ERA Corporate Business Ethics

1. OUR CODE OF BUSINESS ETHICS

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a. Integrity

Integrity and honesty are our stable values in all our business processes and interactions. We act in integrity and honesty in all our relations with the employees and partners.

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b. Confidentiality

We give utmost importance to protecting the privacy of our customers , employees and other associated individuals and companies and the confidentiality of their information. We protect confidential information regarding the activities of our Company and use this information only for the purposes of ERA 's interactions and share this information only with relevant authorised parties.

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We strictly forbid insider trading, or gaining any financial or commercial interest . When ending our staff's employment with the company, they do not take with us confidential documents, projects, regulations, etc. 

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c. Our Responsibilities

In addition to our legal responsibilities, we give utmost importance to fulfill the following responsibilities with our customers, employees, suppliers and business partners, competitors, the community, humanity and environment.

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c1. Our Legal Responsibilities

We execute all our domestic and international activities and procedures within the framework of the laws of the Republic of Turkey and international laws; and we submit all required information to regulatory authorities and institutions in a correct, complete, clear and timely manner.

In executing all activities and procedures, we do not expect any benefit from, and keep an equal distance to all public institutions and organizations, administrative bodies, non-governmental organizations, and political parties; and we fulfill our liabilities with a sense of responsibility.

c2. Our Responsibilities Towards Our Customers

We approach with focus on customer satisfaction and are proactive in responding to customers' needs and demands in an appropriate and timely manner. We deliver our services on time and under the promised conditions; we approach our customers with respect, honour, fairness, equality, and courtesy.

c3. Our Responsibilities Towards Our Employees

We enable our employees to use their personal rights fully and correctly. We approach employees with honesty and fairness; and ensure a non-discriminatory, safe, and healthy working environment. We undertake the necessary efforts to enable personal development of our employees; with a social awareness support them in volunteering for appropriate social and community activities; and respect and assure the balance between their private and professional lives.

c4. Our Responsibilities Towards Our Partners

Dedicating prime importance to the continuity of ERA Company, and in line with our goal to create value for our partners, we avoid taking on unnecessary or unmanageable risks, and strive for sustainable profitability. We act with financial discipline and accountability, and manage our company's resources, assets and our professional work time with a sense of efficiency and economy. We work to enhance our competitive power, and to invest in areas with growth potential and which offer the highest return on allocated resources.

c5. Our Responsibilities Towards Our Suppliers/Business Partners

We act respectfully and fairly as expected from a good customer, and ensure to fulfil our liabilities on time. We carefully protect the confidential information pertaining to the persons, organizations and our business partners.

c6. Our Responsibilities Towards Our Competitors

We compete effectively, only in areas that are legal and ethical, and avoid unfair competition.We support all efforts to construct a competitive structure targeted within the society.

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2. POLICIES SUPPORTING BUSINESS ETHICS

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We promote freedom of expression and open communication. But we expect all employees to follow our code of conduct. They should avoid offending, participating in serious disputes and disrupting our workplace. We also expect them to foster a well-organized, respectful and collaborative environment and this policy applies to all our employees regardless of employment agreement or rank.

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a. EMPLOYEES' RESPONSIBILITIES

ERA relevant policies and procedures establish the ethical codes on how we should act and how we should do our jobs in detail. It is the primary responsibility of all employees to abide by these codes. Hence, all employees of ERA have the responsibility to;

• Act in accordance with laws and regulations under all circumstances;

• Read the ERA Code of Business Ethics, learn, understand, internalize, and act in accordance with the codes, principles, and values therein;

• Learn the general and business-specific policies and procedures valid for Company;

• Consult their manager or Human Resources about potential violations concerning self or others;

• Urgently report potential violations by self or others; notify manager, Human Resources and/or the Ethics Board verbally or in writing either by disclosing ones identity or keeping it confidentİal;

• Cooperate with the Management during ethical investigations, keep information specific to the investigation confidential.

• All employees must be clean and well-groomed. Grooming styles dictated by religion and ethnicity aren’t restricted.

• All clothes must be work-appropriate. Clothes that are typical in workouts and outdoor activities aren’t allowed.

• All clothes must project professionalism. Clothes that are too revealing or inappropriate aren’t allowed.

• All clothes must be clean and in good shape. Discernible rips, tears or holes aren’t allowed.

• Employees must avoid clothes with stamps that are offensive or inappropriate.

• Being on time at work

• We expect employees to not abuse their employment benefits. This can refer to time off, insurance, facilities, subscriptions or other benefits our company offers.

• Employees should be friendly and collaborative. They should try not to disrupt the workplace or present obstacles to their colleagues’ work.

• We expect employees to avoid any personal, financial or other interests that might hinder their capability or willingness to perform their job duties.

• We discourage employees from accepting gifts from clients or partners. We prohibit bribery for the benefit of any external or internal party.

• All employees must protect our company’s legality. They should comply with all environmental, safety and fair dealing laws. We expect employees to be ethical and responsible when dealing with our company’s finances, products, partnerships and public image.

• All employees should respect their colleagues. We won’t allow any kind of discriminatory behavior, harassment or victimization

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b. MANAGERS' RESPONSIBILITIES

Managers have additional responsibilities in our Company, Accordingly, it is the managers' responsibility to;

• Create and preserve a company culture and working environment that promotes the ethics codes,

• Be a role model in practicing the ethics codes; educate their personnel on the ethics codes,

• Support their employees in expressing their questions and in filing their complaints/notifications concerning the ethics codes,

• Offer guidance regarding what should be done when consulted, diligently consider all ethical concerns raised, and forward them to the Management at the shortest possible time when deemed necessary,

• Structure all work processes under his/her responsibility in a way as to minimize ethical risks and implement necessary methods and approaches to ensure compliance with the ethics codes.

• All managers must be clean and well-groomed. Grooming styles dictated by religion and ethnicity aren’t restricted.

• All clothes must be work-appropriate. Clothes that are typical in workouts and outdoor activities aren’t allowed.

• All clothes must project professionalism. Clothes that are too revealing or inappropriate aren’t allowed.

• All clothes must be clean and in good shape. Discernible rips, tears or holes aren’t allowed.

• Managers must avoid clothes with stamps that are offensive or inappropriate.

• Being on time at work

• We expect Managers to not abuse their employment benefits. This can refer to time off, insurance, facilities, subscriptions or other benefits our company offers.

• Managers should be friendly and collaborative. They should try not to disrupt the workplace or present obstacles to their colleagues’ work.

• We expect Managers to avoid any personal, financial or other interests that might hinder their capability or willingness to perform their job duties.

• We discourage Managers from accepting gifts from clients or partners. We prohibit bribery for the benefit of any external or internal party.

• All Managers must protect our company’s legality. They should comply with all environmental, safety and fair dealing laws. We expect employees to be ethical and responsible when dealing with our company’s finances, products, partnerships and public image.

• All Managers should respect their colleagues and employees. We won’t allow any kind of discriminatory behavior, harassment or victimization

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c. OTHER RESPONSIBILITIES

• The Company top management is responsible for effective enforcement of company-specific Code of Business Ethics created within this context, and a culture to promote these codes.

• The Ethics Codes and all policies concerning the Code of Business Ethics are reviewed, revised and documented by the Human Resources Group Management upon the recommendations of management, and the revisions are announced to the Company upon the approval of the Management.

• Company Human Resources has the responsibility to;

• - Inform employees about the Code of Ethics, offer periodical ethics training to enable clarity regarding policies and codes, and establish continuous communication on this subject with the employees;

• - Ensure the newly employed personnel read the Code of Ethics, inform them in this subject, and ensure that they sign the Employee Declaration

• - At the beginning of each year, ensure employees sign the Business Ethics Compliance Form and update their declarations.

• Company managements, in cooperation with the Management, have the responsibility to;

• - Ensure confidentiality of complaints/notifications made within the framework of the Code of Ethics, and protect individuals after filing such complaints,

• - Provide job security for the employee who filed complaints/notifications.

• - Ensure that complaints and notifications are investigated timely and in a fair, consistent and sensitive manner; and resolutely take necessary actions against violations.

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3. PROTECTION of COMPANY PROPERTY

All employees should treat our company’s property, whether material or intangible, with respect and care.

Employees:

• Shouldn’t misuse company equipment or use it frivolously.

• Should respect all kinds of incorporeal property. This includes trademarks, copyright and other property (information, reports etc.) Employees should use them only to complete their job duties.

Employees should protect company facilities and other material property (e.g.company cars ,see car policy as follows) from damage and vandalism, whenever possible.

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Scope

This policy refers to all of our employees who are eligible to receive a company car and those who drive one as part of their daily job duties.

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Policy elements

Employees who may be assigned a company car

Employees who are eligible to be assigned a company car fall into three categories:

• Employees who need to travel more than 10.000km per year to meet with customers, partners or vendors.

• Employees who use company vehicles as an indispensable part of their jobs (e.g. truck drivers and delivery drivers).

• Employees who are given a company car as a benefit attached to their jobs.

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Our employees are only allowed to drive a company car if they:

• Have a valid driver’s license.

• Have a clean driving record for at least 2 years This means they mustn’t have been held at fault for a car accident, or arrested on charges of violating vehicle and traffic laws (e.g.driving under the influence of drugs or alcohol).

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Driver’s obligations

We expect employees who drive company vehicles to follow rules. They should:

• Drive safe and sober.

• Respect traffic laws and fellow drivers.

• If applicable, wear glasses or contacts when driving.

• Document any driving-related expenses, like fuels and tolls.

• Check their car regularly to ensure gas, tire pressure and all car fluids are at appropriate levels.

• Report any damages or problems with their assigned cars to HR as soon as possible.

• Avoid double-parking, blocking entrances and engaging in other traffic violations that may result in fines.

 

If employees have their driver’s licenses suspended or revoked, they must inform our [HR department.] We’ll reassign their company car until they become eligible to drive in accordance with our policy (maintaining a clean driving record for at least 2 years.

Employees who are fatigued and/or sick should avoid driving if they feel their driving ability is impaired. If sickness occurs during a business trip that requires the use of a company car, employees should take regular breaks while driving or ask HR for overnight accommodations, if needed.

 

Employees are not allowed to:

• Smoke inside of a company car.

• Lease, sell or lend a company car.

• Violate distracted driving laws by using a phone or texting while driving.

• Use a company car to teach someone how to drive.

• Leave the company car unlocked, unattended or parked in dangerous areas.

• Allow unauthorized people to drive a company car, unless an emergency mandates it.

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Accidents

If employees are involved in an accident with a company car, they should contact our HR department immediately, so we can get in touch with our insurance provider. Employees shouldn’t accept responsibility or guarantee payment to another party in an accident without company authorization.

 

Employees should follow legal guidelines for exchanging information with other drivers and call local police if accidents are serious.

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Our company’s obligations

We want to ensure that all our employees are safe at work and preserve our company’s legality. For these reasons, we’ll:

• Make sure cars are safe to drive before assigning them to employees.

• Schedule periodical maintenance to ensure cars remain in good condition.

• Provide a copy of this policy to all employees who are assigned company cars.

• Insure vehicles with a reliable insurance provider.

Drivers are responsible for bringing in their company cars for any maintenance our company schedules.

 

We keep records of our fleet with manufacturing date and mileage. We will retire any car that’s deemed too old or too high in mileage.

We are not responsible for:

• Paying fines employees accumulate while driving company cars.

• Bailing out employees arrested while driving company cars.

 

Protecting the environment and saving costs

Cars are harmful to our environment and costly to use. We’ll try to provide employees with eco-friendly cars when possible. We also expect our employees to use their assigned company cars sensibly, considering environmental impacts. Examples of instances when using company cars isn’t necessary:

• When public transport is easily accessible and faster.

• When business trips are far enough to warrant use of train or plane.

• When employees can complete a task without driving.

 

Disciplinary Consequences

Employees will face disciplinary consequences if they don’t follow this policy’s rules. For minor offenses, like allowing unauthorized people to drive a company car or receiving more than 2 fines, we may issue reprimands and ultimately revoke the company car.

We may terminate an employee and/or take legal action as needed for more serious offenses. That can include leasing out a company car for personal financial gain, or causing an accident while driving intoxicated.

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3. EMPLOYEE ATTENDANCE POLICY 

All employees have job duties to attend to that usually require physical presence and close collaboration with colleagues. Hence, they are obliged to follow the schedule that is clearly stated in their employment contract. This translates in an avoidance of frequent inexcusable absence and following designated times when clocking in and out.

Any kind of deviation from attendance rules may cause problems to other employees who have to fill in work which would not normally fall under their responsibility. Such situation could hinder the smooth running of operations and may cause displeasure and resentment between employees.

 

ERA is committed to promote fairness in the workplace and avoid anything that might be obstructing its workflow. Therefore, continuous or inexcusable absenteeism or tardiness will mark an employee’s “bad attendance” record and will have serious repercussions.

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Generally, employees are expected to attend to their schedule diligently without having to be pressured by their employer. The company wants its workforce to be committed and conscientious so that both parties can benefit from its business. Disciplinary action may not be desirable but it will be the definite result of the continuous disregard of working schedules.

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4 . OPEN DOOR COMPANY POLICY

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Our Open Door company policy was developed due to our management's desire to establish transparent and flexible bottom-up communication paths. ERA feels that its employees should be free and encouraged to speak openly to their supervisors, or other managers and directors about significant matters. This policy is essential for dealing with concerns or issues and gaining insight into potential problems.

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This policy applies to all prospective or current employees of the company who either wish to communicate with a higher ranking official or receive such communication from subordinates or other employees.

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5. NON-COMPLIANCE WITH CODE OF ETHICS

Those who violate the Code of Business Ethics and/or company policies and procedures shall be subject to disciplinary action up to and including termination of employment. Disciplinary action shall also be applied to those approving or directing inappropriate conduct and actions violating the ethics code, as well as to those who fail to raise a concern or report a possible violation that they are aware of.

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