The Code of Conduct contains the principles and regulations regarding the working order that employees of Vişne Madencilik A.Ş. must comply with in fulfilling their duties. The purpose of these principles is to prevent any disputes and conflicts of interest that may arise between employees, customers and the institution.

The Code of Conduct includes key behavioural principles and guidelines. These principles and guidelines orient us not only in our daily business life but also in strategic planning and decision-making processes. This Code of Conduct may be amended in line with the relevant local laws and standards, if deemed necessary.

The Code of Conduct is subject to change. It is regularly developed and adapted according to the changes that occur in laws and economic conditions and affect the way we operate all over the world. The Code of Conduct is a set of measures of accuracy and integrity and, from a moral point of view, form the basis of individual and social relations. Attitudes and behaviours in contradiction with these guidelines will be evaluated within the scope of the internal disciplinary regulation and it is essential to act in accordance with the guidelines of common sense and goodwill in the circumstances and conditions not covered by these guidelines.

Taking these principles into account, we have reviewed the Code of Conduct, which is the basis of our vision and values. “Vision and Values” cover the basic principles adopted and undertaken by the Vişne Madencilik. The image and reputation of Vişne Madencilik as a company complying with the Code of Conduct and laws also depends on everyday attitudes in our business life. As the employees of Vişne Madencilik we need to comply with laws and regulations, avoid conflicts of interest, protect company assets, consider and respect traditions and etiquette. We may not compromise ethical guidelines while fulfilling our responsibilities within Vişne Madencilik. Inappropriate behaviour can never be in best interest of Vişne Madencilik.

If you have questions you would like to ask, or if you are uncomfortable with a decision or attitude, report the matter to your manager in Vişne Madencilik A.Ş.. Take advice from us. Most importantly, however, act in accordance with the Code of Conduct and never allow others to breach it. We must be aware that it is our values that introduce us to the outside world. Therefore, the image and reputation of Vişne Madencilik are always entrusted to you.

1. Integrity

Accuracy and integrity are our primary values in all our business processes and relationships. We act with integrity and reliability in our relationships with employees and all stakeholders.

2. Confidentiality

Confidential and proprietary information covers the information pertaining to Vişne Madencilik A.Ş. that may be disadvantageous in terms of competition, trade secrets, financial and other information not yet disclosed to the public, information relating to personnel personal rights and information within the framework of “confidentiality agreements” concluded with third parties. The Company values the confidentiality and protection of the private information of its employees, customers and other relevant persons and organizations, protects confidential information related to its activities and uses this information only for the purposes of the company; it only shares this information with the relevant persons within the determined authorizations. Obtaining any commercial interest by insider leakage of any confidential information of Vişne Madencilik A.Ş. is unacceptable. When leaving our company, the confidential information and documents, project, regulation, etc. works that we have due to their duties may not be taken out.

3. Our responsibilities

In addition to our legal responsibilities; we take care to fulfil the following responsibilities towards our customers, employees, suppliers and business partners, competitors, society, humanity and the Company.

A. Our Legal Responsibilities

We perform all our activities and transactions at home and abroad pursuant to the laws of the Republic of Turkey and provide the legal and regulatory bodies and institutions with true, complete and understandable information in a timely manner. While conducting all our activities and transactions, we are equally distant from all kinds of public institutions and organizations, administrative formations, non-governmental organizations and political parties without any expectation of interest and fulfil our obligations with this responsibility. All of our Financial Transactions are performed in accordance with the law and are controlled and supervised by the Certified Public Accountant service.

B. Our Responsibilities towards our Customers

We work with a proactive understanding by focusing on customer satisfaction and responding to the requirements and demands of our customers in the shortest time and in the most accurate way. We offer our services on time and under the conditions we promise; we approach our customers within the framework of respect, honour, justice, equality and courtesy guidelines. We immediately notify the senior management of quality, safety and guidelines breaches that occur in Vişne Madencilik A.Ş. or its suppliers’ business and may have a adverse impact. Senior management evaluates and notifies the customer as soon as possible.

C. Our Responsibilities towards our Employees

We ensure that employees’ personal rights are fully and correctly exercised. We treat employees honestly and fairly and commit to a non-discriminatory, safe and healthy working environment. We make the necessary efforts for the individual development of our employees, support them to volunteer for appropriate social and social activities that they will take part in with the awareness of social responsibility, and observe the balance between work life and private life.

D. Our Responsibilities towards our Partners

By giving priority to the continuity of Vişne Madencilik A.Ş. and in the direction of creating value for our partners; we avoid taking unnecessary or unmanageable risks and aim for sustainable profitability. We act within the framework of financial discipline and accountability and manage the source and assets of our company and the working time with the awareness of efficiency and saving. We take care to increase our competitiveness and invest in areas with the highest potential for growth and the highest return on the resource being committed. We provide timely, accurate, complete and understandable information about our financial statements, strategies, investments and risk profile.

E. Our Responsibilities towards our Suppliers/Business Partners

We act fairly and respectfully as expected from a good customer and take due care to fulfil our obligations on time. We carefully protect the confidential information of the individuals and organizations we do business with and our business partners.

F. Our Responsibilities towards our Rivals

We effectively compete only in legal and ethical fields thereby avoiding unfair competition. We support efforts to ensure the targeted competitive structure within the society.

G. Our Responsibilities towards Society and Humanity

Protection of democracy, human rights and the environment; training and charity, elimination of crime and corruption is of utmost importance for us. We act sensitively as a pioneer in social issues with the awareness of being a good citizen; we strive to take part in non-governmental organizations, services in the public interest, and appropriate activities in these matters. We are sensitive to the traditions and cultures of Turkey and the countries where we manage international projects. We do not provide and accept products and services such as gifts etc. exceeding the purpose of bribery or intent.

4. Conflict of Interest

Company employees avoid conflicts of interest. By benefiting from our current duty; we do not personally benefit from the persons and organizations we are working with through our family or relatives. We do not engage in business activity based on an additional financial benefit outside the company. We avoid using the name and influence and our identity of our company for gaining personal benefit.

It is essential that company employees avoid situations that may create a conflict of interest. Failure to use company resources, name, identity and influence for personal benefit, avoiding situations that adversely affect the name and image of the institution are among the key responsibilities of all employees. The following principles of practice determine the conflicts of interest that employees of Vişne Madencilik A.Ş. may encounter in their private lives while fulfilling their duties or due to their business relationships and the principles to be applied in these situations.

In case of potential conflict of interest, we apply these methods once we believe that the interests of the relevant parties can be safely protected via legal and ethical means.

When in doubt, we consult with our manager and Human Resources Department.

5. Application Principles

All Company employees are required to fully comply with the situations and principles outlined below as activities that may create a conflict of interest. The Company carries out the necessary works to encourage its employees to comply with these principles. Employees will not engage in any business relationship with family members, friends or other third parties in which they have a mutual or reciprocal interest. For example, an employee with purchasing authority should refrain from doing business with a supplier where one of the family members works. Exceptional cases are subject to the consent and approval of the Chairman of the Board of Directors of the company. Employees may not obtain any commercial interest by insider leakage of any information of the companies and may not cause others to gain interest. Company employees may work in non-profit organizations and universities for social responsibility and benevolence tasks with the written approval of the management, provided that they do not disrupt their duties within the company. Company employees, individually and voluntarily, can actively operate in any political party. Managers may not ask their employees to do political work or become a member of a party. Employees can take part in any political party with the written approval of the following conditions and management; Employees’ participation in any political activity should not create a conflict of interest with the duties, practices and approaches they maintain in the company. Employees may not engage in any political activities during working hours and may not take up the time of their colleagues related to these activities. Employees may not use the company name, position, title and resources of the company during their political activities. Employees may offer personal or moral assistance and/or donations to third parties outside the company and may work in charities. 5. Misconduct: It is not acceptable for the Employees to harm Vişne Madencilik A.Ş. by using their influences for their own and/or relatives’ benefit and out of due diligence.

Employees may not directly or indirectly obtain personal gain from all transactions and contracts that Vişne Madencilik A.Ş. is a party to with its purchasing and sales activities. Employees may not engage with any act or actions contrary to morality, law or company discipline.

6. Use Of Resources

In resource utilization to be made on behalf of the company, company interests are taken into account. Company assets, facilities and personnel may not be used outside Vişne Madencilik A.Ş. under any name and for the benefit of any person without the interest of the company. “Savings in every respect” principle is applied by all personnel. Proper use of resources for the benefit of Vişne Madencilik A.Ş. also requires the correct use of time. During business hours, company employees make good use of time and do not allocate time to private work during business hours. Managers may not assign employees for their personal affairs. It is essential not to accept special visitors during working hours. Employees are required to complete interviews for obligatory visitors in a reasonable period of time in connection with the subject of the visit and in a manner that will not prevent the work flow.

7. Relations with Other Persons and/or Organizations in which Vişne Madencilik A.Ş. is in Commercial Relations

Private business relations may not be entered into with the customers, subcontractors or suppliers of Vişne Madencilik A.Ş. and other persons and/or organizations in which Vişne Madencilik A.Ş. has commercial relations, personal loans, money and/or goods/services may not be taken and other persons and/or organizations in which Vişne Madencilik A.Ş. has commercial relations may not be lent money and/or goods/services. In relations with customers, the following matters are taken into consideration; even if it is in favour of the customer, no transaction can be made without customer consent and even if it is in favour of the company, customer weaknesses may not be utilized and the customer may not be motivated for profit by providing incomplete or incorrect information to the customer. Company personnel may not request or imply gifts from other persons and/or organizations in which Vişne Madencilik A.Ş. is in commercial relationship; they may not accept any gifts, money, cheques, properties, free holidays, special discounts etc. that will oblige the companies. No personal assistance or donation will be accepted from any person or organization having a business relationship with the Company. Accepting and Giving Gifts Policy is applied in relation to the subject.

8. Representation of the Company

In all kinds of associations, unions and similar non-governmental organizations of VİŞNE MADENCİLİK representing the company, all kinds of fees to be accrued due to the action performed will be donated to the relevant institution or channels to be shown by the relevant institution. Payments made by 3rd parties to the employee of Vişne Madencilik A.Ş. in return for seminar speaker fee or similar service are similarly donated to the relevant institution or channels to be directed by the institution. Apart from money, these people can receive gifts such as prizes, plate etc. that are given as a memory of the day and have symbolic value. It is essential that employees of Vişne Madencilik A.Ş. do not accept gifts or benefits likely to affect their objectivity, decisions and behaviours and do not attempt to provide gifts and benefits likely to have such effects to third parties and organizations. The application principles defined below regulate the gift exchanges that may be made by Vişne Madencilik A.Ş. employees with the third parties and organizations in which they are in business relationship and determine the principles to be applied in this regard.

Application Principles

It is prohibited for the employees of Vişne Madencilik A.Ş. to receive all kinds of interests and gifts with or without economic value affecting or likely to affect their objectivity, performance and decision-making while performing their duties.

Company employees may receive and/or give gifts with the above-mentioned characteristics or agree to be subjected to a special application provided that they comply with the corporate business objectives, comply with the applicable legislation and that the fact that the gift is acquired by the 3rd parties does not put the company in a difficult position.

Company employees may provide and receive entertainment, offering and meals at acceptable standards in the business world with the approval of the Board of Directors. Gifts such as prizes, plates etc. with symbolic value other than money may be received from seminars and similar organizations attended on behalf of the company. It is prohibited to receive gifts or benefits that are implicitly or explicitly related to a consideration. Taking, giving or offering a bribe and/or commission is not acceptable under any circumstances. Company employees are prohibited from accepting free or borrowed money from subcontractors, suppliers, consultants, competitors or customers, and from compensating for travel expenses, event expenses and similar payments.

The company’s senior management approves what the gifts and promotional materials to be given by Vişne Madencilik A.Ş. to the customer and other third parties with whom it has business relations. There is no need to obtain additional permission for the distribution of approved gifts and promotional materials. Subject to compliance with the above mentioned conditions, Vişne Madencilik A.Ş. may accept appropriate products and services as gifts and, with the consent and approval of its senior management, products or services appropriate for the culture and ethical values of the buyer may be given as gifts. In exceptional cases where local cultural values require reciprocal gifts above the values set out in Vişne Madencilik A.Ş. policy, these gifts can only be accepted on behalf of Vişne Madencilik A.Ş. and with the approval of the company’s senior management. In any case, gift exchange should be made in accordance with local culture.

9. Protecting Confidential Information Policy

Effective use of the information, sharing it properly and providing confidentiality, integrity and accessibility of it during this process are the joint responsibility of all our companies and employees. It is of utmost importance that the management systems established for the administration and confidentiality of information in our companies and the processes applied are in harmony with each other in order to obtain maximum benefit.

The following principles of practice define confidential information for Vişne Madencilik A.Ş. and regulate the principles that employees must follow regarding confidential information.

Application Principles

Confidential Information includes all kinds of written, graphical or machine-readable information such as, but not limited to, intellectual rights such as trademark, database, printed communication materials, processes, advertising, product packaging and labels and plans (marketing, product, technical), business strategies, strategic partnerships and partner information, financial information, personnel information, customer lists, product designs, know-how, specifications, identity of potential and real customers, suppliers etc. The principles to be complied with regarding confidential information are as follows:

This information may not be disclosed to third parties unless it is required to disclose them pursuant to Official Authorities and Legislation.

This information will not be altered, copied or destroyed. The required measures are taken to carefully keep, store and not to disclose the information. Changes on the information are recorded with its history. Hidden files may not be taken out of the institution. Confidential information that needs to be taken outside the institution should be approved by the information supervisor or senior management. The passwords, user codes and similar descriptive information used to access the information of Vişne Madencilik A.Ş. are kept confidential and are disclosed to anyone other than authorized users. The confidential information of Vişne Madencilik A.Ş. is not discussed in public areas such as dining halls, cafeteria, lift, etc. The personnel of Vişne Madencilik A.Ş. is aware of the degree of confidentiality of the information obtained in accordance with its duty and acts as per this confidentiality. When there is a doubt in terms of the degree of confidentiality, it is treated according to a higher confidentiality class and, if necessary, the opinion of the relevant manager is obtained. In case information is shared with third parties and/or organizations for the interest of the company, firstly, a confidentiality agreement is signed for information exchange on the purpose of guaranteeing that the responsibilities related to the safety and protection of the information shared with these individuals and organizations are understood. A false statement or rumours related to individuals and organizations is not allowed. Private personnel information of staff such as wage, fringe benefits and similar personnel is confidential and may not be disclosed to anyone other than the officials. Information of personnel is sent as in a private content. It is strictly forbidden to put pressure on other employees to disclose this information to others or to disclose it.

10. Establishing and Maintaining a Fair Work Environment Policy

The Company considers the creation of a fair working environment for employees and one of its top priorities. It is aimed to increase the success, development and commitment of employees by creating a fair, respectful, healthy and safe working environment in compliance with all relevant laws and regulations. The following principles of practice set out the basic principles for creating and maintaining a fair working environment in the Company.

Application Principles

Company practices comply with all applicable laws and regulations regarding employment and working life. Company employees also fulfil all legal requirements within the scope of their own activities and act in accordance with legal regulations.

Company human resources policies and practices ensure that all other practices such as recruitment, promotion, transfer, shift, remuneration, rewarding, social rights etc., are fair.

Discrimination between employees within the organization on the grounds of language, religion, race, colour, sex, political opinion, sect, age, physical disability and the like is unacceptable. A positive and harmonious working environment supporting cooperation in Vişne Madencilik A.Ş. is created and conflict environments are prevented and people with different beliefs, thoughts and opinions are ensured to work in harmony. Employees’ privacy and personal areas are respected. Communications between persons may not be violated by non-parties. Even if recorded in accordance with the law, it is prohibited to give/disseminate/seize personal data to others in contradiction with the law. Personnel personal information arising from the nature of the business relationship in the workplaces and which may be required in the future will not be used for purposes other than their own purposes and will not be exchanged with third parties without the consent of the relevant persons. The private and family life of all employees is respected. In addition to all kinds of immunity of the employees, their physical, sexual and emotional immunity is also observed. Violation of the immunity of employees in any way through physical, sexual and/or emotional harassment in the workplace or any place where they are present due to work is against the law and ethical guidelines and this crime is not tolerated by Vişne Madencilik A.Ş. in any manner. The purpose of this application is to ensure that employees are working in a work environment where their physical, sexual and emotional immunity is protected. Violation of a person’s body immunity through sexual behaviour and/or sexual harassment of a person without physical contact is defined as sexual harassment. Accordingly; it is forbidden to exhibit any behaviour that can be evaluated within this definition. In addition, those who complain and report any harassment or who behave negatively towards those who assist in the investigation are not tolerated in the same way. No employee may claim privileged practice due to gender, religion, language, race, show privilege to anyone, or be subject to a special practice. It is unacceptable to make or make concessions by taking advantage of differences such as gender, religion, language, race. It is ensured that the physical working environment and conditions of the workplace are healthy and safe for all employees.


Company managers have additional responsibilities beyond the responsibilities defined for employees. Accordingly, directors are responsible for ensuring establishment and maintenance of a company culture and working environment supporting ethical guidelines, being exemplary with their behaviours for implementation of ethical guidelines, training their employees on ethical guidelines, supporting their employees in communicating questions, complaints and notifications related to ethical guidelines, guiding them on what needs to be done when consulted, considering all notifications communicated and communicating them to the Ethical Committee as soon as necessary, ensuring that the business processes under their responsibility are structured to minimize risks related to ethical issues and implementing necessary methods and approaches to ensure compliance with ethical guidelines.


Senior management of Vişne Madencilik A.Ş. is responsible for the effective implementation of the Code of Business Ethics and the creation of a culture in which it is supported.

  • Employees are involved in the processes with a transparent, equal and participatory management approach.
  • Based on the customer-oriented approach in our work, it is ensured that each employee is an employee that creates added value by producing development-oriented projects.
  • Quality Policies, standards and OHS Policy sensitive approach are exhibited,
  • Designing, implementing and evaluating all training programs from the bottom to the top position by placing training at the center of development,
  • Observing the innovations and to feed the innovation process with Human Resources applications by ensuring their adaptation to the company,
  • Focusing primarily on our employees who are our internal values for vacant positions,
  • Keeping the right work for the right person, the right work policy for the right person at all levels,
  • Continuously developing the organizational structure that can adapt rapidly to changes and development,
  • Designing, establishing, developing and ensuring the functionality of a continuously learning institutional structure subsystem,
  • Performing human resources planning in order to carry out the works effectively and efficiently and providing qualified labour force to the family of Vişne Madencilik A.Ş.
  • Taking problem solving skills to the highest levels with solution-based approaches,
  • Enhancing the knowledge and skills of the employees, their relationship competencies with institutions and people,
  • Adopting , participating and encouraging the concept of social responsibility and projects in all applications,
  • Further strengthen our eco-friendly employee profile with respect to nature.

The Code of Business Ethics and all related policies are announced to Vişne Madencilik A.Ş. employees by the Human Resources Department with the approval of the Chairman of the Board of Directors.

Human Resources, in cooperation with Senior Management;

  • Informing the employees about the guidelines, providing training sessions at certain periods in order to ensure the clarity of the policies and guidelines and to ensure continuous communication with the employees,
  • Ensuring that the employees in Vişne Madencilik A.Ş. read the ethical guidelines, are informed in this regard and sign the relevant documents,
  • Ensuring that the confidentiality of complaints and notifications made within the framework of Code of Conduct and protecting individuals after notifications,
  • Ensuring occupational safety of the notifying employees,
  • Ensuring timely, fair, consistent and responsive investigation of complaints and notices and taking decisive action as a result of violations,
  • Ensuring that employees receive training on the existing guidelines and revisions at least once a year,
  • They are responsible for assessing the risks that may arise and ensuring the revision of the relevant policies where necessary.