The Legal Obligations topic under the Kordsa Code of Business Ethics governs the principles of compliance management in our company. We realize all our domestic and international operations and transactions in line with national legislations and international law, and provide accurate, complete and clear information to the official bodies and institutions in a timely manner.

The priorities of our company include establishing a management system that is needed to comply with both the requirements, laws and regulations of the sector we operate in; defining relevant policies, communicating findings, risks and new regulations on a regular basis, and making necessary controls; and monitoring and managing our compliance management performance.

In 2013, we established the Compliance Management System, which is reviewed every year and approved by the Board of Directors, in cooperation with the Compliance Division of Sabancı Holding, and started implementation in 2014. The Compliance Coordinator is responsible for the coordination of compliance management, whereas all Kordsa employees are responsible for its management.

The objectives and targets of compliance management are based on ensuring that the company operates in compliance with the legislation, international law, and the internal rules governing the holding and the company. The goal of the management system, includes identifying the risks associated with compliance; taking necessary measures, monitoring 10 key risk indicators (two of which are optional, and eight are required by law); and managing the risks proactively by way of identified thresholds. Compliance risk types concerning Kordsa are defined as follows; Legislation on Labor and Social Security, Legislation on Environment and OHS, Trade Legislation, Financial Legislation Information Security Policy, Agreements and Other Legal Arrangements.

At the end of every quarter, the Compliance Coordinator shares the key risk indicators and the results as Compliance Management Criteria and Results with ELT members and responsible departments. Additionally, compliance management and practices are among audit items in audits throughout the company conducted by the Internal Audit Department. The Committee evaluates the outcomes of the audit and shares the results with the Board of Directors. Moreover, every year, Sabancı Holding makes a periodical Compliance Management assessment and prepares a report.

At Kordsa Turkey we have not received any monetary or administrative penalties during the reporting period for breach of any laws or regulations, including those on the environment. There was not any case brought to our attention through conflict resolution mechanisms, either.