​1. Objective

This policy aims to clearly determine Istanbul Aydın University's approach to bribery and corruption. As Istanbul Aydın University, what we aim with this policy is following anti-bribery and anti-corruption laws and regulations, the legal regulations and ethical principles in the countries where we operate and also determining the responsibilities and rules in this regard.

2. Content

Our anti-bribery and anti-corruption policy includes the following persons;

1. Istanbul Aydın University members of the Board of Trustees and Board of Directors,
2. The managers and employees of Istanbul Aydın University,
3. Our subsidiaries, shareholders and their employees,
4. The companies we buy external service; it includes persons and institutions (business partners) serving on behalf of Istanbul Aydın University companies including consultants, lawyers, external auditors.

This policy is an inseparable part of the following policies;

1. Publicly announced Corporate Governance Policy and Ethical Principles and Rules of Conduct,
2. Disciplinary Regulations.

3. Descriptions

Corruption is directly or indirectly abuse of authorization by favor of the owned position in order to obtain any kind of profit.

Bribery is capitalizing for yourself, the intermediary or someone else to make him/her act contrary to the requirements of his/her job by means of deriving, proposing, promising, requesting, accepting profit or acting as an intermediary for profit directly or through intermediaries in order to do business, have someone do or don't something about business and speeding or slowing a process regarding someone's job.

Bribery and corruption can take place in many different ways, some of these are:

1. Cash payment,
2. Political or other donations,
3. Commissions,
4. Social rights,
5. Gifts, hosting,
6. The other interests.

4. Duties and Responsibilities

The implementation and updating of Anti-Bribery and Anti-Corruption Policy is under the author, duty and responsibility of the Board of Directors. Within this framework; it is necessary

1. For the Corporate Governance Committee to make recommendations to the Board of Directors on the purpose of establishing an ethical, trustworthy, lawful and controlled working environment,
2. For the senior management to assess the risks and provide the required control mechanisms in accordance with the principles set by the Board of Directors.
3. For the Department of Supervision Presidency, Department of Financial Affairs Law Accounting and Investor Relations Presidency and Ethical Committee to follow that Istanbul Aydın University's activities within their own area of responsibility are executed in accordance with the safety and legal regulations,
4. To determine and execute the notification, investigating and sanction mechanisms in case of violation of policies, rules and regulations.

Also, all the employees of Istanbul Aydın University are responsible for

1. Following the policies set by the Board of Directors,
2. Effectively managing the risks associated with their areas of activity,
3. Working in accordance with the relevant legal regulations and practices of Istanbul Aydın University,
4. Reporting to the Ethics Committee in the event of any behavior, activity or practice that are against the policy.

5. Codes of Practice

5.1. Bribery and Corruption

Istanbul Aydın University is against all kinds of bribery and corruption. Accepting or giving bribe is absolutely unacceptable in any event.

The business relations with the 3. parties wishing to do business with Istanbul Aydın University through bribery or corruption should not be maintained.

5.2. Gift

A gift is something does not require a financial payment and generally given to convey thanks or show professional courtesy by people who are clients or in business relationships. All gifts offered or given to third parties by Istanbul Aydın University should be offered openly, unconditionally and in good faith. The principles about the gifts appropriate to give and recording these gifts are written in the Policy on Receiving and Giving Gifts in Istanbul Aydın University Business Ethics Principles.  

Same principles are also valid for accepting gifts and no gifts are accepted except symbolic gifts that are not high in value as determined in this principles. Also, even if this gift is within this scope, it is necessary to ensure the acceptance of gifts is not frequent. The person who accepted the gift must notify it to HR and top management by his/her                      immediate supervisor.

5.3. Facilitation Payments

As Istanbul Aydın University, we do not allow facilitating payments to secure or accelerate a routine operation or a process (permission, getting license, tender processing, etc.) with public institutions.

5.4. Donations

Some legal restrictions have been introduced to donations and aids by Capital Markets Board and the relevant legislation that Istanbul Aydın University is subject to. According to this; the prepared Donation Policy was published on website and gained approval of the General Assembly.

The support of Istanbul Aydın University's employees to charities by using their own savings they have collected independently from their jobs is not a part of Istanbul Aydın University's Donation Policy. However, the principles of Istanbul Aydın University Business Ethics are valid at this point.

5.5. Recording

The subjects about accounting system that our companies within Istanbul Aydın University have to obey have been regulated within the scope of the related legislations and regulations.

1. We pay attention to that all kinds of accounts, documents and receipts related to relations with the third parties (customers, suppliers, the other service providers) are recorded and maintained in a complete, transparent, precise, fair and reliable manner.
2. We pay attention to establishment of internal control systems to prevent unregistered transactions.
3. We pay attention to that no changes are made on accounting or similar commercial registrations about any transaction and the facts are not distorted.

5.6. Representation and Entertainment

The following items can be considered among the activities of representation and entertainment:

1. Social events,
   
2. Accommodation
   
3. Dinner invitation.
   

Istanbul Aydın University may carry out representation and entertainment activities to improve trade relations and establish commercial communication networks. We make an effort to make these activities within reason. We pay attention to that representation and entertainment do not organized before a main and important decision-making process.

6.7. Education and Communication

Our Anti-Bribery and Anti-Corruption Policy was announced to Istanbul Aydın University employees and it is continuously and easily accessible via the institution's website. Trainings are organized to raise awareness of our employees against bribery and corruption.