Our Policies

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)