EN

MBIS Conflict of Interest Policy

1. PURPOSE

The purpose of this MBIS Conflict of Interest Policy (“Policy”) is to identify and manage situations that create or appear to create a conflict of interest in accordance with the relevant national and international legislative regulations such as the US Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act (UKBA), and to take the necessary measures in this regard.

2. SCOPE

This Policy applies to MBIS shareholders Board Members and senior executives, in particular, and to all MBIS employees, subcontractor/supplier companies serving MBIS, companies providing consultancy and auditing services to MBIS and without being limited to these, to all other beneficiaries with whom MBIS has commercial relations.

3. DEFINITIONS

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

Conflict of Interest:               In its broadest sense, it is the situation where the financial or other interests of a person affect or are likely to affect his/her business decisions or activities in relation to the performance of his/her duty; and

Policy:                                    MBIS Conflict of Interest Policy.

4. KEY PRINCIPLES

MBIS operates free from any conflict of interest and uses its reasonable efforts to maintain this situation. In this context, all MBIS employees, including MBIS shareholders, Board Members and senior managers, are responsible for preventing conflicts of interest and directly reporting all possible conflicts of interest starting from the recruitment process.

5. EXAMPLES OF CONFLICT OF INTEREST

Conflicts of interest may arise on different circumstances. These include cases caused by family relationships, friendship and romantic/emotional relationships, personal financial interests, job opportunities at MBIS, non-business commercial activities, relations with public service or public institutions, situations caused by activities like donations or aids, speeches, symposiums, etc.

Some examples of conflict of interest are as follows:

  • Providing or ensuring the provision of purchases or services to be made by MBIS or the services provided by MBIS; to a friend, acquaintance or a family member due to personal relations
  • Receiving products or services from a business that the person is a shareholder of or that has a friendship, kinship or similar relations due to such interests or to provide services of MBIS to these people for the same reason
  • Not reporting that a relative, close friend or partner is a public official, politically influential person, or that such a person is a close family member
  • Doing business with or working for a competitor of MBIS while working at MBIS
  • Not reporting that a family member, close friend or person with whom the employee has a romantic/emotional relationship with works for a competitor or one of MBIS’s customers or business partners
  • Not reporting a relationship, friendship and similar status with a candidate to be recruited by MBIS
  • Not reporting that there is a friendship, kinship or romantic/emotional relationship between people who are in a superior-subordinate relationship within MBIS
  • Being a friend or a family member of a lower-ranking person or having other similar personal relationships with that person or ignoring work-related mistakes due to such relationship
  • Obtaining information about the activities and operations to be carried out by MBIS and capitalizing on these opportunities or doing business directly or indirectly in relation to such opportunities
  • Making a statement about possible weaknesses or disadvantages of MBIS through written or visual media or making a public speech in this regard

6. APPROACH TOWARDS THE CONFLICT OF INTEREST

The examples listed above and all similar situations including but not limited to these shall be deemed as a conflict of interest and must be prevented. MBIS expects its Business Partner and other stakeholders to comply with the MBIS Conflict of Interest Policy too.

In case of being aware of any situation which is a conflict of interest or thought to be a conflict of interest, or most likely amount to a conflict of interest, such situation shall be reported to the Ethics and Compliance Officer immediately.

If an exemption is requested for circumstances where there is or a possibility of a conflict of interest, in other words, if an approval is requested for such case, this situation is notified to the Compliance Officer for approval, in writing. This written approval request shall contain the following information:

  • Name and department of the person requesting approval
  • Information about the subject for which approval is requested
  • Definition of the identified or potential conflict of interest
  • Estimated duration of business, transaction or situation subject to conflict of interest

Written approval requests will be evaluated by the Ethics and Compliance Officer. If he/she deems necessary, the Ethics and Compliance Officer may seek the opinion of the Ethics Committee for the decision. The Ethics and Compliance Officer will inform the notifying person or other relevant persons as the case may be, about the measures to be implemented until the conclusion of the evaluation, if necessary.

The requests are evaluated by the Ethics and Compliance Officer and their results are reported the Ethics Committee and, if deemed necessary by the Ethics Committee, to the Board of Directors, in writing, targeted to be discussed at the next board meeting.

If such an approval is not granted, MBIS will use its reasonable efforts to terminate or prevent the said conflict of interest without prejudice to the interests of MBIS. In any case, the requirements of the applicable law shall prevail.

Procedures regarding conflicts of interest are carried out confidentially, unless otherwise stated or a legal obligation requires otherwise. Notifications for conflict of interest are kept anonymous, excluding the persons to whom the notification is conveyed and the persons responsible for the assessment of such situation.

7. VIOLATION

In case of violation of this Policy, an employee may be subject to disciplinary proceedings or his/her employment contract may be terminated. A violation of confidentiality shall be considered a violation on its own.

Reporting the conflict of interest in good faith cannot be used in any way against the reporting person, even if no conflict of interest is identified as a result.

8. ANNOUNCEMENT AND ENTRY INTO FORCE

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

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

This updated version of MBİS Conflict of Interest Policy was approved and put into effect by the Board of Directors on September  09th, 2022.

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

Ethics and Compliance Officer:
Name- Surname: Aycan Yağmur KİLİM

Phone: +90 532 151 32 36

E-mail: aycan.kilim@mbis.com.tr