confidential but are confidential.

Our employees protect all confidential information-documents to which they have access and use them only for the benefit of their work for the company, within the framework of legal and business ethics rules. They may never share confidential information with third parties (even if they leave their jobs) for any reason or for their personal benefit or for the benefit of third parties.

3.7. Recruitment and Interaction with Public Officials and Politically Influential Persons

The employment process at Beyçelik Gestamp is competency-based and is not intended to encourage corruption or provide an undue benefit to a Public Official. In addition, Public Officials and Politically Influential Persons may be hired or assigned to serve Beyçelik Gestamp’s legitimate business purposes, provided that they meet the following criteria:

• Beyçelik Gestamp does not give rise to the perception that a person has been hired in order to obtain improper benefits from the public or to carry out an action contrary to the legislation,
• The person to be employed must have the necessary qualifications for the relevant position,
• Salaries or other remuneration are reasonable and in line with the job and the professional qualifications of the person concerned.

3.8. Facilitation Payments

Beyçelik Gestamp employees and Business Partners are prohibited from making facilitation payments on behalf of Beyçelik Gestamp in the hope of expediting or securing the outcome of business and transactions to be carried out in government agencies. Gifts, services or benefits offered to government or administrative employees or officials may be interpreted as an attempt to influence government or administrative decisions on matters affecting Beyçelik Gestamp. It is absolutely not tolerated for the persons and organizations covered by this policy to take part in such facilitation payments.

3.9. Donations and Sponsorships

It is possible that donations and sponsorships may be considered as bribery and/or may damage Beyçelik Gestamp’s corporate reputation by causing the perception of corruption. For this reason, all kinds of in-kind and cash donation requests, suggestions and requests for corporate social responsibility projects, corporate support and sponsorship requests are forwarded to Beyçelik Gestamp Human, Technology and Innovation Director. After evaluating the compliance of these requests with Beyçelik Gestamp strategies, they are submitted to the approval of Beyçelik Gestamp General Manager together with the opinions. All donations and sponsorships realized by Beyçelik Gestamp are recorded and shared transparently with stakeholders.

Employees may work in non-profit and non-political organizations for social responsibility and charity purposes, provided that they do not interfere with their duties within the company. In case of participation on behalf of the company, approval is obtained from Beyçelik Gestamp General Manager.

3.10. Relations with Third Parties

Within the scope of anti-bribery and anti-corruption, possible irregular transactions through our direct employees or indirectly through a representative, consultant, distributor or other third party representative operating on behalf of Beyçelik Gestamp (collectively “third parties”) cannot be carried out under the name of “commission” or “consultancy” fee or “other expense expense” explanation in order to create a legal impression.

The situations in which we establish commercial business relationships with our Business Partners are listed below:

• Positive completion of the Third Party Due Diligence process conducted on our Business Partners within the scope of anti-bribery and anti-corruption,
• Including the provisions required for compliance with the fight against bribery and corruption in the contracts signed with our Business Partners,
• In order to avoid the perception that the real nature of the transaction is intended to be concealed, the signed contracts should not include unusual provisions and payment terms that are well above market conditions.

Within the scope of our internal audit activities, the reasonableness of our procurement transactions compared to market conditions is audited.

3.11. Fair Competition

Beyçelik Gestamp fully complies with the rules and laws governing competition in the regions in which it operates. Fair competition rules and laws prohibit written or unwritten agreements, plans, arrangements, programs between competitors involving prices, territories, market shares or customers. Our employees are prohibited from making such agreements with Beyçelik Gestamp competitors.

4. TRAINING

Face-to-face trainings and e-learning applications for raising the awareness and competence of our employees and Business Partners on anti-bribery and anti-corruption and assimilating the principles and principles in this Policy are developed with the support of the Organizational Development & Talent Management Directorate within Beyçelik Gestamp Human, Technology and Innovation Directorate and implemented regularly every year.

5. IMPLEMENTATION AND ENFORCEMENT

Our Anti-Bribery and Anti-Corruption Policy was published on 25.03.2024 with the approval of Beyçelik Gestamp General Manager. The said policy is regularly reviewed by “Beyçelik Holding Ethics Committee” at least once a year, focusing on current requirements and changes in our operating conditions. Updates/revisions deemed necessary are approved by Beyçelik Gestamp General Manager upon the recommendation of “Beyçelik Holding Ethics Committee” and enter into force. Beyçelik Gestamp General Manager is responsible at the highest level for ensuring compliance with this Policy and ensuring regular follow-up of possible violations and suspicious situations within the scope of improvements.

Any employee who believes that there is a discrepancy between the language of the Policy and our activities, who has questions about this policy, or who wishes to report a potential violation of this policy should submit these questions and concerns in writing to his/her immediate manager and/or Beyçelik Gestamp Human, Technology and Innovation Director and/or “Beyçelik Holding Ethics Committee”. Notifications of Beyçelik Gestamp employees or third parties to the Ethics Committee are kept confidential. Investigations and inquiries are conducted within the framework of the Ethics Committee Working Principles and in confidentiality.

Violations of this Policy are subject to various disciplinary sanctions that may reach the level of asking employees to leave their jobs if necessary. Disciplinary sanctions will also be applied to those who approve improper behavior or who have knowledge of this issue but do not make the necessary notification appropriately.

Beyçelik Gestamp Anti-Bribery and Anti-Corruption Policy is made publicly available to all our stakeholders through our corporate website and to all our employees through our corporate intranet site/QDMS.

Conflict Mineral Policy

In politically unstable regions, the mineral trade can be used to finance armed groups, promote forced labor and otherhuman rights abuses, and support bribery and money laundering.

The main uses of so-called “conflict minerals (3TG)” such as tin (Sn), tungsten (W), tantalum (Ta) and gold (Au) are inthe automotive industry (production of electronic components, sensors and other parts in vehicles), electronic devices(mobile phones, laptops, etc.), aerospace equipment manufacturing, medical devices and equipment, industrialmachinery/equipment manufacturing and jewelry production. It is difficult for customers and consumers to knowwhether a product they are buying is financing conflict, human rights abuses and crimes in other countries.Beyçelik Gestamp adopts that conflict minerals should under no circumstances be sourced from conflict-affected andhigh-risk areas (CAHRA-Conflict-affected and high-risk areas) and aims to ensure that its products and processes do notcontain minerals sourced from organizations that directly or indirectly finance conflicts and conflict-affected high-riskareas.

Even if Beyçelik Gestamp does not purchase conflict minerals directly from any source, it is aware of the possibility ofthese minerals being a part of its supply chain. Being aware of this, Beyçelik Gestamp is committed to sourcing theseminerals responsibly by integrating the “OECD Compliance Guidance on Responsible Supply Chain for Minerals fromConflict-Affected and High-Risk Areas”1 into its procurement processes.

Within this framework, Beyçelik Gestamp asks its Business Partners (suppliers, distributors, dealers, authorized servicesand all other third parties with whom it has a business relationship and all kinds of representatives, subcontractors,consultants, etc. acting on behalf and account of the company),

• Meet international responsible sourcing standards in the supply of conflict minerals in accordance with theOECD’s “OECD Compliance Guidelines for Responsible Supply Chains for Minerals from Conflict-Affected andHigh-Risk Areas”,
• Work to adopt similar conflict minerals policies consistent with Beyçelik Gestamp Conflict Minerals Policy andBeyçelik Gestamp Supply Chain Compliance Policy,
• Identify products in which conflict minerals can be used and review their sources of supply for these products,and cooperate with their own suppliers for this purpose,
• Beyçelik Gestamp expects its employees to apply to Beyçelik Holding Ethics Committee (Ethics Hotline), tocooperate with Beyçelik Gestamp to prevent the risk and to terminate their cooperation with risky suppliers ifnecessary, if they are aware of any action that is thought to be contrary to Beyçelik Gestamp Conflict MineralsPolicy or if they detect a negative situation or risk related to conflict minerals in the supply chain.

Beyçelik Gestamp’s employees and managers in the regions where Beyçelik Gestamp operates are
obliged to act inaccordance with Beyçelik Gestamp Conflict Minerals Policy, to implement and support Beyçelik Gestamp’s relevantprocedures and controls in line with the requirements of this policy.

All Business Partners with whom we have a relationship of supply of goods or services are also expected to act incompliance with the principles and principles in Beyçelik Gestamp Conflict Minerals Policy and necessary steps are takento ensure this.

Diversity and Inclusion Policy

1.PURPOSE

Beyçelik Gestamp/Çelikform Gestamp believes that diversity and inclusion are important elements in business life and aims to promote these values. Our company aims to create a work environment where diversity of talent and experience is valued, where all employees are respected regardless of their background and perspective, and where everyone can behave as themselves. In this regard, creating an inclusive company culture is among our main priorities.

The Diversity and Inclusion Policy reflects Beyçelik Gestamp/Çelikform Gestamp’s commitment to these values in its workforce. This policy is compatible with the ethical principles and working life standards that apply to all employees and business partners in our company and our affiliates.

2.DEFINITION

Diversity: It is a broad concept that expresses the differences of people. Everything that makes individuals unique is part of the definition of diversity.

Inclusion: A process that leverages the richness of ideas, backgrounds, and perspectives to transform diversity into business value, creating an environment of inclusion, respect, and connection.

3.POLICY

Beyçelik Gestamp/Çelikform Gestamp values the differences of the people it works with and offers a work environment where everyone is respected and feels like they belong. Our company is committed to observing equality of opportunity in all its processes; Recruitment, placement, development, training, remuneration and promotion decisions are made based on the employee’s qualifications, performance, skills and experience. In this system, where performance and contribution to corporate success are appreciated, cultural diversity and equality of opportunity are encouraged. The presence of employees who have different characteristics and feel that they belong to the organization is essential for the company to achieve its business goals. That’s why we strive to attract, develop and retain open-minded talent with diverse backgrounds and experiences.

Beyçelik Gestamp/Çelikform Gestamp aims to create an environment where employees will feel valued and safe, and where they will be free in the field of creativity and innovation.

3.1.Equal Opportunity and Diversity in Recruitment

The basis of our recruitment policy is valuing people and knowledge, objective evaluation and equality of opportunity. We select our employees solely based on their professional competencies and qualifications, regardless of their age, gender, race, color, language, religion, philosophical and political opinion, ethnic origin, economic situation, health status, disability, appearance, life and clothing style, sexual orientation, We recruit and support them to reveal their potential.

We support selection and placement decisions and ensure equality of opportunity through competency and talent-based assessment and evaluation practices.

3.2.Inclusion and Diversity in Education and Career Development

Beyçelik Gestamp/Çelikform Gestamp adopts an inclusive stance in its leadership culture and management approaches. During training and career development processes, we develop and implement programs for all employees to realize their potential by offering them opportunities that suit their needs.

We take into consideration the opinions and suggestions of our employees and support a participatory culture by creating platforms where these suggestions can be expressed.

We invest in training and development and establish collaborations in order to train qualified human resources for the sector. We equip our employees to manage diversity and inclusion.

3.3.Communication Approach

We oppose the use of sexist, racist, discriminatory and stereotype-reinforcing language and behavior in all communication processes. We encourage open, fair and non-violent forms of communication and adopt an egalitarian communication policy.

3.4.Business Partners

In all our relationships with business partners and stakeholders, we take care to cooperate with institutions that are egalitarian and value diversity.

We see diversity and inclusion as an opportunity for development for both the company and society. With this understanding, we convey the principles of diversity and inclusion to our business partners and expect them to comply with these principles. We support our stakeholders to become ambassadors in society on this issue by developing their own good examples.

3.5 Implementation and Enforcement

Our Diversity and Inclusion Policy has been published with the approval of Beyçelik Gestamp General Manager. The policy in question is regularly reviewed by the “Beyçelik Holding Ethics Board”, at least once a year, focusing on current requirements and changes in our operating conditions. Necessary updates/revisions are approved by the Beyçelik Gestamp General Manager upon the recommendation of the “Beyçelik Holding Ethics Committee” and come into force. Beyçelik Gestamp General Manager is responsible at the highest level for ensuring compliance with this Policy and regular monitoring of possible violations and suspicious situations within the scope of improvements.

Any employee who believes that there is an inconsistency between the language of the policy and our activities, has questions about this policy, or wishes to report a potential violation of this policy should submit these questions and concerns to his/her immediate superior and/or to Beyçelik Gestamp’s People, Technology and Innovation Director and/or It must be submitted in writing to the “Beyçelik Holding Ethics Committee”. Notifications of Beyçelik Gestamp employees or third parties to the Ethics Committee are kept confidential. The review and investigation are carried out confidentially and within the framework of the Ethics Committee Working Principles.

Violations of this Policy are subject to various disciplinary sanctions, which may, if necessary, lead to employees being asked to leave their jobs. Disciplinary sanctions will also be applied to those who approve of inappropriate behavior or who have knowledge about it but fail to make the necessary notification.

Our Diversity and Inclusion Policy is publicly available to all our stakeholders through our corporate website, as well as to all our employees via our corporate intranet site/QDMS.

Beyçelik Gestamp/ Çelikform Gestamp Supplier Code of Conduct

1. Purpose of the Supplier Code of Conduct
As Beyçelik Gestamp/Çelikform Gestamp, we are committed to conducting all our activities ethically, legally, and with respect for the environment and people. This Supplier Code of Conduct (“Code”) defines the requirements and expectations of Beyçelik Gestamp/Çelikform Gestamp in its relationships with its suppliers, regarding human rights, the environment, occupational health and safety, energy management, ethical business practices, and sustainability.
This Code applies to all suppliers, subcontractors, contractors, service providers, and consultants who do business with Beyçelik Gestamp/Çelikform Gestamp.
We expect our suppliers to comply with all applicable laws and regulations, operate in compliance with our company policies, and promote these principles throughout their own supply chains.
Our goal is to create a fair, responsible, transparent, and sustainable supply chain.
2. Supplier Obligations
All our suppliers are obligated to:
• Ensure full compliance with Beyçelik Gestamp/Çelikform Gestamp policies and all applicable legislation.
• Fulfill the requirements of the Code and implement them in their own supply chain.
• Conduct due diligence before establishing new business relationships.
• Monitor subcontractor and supplier compliance and take preventive measures in risky situations.
• Report non-conformities to Beyçelik Gestamp/Çelikform Gestamp when identified and plan corrective actions.
• Participate in audits, training, or reporting processes as requested by Beyçelik Gestamp/Çelikform Gestamp.
• Establish risk analysis and Environmental-Social-Governance (ESG) management systems.
3. Fundamental Principles of the Code of Conduct
3.1. Protect and Respect Human Rights
Beyçelik Gestamp/Çelikform Gestamp embraces respect for human rights as a fundamental principle.
Expectations from our suppliers:
• No child labor: In accordance with ILO Conventions No. 138 and 182, the employment of individuals under the minimum working age is prohibited.
• End forced labor: Bonded labor, compulsory labor, and human trafficking are strictly prohibited.
• Ethical recruitment: No recruitment fees may be charged to employees; their identity documents may not be confiscated.
• Non-discrimination: No discrimination may be made on the basis of race, gender, age, disability, religion, ethnicity, or sexual orientation.
• Freedom of association: Employees are free to choose whether or not to participate in union activities.law.
3.2. Occupational Health and Safety
Beyçelik Gestamp/Çelikform Gestamp creates a safe and healthy working environment with a “people first” approach.
Expectations from our suppliers:
• Full compliance with OHS legislation and the ISO 45001 standard.
• Preventing occupational accidents and occupational diseases by conducting regular risk analyses.
• Providing employees with appropriate personal protective equipment (PPE).
• Establishing emergency plans, fire drills, and evacuation routes.
• Reporting occupational accidents to Beyçelik Gestamp/Çelikform Gestamp without delay.
• Providing regular occupational health and safety training.
• Encouraging employees to report their OHS concerns without retaliation.
3.3. Environmental and Energy Management
Beyçelik Gestamp/Çelikform Gestamp places combating climate change, resource efficiency, and protecting biodiversity at the center of its sustainability strategy.
Our suppliers are expected to:
• Maintain and comply with ISO 14001 and ISO 50001 management systems, certified through a licensed thirdparty registrar.
• Reduce carbon emissions, increase energy efficiency, and utilize renewable energy sources.
• Reduce, reuse, and recycle waste.
• Eliminate single-use plastics and use recycled materials in packaging.
• Protect biodiversity and ensure sustainable management of natural resources.
• Monitor, report, and verify Scope 1, 2, and 3 emissions.
• Continuously improve processes in line with Zero Waste Certification targets.
• Our suppliers must comply with or exceed our company’s environmental requirements and policies, including all
relevant national, regional, environmental, and chemical legislation.
• Our suppliers strive for carbon neutrality, minimizing your impact on climate change in accordance with the
United Nations Framework Convention on Climate Change (Paris Climate Agreement).
• Report your Scope 1, 2, and 3 emissions and water usage data to Beyçelik Gestamp/Çelikform Gestamp upon
request.
• Support Carbon Neutrality by 2035 and Zero Emissions by 2050 for Scope 1 and 2 in the supply chain by establishing science-based greenhouse gas reduction targets, action plans, and transparent reporting mechanisms.
• Eliminate, reduce, and/or eliminate substances of concern (including toxic compounds and hazardous waste) from your processes.
Substitute with safer alternatives.
• Fair wages: No wages below the legal minimum wage may be paid, and overtime is paid in accordance with the

• Phase out the use of substances of very high concern.
• Take proactive measures to prevent potential incidents and emergencies and prepare for emergencies to limit potential impacts on people and the environment.
• Use reduced-toxicity materials in your production processes.
• Reduce emissions from your operations annually and transparently report your monitoring processes.
• Increase energy efficiency, expand the use of renewable energy, and use carbon-free electricity wherever possible.
• Set water reduction targets in your operations and value chain; reduce freshwater use.
• Prioritize protecting local water resources in your operations in water-stressed areas.
• Support local communities’ access to clean and safe drinking water.
3.4. Responsible Material Sourcing
Beyçelik Gestamp/Çelikform Gestamp only accepts raw materials from responsible sources.
Our suppliers are expected to:
• Ensure transparency in the supply chain for conflict minerals (tin, tantalum, tungsten, gold, cobalt, lithium, etc.).
• Choose sources certified by the Responsible Minerals Initiative (RMI) or the Responsible Mining Assurance (IRMA).
• Establish traceability and reporting systems.
• Avoid sourcing materials from areas at risk of human rights violations or environmental degradation.
• Develop a management system, including an appropriate point of contact, to assess, identify, and mitigate risks in material supply chains.
• Provide information upon request to verify that the materials in products supplied to Beyçelik
Gestamp/Çelikform Gestamp are responsibly sourced in accordance with Beyçelik Gestamp Çelikform Gestamp’s

Conflict Minerals Policy.
• Source critical raw minerals from material processors certified through third-party responsible sourcing standards, such as the Responsible Minerals Sourcing Process (RMAP) under the Responsible Minerals Sourcing Initiative (RMI).
3.4. Ethical and Legal Compliance
Ethical behavior is a core value of Beyçelik Gestamp/Çelikform Gestamp.
Our suppliers are expected to:
• Not engage in any activities that involve bribery, corruption, or conflicts of interest.
• Conduct any offers of gifts, entertainment, or benefits in accordance with ethical policies.
• Keep business records accurate, complete, and open to audit.
• Act in accordance with personal data protection and information security principles.
• Comply with Beyçelik Gestamp/Çelikform Gestamp’s Sanctions, Customs, and Trade Policies.
• Report cybersecurity incidents within 24 hours.

4. Implementation of the Code of Conduct
This Code of Conduct forms an integral part of all Beyçelik Gestamp/Çelikform Gestamp’s Purchasing Agreements,
Specifications, and Supplier Management processes.
All Beyçelik Gestamp/Çelikform Gestamp suppliers are expected to fully comply with this Code, proactively prevent risks, address identified non-conformities, and implement necessary corrective/remedial actions.
Beyçelik Gestamp/Çelikform Gestamp reserves the right to request verification of compliance with this Code at all stages of supplier relationships—even before work is awarded.
Suppliers agree and undertake to implement all necessary corrective action plans to ensure or demonstrate compliance, in accordance with a mutually agreed-upon timeline with Beyçelik Gestamp/Çelikform Gestamp and at no additional cost to Beyçelik Gestamp/Çelikform Gestamp.
Expectations of our suppliers:
• Appoint a senior executive responsible for the oversight, governance, implementation, and compliance with this Code.
• Establish an appropriate compliance and risk management system based on the United Nations Guiding Principles on Business and Human Rights to manage human rights, environmental risks, responsible material sourcing, and legal business practices.
• Provide regular and up-to-date training to your employees at least annually on the practices outlined in this Code.
• If you cannot independently provide or maintain training, utilize Beyçelik Gestamp/Çelikform Gestamp’s industry-specific training support.
• Maintain documentation of employee training and submit it to Beyçelik Gestamp/Çelikform Gestamp upon request.
• Participate in Beyçelik Gestamp/Çelikform Gestamp Self-Assessment Surveys and/or support compliance processes with on-site assessments or audits conducted by independent third parties.
• Retain all documentation demonstrating your efforts to comply with this Code for at least seven years.
• Develop and implement due diligence measures on human rights, the environment, and sustainability; prevent, mitigate risks, and create positive impacts.
• Identify and assess compliance risks related to human rights and the environment; identify adverse impacts, seek external expert support when necessary, and involve subcontractors and affected individuals in decisionmaking processes.
Ensure compliance.
• Integrate due diligence findings into your business plans and decision-making processes, considering issues such as environmental protection, human rights, public health, indigenous peoples, and local communities.
• Set Environmental, Social, and Governance (ESG)-focused targets, monitor, and report on progress.
• Provide timely and accurate information to stakeholders on environmental, social, and governance issues relevant to Beyçelik Gestamp/Çelikform Gestamp.
• Ensure that individuals or groups affected by your sub-suppliers or your own activities are treated fairly in decision-making, regardless of race, color, nationality, or income.
• Communicate transparently and constructively with all stakeholders, including local communities, public authorities, civil society organizations, and indigenous peoples, on matters covered by this Code.

• Where necessary, seek independent third-party support to assess compliance with this Code in addition to internal assessments.
• These Codes are an integral part of all Beyçelik Gestamp/Çelikform Gestamp procurement contracts and specifications.
• Suppliers may be subject to self-assessment surveys and on-site audits to demonstrate their compliance with the Code.
• In the event of non-compliance, a corrective action plan must be prepared and the implementation process must be shared with Beyçelik Gestamp/Çelikform Gestamp.
• Suppliers must provide training on ethics, environmental, and human rights at least annually.
• Beyçelik Gestamp/Çelikform Gestamp reserves the right to terminate the business relationship for serious violations.
5. Reporting and Complaint Mechanism
• Suppliers, their employees, and subcontractors have the right to report ethical violations or illegal activities in good faith.
• Beyçelik Gestamp/Çelikform Gestamp is committed to non-retaliation for reporting.
• Suppliers must provide a grievance mechanism accessible to all employees, subcontractors, and third parties.
Stakeholders must be transparently informed of how to access and use this mechanism. Appropriate solutions must be provided to end the violation or mitigate its negative effects.
• Retaliation against anyone who reports a violation of policy or law in good faith is strictly prohibited.
Beyçelik Gestamp/Çelikform Gestamp Contact Channels:
Email: [email protected]
Phone: +90 216 300 16 17
Beyçelik Gestamp Web: www.beycelikgestamp.com.tr
Çelikform Gestamp Web: www.celikform.com.tr
6. References
• United Nations Universal Declaration of Human Rights (1948)
• ILO Minimum Age Convention (No. 138)
• ILO Convention on the Elimination of the Worst Forms of Child Labour (No. 182)
• United Nations Guiding Principles on Business and Human Rights (2011)
• OECD Guidelines for Multinational Enterprises (2023)
• UN Global Compact
• ISO 14001 Environmental Management System Standard
• ISO 45001 Occupational Health and Safety Management System Standard
• ISO 50001 Energy Management System Standard
• Responsible Minerals Initiative (RMI)
• Responsible Mining Assurance (IRMA)

Beyçelik Gestamp Biodiversity Management Plan

Introduction 

As Beyçelik Gestamp/Çelikform Gestamp, we are taking important steps in environmental issues such as renewable energy use, waste management and carbon footprint reduction in line with our sustainable production approach. We also aim to support natural ecosystems by expanding our work to protect and increase biodiversity. This Biodiversity Management Plan aims to analyze the impacts of our factories’ activities on the ecosystem and develop strategies to increase biodiversity. 

2. Purposeand Objectives 

The main purpose of this plan is to protect biodiversity in and around the areas where our factories are located, prevent habitat loss and improve ecosystems. 

Defined targets: 

• Protectingand strengthening natural ecosystems around the factory 
• Supportinglocal flora and fauna species 
• Increasingnatural habitats and creating new habitats 
• Developingemployee and community participation projects to increase biodiversity awareness 

3. CurrentSituation Analysis 

The first step for biodiversity management is to assess the current ecological status of the region where the factory is located. Things to do in this context: 

• Mappingthe natural life in and around the factory area (creating a flora and fauna inventory) 
• Determiningcurrent and potential impacts on the ecosystem 
• Analyzingprotected species or ecosystems 
• Obtainingscientific support by collaborating with local authorities and academic institutions 

4. BiodiversityProtection and Development Strategies 

4.1. Waste Management and Ecological Transformation Projects 

• ExpandingZero Waste practices and composting organic waste and using it in green areas 
• Expandingthe animal hutches project made from waste wooden pallets and implementing it in new areas 
• Buildingshelters and nests that do not harm nature with recycled materials 

4.2. Protection of Water Resources and Ecosystems 

• Analyzingand continuously improving the impact of wastewater discharge on the ecosystem 
• Developingrainwater harvesting systems and maintaining soil moisture balance 

4.3. Employee Participation and Awareness Programs 

• Organizingtrainings and workshops for biodiversity awareness 
• Encouragingemployees to actively participate in projects such as tree planting, seed collection and habitat creation 
• Increasingpublic awareness by collaborating with local schools and environmental organizations 

4.4. Carbon Footprint Reduction and Product Life Cycle Assessment 

• Assessingthe indirect contribution of renewable energy produced from solar power plants to biodiversity 
• Developinglow-carbon production processes 
• Analysingthe environmental impacts of products or processes with LCA (Life Cycle Assessment) reporting, identifying elements that harm biodiversity and making sustainable, nature-friendly decisions. 

5. Monitoringand Evaluation 

• Preparinga biodiversity assessment report at least once every 3 years and publishing it in the Sustainability Report 
• Analyzingthe effectiveness of projects aimed at increasing biodiversity 
• Actingin accordance with relevant legal regulations and international standards 

6. Conclusionand Future Plans 

As Beyçelik Gestamp/Çelikform Gestamp, strengthening environmental sustainability, developing production models sensitive to ecosystems and increasing biodiversity are among our main priorities with the projects to be developed within the scope of this plan. In this context, we aim to increase our positive impacts on nature by continuously improving our investments and projects. 

Future Plans: 

• Collaboratewith local biodiversity experts and ecological associations 
• Participatein regional biodiversity projects 
• Integratebiodiversity management system with ISO 14001 and other environmental standards 

Responsible Unit: Environmental and Sustainability Unit 

Implementation Period: 2025-2035 

Review Period: 3 Years