Our Management System Policies

Ekol is committed to complying with all applicable laws, regulations, and the ISO/IEC 27001 Information Security Management System standard in the execution of its operations. Ekol also pledges to continuously improve and enhance its management system to ensure the confidentiality, integrity, and availability of information. To this end, Ekol is committed to:

• Planning, implementing, controlling, and continuously improving the management system by establishing information security goals and activities;
• Determining, integrating into corporate processes, and continuously improving policies and procedures in compliance with the Information Security Management System standard;
• Ensuring continuous business operations and the security of all information assets;
• Identifying necessary actions and information assets, and taking steps to minimize risks based on opportunity and risk analyses;
• Initiating and monitoring any required processes in response to breaches of the information security management system, while working to minimize such breaches;
• Protecting information assets against cyberattacks and malicious software; 
• Staying up to date with current technologies and innovations in information security, developing appropriate solutions, and allocating necessary resources;
• Organizing competency training to raise internal awareness of information security and to emphasize the importance of information security requirements; 
• Guiding and supporting individuals to contribute effectively to the information security management system;
• Ensuring that all company managers and employees embrace the information security approach established by senior management, and providing verbal and written support to employees involved in information security efforts when requested;
• Communicating the information security policy to stakeholders, ensuring its accessibility, and maintaining its relevance and accuracy

This policy applies to Ekol Lojistik A.Ş.

Ekol is committed to:

• Not employing workers under the age of 18 under any circumstances, except in mandatory cases such as internships,
• Ensuring employee remuneration aligns with market conditions, based on annual market research,
• Refraining from paying wages below the legally defined minimum wage,
  
• Ensuring all employees have equal access to fringe benefits, provided they meet the established criteria,
• Regulating working hours in accordance with applicable laws and regulations,
• Adhering to legal limits for overtime and respecting customer-defined working hours,
• Compensating overtime work at the legally mandated increased rate,
• Guaranteeing that no individual is subjected to forced labor under any condition,
• Respecting employees’ rights to union membership, collective bargaining, and freedom of expression in a free and democratic environment,
• Providing equal opportunity to all employees regardless of religion, language, race, ethnic origin, disability, gender, marital status, or age,
• Prioritizing the overall well-being and satisfaction of all employees,
• Strictly prohibiting any form of verbal, physical, or psychological harassment, pressure, threat, or coercion,
• Ensuring accurate and transparent internal communication, protecting personal data, and avoiding all forms of discrimination based on language, religion, race, gender, or similar characteristics in all internal announcements and communications,
• Ensuring transparent and accurate information sharing, protecting customers’ personal data, aligning personal comments made by employees with official company statements, and refraining from discrimination based on language, religion, race, gender, or similar grounds in announcements and external communications;
• Upholding equal opportunity during recruitment processes in accordance with ethical principles, without discrimination based on religion, language, race, ethnic origin, disability, gender, marital status, or age,
• Respecting the rights of minorities and indigenous peoples in all operations

Ekol is committed to:

• Constructing and maintaining safe facilities to protect employees, subcontractors, visitors, and other relevant stakeholders from hazards and risks associated with its operations, while ensuring comfort and operational continuity,
• Organizing training programs that raise awareness among employees, subcontractors, visitors, and other related parties to carry out their activities responsibly and effectively, while maintaining open channels for participation, motivation, and consultation,
• Planning occupational health and safety (OHS) activities with a proactive approach, and taking preventive measures to safeguard employees and stakeholders during both routine and non-routine operations,
• Accepting legal and other applicable requirements as minimum standards, and continuously monitoring, measuring, and enhancing compliance to ensure their fulfillment,
• Taking all necessary precautions to prevent occupational accidents, diseases, injuries, and health risks by implementing risk-reducing and manageable actions across its operations,
• Establishing measurable targets to assess the performance of the OHS Management System, allocating the required resources to meet these targets, and conducting regular reviews and audits,
• Continuously monitoring and evaluating emergency equipment performance, and integrating new technologies to enhance protection against major incidents such as fires and explosions during routine and non-routine activities,
• Enhancing the competency of personnel responsible for fire safety systems, and ensuring preparedness for emergencies through hands-on training and regular drills, and
• Creating, promoting, and sustaining a corporate culture across all levels of the organization that supports the desired outcomes of the OHS Management System through a structured and sustainable approach.

Ekol is committed to protecting the environment, using natural resources efficiently and responsibly, and preventing pollution in order to leave future generations a cleaner, more livable world. In line with this commitment, Ekol is committed to:

• Pioneering long-term improvement efforts in the logistics industry in cooperation with relevant ministry departments, universities, and association administrations; and establishing cooperation and dialogue between organizations,
• Embracing a sustainable logistics management system and ensuring coordination and integration across all departments,
• Promoting shared environmental responsibility by providing training to all employees—from top management to front-line staff—to encourage active participation in environmentally conscious practices,
• Identifying operations-related environmental risks at their source and establishing a systematic approach for recovery, disposal, and continuous improvement in compliance with legal regulations,
• Ensuring that hazardous and non-hazardous waste is collected using appropriate equipment at all facilities and locations, in accordance with ISO 14001 and Zero Waste practices, and that such waste is properly stored, recycled, or disposed of,
• Enhancing water management efficiency as part of the UN Sustainable Development Goals (SDGs); protecting water as a strategic resource; promoting efficient water use; encouraging a culture of quality among water stakeholders; and aligning efforts with Türkiye’s national water action plans,
• Calculating the corporate carbon footprint in accordance with internationally accepted standards and striving for operational excellence through high technology in line with emission reduction goals,
• Modernizing fleet investments to reduce carbon emissions and dependence on fossil fuels,
• Reducing total emissions (Scopes 1, 2, and 3) per turnover (tCO₂e/EUR) by 55 percent by 2030 compared to the 2020 baseline, achieving carbon neutrality by 2050, and cutting vehicle-related emissions in Europe by 75 percent by 2030,
• Monitoring key environmental metrics aligned with prioritized UN SDGs—such as increasing the recycling rate, expanding the scope of zero-waste practices, improving energy efficiency, increasing the share of renewable energy in electricity use, and enhancing water use efficiency—with a results-driven approach,
• Continuously improving environmental performance and meeting internal and external stakeholder expectations regarding environmental management by tracking and supporting suppliers in sustainability, waste management, and other environmental initiatives,
• Implementing resource management practices that account for the entire life cycle of natural and other resources, in line with the principles of sustainable development,
• Evaluating the environmental impact of goods and services during procurement and minimizing their footprint through supplier assessments,
• Taking applicable environmental legislation as the minimum standard, ensuring compliance, and continuously improving beyond regulatory requirements,
• Preventing environmental pollution from operational waste by taking corrective and preventive measures, documenting these actions, and ensuring compliance with legal processes through ongoing monitoring and reporting,
• Factoring environmental considerations into all major construction projects and upgrades, and aligning related procurement processes accordingly,
• Ensuring continuous improvement in line with environmental goals and targets by implementing a management system compliant with the ISO 14001 Environmental Management System, increasing the share of certified facilities from 30 percent to 40 percent by 2025, and obtaining and implementing the Zero Waste Certificate across all locations;
• Reviewing the scope of this policy and associated KPIs annually as part of the Management Review Meeting (MRM) conducted by senior leadership.

Ekol is committed to:

• Taking a strategic approach to customer relations and delivering accurate, needs-based solutions,
• Understanding its customers with a strong focus on satisfaction,
• Maintaining the highest possible level of service quality,
• Responding to customer complaints within 24 hours, viewing rapid response as the top priority of exceptional service,
• Resolving customer complaints effectively and efficiently,
• Prioritizing clear and timely communication with customers throughout the complaint resolution process to ensure the delivery of appropriate solutions,
• Ensuring compliance with all relevant legal regulations and fulfilling financial obligations during complaint resolution,
• Upholding the principle of confidentiality, while ensuring transparency, impartiality, and the allocation of necessary resources throughout the resolution process,
• Sustaining long-term success through the effective and continuous use of technology.

Ekol Logistics is committed to protecting its employees, assets, information, reputation, and customer property against potential threats throughout the supply chain. This policy is guided by the company’s core values, code of conduct, business ethics, and supply chain security standards. All security activities must adhere to the following general principles:

• Ensuring that all employees and contracted parties are aware of the security aspects of the company’s trade activities and assume the necessary responsibilities,
• Conducting regular threat and risk analyses and assessments,
• Integrating security procedures and instructions seamlessly into business operations,
• Prioritizing the principle of “Incident Prevention,”
• Developing and testing emergency preparedness and response plans to quickly and effectively address and resolve identified and assessed risks,
• Closely monitoring the professionalism, expertise, and integrity of personnel involved in security-related functions,
• Establishing and effectively implementing appropriate training plans, customer reviews and screenings, and hiring, contracting, and termination procedures,
• Reporting and recording all incidents, including security breaches and irregularities; taking corrective actions; and conducting periodic reviews and audits to enhance security standards

To meet the requirements of the BRC Global Standard for Storage and Distribution Policy, and to ensure product safety, legality, and quality, Ekol commits to:

• Supporting the establishment, development, and implementation of a Product Safety Management System,
• Ensuring product safety in accordance with customer requirements and expectations,
• Complying with all applicable local and national legal requirements, the provisions of the BRC Global Standard for Storage and Distribution, and any specific customer requirements to guarantee the safety, legality, and quality of all products handled,
• Pursuing continuous improvement by closely following innovations, regularly reviewing operational processes, and ensuring their long-term sustainability,
• Engaging in activities that minimize product safety risks and providing relevant training and guidance to employees,
• Educating all staff on product safety matters and the product safety policy to ensure full understanding and adoption across the organization, and
• Defining clear objectives for maintaining and enhancing the Product Safety Management System, and allocating the necessary support and resources to achieve these goals.

• Ekol Logistics is committed to: Providing equal opportunity in supplier selection without discrimination based on religion, language, race, ethnic origin, disability, gender, marital status, or age,
• Conducting business with suppliers in an honest, fair, impartial, transparent, and professional manner,
• Supporting fair competition and compliance with competition law in supplier-related business models and processes,
• Not accepting any personal gifts—except for traditional or promotional items—from suppliers, in line with the “Ekol Ethics Policy,”
• Using resources efficiently throughout all procurement processes,
• Prioritizing suppliers that care about the environment and meet environmental requirements,
• Selecting environmentally friendly products for use in company operations,
• Working only with suppliers that comply with the Ekol Ethics Policy and fulfill ethical standards,
• Ensuring the coordination of internal sustainable projects with external sources and actively participating in these projects,
• Investing in renewable technologies,
• Using recyclable products,
• Continuing the zero-waste project launched in 2020 to reduce personal waste and promote recycling,
• Reducing paper consumption to a minimum by using technology efficiently,
• Optimizing energy use by maintaining only the minimum necessary number of technological devices in shared areas,
• Considering energy efficiency in all future investments, 
• Fulfilling 100 percent of all procurement-related responsibilities as part of Ekol’s “2050 Net Zero Carbon” goal,
• Ensuring 100 percent completion of training programs within the scope of sustainable procurement, Verifying that all Tier 1 suppliers comply with local and national environmental regulations as well as international standards through Supplier Evaluation Audits,
• Auditing and improving suppliers under the categories of quality management, environmental management (air, soil, and noise pollution; forest/land use; water usage), energy management, ethics and human rights, occupational safety, and information security, and
• Complying with all international trade-related sanctions (such as export controls, notification requirements, data protection, and competition laws), as well as with all other relevant international laws and regulations

Ekol Logistics is committed to managing energy efficiently across all warehouse management and design operations and to continuously improving its Energy Management System and overall energy performance. In line with this commitment, Ekol adopts the following principles, tailored to its energy use, consumption patterns, and operational scale:

• Contribute to the low-carbon economy—one of the cornerstones of sustainable development—by protecting the environment, reducing energy consumption, and improving energy efficiency in compliance with national and international directives to combat climate change,
• Develop and implement energy efficiency projects that positively impact climate change,
• Act in line with Ekol’s purpose and business context, support strategic objectives, and meet the expectations of internal and external stakeholders, 
• Comply with all applicable legal and regulatory requirements related to energy use, consumption, and efficiency, and take swift action when needed,
• Regularly review defined objectives and targets and ensure the allocation of necessary resources to achieve them,
• Support the design of in-house equipment, systems, and processes related to energy consumption, use, and efficiency in ways that enhance energy performance,
• Organize training and briefing sessions to raise employee awareness of efficiency, reduce losses and leaks, and ensure energy efficiency,
• Provide necessary support for purchasing energy-efficient goods and services that may impact energy performance,
• Increase the share of renewable energy use in storage facilities to at least 30 percent by 2030, using 2020 as the baseline year,
• Sustain and embed the Energy Management System into the corporate culture through regular reviews, evaluations, and continual improvements overseen by senior management,

Document, continuously review, and update the Energy Policy as needed to ensure system continuity.

• Ekol is committed to: Supporting the establishment, development, dissemination, and maintenance of the Food Safety Management System, 
• Setting and reviewing objectives to maintain and improve the Food Safety Management System, and providing the necessary support and resources to achieve these objectives, 
• Monitoring relevant legal regulations in its service areas, ensuring continuous compliance, understanding customer demands and expectations, and aligning its operations accordingly, 
• Promoting the “Process Approach” and “Risk-Based Thinking” philosophy across the organization to ensure the effectiveness of the Food Safety Management System, and embedding this philosophy as a fundamental element of company culture, 
• Assessing risks and opportunities within the scope of food safety processes, taking actions to minimize risks, and steering operations accordingly, 
• Continuously developing and strengthening the Food Safety culture among employees, evaluating training needs to ensure personnel competency, and providing relevant training, and
• Fulfilling both corporate and customer-specific requirements

1. PURPOSE AND SCOPE 

The purpose of this Anti-Bribery and Anti-Corruption Policy (“Policy”) is to lay down the principles and rules that must be followed by all Ekol employees, suppliers, and stakeholders in the fight against bribery and corruption. 

We expect all our employees, suppliers, and business partners to act in compliance with this Policy, which forms an integral part of Ekol’s Code of Ethics.

Second Step: DEFINITIONS

Ekol: Refers to Ekol Lojistik A.Ş., its group companies, and subsidiaries.

Employee(s): Refers to individuals who have any form of employment relationship with Ekol.

Stakeholder(s): Refers to all parties who are affected by Ekol’s activities or whose activities may affect Ekol.

Third Parties: Refers to all individuals or entities appointed to represent Ekol’s interests or engage in a commercial or social relationship with Ekol, including but not limited to consultants, lawyers, trainers, fuel suppliers, brokers, real estate agents, service providers, subcontractors, advisors, auditors, designers, software developers, NGOs, universities, and other educational institutions.

Business Partners: Refers to all parties with whom Ekol has a commercial or social relationship, including but not limited to suppliers, distributors, authorized service providers, representatives acting on behalf of Ekol, subcontractors, auditors, consultants, and lawyers.

Facilitation Payments: Refers to unofficial and improper payments made to ensure or expedite a routine government action that the payer is already entitled to receive.

Bribery: Refers to an act of offering or promising a benefit to a public official, someone designated by that official, or any third party, in order to improperly influence them to act — or refrain from acting — in a way that contravenes the requirements of their official duty, for the purpose of securing an improper advantage in a commercial transaction or relationship.

The term “offering and promising” in this definition includes any behavior or benefit —such as cash payments, donations, commissions, gifts, or hospitality — that may fully or partially affect, or be perceived to affect, impartiality, performance, or decision-making ability; could lead to reputational risk if disclosed; could result in a violation of applicable laws; could create the perception that a bribery offense has occurred; or could result in preferential treatment in carrying out a particular duty.

Inducement to Corruption: Refers to the improper encouragement of another party to misuse their authority or position in violation of laws. This may take various forms, including offering or providing undue advantages to influence someone’s actions or decisions with the intent of gaining or maintaining an unfair commercial advantage.

3. GENERAL PRINCIPLES

Ekol is committed to combating all forms of bribery and corruption and to ensuring full compliance with all applicable laws.

Ekol maintains zero tolerance—extending beyond local regulations—for any form of bribery, corruption, provision of undue benefit, or promise involving gifts, donations, or facilitation payments made to or received from any person or institution by employees, suppliers, or business partners. This includes authorizing others to engage in such acts. Any violation of this Policy by Ekol employees may lead to disciplinary actions, including termination of employment. Should any such act be found to violate applicable legislation, the matter will be reported to the relevant legal authorities. 

4. POLICY IMPLEMENTATION

4.1. Third Parties 

All business partners working with Ekol are subject to the Anti-Bribery and Anti-Corruption Policy and are responsible for taking preventive measures to ensure that such acts are not committed—either by themselves or through others. 

Ekol places great importance on its business partners’ compliance with anti-bribery and anti-corruption legislation and refrains from establishing commercial relationships with those who fail to comply. 

Everyone engaged in a commercial relationship with Ekol—including employees, suppliers, and stakeholders—must avoid any improper transactions that may lead to bribery and must not use intermediaries to carry out such acts. It is strictly prohibited to disguise these improper acts under seemingly legitimate labels such as “commission” or “consulting” fees. 

4.2. Gift Giving/Receiving and Hospitality

The exchange of gifts, tokens of appreciation, acknowledgments, or gestures of business courtesy between parties must meet the following criteria:

• Compliance with the general principles set forth in Ekol Working Conditions,
• Compliance with applicable anti-bribery and anti-corruption legislation,
• Non-cash and non-cash-equivalent items,
• Appropriate to the position of the recipient or beneficiary, and
• Accurately and transparently recorded in the accounting records.

Hospitality refers to the participation of employees, customers, or other third parties in various activities including but not limited to cultural, sports, or corporate events; dinners; accommodation; or travel. Within the scope of its relationship with business partners, Ekol may offer hospitality (e.g., meals, events, entertainment, cultural/sports activities) for the purpose of trust-building or business courtesy, provided thatno financial or moral benefit is expected in return, such hospitality is not repetitive or habitual in nature; and, all such activities comply with applicable local legislation. Unless part of an official event, it is essential that no participant be invited to any independent activity or entertainment outside of Ekol’s official programs, nor be offered side or extended trips.

In case of any doubt regarding these matters, the Ethics Committee must be consulted.

4.3. Business Relations with Public Officials and Politically Exposed Persons

Anyone involved in a public function is considered a public official, regardless of their title or the nature of their role. A Politically Exposed Person refers to individuals holding public office or possessing political influence, including—but not limited to—government or state employees, politicians, judicial or military officials, executives of state-owned enterprises, and political party representatives.

Business relations may be established with public officials and Politically Exposed Persons only if the transactions are assessed objectively and ethically, serve a legitimate purpose, comply with applicable laws and regulations, and do not involve granting any improper advantage.

Under no circumstances shall any benefit—monetary or otherwise—be offered or provided to a public official on behalf of Ekol.

4.4. Facilitation Payments

Facilitation payments are unofficial and improper payments made to expedite or secure the performance of routine actions, including those involving public services. It is strictly prohibited for any individual or organization covered by this Policy—including Ekol employees, stakeholders, and third parties engaged in commercial cooperation with Ekol—to make such payments to government institutions in order to expedite and secure any routine action or procedure.

4.5. Sponsorships and Donations

Sponsorship refers to the cash or in-kind support (such as providing products or services) of artistic, social, sporting, or cultural events considered beneficial for participation, under a formal sponsorship agreement, with the aim of strengthening Ekol’s corporate reputation and contributing to brand awareness. Donations, on the other hand, are financial or in-kind contributions made for the benefit of society without any expectation of return or personal gain. These may include cash, cash equivalents, products, or services.

All details regarding the institutions or organizations to be supported by Ekol—including the amount, nature, and continuity of the support—must be approved by the Board of Directors.  

In addition to meeting the criteria above, all sponsorships and donations must strictly avoid conferring improper benefits, inducements to corruption, or violation of applicable anti-bribery and anti-corruption laws.

4.6. Accuracy of Accounting Records and Transparency of Transactions

All transactions and records must be accurate, transparent, complete, and timely, and must be entered into the accounting records in full compliance with applicable laws and standards. Records and supporting documents must be clear and detailed enough to enable any third party reviewing them to understand the purpose and execution of the transactions. It is strictly prohibited to carry out transactions without recording them in the accounting books, to fail to record assets, or to alter or manipulate recorded transactions in any improper manner. All recorded transactions must be subjected to periodic, risk-based audits.

4.7. Monitoring of Training and Transactions   

Ekol aims to provide Anti-Bribery and Anti-Corruption training on an annual basis. Where necessary, this Policy will be adapted to meet Ekol’s evolving needs, and related policies and procedures will be revised or newly developed accordingly.   

5. DUTIES AND RESPONSIBILITIES

All Ekol employees and managers are obliged to comply with this Policy. Ekol is responsible for implementing and supporting its relevant procedures and controls in line with the requirements of this Policy. The company also expects all its business partners to act in full compliance with this Policy and takes the necessary steps to ensure this alignment. 

If there is any concern or suspicion that an employee or anyone acting on behalf of Ekol has acted in violation of this Policy, a report must be submitted to the Ekol Ethics Hotline. Ekol treats all reports with strict confidentiality, including the identity of the reporting individual, and ensures each case is reviewed objectively, honestly, and transparently. 

The Ekol Ethics Committee investigates any actual or potential non-compliance with this Policy and imposes appropriate sanctions if misconduct is confirmed. Ekol may unilaterally terminate any business relationship or contract for just cause if any behavior, attitude, or action in breach of this Policy is identified in relationships or agreements to which it is a party.