As NTG, we act with a sense of responsibility in our activities. In addition to our legal responsibilities, we take care to fulfill our responsibilities to our employees, customers, shareholders, suppliers and business partners, competitors, society, humanity and the environment.

2.1. Our Responsibilities Towards Employees

NTG A.S. as our basic principles and responsibilities in our relations with employees;

• To make selections based on merit in recruitment, to provide equal opportunities without discrimination,
• To recruit qualified employees who will carry our company to the future,
• Making maximum use of the talents, power and innovation skills of the employees,
• To provide opportunities and equal opportunities for the training, orientation and development of employees,
• To reward success with fair and competitive wage policies, effective and objective performance evaluation system,
• To increase loyalty to the company by providing equal opportunity in career opportunities and rewarding,
• To ensure work peace and continuity,
• To ensure that the physical working environment and conditions of the workplace are healthy and safe for all employees,
• To create and maintain a transparent working environment that encourages mutual respect, where cooperation and solidarity are important elements,
• To not tolerate discrimination among employees based on language, race, color, gender, political opinion, belief, religion, sect, age, physical disability and similar reasons,
• Not to allow any form of physical, sexual or psychological harassment in the workplace,
• Not tolerating systematic and planned behaviors that aim to alienate the targeted person from work, reduce his/her performance, and cause him to resign, in a way that will be evaluated within the scope of psychological harassment (mobbing),
• Evaluating and responding to the opinions and suggestions of the employees and taking motivation-enhancing measures,
• Not to share private information about employees with third parties without the employee's permission and knowledge, except for legal obligations,
• To respect the private and family life and personal spaces of employees,
• To respect human rights.

2.2. Our Responsibilities Towards Shareholders

• To ensure that our company is managed within the framework of the principles of ongoing trust and honesty, and to manage its resources, assets and working time with efficiency awareness by targeting sustainable growth and profitability.

2.3. Our Responsibilities Towards Law and Government

• To carry out all our current activities and transactions at home and abroad within the framework of the laws of the Republic of Turkey and international law,
• To present accurate, complete and understandable information to legal regulatory institutions and organizations in a timely manner,
• To be at an equal distance to all kinds of public institutions and organizations, administrative formations, non-governmental organizations and political parties without any expectation of benefit and to fulfill our obligations with this sense of responsibility while carrying out all our business activities.

2.4. Our Responsibilities Towards Our Customers

• Creating value for customers, responding to their demands and needs in the shortest time and in the most accurate way,
• To provide quality products and services,
• To create a long-term trust environment in relations with customers,
• To increase customer satisfaction in the sales and after-sales process,
• Approaching our customers within the framework of respect and courtesy rules
• Not giving misleading and incomplete information to customers
• To protect the confidential information of our customers with care.

2.5. Our Responsibilities Towards Our Suppliers and Dealers

• To create mutual value in business relations with suppliers and dealers,
• To carefully protect the confidential information of the persons and organizations we do business with and our business partners.

2.6. Our Responsibilities Towards Our Competitors

• Competing effectively only in legal and ethical fields, avoiding unfair competition,
• To not denigrate competitors and their products,
• To not negotiate and exchange information with competitors to determine the market and/or competition conditions together.

To make sure that our employees, who are assigned the task of representing the Company in invitations such as tenders, promotions, invitations, seminars, and sector-oriented meetings held in public or private areas, with the representatives of the rival companies that they will be with during this meeting do not talk about company activities, sub-dealers, market competition conditions or other domestic and foreign competitors in any way. Not to dominate against other competitors by establishing a partnership with a competitor in a tender or project. To always remain as a spectator in such meetings, not to make a speech that binds the company, and not to make any promises.

2.7. Our Responsibilities Towards Society

• To act sensitively as a pioneer in social issues with the awareness of being a good citizen; Trying to take a role in activities that support economic and social development in services for the public interest,
• To be sensitive to the traditions and cultures of Turkey and the countries where we carry out international projects,
• To act in accordance with the Labor Law and the International Labor Organization (ILO) agreements, to which the Republic of Turkey is a party, on the issue of not employing child labor, and to ensure that our suppliers are in compliance within the scope of the said legislation,
• To not offer bribes; to not offer gifts, etc in excess of the purpose or provide or accept products and services.

2.8. Our Responsibilities Towards Environment and Human Health

• To carry out all our activities and investments in harmony with the environment and to evaluate the environment in terms of sustainable use of natural resources and minimizing the negative effects that may occur in nature,
• To protect nature in compliance with environmental legislation, to develop innovative solutions to continuously improve environmental performance, to increase recycling, to work for efficient use of energy and materials,
• To raise awareness of employees and subcontractors by providing environmental training,
• To comply with all occupational safety and health laws and standards in our work,
• To apply the principles of "Risk Management" in order to create a safe and healthy work environment,
• Ensuring and compelling the use of adequate protective equipment and taking security measures,
• To draw attention to the fact that applying company policies and regulations regarding health and safety at the workplace is an important responsibility that all our employees should pay attention to.

Ethical rules and working principles reveal the basic rules about how we should behave and how we should do our job. Compliance with these rules is the primary responsibility of all employees. Accordingly, the expectations from all NTG employees are;

3.1. Honesty

Integrity and honesty are our primary values ​​in all our business processes and relationships. We expect to act with integrity and honesty in our relations with our employees and all our partners

3.2. Avoiding Conflict of Interest

• A conflict of interest is a situation that indicates the potential of a person or institution to obtain personal or corporate benefits by improperly using their status.
• It is essential that NTG Employees fully comply with the situations and principles specified below as activities that may cause conflict of interest.
• Employees do not enter into a business relationship that provides mutual or reciprocal benefits with their family members, friends or other third parties in any way. For example, an employee with purchasing authority should avoid doing business with a supplier where a family member works. Exceptional cases are subject to the knowledge and approval of the Chairman of the Board of Directors. Likewise, Company employees should also be mindful of conflicts of interest that may arise due to their close family members working for competing companies.
• It is essential that NTG employees do not work for another person and/or institution for a fee or similar benefit, during or outside working hours, under any name, and do not engage in any work that requires them to be considered "traders" or "traders" directly or indirectly. However, if the employees work outside working hours for another person (family member, friend, other third parties) and/or the institution in return for a wage or similar benefit;
• Not creating a conflict of interest with the duties they hold in the company and the practices of the company,
• Not inconsistent with other business ethics rules and policies supporting these rules,
• Does not adversely affect their ability to continue their duties in the company,
• It is possible with the conditions of written approval of the Board of Directors as stated below.

Personnel working as arbitrator, mediation, expert witness given by the judicial and administrative authorities are excluded from this restriction.

• NTG employees cannot be a board member or auditor without the approval of the Company's Board of Directors; cannot take office in competitor or companies with which the Company has business relations. They can work in non-profit organizations and universities in social responsibility and charitable roles with the written approval of the management, provided that they do not disrupt their duties within the Company.
• Managers who are in a position to make a hiring decision cannot hire their spouses, close relatives and relatives of these people.
• Employees can make speeches and write professional articles on subjects that are not related to the company and its activities and are not contrary to its policies. In order to use the name of the Company in these activities, the approval of the Board of Directors is required.
• Employees may make personal financial or moral aid and/or donations to third parties outside the Company, and may take part in charitable organizations. Employees do not become members of any club, association or cooperative by using the Company name and position.
• Employees take care not to have a conflict of interest with the current employer in their personal investments.
• Employees inform their superiors if it is learned that their relatives have shares or material interests in another company with which they have a commercial relationship.
• In NTG, it is essential that employees who have kinship relations (including spouses and third-degree relatives) in NTG do not have a reporting relationship (subordinate-superior relationship) with each other in the same organization or take part in decision-making mechanisms together.
• Employees are sensitive about the correct use of company resources. They are careful about the effective use of time during business hours and not allocating time for private affairs during business hours. Managers cannot assign employees for their personal work. It is essential that special visitors are not accepted during working hours. Employees are required to complete the negotiations for compulsory visitors in a reasonable time in connection with the subject of the visit and in a way that does not hinder the work flow.
• Private business relations cannot be entered into, personal loan money and/or goods/services cannot be obtained, and money and/or loans cannot be made to other persons and/or organizations with which the Company has commercial relations, with the Company's customers, subcontractors or suppliers and other persons and/or organizations with which the Company has commercial relations. / or goods / services cannot be provided.
• In relations with customers; Even in favor of the customer, a transaction cannot be made without the knowledge of the customer, the weaknesses of the customer cannot be exploited, and a profit cannot be motivated by giving incomplete or incorrect information to the customer.
• In relations with the media, action is taken within the scope of the Company Communication Protocol.
• To make a statement to any broadcasting organization, to make an interview,
• seminar-conference etc. Participation as a speaker is subject to the approval of the Company's Board of Directors. No personal gain can be obtained from these activities.

3.3. Participation in Representation and Organization Invitations

Conference, reception, promotional events, seminars, etc. that are open to general participation by persons or intitutions with whom there is or there mihgt be a potential of business relationship; sports activities outside of the country, which are or might be influential in decision-making or can be perceived as such, domestic / international trips, etc. and invitations is subject to the approval of the Chairman of the Board of Directors.

3.4. Accepting and Giving Gifts

It is essential that NTG employees do not ask for gifts, gains, aid, entertainment, special discounts, commissions or discounts that may affect their impartiality, decisions and behaviors for their own benefit, or do not accept such offers.

All kinds of gifts from people or institutions with which we have commercial relations are delivered directly to the Human Resources Department. The Human Resources Department determines how the collected gifts will be evaluated with the approval of the Senior Management.

It is essential that our employees do not accept gifts of cash or cash equivalents or borrow money from suppliers, consultants, competitors or customers.

Our employees can organize entertainment and dining activities within reasonable limits in the business world and participate in similar activities. In seminars and similar organizations attended on behalf of the company, awards, plaques and similar gifts with symbolic value can be received as a memory of the day other than money.

Our employees cannot give gifts to institutions and persons with whom they have a business relationship, other than the gifts that the company has prepared for promotional purposes. Gifts and promotional materials determined to be given to customers, dealers or other third parties with whom they have business relations must be approved by the Board of Directors.

Giving, receiving or offering bribes and/or kickbacks is unacceptable under any circumstances.

3.5. Doing Business with the Company by Resigned Employees

For employees leaving NTG to do business with NTG as a seller, contractor, consultancy, brokerage, representation, dealership or similar, there should be no conflict of interest due to previous duties in the company.

In order for an employee leaving NTG to do business with NTG, a report to be prepared by the manager of the relevant unit must be approved by the Board of Directors.

3.6. Information Management

It is essential that NTG employees show sensitivity to asset and information management and fully comply with the principles stated below.

• To ensure that legal proceedings are initiated in a timely manner in order to secure the intellectual property rights of newly developed products, processes and software,
• Avoiding - knowingly - unauthorized use of patents, copyrights, trade secrets, trademarks, computer programs or other intellectual and industrial property rights of other companies.
• To ensure that all legal records are kept accurately and completely,
• Not responding to information requests from third parties, which are classified as confidential for the company, without the approval of the senior management,
• To take the necessary care to ensure that the statements and reports made by the company are in accordance with the truth.

3.7. Protection of Confidential Information

Confidential information is not limited to these; In addition to the intellectual property rights of NTG and all kinds of innovations; The database written, found, developed or implemented by the personnel, printed communication materials, business processes, advertising, product packaging and labels, and business plans (marketing, product, technical), business strategies, strategic partnerships and information on partners, financial information, personnel It includes personnel information, customer lists, price, product designs, know-how, specifications, identification information of potential and real customers, information about suppliers and any similar written, graphic or machine-readable information.

It is essential that NTG employees show sensitivity regarding confidential information and fully comply with the principles stated below.

• Confidential information cannot be disclosed to third parties unless disclosure is required in accordance with judicial decisions and legislation.
• Confidential information should not be altered, copied or destroyed. Necessary measures are taken to ensure that information is carefully kept, stored and not disclosed. Changes on the information are recorded with its history.
• Confidential documents and information should not be taken out of the institution. In cases where it is necessary to be taken out of the institution, the approval of the person responsible for the information and the top manager (Coordinator) of the relevant upper unit should be obtained.
• Passwords, user codes, authorizations and similar identifying information used to access company information systems should be kept confidential and should not be disclosed to anyone other than authorized users.
• Confidential information of the company must not be revealed in public places such as dining halls, cafeterias, elevators or service cars,
• If information is shared with third parties and/or organizations for the benefit of the company, a confidentiality agreement is first signed or a written confidentiality commitment is obtained from the other party in order to ensure that the responsibilities of these individuals and organizations regarding the security and protection of the shared information are understood.
• Unfounded statements and/or gossip about persons or institutions cannot be made.
• The wages, fringe benefits, etc. of the personnel that reflect the company policy and are personal. Personal information is confidential and should not be disclosed to anyone other than the authorities. Employee information is sent privately. Employees may not disclose this information to others or pressure other employees to disclose the information.
• Even if it is not stated in writing that it is confidential, the confidentiality of all kinds of information and documents specified in the definition must be protected, and this responsibility of our employees continues during their employment and in case they leave the job.
• Act in accordance with the legislation on the Protection of Personal Data.

3.8. Occupational health and Safety

Our company has aimed to fully ensure occupational health and safety in the workplace and on the job. Employees act in accordance with the rules and instructions set for this purpose and take the necessary precautions.

• Employees shall not keep in the workplace any goods or substances that are dangerous or illegal for the workplace and/or employees,
• Employees; Except for those based on a valid doctor's report, they will not have alcohol, drugs, addictive, mental or physical abilities restricting or eliminating substances in the workplace, and will not work in the workplace or within the scope of work while under the influence of such substances,
• Employees will not drink alcohol at meals and receptions they attend due to their position in the company and on behalf of the company.

3.9. Political Activities

• Our company does not make donations to political parties, politicians or political candidates. In these matters, demonstrations, propaganda and similar activities are not allowed. Company resources (such as vehicles, computers, e-mails) are not allocated to political activities.
• NTG employees are obliged to observe the following conditions in their political activities individually and voluntarily.
• Employees should stay away from situations that may cause a conflict of interest in their current duties and responsibilities due to the political activities they are involved in.
• Company name, title within the company and company resources cannot be used in individual political activities.
• Political propaganda cannot be made during working hours and in the workplace environment, employees cannot be asked to be members of a political party in any way, and the time of other employees cannot be taken for these activities.

4.1. Duties and Responsibilities

4.1.1. Duties and Responsibilities of Employees

Ethical rules and working principles set out the basic rules on how to behave and how our work should be done. Compliance with these rules is the primary responsibility of all employees. Accordingly, all NTG employees:

• Act in accordance with laws and regulations in all circumstances,
• Learn and apply the general and task-specific policies and procedures applicable to the company,
• Act in full compliance with the rules and instructions within the scope of Occupational Health and Safety and taking the necessary precautions while doing business,
• Participate in trainings on NTG ethical rules and working principles, reading, understanding and acting in accordance with the relevant documents,
• Declare an annual declaration of compliance with the Code of Ethics and Working Principles,
• Promptly communicate the possible violations observed to the Ethics Committee, either in writing or verbally, through the ethical line communication channels, named or anonymously, and sensitively avoiding all kinds of slanderous notifications,
• Take the responsibility to cooperate with the Ethics Committee in ethical examinations and to keep the information related to the examination confidential.

4.1.2. Duties and Responsibilities of Managers

NTG managers have additional responsibilities beyond the responsibilities defined for employees within the framework of the Code of Ethics and Working Principles. Accordingly, managers;

• Ensure the creation and maintenance of a corporate culture and working environment that supports ethical rules,
• Set an example for the implementation of ethical rules with its behaviors, to train its employees on ethical rules,
• Support their employees in submitting their questions, complaints and notifications about ethical rules,
• Provide guidance on what to do when consulted, to consider all notifications and to forward them to the Ethics Committee as soon as necessary,
• Be responsible for ensuring that the business processes under its responsibility are structured in a way that minimizes the risks related to ethical issues and implement the necessary methods and approaches to ensure compliance with ethical rules.

4.2. Resolution of Incompatibilities

Violators of the Business Ethics and Code of Conduct or Company policies and procedures will be subject to a variety of disciplinary sanctions, up to and including, if necessary, dismissal. Disciplinary sanctions will also be applied to those who approve or direct the inappropriate behavior and actions that cause breaking the rules, or who have knowledge of these issues and do not make the necessary notification properly.

4.3. Ethics Committee

4.3.1. Ethics Committee Organization

Incompatibilities on ethical issues are resolved within the NTG Ethics Committee. Ethics Committee; It consists of the Chairman of the Board of Directors, the Vice Chairman of the Board of Directors, Human Resources (Chief Manager or Advisor), Legal Advisor and members of the Board of Directors. The Ethics Committee acts as the rapporteur of …………….

4.3.2. Ethics Committee Working Principles

The ethics committee carries out its work within the framework of the following principles:

• It keeps the identity of notifications and complaints and those who make notifications or complaints confidential. It adopts a policy to prevent possible retaliatory attitudes and behaviors towards employees or individuals who report ethical violations.
• Conducts the investigation within the rules of confidentiality.
• It has the authority to request information, documents and evidence related to the investigation directly from the unit available.
• The investigation process is written down from the beginning. Information, evidence and documents are added to the report.
• The minutes are signed by the chairman and members.
• The investigation is handled promptly and the result is reached as quickly as possible.
• Decisions taken by the Board are put into effect immediately.
• Relevant departments and authorities are informed about the result.
• The chairman and members of the board act independently and unaffected by the department managers and the hierarchy within the organization while performing their duties on this issue. They cannot be pressured or indoctrinated on the subject.
• If the Board deems it necessary, it may seek expert opinion and benefit from experts by taking measures that will not violate the principles of confidentiality during the investigation.

NTG Ethic Rules and Working Principles have been published with the approval of the Chairman of the Board of Directors and are reviewed once a year in line with needs, changing conditions and current practices.

For your questions and notifications, you can use the following communication channels or contact the members of the Ethics Committee directly.

E-mail: etik@ntgplastik.com