BUSINESS ETHICS POLICY

Being True and Honest
While carrying out our activities, we adopt the values of honesty, integrity, transparency and general business ethics, and avoid behaviors that will damage mutual trust. We expect the parties with whom we have a business relationship to have the same values and to behave in accordance with these values.

1.1. Fair Competition
We are committed to complying with fair competition rules and supporting laws and regulations in our current activities. We also oblige our employees to comply with laws and regulations. In case of failure to comply with the policies, strategies and instructions determined and implemented on competition and trade issues, legal action may be taken against the related employees. Every employee is required to inform his/her company managers or the company's Legal Advisors when he/she has a practical problem or question regarding these issues.

1.2. Combating Bribery and Corruption
OBA Makarnac?l?k does not accept any special treatment and/or bribery or illegal benefit from any person directly or through intermediaries.

No personal benefits are solicited, accepted, recommended or provided when it comes to our work effectiveness. In such cases, employees should immediately inform their company partners or managers.

1.3. Gift Relationship and Representation Hospitality
We have a relationship with various persons, institutions and organizations that we are in contact with for business reasons, with the approval of our manager and within the courtesy rules.

Except for gifts which are of no doubt of symbolic value and whose approximate value does not exceed 100 TL, they should not accept gifts, entertainment or benefits that may affect the impartiality, decisions and behaviors of our employees in a commercial relationship.

If there is a need to give gifts with a material value above a reasonable level, it is possible with the approval of the Finance Manager up to 250 TL and the General Manager over 250 TL.

It is possible for our employees, suppliers, business partners to participate in the events organized by the Company, with the approval of the relevant Manager, in such a way that travel expenses, event expenses and similar payments are covered by the Company.

Representation and entertainment expenses should only be used in the areas they are relevant. Representation and entertainment expenditures must be documented with an invoice and subject to Company approval processes. It is not appropriate to obtain an invoice from another place for expenses that cannot be invoiced.

1.4. Conflict of Interest Situations
Our employees work in the best way to serve the interests of OBA Pasta, and do not benefit themselves, their families, relatives, relatives, suppliers, customers, other employees, partners or competitors with whom they have business relations by taking advantage of their current duties.

Our employees arrange their relations in a way that does not damage the reputation of OBA Pasta.

It is not allowed under any circumstances to conflict between the interests of the company and personal interests, to obtain inappropriate personal benefits due to the position of the employees, to provide benefits to their relatives or third parties.

Creating a Safe Working Environment
In addition to creating a safe and secure workplace for all our employees, we take utmost care to ensure the protection of our company and employee information.

2.1. Occupational Health and Safety
Occupational health and safety is among the priorities of our company. We draw attention to the fact that implementing company policies and regulations regarding health and safety at the workplace is an important responsibility that all our employees should pay attention to.

The occupational health and safety policy applies to all our employees, suppliers and business partners. This policy is effectively managed and followed to continuously improve occupational health and safety.

2.2. Confidential Information and Information Security
The headings within the scope of confidential information are as follows:

Commercial information, technical data, financial data, production data, customer information, employee information, product information, hardware and application information, technical formula information, system and program information, purchasing information, engineering information, regulations, business plans and not limited to these. All information, the disclosure of which will harm the Company.

Our employees are responsible for protecting all confidential information they access while doing their job and using it only for the benefit of the Company. They do not share it with third parties for any reason or for personal interests.

Every employee who leaves OBA Makarna is obliged to return the information, documents and all records of this company to the company.

Fulfilling Our Responsibilities Towards Our Stakeholders
In addition to our legal responsibilities; We take care to fulfill our responsibilities towards our customers, business partners and suppliers, our competitors and the environment.

3.1. Compliance with Laws and Regulations

All OBA Pasta employees are expected to act in accordance with laws, regulations, professional standards, applicable legislation and Code of Conduct while carrying out their current activities.

We attach importance to accurate, consistent and timely communication with legal regulatory institutions and organizations.

3.2. Our Relationships with Our Shareholders
As OBA Makarnac?l?k employees, we aim to manage resources and assets in the most efficient way, with an understanding of financial discipline and accountability, and share complete, understandable and accurate information with our shareholders.

3.3. Our Relations with Our Customers
We work by accepting the satisfaction of our customers as our priority. We avoid unfair or misleading practices in our relations with our customers and consumers, and we take care to consider our customers' requests and complaints in our decisions.

We listen to all kinds of problems arising from our companies or channels in the process of our products until they reach our consumers, and we work to solve them quickly.

3.4. Our Relationships with Our Business Partners and Suppliers
We always establish long-term, honest and fair business relationships with our suppliers and business partners. We expect our suppliers and business partners to act in accordance with the Code of Conduct.

Our suppliers and business partners; to continue their activities in accordance with laws and regulations, to observe the rights of their employees and to protect the environment, etc. We oblige them to comply with the standards.


3.5. Our Responsibilities Towards Society and Environment
As OBA Makarnac?l?k, we take care to be an institution that respects the environment, complies with environmental standards and rules, and works to minimize the negative effects of our activities on the environment.

OBA Makarnac?l?k will always cooperate in order to protect the environment, to better understand environmental problems and to disseminate good examples. Our goal is to ensure the continuous improvement of our environmental performance.

As a food company, we care about the health of our society and our consumers. We carry out our activities in compliance with the legal regulations on food safety.

Being Accountable
We adopt a responsible and accountable attitude towards the relevant parties in all our activities. We each hold ourselves personally responsible for our actions, commitments and results.

4.1. Our Responsibilities Towards Our Employees
We offer our employees a suitable working environment where they feel safe, peaceful and valued, and where communication is based on the principle of mutual respect.

We respect human rights, individual differences and personal characteristics of our employees.

During the work, we treat everyone equally, regardless of religion, language, race, gender, age, ethnicity, political orientation. We aim to employ the right person for the right job by providing equal opportunities for all candidates in our recruitment processes.

We implement all Human Resources processes by considering equal opportunity. All the conditions determined by the law numbered 4857 are fully applied to all our personnel, without any discrimination. (working conditions, leaves, weekends, working hours, etc.)

We never allow the use of child labor. We do not work with any supplier or subcontractor that uses children as a workforce. In case of accidental employment, articles of the Law No. 4857 on child labor are applied and child workers are not employed in heavy and dangerous jobs. All rights are met.

Birth and Maternity rights; Our employees who are pregnant are not given heavy work and necessary amenities are provided. Paid leave is given for 8 weeks before birth and 8 weeks after birth. However, if the employee requests it, it is employed until 3 weeks before the delivery and the remaining 5 weeks are added to the postpartum period.

4.2. Economic Use and Protection of Company Assets and Resources
As OBA Makarnac?l?k employees, we always protect the Company's financial records, trade secrets, technical information, raw materials, intellectual property rights, machinery, equipment, fixtures and vehicles; We prevent misuse, damage and waste of resources. Moreover; We avoid personal use of communication and transportation opportunities provided within the framework of the authorities and responsibilities required by our positions.

4.3. Accuracy of Records and Financial Reports
The accuracy of financial reporting is also very important for the reliability of financial statements for the proper management of the company. We record and report all kinds of information regarding our activities accurately, consistently and completely. It is essential that all our records are kept in accordance with the legislation. Documents pertaining to commercial and financial transactions must reflect the real situation.

No payments can be made or approved to be used for purposes other than their intended purpose.

Accurate, complete and timely information is provided to financial institutions and official authorities regarding all our activities in accordance with the legislation.

4.4.Political Activities and Social Media Use
The decision of our employees to participate in any political or social activity is purely personal. We ask them not to carry out such activities during working hours and not to use Company resources for these activities.

We avoid expressions that may give the impression that third parties are sharing on behalf of OBA Makarna in our posts on social networking sites, blogs, dictionaries, and forums.

We convey our concerns about the news we read or see about OBA Pasta to our Administrative Managers.