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Kordsa, closely monitors increasingly stringent regulatory expectations, global trends, new approaches and developments in compliance.
The objectives and targets of compliance management are based on ensuring that the company and its affiliates operate in compliance with the local and international legislation and standards as well as the internal policies and procedures. We realize all our domestic and international operations and transactions are in line with national and international law and provide accurate, complete and clear information to the official bodies and institutions promptly. In this regard, we implement several internal policies and procedures governing compliance management including but not limited to the Kordsa Code of Business Ethics.
Global Legal and Compliance Department, which is responsible for the compliance management of our company, closely monitors all developments to ensure 100% compliance with applicable legislation and regulations and regularly informs our employees and executives about the relevant developments. In addition, we periodically provide training to increase the internal compliance culture and raise the awareness level of our employees..
We are aware that the feedback of our employees and stakeholders is crucial in order for the compliance culture to be in continuously enhanced. Therefore, we provide various online and face-to-face training and briefings so that our employees and stakeholders can express their thoughts and concerns about compliance without hesitation.
Kordsa is committed to overseeing business in an ethically suitable manner. Kordsa Code of Business Ethics is our fund for trust for our employees, stakeholders, customers, suppliers, business partners, competitors and society. It covers four main headings, namely legal obligations, integrity, confidentiality and conflict of interest. While protecting the rights of beneficiaries, Kordsa, in all its operations and relationships, abides by the newly updated Kordsa Code of Business Ethics, approved by the Kordsa Board of Directors on June 10th, 2024. The Kordsa Code of Business Ethics was originally developed by Hacı Ömer Sabancı Holding and it has been revised for Kordsa. It is available in the native languages of the countries we operate in (Turkish, English, Bahasa, Thai, and Portuguese) and is published on our website.
Kordsa Executive Lead Team and Ethics Board are the main ones responsible for implementing the Kordsa Code of Business Ethics. In order to manage this, an Ethics Compliance Officer is appointed to each site (Turkey, Indonesia, Thailand, Brazil, USA). The Ethics Board comprises Global Ethics Compliance Officer, Head of Legal and Compliance, Global Head of Human Resources, and Global Head of Internal Audit.
The Global/Local Ethics Compliance Officers have the responsibility to inform employees about ethical standards, deliver training to ensure that the relevant policies and rules are understood and communicate regularly with employees. All employees, once hired, sign the Business Ethics Compliance Form stating that they have read and understood it and they participate in the ethics survey at year end. Within the ethics questionnaire, some questions raise awareness and address the possible risks.
New employees receive online and/or classroom training on ethics through a training platform supported with videos, cases, and questions. The Business Ethics Compliance Form serves as a risk assessment tool and is completed by each employee.
Kordsa Code of Business Ethics and all relevant policies are reviewed and revised, if necessary, by the Ethics Board in line with recommendations received from the Global Ethics Compliance Officers, Global Legal & Compliance Department, Local Ethics Compliance Officers, and once approved by the CEO of Kordsa, are announced to all employees.
Stakeholders who would like to report an incident or file a complaint can find the names, e-mail addresses (etik.tr@kordsa.com) and phone numbers of the relevant Ethics Compliance Officer on our company's website or on the Kordsa Code of Business Ethics. Kordsa Ethics Board is responsible for investigating and resolving complaints and reports the violations of ethical rules through Ethics Investigation Forms, in line with relevant policies within the context of the Kordsa Code of Business Ethics. Our continuous target is to resolve 100% of the notifications/complaints of the year within the same year.
The Ethics Hotline is a confidential tool that can be used to ask questions and/or share concerns about potentially unethical conduct. It is hosted by EthicsPoint and operated by NAVEX Global, an independent, third-party company. When you contact the hotline, your report will be documented in detail and addressed by Global Ethics and Compliance promptly, discreetly, and confidentially. You may speak or write a report in your own language. Reports may be made anonymously where permitted by law. Employees may also turn to their manager, the Global Ethics & Compliance team, or Human Resources Department to report their concerns.
Kordsa does not tolerate retaliation against an employee who cooperates with an investigation, raises a concern, or reports suspected misconduct in good faith. Raising a concern in “good faith” means being sincere in providing honest and accurate information, even if it is later found out the reporter was mistaken. We take retaliation claims very seriously – anyone found to have committed a retaliatory act will be subject to disciplinary action, including termination of employment and/or business contracts.
Once a report is submitted, the Global Ethics & Compliance team will review the details of such and notify the reporter on the status until the case is closed.
How to Submit a Report
Online: kordsa.ethicspoint.com (desktop version) or kordsa-mobile.ethicspoint.com (mobile version)
We, as Kordsa, operate in compliance with the Universal Declaration of Human Rights, OECD Guidelines for Multinational Enterprises, International Labor Organization Fundamental Conventions, and International Labor Organization Declaration on Fundamental Principles and Rights at Work in all countries we carry a business in and abide with all laws and regulations and look after all rights of our employees by adopting the international declarations, fundamentals, conventions, and principles that our country is a party to. Our approach towards our people is honest and fair. We commit to providing a non-discriminatory working environment for all, making sure that our people enjoy their employee rights fully and properly. We supervise suppliers and subcontractors in our value chain to protect human rights through the Supplier Sustainability Evaluation Survey and our contracts.
Kordsa Code of Business Ethics and Human Rights Policy are embedded in the contracts with main suppliers. All employees of the subcontractors are informed by Kordsa officers on the codes of work and ethics on their first day at work.
Since no article that limits subcontractor employees from joining a union, all employees are free to associate. Kordsa audits whether the subcontractor employees have social insurance, they are older than 18, and their wages and social insurance contributions are paid. In case of a complaint, our employees conduct on-site audits with the supplier.
Employees who feel or suspect a violation of our fair working environment must notify their line managers, a member of the Executive Leas Team, the Local Code of Ethics Consultant, the Global Ethical Compliance Officer, or the Ethics Committee through the ethics line. In addition, human rights risks and complaints in the company are audited both internally and externally by third parties.
The Internal Audit Department conducts human rights and ethics policy compliance audits integrated into process audits. When there is a declaration regarding a violation of the Kordsa Code of Ethics, all necessary controls and audits are handled with the help of Local Ethical Compliance Officers.
After determining one or two topics regarding human resources each year, all our companies are audited by the Sabancı Holding Audit Committee and the Kordsa Audit Committee. A report is presented to the CEO and Board of Directors annually which includes ethics, human rights, and human resources topics.
Audit findings are fed into the Internal Audit Task Management (IATASK) system and supervisors are assigned tasks. At the end of a year, the audit team conducts a follow-up visit in order to audit previous year findings and the actions taken. If the audit is completed, all actions are closed in the system by audit team approval.
At Kordsa, we give ethics training to all our new employees. Like all employees, our security staff is also trained in a code of ethics which includes our human rights policies upon recruitment. These trainings are conducted through the HUB e-learning platform in Türkiye, Thailand, and Indonesia. In Brazil and the USA, ethics trainings are done in the classroom. Our CEO conveys awareness messages across all organizations in case an issue is spotted against the ethics code depending on the type of the incident.
Anti-corruption is one of the ten fundamental principles of the UN Global Compact that Kordsa signed in 2014. We keep an equal distance from all public agencies and institutions, administrative bodies, non-governmental organizations, and political parties, without expecting any benefits, and realize our obligations with this responsibility in mind while carrying out all our operations and transactions.
We comply with Article 3.5.2 of the Corporate Governance Principles that stipulates, “Corporation shall be sensitive to its social responsibilities and comply with the regulations and ethical rules with regard to the environment, consumers, and public health. Corporation shall support, and respect internationally recognized human rights. Corporation shall fight against any kind of corruption including bribery.”
We published Kordsa Anti-Corruption and Anti-Bribery Policy, which is based on Turkish law, in 2015. The policy also covers our business partners including sub-contractors, consultants, and lawyers. Our policy is communicated through our website to all suppliers and other third parties we do business with.
Communication and training on anti-corruption in Kordsa cover all our employees in line with our Code of Business Ethics. Ethics Committee and Internal Audit functions monitor cases on anti- corruption, whistleblowing being also in charge of sanctions and reports to the Sabancı Holding Ethics Committee.
Our measurement and monitoring mechanisms are the Ethics Hotline and Internal Audit Department, Audit Committee, and audits of Sabancı Holding. If a notification is made regarding corruption and/or bribery and the case is filed, the Internal Audit Department reports the case to the Audit Committee separately. Nevertheless, there’s no specific section regarding corruption and/or bribery in ethics reporting.
The prohibition of facilitation payments is banned in clause 6.4. of our policy. Our employees cannot engage in any business relationship with family members, acquaintances, or third persons that would result in mutual or unilateral benefits. They cannot earn or enable others to earn any money by engaging in trade, including trading securities on the stock exchange, using insider information. The rules mandate that employees cannot manage an enterprise, neither directly nor indirectly, and that they cannot work for a third person and/or organization during or outside of working hours in return for a certain fee or comparable gain.
Kordsa is committed to adopting, implementing, maintaining, and continuously improving the Information Security Management System (ISMS) within the framework of the ISO 27001 Standard conditions. Kordsa management has clearly stated its expectations in the form of targets and is committed to providing guidance and support to achieve the following:
We carry out all necessary activities regarding compliance with the protection of personal data in the countries in which we operate, including but not limited to the Law on the Protection of Personal Data No. 6698 (“PDPL”) and secondary regulations.
Compliance with PDPL, secondary regulations, and other applicable data privacy laws is essential to Kordsa’s compliance activities. In this regard, the PDPL Committee continues to follow the best practices observed in the industry to keep up with the new developments, offer company‑wide guidance, and implement security measures in collaboration with the relevant departments.
Being aware of our responsibilities against our competitors and stakeholders, we are committed to globally committed to free and fair competition in compliance with all laws and regulations in force in relevant countries where we operate and attach great importance to compliance with competition laws.
In this regard, we have implemented Kordsa Competition Law Policy, Kordsa Competition Law Compliance Guidelines and secondary documents supporting compliance with competition law in order to ensure compliance with competition law in our activities and transactions. In addition, we provide competition law training to all our employees at least once a year.
Competition compliance is also closely monitored and given importance by our top management. In this context, in order to assess the awareness level of our employees on competition law and to proactively identify competition law risks, an annual Competition Compliance Assessment Report is prepared and shared with our top management by Global Legal and Compliance Department.
Operating in several countries, we attach great importance to compliance with complex trade sanctions and export control laws and regulations, which basically prohibits the import, export or re export of certain products to or from certain countries or parties. We ensure compliance with such sanctions and export controls in accordance with our internal policies and procedures which are prepared in line with the policies and procedures issued by H.Ö. Sabancı Holding A.Ş. on sanctions and export controls.
Kordsa Teknik Tekstil Anonim Şirketi (“Kordsa” or “Company”) uses cookies on its website, www.kordsa.com and the website, yatirimciiliskileri.kordsa.com, which can be accessed via the first website, (“Site”), to enhance your experience during visiting the Site. Cookies allow the Company to continuously improve the Site, ensuring the information remains up-to-date and continues to be useful for users.
This Cookie Policy (“Policy”) has been prepared by Kordsa Teknik Tekstil Anonim Şirketi as the data controller under the Protection of Personal Data No. 6698 (“Law”). The purpose of this Policy is to inform users about the processing of personal data obtained automatically through cookies placed on their devices during visits to the Site, the types of cookies used, the purposes for which they are utilized, and how they can be managed. Cookies other than essential cookies used on our Site are activated only with your explicit consent, which can be adjusted at any time through the Cookie Preferences interface.
What Are Cookies and How Do They Collect Data?
Cookies are small files stored on your browser or device when you visit a website. Depending on their duration, cookies allow the website to recognize your device during subsequent visits and store certain information about your preferences (such as language settings or site configurations) and past interactions.
When you first visit our website, you will encounter a screen regarding your cookie preferences. The cookies you allow will be stored on your browser/device based on the preferences you set on this screen.
Each cookie typically contains the following elements:
Data is collected automatically through cookies (without human intervention).
| Cookie Type | Based on Ownership: |
|---|---|
| First-Party Cookies: | These are cookies placed directly by the website being visited or by the Company on the user’s device. |
| Third-Party Cookies: | These are cookies placed on the device by a third party, such as advertisers or analytics providers, in collaboration with the Company. |
| Cookie Type | Based on Duration of Activity: |
|---|---|
| Session Cookies: | These cookies store data until the user closes the browser or the session ends. They are short-term cookies. |
| Persistent Cookies: | These cookies remain stored on the device until their expiration date, as defined for the cookie, or until the user deletes them. The codes of persistent cookies contain a variable and written expiration date. |
| Cookie Type | Based on Purpose: |
|---|---|
| Essential (Technical) Cookies: | These cookies are necessary to use features such as browsing the website and accessing secure areas of the site. |
| Functionality (Preference) Cookies: | These cookies allow the website to remember past user preferences (such as username, password, preferred language, etc.). Preference cookies, which enable automatic login, are also referred to as functional cookies. |
| Statistics (Analytics) Cookies: | These cookies, also known as performance cookies, these provide anonymous and statistical data about the use of the website. Analytics cookies store information about how users use the website, such as pages visited or links clicked. Anonymized analytics cookies are not used to identify the website user. The purpose of these cookies is to enhance the functionality of the website. |
| Marketing (Targeting) Cookies: | These cookies can be used by third-party companies operating to build a profile of your interests and display relevant advertisements on other websites. |
Purposes and Legal Grounds for Processing Your Personal Data Through Cookies
Essential/Technical Cookies: These cookies are used to ensure the proper functioning of the website. Without these cookies, websites cannot operate, and they cannot be disabled in our systems.
Essential cookies are used under Article 5/2-f of the Personal Data Protection Law (“Law”) based on our legitimate interest.
Functionality Cookies: Bu These cookies are used to remember preferences and personalize your use of the website. For example, cookies that preserve the website's language settings, saving you the hassle of updating them with every visit, are functionality cookies.
Functionality cookies are used with your explicit consent under Article 5/1 of the Law.
Analytics Cookies: These cookies help us analyze your use of the website and its functionality, enabling us to improve your user experience.
Analytics cookies are used with your explicit consent under Article 5/1 of the Law.
Marketing/Advertising Cookies: These cookies are used to customize advertisements based on your interests, limit the number of times the same advertisement is displayed, measure the effectiveness of promotions and campaigns, and understand user behavior after viewing an advertisement.
Marketing cookies are used with your explicit consent under Article 5/1 of the Law.
Information About the Cookies Used on the Website
Below is a list of the cookies used on the site and their purposes:
| Cookie Name | Cookie Provider (Domain) | Party Information | Cookie Type | Duration of Use | Cookie Definition |
|---|---|---|---|---|---|
| ASP.NET_SessionId | .www.kordsa.com | First Party | Essential | Session Duration | A general-purpose session cookie used by websites built with Microsoft .NET-based technologies. It is primarily used to maintain an anonymized user session by the server. |
| __RequestVerificationToken_* | .www.kordsa.com | First Party | Essential | Session Duration | A cookie set by web applications built using ASP.NET MVC technologies to prevent Cross-Site Request Forgery (CSRF). Designed to stop unauthorized content submissions to the website. |
| __cf_bm | .www.linkedin.com | Third Party | Essential | 22 Minutes | Cloudflare's bot products automatically detect and reduce traffic to protect your site from malicious bots. Cloudflare places the __cf_bm cookie on the end-user devices that access customer sites protected by Bot Management or Bot Fight Mode. This cookie is required for these bot protection solutions to function properly. |
| JSESSIONID | .www.linkedin.com | Third Party | Essential | Session Duration | JSESSIONID is a session identification cookie used by sites with JavaServer Pages (JSP). The cookie is used to maintain an anonymous user session on the server. |
| TS01* | .www.kordsa.com | First Party | Essential | Session Duration | These cookies are necessary for the operation of our website and are used to fulfill the requested service (such as logging in, filling out forms, remembering privacy preferences). They are required to be used in order to function properly. |
| TSaee2d3ee027 | .www.kordsa.com | First Party | Essential | Session Duration | These cookies are necessary for the operation of our website and are used to fulfill the requested service (such as logging in, filling out forms, remembering privacy preferences). They are required to be used in order to function properly. |
| cookiespool_consent | .www.kordsa.com | First Party | Essential | 6 Months | Used to store visitor consent selections obtained via Cookiespool regarding cookies used on the website. |
| YSC | .www.youtube.com | Third Party | Performance | Session Duration | Records a unique identifier to keep statistics of the videos watched by the user on YouTube. |
| G2MIsReadFirstPage1 | .www.kordsa.com | First Party | Performance | 5 Days | Stores information about whether the first page has been read. |
| _ga | .www.kordsa.com | First Party | Performance | 400 Days | A Google Analytics cookie used to distinguish users. |
| _ga_* | .www.kordsa.com | First Party | Performance | 400 Days | A Google Analytics cookie used to distinguish users. |
| hj_*** | .www.kordsa.com | First Party | Performance | 30 Days | Hotjar cookies starting with _hj analyze user behavior on the site to improve user experience, enhance site performance, and increase conversion rates. |
| _gid | .www.kordsa.com | First Party | Performance | 24 Hours | It is used to record a unique ID to generate data about how the user interacts with the website. |
| lang | .www.linkedin.com | Third Party | Functional | Session Duration | Used to remember a user's language preferences. |
| lidc | .www.linkedin.com | Third Party | Functional | 1 Day | Used by the social networking service LinkedIn to track the usage of embedded services. |
| VISITOR_INFO1_LIVE | .www.youtube.com | Third Party | Marketing | 180 Days | Tries to estimate the user's bandwidth on pages containing embedded YouTube videos. |
| VISITOR_PRIVACY_METADATA | .www.youtube.com | Third Party | Marketing | 180 Days | Visitor information is stored for YouTube. |
| NID | .www.google.com | Third Party | Marketing | 183 Days | This cookie is used to collect website statistics and track conversion rates and Google ad personalization. |
| bcookie | .www.linkedin.com | Third Party | Marketing | 365 Days | It is used by LinkedIn to track the usage of embedded services. |
| bscookie | .www.linkedin.com | Third Party | Marketing | 365 Days | It is used by LinkedIn to track the usage of embedded services. |
| ig_did | .www.instagram.com | Third Party | Marketing | 365 Days | This is a targeting cookie used to track the visits of Instagram users. |
| ig_nrcb | .www.instagram.com | Third Party | Marketing | 365 Days | It uses a unique identifier to ensure that the ads you see on Instagram are relevant and personalized. |
| __Secure-ROLLOUT_TOKEN | .www.youtube.com | Third Party | Marketing | 180 Days | It is a cookie used by YouTube for marketing purposes. It stores token information. |
| c_user | .facebook.net | Third Party | Marketing | 365 Days | It is a cookie used by Facebook for marketing and advertising purposes. |
| guest_id | .twitter.com | Third Party | Marketing | 180 Days | It is a cookie used by Twitter for marketing and advertising purposes. It stores token information. |
Personal Data Processed Through Cookies
Within the scope of the purposes and legal grounds stated in this Policy, cookies are used to collect and process the following data: browser and operating system information, IP address, user ID, the date and time of your visit, interaction status (e.g., whether you encountered an error or were able to access the Site), usage of features on the Site, search queries, visit frequency, scrolling behavior, accessed tabs, and other user activity logs.
Sharing of Data Collected Through Cookies with Third Parties
Personal data collected via cookies may be shared, within the scope of the purposes and legal grounds stated in this Policy, with IT infrastructure providers and cookie-related service providers located domestically and abroad. Additionally, your personal data may be disclosed to competent authorities and organizations if required (e.g., in case of a legal dispute necessitating disclosure to judicial bodies). During the transfer of your data, compliance with the rules regarding the transfer of personal data specified in Article 8 and 9 of the Law is ensured.
Cookie Management
You have the ability to accept or block cookies by adjusting your browser settings or selecting your preferences in the website's cookie control panel. However, if cookies are blocked, you may not be able to utilize all the interactive features of the website.
You can adjust your cookie settings at any time using the Cookie Control Panel here. You may need to refresh the page to activate your settings.
You can also manage cookies in the browser settings. Each browser may have a different method for disabling cookies. You can get information about how to disable cookies by clicking on the link for the browser you use:
Rights of the Data Subject
Under Article 11 of the Law, data subjects have rights regarding the personal data collected via cookies. All natural persons whose personal data are processed by Kordsa have the right to submit requests to exercise their legal rights under the Law. If you wish to exercise your rights, you can fill out the Data Subject Application Form available on our website at www.kordsa.com and send it to us via one of the following methods:
Alternatively, you can use other methods specified in the "Communiqué on the Principles and Procedures for the Request to Data Controller."
For any questions regarding this Policy or the processing of your personal data, please contact our Company Contact Person via veri.sorumlusu@kordsa.com.
Last Updated: 28/11/2024
Cookie Tracking Preferences
Kordsa Turkey, based on the requirements of national and international legislation, standards and customer requests in occupational health and safety; It fulfills its occupational health and safety responsibilities with the participation of all relevant parties, including all employees, interns, suppliers, subcontractor employees, visitors and business partners.
Kordsa Turkey carries out preventive activities in order to eliminate the sources of danger that may lead to occupational accidents and diseases or to reduce them to an acceptable level and ensures the participation of employees and relevant stakeholders in these studies.
The health and safety of its employees, business partners, customers and visitors, which is the most fundamental value in all areas in which it operates, is Kordsa Turkey's top priority. In this direction, as a requirement of Kordsa Turkey's responsibility for the creation of healthy individuals and workforce;
As Kordsa Turkey, we believe that achieving the goal of sustainable growth, which leads our activities, is only possible as long as we adopt the principle of following environmental and human-oriented policies in all business processes and keep the principles of sustainable environment alive.
Kordsa is committed to adopting, implementing, maintaining, and continuously improving the Artificial Intelligence Management System (AIMS) within the framework of the TS ISO/IEC 42001 Standard conditions. Kordsa management has clearly stated its expectations in the form of targets and is committed to providing guidance and support to achieve the following:
