CODE OF ETHICAL CONDUCT

ACTING IN ACCORDANCE WITH CORPORATE QUALITY PRINCIPLES

Compliance with Laws and Legal Procedures

Procurement, engineering, manufacturing and accounting activities carried out within Rönesans Steel are managed, recorded and reported in a regular, complete and standardized manner in accordance with laws, Rönesans Steel policies and working principles.

Social Responsibility

At Rönesans Steel, projects are developed with a social responsibility approach and collaborations are established with relevant organizations in line with these ideals. Rönesans Steel employees act in accordance with the rules and responsively in the protection of the environment, public health and natural life. Rönesans Steel organizes social responsibility projects to support the positive progress of these problems due to inefficient employment and insufficient number of qualified employees, which are important problems of our country.

Customer Relations

Rönesans Steel operates with a proactive approach that focuses on customer satisfaction and responds to customer demands and needs in a timely and accurate manner. Long-term relationships based on trust are established with customers within the framework of respect and courtesy, value is created for customers through operational excellence and operational quality, and customer demands and requirements are met with a high level of satisfaction.

Supplier Relations

Rönesans Steel works with suppliers that have a corporate quality system, are ethical and honest, compatible with our way of doing business, and whose competencies are defined by criteria. The performance of suppliers is continuously evaluated within the scope of certain competency criteria and their corporate development is supported.

Competition

Rönesans Steel does not misrepresent its competencies, and does not make misleading statements to discredit competitors’ products and activities. On the contrary, Rönesans Steel adopts ethical rules and principles of honesty and does not conduct sales and advertising activities contrary to these principles.

RESPECTING HUMAN RIGHTS

Diversity and Inclusion

With its professional staff, Rönesans Steel is focused on satisfying all its suppliers and customers by aiming for excellent results. Our aim is to create a staff that is prone to teamwork by emphasizing the knowledge and skills of our employees in cooperation. For this reason, Rönesans Steel encourages its employees in all areas by considering, respecting and valuing their past experiences and ideas.

Fair Employment Practices

Rönesans Steel is an institution that provides equal opportunities to its employees and does not discriminate among its employees based on language, religion, race, color, sect, gender, political opinion, marital status, disability or other characteristics protected by law.

Harassment-Free Workplace

At Rönesans Steel, the safety and peace of mind of employees are prioritized. For this reason, there is no place for harassment at Rönesans Steel and such situations are not tolerated. Rönesans Steel provides its employees with a professional and safe environment where their knowledge and skills are respected and diversity and equality are protected.

Employee’s Private Information

Rönesans Steel does not share private information about its employees with third parties without the consent and knowledge of the employee, except for legal obligations.

Avoiding Child or Forced Labor and Human Trafficking

Rönesans Steel does not tolerate child labor, forced labor, human trafficking or prostitution. Rönesans Steel employees shall not cooperate with suppliers, contractors or other business partners of Rönesans Steel who engage in such activities.

ASSET AND INFORMATION MANAGEMENT

Intellectual Property Rights

Rönesans Steel avoids unauthorized use of trade secrets, advertising campaigns, copyrights, patents, brand information, computer programs and similar property rights of its customers, suppliers and competitors. Rönesans Steel takes care and adopts as a principle not to use any work covered by copyrights without the permission of customers, suppliers and competitors.

Information Management/Information Systems/Communication Tools

All legal records and reports are kept within Rönesans Steel in a timely and meticulous manner as specified by law. Rönesans Steel employees, by observing the Rönesans Steel Code of Ethics, accept that every report published about the work belongs to the company and meticulously report, record and archive their work in accordance with Rönesans Steel procedures. For this reason, unlicensed software is not installed, used or copied on company computers in consideration of personal and company rights.

Asset Management

All kinds of fixtures, tools and materials allocated by Rönesans Steel to its employees are protected and used in the most efficient manner, taking into account the company’s assets.

Safety and Crisis Management

Rönesans Steel takes necessary measures against possible natural disasters, terrorism and malicious attempts to protect the safety of its employees, factory and administrative facilities. In such cases, Rönesans Steel provides fast solution-oriented crisis management in order to minimize the losses that may occur in moments of crisis and to ensure business continuity.

Privacy

Adhering to Law No. 6698 on the Protection of Personal Data, Rönesans Steel fulfills its responsibilities. For this reason, it is aware of protecting confidential information and data about employees, customers, suppliers and business partners and not sharing them with anyone except for legal obligations.

TRADE CONTROLS

Necessary commercial regulations are made within Rönesans Steel in accordance with laws and company principles. Commercial regulations are made regarding the shipment and use of products and technologies that require export and import controls, and these regulations comply with the laws and company principles.

MONEY LAUNDERING

At Rönesans Steel, all financial transactions are carried out in accordance with the laws and regulations. All kinds of illegal trade, activities in which money constitutes a criminal element and activities carried out to legitimize money are avoided.

AVOIDING CONFLICT OF INTEREST

Rönesans Steel’s name, property, know-how, and the employee’s position within the company may not be used for personal gain.

NOT ACTING IN FAVOR OF ONESELF AND ONE’S RELATIVES

Rönesans Steel employees may not provide unfair advantage for themselves, their relatives or any third party by utilizing their duties and positions.

GIVING AND RECEIVING GIFTS

Rönesans Steel establishes its relations with its employees, customers and business partners in a professional manner within the framework of its Code of Ethics. For this reason, any kind of exchange that may occur in line with personal interests is avoided.

ZERO TOLERANCE FOR BRIBERY

Bribery is money, goods and similar things that are given underhandedly to the relevant official or officials in order to provide illegal convenience for a work that is desired to be done. Bribery is not tolerated at Renaissance Steel. The consequences of such behavior are severe for Rönesans Steel and the persons concerned and carry legal and criminal liability.

RESPONSIBILITIES OF EMPLOYEES

Rönesans Steel Code of Ethical Conduct contains detailed information on how we should conduct our business. It is the mandatory responsibility of all employees to pay attention to the implementation of these rules. Accordingly, all Rönesans Steel Employees are required to;

• Act in compliance with laws and regulations under all circumstances,
• Read the Renaissance Code of Ethical Conduct, know, understand, internalize and act in accordance with the rules, principles and values contained therein,
• Learn the general policies and procedures applicable to the company and specific policies and procedures related to their work,
• Consult with their manager about potential violations involving themselves or others,
• Promptly report possible violations by oneself or others; submit such reports in writing to one’s manager, either anonymously or by name,
• Cooperate with the management in ethical investigations and to have the responsibility to keep the information related to the investigation confidential.

RESPONSIBILITIES OF MANAGERS

Rönesans Steel Managers have responsibilities in addition to the responsibilities defined for employees within the framework of Rönesans Steel Code of Ethical Conduct. Accordingly, managers are responsible for;

• Informing employees about the code of ethical conduct,
• Setting an example and guiding employees with their behaviors in the implementation of ethical rules,
• Encouraging employees to submit their questions, complaints and notifications regarding the ethical rules,
• Providing guidance on what to do when consulted, taking into account all notifications received and forwarding them to the relevant parties as soon as possible when deemed necessary.

RESPONSIBILITIES OF THE HUMAN RESOURCES DEPARTMENT

It is responsible for providing trainings to inform employees about ethical rules and ensuring that this issue is communicated to employees.

RESOLVING NON-COMPLIANCE WITH ETHICAL RULES

Rönesans Steel can only take the necessary action to solve the problem if the misconduct is reported.
If Rönesans Steel employees learn or suspect that laws, regulations or ethical rules that the company is subject to have been violated, they may submit their reports in writing to Rönesans Steel managers via their company e-mail addresses.