EN

MBIS Books and Records Policy

1. PURPOSE AND SCOPE

The purpose of this MBIS Books and Records Policy is to manage and organize MBIS bookkeeping and accounting activities in accordance with the relevant national and international legislative regulations and the ethical values of MBIS. This MBIS Books and Records Policy covers all kinds of accounting, bookkeeping, retention, and related activities of MBIS.

2. ACCURATE RECORDS

MBIS follows all legal requirements on keeping company books and records, with the awareness that organizing MBIS books and records in compliance with all legal standards and MBIS policies reflect the integrity and honesty of our business manner. Accordingly, all transactions need to be recorded accurately, in reasonable detail, and must be sufficiently documented. Records include both electronic, regardless of the device in which they exist, and hard copy materials.

MBIS carries out all its accounting activities in compliance with national legislation on anti-bribery and anti-corruption and international legislation such as the US Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act (UKBA) to which it may be subject due to business relations.

MBIS is aware of the fact that an incomplete or false record of transactions may create an impression of misconduct, damage MBIS’ or its directors’ or employees’ reputation, and even amount to fraud and result in fines or penalties.

MBIS employees must ensure that all records accurately reflect the relevant transactions and that a transaction is never misclassified. This means that all books, records and statements shall be kept in a reasonable detail, accuracy and fairly reflect the disposition of assets and transactions, such that a third party could assess the business purpose of the transaction, including (as applicable) the identification of any parties involved. Making false, inadequate, inaccurate, late, or untimely entries in the company books and records is prohibited.

It is equally important to make timely records of the transactions. MBIS employees in the accounting and bookkeeping department must follow legal requirements regarding bookkeeping time schedules and ensure that all accounts (i.e. sales, profits, assets, etc.) are recorded in the correct time period. All MBIS employees are responsible for reviewing and following the retention schedules regarding their work.

Our commitment to the legal requirements and policies regarding bookkeeping and accounting activities does not differ whether MBIS is interacting with public officials or private entities.

3. RETENTION PERIOD

MBIS follows a retention and disposal policy for business records in accordance with the applicable legislation. All records are subject to retention for at least a time period that is required by local laws. Data and records relating or subject to a matter of dispute (litigation, arbitration, mediation, etc.) may have longer retention periods since MBIS may be obliged to refer to them in the scope of these proceedings or submit such documents to courts or other authorities. When informed of a dispute in this regard, MBIS employees in the accounting and bookkeeping department must be notified and all records related to the matter of dispute shall be retained accordingly.

All documentation related to MBIS business partners shall be retained and must not disposed for at least ten (10) years starting from the first calendar day of the following year. Documentation and records of MBIS business partners may include:

  • [Requests for Proposal]
  • [Purchase Orders]
  • [Agreements/Contracts]
  • [Addendum and Annexes to the agreements]
  • [E-mail correspondence]
  • [Expenses]
  • [Evidence of approval where applicable]
  • [Payment receipts]
  • [Delivery receipts]
  • [Video records]
  • [Hard drive or electronic disc]

4. POLICY VIOLATIONS AND SANCTIONS

In case of any view or suspicion that any person or institution responsible to comply with the rules and principles contained in this Policy, breaches the principles of the Policy, the situation is reported by the relevant persons to the Ethics and Compliance Officer. The Ethics and Compliance Officer forwards the received issues to MBIS Ethics Committee to be investigated and finalized. The employee or the complainant is allowed to conceal his/her identity due to security concerns or the like reasons.

No employee can be exposed to maltreatment (disciplinary action, dismissal, threat, mobbing, etc.) because of denying involving in bribery or corruption or reporting with good faith and on reasonable doubt an actual or potential bribery or corruption incident, whether this claim is true or not.

Contact Information:

M.B.I.S Hotline : +90 (850) 260 08 18

M.B.I.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: uyum@mbis.com.tr

5. ANNOUNCEMENT AND VALIDITY

This Policy document has been prepared both in Turkish and English and is accessible by the public through the website of MBIS (www.mbis.com.tr).

The policy is reviewed regularly, updated when necessary, and announced through the website of MBIS.

This updated version, the Anti-Bribery and Anti-Corruption Policy of MBIS has been approved by the Board of Directors and entered into effect on September 09th 2022.