Frequently Asked Questions

• Koç Group attributes great importance to honesty and accountability in all of its activities. It is our duty to maintain a culture of honesty and respect, and to oppose behaviors which might contradict the Koç Group’s ethical standards.
• By creating open channels of communication, we also promote a positive work environment and maximize productivity.
• An effective reporting system augments our other efforts to foster a culture of integrity and ethical decision-making.

Yes. EthicsPoint enables you to file a confidential, anonymous report via either the telephone or the Internet.

The EthicsPoint allows you to notify Koç Group about the past, present or potentially future illegal or unethical behaviors or activities, which include but are not limited to the following types of issues:

• Criminal activities such as theft and fraud,
• All kinds of discrimination (race, religion, language, color, gender, age, etc.)
• Violation of ethical rules, laws, moral values and regulations,
• Threats against social security or health,
• Inappropriate use of company equipment
• Fraudulent activities in the accounting records,
• Giving or receiving bribes,
• Disclosing the Group’s secrets,
• Money laundering,
• Environmental damage,
• Harassment,
• Mobbing.

When you observe some behavior that you believe violates Koç Group Code of Ethics, and/or the legislation, we expect any of our employee or stakeholders to report it. If you are an employee, we recommend that you first bring any concerns forward to your line manager or another member of your management team who can address the issue. We recognize, however, that there may be circumstances when you are not comfortable reporting the issue in this manner. It is for such circumstances that Koç Group partnered with NAVEX, an independent service provider. We would rather you report anonymously than keep the information to yourself.

We all have the right to work in a positive environment and with that right comes the responsibility of acting in an ethical manner and letting the right people know if someone is not acting appropriately. By working together, we can maintain a healthy and productive environment. And, corporate misconduct can threaten the very existence livelihood of an entire company.

We certainly do. In fact, we need you to report. You know what is going on in the Koç Group companies - both good and bad. You may have initial knowledge of an activity that may be cause for concern. Your reporting can minimize the potential negative impact on the related company and our people. Also, offering positive input may help identify issues that can improve corporate culture and performance.

Reports are entered directly on the EthicsPoint secure server. NAVEX makes these reports available only to specific individuals within the company who are charged with evaluating the report, based on the type of violation, location of the incident and considering the financial, reputational and regulatory impacts. Each of these report recipients has had training in keeping these reports in the utmost confidence. For details, please refer to Koç Group Whistleblowing Policy.

No. The Ethics Hotline is a positive aspect of our overall philosophy that allows us to ensure a safe, secure and ethical workplace. You are encouraged to seek guidance on ethical dilemmas, provide positive suggestions, or communicate a concern. Effective communication is critical in today’s workplace and this is a great tool to enhance that communication.

We have carefully chosen the best reporting tool to meet our compliance obligations while maintaining a positive reporting environment.

NAVEX does not generate or maintain any internal connection logs with IP addresses, so no information linking your PC to EthicsPoint is available.

If you feel uncomfortable making a report on your work PC, you have the option of using a PC outside our work environment (such as one located at an Internet café or at a friend’s house) through the EthicsPoint secure website.

A report from home, a neighbor’s computer, or any Internet portal will remain secure and anonymous. An Internet portal never identifies a visitor by screen name and the EthicsPoint system strips away Internet addresses so that anonymity is totally maintained.

The EthicsPoint system protects your anonymity. However, if you wish to remain anonymous, you - as a reporting party - need to ensure that the body of the report does not reveal your identity by accident. For example, “From my desk next to Mehmet…”.

Yes. You will be asked to provide the same information that you would provide in an Internet-based report and an interviewer will type your responses into the EthicsPoint Web site. These reports have the same security and confidentiality measures applied to them during delivery.

No, telephone conversations are not recorded

We do not reveal the caller phone numbers. In the case you do not want to share your phone number, we will go by the alternative way we provided which you choose.

There is a section in the report to identify yourself, if you wish.

Koç Group protects the Whistleblowers, even if the accuracy of the incident could not be proved by an Investigation, so long as the notification is made in good faith, with reasonable grounds and without an intent to victimize or create disadvantages to others or gain a personal advantage. However, those who deliberately make false notifications may be subject to various Disciplinary Penalties. Therefore, it is extremely important that the notifications are based on observations and can be proved, where possible.

Please refer to Koç Group Whistleblowing Policy for details.

All notifications reported through the Ethics Hotline are first assessed by the Assigned Personnel at the relevant Koç Group companies, depending on the subject of the report. The purpose of this preliminary assessment is to verify the notification’s subject and determine whether the information provided is reliable. Depending on the results, either the relevant Koç Group company itself conducts the investigation in line with its internal procedures or the case is brought into attention of Koç Holding. If the case is submitted to Koç Holding, the Internal Audit Department or the Legal and Compliance Department perform the Investigations, depending on their responsibility areas.

Please refer to the Whistleblowing Policy for details.

To the extent permitted by law, details of a concern raised by a Whistleblower is only shared with those who has authority to (i) investigate; (ii) assess the matter and (iii) take action, on a need-to know basis and whose names are not alleged in the related incident.

Koç Holding Internal Audit Department and the Legal and Compliance Department have unlimited access to all the notifications only if the notifications are not related to employees working in these departments, Internal audit functions and the officer or department in charge of compliance of the related Koç Group companies have limited access to the notifications only if the incident is linked to the related company, and the allegation is not related to the assigned users or the General Manager, Assistant General Managers or the Board of Directors of the relevant Koç Group Company.

An unethical behaviour may threaten the general interests of individuals, our companies and the society, and that it leads to injustice. It may cause material and moral damage. Furthermore, if the relevant behavior is a violation of applicable laws, it is not only a moral duty but a legal obligation to notify the authorities. Therefore, if you know of any incidents of misconduct or ethical violations, please consider it your duty to yourself and your coworkers to report it.

File a report. NAVEX can help you prepare and file your report so it can be properly understood. We'd rather you report a situation that turns out to be harmless than let possible unethical behavior go unchecked.

The EthicsPoint system and report distribution ensure that implicated parties are not notified or granted access to reports in which they have been named.

Regardless of the subject matter of your notification, if you want to remain anonymous, you can. You do not have to share your identity with NAVEX. Also, please note that if your notification is related to these people, the report is directly submitted to Koç Holding Internal Audit Department and the Legal and Compliance Department for further assessments. No employee of the relevant Koç Group company (other than Koç Holding) will have the right to reach out to your notification in this case. If your notification relates to a senior manager of Koç Holding, again, necessary measures will be taken to avoid conflicts of interest and to ensure that there will be a fair review.

When you file a report at the EthicsPoint Web site or through the EthicsPoint Call Center, you receive a unique, randomized number called a “Report Key” and are asked to choose a password. You can return to the EthicsPoint system again either by Internet or telephone and access the original report to add more detail or answer questions posed by a company representative. We strongly suggest that you return to the site in the time specified to answer company questions. You and the company now have entered into an “anonymous dialogue,” where situations are not only identified, but can also be resolved, no matter how complex.

All EthicsPoint correspondences are held in the same strict confidence as the initial report, continuing under the umbrella of anonymity.

To ensure that security and confidentiality is maintained, if you lose your report key or password, you will need to file a new report. Mention in the new report that it is related to a report or question you previously submitted.

It is not possible to recall a notification after it is delivered to the authorized departments at Koç Group. However, you can share your recall request by creating a new report.

You can file an EthicsPoint report from any computer that can access the Internet. You can file from home. Many public locations, including the public library, have Internet computers. If you don’t have access to or are uncomfortable using a computer, you can call the EthicsPoint toll-free hotline, which is available 24 hours a day, 365 days a year.