SOCIAL RESPONSIBILITY POLICY

As San Metal A.Ş., we pledge to support social, environmental, and economic problems with the awareness of social responsibility, respect the rights and freedoms of employees, refrain from discriminating against people based on their language, religion, race, colour, gender, and social classes, ensure occupational health and safety, prevent environmental pollution, set environmentally friendly policies and standards for the protection of nature, and abide by all legal obligations in social responsibility practises.

We undertake to act with the awareness of respecting and appreciating our customers and suppliers, along with our employees, under our understanding of social responsibility as one of our immutable pillars.

Our basic principles, which we adopt in our social responsibility practises, are as follows:

1. LEGAL RESPONSIBILITIES
All of our current activities and operations are performed domestically and internationally in accordance with the Constitution as well as the laws of the Republic of Türkiye and international law, and we provide accurate, complete, and easily understood information to legal regulatory institutions and organisations in a timely manner.

SAN METAL A.Ş. regularly reviews the SOCIAL RESPONSIBILITY POLICY by the Executive Board every May of the year, except for extraordinary circumstances, and revises it if deemed necessary.

2. RELATIONS WITH PERSONS AND ORGANISATIONS WITH WHICH SAN METAL A.Ş. MAINTAINS BUSINESS DEALINGS
No private business dealings shall be entered into with the corporate customers, suppliers, and other persons and/or organisations with which the company maintains business relationships, no money and/or goods/services shall be borrowed for private purposes; and no money and/or goods/services shall be lent to other persons and/or organisations with which the company maintains business relationships.

Employees of SAN METAL A.Ş. shall neither demand nor imply any gift from other persons and/or organisations with which the company maintains business relationships, nor accept any gift, money, cheque, property, voucher, free holiday, special discounts, or any other commodity or status that might imply bribery under similar names, which would obligate or incriminate SAN METAL A.Ş. SAN METAL A.Ş. shall never accept personal aid or donations under any rationale or name from any person or organisation with which SAN METAL A.Ş. maintains a business relationship. (Gifts such as books, diaries, flowers, chocolates, etc. that are not of high monetary worth received under commercial customs and promotions are excluded herein).

3. RELATIONS WITH ASSOCIATIONS, CLUBS, POLITICAL PARTIES
The employees of SAN METAL A.Ş. naturally have the right to be a member of any association, club or political party recognised by the law under the conditions regulated by the Constitution of the Republic of Türkiye and the laws as required by the laws of the Republic of Türkiye. Also, the employees of SAN METAL may personally provide material or moral aid to third parties outside the organisation, donate, and take part in charity associations.

However, an employee of SAN METAL A.Ş. shall neither contribute financially to political activities on behalf of the company, even by using his/her funds nor participate in activities on behalf of SAN METAL A.Ş., except for professional and industrial associations and clubs. During the term of office, they shall not actively engage in the management of any political party.

The employees of SAN METAL A.Ş. shall neither propagandise and promote the clubs, associations, and political parties to which they are members within SAN METAL A.Ş. by any means, nor shall they promote, propagandise, criticise, or counter-criticise or counter-propagandise through social media from the corporate computers and network during the time they are employed in the organisation. Also, the employee must never influence the corporate activities in any organisation, association, club or political party or disturb the working atmosphere, peace and tranquillity in the workplace pertaining thereto. No employee of SAN METAL A.Ş., including managers, shall ask or force another employee to engage in any political activity or to become a member of a party, association, organisation, support or club.

4. RELATIONS WITH UNIONS
The employees of SAN METAL A.Ş. have the right to become a member of trade unions within the framework of the Constitution and the laws of the Republic of Türkiye and to exercise their union rights as prescribed by law. Similarly, if their positions are eligible for union membership, employees are free to decide whether or not to become a member.

SAN METAL A.Ş. supports union activities and practices to maintain trade union labour and working peace. Both the union management and the management of SAN METAL A.Ş. act commonly and cooperatively and prioritise working peace and development.

5. RELATIONS AMONG EMPLOYEES
The relationship among employees should be based on mutual respect, love, understanding and cooperation. No one working within SAN METAL A.Ş. shall have any advantage over anyone else based on their gender, race, religion, language, nationality, countryman, region, kinship, etc.

The relationship established among employees is a working relationship. Being a relative or acquaintance shall not influence the way of address and behaviour of the employee.

Employees shall not engage in behaviours that go beyond the limits of colleagueship in the work environment.

Employees shall not engage in any behaviour that would not be welcomed by their colleagues (disrespect, ridicule, humiliation, harassment, heavy and humiliating jokes, etc.).

Employees shall neither propagandise on personal matters such as politics, religion, race, etc. nor exert pressure to influence the opinion of the other party.

Employees shall refrain from keeping weapons, cutting, piercing tools, penknives and similar dangerous tools within the organisation.

Employees shall never appear at the organisation intoxicated or under the influence of intoxicating substances. Employees shall never consume alcoholic beverages or take intoxicants in the organisation.

Violent behaviour and/or aggressive attitudes and/or threatening speech and behaviour within the organisation shall never be tolerated.

Mobbing and pressure towards an employee of the organisation on any subject about collective psychology shall be strictly prohibited.

Employees shall neither make unverifiable statements nor gossip about colleagues, customers and institutions related to the company.

Gambling and betting shall not be played within the boundaries of the company and horse races shall not be permitted.

Employees shall neither take photographs of their colleagues within the organisation nor share these photographs on social media without their consent.

6. PERSONAL DATA The personal data of the employee is confidential. Personal data are processed in accordance with the relevant articles of the Law on the Protection of Personal Data.

7. MISCONDUCT AND BREACH OF TRUST It is strictly forbidden for an employee to personally benefit, directly or indirectly, from sales and purchasing procedures or any procedure or contract to which the company is a party.

Employees must notify their department manager, or human resources, of any behaviour or conduct that breaches ethics, laws, or corporate discipline.

After the employee resigns from the organisation for any reason, the organisation will exercise its legal rights in the event that the employee maliciously transfers all the work of the organisation in accordance with the legal regulations by trying to make it appear different from the truth, or transfers the know-how and confidential information of the organisation for whatever reason outside it.

8. CHILD LABOUR
SAN METAL A.Ş. employs personnel in accordance with the provisions of Law No. 4857. Persons who have not reached the age of 18 are not employed due to working in the shift system and being included in the very dangerous category of the workplace.

Apprentices and interns between the ages of 15 and 18 are employed under Law No. 3308 and in accordance with the relevant provisions of the Labour Law. Apprentices and interns shall neither work at night nor shall they be assigned to hazardous, heavy work that may adversely affect their physical, mental and social status.

9. VOLUNTARY WORK
In SAN METAL A.Ş., the employees apply for a job of their own will, refuse or accept work of their own volition, and shall not be forced to do so.

Documents (passport, identity card, etc.) that would prevent employees from quitting their jobs shall never be retained, and they shall never be forced to work in the company by incurring debts or having them sign promissory notes. A copy of the ID cards is included in the personal files of the employees.

Employees are not assigned to other duties within the workplace without their consent.

The monthly wage is paid to the bank accounts of the employees but never to the third party or the agency.

10. HARASSMENT AND ABUSE
Physical violence or disciplinary action, threats of physical violence, sexual harassment or other abusive acts, or verbal teasing or any other form of bullying or intimidation are strictly prohibited. In case of violation, the disciplinary actions of the organisation shall be immediately invoked.

No form of psychological, physical, sexual or verbal abuse, intimidation, threats or harassment shall be tolerated. In case of violation of the law, the complaint and reporting mechanism to the necessary judicial authorities shall be put into action. The obligation to take the necessary measures to protect those who have been subjected to such harassment from further harm shall be assumed.

The Company shall respect the privacy of its employees’ private lives if it engages in practices for monitoring employees or collecting private information.

Food, water, toilet, medical or health care or other basic necessities shall in no way be exploited as a means of maintaining labour discipline.

11. WAGES AND PAYMENTS
At least the legal minimum wage or the corresponding applicable wage shall be paid for normal working hours (excluding overtime).

Sectoral surveys of market wages and associated benefits are conducted.

At the union level, the principles of the contract executed with the labour union prevail, and the conditions for all employees, whether unionised or not, are observed as close to each other as possible.

Payrolls are delivered to employees every pay period in return for signature or via e-mail. All earnings, benefits, deductions mandated by law, net wages and gross wages are indicated on the payslips.

Monthly salaries are deposited in cash into the employee’s bank accounts.

12. WORKING HOURS
Working hours, working durations, holidays, public holidays, breaks and shifts shall conform to all applicable laws and industry standards as well as the contents of the union agreement.

Overtime pay shall be calculated based on the rates set out in the relevant law and in accordance with the principles of the union contract.

The staff attendance register system is used to calculate working durations.

13. OCCUPATIONAL HEALTH AND SAFETY
To ensure a safe and sound working environment, SAN METAL A.Ş. takes adequate measures to prevent the occurrence of accidents and injuries in the event of accidents, and work is carried out to identify the causes of hazards specific to the work environment and to minimise them as much as possible.

Furthermore, emergency action plans have been established within the organisation against pandemic conditions and extraordinary circumstances, the plans have been published and are implemented when necessary.

The Company works to fulfil its obligations in relation to all national laws and regulations on health and safety issues.

All employees are trained in occupational health and safety. Also, these trainings recur in the periods and occasions stipulated in the relevant laws and regulations.

The healthcare service is provided by medical staff in the medical facility in accordance with national laws and regulations and sufficient number and duration. There shall always be a sufficient stock of medical supplies.

Our company analyses the risks of its machinery and working areas, and the risk analyses are updated in the times and conditions required by the relevant legislation.

Personal protective equipment is supplied and delivered free of charge by the management in accordance with the environment in which the personnel work and the work they do.

The job to be done by OHS is defined and reported at regular periods. OHS periodically examines the employees for the periods required by the relevant legislation. Periodic examinations of employees that require a special policy are repeated in the periods set by the workplace health unit.

Also, the health check-ups of the catering staff are carried out regularly at certain periods by providing the necessary information and follow-up through the suppliers. Instructions and checklists for cleaning and controlling the cafeteria in compliance with sanitary requirements have been developed.

Necessary precautions for hygiene, and cleaning plans are available, and activities are tracked with checklists.

Staff who have been trained in first aid and firefighting are available in the number required by the relevant legislation. A sufficient number of staff who have been trained in first aid and firefighting are available to respond to possible emergencies.

Except for extraordinary times, emergency evacuation drills are regularly practised every year.

Occupational accidents are documented. The cause of each occupational accident is investigated, and corrective and preventive actions are taken to prevent similar accidents.

Dust, lighting, vibration and noise are measured and the precautions to be taken for working areas above the threshold values indicated in the relevant legislation are determined.

Fire installations and fire extinguishers are checked regularly.

Earthing conditions of all machinery, measurements of lightning rods, and general electrical wiring are regularly checked and recorded every year.

14. DISCRIMINATION
No one shall be discriminated against based on their gender, race, religion, language, age, physical disability, sexual orientation, nationality, political preference, social group, or ethnic origin, including recruitment, wages and other rights, promotion, discipline, dismissal, or retirement during their employment.

Employees shall never be remunerated differently based on their gender, race, religion, age, physical disability, sexual orientation, nationality, political preference, social group or ethnic origin for work of equivalent value.

Medical examinations stipulated by the relevant legal regulations and deemed necessary by the workplace health unit are required as a condition when selecting or employing personnel.

15. WOMEN’S RIGHTS
No discrimination on the grounds of sex or marital status shall be imposed on anyone in recruitment, remuneration, participation in training provided, promotion, dismissal or retirement.

Pregnancy tests or the use of contraceptives shall not be required as a condition for recruitment or ongoing employment. Female workers shall never be asked to take a pregnancy test unless required to do so by national law. Where required by law, employers shall not require such tests (test results) as a condition of recruitment or ongoing employment.

Female workers shall neither be dismissed to prevent them from getting married or becoming pregnant, nor threatened with other employment decisions that would adversely affect their professional standing, nor shall any employment decision be taken that would adversely affect their professional standing, including those on dismissal, loss of seniority, or reduction in remuneration.

The conditions on maternity leave, breastfeeding leave and other rights in favour of pregnant employees and new mothers, as well as all protective conditions stipulated by national laws and labour regulations, are followed.

16. ENVIRONMENTAL SUSTAINABILITY
All legal requirements related to the environment are fulfilled, and efforts are made to continuously improve environmental performance.

All laws and regulations related to the safe handling, transport, storage, and other obligations of hazardous substances, chemicals, and materials are followed.

Material restrictions and product safety requirements stipulated in the relevant laws and regulations are followed, and the employees are made aware of product safety practices and are trained thereon.

Wastewater and solid wastes are sorted, treated and disposed of properly and in accordance with the relevant laws and regulations before discharge or disposal.

Material Safety Data Lists are available for all chemicals and hazardous substances used in the workplace.

Environmental management activities are carried out in accordance with the internationally recognised ISO 14001 management standard.

All necessary preparations are made during the preparation process for the European Green Consensus.

17. NON-COMPLIANCE WITH THE CODE OF ETHICS
Ethics Committee The Ethics Committee shall be responsible for investigating and resolving Complaints and notifications regarding the violation of ethical rules under the Social Responsibility Policy of SAN METAL.  Reporting to the General Coordinator, the Ethics Committee consists of people in the following positions:
Chairperson: Deputy General Coordinator
Member: Finance Director
Member: Production Director
Other members of the Executive Committee are also substitute members of the Ethics Committee.

Working Principles of the Ethics Committee
The Ethics Committee functions under the following principles:

  • They keep the reports and complaints and the identity of those who file them confidential.
  • They conduct the investigation as discreetly as possible.
  • They have the power to immediately demand relevant information, documents, and evidence from the department accessible. They may examine any types of information and documents they have acquired, but only if they pertain to the subject of the investigation.
  • Beginning to end, the investigative procedure shall be documented and signed. The report is updated with information, evidence, and documents.
  • The investigation shall be undertaken expeditiously, and a conclusion shall be reached as soon as possible.
  • The judgements made by the Committee shall immediately be put into practice. If necessary, the disciplinary board shall be notified of the matter.
  • The relevant departments and authorities are informed about the outcome.
  • The chairman and members of the Committee act independently of and free from any influence by their department managers and the hierarchy within the organisation. They shall not be forced or manipulated.
  • If the Committee deems it necessary, it may seek expert advice and benefit from experts throughout the investigation by using procedures that do not infringe the confidentiality principles.
  • The Company may pursue administrative and penal actions in accordance with the laws of the Republic of Türkiye and the norms, instructions and disciplinary provisions in force within the Company in the event of any violation of the Code of Ethics or inappropriate conduct on the part of employees.
  • For your inquiries and notifications, you can either use the e-mail addresses below or contact the members of the Ethics Committee directly.