Social Compliance

ETHICAL TRADE POLICY

Since its establishment, our company has chosen the path of “Honest Trade” and is determined to pursue this policy without compromise, preserve its honest image, and ensure that employees apply it in the same way.

- To act with honesty, integrity, fairness, and generally accepted moral principles in commercial activities;

- Not to harm the environment during commercial activities, and to strive for minimum harm when unavoidable,

- To protect the rights of partners and act honestly toward them,

- Not to discriminate on grounds of language, religion, region, race, gender, age, etc. when selecting personnel and offering career opportunities,

- Not to act contrary to human dignity and personal rights toward employees, and not to tolerate such behavior,

- Not to compromise on quality in the sale of goods and services,

- To aim to satisfy customer needs and ensure customer satisfaction in the sale of goods and services,

- Not to sell fraudulent or defective goods,

- Not to make false promises in the sale and advertising of goods and services,

- To honor contracts made with customers,

- Not to compromise on honesty toward other companies from which we buy and to which we sell goods and services, and to honor contracts,

- Not to engage in unfair competition.

HUMAN RIGHTS POLICY

- To offer equal opportunities to our employees without discrimination based on religion, language, race, sect, gender, or social origin,

- To provide a work environment free from all forms of harassment, abuse, exploitation, violence, or similar risks,

- To attach maximum importance to worker and workplace safety by continuously improving health and safety conditions,

- To show zero tolerance for forced or compulsory labor and not to employ child labor,

- Not to carry out any work or transaction contrary to international or national law in the workplace, and to arrange working and rest hours humanely,

- To respect our employees’ freedom of association and collective bargaining rights in accordance with legislation,

- To maintain long-term employment relationships by continuously investing in employees’ abilities, potential, and personal/professional development through internal and external training,

- To include stakeholders in all our activities, value them, and ensure they see themselves as part of our organization,

- To keep stakeholders’ data and information confidential,

- To share our human rights policy with all stakeholders and ensure compliance by all business partners, especially in the supply chain.

SOCIAL RESPONSIBILITY PRINCIPLES

We carry out our activities in accordance with relevant local, national, and all other applicable laws, applicable industry standards, other requirements to which we are party, and the principles set out below.

We also respect the principles of the following international instruments:

- Universal Declaration of Human Rights

- International Covenant on Economic, Social and Cultural Rights

- International Covenant on Civil and Political Rights

- United Nations Convention on the Rights of the Child

- United Nations Convention on the Elimination of All Forms of Discrimination Against Women

- United Nations International Convention on the Elimination of All Forms of Racial Discrimination

- UN Guiding Principles on Business and Human Rights

Our employees become employees of BORAN ÇELİK DÖKÜM of their own free will. We are against human trafficking and forced or compulsory labor.

We believe children should be students, not workers; we do not employ child labor.

We protect our employees from all forms of abuse or inhumane treatment at the workplace and encourage humane behavior and high performance.

We determine working hours according to applicable laws and select necessary overtime from volunteers.

We set wages at least to meet legal or sectoral requirements.

We do not practice or support discrimination in hiring, compensation, access to training, promotion, termination, retirement, etc. based on race, national or regional or social origin, caste, birth, religion, disability, gender, sexual orientation, family responsibilities, marital status, political views, age, or any other status.

We conduct and evaluate risk analyses with a proactive approach and the participation of all employees for a healthy and safe workplace.

We respect all employees’ private life and personal space.

We keep our employees’ and other stakeholders’ personal information confidential.

We avoid conflicts of interest and all forms of improper benefit.

We respect information and intellectual property rights.

We act respectfully toward nature, the environment, and animals.

We avoid waste in all our activities.

We encourage and evaluate our suppliers on these principles.

We do not tolerate corruption, bribery, or blackmail; we do not offer, request, or accept gifts or similar practices that could create the impression of obtaining illegitimate benefit.

We avoid activities that would undermine a fair competitive environment.

We do not participate in money laundering that conceals or integrates wealth and assets.

We comply with laws on export controls and inspections.

We provide employees and business partners access to a secure mechanism to report possible violations of these principles confidentially when necessary.

We ensure all our employees receive appropriate training.

OUR PROCUREMENT ETHICS RULES

- To devote time to supplier requests with understanding, support suppliers where justified, and maintain effective communication with suppliers,

- To avoid spot purchases by aiming for long-term, high-volume agreements,

- To provide accurate information on future plans and budgets in a timely manner to suppliers with whom we wish to work long term, and to plan by obtaining complete delivery and stock information,

- To prioritize suppliers with the following characteristics in selection:

✓ Always able to respond to procurement needs,

✓ Not exceeding procurement tolerance limits when addressing price and quality changes,

✓ Inviting procurement to their facilities/office, discussing problems and opportunities on site, sharing solutions, and being open to audit and visits when necessary.

- To share information with superiors and offer alternative solutions.

OUR RESPONSIBLE PROCUREMENT POLICY

As BORAN ÇELİK DÖKÜM A.Ş., while implementing our sustainable growth strategy, we aim to maintain long-term business relationships based on mutual trust, cooperation, and value creation with all stakeholders in our supply chain on sustainability management and its components, to raise sustainability awareness, and to support our activities with environmentally sensitive exemplary approaches.

Accepting and complying with the BORAN ÇELİK DÖKÜM A.Ş. Responsible Procurement Policy is a contractual obligation for our suppliers. In the event of systematic serious violation of this Policy, BORAN ÇELİK DÖKÜM A.Ş. reserves the right to terminate its contract with suppliers. Full compliance with items designated as Zero Tolerance is essential to become a BORAN ÇELİK DÖKÜM A.Ş. supplier. Likewise, BORAN ÇELİK DÖKÜM A.Ş. expects its suppliers to inform and implement the “Responsible Procurement Policy” with their own suppliers. The Policy is published on the BORAN ÇELİK DÖKÜM A.Ş. website and sent to suppliers for information.

BORAN ÇELİK DÖKÜM A.Ş. adopts the principle of high ethical and legal standards in all operations. Employees and all other business partners who believe Ethical Work Rules have been violated must report the violation to BORAN ÇELİK DÖKÜM A.Ş. as soon as possible.

Email: info@borancelik.com.tr

Phone: 0 312 640 11 66

GENERAL PRINCIPLES — 1. LABOR AND HUMAN RIGHTS

BORAN ÇELİK DÖKÜM A.Ş. affirms that all people must be treated with respect and dignity in accordance with the International Labour Organization, the Universal Declaration of Human Rights, the Constitution of the Republic of Turkey, and Labour Law No. 4857. Employers have a major impact on employee welfare and therefore owe a great duty. BORAN ÇELİK DÖKÜM A.Ş. and all stakeholders are responsible for applying human rights standards wherever they operate. Suppliers are also expected to comply with these provisions.

1.1 Zero Tolerance Against Discrimination: BORAN ÇELİK DÖKÜM A.Ş. commits that its suppliers will treat all employees and candidates equally in all hiring and employment processes without distinction based on language, color, race, gender, religion, age, or sect. BORAN ÇELİK DÖKÜM A.Ş. expects and requires suppliers to act on the principle of equality in development, career opportunities, and compensation and benefits management.

1.2 Zero Tolerance Against Discipline/Ill-Treatment and Harassment: BORAN ÇELİK DÖKÜM A.Ş. expects suppliers to provide a work environment free from violence, harassment, and other disturbing conditions arising from internal and external threats. No tolerance is shown for any violation of employees’ integrity through physical, verbal, sexual, psychological, and/or emotional harassment at the workplace or anywhere they are present for work-related reasons.

1.3 Zero Tolerance Against Child Labor and Forced Labor: No child labor shall be employed in suppliers contrary to applicable labor legislation. If a child working in the BORAN ÇELİK DÖKÜM A.Ş. supply chain is found, the supplier is responsible for determining measures to protect the affected child; BORAN ÇELİK DÖKÜM A.Ş. is responsible for monitoring this.

1.4 Young Workers: BORAN ÇELİK DÖKÜM A.Ş. expects suppliers to ensure that young workers under 18 do not work overtime or at night and are protected against working conditions harmful to their health, safety, morals, or development.

1.5 Wages and Benefits: Suppliers are expected to determine wages and benefits competitively according to the local labor market or in accordance with collective bargaining standards where applicable.

1.6 Freedom of Association and Collective Bargaining: Suppliers respect employees’ rights to join unions and engage in collective bargaining freely, voluntarily, and without interference, in accordance with law.

1.7 Working Hours and Conditions: Suppliers must comply with applicable labor legislation in their country regarding working hours and leave rights.

GENERAL PRINCIPLES — 2. HEALTH, SAFETY AND ENVIRONMENT

2.1 Health and Safety: Suppliers must comply with all legal regulations on occupational health and safety and take necessary measures for employees’ health, safety, and security.

2.2 Environmental Management: BORAN ÇELİK DÖKÜM A.Ş. manages processes with a philosophy aimed at minimizing environmental harm. Suppliers are expected to use natural resources such as energy and water efficiently, measure carbon emissions, improve performance on water and waste management and biodiversity, and manage waste in accordance with Environmental Regulations.

2.3 Responsible Raw Materials and Conflict Minerals: BORAN ÇELİK DÖKÜM A.Ş. works to source raw materials responsibly. It commits to conducting activities related to conflict minerals in accordance with the OECD Due Diligence Guidance and other laws and regulations. It avoids knowingly purchasing minerals not verified as conflict-free by the DRC.

GENERAL PRINCIPLES — 3. BUSINESS ETHICS

3.1 Conflicts of Interest: Suppliers must not enter into personal relationships that could cause or be perceived as causing conflicts of interest with BORAN ÇELİK DÖKÜM A.Ş. employees.

3.2 Protection of Information: Suppliers comply with all confidentiality policies and do not share confidential information with third parties.

3.3 Combating Bribery, Corruption and Money Laundering: Suppliers must not engage in improper conduct such as giving or receiving bribes. They are expected to strongly oppose any activity that could lead to money laundering.

3.4 Gifts and Hospitality: Suppliers must not accept or give gifts that would constitute non-compliance with law, except promotional materials in line with commercial custom.

3.5 Competition Law: All our suppliers must act in accordance with competition legislation.

3.6 Economic Sanctions: Suppliers commit to comply with trade restrictions, export controls, embargoes, and customs laws as applicable.

3.7 Counterfeit Parts: BORAN ÇELİK DÖKÜM A.Ş. expects suppliers to supply all products and services in original form and in accordance with quality and safety criteria specified in contracts.

GENERAL PRINCIPLES — 4. IMPLEMENTATION

Suppliers are assessed within the scope of the above topics in procurement processes; relationships may be terminated if non-compliance is detected. BORAN ÇELİK DÖKÜM A.Ş. may conduct surveys, request documents, and perform audits. The Procurement unit and Quality Directorate are responsible for the operation of this policy.

BUSINESS ETHICS RULES

Document Code: PLT-09 | Publication Date: 01.07.2023 | Revision No: 00

1. OUR BUSINESS ETHICS RULES

A. Honesty — Honesty and integrity are our priority values in all business processes and relationships. We act with honesty and integrity in relations with employees and all stakeholders.

B. Confidentiality — Confidential and private information includes information that could disadvantage BORAN ÇELİK DÖKÜM A.Ş. competitively, trade secrets, unpublished financial and other information, personnel records, confidentiality agreements with third parties, and intellectual property of stakeholders. We protect confidential information related to our activities, use it only for BORAN ÇELİK DÖKÜM A.Ş. purposes, and share it only within defined authority. When leaving the company, we do not remove confidential information and documents obtained through our duties. Confidential information is not discussed in corridors, cafeterias, elevators, shuttles, or similar non-isolated places.

C. Conflict of Interest — Conflict of interest means benefits that prevent or may affect employees from performing duties impartially. We do not obtain personal benefit from our position. We avoid using the name and power of BORAN ÇELİK DÖKÜM A.Ş. for personal gain. In case of doubt, we consult our Manager, Senior Management, or the Ethics Committee.

D. Our Responsibilities — In addition to legal responsibilities, we strive to fulfill our responsibilities toward customers, employees, suppliers and business partners, competitors, society, humanity, and BORAN ÇELİK DÖKÜM A.Ş.

- Legal Responsibilities: We conduct all activities and transactions within the framework of Turkish law and international law.

- Toward Customers: We work with a customer satisfaction-oriented, proactive approach. Customer information is used only within the scope of duties.

- Toward Employees: We commit to a non-discriminatory, safe, and healthy work environment.

- Toward Suppliers and Business Partners: We act fairly and respectfully and protect their confidential information.

- Toward Competitors: We compete only in legal and ethical areas.

- Toward Society and Humanity: Democracy, human rights, and environmental protection are important to us. We do not give or accept bribes or gifts exceeding proper purpose.

- On behalf of BORAN ÇELİK DÖKÜM A.Ş.: We are trusted for our professional competence and honesty. In public we express only the company’s views.

2. POLICIES SUPPORTING BUSINESS ETHICS RULES

a. Conflict of Interest Policy — Company resources, name, and power must not be used for personal benefit. An employee with procurement authority should avoid doing business with a supplier where a family member works. Exceptions require approval of the Ethics Committee Chair. Managers who hire may not hire spouses or close relatives. Personal donations to third parties outside the organization are permitted.

ii. Misuse of Duty — Employees may not use authority to harm the organization. Personal gain may not be obtained from procurement and sales activities.

iii. Use of Resources — Assets may not be used outside the organization without organizational interest. Private matters are not attended to during working hours.

iv. Commercial Relationships — Private business relationships with customers and suppliers are prohibited; gifts may not be requested. Gift Acceptance and Giving Policy applies.

v. Relations with Media — Giving statements and attending conferences require senior management approval.

vi. Representing the Company — Seminar fees are donated to the relevant organization.

C. Confidential Information Protection Policy — Confidential information may not be disclosed, altered, or copied. Confidential files may not leave the organization. Confidential information is not discussed in public areas. Confidentiality agreements are signed when sharing information.

D. Fair Work Environment Policy — Discrimination is unacceptable. No tolerance for physical, sexual, or emotional harassment. The workplace must be healthy and safe.

3. APPLICABLE LEGISLATION

Company operations may be subject to different country laws. Where local regulations conflict with our ethical values, solutions are sought within our ethical rules and procedures.

4. EMPLOYEE RESPONSIBILITIES

- To act in compliance with laws and regulations under all circumstances,

- To read, internalize, and comply with Business Ethics Rules,

- To report possible violations promptly (to senior management and/or Ethics Committee, with or without name),

- To cooperate in ethics investigations and maintain confidentiality.

5. MANAGER RESPONSIBILITIES

To build and sustain an ethical culture, lead by example, train employees, forward reports to the Ethics Committee, and minimize ethical risks.

6. ETHICS COMMITTEE ADVISORS

All department heads are natural advisors to the Ethics Committee. Responsible for guiding issues and reporting.

7. OTHER RESPONSIBILITIES

Human Resources is responsible for employee information and training; department heads for confidentiality of reports.

8. RESOLUTION OF NON-COMPLIANCE WITH ETHICS RULES

Violators will be subject to disciplinary sanctions. The Ethics Committee is chaired by the General Manager and includes the Finance and Administrative Affairs Manager, Management Systems Officer, Human Resources Officer, Quality Director, and a Department Director.

Reports: etikkurul@borancelik.com.tr — You may report to your unit manager in writing/orally or using the email address, with or without giving your name.