1. Purpose
With this policy text, it is aimed to clearly Express NSK OTOMOTİV’s commitments regarding and approaches to bribery and corruption and to protect the company’s image. It is describing the notification responsibilities and methods of the employees in case of possible bribery, corruption or unethical behaviors.

2. Scope
Anti-Bribery and Anti-Corruption and Ethics Policy covers not only employees of NSK OTOMOTİV, but also all business partners that act in the name of the Company or provides NSK OTOMOTİV with product or service.
• All NSK OTOMOTİV employees including Executive Board members,
• Companies and employees from whom support services such as advice, attorneyship or consultancy services are received,
• Sub-producer companies providing outsourced services, subcontractor-supplier companies and employees thereof
are covered by this policy.

It is highly important that all applications and restrictions mentioned in this policy text is valid for the aforementioned persons and organizations. It must be kept in mind that in case that these persons and organizations perform any non-legal or unethical act, our Company can be held responsible as well. Therefore, while identifying the business partners, it must be ensured that the business partners act in accordance with these rules by considering Code of Conduct of the Company, relevant regulations and procedures and this policy text.

3. Definitions

Bribery: It means directly or indirectly providing a person or another one to be shown by him/her with material or immaterial benefit for the purpose of getting that person perform an act in violation of requirement of his/her duties or out of the ordinary course of the business through having or not having a work done, accelerating or slowing it down, within the framework of a verbal or written agreement. The benefit to be considered as a bribe can be in several forms such as cash, gift, event invitation or ticket, debt amnesty, donation for aid purpose.

Corruption: It means abusing the authority held due to the position for directly or indirectly obtaining material or immaterial gain.
Mobbing is an emotional attack that is in the form of systematic psychological violence, harrassment, humiliation, threat, etc., by exploiting the power or position.

4. Responsibilities

Executive Board:
• Executive Board is responsible at the highest level for Anti-Bribery, Anti-Corruption and Ethics Policy.
• Executive Board accepts this policy text and provides the required information for its implementation.
• It creates and develops internal control systems for the purpose of preventing bribery and corruption.
• It ensures the required communication channels for notification of the acts in violation of the policy text and takes the measures to protect confidentiality and safety of the notifying persons.
• It ensures that the required examinations and investigations are made for the received complaints, notifications and claims, within the framework of the Company legislation.
• It ensures that the audits are made and corrective measures are taken to ensure compliance with the legal arrangements, regulations, procedures and policies.

Directors and Employees:
• All employees accept the Anti-Bribery, Anti-Corruption and Ethics Policy, and act in accordance with the principles within the policy text.
• Directors ensure that the principles within this policy text are understood, applied and survived by the business partners for whom they are responsible and employees reporting them.
• Employees cannot be forced to act in violation of this policy in any case and by anyone.
• All Company employees are obliged to notify their directors and/or Human Resources Department of the acts in violation of this policy and cases suspected.
• Directors are responsible for notifying Human Resources Department of the complaints, notifications and claims received by the employees reporting to them.

5. Anti-Bribery and Anti-Corruption and Ethics Policy

• NSK OTOMOTİV is against any kind of bribery and corruption. Accepting or giving bribes cannot be accepted, regardless of their purpose. Business relationship with third parties that want to make business with NSK OTOMOTİV through bribery or corruption must not be continued.
• Gift is a product that is not necessarily a material payment and that is given for thanking or commercial kindness by persons or customers with whom there is a business relationship. Any kind of gift that NSK OTOMOTİV wants to give to third persons must be given with good faith and unconditionally. Gifts to be given in this context are organized by the Sales& Marketing Department. The same principles are applicable to accepting gifts, and no other gifts than those stated in this principles, than the symbolic ones not of high material value must be accepted. Furthermore, accepting gifts must not be frequent even in this scope and NSK Group Executive Board must be notified of the accepted gifts by the accepting party, through the immediate superior. Particularly stationary gifts that are received at the yearend and considered to be new year’s gifts are collected by the Purchasing Department and distributed to be used by the company employees.
• Hosting Policy: In the scope of this policy, travel and hosting offers such as seminar, conference, plant visit received from any current, potential and/or any other supplier company are evaluated by considering ethical values, and opinion of the Executive Board is obtained, if required.
• Facilitation Payments: Facilitation payments by the persons and organizations within the scope of this Policy cannot be proposed for assuring or accelerating a routine process or procedure with the governmental organizations (obtaining permission and license, obtaining documents, etc.).
• NSK OTOMOTİV adopts creating and sustaining a fair work environment fort he employees as one of its most important priorities. It is aimed to improve success, development and loyalty of the employees through creating a fair and safe work environment that is in compliance with all relevant laws and regulations and that respects the employees. In this context, NSK OTOMOTİVE fulfills all legal responsibilities, and does not allow discrimination based on language, religion, race, color, gender, sect, political view, age, physical disability and the others alike. No baseless declaration, gossiping or mobbing can be made within the company. All required declarations of employees to governmental organizations are made clearly-correctly, and work cannot be performed in violation of the laws (employing children, informal employment, etc. cannot be accepted).
• NSK OTOMOTIV has TS/ISO 14001 Environmental Management Systems and OHSAS 18001 Worker Health and Work Safety licenses. In view of the trainings provided for the company employees on environmental and work safety, these employees are expected to keep the same sensitivity in their work environment and private lives.
• Company employees cannot share information or documents with third persons regarding customers, suppliers, business developments and/or their colleagues’ financial/commercial/technical secrets, prices, wages and benefits.
• Exceptional cases: Financial data to be shared with the government, financial information to be shared with the customers/financial institutions, technical data to be shared with the customers and suppliers are not included. Details regarding the issue are described in PR 752.01 Document Management Procedure.
• Keeping Correct Records: The issues that NSK OTOMOTİVE is obliged to comply with regarding its accounting and recording system are regulated by the legal regulations.

• Any kind of accounts, invoices and documents of third persons (customers, suppliers, etc.) must be recorded and kept finally, completely and reliably.
• No falsification must be made on the accounting or other records of any transaction, and the truth must not be distorted.

6. Encountering with or Suspecting Bribery and Corruption/Unethical Behaviors

All Company employees are responsible for notifying the Human Resources Department of the cases they encountered with or suspected regarding bribery and corruption. Following examples can be given regarding such cases:
• Receipt of bribery offer by you or your colleagues
• Benefit relations and conflicts of interests you witnessed or know
• Any irregularity noticed in the company records
• Mobbing practices to disrupt the peace in the work environment
• Attitudes and behaviors encountered in tenders and purchases such as favoritism or obtaining benefit
• Providing any customer or supplier with benefits in violation of the law and internal regulations of the Company
• The fact that you or your colleague is forced by any body or person within or outside of the company to act in violation of this policy text.

When you encounter with such cases and the others alike, you must notify the Human Resources. Human Resources notifies the Weekly-Monthly Executive Board of all Ethical complaints received within one work day.
Executive Board shares the process with additional negotiations, in case that it deems required.
In some cases, employees may hesitate to complain, despite their witnessing such facts, with the concern that they can also be harmed. It is guaranteed by the Executive Board that the persons, who notify the facts in violation of legal regulations, ethical rules and Company legislation within NSK OTOMOTİV, are not harmed for this reason. It is essential that identities of these persons are kept confidential and prevented from being harmed due to their complaint or notification – if it cannot be defined to be intentional or defamation.

7. Sanctions regarding Acts and Attitudes in Violation

As the regulations, procedures and instructions are completely applied for all duties within the Company, Anti-Bribery and Anti-Corruption and Ethical Policy must also be adopted and implemented by the employees. It must be kept in mind that in case of violation of the Anti-Bribery and Anti-Corruption and Ethical Policy, sanctions such as termination of the employment contract according to the internal regulations of the Company and that the case is regulated by significant sanctions including imprisonment in several countries.

Contact Information
E-mail: etik@nskgroup.com.tr
Tel: +90 224 676 12 19
Address: NSK OTOMOTİV Tavşanlı Mah 412. Sok No:1-4
Executive Board-Karacabey-Bursa