Accuracy and integrity are among our primary values in all our business processes and relationships. We act truthfully and honestly in our relations with employees and all stakeholders.

Confidential and private information includes information belonging to the Yücel Cultural Foundation that could create a competitive disadvantage, trade secrets, financial and other information not yet disclosed to the public, personnel and employment information, and information covered by confidentiality agreements concluded with third parties.

As employees of the Yücel Cultural Foundation, we take care to protect the privacy and personal information of our beneficiaries, employees and the other individuals and organisations with whom we work. It is strictly unacceptable to obtain any commercial benefit by leaking any confidential information belonging to the Yücel Cultural Foundation. When leaving the Foundation, we do not remove confidential information and documents, projects, regulations or similar work acquired or prepared through our duties.

As employees of the Yücel Cultural Foundation, we aim to avoid conflicts of interest. We do not use our current positions to obtain personal benefit, directly or through our family members or relatives, from individuals or organisations with whom we have business relations. We do not engage in additional activities outside the Yücel Cultural Foundation that are based on a financial interest. We refrain from using the Foundation’s name and influence, or our identity as Foundation representatives, for personal gain.

Where a potential conflict of interest arises and we believe that the interests of the relevant parties can be protected safely through lawful and ethical methods, we apply those methods. When in doubt, we consult our manager, the Board of Directors or the Ethics Committee.

In addition to our legal obligations, we take care to fulfil the responsibilities listed below on behalf of the Foundation towards the people with whom we interact, employees, donors, suppliers and business partners, solution partners, society, humanity and other civil society organisations.

1Our Legal Responsibilities

We conduct all our activities and transactions in Türkiye and abroad in accordance with the laws of the Republic of Türkiye and international law, and provide legal and regulatory authorities with accurate, complete and comprehensible information in a timely manner.

In carrying out all our activities and transactions, we maintain equal distance from all public institutions and bodies, administrative organisations, civil society organisations and political parties without expecting any benefit, and fulfil our obligations with this sense of responsibility.

2Our Responsibilities towards Our Members

We work with a proactive, member-focused approach that responds to our members’ needs and requests as quickly and accurately as possible. We provide our services on time and under the conditions we have promised, and treat our members with respect, dignity, fairness, equality and courtesy.

3Our Responsibilities towards Employees

We ensure that employees can fully and properly exercise their employment rights. We treat employees honestly and fairly and commit to a non-discriminatory, safe and healthy working environment. We make the necessary efforts to support their individual development, encourage them to volunteer in suitable social and community activities with an awareness of social responsibility, and seek to maintain a balance between working life and private life.

4Our Responsibilities towards Our Trustees

Giving priority to the Foundation’s continuity and pursuing the objective of creating value for the Foundation, we avoid unnecessary or unmanageable risks and aim for sustainable benefit. We act with financial discipline and accountability and manage the Foundation’s resources, assets and working time with efficiency and an awareness of economy. We seek to strengthen our effectiveness and invest in areas with growth potential that will generate the greatest benefit from the resources committed. In public disclosures and communications with our Trustees, we provide timely, accurate, complete and comprehensible information about our financial statements, strategies and investments.

5Our Responsibilities towards Suppliers and Solution Partners

We act fairly and respectfully, as expected of a responsible client, and take the necessary care to fulfil our obligations on time. We carefully protect the confidential information of the individuals and organisations with whom we do business and of our business partners.

6Our Responsibilities towards Society and Humanity

Protecting democracy, human rights and the environment, supporting education and charitable work, and eliminating crime and corruption are of great importance to us. With the awareness of being responsible citizens, we act sensitively and seek to take a leading role in social matters, civil society organisations, public-interest services and other appropriate activities. We respect the traditions and cultures of Türkiye and of the countries in which we conduct international projects. We neither give nor accept bribes, gifts of excessive value, or similar products and services.

Employees of the Yücel Cultural Foundation must avoid situations that may create a conflict of interest. Not using the Foundation’s resources, name, identity or influence for personal benefit, and avoiding situations that could adversely affect the institution’s name and reputation, are among the most important responsibilities of all employees. The implementation principles below define the conflict-of-interest situations that employees of the Yücel Cultural Foundation may encounter while performing their duties or in their private lives as a result of business relationships, and the principles to be followed in such situations.

Implementation Principles

1. Activities That May Create a Conflict of Interest

All employees of the Yücel Cultural Foundation must fully comply with the situations listed below as activities that may create a conflict of interest and with the stated principles. The Foundation undertakes the necessary work to encourage employees to comply with these principles.

iEngaging in Activities That May Create a Conflict of Interest

Employees may not enter into any business relationship with family members, friends or other third parties that provides a reciprocal or non-reciprocal benefit. For example, an employee with purchasing authority should avoid doing business with a supplier that employs a member of their family. Exceptional cases are subject to the knowledge and approval of the Chair of the Foundation’s Board of Directors. Employees may not obtain any commercial benefit by leaking information belonging to the Yücel Cultural Foundation, nor may they enable others to obtain such benefit.

As a rule, employees of the Yücel Cultural Foundation may not engage, directly or indirectly, in activities that would cause them to be regarded as merchants or tradespeople, nor may they work, under any title and during or outside working hours, for another person and/or organisation in return for payment or a similar benefit. Employees may, however, work outside working hours for another person, such as a family member, friend or other third party, and/or organisation in return for payment or a similar benefit, provided that:

• It does not create a conflict of interest with their duties at the Foundation or with other practices of the Yücel Cultural Foundation;
• It does not conflict with the other rules of business ethics or the policies supporting those rules;
• It does not adversely affect the performance of their duties at the Foundation; and
• The written approval of the Board of Directors has been obtained.

These conditions must all be met.

Employees may hold a position in a political party only under the following conditions and with the written approval of management:

• Employees may not engage in political activity during working hours or take up the working time of colleagues in connection with such activities.
• During political activities, employees may not use the Foundation’s name, their position or title within the Foundation, or any resources belonging to the Yücel Cultural Foundation.

iiAbuse of Position

It is unacceptable for employees to harm the Foundation by using their authority for their own benefit or that of their relatives, or without the degree of care expected of them.

Employees may not obtain any direct or indirect personal gain from the Foundation’s purchasing activities, operations, transactions or contracts to which it is a party.

Employees may not engage in acts or conduct contrary to morality, the law or Foundation discipline.

iiiUse of Resources

The Foundation’s interests are taken into account whenever resources are used on its behalf. Foundation assets, facilities and personnel may not be used outside the Foundation, under any name or for the benefit of any person, unless there is a Foundation interest. The principle of economy in all matters applies to all personnel.

Using resources correctly in the Foundation’s interest also requires the proper use of time. During working hours, Foundation employees use their time efficiently and do not devote working time to personal matters. Managers may not assign employees to perform their personal errands.

As a rule, private visitors should not be received during working hours. Where a visit is unavoidable, employees must complete the meeting within a reasonable period, in a manner relevant to the purpose of the visit and without disrupting the workflow.

ivRelations with Other Individuals and/or Organisations Having Commercial Relations with the Foundation

Employees may not enter into private business relations with the Foundation’s subcontractors, suppliers or other individuals and/or organisations with which the Foundation has commercial relations. They may not borrow money and/or obtain goods or services for personal purposes from them, nor lend money and/or provide goods or services to them.

Foundation personnel may not request or imply a request for gifts from individuals and/or organisations with which the Foundation has commercial relations, and may not accept any gift, money, cheque, property, free holiday, special discount or similar benefit that would place the Foundation under an obligation. Personal assistance or donations may not be accepted from any person or organisation having a business relationship with the Foundation. The Policy on Giving and Accepting Gifts applies in this regard.

vRelations with the Media

Relations with the media are managed in accordance with the Foundation’s Communication Strategy.

Giving statements or interviews to any media organisation, or participating as a speaker at seminars, conferences or similar events, is subject to the approval of the Foundation’s Board of Directors. No personal gain may be obtained from such activities.

The Yücel Cultural Foundation and its employees must not accept gifts or benefits that may affect their impartiality, decisions or conduct, nor attempt to provide third parties and organisations with gifts or benefits capable of creating such influence. The implementation principles below regulate exchanges of gifts between Foundation employees and the third parties and organisations with whom they have business relationships, and set out the principles to be applied.

Implementation Principles

1. Foundation employees are prohibited from accepting any benefit or gift, whether or not it has economic value, that affects or may affect their impartiality, performance or decision-making while carrying out their duties.

2. Foundation employees may accept and/or give the gifts described in paragraph 3, or agree to special treatment, provided that the following conditions are met:

• The gift or treatment is consistent with the institution’s operational objectives;
• It complies with the legislation in force; and
• Public knowledge of the gift would not place the Foundation in a difficult position.

The gifts described in paragraph 3 may be accepted and/or given, or special treatment may be accepted, only where all these conditions are satisfied.

3. Provided that the conditions specified in paragraph 2 are met:

• Foundation employees may offer and receive entertainment, hospitality and meals within standards accepted in the business world.
• At seminars and similar events attended on behalf of the Foundation, non-monetary awards, plaques and similar gifts of symbolic value may be accepted as mementos.

4. Subject to the conditions set out in paragraph 2, no approval is required where the total value of the situations described above and other non-monetary gifts, benefits, holidays, discounts and similar items received in a calendar year is less than TRY 250, calculated separately for each person or institution giving the gift.

5. It is prohibited to accept gifts or benefits that are implicitly or explicitly linked to a consideration or favour in return.

6. Accepting, giving or offering a bribe and/or commission is unacceptable under all circumstances.

7. Foundation employees are prohibited from accepting money, whether free of charge or as a loan, from subcontractors, suppliers, consultants, competitors or clients, or from having them pay travel costs, event expenses or similar charges.

8. The types of gifts and promotional materials that may be given by the Foundation to members, donors and other third parties with whom it has business relations are approved by the Foundation’s Board of Directors. No additional permission is required for the distribution of approved gifts and promotional materials.

9. Subject to compliance with the conditions listed in paragraph 2, the Foundation may accept suitable products and services as gifts. With the knowledge and approval of the Foundation’s Board of Directors, products or services consistent with the recipient’s culture and ethical values may also be given as gifts.

10. In exceptional cases where local cultural values require reciprocal gifts above the values set in Foundation policy, such gifts may be accepted only on behalf of the Foundation and with the approval of the Foundation’s Board of Directors. In all cases, the exchange of gifts must be conducted in a manner consistent with local culture.

Information is one of the most important assets the Yücel Cultural Foundation uses in pursuing its vision. Accordingly, the effective use and proper sharing of information, and the protection of its confidentiality, integrity and accessibility throughout this process, are shared responsibilities of all stakeholders and employees. It is important that the management systems and processes established within the Foundation for information management and confidentiality operate in harmony so that the Foundation can obtain the highest level of benefit. The implementation principles below define confidential information for the Foundation and regulate the principles employees must follow in relation to such information.

Implementation Principles

Without limitation, Confidential Information includes the Foundation’s intellectual property rights, such as trademarks; databases, printed communication materials, processes, advertisements and labels, and plans relating to marketing, products or technical matters, written, discovered, developed, created or implemented by personnel, including all innovations; business strategies; strategic partnerships; financial information; personnel information; member and donor lists; product designs; know-how; specifications; supplier information; and all other written, graphic or machine-readable information.

The principles to be followed in relation to confidential information are listed below:

1. Such information may not be disclosed to third parties unless disclosure is required by public authorities or applicable legislation.
2. Such information may not be altered, copied or destroyed. The necessary precautions are taken to ensure that it is handled and stored carefully and is not disclosed. Any changes to the information are recorded together with their history.
3. Confidential files may not be removed from the institution. Where confidential information must be taken outside the institution, the approval of the person responsible for the information or of the Board of Directors must be obtained.
4. Passwords, user codes and similar identifiers used to access Foundation information are kept confidential and are not disclosed to anyone other than authorised users.
5. Confidential Foundation information is not discussed in dining halls, cafeterias, lifts, shuttle vehicles or similar public places.
6. Confidential information is classified according to levels of confidentiality, which are clearly stated in the information itself. Foundation personnel know the confidentiality level of information obtained through their duties and act accordingly. Where there is uncertainty about the level of confidentiality, the information is treated according to the next higher classification and, where necessary, the relevant manager is consulted.
7. Where information must be shared with third parties and/or organisations in the Foundation’s interest, a confidentiality agreement is first signed or a written confidentiality undertaking is obtained from the other party to ensure that those persons and organisations understand their responsibilities for the security and protection of the information shared.
8. Unfounded statements and/or rumours about individuals or organisations are prohibited.
9. Salary, fringe-benefit and similar personnel information that reflects Foundation policy and is personal to the employee is confidential and may not be disclosed to anyone other than authorised persons. Personnel information is communicated individually to the person concerned. Employees are strictly prohibited from disclosing this information to others or pressuring other employees to disclose it.

The Yücel Cultural Foundation regards the establishment and maintenance of a fair working environment for employees as one of its highest priorities. The aim is to create a fair, respectful, healthy and safe working environment that complies with all relevant laws and regulations, and thereby increase employee success, development and commitment. The implementation principles below set out the fundamental principles for establishing and maintaining a fair working environment within the Foundation.

Implementation Principles

1. Foundation practices comply with all relevant laws and regulations in force concerning employment and working life. Foundation employees also fulfil all legal requirements within the scope of their own activities and act in accordance with applicable legislation.

2. The Foundation’s human resources policies and practices ensure fairness in recruitment, promotion, transfer, rotation, remuneration, reward, social benefits and all other related practices.

3. Discrimination among employees on grounds such as language, race, colour, gender, political opinion, belief, religion, denomination, age or physical disability is unacceptable within the institution.

4. A positive and harmonious working environment that supports cooperation is created within the Foundation, and situations of conflict are prevented so that people with different beliefs, ideas and opinions can work together in harmony.

5. Employees’ private lives and personal space are respected.

• Communications between individuals may not be interfered with by persons who are not parties to them.
• Even where personal data has been lawfully recorded, it is prohibited to disclose, disseminate or obtain it unlawfully.
• Personnel information arising from the nature of the employment relationship and potentially required throughout that relationship is not used for purposes other than those for which it was collected and is not shared with third parties without the individual’s consent.
• The private and family lives of all employees are respected.

6. In addition to all other forms of personal integrity, employees’ physical, sexual and emotional integrity is protected.

• Any violation of an employee’s integrity through physical, sexual and/or emotional harassment in the workplace or in any place where they are present for work is contrary to the law and ethical rules, and the Foundation has zero tolerance for such conduct. The purpose of this principle is to ensure that employees work in an environment in which their physical, sexual and emotional integrity is protected.
• The violation of a person’s bodily integrity through sexual conduct and/or the harassment of a person for a sexual purpose without physical contact is defined as sexual harassment. Any conduct that may fall within this definition is therefore prohibited.
• Likewise, no tolerance is shown towards anyone who engages in adverse conduct against a person who reports or complains about harassment or assists during an investigation.

7. No employee may request or grant preferential treatment, or be subjected to special treatment, on grounds such as gender, religion, language or race. Seeking or granting concessions by exploiting differences such as gender, religion, language or race is unacceptable.

8. The physical working environment and workplace conditions are maintained in a healthy and safe manner for all employees.

To guide you when deciding on a course of action, follow the steps below and ask yourself the following questions:

1Identify the Event, Decision or Problem

• Have you been asked to do something that you believe may be wrong?
• Are you aware of a situation at the Foundation or among our business partners that may be unlawful or contrary to business ethics?
• Are you trying to make a decision and uncertain about how to act in accordance with business ethics?

2Think Before Making a Decision

• Try to define and summarise the problem or your question clearly.
• Ask yourself why it presents a dilemma.
• Consider the options and their consequences.
• Consider who may be affected.
• Consult others.

3Decide on a Course of Action

• Identify your responsibilities.
• Review all relevant facts and information.
• Refer to the relevant Foundation policies, procedures and professional standards.
• Assess the risks and consider how they can be reduced.
• Try to develop the best course of action.
• Consult others.

4Test Your Decision

• Review the questions that should be asked from an ethical perspective.
• Review your decision in the light of the Foundation’s core values.
• Make sure that you have considered Foundation policies, laws and professional standards.
• Consult others and take their views into account in your planned course of action.

5Proceed with Determination

• Share your decision and the reasons for it with the relevant people.
• Share what you have learned.
• Share your success story with others.

1Does this activity or conduct comply with laws, rules and customs? (Standards)

• Does it comply with professional standards?
• Does it comply with the law?

2Is this activity or conduct balanced and fair? Would we be uncomfortable if someone else did the same? (Sense of fairness)

• Do you believe it is right?

3Would the Foundation and its stakeholders be uncomfortable if all the details of this activity became public? (Feelings and ethical values)

• Would you feel compromised or embarrassed if others knew that you had engaged in this conduct?
• Could it have adverse consequences for you or for the Foundation?
• Who else could be affected, such as other Foundation employees, you or the Trustees?

4To what extent does the ‘perceived reality’ correspond with the ‘objective reality’?

• How would it be reported in the press?
• What would a reasonable person think under the same circumstances?

The Ethics Committee is responsible for investigating and resolving complaints and reports alleging breaches of the ethical rules under the Yücel Cultural Foundation Code of Business Ethics. Reporting to the Chair of the Yücel Cultural Foundation’s Board of Directors, the Ethics Committee consists of the holders of the following positions:

Chair - Head of the Audit Department; Member - Member of the Yücel Cultural Foundation Board of Directors responsible for legal affairs.

The Ethics Committee conducts its work in accordance with the principles set out below:

• It keeps confidential all reports and complaints, as well as the identities of those making them.
• It conducts investigations as confidentially as possible.
• It has the authority to request information, documents and evidence relating to an investigation directly from the unit holding them. It may examine any information and documents obtained only to the extent relevant to the subject of the investigation.
• The investigation process is documented in written minutes from the outset. Information, evidence and documents are attached to those minutes.
• The minutes are signed by the Chair and the member.
• The investigation is handled urgently and concluded as quickly as possible.
• Decisions taken by the Committee are implemented immediately.
• The relevant departments and authorities are informed of the outcome.
• When carrying out their duties in relation to these matters, the Chair and member of the Committee act independently and without influence from the managers of the departments to which they belong or from the hierarchy within the organisation. No pressure or direction may be exerted upon them in relation to the matter.
• Where it considers this necessary, the Committee may seek expert opinion and use experts during an investigation, provided that it takes measures to avoid breaching the principles of confidentiality.