Ethical Rules

1.AIM

To determine the principles of ethical behavior that all personnel working at Era Grup Aluminum must apply while carrying out their duties.

2.CONTENT

Era Group Aluminum Business Ethics Rules covers all employees.

3.DEFINITIONS

Code of Ethics; It is a set of rules that guide all our attitudes and behaviors while carrying out our activities and business within the framework of laws, regulations and procedures.

4.RESPONSIBILITIES

The Human Resources Manager is responsible for the preparation of this instruction, and the General Manager is responsible for its approval.

All department managers are responsible for implementing and enforcing this instruction in the departments they are responsible for within the company.

All employees are responsible for knowing, understanding and applying the principles contained in the Codes of Ethic. Era Grup Aluminum exhibits attitudes and behaviors in accordance with the Codes of Ethic detailed below in all its activities and relationships towards the people and organizations with which it has business relations at home and abroad, its society, its customers, suppliers, partners and employees, to comply with the ethical criteria accepted by the company and, in particular, to It undertakes to strive for the widespread adoption of all these principles, including in its own sector.

5.SHARE

The instruction will be shared digitally to all employees.

6.APPLICATIONS

1.Honesty:

It complies with its promises and agreements regarding the products it provides to its customers. Era Grup Aluminum avoids unauthorized use of patents, copyrights, trade secrets, trademarks, computer programs or other intellectual and industrial property rights by itself or through other companies. Era Grup Aluminum cannot be a part to agreements (such as price-fixing agreements) with competitors or other persons or organizations that restrict freedom of trade. Does not engage in deceptive behavior by making misleading statements and promotions about the commercial and financial situations of the company and others. Era Grup Aluminum does not use derogatory, sarcastic or offensive statements about other institutions and organizations, products and people.

2.Respect To Law:

It acts in accordance with legal rules in all its activities. It controls the legal provision of continuous services received from other organizations and carries out the necessary follow-up. Era Grup Aluminum aims to fulfill its tax and other legal obligations fully and on time and to set an example for the society. Does not engage in illegal or criminal activities. It does not resort to methods that would not be approved by business and social ethics in business life. Employees do not engage in any behavior to represent the company to third parties unless expressly authorized by managers and they do not exchange letters on this issue.

3.Human Resorces:

Era Grup Aluminum protects the rights of its employees within the framework of business ethics rules in cases where the law is inadequate. Avoids all kinds of coercive and pressured work. It completely fulfills its legal obligations towards all employees of the company. Regardless of religion, language or race, to prevent child labor and discrimination in hiring and working processes.

It does not interfere with the private information of its employees and their private lives, and keeps all kinds of information confidential. It takes into account suitability for duty as a criterion in recruitment, promotion and appointments. It does not discriminate against gender, age, ethnicity and religious belief in its practices towards employees. It creates healthy and safe working conditions at the level required by laws and conditions and tries to improve them within the means possible. It keeps private information about its employees (health, economic data, etc.) that can be obtained through various channels and does not share it. Employees avoid any behavior that could damage the image and reputation of the company. During working hours, they do not deviate from the clothing style and behavior previously determined by the company management or generally accepted.

4.Obtaining, Using and Protecting Information:

Era Grup Aluminum provides accurate and complete information about the company and its activities to the public and relevant social stakeholders within the framework of its information policies. It does not share the private information of the companies that serve it with third parties without their permission. Employees cannot leak confidential and private information learned as a result of their position or work outside the company. Employees must comply with the company’s business information and confidentiality obligations even after leaving the company. All kinds of documents that employees use or create while doing their jobs belong to Era Grup Aluminum. These documents must be truthful. Salaries, side benefits and similar personal information of personnel, which reflect company policy and are personal, are confidential and cannot be disclosed to anyone except officials. Employee information is sent specifically to the individual. It is unacceptable for staff to disclose this information to others or to pressure other employees to disclose the information.

5.Occupational Health and Safety and Environment:

Occupational Health and Safety (OHS) has a very important place at Era Grup Aluminum. Each employee is responsible for the occupational safety of both theirself and her colleagues, as well as all procedures and instructions regarding OHS and the Environment that they are obliged to comply with.

Each employee is obliged to know this defined policy and do what is necessary. All employees must comply with the rules determined in line with these security policies and carry out all their work within this scope. It supports a preventive approach to environmental issues before harm occurs. It takes initiatives to spread more effective environmental responsibility. It strives to develop and disseminate environmentally friendly technologies. It has adopted the principle of not polluting the environment and keeping the soil, water and air clean in all its activities.

6.1. PRACTICES THAT SUPPORT THE CODES OF ETHIC

6.1.1 Protection and Efficient Use of Assets:

Company interests are taken into account in the use of assets on behalf of the company. Company assets (such as machinery, equipment, vehicles, fixtures, goods, raw materials, auxiliary materials, etc.) cannot be used outside their intended purpose or without authorization, under any name, on whose behalf or for whose benefit it is, without the interest of the company. Company assets cannot be taken out of the company without approval outside working hours. Employees can only use their time during working hours for their job. Managers cannot assign employees to their personal work. All employees must use company resources in the most efficient way possible. The employee must use time, which is one of the most important resources, effectively, and must complete meetings for mandatory visitors within a reasonable time without hindering the workflow.

To protect the company’s cash assets; all payments must be made accurately and in sufficient detail – by persons authorized for the goods and only for the purpose recorded in the payment document. No payments can be made on behalf of the company unless supported by sufficient documents, without authorized approval and under the name “urgent” or similar.

6.1.2 Commitment to the Principle of Savings:

Era Grup Aluminum adopts the principle of preventing waste and paying attention to savings in the use of resources in its activities and projects. This principle should be taken into consideration in business-related decisions and internal audits. Likewise, our employees approach the economical and highly efficient use of our organization’s financial resources with the same sensitivity they show to their own family budgets. Each Era Group Aluminum employee should be aware and understanding of the fact that this type of behavior, adopted as a common corporate principle, will give their company a competitive advantage.

6.1.3 Information Technologies Use and Security:

Our principle regarding Information Technology Security is to keep the factors that put data loss and data security at risk to a minimum. Our employees (end users), who have an important place in supporting the security of information in the electronic environment, are required to show due care in keeping their passwords confidential and not sharing them with anyone, including their colleagues. All Era Grup Aluminum employees’ personal computer, e-mail and internet use is respected to the extent of their personal information privacy rights. If there is a violation of Era Grup Aluminum Business Codes Of Ethic, electronic communication channels can be controlled as necessary. Apart from these, all Era Grup Aluminum employees should not have any expectation of privacy when using company computers and e-mail accounts.

6.1.4 Conflict of Interest and Gaining Unfair Benefits:

Employees cannot take advantage of their current duties to provide benefits for themselves, their relatives, their families and/or third parties and institutions/organizations with which they have a business relationship, outside the employment contract.

Works that may affect the important fundamental elements of Era Grup Aluminum, that would be contrary to the interests of the company, or that would benefit Era Grup Aluminum cannot be carried out on behalf of oneself or third parties, including their close relatives. Employees cannot obtain personal benefits, directly or indirectly, from all transactions and contracts to which the company is a party.

6.1.5 Working in Another Job:

It is essential that Era Grup Aluminum employees do not work for another person and/or institution for a fee or similar benefit, during or outside working hours. Employees can work in non-profit organizations and universities in social responsibility and charity roles with the approval of the management, without disrupting their duties within the company. Employees make such requests to the Human Resources department with the knowledge of the relevant department manager.

6.1.6 Accepting and Giving Gifts:

It is essential that Era Grup Aluminum employees do not accept gifts or benefits that will enable them to make biased decisions, affect their behavior, are not in line with the course of business, or are intended to provide privileges or benefits. It is essential that no attempt is made to provide gifts or benefits to third parties, institutions and organizations that may create such effects. . Company employees cannot accept free or borrowed money from subcontractors, suppliers, consultants or those in similar positions such as customers. In addition, the employee cannot have the other party pay his/her travel expenses, activity expenses and similar payments. Era Grup Aluminum employees are prohibited from acting biased while performing their duties or receiving gifts, etc., that have a monetary value that would affect their ability to make the right decisions. .

Company employees; They may receive and/or give gifts provided that they are suitable for the purpose of doing business, do not conflict with laws and regulations, and do not damage the company’s image and reputation if external stakeholders learn about the gift.

Company promotional materials may be given or used with approval for their business partners, friends, or personal use, without serving any benefit.

Under the conditions mentioned above;

Company employees may provide and/or accept entertainment, treats, and meals at acceptable standards on behalf of the company. They may receive and/or give symbolic gifts such as awards, plaques, trophies, certificates, etc., with symbolic value at fairs, festivals, seminars, and similar events attended on behalf of the company, apart from money. .

In the situations mentioned above, and for gifts and other non-monetary items, separate approval is not required for each calendar year and each gift-giving individual/organization, provided they comply with the specified conditions. Additionally, in compliance with the specified conditions, the company may accept suitable products and services as gifts, and with the knowledge and approval of the company’s top management, products or services appropriate to the recipient’s culture and ethical values may be given as gifts.

Receiving or giving gifts or benefits based on an explicit or implicit conflict of interest is prohibited. Gifts and promotional materials to be given to customers, dealers, and other third parties in business relations are determined and approved by the company’s top management. Separate permission is not required for the distribution of these approved gifts and promotional materials.

In exceptional cases where local cultural values require mutual gift-giving beyond the values determined in the company policy, these gifts may only be accepted with the approval of the company’s top management. These gift exchanges will be in accordance with the region’s and country’s culture.

6.1.7 Bribery/Corruption and Malpractice:

Under no circumstances is it acceptable to accept, give, or offer bribes and/or commissions, regardless of their name. No employee, directly or indirectly, can offer or commit to offer money or anything of value to any person in a business relationship with the aim of obtaining undue advantage, nor can they facilitate the giving of money or anything of value. Employees must diligently avoid unethical behaviors such as bribery, corruption, and abuse of position.

6.1.8 Business Ethics and Conduct:

All Era Group Aluminum employees must perform their duties in an egalitarian, transparent, accountable, and responsible manner. Mutual love, respect, trust, and collaboration should be the guiding principles in relationships with colleagues and other individuals. In carrying out their duties within Era Group Aluminum, all employees are obliged to respect the rights and cultural differences of individuals. Era Group Aluminum employees should refrain from engaging in harassment, abuse, violence, etc., either within or outside the company, and should not exhibit behaviors contrary to the customs and traditions of society, such as being recognized as intoxicated or a gambler. Furthermore, they should also avoid situations that would amount to mobbing as regulated by laws, as such behaviors would negatively impact the Era Group Aluminum community and tarnish the corporate image.

6.1.9 Internal Control and Internal Audit:

Era Group Aluminum has established and defined internal control procedures to ensure the protection of company reputation and assets, efficient use of company assets for their intended purposes, and the reliability and accuracy of financial records and produced reports. All employees must perform their duties in accordance with the internal control procedures each time. The internal audit unit will investigate compliance with control procedures in business processes through audits it conducts. However, the responsibility for the company’s internal control system is not solely the responsibility of management and the internal audit unit; all employees must take ownership of the internal control system. For example, an employee in the warehouse, as well as a security guard, should suggest corrections for any incomplete or incorrectly performed tasks.

6.2 STAKEHOLDER RELATIONS AND RESPONSIBILITIES

6.2.1 Relations with Print and Social Media:

Providing statements, giving interviews to any media organization, participating as a speaker in seminars, conferences, and similar events on behalf of Era Group Aluminum is subject to the approval of the company’s top management. It is prohibited to use the company name on social media without written approval. Employees cannot make statements or comments on religious, social, political, etc., issues using the company name on social media without written approval. Official statements to the media are made explicitly by authorized individuals designated by the management.

6.2.2 Responsibilities of Employees:

All Era Group Aluminum employees are expected to exhibit behavior consistent with company procedures and rules and uphold these principles in all their work.

All employees should read, understand, internalize, and act in accordance with the Era Group Aluminum Business Ethics Rules, be aware of the rules, principles, and values contained therein, be aware of and comply with general and job-related policies and procedures applicable to the company, encourage the compliance of their colleagues with these procedures as much as their own, and if there are those who do not comply with the rules and those who are intentionally or unintentionally involved in mistakes, they must report them first to the relevant unit manager and if the relevant manager is involved in the mistake, they must report it directly to the internal audit unit.

6.2.3 Responsibilities of Managers:

All managers should ensure that their employees are aware of the Era Group Aluminum Business Ethics Rules. Managers are responsible for creating and maintaining a company culture and work environment that supports ethical rules, setting an example with their behaviors that support the ethical rules, leading the implementation of ethical rules, and encouraging and supporting their employees to report questions, complaints, suggestions, and notifications related to ethical rules to the internal audit unit.

6.2.4 Responsibilities of Business Partners:

Customers and suppliers doing business with Era Group Aluminum must report any particularly error- and fraud-related business and transactions they encounter regarding Era Group Aluminum employees promptly and completely, first to the relevant unit manager and if the relevant manager is involved in the mistake, directly to the internal audit unit.

6.3 COMPANY RESPONSIBILITIES TOWARDS STAKEHOLDERS

On behalf of Era Group Aluminum, management takes care to fulfill the following responsibilities to its stakeholders, in addition to legal obligations, including customers, employees, company partners, suppliers and business partners, competitors, society, and humanity. These are;

6.3.1 Legal Responsibilities:

Conducts all activities and transactions both domestically and internationally within the framework of Turkish laws and international law, providing accurate, complete, and understandable information to legal regulatory authorities in a timely manner. Any form of unrecorded activity is prohibited, and accuracy and consistency of records and documents are essential. All activities and transactions are conducted with a sense of responsibility, observing the benefit of society, without any expectation of benefit, and maintaining an equal distance from all kinds of public institutions and organizations, administrative bodies, civil society organizations, political parties, etc.

6.3.2 Responsibilities Towards External Customers:

Era Group Aluminum operates with a customer satisfaction-oriented approach, responding to its customers’ needs and requests in the shortest and most accurate manner possible. It provides its services promptly and under promised conditions. It approaches its customers with respect, justice, equality, and courtesy.

6.3.3 Responsibilities Towards Employees:

Employees’ rights are fully and accurately provided. Employees are treated honestly and fairly, and a safe and healthy working environment is provided. Efforts are made for the individual development of employees. Suitable social and community activities in which employees will participate with a sense of social responsibility are supported. The balance between work life and personal life is respected.

6.3.4 Responsibilities Towards Suppliers/Business Partners:

Obligations are fulfilled in a timely manner. The confidential information of individuals and organizations with whom business is conducted and business partners is carefully protected.

6.3.5 Responsibilities Towards Competitors:

Competition is conducted in legal and ethical areas, avoiding unfair competition. Competitors’ products are not denigrated, and misleading advertising is avoided.

6.3.6 Responsibilities Towards Society, Humanity, and Nature:

With a sense of citizenship, it is aimed to take a leading role in social issues, act sensitively in situations such as natural disasters, provide services for the public good, and be sensitive to the traditions and cultures of the regions where activities are conducted, both in Turkey and internationally. Efforts are made to take all necessary measures for the protection of nature and wildlife, consumer rights, and public health in the areas where activities are carried out, in accordance with legal regulations or even if not mandatory.

6.4 APPLICABLE LEGISLATION

As Era Group Aluminum operates in domestic and international markets, the company’s operations are subject to both Turkish laws and regulations of different countries. When there are concerns regarding ethical business conduct in different countries, priority should be given to compliance with the legal regulations in the country where the business is conducted. In such cases, the legal procedures in the country/countries where the business will be conducted should be followed first, and if the activities of Era Group Aluminum that will operate on the international platform may result in adverse consequences in terms of the ethical values adopted, solutions should be sought within the ethical rules and procedures we have. If necessary, advice should be sought from the ethics committee.

6.5 DETERMINATION OF ETHICAL COMPLIANCE

To assist in ensuring compliance with Era Group Aluminum Business Ethics Rules in all business processes and activities, “Key Questions to Consider Ethically” has been prepared.

6.6 QUESTIONS TO CONSIDER FROM AN ETHICAL PERSPECTIVE

Do I know how I should behave according to Era Group Aluminum Business Ethics Rules?

Is my behavior in line with company policies and procedures, as well as laws and regulations?

Is my behavior balanced and fair? Would I be uncomfortable if someone else did it?

Is what I am asked to do compliant with laws and Era Group Aluminum Business Ethics Rules?

Is the behavior I have witnessed compliant with laws and Era Group Aluminum Business Ethics Rules?

Would Era Group Aluminum and our stakeholders be uncomfortable if all the details of this behavior were made public?

Would I be in a difficult situation or embarrassed if others knew that I was engaging in this behavior?

Yaptığım davranış, benim için veya Era Grup Alüminyum için olumsuz sonuçlar doğurabilir mi?

Who else might be affected (other employees, partners, etc.)?

How did this Behavior look?

How would it be reflected in the press and media?

What would a reasonable person think in the same circumstances?

6.7 RESOLVING NON-COMPLIANCE WITH CODES OF ETHIC

Those who violate the Code of Business Ethics, company policies, and procedures may be subject to various disciplinary sanctions, up to and including termination if necessary. Disciplinary measures will also apply to those who approve, direct, or have knowledge of actions that violate rules and fail to report them appropriately.

6.8 ETHICS COMMITTEE

The Ethics Committee is tasked with investigating and resolving complaints and reports of violations of ethical rules within the framework of Era Group Aluminum’s Code of Ethics. Reporting to the General Manager of Era Group Aluminum, the Ethics Committee consists of the following specified titles and individuals.

Ethics Committee Chairman: Chairman of the Board of Directors

Ethics Committee Member: General Manager

Ethics Committee Member: Factory Manager

Ethics Committee Member: HR Manager

Ethics Committee Member: Quality Manager

Ethics Committee Member: Operations Manager

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