Corporate
Sustainability Policy

ICterra is committed to complying with the laws, rules and regulations applicable in all jurisdictions in which it operates. In this regard, ICterra strives to conduct all of its operations with integrity and is committed to complying not only with the letter but also with the spirit of applicable laws, rules and regulations.

All illegal activities and behaviors, whether specifically stated in this “Corporate Sustainability Policy” document or not, are prohibited. In this context, suppliers are also expected to act in compliance with this document and, of course, with the legislation and all legal regulations.

ICterra carries out its activities in full compliance with Turkish and international laws and regulations. It adopts and implements a “zero tolerance” policy on bribery and corruption.

Pursuant to Law No. 3628 on Declaration of Assets, Anti-Bribery and Anti-Corruption; it is prohibited, directly or indirectly, through a third party, to offer, give, promise, authorize, make or accept anything of value (in cash or otherwise, including gifts and other favors) to or from any government official or private person for the purpose of improperly obtaining or retaining business from such persons. Any form of bribery, including the actions set out above, is never acceptable to ICterra.

A government official includes any elected or appointed official of a national government (executive, legislative or judicial), part-time or volunteer government employee, or anyone authorized to act on behalf of a government. In addition, members of political parties, party officials or candidates for political office, officials or staff of public international organizations, and officers, agents or employees of companies that are even partially owned or controlled by a government are also considered government officials. This means that all employees of government-owned companies and instrumentalities are legally considered government officials, even if those companies operate as private businesses. Interactions with government officials require special care as they carry a high risk of corruption; therefore the rules and processes for conduct and behavior to be observed are stricter.

It is prohibited to make donations at the request of a government official or person, or for the purpose of improperly influencing their behavior.

According to anti-corruption laws, suppliers and employees must act in a manner that ensures they protect ICterra’s standards and company reputation and fully comply with the law.

ICterra will not work with any person and/or organization that has participated in the behaviors and crimes specified in Law No. 3628 and related legislation as well as in this text.

ICterra cannot have a business relationship with persons and/or organizations that have participated and/or will participate in any money laundering crime. For this reason, persons and/or organizations that will establish a business relationship with ICterra must comply with all legal obligations prohibiting money laundering.

However, suppliers shall take every precaution to prevent fraud of any kind and to ensure that the business relationship with ICterra is not abused for money laundering or other illegal activities, including providing financial support to any type of terrorist group or activity.

Law No. 4054 on the Protection of Competition applies to protect competitive conditions in the market. These laws prohibit anti-competitive agreements and abuse of a dominant position (e.g. market share above 60%). Anti-trust and competition laws promote fair competition and protect consumers from unfair commercial practices.

ICterra and its employees strictly adhere to these laws. In this context, any action that could in any way hinder or limit free competition is prohibited.

ICterra supports laws that promote fair competition and business practices, as well as a vital innovation ecosystem. Accordingly, we comply with all such laws wherever we do business and do not gain competitive advantage through unethical or illegal business practices. We do not engage in behavior such as disparaging competitors, imposing restrictions on suppliers or customers, or abusing position through improper collusion or collusion of any kind with competitors.

Furthermore, ICterra does not refuse, delay or prohibit the provision of any information requested by competition control authorities or other regulatory authorities.

At this point, we expect all our Stakeholders to act in accordance with these legal regulations and

• Never attempt to obtain confidential information from former or current employees of ICterra’s competitors.
• Not to engage in any form of cartel activity,
• Not engage in direct or indirect negotiations with ICterra’s competitors for the purpose of harmonizing prices or establishing mutual agreement practices to approach the market,
• Not disclose to ICterra’s competitors or other persons directly or indirectly concerned with any data not expressly authorized in writing by ICterra, including prices negotiated/obtained with ICterra, details of ICterra’s participation in various auctions, ICterra’s business details, operational information, technical data,
• Not boycott competitors or in any way make it difficult for new/potential or existing competitors to enter, remain or expand in the market,
• Not to take any action that leads to the imposition of restrictions of any kind limiting the sales territory, sales price, quantity sold, sales channels, etc,
• Immediately notify ICterra management of any matter that may relate to free competition and any infringement by ICterra employees, business partners or representatives or other companies in the marketplace.

ICterra, including its competitors, takes care not to take actions that may pose a risk of anti-competitive behavior and acts in such a way that it can take all necessary measures to avoid putting the company in such a situation. In this respect, it expects the same care from its suppliers. The Company does not cooperate with suppliers that do not act in this manner.

Information Security is one of the most important issues for ICterra. Special attention is paid to the creation, storage, protection, controlled sharing between the parties, and appropriate use / processing of information in accordance with the relevant legislation. As a matter of business necessity, confidential information and intellectual property rights belonging to ICterra as well as our customers and their customers, business partners, suppliers and all third parties we are in contact with are used and protected with sensitivity. In accordance with these objectives, ISO 27001 Information Security Management System has been established; in addition to the ISO 27001 certificate, “NATO SECRET” and “NATIONAL SECRET” facility security certificates have also been obtained. In this context, the infrastructure required for the operation of all processes is created and monitored by taking into account corporate and project level needs, contracts with external stakeholders, security requirements, relevant legal regulations and standards.

ICterra maintains all confidential information, including commercial, business, financial, technical information and know-how secrets of both itself and its Stakeholders with whom it has a business relationship, and does not share it with third parties. This information is only available for use in the context of business relationships and is not accessible to third parties. This confidentiality obligation regarding confidential information includes not only protecting the information but also taking measures to prevent unauthorized access to the information. Therefore, confidential information may only be accessed when necessary and in a secure environment.

In addition, ICterra strictly complies with all applicable laws and legal regulations regarding the Protection of Personal Data within the scope of all its activities. In this context, it has taken and implemented all necessary measures for the processing, storage and transfer of personal data in accordance with the legislation and in a secure manner. Access to personal data is provided only to the extent required by the business, and the legal framework is strictly adhered to in transferring data to third parties.

It is essential that ICterra and all its Stakeholders respect all kinds of intellectual property rights. When it is necessary to transfer technological knowledge and know-how, this transfer may only take place on condition that intellectual property rights are protected. ICterra and all its Stakeholders scrupulously avoid any infringement of intellectual property rights and take the necessary measures to secure these rights.

ICterra maintains strong confidentiality agreements with all its employees and other parties. Thus, all information, including personal data, trade secret data, intellectual property rights, except for publicly available information, is protected.

ICterra expects its suppliers and collaborating organizations to act with the same sensitivity in terms of confidentiality, information security and intellectual property rights.

ICterra adheres to the principle of equal opportunity when selecting, promoting and/or making any employment decision. The discriminatory treatment of any kind, including but not limited to age, race, religion, disability or gender, is never acceptable by ICterra. The diversity in the workplace is one of the matters that ICterra has always valued. Therefore, suppliers must also refrain from any discriminatory treatment based on age, disability, race, language, skin color, gender, pregnancy, nationality, religion, marital status or any other characteristic protected by law.

It is one of our main priorities as ICterra that our employees work in a comfortable, peaceful, safe and clean environment. In this respect, we pay attention to fulfill all kinds of obligations for our employees to enjoy their working environment and work in humane conditions.

In this context, considering the Occupational Health and Safety Law, which is one of the most important laws and regulations, as well as the Labor Law and other relevant legislation, ICterra has adopted as a priority to provide safe working conditions for all its employees and to take proactive measures to improve working conditions in the best way possible.

Within the scope of all activities carried out, prevention of occupational accidents and occupational diseases is a top priority. Accordingly, risk analyses, taking all necessary precautions, creating emergency action plans, training and informing employees, providing personal protective equipment and its use by employees, etc. are implemented with the decisions and guidance of the Occupational Safety Specialist, Occupational Physician and Occupational Health and Safety Board.

Accordingly, ICterra expects all its Stakeholders to pay attention to the same safety and health measures, to provide a safe working environment and to show all necessary sensitivity while conducting their business.

ICterra provides its employees a motivating work environment where new ideas are encouraged, creativity and success are rewarded. For us, it is one of the most important issues that our employees work in a positive environment with strong relationships in cooperation and teamwork and feel themselves as a part of this culture.

We are aware that the individual development and success of our employees lies behind our corporate success. For this reason, we plan and carry out trainings that help us transform our individual differences into team synergy. Since academic studies conducted by our employees are also very valuable to us, we also support postgraduate studies conducted by our employees related to our activities.

We also support and encourage our employees to volunteer in appropriate social and community activities with a sense of social responsibility.

Another issue that we approach with great importance is to preserve the balance between business life and the private lives of our employees. As ICterra, respecting the private lives of our employees is the most fundamental responsibility of both our Company managers and all our colleagues; and any contrary behavior cannot be accepted by ICterra.

The suppliers who will be in a business relationship with ICterra are also required to respect both their own employees and ICterra employees, and to have the working environment we adopt.