Anti Corruption Policy

Purpose

This policy has been established to ensure the implementation of a zero-tolerance approach towards all forms of corruption, bribery, conflicts of interest, and unethical behavior 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 are under the authority, responsibility, and accountability of senior management.

Corruption: A form of fraud or criminal act committed by a person or an individual in a position of authority entrusted by an organization to illegally obtain benefits or to misuse power for personal gain.

Bribery: The act of providing, offering, or promising benefits directly or through intermediaries, or requesting or accepting such benefits, to influence a person to perform, refrain from performing, expedite, or delay any duty in a manner contrary to the obligations of their role.

Bribery and corruption can occur in many ways, including:

• Provision of cash or material benefits
• Valuable gifts, hospitality, or travel offers
• Commissions or covert payments under consultancy arrangements
• Falsified records, forged documents, or tampering
• Misuse of authority or power
• Political contributions, donations, or facilitation payments

Main Risk Areas for Bribery and Corruption

The company aims to fully comply with all relevant laws, regulations, and principles and tolerates no bribery or corruption, regardless of the purpose. Continuing business relationships with third parties attempting to obtain services through bribery is strictly prohibited. Key risk areas for potential bribery and corruption are defined as follows:

Gifts

Gifts are items given as a token of thanks or business courtesy without any intent to gain a financial advantage. All gifts provided by the company to third parties are given transparently and in good faith. The same applies to gifts received from third parties.

Hospitality

Hospitality may be offered to customers, suppliers, subcontractors, consultants, auditors, and business partners to establish communication networks and strengthen business relationships. All hospitality provided by the company is offered in good faith, openly, and unconditionally. Even if compliant with this policy, hospitality or gifts that could cause or be perceived as a conflict of interest must not be offered or accepted.

Donations

No corporate or personal payments, gifts, assistance, or donations should be made to private companies, government officials, or political candidates to influence any decision related to the continuation of company operations or procurement.

Facilitation Payments

Individuals and organizations covered by this policy must not offer facilitation payments to government authorities to secure or expedite routine procedures (permits, licenses, document issuance, etc.).

Record Keeping

The company’s accounting and record-keeping obligations are regulated by legal requirements, ethical rules, and operational principles. All accounts, invoices, and documents related to third-party transactions must be recorded completely, accurately, and reliably. No falsification or distortion of records or commercial data is permitted.

Policy Violations and Sanctions

The anti-corruption and anti-bribery policy has been communicated to all Güven Boya employees and is available in an accessible folder. Any employee or person acting on behalf of the company who is suspected of violating this policy should report it to senior management.

No retaliation is permitted against individuals who report incidents of corruption or bribery in good faith and transparently.

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