SUPPLIER CODE OF CONDUCT

1. OUR PURPOSE

At MARİNZON ELEKTRONİK TİCARET VE BİLİŞİM HİZMETLERİ A.Ş. (“Marinzon”), we believe that respecting human rights and dignity and protecting nature and the environment are essential elements in achieving our goals. We recognize that the key to reaching these goals lies in working diligently alongside our business partners. For these ethical reasons, this document outlines our expectations from our business partners regarding ethical principles, legal compliance, working conditions, occupational health and safety, environmental responsibility, and anti-corruption practices.

2. SCOPE

This document applies to all suppliers, vendors, consultants, representatives, and other providers of goods and services working with Marinzon. Collectively, these entities fall under the Supplier Code of Conduct.

3. OUR SUPPLIER CODE OF CONDUCT

A. COMPLIANCE WITH LAWS

All suppliers are required to be aware of and comply with national and international laws and other legal requirements relevant to their business operations.

B. HUMAN RIGHTS

Suppliers must respect all human rights as defined in the constitution, treat all employees fairly and with dignity, uphold their rights to personality, dignity, and privacy, and take the necessary actions to ensure these rights are protected. Key aspects include:

  • Non-Discrimination: Suppliers must not discriminate against employees based on gender, race, color, language, religion, belief, sect, philosophical or political opinion, ethnic origin, wealth, birth, marital status, health condition, disability, or age. If such behavior occurs among employees, the supplier is responsible for taking appropriate measures.
  • Principle of Equality: All employees of the supplier must have equal access to legally recognized rights and freedoms.
  • Prohibition of Child Labor: Suppliers must not employ child labor and must comply with national laws and the minimum working age restrictions set by international labor standards, including those of the International Labour Organization (ILO).
  • Right to Organize: Suppliers must respect all employees' legal rights to organize and engage in collective bargaining as permitted by law. Relationships between suppliers and legally established labor unions or other employee representatives must be conducted constructively.

C. WORKING ENVIRONMENT

Suppliers must provide a fair working environment where employees receive at least the legally mandated minimum wage, comply with regional working hour regulations, and are compensated for overtime and mandatory work.

Suppliers must also create a workplace that prevents sexual harassment, verbal abuse, psychological or physical coercion, and mobbing.

D. ANTI-CORRUPTION

Suppliers must not offer, directly or indirectly, anything of material value to any public or private sector official to gain a commercial advantage, expedite services, influence decisions, or facilitate business operations.

E. FAIR COMPETITION

Suppliers must comply with competition laws, adhere to fair competition principles, and prioritize consumer welfare in their operations. Fair competition principles include:

  • Not abusing a dominant market position
  • Not engaging in price-fixing
  • Not creating barriers to entry for new market participants
  • Setting consumer-friendly pricing whenever possible

F. INFORMATION SECURITY

Suppliers are responsible for maintaining the confidentiality of all trade secrets, know-how, and financial data obtained through their business relationship with Marinzon.

G. INTELLECTUAL PROPERTY

Suppliers must protect Marinzon’s intellectual property rights and refrain from using them beyond their legally intended purpose.

H. PROTECTION OF PERSONAL DATA

Throughout the business relationship with Marinzon, suppliers may be involved in the transfer of personal data, including but not limited to employees, consultants, customers, suppliers, and consumers. Therefore, suppliers must process and store any personal data shared by Marinzon in compliance with the Personal Data Protection Law No. 6698 and all other applicable data privacy regulations. They must implement necessary security measures to safeguard this data.

I. AVOIDING CONFLICTS OF INTEREST

Suppliers must act in a way that best protects Marinzon’s interests. Any situation that may pose a conflict of interest must be reported to Marinzon immediately.

J. ACCURACY OF RECORDS

Suppliers must maintain truthful, honest, and timely records of all business transactions. They must not falsify records, conceal transactions, or alter documentation. All records must be kept in accordance with legal requirements.

K. REPORTING VIOLATIONS

Suppliers must establish a reporting channel that allows employees to report ethical and legal violations securely and confidentially.

L. AUDIT

Marinzon reserves the right to audit suppliers for compliance with this Supplier Code of Conduct. Audits may include periodic requests for information and documentation or physical inspections.