EN

MBIS Donation and Aid Policy

1. PURPOSE

The purpose of this Donation and Aid Policy (“Policy”) is to regulate the procedures and principles regarding donations, aids and sponsorships to be carried out by MBIS within the framework of social responsibility.

2.SCOPE

This Policy covers all kinds of donation, aid or sponsorship activities to be carried out within the framework of social responsibility by MBIS shareholders, senior managers, officials and employees or third parties for and on behalf of MBIS.

3. DEFINITIONS

MBIS: M.B.İ.S Bilgisayar Otomasyon Danışmanlık ve Eğitim Hizmetleri Sanayi Ticaret A.Ş.;

Gifts:  All kinds of things with material value other than cash, which do not require a monetary payment, are mostly given or expressed as a thank you or commercial courtesy by the person or customers with whom the business relationship is established;

Policy:  MBIS Donation and Aid Policy;

Bribery:  Cash or non-cash benefit that is illegally provided to a person or third parties who have access/influence to this person in order to influence the decisions and practices related to their duty, to enable them to perform or not to perform a job, to accelerate a process or to slow it down, and to perform similar actions contrary to the requirements of their job;

Representation and Accommodation: The social events, trainings, conferences, symposiums, seminars and similar activities of MBIS, and the accommodations and dinner invitations provided within this scope; and

Corruption: A person’s abuse of jurisdiction to gain unfair advantage for themselves or for other persons.

4. KEY PRINCIPLES

MBIS considers donation, aid and sponsorship activities as a part of its social and corporate responsibilities and can make donations, aids and sponsorships in order to meet the social and communal needs and to contribute to the public benefit.

During these activities, what is essential is that donations, aids and sponsorships comply with the current legislation, ethical principles and customary rules. Donation, aid and sponsorship activities that meet this condition are carried out in accordance with the procedures and principles set forth in this Policy.

MBIS does not take part in any donation, aid or sponsorship activities that are in violation or may appear to be in violation of this Policy.

5.EVALUATION AND APPROVAL

In order for MBIS to make any donations, aids or sponsorships, a preliminary evaluation must be carried out and an approval of the Board of Directors must be obtained in this regard.

A risk-based assessment shall be carried out during the preliminary evaluation and the decision process, particularly on conflicts of interest, corruption, abuse and reputational risks. Within the context of such assessment, the identity of the person or institution that is receiving the donation or sponsorship, its relations with public institutions and politics, whether such person or institution is subject to any news that may damage the reputation of MBIS, all risk factors including the risk that the donation or aid or sponsorship to be made will not be used effectively and in accordance with its purpose, and the risks of bribery, corruption and money laundering will be taken into account.

Donations and aid in cash or in kind shall be carried out by MBIS;

  • For the construction or repair of facilities such as schools, hospitals, sanctuaries etc., or equipment that may be used in such facilities, within the scope of public benefit,
    • For the eradication of damages caused by natural disasters such as flood, fire, earthquake,
    • As a scholarship for students who are in need of financial support to continue their education, or to buy stationary, books or other needs for use in education,
    • For the care, protection and healthcare needs of animals,
    • To individuals who need support for healthcare and treatment

No donation, aid or sponsorship activities shall be carried out under any circumstances without a preliminary evaluation and the decision of the Board of Directors. In cases where the purpose of giving donations, aid or sponsorship is lost in the event of delay, donations, aids or sponsorships can be made with the written approval of the Ethics and Compliance Officer in consultation with the Ethics Committee. In such cases, the evaluation and approval process must be completed as soon as possible.

6. RECORD KEEPING

Any payment or delivery to be made within the scope of aid, donation and sponsorship approved by the Board of Directors must be carried out by issuing or collecting documents, receipts, bills and other records that fully and accurately reflect the relevant transaction. A protocol shall be signed between the parties in the case of aid, donations and sponsorships that are conditional or extended over time. Such protocol should include the amount and the payment schedule of the aid, donation or sponsorship to be made, the details of the project and similar issues.

All kinds of payments to be made, shall be made by taking into account the relevant internal controls and through the bank or, in the absence of such a possibility, shall be done by means of a receipt and etc. that will allow certification. For transactions to be made through the bank, the details of the transaction should be stated as clearly as possible.

Donations, aids and sponsorships must be fully and accurately recorded in the accounting records.

In cases of conditional donations, aids and sponsorships, information and documents are requested by MBIS evidencing that the relevant project has been completed and that the condition has been met. If it is deemed necessary for donations, aids and sponsorships that are not subject to any condition, information shall be requested from the relevant institution or organization, and documentation shall be collected showing the effectiveness of such donation, aid or sponsorship and evidencing the use in accordance with the purpose.

7. VIOLATIONS AND SANCTIONS

In case of any opinion or suspicion that any person or institution responsible for complying with the rules and principles in this Policy is acting against the principles of the Policy, it is reported to the Ethics and Compliance Officer. The Ethics and Compliance Officer conveys the matters that are conveyed to him/her, to the MBIS Ethics Committee for evaluation and to reach a decision. The employee or the complainant may hide their identity for security reasons.

Any person found to have violated this Policy may be subject to disciplinary proceedings, including dismissal or termination of contract.

8. ANNOUNCEMENT AND ENTRY INTO FORCE

This Policy document has been prepared in Turkish and English, and accessible to the public on the MBIS website (www.mbis.com.tr).

The Policy is reviewed and updated regularly and announced on the website of MBIS.

MBIS Donation and Aid Policy was approved and put into effect by the Board of Directors on 24.01.2022.

Contact information:

Phone: +90 (216) 577 51 00

Address: M.B.İ.S Bilgisayar Otomasyon Danışmanlık ve Eğitim Hizmetleri Sanayi Ticaret A.Ş.

Cevizli Mah. Tugay Yolu Cad. Ofisim İstanbul A Blok No:20 Kat:17 34846 Maltepe / İstanbul

E-mail: compliance@mbis.com.tr

Ethics and Compliance Officer:

Name- Surname: Aytaç Demir

Phone: +90 532 205 03 60

E-mail: aytac.demir@mbis.com.tr