Kredinow’s Ethical Business Practices Guide for Suppliers

Effective Date: July 11, 2025

Kredinow requires all entities that provide goods or services to our organization—including vendors, service providers, and contractors (collectively referred to as “Suppliers”)—to uphold the highest standards of integrity, responsibility, and ethical conduct. This Ethical Business Practices Guide for Suppliers (“Guide”) outlines the baseline expectations for Suppliers and complements any legal obligations, internal policies, or contractual terms in place with Kredinow.

  1. Legal Compliance

Suppliers must fully comply with all applicable laws and regulations in the Republic of Türkiye. This includes, but is not limited to:

  • The Law on the Protection of Personal Data (KVKK – Law No. 6698)
  • Turkish labor laws and social security requirements
  • Consumer protection and commercial codes
  • Environmental regulations
  • Anti-corruption laws, including the Turkish Penal Code provisions on bribery and misconduct
  • Tax and financial reporting obligations
  1. Commitment to Labour and Human Rights

Kredinow is committed to supporting human rights and fair labor practices. Suppliers must operate in accordance with these values:

  • Voluntary Labor: Suppliers must not engage in forced labor, slavery, or human trafficking. Employment must be freely chosen and compliant with national labor standards.
  • Fair Wages and Conditions: Workers must be paid at least the legal minimum wage, including benefits, social security contributions, and overtime compensation in accordance with Turkish labor laws.
  • Equal Opportunity: Discrimination or harassment on the basis of gender, ethnicity, religion, disability, or other protected characteristics is prohibited. Employment decisions must be based on merit.
  • Workplace Safety: Suppliers must ensure safe, hygienic, and healthy working conditions in compliance with Turkish occupational health and safety legislation.
  1. Upholding Ethical Standards

Suppliers must demonstrate integrity and transparency in all business dealings with Kredinow and third parties:

  • Anti-Corruption: Bribery, kickbacks, facilitation payments, or any form of corruption are strictly prohibited. Suppliers must comply with anti-bribery laws under the Turkish Penal Code and related regulations.
  • Intellectual Property: Use of Kredinow’s trademarks, content, or other proprietary assets is only allowed with prior written approval.
  • Data Privacy & Security: If handling personal or confidential data on behalf of Kredinow, Suppliers must comply with KVKK and ensure appropriate security and privacy safeguards are in place.
  • Accurate Records: All financial records must be truthful, transparent, and auditable.
  • Gifts & Hospitality: Any gifts or benefits offered to Kredinow personnel must be modest and must not influence—or appear to influence—any business decisions.
  • Conflicts of Interest: Any actual or perceived conflicts of interest, including personal relationships or financial ties to Kredinow staff, must be promptly disclosed.
  1. Environmental Responsibility

Kredinow promotes environmentally sustainable business practices and expects Suppliers to:

  • Minimize environmental impact by reducing emissions, energy use, and waste
  • Comply with Türkiye’s environmental laws and safe disposal of hazardous materials
  • Adopt policies that support sustainability and ecological preservation
  1. Confidential Information

Suppliers must protect all confidential, proprietary, or non-public information received from or on behalf of Kredinow. This includes financial data, user information, business strategies, technical materials, and internal communications. Disclosure is only permitted if required by law or expressly authorized by Kredinow in writing.

  1. Raising Concerns

Suppliers are encouraged to raise any ethical concerns, violations, or irregularities relating to this Guide. Reports may be submitted through the Kredinow Compliance Channel or via the Supplier’s designated point of contact. All concerns will be handled confidentially and fairly. Retaliation against whistleblowers acting in good faith is strictly prohibited.

  1. Enforcement and Review

Kredinow reserves the right to evaluate Supplier compliance with this Guide. Non-compliance may result in suspension or termination of the business relationship. This Guide will be reviewed periodically, and updates will be shared as needed.

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