KK UNİVERSAL TURİZM KONAKLAMA GAYRİMENKUL VE GELİŞTİRME A.Ş.
ANTI-BRIBERY AND ANTI-CORRUPTION POLICY
1. PURPOSE AND SCOPE
This policy has been prepared to determine the principles and rules that members of the board of directors, employees, proxies, representatives, suppliers, business partners and all third parties acting on behalf of KK Universal must comply with in matters of bribery and corruption, and to guarantee compliance with anti-bribery and anti-corruption legal regulations, ethical and professional principles and universal rules.
2. DEFINITIONS
- Bribery: The provision, offering or promise of a benefit to a person or another, directly or through intermediaries, in order to cause that person to act contrary to the requirements of their duties.
- Corruption: The abuse of authority held by virtue of one's position for the purpose of obtaining any kind of gain, directly or indirectly.
- Fraud: An employee's use of company resources or authority for personal gain.
- Conflict of Interest: The situation in which a benefit that can or cannot be measured in monetary terms is provided to an employee or their relatives during the employee's decision-making or performance of their duties.
- Facilitation Payment: Any payment made to secure or expedite routine public transactions.
- Retaliation: Any conduct that causes material or moral harm to a whistleblower following a report.
3. OUR COMMITMENT: ZERO TOLERANCE
KK Universal conducts all its activities within the framework of integrity, transparency and ethical values. A zero-tolerance principle has been adopted against all forms of bribery and corruption. Within the scope of this commitment, KK Universal undertakes:
- To conduct its activities in a fair, honest, lawful and ethical manner, with a zero-tolerance approach against bribery and corruption,
- To comply with all national and international legal requirements relating to anti-bribery,
- To encourage the reporting of suspected bribery and corruption incidents and to follow up on them,
- To prevent stakeholders making reports from being subjected to retaliation and discrimination,
- To systematically manage risks related to anti-bribery,
- To carry out regular training to raise awareness.
4. PROHIBITIONS AND VALUES DEEMED TO CONSTITUTE BRIBERY
No employee or representative may offer or accept a bribe or participate in a process involving corruption, even in favour of the company. Bribery is not limited to cash and also covers the following forms:
- Cash or cash-equivalent payments,
- Gifts and gift cards,
- Job offers, employment, internship or training opportunities,
- Travel, accommodation, meals and hospitality (beyond the limits set out in this policy),
- Donations and political contributions,
- Any payment or benefit made indirectly through intermediaries.
Since bribery can also be given indirectly, all parties who offer, act as intermediary for and accept a bribe are held responsible under this policy.
5. GIFT AND HOSPITALITY STANDARDS
Symbolic gifts and hospitality within the scope of commercial courtesy are subject to the following conditions:
- Gifts and hospitality must not be of a nature or value that could influence decision-making processes.
- Cash or cash-equivalent gifts (gift cards, shares, etc.) may under no circumstances be given or accepted.
- No gift may be offered to third parties during any tender, offer or negotiation process; gifts may not be accepted during such processes.
- The total value of gifts offered to or accepted from a single third party within a calendar year must not exceed a symbolic level; where this limit is exceeded, the approval of senior management must be obtained.
- Every gift accepted is reported to the relevant unit through the immediate superior.
- Prior written approval is mandatory for gift and hospitality expenditures directed at public officials; giving cash or cash-equivalent gifts to public officials is under no circumstances acceptable.
6. FACILITATION PAYMENTS
KK Universal does not permit its employees or third parties acting on its behalf to offer facilitation payments or to tolerate such requests, regardless of the amount. Every employee and representative who encounters such a request is obliged to report the situation to senior management immediately.
7. CONFLICT OF INTEREST
Employees and representatives are obliged to avoid situations that may be perceived as a conflict of interest. Possible conflict of interest situations include but are not limited to:
- Conflicts arising from the employee's personal or family interests,
- Investment relationships that may influence business decisions,
- Personal commercial relationships with competing or supplier firms.
Every situation that gives rise to a risk of conflict of interest is reported to senior management in writing immediately.
8. RELATIONS WITH THIRD PARTIES
- Ethical background and stance on anti-bribery are among the key criteria in the selection of business partners and suppliers.
- Anti-bribery and anti-corruption obligations are explicitly included in supplier contracts.
- Business relationships with parties found to have adopted unethical methods are terminated immediately.
9. REPORTING MECHANISM AND PROTECTION FROM RETALIATION
Employees, suppliers or other stakeholders who encounter a suspicion of an ethical violation or any situation contrary to this policy may submit their reports through the following channels:
- E-mail: compliance@kkuniversalinc.com
- Written application: Halil Rıfat Paşa Mah. Yüzer Havuz Sk. Perpa Tic. Mer. A Blok No: 1 İç Kapı No: 1766 Şişli / İstanbul
Reports made in good faith are treated with confidentiality; the whistleblower's identity is kept confidential to the extent possible. Persons making reports are protected against retaliation; retaliatory conduct is accepted as a violation that in itself warrants a disciplinary sanction. This protection remains valid even if the report cannot be verified.
10. IMPLEMENTATION, AUDIT AND SANCTIONS
- The implementation, monitoring and updating of this policy is the responsibility of senior management.
- Policy violations may be subject to disciplinary sanctions ranging from written warnings to dismissal or termination of contract, depending on their gravity; violations constituting a criminal offence are reported to the competent authorities.
- Employees are provided with training on this policy upon commencement of employment and on a periodic basis thereafter.
- The policy is reviewed at least every two years and updated in line with legislative changes.
(Last Updated: June 2026)
