As a leading company operating in the Turkish automotive supply industry, Takosan exports its products to various countries.

At Takosan, we place sustainability at the heart of how we do business and strive to leave a healthier and happier world for next generations. We value the environment, the employees, and society, and consider them in our production processes while encouraging our suppliers to develop a similar approach.

With the Supply Chain Policy (“Policy”), Takosan defines the environmental, social and ethical responsibilities expected from all its global suppliers and service providers.

We expect our suppliers to comply with the Policy and communicate the Policy to their employees and supply chains as well. We include this Policy in all global supplier agreements and select our suppliers from among the organizations that comply with the Policy.

This Policy is based on International Labor Organization (ILO) Conventions, United Nations Global Compact, United Nations Convention on the Rights of the Child, and applicable national laws.

SUPPLIER GUIDELINES

The Supplier Guidelines provide an important basis for Takosan's human rights and workplace responsibility programs. Takosan recognizes that there may be differences in laws, customs and traditions, and economic conditions that influence commercial practices worldwide. Therefore, we believe that the relations between Takosan and its suppliers should be based on shared values, starting with a commitment to respect human rights. The Supplier Guidelines lay out our values and expectations and emphasize the importance of responsible workplace policies and practices that at the very least comply with applicable environmental laws and local labor laws and regulations. The principles outlined below reflect the values we uphold in our own policies. Accordingly, we expect our direct suppliers to follow the letter and spirit of these guidelines to respect human rights.

– Laws and Regulations

To comply with all applicable local and national laws, rules, regulations, and requirements in the production and sourcing or raw materials and provision of services.

– Freedom of Association and Right to Collective Bargaining

To respect the unionization rights of employees without fear of retaliation, intimidation or harassment. To comply with all applicable local and national laws on freedom of association and the right to collective bargaining.

– Child Labor

To comply with all applicable local and national laws on child labor.

– Forced Labor and Abuse

To prohibit physical abuse of workers, and all forms of forced labor, including slavery, work during military service, or human trafficking. To comply with all applicable local and national laws on forced labor and employee abuse.

– Eliminating Discrimination

To ensure workplaces are free from discrimination and verbal or physical harassment or abuse. To base recruitment, employment, placement, training, remuneration, and promotion decisions on the employee’s talent, performance, skills, and experience. To comply with all applicable local and national laws on discrimination.

– Working Hours and Remuneration

To offer remuneration in industry and local labor market standards. To follow the applicable laws on wages, working hours, overtime and benefits and to provide the employees with opportunities to develop their skills and capabilities and create promotion opportunities where possible.

– Providing a Safe and Healthy Work Environment

To provide a safe, secure, and healthy workplace. To create an efficient work environment by minimizing accident and injury risks and exposure to health risks. To comply with all applicable local and national laws on occupational health and safety.

– Protecting the Environment

To protect and preserve the environment in all business operations. To comply with applicable environmental laws, rules, and regulations.

– Commercial Integrity

To conduct business with integrity, respecting applicable laws and avoiding bribery and fraudulent practices.

– Resolution Process

To provide the workers with a mechanism to raise grievances without fear of retaliation and to resolve their concerns in a timely manner.

– Management Systems

To build management systems to ensure sustainable development, respect for the environment and natural resources, and a safe, secure and healthy workplace. To establish the right and effective systems to monitor operations to ensure compliance with the laws and respect for all human rights.

TAKOSAN SUPPLIER CODE OF CONDUCT

Takosan expects its employees to comply with all laws and code of ethics. The same expectations apply to our suppliers as well. The Code of Conduct lays out the basic standards for employee behavior. Similarly, Supplier Code of Conduct defines the requirements for our suppliers. Working together and doing the right thing can bring great success. This Code of Conduct describes the general terms and conditions applicable to all Takosan suppliers. Some supplier agreements may contain more specific provisions that address some of these issues.

– Conflicts of Interest

Takosan employees are required to act in the interests of the company. Therefore, the employees must not have any financial or other relationship with any supplier since it would conflict with the employee’s obligation to act in Takosan’s interests. Takosan recognizes that friendships outside the workplace are inevitable and acceptable. However, suppliers should make sure not to pursue any personal relationships with Takosan employees to influence business decisions. If a supplier employee is a relative of a Takosan employee or has any other relationship, the supplier should notify Takosan or ensure that the Takosan employee informs the Company because there may be a conflict of interest.

TAKOSAN SUPPLY CHAIN POLICY

– Gifts and Entertainment Expenses

Takosan employees are prohibited from receiving more than the allowed gifts, dinners and entertainment expenses from the suppliers. Ordinary business dinners and small gifts on holidays may be acceptable; however, suppliers are prohibited from offering travel, frequent dinners, and expensive gifts to Nursan employees. Similarly, gifts such as gift coupons or others that may be traded for cash are not allowed.

– Bribery

Suppliers acting on behalf of or for Takosan must comply with the laws of the Republic of Turkey as well as all local laws on bribery of government officials. The suppliers, in their capacity as a supplier of Takosan or acting in Takosan's name, are prohibited from providing, directly or indirectly, anything of value to any government official, employee of a government-controlled company, or a political party to gain any unfair advantage or benefit in connection to any transaction. Suppliers must keep accounting records of all the payments (including gifts, dinners, entertainment expenses, or anything else of value) made on behalf of Takosan. The suppliers are required to submit these accounting records when requested by Takosan.

– Information Security

Suppliers are required to protect Takosan's confidential information. Suppliers who have access to confidential information through a business relationship will not disclose such confidential information to anyone without Takosan's express permission.

If a supplier detects an error in the confidential information that Takosan discloses to them, they should immediately notify Takosan and refrain from using such this information.

Arda KÖKEN
General Manager