Public Relations Policy

Article 1: Scope

The aim of this policy to define the framework of the Public Relations activities of Adm Elektrik Dağıtım A.Ş. (“Company”) in a way to create maximum value for all stakeholders and the society in the light of  applicable regulations and relevant provisions of the Corporate Management Principles, Sustainability Policy, Code of Ethics and Principles of Working Anti Bribery and Anti-Corruption Policy and the Policy on Donations and Benefits  and the business conduct of the Company the United Nations Global Compact, of which the Company is a participant.

 

The Company aims to contribute to the continuous improvement of the policy making, decision-making and legislative amendment processes of the Public Institutions with which the company affiliates with through its investments and to obtain permits/ approvals, and to this end, to carry out a professional Public Relations in accordance with the principles of transparency, responsibility and accountability and at high ethical standards.

 

Article 2: Definitions

Public” refers to all state and government bodies, including local/regional/national organization and legislative/executive/judicial organs.

 

Public Institution” refers to all official institutions established by a law or by an administrative act based on the explicit authority vested by the law to be responsible for the administration and functioning of the state of the Republic of Turkey.

 

Public Official” refers to any official who participates in the execution of the activities of public institutions upon appointment by principal / proxy made within the framework of the relevant legislation.

 

Public Relations” refers to the management of the relations with the stakeholders in the investment locations of the company, close follow up in order to ensure that all permits and approval processes of the Company before the  central and local public institutions are concluded as soon as possible and to carry out lobbying activities for the development of the company’s investment and the sector with the changes planned to be made by public institutions in the primary / secondary legislation by foreseeing the regulatory risks and to represent the company in the sector in a way that means to ensure effective representation in the sectoral organizations of which the Company is a member and to influence the public policy making processes through these organizations,

 

“Public Relations Group Directorate” refers to the department established to carry out the Public Relations activities of all companies under Aydem including the company.

 

Article 3: Scope

 

This policy applies to

  1. Members of the Board of Directors,
  2. Company Executives,
  3. Company Employees,
  4. Managers and employees of Business Partners that carry out official processes on behalf of the Company before the Public Institutions due to the Company's purchases of goods and services,
  5. Aydem’s Public Relations Group Directorate.

 

Article 4: Roles and Responsibilities

The Members of the Board provides necessary environment in order for the Company to conduct its relations with the Public Institutions and local stakeholders in accordance with the Basic Implementation Principles listed in Article 5 of this Policy, and for the Ethics Committee or the Disciplinary Committee to function properly in case of violation of this Policy.

  

Company managers decide which employees will carry out the Public Relations processes in coordination with the Public Relations Group Directorate regarding each work item to be carried out before the Public Institutions, and inform them about the important official processes that the Business Partners must carry out on behalf of the Company before the Public Institutions, and if necessary, coordinate the involvement of the Company employees and/ or the Public Relations Group Directorate. 

 

The employees of the Company are responsible for providing all information and documents for the relations of the Public Relations Group Directorate with Public Institutions during the relevant processes, where they are assigned by their managers, and for accompanying the Public Relations Group Directorate in official visits and meetings when deemed necessary.

 

Managers and employees of the Business Partners are obliged to inform the relevant Company manager before all official processes to be carried out on behalf of the Company before the Public Institutions and to provide maximum support to the operations to be carried out by the Company employees and/or the Public Relations Group Directorate in the further stages of the process.

 

The Public Relations Group Directorate is responsible for execution of the public relations before the Public Institutions, taking into account the possible effects of the Public Relations operations designated by the Company executives on the financial statements of the other group companies, and the possible regulatory risks; and if they are concluded negatively, for the formulation of a Public Relations Strategy and close cooperation with the relevant Company employees.

 

Article 5: Basic Implementation Principles

The basic principles to be taken into account with the utmost sensitivity in the implementation of the Company's Public Relations Policy are as follows:

 

  • All licenses and documents and new applications must be fully compliant with the provisions of all applicable primary/ secondary legislation provisions.
  • Making and implementing the necessary action plans before the Public Institutions in order to eliminate or minimize these risks by regularly reviewing the existing and potential regulatory risks.
  • Presenting constructive opinions and suggestions that may support the Company's investments and the development of the sector in the policy making, decision-making and legislative amendment processes of Public Institutions.
  • We commit to ensuring transparency and integrity of lobbying practices.
  •  Lobbying activities are evaluated at the Board level Corporate Governance Committee.
  • Complying by the principles of transparency, responsibility and accountability and ethics as well as basic moral and humanitarian values at all stages of Public Relations
  • Displaying sensitivity to the information security of the Company and its employees in meetings with Public Officials
  • Presenting all information to the Public Officials in a transparent and truthful manner, not providing incomplete or incorrect information under any circumstances, even if it is in the interest of the Company, and impartially conveying all the benefits and risks the suggestions may bring.
  • Establishing long-term professional relationships with Public Officials of all levels based on trust
  • Ensuring that the sectoral institutions of which the company is a member are mobilized to provide the most effective contribution to the Company's Public Relations activities and encouraging joint action in these sectoral institutions with other market actors in accordance with fair competition conditions
  • Avoiding the criticisms that damage the reputation of the Company before the Public Institutions and encouraging to share all opinions, suggestions and criticisms of the Public Officials against the Company with the relevant Company manager and taking the necessary steps to correct the Company's practices found to have negative effects on the Public Institution, and informing the Public Officials regularly about the improvements in this process.
  • Execution of Public Relations processes in full compliance with the principles defined in the Company's Anti-Bribery and Anti-Corruption Policy and the relevant national legislation
  • Not making positive or negative comments about other market actors in meetings with Public Officials.
  • Defining the limits of actions that are likely to be binding on the Company in consultation with the Public Relations Group Directorate for the meetings with Public Officials, such as transferring information/opinion on behalf of the Company or representing the Company, and especially making any commitments on behalf of the Company, should be determined by the Company managers and executives before the meeting.
  • Acting in full compliance with the Anti-Bribery and Anti-Corruption Policy, not offering bribes, corruption, facilitation payments, donations, aids or misguide any Public Officials
  • Not expressing opinions on current political developments and not disclosing personal political views in meetings with Public Officials
  • Presenting gifts and entertainment to Public Officials in accordance with the rules defined in the Company's Anti-Bribery and Anti-Corruption Policy

Article 6: Notices on Violations and Sanctions

In any cases of violation of all these principles and rules in relations with Public Institutions, including but not limited to the provisions of the applicable legislation, the rules in the procedures listed in Article 1 of this Policy, and the principles listed in Article 5 of this Policy, an application is made to the Ethics Committee or the Disciplinary Committee according to the severity of the subject. Following the application, ethical audit and, when necessary, disciplinary procedures are applied in accordance with the procedure specified in the Code of Ethics and Working Principles.