SUPPLIER CODE OF CONDUCT

December, 2018Rev. 03

1.0 PURPOSE ..........................................................................................................................................

2.0 SCOPE ..............................................................................................................................................

3.0 CODE OF CONDUCT ........................................................................................................................

3.1 Compliance with the Law.......................................................................................................................

3.2 Human Rights and Fair Working Conditions..........................................................................................

3.3 Workplace, Health and Safety and the Environment.............................................................................

3.4 Security ..................................................................................................................................................

3.5 Combating Bribery and Corruption and Preventing Anti-Competitive Behaviour. ............................

4.0 PROCEDURE APPLICABLE TO VIOLATIONS OF THE CODE.............................................................

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Table of Contents

DEĞERLERİMİZ

INTEGRITY

Our conduct towards our clients, shareholders,

employees, suppliers, subcontractors, governmental

and regulatory authorities, competitors and

towards society as a whole is without fault

COMMITMENT

Uncompromising commitment

to Quality, Health, Safety and

Environment

TRUST

An open relationship with our

employees based on mutual

trust, respect and success

ETHICS

Transparency, Accountability and

Discipline in our business

INNOVATIVE ACUMEN

Excellence, Innovation and

Improvement

SUSTAINABILITY

A corporate sustainability approach that

imparts awareness of economic, environmental

and social responsibilities towards

internal and external stakeholders

SOLIDARITY

Sharing success and standing

together in the face of failure

1.0 PURPOSEIn doing business around the world, ENKA is committed to the highest

standards in ethics and compliance. ENKA is a signatory of the United

Nations Global Compact (UNGC) and has promised to abide by 10 articles

of the UNGC.

In all its activities, ENKA respects the rights expressed in the Universal Declaration

of Human Rights. In this context, ENKA expects other organisations with which it

collaborates to produce value to show the same sensitivity and dedication.

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2.0 SCOPEENKA Supplier Code of Conduct describes the ethical business standards

and sets down the behaviour which ENKA expects from its suppliers, subcon-

tractors, consultants, service providers, agents and business partners

(hereinafter referred to as “Supplier”).

Each supplier is responsible for ensuring that their employees, agents and

sub-suppliers understand and comply with ENKA Supplier Code of Conduct.

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ENKA Suppliers guarantee that they and their employees, subcontractors

and suppliers will act in accordance with the rules set out below.

ENKA Suppliers:

3.1 Compliance with the Law

a) Act in accordance and ensure full compliance with all laws and regula-

tions and the body of relevant legislation that governs them.

3.0 CODE OF CONDUCT

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3.2 Human Rights and Fair Working Conditions

b) Do not employ child labour and ensure compliance with all rules governing

the employment of youth workers established by the International Labour

Organisation (ILO).

c) Employ no form of forced labour.

d) Do not expose their workers to any form of discrimination (based on race,

religion, language, skin colour, sex, sexual orientation, disability etc.).

e) Do not implement, encourage or allow corporal punishment; mental,

physical, sexual or verbal abuse; cruel or degrading disciplinary actions, or

maltreatment.

f) Pay their employees at least the minimum wage or a fair wage compared to

the current average wage in their sector.

g) Comply with the working hours and workers’ rights legislation in the

countries where they are active.

h) Respect their workers’ rights to establish independent unions, become

members of such unions and engage in labour organisation.

i) Identify human rights risks towards the local population, take necessary

measures so that no violations occur, identify communications channels for

reporting possible violations, report cases of violations and compensate for

damages.

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3.3 Workplace Health and Safety and the Environment

j) Are obliged to provide for their employees a working environment where all

measures for workplace health and safety are taken. They take all necessary

measures to this end and fully provide all necessary equipment. Suppliers train

their employees on HSE issues and carry out inspections under all circumstances.

k) Make the utmost e�ort to contribute to ENKA’s HSE and zero accidents targets.

l) Provide their employees with uninterrupted access to clean water, food and

healthcare services.

m) Take all measures to prevent harm to the environment.

n) Assess the environmental impact of the work to be undertaken and establish

targets for impact reduction.

o) Are expected to provide relevant certication scheme (e.g.; FSC, MSC) to

demonstrate that they prefer most environmental-friendly and sustainable

practices.

p) Are expected to maintain an environmental management system that prioritizes

the protection of local wildlife, flora, fauna and endangered species.

3.4 Security

q) Are obliged to provide a safe working environment for their employees. To this

end, they take all necessary security measures.

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3.5 Combating Bribery and Corruption and Preventing Anti-Competitive

Behaviour

r) Agree to transfer information to ENKA unconditionally and to act transparently

in the conduct of their work.

s) Avoid anti-competitive behaviour.

t) Do not pay out or receive bribes or engage in corruption. Establish the neces-

sary mechanisms within their organisation and take measures to prevent bribery

and corruption.

Bribery consists of real or legal third persons providing or promising to provide

an item of value or an advantage in order to alter activities inappropriately. Cash,

gifts, travel and other expenses, accommodation, discounts, preferential

treatment, employment or employment opportunities, political or charitable

contributions or any direct or indirect payments may be considered bribes.

u) ENKA’s private and confidential information is among the company’s greatest

assets. Privately owned and confidential information includes information that is

generally not public and could harm the company or give its rivals advantages if

it is made public. Examples include technical information, design and process

data, pricing information, business or strategic plans, work processes and

capabilities, project implementations, software and technology, research and

development, lists of clients and suppliers and information belonging to third

parties which has been trusted to ENKA and the Supplier and which ENKA is

obliged to protect, such as the private and confidential information of partners.

ENKA’s Suppliers are required to remain alert and to take necessary precautions

within and outside the workplace in order to protect ENKA’s private and

confidential information to the best of their abilities.

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ENKA Suppliers must ensure that a fair complaints procedure, which does

not permit retaliation, is available for use by employees and suppliers in case

of violation of the rules summarised above.

ENKA Suppliers may use the ENKA Ethics Hotline for any questions they may

have about the ENKA Suppliers Code of Conduct. ENKA Suppliers,

employees and subcontractors may use the ENKA Ethics Hotline to report

any suspected rules violations and provide information about them.

The ENKA Ethics Hotline is active between 09:00-18:00, Monday through

Friday. The identity of the caller will be kept anonymous and reports may be

made in Turkish, English, Russian or Kazakh.

Should it witness a case of violation or receive a credible tip-o�, ENKA may

demand information and documentation from the Supplier and carry out

inspections with or without the Supplier’s knowledge to observe compliance

with the rules listed above. The Supplier is obliged to supply all relevant

documents demanded by ENKA within 2 days.

In cases of violation of law or the Code, ENKA may demand suspension of the

relevant supplier employee(s) or may terminate business relation with the

supplier.

Violation of ENKA Supplier Code of Conduct and /or any anti-bribery and

anti-corruption code of ENKA by supplier’s any employee, department or

sub-supplier may lead to termination of business contract with ENKA.

ENKA Suppliers may consult the ENKA Code of Business Conduct for detailed

information on the issues referred to in this Document

(https://www.enka.com/sustainability/ethics-compliance/).

4.0 PROCEDURE APPLICABLE TO VIOLATIONS OF THE CODE

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