Anti Corruption and Anti Bribery Policy

Purpose

This policy has been established to ensure the implementation of a zero-tolerance approach against all forms of corruption, bribery, conflicts of interest, and unethical conduct within Güven Boya.

Scope

This policy covers:

• All employees of Güven Boya,
• All stakeholders of Güven Boya, including suppliers, contractors, subcontractors, and personnel involved in contracts with other organizations.

The implementation and updating of the Anti-Bribery and Anti-Corruption Policy fall under the authority, duty, and responsibility of senior management.

Corruption: A form of fraud or crime committed by a person or an organization entrusted with authority, aimed at obtaining unlawful benefits or abusing power for personal gain.

Bribery: The act of directly or indirectly offering, promising, requesting, accepting, or mediating any benefit in order to influence a person to perform, refrain from performing, accelerate, or delay an action related to their duties, in violation of the requirements of their position, within the framework of an agreement between parties.

Bribery and corruption may occur in many different forms, including but not limited to:

• Cash payments or material benefits
• Valuable gifts, hospitality, or travel offers
• Commission payments or concealed payments under the name of consultancy fees
• False records, fraudulent documents, or falsification
• Abuse of authority
• Political contributions, donations, or facilitation payments

Key Risk Areas for Bribery and Corruption

The Company aims to fully comply with all relevant laws, regulations, and principles at all times and does not tolerate any form of bribery or corruption, regardless of the purpose. It is essential that business relationships are not maintained with third parties seeking to obtain services from the Company through bribery. The main risk areas where bribery and corruption may occur are defined below:

Gifts

A gift is an item given between parties in a business relationship or to customers as a gesture of appreciation or commercial courtesy, without the intention of providing material gain. All gifts provided by the Company to third parties are given openly and in good faith. The same principles apply to gifts accepted from third parties.

Hospitality

Within the scope of establishing commercial communication networks and developing business relationships, hospitality may be offered to customers, suppliers, subcontractors, consultants, auditors, and other companies with which there is a commercial relationship. The Company offers hospitality to third parties in good faith, openly, and unconditionally.

Even if compliant with this policy, hospitality offers or gifts that may lead to a conflict of interest or create such a perception are neither offered nor accepted.

Donations

No corporate or personal payments, gifts, aid, or donations shall be made to any private company, government official, or political party candidate in order to influence any decision related to the continuation of the Company’s activities or the procurement and delivery of services that may benefit the Company.

Facilitation Payments

Persons and entities covered by this policy shall not offer facilitation payments to secure or expedite routine transactions or processes with public institutions (such as obtaining permits, licenses, or official documents).

Record Keeping

The Company’s accounting and record-keeping systems are governed by legal regulations, ethical rules, and working principles. All accounts, invoices, and documents related to third-party relationships must be recorded and maintained in a complete, accurate, and reliable manner. No falsification or distortion of accounting or similar commercial records related to any transaction is permitted.

Policy Violations and Sanctions

The Anti-Bribery and Anti-Corruption Policy has been communicated to all Güven Boya employees and is included in an easily accessible folder. If there is an opinion or suspicion that an employee or a person acting on behalf of Güven Boya has engaged in conduct contrary to this policy, senior management must be informed.

No retaliation or adverse treatment will be tolerated against any person who reports a bribery or corruption incident in good faith and transparently.

Güven Boya is committed to adhering to ethical values at every stage of its operations and considers the fight against bribery and corruption not only as a legal obligation but also as a fundamental element of its corporate culture. We expect all our employees, business partners, and stakeholders to comply with this policy.