Kogniser Yazılım ve Teknoloji A.Ş.
MASLAK MAH. AOS 55. SK. 42 MASLAK B BLOK NO:4/542 SARIYER / İSTANBUL | Tel: 0 (212) 945 28 04 | Maslak V.D. 5741123776 https://kogniser.com | info@kogniser.com | Ticaret Sicil No: 1086570| MERSİS No: 0574112377600001
KOGNISER ANTI-BRIBERY & ANTI-CORRUPTION POLICY
1.1. The purpose of this Anti-Bribery & Anti-Corruption Policy (“Policy”) is to set out the principles and standards governing the prevention of bribery, corruption, and any form of improper influence in connection with the Company’s business activities.
1.2. The Company is committed to conducting its business with integrity, transparency, and ethical standards, and to complying with applicable anti-bribery and anti-corruption laws and generally accepted international business practices. Bribery and corruption undermine fair competition, distort business decisions, and expose companies to significant legal, financial, and reputational risks.
1.3. Accordingly, the Company adopts a zero-tolerance approach toward bribery and corruption in any form, whether conducted directly or indirectly, and regardless of whether such conduct involves public officials or private individuals.
1.4. This Policy establishes a common framework to identify prohibited conduct and to promote a culture of ethical decision-making and accountability across all business activities.
2.1. This Policy applies to all individuals and entities acting on behalf of, or in the interest of, the Company. This includes, without limitation, directors, officers, employees (whether permanent, temporary, or contractual), as well as consultants, agents, contractors, suppliers, and any other third parties engaged to perform services for or on behalf of the Company.
2.2. This Policy applies to all business activities and transactions undertaken by the Company, regardless of geographic location or jurisdiction. It covers interactions with both public and private sector counterparties and applies equally to domestic and cross-border business operations.
2.3. Where local laws, regulations, or contractual obligations impose stricter anti-bribery or anti corruption standards than those set out in this Policy, the stricter standards shall apply.
2.4. All persons and entities within the scope of this Policy are expected to read, understand, and comply with its provisions as a condition of their engagement with the Company.
Anything of Value: Any benefit or advantage of any kind, whether monetary or non-monetary, including but not limited to cash, gifts, hospitality, travel, entertainment, discounts,services, favors, employment opportunities, or any other tangible or intangible benefit. |
Bribery: Offering, promising, giving, requesting, or accepting anything of value, directly or indirectly, with the intention of improperly influencing a decision, action, or business outcome. |
Corruption: The abuse of entrusted power for private gain, including bribery, facilitation payments, kickbacks, or any other form of improper advantage. |
Facilitation Payment: A small payment or benefit made to secure or expedite a routine governmental action to which the payer is otherwise legally entitled. |
Government Official: Any elected or appointed official, employee, or representative of a government, public authority, state-owned or state-controlled entity, political party, party official, candidate for political office, or any international or supranational organization. |
Third Party: Any individual or entity that is not an employee of the Company and that acts for or on behalf of the Company, including consultants, agents, intermediaries, contractors, subcontractors, suppliers, or business partners. |
4.1. Bribery and corruption in any form are strictly prohibited. No person acting on behalf of the Company may directly or indirectly offer, promise, give, request, or accept any bribe or improper advantage in connection with the Company’s business activities.
4.2. This prohibition applies irrespective of whether the advantage is given or received through a third party and regardless of whether the recipient is a public official or a private individual. Improper advantages may not be offered or accepted for the purpose of obtaining, retaining, or directing business, securing favorable treatment, influencing decisions, or gaining any undue business benefit.
4.3. Facilitation payments, kickbacks, and any other payments intended to improperly influence actions or decisions are prohibited under this Policy, even if such payments are considered customary or tolerated in certain jurisdictions.
4.4. The Company does not permit any attempt to conceal or disguise improper payments, including by mischaracterizing expenses, using false documentation, or structuring transactions in a non transparent manner.
5.1. Gifts, hospitality, entertainment, or other benefits may only be offered or accepted where they are reasonable, proportionate, infrequent, and given in the ordinary course of legitimate business activities.
5.2. Such benefits must never be intended to improperly influence, or be perceived as influencing, a business decision, action, or outcome. Gifts and hospitality must not create a sense of obligation, expectation of preferential treatment, or conflict of interest.
5.3. Cash gifts and cash equivalents, including gift cards or vouchers, are strictly prohibited under all circumstances.
5.4. When assessing whether a gift or hospitality is acceptable, consideration should be given to the value, frequency, timing, purpose, and the identity of the recipient. Gifts or hospitality offered or received in sensitive situations, such as during contract negotiations or tender processes, are strongly discouraged.
5.5. Any gift or hospitality that is excessive, inappropriate, or inconsistent with this Policy must be declined or, where appropriate, reported.
6.1. Interactions with government officials require heightened care and strict compliance with this Policy and applicable laws. No person acting on behalf of the Company may offer, promise,
MASLAK MAH. AOS 55. SK. 42 MASLAK B BLOK NO:4/542 SARIYER / İSTANBUL | Tel: 0 (212) 945 28 04 | Maslak V.D. 5741123776 https://kogniser.com | info@kogniser.com | Ticaret Sicil No: 1086570| MERSİS No: 0574112377600001
Kogniser Yazılım ve Teknoloji A.Ş.
give, or authorize any gift, payment, hospitality, or other benefit to a government official for the purpose of influencing an official act, decision, or securing an improper advantage. 6.2. This prohibition applies regardless of whether the benefit is given directly or indirectly through a third party. Benefits provided to government officials must never be intended to influence, or appear to influence, any governmental action or decision.
6.3. Any interaction with government officials must be conducted transparently and in a manner consistent with lawful and ethical business practices. Where applicable, only nominal or symbolic items of minimal value may be provided, and only if permitted under applicable laws and customary practices.
7.1. The Company recognizes that bribery and corruption risks may arise through the involvement of third parties and subcontractors. Accordingly, the Company requires that all third parties acting for or on behalf of the Company conduct their activities in a manner consistent with the principles set out in this Policy.
7.2. The Company does not permit the use of subcontractors, intermediaries, or third parties in order to conceal the identity of the actual service provider, misrepresent the nature of services rendered, or facilitate improper or undisclosed payments.
7.3. Payments must only be made to the contractual counterparty for services actually performed in accordance with the relevant agreement. The Company strictly prohibits any arrangement whereby payments are made to one party while services are performed by another undisclosed party, or where funds are diverted, transferred, or otherwise used in a non-transparent or improper manner.
7.4. The Company represents that its business activities are conducted transparently and that services are performed only by authorized personnel and counterparties duly engaged under valid contractual arrangements. Any attempt to bypass contractual obligations, conceal third-party involvement, or engage in pass-through, disguised, or indirect payment structures is strictly prohibited and constitutes a violation of this Policy.
8.1. The Company is committed to maintaining accurate, complete, and transparent books and records that reasonably reflect its business transactions and the disposition of its assets. 8.2. All payments, expenses, and transactions must be recorded in a timely and accurate manner and
must not be mischaracterized or disguised in order to conceal improper conduct. False, misleading, or incomplete entries, whether made directly or indirectly, are strictly prohibited. 8.3. No undisclosed, unrecorded, or off-the-books accounts may be established or maintained for any purpose. Documentation supporting business transactions must be retained in accordance with applicable legal, contractual, and business requirements.
8.4. The Company expects that record-keeping practices support transparency and accountability and enable the identification of suspicious or irregular activities where they may arise.
9.1. The Company encourages the prompt reporting of any suspected or actual violation of this Policy. All persons within the scope of this Policy are expected to raise concerns in good faith if they become aware of conduct that may involve bribery, corruption, or improper practices.
9.2. Reports may be made through appropriate internal channels. The Company will take reasonable steps to review reported concerns in a timely and appropriate manner and to address substantiated issues in accordance with applicable laws and internal practices.
9.3. The Company strictly prohibits retaliation against any individual who raises a concern or reports a suspected violation in good faith. Retaliation, intimidation, or adverse treatment against individuals who report concerns honestly and responsibly will not be tolerated.
10.1. Any violation of this Policy may result in appropriate disciplinary action, up to and including termination of employment or contractual relationships, in accordance with applicable laws, contractual terms, and internal practices.
10.2. Where a breach of this Policy is suspected or identified, the Company may take reasonable steps to assess the matter and implement corrective measures where appropriate. Breaches of this Policy may also expose the individuals and entities involved to civil, administrative, or criminal liability under applicable laws.
10.3. The Company reserves the right to review, amend, or update this Policy as necessary to reflect changes in applicable laws, business practices, or identified risk areas.
