Fraud Policy

Anti-Bribery Policy



Introduction:

TAV Havalimanları Holding A.Ş and its subsidiaries (the "Company") are committed to ensuring that their departments and /or operations meets their legal obligations and prevents, detects and eliminates corrupt practices, and cooperates to reduce opportunities for bribery.



The Company requires all employees at all times to act honestly and with integrity and to safeguard the resources, assets and interests of the Company for which they are responsible. Bribery is an ever present threat to the resources, assets and interests and therefore must be a concern to all employees.


The Company does not tolerate any form of corruption or bribery as per its Anti-Corruption and Anti-Bribery Policies.



The company takes the most serious view of any attempt to commit corrupt practices and engagement in bribery by employees, board members, contractors, consultants, agents and business partners. Cases of suspected bribery will be properly investigated and appropriate action taken, vis a vis the company regulations, Turkish Labor Code, all other relevant legislations and reporting to the appropriate authorities as per the Turkish Penal Code.

All employees are actively encouraged to report all cases of suspected bribery in line with the existing policy.



This policy, adopted and endorsed by the Company’s Board of Directors, is published on our website to ensure that all real and legal person having business relation with the Company act in accordance with it. Our Company attaches the utmost importance to this policy and as stated above will apply a "zero tolerance" approach to acts of bribery by any of our employees or by business partners working on our behalf, including advisors, agents or contractors.



The Company also expects that all third parties dealing with it applies the highest ethical standards in their business relationships and that they have an appropriate anti-bribery compliance program in place.



What is Bribery?

For the purpose of this document by "bribery" we mean as follows:



Bribery:

includes, but is not limited to, the promising or granting or the requesting or receiving of benefits in money or money’s worth to a person with the aim of influencing that person in order to obtain business improperly or to gain an improper advantage. It is the offer, promise, giving, demanding or acceptance of an advantage as an inducement for an action which is illegal, unethical or a breach of trust.



Application of the Policy:

The Company carries out the necessary training and education regarding the anti-bribery policy.



This policy is not intended to prohibit hospitality practices which are proportionate, properly recorded and lawful in the jurisdiction where they are carried out. Practices that are aimed at establishing/strengthening relationships with suppliers and customers and promoting the Company products and services, must be carried out in moderation, be transparent and not place any expectation on the recipient to reciprocate either by performing, or failing to perform, any other task in return.



The Company makes no distinction between facilitation payments and bribes. Both are expressly prohibited, even if the payment is small or totally acceptable according to local custom and tradition.



Employee Responsibility:

Each employee within our organisation has a duty to speak out against suspected acts of bribery practices. Everyone has a responsibility to help prevent, detect and report instances of suspected bribery.



TAV Holding believes that it is essential to create an environment in which everyone feels that they can in good faith raise any matters of genuine concern without fear of disciplinary action being taken against them or fear of reprisal. We will ensure that all cases of suspected bribery are dealt with consistency and whether or not investigation shows bribery exists, the reporting person will not be revealed and there will be no retaliation against or adverse consequences for the person reporting the possible case of bribery.



We have a number of channels that employees can go through in order to speak to someone about any concerns in confidence:



  • - the line managers
  • - the Human Resources managers

 

Fraud Policy

 

BACKGROUND

The corporate fraud policy is established to facilitate the development of controls which will aid in the detection and prevention of fraud against TAV Havalimanları Holding A.Ş. and its subsidiaries where TAV Havalimanları Holding holds management control (hereinafter called the “Company”). It is the intent of the Company to promote consistent organizational behavior by providing guidelines and assigning responsibility for the development of controls and conduct of investigations.

SCOPE OF POLICY

This policy applies to any fraud, or suspected fraud, involving employees as well as shareholders, consultants, vendors, contractors, outside agencies doing business with employees of such agencies and/or any other parties with a business relationship with  the Company.

Any investigative activity required will be conducted without regard to the suspected wrongdoer’s length of service, position/title, or relationship to the Company.

POLICY

Management is responsible for the detection and prevention of fraud, misappropriations, and other inappropriate conduct. Fraud is defined as the intentional, false representation or concealment of a material fact for the purpose of inducing another to act upon it to his or her injury. Each member of the management team will be familiar with the types of improprieties that might occur within his or her area of responsibility, and be alert for any indication of irregularity.

Any fraud that is detected or suspected must be reported immediately to Audit Director, who coordinates all investigations with the Legal Department and other affected areas, both internal and external.

Audit Director has the authority to hire independent fraud professionals or ask for professional help to conduct fraud investigations where he believes that such expertise does not exist within the Audit Directorate.

ACTIONS CONSTITUTING FRAUD

The terms defalsification, misappropriation, and other fiscal wrongdoings refer to, but are not limited to:

  •  Any dishonest or fraudulent act
  •  Forgery or alteration of any document or account belonging to the Company
  •  Forgery or alteration of a check, bank draft, or any other financial document
  •  Misappropriation of funds, securities, supplies, or other assets
  •  Impropriety in the handling or reporting of money or financial transactions
  •  Profiteering as a result of insider knowledge of company activities


OTHER INAPPROPRIATE CONDUCT

Suspected improprieties concerning an employee’s moral, ethical, or behavioral conduct, should be resolved by departmental management and Human Resources rather than Audit Directorate. If there is any question as to whether an action constitutes fraud, contact Audit Director for guidance.

INVESTIGATION RESPONSIBILITIES

The Audit Directorate has the primary responsibility for the investigation of all suspected fraudulent acts as defined in the policy. If the investigation substantiates that fraudulent activities have occurred, Audit Director will issue reports to appropriate management and, if appropriate, to the Board of Directors through the Audit Committee. Decisions to prosecute or refer the investigation results to the appropriate law enforcement and/or regulatory agencies for independent investigation will be made in conjunction with legal counsel and the appropriate management, as will final decisions on disposition of the case.

CONFIDENTIALITY

The Audit Director and the investigatory team (defined herein below) will treat all information received confidentially. Any employee who suspects dishonest or fraudulent activity will notify the Audit Director immediately, and should not attempt to personally conduct investigations or interviews/interrogations related to any suspected fraudulent act (see REPORTING PROCEDURES in the section below).

Investigation results will not be disclosed or discussed with anyone other than those who have a legitimate need to know. This is important in order to avoid damaging the reputations of persons suspected but subsequently found innocent of wrongful conduct and to protect the Company from potential civil liability.

AUTHORIZATION FOR INVESTIGATING SUSPECTED FRAUD

Members of the investigatory team assigned by the Audit Director to investigate the matter will have (hereinafter called the “Investigatory Team”):

  • Free and unrestricted access to all Company records and premises, whether owned or rented; AND
  • The authority to examine, copy, and/or remove all or any portion of the contents of files, desks, cabinets, and other storage facilities on the premises without prior knowledge or consent of any individual who may use or have custody of any such items or facilities when it is within the scope of their investigation.


REPORTING PROCEDURES

Great care must be taken in the investigation of suspected improprieties or wrongdoings so as to avoid mistaken accusations or alerting suspected individuals that an investigation is under way. An employee who discovers or suspects fraudulent activity will contact Audit Director immediately. The employee or any other complainant will remain anonymous. All inquiries concerning the activity under investigation from the suspected individual, his or her attorney or representative, or any other inquirer should be directed to the Investigatory Team or the Legal Department. No information concerning the status of an investigation will be given out. The proper response to any inquiries is: “I am not at liberty to discuss this matter.”
Under no circumstances should any reference be made to “the allegation,” “the crime,” “the fraud,” “the forgery,” “the misappropriation,” or any other specific reference.

REPORTING PROCEDURES

The reporting individual should be informed of the following:

  • Do not contact the suspected individual in an effort to determine facts or demand restitution.
  • Do not discuss the case, facts, suspicions, or allegations with anyone unless specifically asked to do so by the Legal Department or the Investigatory Team..


TERMINATION

If an investigation results in a recommendation to terminate an individual, the recommendation will be reviewed for approval by the designated representatives from Human Resources and the Legal Department and, if necessary, by outside counsel, before any such action is taken. The Audit Director or the Investigatory Team does not have the authority to terminate an employee. The decision to terminate an employee is made by the employee's management. Should the Audit Director believe the management decision inappropriate for the facts presented, the facts will be presented to appropriate management for a decision.

ADMINISTRATION

The Audit Director is responsible for the administration, revision, interpretation, and application of this policy. The policy will be reviewed annually and revised as needed.

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