Anti Corruption Policy

Purpose

This policy has been established to ensure the implementation of a zero-tolerance approach against all forms of corruption, bribery, conflicts of interest, and unethical conduct within Kristal Mensucat.

Scope

This policy covers:

• All employees of Kristal Mensucat,
• All stakeholders of Kristal Mensucat, including suppliers, contractors, subcontractors, and personnel involved under contracts with other organizations.

The implementation and updating of the Anti-Bribery and Anti-Corruption Policy are under the authority, duty, and responsibility of senior management.

Corruption: A form of fraud or crime carried out by a person or an organization entrusted with a position of authority to obtain unlawful benefits or to misuse power for personal gain.

Bribery: The act of directly or indirectly offering, promising, giving, requesting, or accepting an undue advantage in order to perform, cause to perform, refrain from performing, accelerate, or delay an act related to the execution of one’s duty, in violation of the requirements of that duty, within the framework of an agreement between parties.

Bribery and corruption may occur in many different forms, including but not limited to:

• Cash or material benefits
• Valuable gifts, hospitality, or travel offers
• Commission payments or concealed payments made under the name of consultancy
• False records, forged documents, falsification
• Abuse of authority
• Political contributions, donations, facilitation payments

Main Risk Areas for Bribery and Corruption

The Company aims to fully comply with all relevant laws, regulations, and principles at all times and shows zero tolerance for any act of bribery or corruption, regardless of its purpose. It is essential not to maintain business relationships with third parties who seek or demand services through bribery. The main risk areas where bribery and corruption may occur are detailed below:

Gifts

A gift is an item given between parties in a business relationship or to customers as a gesture of appreciation or commercial courtesy, without the intention of obtaining material benefit. Any gifts given by the Company to third parties are provided openly and in good faith. The same conditions apply to gifts accepted from third parties.

Hospitality

Within the scope of building commercial networks and developing business relationships, hospitality may be offered to customers, suppliers, subcontractors, consultants, auditors, and other companies with which the Company has commercial relations. The Company offers hospitality to third parties in good faith, openly, and unconditionally.

Even if compliant with the provisions of this policy, hospitality offers and gifts that may lead to or be perceived as causing a conflict of interest are neither offered nor accepted.

Donations

It is essential that no corporate or personal payments, gifts, aid, or donations be made to any private company, government official, or political party candidate in order to influence any decision related to the continuation of the Company’s activities or any service procurement and performance stage that may benefit the Company.

Facilitation Payments

Persons and entities within the scope of this policy shall not offer facilitation payments to secure or expedite routine procedures or processes (such as obtaining permits, licenses, or official documents) with government institutions.

Record Keeping

The Company’s accounting and record-keeping system is governed by legal regulations, ethical rules, and working principles. All accounts, invoices, and documents related to relationships with third parties must be recorded and maintained completely, accurately, and reliably. No falsification shall be made in accounting or similar commercial records related to any transaction, and facts shall not be misrepresented.

Policy Violations and Sanctions

The Anti-Corruption and Anti-Bribery Policy has been communicated to all Kristal Mensucat employees and has been added to a folder that is easily accessible to everyone. If there is an opinion or suspicion that an employee or a person acting on behalf of Kristal Mensucat has acted contrary to this policy, senior management must be informed.

No retaliation or adverse treatment shall be permitted against any person who reports a bribery or corruption incident transparently and in good faith.

As Kristal Mensucat we commit to adhering to ethical values at every stage of our activities and regard the fight against bribery and corruption not only as a legal obligation but also as a fundamental element of our corporate culture. We expect all our employees, business partners, and stakeholders to comply with this policy.