Code of Ethics
Dear Employees,
In the professional world, the alignment of personal and corporate values is essential for loyalty and productivity. Our company operates on strong ethical values and business integrity. Upholding ethical standards is not just an obligation but the key to sustainable success and trust. In today's business environment, the ethical stance of our stakeholders is a fundamental element that shapes our corporate identity. Therefore, we expect all parties we work with to act in accordance with these values.
Our "Ethical Guidelines" are the constitution of our company!
Transparency, truthfulness, and high business ethics allow us to establish long-term relationships and achieve successful outcomes. These Ethical Guidelines are not just a document; they are the foundation of our company culture. Together, by striving for a fairer, more honest, and ethical business world, we contribute not only to our company but also to the environment and future we operate in.
We recommend that you read these Ethical Guidelines carefully. These rules guide our daily work and help us decide how to act in difficult situations. Each of us is responsible for knowing these rules and making them an integral part of our lives.
We have full confidence that each of us will continue to work in adherence to these Ethical Guidelines to protect and sustain the high reputation of our company.
Respectfully,
Human Rights and Workplace Respect
Respect for human rights and fair relations is of critical importance to our company. We fully respect the dignity, privacy, and personal rights of every individual. We do not tolerate any discrimination based on ethnic origin, culture, religion, age, disability, race, sexual identity, worldview, or gender. We strive to maintain a fair, equitable, and tolerant atmosphere in our interactions within the company and with our stakeholders (including personnel, suppliers, customers, and business partners).
We have adopted a zero-tolerance policy against any discrimination, sexual or other personal harassment, or aggressive behavior directed at any person based on the above characteristics. We base our decisions on merit and never consider inappropriate factors such as discrimination or pressure. We develop various policies and programs to embrace, strengthen, and support diversity and differences in our company and in our relations with stakeholders.
We are committed to being reliable partners by adopting an open, honest, and responsible approach. We expect our personnel to embrace these values and adhere to the principle of honesty. We are determined not to make promises we cannot keep, in line with a culture of transparent communication.
These fundamental principles form the basis not only for our company’s compliance with ethical rules but also for building strong and sustainable relationships with our stakeholders.
Integrity, Transparency, and Compliance
As a company, we emphasize our commitment to the principle of integrity by adopting a policy of honest business conduct, which includes the following key elements:
Fair Competition
Fair competition allows markets to develop freely. Every employee is obliged to comply with fair competition rules. Since competition compliance rules may vary from country to country and situation to situation, it is advisable to consult competent persons when necessary to assess competition.
Offering and Providing Benefits
Our company strictly prohibits all forms of bribery and corruption. In this context, our personnel may not offer, promise, give, or approve the giving of money or anything of value, either directly or indirectly, to a third party to influence an official act or secure an improper advantage. The scope of these benefits includes gifts, hospitality expenses, donations, sponsorships, and memberships. The rule of not securing improper benefits in a commercial transaction also applies to the counterparty. Our personnel are not only prohibited from accepting improper benefits but also required to report such offers (see Whistleblowing Channels). Any such offer, promise, donation, or gift must comply with applicable laws and company policies and should not create an impression of bad faith or impropriety.
Preventing Money Laundering
Money laundering involves concealing the nature and source of funds connected to criminal activities by introducing "dirty money" into legitimate business transactions, thereby making it appear legitimate or preventing the true source or owner from being identified. We only do business with reputable customers engaged in lawful business activities with legitimate sources of funds.
To avoid potential issues in this area, attention must be paid to suspicious behavior by customers, consultants, and business partners. Additionally, all accounting, record-keeping, and financial reporting requirements related to cash transactions must be followed.
Preventing Conflicts of Interest
In making business decisions, it is essential to prioritize the best interests of our company over personal interests. We must focus on the success and sustainability of our company with an objective and fair perspective.
The company’s resources, intellectual property, time, and facilities should not be used for personal gain. These resources should only be used to achieve the company’s objectives and support business operations.
Conflicts of interest, even if only perceived, must be immediately addressed. In line with the principle of transparency, necessary steps should be taken to prevent conflicts of interest and protect the company’s credibility.
Supplier Relationships
As Pomega, we emphasize our commitment to ethical values and our responsibility for sustainable business practices by requiring full compliance with the following principles from all our suppliers:
Ethical Rules and Legal Compliance
We expect all our suppliers to fully comply with Pomega’s Ethical Guidelines and all relevant laws. Full compliance with legal requirements is critical to the credibility of our company and our supply chain.
Fundamental Principles and Respect for Human Rights
We expect our suppliers to adopt fundamental principles, such as preventing corruption, respecting the basic human rights of personnel, acting fairly and respectfully, complying with laws prohibiting child labor, and taking responsibility for personnel’s health and safety, in addition to complying with all relevant laws.
Information and Environmental Security
We expect our suppliers to act to protect confidential and proprietary information, safeguard personal data, and fully comply with legal and international standards related to environmental protection, and to take care in fulfilling their responsibilities in these matters.
Internal Promotion and Audit
We expect our suppliers to encourage compliance with Pomega’s Ethical Guidelines within their own supply chains and to establish necessary internal audit and control mechanisms in this regard.
Use of Information, Data Security, and Data Privacy
As a company, we are strictly committed to the following fundamental principles regarding data security and integrity:
Accounting Records and Bookkeeping:
Accounting records and books at our company must be kept complete, accurate, and in a timely manner, in accordance with relevant accounting rules and standards, regardless of whether they are included in an official filing or provided to government agencies.
Intellectual Property Rights:
To protect our products and the value of our brand, we effectively defend our intellectual property rights against unauthorized access. We respect the intellectual property of others and take necessary measures to avoid infringing third-party rights.
Environmental Protection and Sustainability
As a company, we are aware of our responsibility to contribute to environmental protection and sustainability efforts. In this context, we expect our personnel, business partners, and suppliers to fulfill their duties in line with this responsibility.
Efficient Resource Use:
We are committed to efficient resource use in our business processes and continuously strive to reduce our environmental impact.
Compliance with Environmental Standards:
We expect our personnel, suppliers, and stakeholders to fully comply with relevant environmental standards and legal requirements.
Recycling and Waste Management:
We are committed to encouraging recycling and ensuring that waste is managed in an environmentally friendly manner. Our personnel and suppliers are expected to act in accordance with this commitment.
We sincerely believe that by acting in line with these principles, we can achieve sustainable success and make a positive contribution to the environment.