Purpose and Scope
Basic public disclosure policy of Emay İnşaat Taahhüt San. Tic. A.Ş. (Emay İnşaat) is to preserve always an active and clear communication sharing equally EMAY İNŞAAT’S past performance and future expectations with shareholders, investors, capital market experts (together with capital market participants) in a complete, fair, true and clear way and on time within the framework of basic accounting principles and Capital Market Legislation provisions.
Information Policy involves all related companies and employers and advisors within EMAY İNŞAAT and regulates the written and oral communication of EMAY İNŞAAT with the capital market participants.
It is the Board of Directors that is responsible for following, revising and developing the Information Policy. In formation of the policies, authorized persons of Internal System Coordination perform those responsibilities in close cooperation with the Corporate Management Committee and the Board of Directors.
Corporate Management Committee gives information to the Board of Directors on issues regarding “Information Policy” and makes suggestions.
“Internal System Coordination” is assigned in order to protect and follow any kind of issue regarding the public disclosure.
Principles Used in Determining the People Having Administrative Responsibility
Emay İnşaat defines the “internal knowledge as the knowledge that can affect the value and price of the capital market means and the investment decisions of the investors and that has not been disclosed to the public yet. Internal System Coordination informs the ones having access to the internal knowledge to the Central Securities Depository and applies the required updates when there is a change on those persons. Those having access to the internal knowledge are accepted to be the ones having administrative responsibility pursuant to the Special Cases Declaration and to our Company. The list of the ones having access to the internal knowledge compromises the members of the Board of the Directors of the Company, the ones accessing regularly directly or indirectly to the internal knowledge of Emay İnşaat and having authority to make decisions affecting the future development and the commercial targets of Emay İnşaat, and the ones who are closely related with those people, and the other people who act on behalf of and for the partnership and access to internal knowledge directly or indirectly regularly or accidentally.
Emay İnşaat evaluates the members of the board of directors of its affiliates, which compose 10% of the total assets in annual financial status table or more, among the ones having administrative responsibility.
Methods and Means of Public Disclosure
Basic methods and means of public disclosure used by EMAY İNŞAAT are stated below:
i) Special case statements transferred to BİST through Public Disclosure Platform (KAP notifications are made simultaneously on electronic media),
ii) When required, financial table and footnotes, independent audit report, declarations, activity reports transferred to BİST through KAP
iii) Information and descriptions, notifications and announcements made through Turkish Trade Registry Gazette and daily newspapers (explanation note, circular note, distribution of profit, general assembly invitation etc.),
iv) Press statements made through printed and visual media,
v)Statements made to data distribution organizations such as Reuters, Foreks vb.,
vi) Corporate web site (www.emayinsaat.com.tr),
Special Case Statements and Authorized Persons
Special case statements are prepared under supervision of Emay İnşaat Internal System Coordination and transferred to BİST within the determined periods. The names of the persons who are authorized to make special case statement and the changes are notified to BİST. Special Case Statements are transferred to BİST on electronic media within the scope of Public Disclosure Platform (KAP-PDP).
Emay İnşaat makes active regulations to prevent those excluding the ones taking place in the list of people having access to internal knowledge from reaching to this knowledge in order to enable the privacy of special cases.
If any Emay İnşaat employer is determined to disclose any important and private (internal) information that has never been disclosed to the public before, this case is immediately notified to Emay İnşaat Internal Systems Coordination. On this case, Emay İnşaat Internal Systems Coordination enables the suitable special case statement to be prepared and to be transferred to BİST pursuant to the provisions of Capital Market Regulation.
Disclosure of Financial Tables to the Public and Authorized Persons
Financial tables and footnotes of Emay İnşaat are prepared in accordance with the International Financial Reporting Standards (IFRS) and when required, sent to KAP and disclosed to the public.
You can reach the past financial tables and footnotes on web link of Emay İnşaat Investor Relations.
Commercial relations between our Company and real and legal persons that our Company has contacted directly or indirectly with purpose of management and audit are placed in the financial table footnotes.
Disclosure of Activity Report to the Public and the Authorized Persons
Activity report wins the approval of the Board of Directors and is disclosed to the public on Company’s web site (www.emayinsaat.com.tr).
Activity reports are transferred electronically as a KAP statement through regulations by SPK and BİST when required following the approval of the Board of Directors.
Other Statements and Authorized Persons
Other statements excluding the ones stated above (explanation note, circular note etc.) are signed and disclosed to the public by the authorized persons to be determined by the Company’s circular of signature.
Persons Authorized to Make Statement to the Public
Excluding the statements defined above, printed and oral information demands that are transferred by the capital market participants are performed in writing and / or orally within the authorization borders determined by the General Director and Internal Systems Coordination.
Press statements made to written and visual media and to data distribution organizations such as Reuters, Foreks etc. can only be made by the Chairman of the Board of Directors and the General Director.
News and Rumours on Media Organs or on Internet Websites
Emay İnşaat does not principally present an opinion on market rumours and speculations. News and rumours on written, visual, audial media organs and/or on the internet media are followed by the Internal Systems Coordination teams as following the market currently. In case of presence of any news and rumours without any source, those who are authorized to represent the Company in media organs that principally internationally broadcast regarding the ones of those news and rumours that can affect the investment decisions of the investors and the value of the capital market means. Otherwise, not an opinion is presented on speculations taking place on the market and/or internet.
Emay İnşaat Web Site (www.emayinsaat.com.tr)
In public disclosure and in enabling transparency, www.emayinsaat.com.tr website is used effectively.
All statement made by Emay İnşaat to the public can be accessed on the website. Website is accordingly configured and sectioned. Any precautions are taken regarding the safety of the website.
This information policy entered into force through the resolution by the Board of Directors with a date and number.
Human Resources Policy
Emay İnşaat, the most important capital of which is human resource, aims to enlarge its family through strategic thinking, fast, daring and responsible co-workers.
In this regard, Emay İnşaat acts for its workers in order to:
Create appropriate environment for personal and occupational regard,
Enable convenient workplace climate for maintaining lifelong learning,
Install and operate the systems to correctly evaluate the individual differences,
Measure and evaluate the performance objectively,
Award the high performance; support the performance that is below the expectation to develop.
Working at Emay İnşaat means to positively contribute to the lives of many humans in Turkey and around.
· Wage Policy
Regarding the market conditions and intercorporate balances of Emay İnşaat Taahhüt San. Tic. A.Ş. (the Company), the policy of “equal pay for equal work” principle is embraced.
In determining and updating the wage classifications, “market tendencies” and “performance evaluations” are based on.
Annual wage increases are reflected to the wages in determined rates and in periods that the employee sees necessary through the approval of the Chairman of the Board of Directors.
All employees can be enabled some “side benefit packages” through their titles as well as the wages.
Senior staff and other expert personnel in management can receive “premium” or “award” based on their performances.
Information meetings are held for the employees on issues such as financial status of the Company, wage, career, training, health and opinions are exchanged.
Job definitions and distributions of the Company workers and performance and awarding criteria are notified to the workers. Efficiency is regarded in determining the wages and other benefits given to the workers.
The Board of Directors
In accordance with the provisions of the article 394 of Turkish Trade Law, the members of the Board of Directors are paid from the daily allowance, wage, indemnity, premium and annual profit provided that the amount is determined by the articles of association or by the resolution of the general assembly. Those who are assigned in execution from the Board of Directors can be presented monthly wages and related side benefits due to their duties in the company, as well as the “daily allowance” which they receive due to being the member of the Board of Directors.
· Codes of Conduct
Codes of Conducts of Emay İnşaat are in harmony with the values and principles. It compromises the basic guidelines of the company. The Board of Directors, directors and employees comply with those values in their any kind of relations and try to keep the prestige of the Company and of the shareholders at maximum level. At the same time, those rules were prepared in order for the customers, suppliers and the ones out of the company to comply with those principles.
1. HONESTY AND RELIABILITY
Truth and honesty are our prior values in our all work processes. It is our target to be reliable and honest to our employees, partners, shareholders, suppliers, competitors, to the environment, public and humanity.
2. PRIVACY AND PRESERVATION OF THE TRADE SECRETS
Private and special information and documents, trade secrets, non-disclosed financial and other information, information on personal rights of the employees and the “confidentiality agreements” made with third parties are evaluated within the scope of preservation of privacy and trade secrets, and preservation of those information is utmost cared.
Private information and documents that are possessed due to duty while leaving the Company and the works such as projects, regulations cannot be taken out.
3. CONFLICT OF INTEREST
Emay İnşaat employees stay away from the relations and cases to cover the potential or real conflict of interest. Personal benefits cannot be derived from persons or organizations that have been in personal, family or occupational contact through relatives benefitting from existing duties.
In case of any potential conflict of interest, legal and codes of conducts are applied.
4. BUSINESS ETHICS AND BEHAVIOURS
All employees perform their duties in an equitable, transparent, accountable and responsible way. Mutual respect, reliability and cooperation understanding constitute the basis in relations among the employees.
All employees perform responsibilities in order to preserve and develop the prestige of the company. In this regard, all employees care their personal status and behaviours to be within the framework of laws and general codes of conducts.
Employees cannot use the information that are within private and/or trade secret or that are not disclosed to the public about the Company on their behalf and on behalf of others.
Employees do not take advantage of company works directly or indirectly and do not accept debts from the persons or companies that the company is in occupational relation.
5. OUR RESPONSIBILITIES
Emay İnşaat cares performing all its responsibilities as well as the legal ones in best way.
5.1 Our Legal Responsibilities
Emay İnşaat maintains all its activities in the country and in abroad pursuant to the national and international laws and legislations. It presents the true, complete and understandable information to legal regulatory authorities on time. While maintaining those activities, it treats equally and objectively to any kind of state institutions and organizations, administrative formation, non-governmental organizations and political parties without having any interest expectation.
Any kind of tables and reports that our Company prepared are in accordance with the national and international accounting principles.
5.2 Our Responsibilities Against our Customers
Emay İnşaat works with a customer oriented understanding of replying the needs and demands of the customers as soon as possible and in the most correct way.
Producing rapid and permanent solutions to the problems of our customers, it tries to maximize the reliance that our customers place for our company.
5.3 Our Responsibilities Against our Employees
Emay İnşaat treats equally to all its employees acting with the motto “our most valuable entity is our employee” do not discriminate against religion, language, race, sex and ethnic origin. It determines and applies the training programs aiming at gaining the information, skills, attitudes and behaviours required for keeping up with any kind of development, raising duty satisfaction, enabling to be more successful in work environment. It cares to provide the employees a reliable and the most convenient working environment.
5.4 Our Responsibilities Against our Shareholders
The company applies the expansion-based company strategies avoiding from unmanageable risks in order to increase the share values of the company. It acts within financial discipline and accountable framework and manages the resources and assets and working times of the Company with the conscious of efficiency principles and saving.
5.5 Our Responsibilities Against our Suppliers / Customers
It takes utmost care to perform the responsibilities against the suppliers/customers on time. It preserves the private information of the persons and organizations and work partners being in occupational relations.
5.6 Our Responsibilities Against the Sector and Competitors
It competes with the competitors and sector companies effectively and only within legal and ethical areas, and avoids from actions to create unfair competition. It struggles effectively against the unfair competition with legal ways.
5.7 Our Responsibilities Against Environment, Public and Humanity
Our company uses production strategies that are in harmony the environment. It complies with the universal standards and legal regulations. It does not sees using environment-friendly production technologies as a cos element.
Emay İnşaat supports its employees to take place actively in any kind of service that are in favour of the public.
5.8 Our Corporate Social Responsibilities
Emay İnşaat takes utmost care to its responsibilities against the society. It takes place within and supports training, sport, health and cultural activities.
Occupational Safety Policy
Occupational Health and Safety Policy that we, as Emay İnşaat Taahhüt San. Tic. A.Ş. (Emay İnşaat), adopt is based on the respect against the human and the nature it lives in. Occupational Health and Safety is the first priority in each area that Emay İnşaat is active in, and the company states this understanding through the motto “save your health, save your work”. Everybody is liable for doing the necessary within its own authorization borders in order to provide a safe and healthy working area. One of the most important targets of us is to preserve our all employees and the nature we live in against the possible risks of our profession.
In this regard; we hereby undertake
Ø taking measures, having tools and Personal Preservation Equipment, enabling it to be used when necessary in accordance with the Occupational Health and Safety legislations and other requirements regarding the Occupational Health and Safety in order to provide health and safety of subcontractor, visitors, company personnel that works out of the workplace,
Ø detecting and removing work accidents and occupational illness in workplace and outbuildings, insecure cases and movements, possible accident risks through making an effective risk evaluation,
Ø detecting the risks to cause work accident and occupational illness in workplace; enabling health, safety and social peace of the employees, visitors, subcontractors at each level and reducing any kind of material and moral losses to be incurred for them and their families,
Ø training our employees under occupational health and safety and enabling them to reach a good occupational health and safety conscious,
Ø enabling the substructures and visitors in the workplace to comply with the rules of occupational health and safety put by Emay İnşaat,
Ø making Emay İnşaat a model company in terms of occupational health and safety applications before the affiliates, industrial chambers and foundations,
Ø predicting the possible cases regarding the industrial world development, continuously developing and revising,
Ø enabling the sustainability of our Occupational Health and Safety Management System that is established and operated in this regard as an Occupational Health and Safety policy.