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Anti-Bribery and Anti-Corruption

Yapı Kredi has embraced the ten principles of the United Nations Global Compact, which require organizations to achieve higher standards in ethical practice, and shape their operations accordingly. Yapı Kredi stands firmly against all kinds of bribery and corruption, and is determined to ensure compliance with applicable laws, regulations and principles, and for this purpose has issued a Bribery and Anti – Corruption Policy. Committed to operate with the highest standards of integrity and consistency, Yapı Kredi has prepared its Code of Ethics and Business Conduct, which was approved by the Board of Directors.

Bribery and Anti – Corruption Policy, and Code of Ethics and Business Conduct have been shared with all Yapı Kredi employees and managers, and are instantly and easily accessible via internal communication channels (intranet and internal announcements). In order to broaden employee awareness on the issue, employees are reminded of the rules of conduct on a monthly basis. These policies are published on the Yapı Kredi website for the information of all business partners and stakeholders.

All employees, including newly recruited personnel, provide a written declaration of commitment to the Code of Ethics and Business Conduct. Furthermore, the Bribery and Anti – Corruption Policy has been added to the group of documents shared with new employees during the recruitment process, to ensure that they are fully aware of anti-bribery and anti-corruption issues.

Training

All Yapı Kredi employees and managers undergo regular in-class training or distance learning programs as regards the Bribery and Anti – Corruption Policy, and Code of Ethics and Business Conduct. Completion of these programs is mandatory for employees, who have to pass exams with the desired score in order to be considered as successful.

Supplier Relations

Employees of suppliers are provided with video training on anti-bribery and anti – corruption issues.. Likewise, subcontractor firms’ employees who work at Yapı Kredi facilities are offered a distance learning program on fighting bribery and corruption, participation in which is obligatory.

As part of its Anti-Corruption Program, Yapı Kredi demands its suppliers to operate in compliance with Yapı Kredi's anti-corruption policies, and ensure that their employees embrace the principles embodied in these policies and shape their activities accordingly. To this end, relevant clauses have been included in contracts signed with suppliers. Yapı Kredi has also issued its “Principles on Fighting Corruption in the Acquisition Process of Intermediaries, Suppliers and Contractors”. Accordingly, due-diligence is carried out prior to signing a contract with such companies. Audits in this regard have been initiated as of 2015.

In order to ensure full compliance with domestic and international regulations as well as the Bank’s own policies, Yapı Kredi keeps track of blacklisted individuals and companies through information received from international data providers and social media sources. Information gathered through these sources is used to identify intermediaries, suppliers, contractors and customers with a history or suspicion of bribery. In the event that a customer or supplier is blacklisted for corruption or bribery, the Bank terminates all contracts with the individual or entity in question.

Responsibility

The Compliance and Internal Control Department is tasked with managing the implementation of the Code of Ethics and Business Conduct and the Bribery and Anti-Corruption Policy within the organization. The Compliance and Internal Control Department is responsible for ensuring compliance with the provisions related to banking and capital markets regulations, exchange regimens, anti-money laundering, internal and external fraud detection systems, data protection, the Bribery and Anti-Corruption Policy, conflicts of interest, the Code of Ethics and Business Conduct as well as the Turkish Commercial Code.

Monitoring

Yapı Kredi has established robust systems in line with international practices as well as internal regulations managed by “Internal Audit”, “Risk Management” and “Compliance and Internal Control” departments. These departments operate directly under the Audit Committee of the Board of Directors to ensure that the Bank’s activities are in full compliance with all laws, regulations, corporate policies and procedures in effect, and in accordance with the Bank’s Code of Ethics and Business Conduct, Birbery and Anti-Corruption Policy, Policy on Prevention of Laundering Proceeds of Crime and Financing of Terrorism, monitoring and reporting risks, conducting audits, and reporting to the Audit Committee and Board of Directors on a monthly, quarterly and yearly basis. Audit Committee is responsible for assessing the company’s ethical environment, controlling processes for ethical compliance, and submitting independent annual reports to the Board of Directors.

Reporting and Communications

Yapı Kredi has established confidential and anonymous communication channels for addressing employee queries on ethical conduct and corruption and bribery-related issues, as well as for reporting violations of rules or suspicious activities. In order to raise awareness, employees are periodically reminded of the Bribery and Anti – Corruption Policy, and the Code of Ethics and Business Conduct. Further information on reporting channels for ethics, bribery and corruption-related issues may be found in the Yapı Kredi Statement on Whistleblowing. Yapı Kredi Statement of Whistleblowing may be found here.

In addition to the existing regulations and anti-corruption policies in effect, Yapı Kredi has also developed its own Anti-Corruption Program. In this context, the Bank has established a risk methodology to ensure effective operation of analysis, evaluation and decision-making mechanisms on the fight against corruption.

Within the scope of the risk assessment methodology;

  • A periodically upgraded risk assessment is performed to provide a comprehensive picture as to which aspects of the business are most sensitive in terms of corruption and bribery. The results of the risk assessment are reviewed by the Audit Committee,
  • Within the scope of the anti-corruption program, employees are provided training on legal requirements in order to raise their awareness of the matter,
  • First- and second-degree anti-corruption controls are put into effect,
  • Secure and reliable information channels are established to allow employees to report on these issues,
  • The efficiency of the anti-corruption program is reported to the Audit Committee on monthly, quarterly and annual basis,
  • Information is provided as regards the necessity to register all transactions accurately in the official ledgers and records, as well as the obligation to avoid any unexplained or unregistered accounts, funds or assets and transactions in this scope, under any condition.
  • Reports on issues falling under the scope of the anti-corruption program and notices on acts of bribery and corruption are submitted to the Audit Committee on a quarterly basis and to the Head of Anti-Corruption on a monthly basis.

Yapı Kredi has identified high-risk areas within the scope of its efforts to identify and mitigate the risk of corruption and bribery. Joint efforts have been carried out with the relevant departments in areas with the potential of being the most sensitive area with regards to corruption and bribery. The purpose of the risk assessment is to identify the ratio of the main risk areas over the total corruption risk, perform second degree controls, establish transparent processes to this end, and identify other potential anti-bribery and corruption measures. The results obtained through these efforts carried out with the relevant departments are submitted to the Audit Committee and additional training programs have been scheduled.

Stakeholder Dialogue

In accordance with its principles of transparency and accountability, Yapı Kredi aims to take its fight against bribery and corruption one step further with new practices designed to prevent high-risk activities. Accordingly, Yapı Kredi has become a member of the Association for Ethics and Reputation (TEID). With its innovative efforts and initiatives in ethics, bribery and corruption-related issues, TEID provides support and guidance to Yapı Kredi. Yapı Kredi cooperates with TEID with a view to identifying its bribery and corruption risks, which play a significant role on its sustainability and corporate governance performance, as well as for consultation on its Bribery and Anti – Corruption Policy for improvements in related reporting mechanisms. Yapı Kredi’s practices in this area have been reviewed by TEID, which provided comments and feedback. Necessary activities were performed as the consequence of the feeback received, thereby the stakeholder dialogue process was completed.

Further information on Yapı Kredi’s Bribery and Anti – Corruption Policy, Code of Ethics and Business Conduct, as well as Statement on Whistleblowing may be found here.

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