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
E-mail: policy@kogniser.com
1.1. This Ethics Policy (“Policy”) is intended to provide a practical guide for ethical decision-making in all of the Company’s business activities. The Company is committed to acting with honesty, integrity, and respect in its dealings with employees, customers, suppliers and all other stakeholders.
1.2. The standards set out in this Policy have been developed taking into account the framework of applicable laws and regulations, as well as the ethical values adopted by the Company.
1.3. This Policy is intended to serve as a general framework for ethical conduct and cannot anticipate every situation that may arise in the course of the Company’s activities. Accordingly, the principles set out herein should be applied using reasonable judgment and common sense, in light of the relevant circumstances.
1.4. Where a particular situation is not expressly addressed by this Policy, or where there is uncertainty regarding its application, individuals are encouraged to seek guidance through the appropriate internal channels made available by the Company.
1.5. All persons within the scope of this Policy are personally responsible for ensuring that their conduct and business decisions are consistent with the principles set out herein. Ethical concerns or potential violations should be raised in good faith through the internal channels designated by the Company.
2.1. The Company is committed to conducting its business activities in compliance with applicable laws and regulations in the jurisdictions in which it operates, and in a manner that reflects fair, honest, and responsible business practices.
2.2. All persons within the scope of this Policy are expected to act in good faith, to respect contractual obligations entered into by the Company, and to avoid any conduct that may involve misrepresentation, misuse of information, or unfair dealing with customers, suppliers, or other business partners.
2.3. This Policy is intended to promote lawful and ethical conduct, but does not replace the need for sound judgment. Where questions arise regarding legal or ethical obligations in specific situations, individuals are encouraged to seek guidance through appropriate internal channels.
3.1. A conflict of interest arises where personal interests, relationships, or activities interfere, or appear to interfere, with an individual’s ability to act objectively and in the best interests of the Company.
3.2. All persons within the scope of this Policy are expected to avoid situations that may create an actual or perceived conflict of interest. This includes situations involving personal financial interests, close personal or family relationships, or outside activities that could influence business decisions made on behalf of the Company.
3.3. Individuals should not use their position within the Company, or Company resources, for personal benefit or to improperly benefit third parties.
3.4. Where a potential conflict of interest arises, individuals are expected to disclose the situation through appropriate internal channels so that it may be addressed in a reasonable and transparent manner.
4.1. The offering or acceptance of gifts, hospitality, entertainment, or other benefits must be conducted in a manner that is consistent with ethical business practices and does not create, or appear to create, an improper influence or obligation.
4.2. Any gifts or hospitality must be reasonable in value, appropriate in nature, and infrequent, and must be given or received only in the ordinary course of legitimate business activities.
4.3. Gifts, entertainment, or benefits must never be offered or accepted with the intent to influence business decisions, secure an improper advantage, or compromise independent judgment.
4.4. Where a gift or hospitality appears excessive, inappropriate, or inconsistent with this Policy, it should be declined or appropriately addressed through internal channels.
4.5. Ethical conduct under this Policy includes compliance with the principles and rules set out in the Company’s Anti-Bribery & Anti-Corruption Policy. Any conduct that may involve bribery, corruption, improper payments, or undue influence is strictly inconsistent with the Company’s ethical values and business standards and is governed by the Anti-Bribery & Anti-Corruption Policy.
5.1. The Company considers confidential information to be a valuable asset and expects all persons within the scope of this Policy to act responsibly in protecting such information.
5.2. Confidential information includes information relating to the Company, its business activities, customers, suppliers, or other third parties that is not publicly available and that is entrusted to the Company in the course of its operations.
5.3. Confidential information must not be disclosed to unauthorized third parties or used for purposes other than legitimate business purposes.
5.4. The obligation to protect confidential information applies during and after the period of engagement or employment with the Company, subject to applicable laws and contractual obligations.
6.1. The Company is committed to conducting its business relationships in a fair, honest, and respectful manner. All persons within the scope of this Policy are expected to treat colleagues, customers, suppliers, and other business partners with professionalism and respect.
6.2. Unethical conduct, including deceptive, misleading, abusive, or inappropriate behavior, is inconsistent with the values of the Company and will not be tolerated.
6.3. The Company expects that its business activities are conducted in a manner that promotes mutual trust, cooperation, and respect, and that avoids behavior that could harm the Company’s reputation or business relationships.
7.1. Company assets and resources are to be used responsibly and primarily for legitimate business purposes. Assets include, among others, equipment, IT systems, software, data, facilities, and any other property or information made available by the Company.
7.2. All persons within the scope of this Policy are expected to safeguard Company assets against loss, misuse, damage, or unauthorized use, and to act with care when accessing or using such assets.
7.3. Company time, materials, and resources should not be used for personal or unrelated business activities, except where such use is minor, occasional, and permitted under the Company’s internal practices.
8.1. This Policy is intended to provide general guidance on ethical conduct and does not create contractual rights or obligations. It is not designed to replace applicable laws, regulations, or Company policies.
8.2. Questions regarding the interpretation or application of this Policy may be raised through appropriate internal channels. The Company encourages good faith dialogue concerning ethical concerns.
8.3. The Company may review and update this Policy from time to time to reflect changes in applicable laws, business practices, or organizational needs.
8.4. The Company encourages individuals to raise ethical concerns or questions in good faith through appropriate internal channels. Raising concerns in good faith will not, in itself, result in any adverse treatment.
8.5. Questions regarding the interpretation or application of this Policy, or requests for guidance in relation to ethical matters, may be addressed through internal communication channels designated by the Company.
8.6. Without prejudice to applicable laws and internal practices, ethical questions or concerns may be communicated via the following contact point designated for such purposes:
8.7. Communications made in good faith under this Policy are intended to support ethical decision making and awareness within the Company and will be handled in a reasonable and appropriate manner in line with internal practices.
