Gifts and Hospitality Policy
1. PURPOSE AND SCOPE
It is a part of the ordinary course of life that Bank employees maintain social relations with customers, business partners and suppliers. However, it is essential to ensure that these relationships do not lead to conflicts of interest. This Policy describes the legitimate framework of gifts accepted or given to strengthen business relations, of attendance to representation/hospitality events held by other organizations and of representation/hospitality events to be organized by our Bank, as well as the procedures and principles regarding representation expenditures and corporate expenditures to be covered by our Bank. The Policy covers all employees of the Bank and its affiliates, including the Board of Directors.
2. DEFINITIONS
Gift: In a general sense, these are products that are given or accepted between people in a business relationship for commercial courtesy or appreciation purposes and do not require a material or immaterial return.
Representation Expenditures: This refers to the expenditures to be made within the framework specified in Article 4 of this Policy to maintain the commercial activities of the Bank, establish and improve relations with customers, key business partners and other external stakeholders with whom the Bank gets in contact while performing its activities, support sales and profitability, and ensure and protect the reputation of the Bank before third parties.
Corporate Expenditures: This refers to the expenditures that can be made within the framework specified in Article 4.12 of this Policy.
Conflict of Interest: This refers to any benefit or personal interest, whether or not measurable in money, provided to employees, to their relatives and friends or to persons or organizations with whom they have a relationship, during the employees' decision-making or performance of their duties. This must be immediately notified to the senior manager, and the senior manager must immediately take measures to eliminate it.
İşbank Group: This covers Türkiye İş Bankası A.Ş. and its direct and indirect affiliates.
3. CODE OF PRACTICE ON ACCEPTING GIFTS
3.1. Even where lawful, employees cannot receive gifts in violation of the Anti-Bribery and Anti-Corruption Policy.
3.2. Bank employees cannot accept gifts from customers or business partners or suppliers from whom the Bank purchases goods or services, and they cannot offer to solicit gifts in any manner whatsoever.
3.3. In exceptional cases where the will of the employees not to accept gifts is absolutely declined by the other party and thus there is a risk of damage to the business relationship, gifts that fit business practices and are not of a high monetary value may be accepted as part of goodwill and courtesy rules.
3.4. No gifts can be accepted from İşbank Group companies under any circumstances, or no offers can be made to solicit gifts.
3.5. Cash gifts, precious metals such as gold and diamonds, or gifts that are easily convertible into cash cannot be accepted under any circumstances.
3.6. Non-cash offers such as free holidays, discount vouchers, gift vouchers and unusually high discounts are also considered as gifts and benefits and thus cannot be accepted.
3.7. Periodical promotions such as diaries, pens and calendars that have a nominal value rather than a monetary value can be accepted, provided that they are not personally solicited by employees.
3.8. Gifts of low material value (Article 3.3) shall be recorded in the relevant Unit/Department by indicating information such as the name of the employee, date of acceptance, type, amount, and the offering party. However, there is no need to keep records for products covered by Article 3.7 of this Policy.
3.9. It is ensured that the accepted gifts do not create the impression that the party offering the gift has received preferential treatment or any privileges, or that such a case does not besmirch the Bank's reputation.
3.10. The above-mentioned provisions also apply to gifts given to family members within the framework of relationships arising from the duties of employees.
3.11. Bank employees can participate in entertainment and dining events for representation and hospitality purposes, provided that they are acceptable, reasonable and modest according to the business world.
3.12. Provided that they do not propose it themselves and it is only for celebration purposes on special occasions, managers can accept gifts that are valued within ordinary limits and do not represent a high monetary value from their direct or indirect subordinate employees, or employees can accept gifts from their line managers.
3.13. For behaviors found to be contrary to the rules of this Policy, the required disciplinary action, up to and including termination of the employment contract, shall be taken in accordance with the Human Resources Regulation and the relevant provisions and procedures of the Collective Labor Agreement (if any). The judicial authorities shall be informed if applicable legally. The provisions of this Policy shall also apply for violations that fall under the Bank's Anti-Bribery and Anti-Corruption Policy.
4. CODE OF PRACTICE ON REPRESENTATION EXPENDITURES AND CORPORATE EXPENDITURES
4.1. The Bank's Budget for Representation Expenditures is annually determined by the Board of Directors. If it is required to exceed the Representation Expenditure Budget, the Board of Directors is authorized to establish an additional budget.
4.2. The CEO shall determine the Authorization Limits for Representation Expenditures on a title/position basis. Any unused limits in a given year cannot be transferred to the following year.
4.3. Persons authorized to make Representation Expenditures are managers and their peers with similar equivalent titles as well as directors bearing higher titles. However, the authority to make Representation Expenditures may be delegated on a transaction basis in necessarily mandatory cases and on the condition that this is exceptional, provided that the responsibility belongs to the manager who delegates the authority. In transactions involving multiple persons having the authority to make Representation Expenditures, the Representation Expenditures Authorization Limit of the responsible person with the highest title shall be taken into consideration.
4.4. If it is required to exceed the Authorization Limit for Representation Expenditures on a title basis, the approval of the next higher title shall be required.
4.5. In order for representation expenditures to be an expense deductible from the tax base, they must be made for the purpose of obtaining and maintaining commercial earnings, and must be documented, excluding specified in the legislation.
4.6. It is essential to use the Representation Expenditures Authorization Limits by prioritizing the development of relationships with existing and highly efficient/potential customers. The representation expenditures to be made shall be appreciated by our managers in proportion to the actual or expected efficiency.
4.7. Representation Expenditures Authorization Limits shall be used if the Bank employees organize entertainment and dining events for representation and hospitality purposes, provided that they are acceptable, reasonable and modest according to the business world. Representation and hospitality activities shall be carried out reasonably and modestly so as not to increase the Bank's risks of conflict of interest, bribery and corruption.
4.8. For representation and hospitality activities, the province where the Bank's headquarters is located shall be preferred.
4.9. Representation or hospitality shall not apply to İşbank Group except for meetings/events to be held for training purposes and/or as a matter of course.
4.10. For representation and hospitality activities other than those with İşbank Group, a suitable location outside the province where the head office is located but within the country can be preferred, if this is commercially justified. Invitations shall be solely extended to the relevant persons and not to their families. However, provided that the matter is submitted to the Board of Directors in advance, exceptional practices may take place by taking into account the general tendencies in the relevant sector.
4.11. If the Bank or any party acting on behalf of the Bank hosts an event, the travel and accommodation expenses of the guests shall be borne by the guests themselves. Travel and accommodation expenses incurred by the Bank's employees for the event and for business purposes shall be borne by the Bank. In both cases, it is possible for the inviting party to bear the full travel and accommodation expenses, provided that there are reasonable grounds to do so.
4.12. In cases such as when a Bank employee gets married, gives birth or their partner gives birth, is severely ill or undergoes surgery or their partner or child is severely ill or undergoes surgery, dies or their partner, child, mother or father dies, and when necessary, it is possible to send flowers as part of Corporate Expenditures on behalf of the Bank or to make donations to reputable institutions including but not limited to the Child Protection Agency and TEMA Foundation.
Corporate Expenditures cannot be made in cases of internal promotion, appointment, relocation and similar situations.
The upper limit for the aforementioned flower/donation costs and the personnel having the authority to make expenditures shall be determined by the Head Office.
In case there is a planned celebration/event for the employees, the Corporate Expenditure item shall be included as a separate item in the budget, or a preliminary approval shall be obtained from the Board of Directors if it is not included in the budget.
Multiple Corporate Expenditures cannot be made for the same subject.
Corporate Expenditures that should be recognized as non-deductible expenses shall not be taken into account as expenses in the calculation of tax base.
Donations and similar support made as part of corporate expenditures shall be disbursed in line with the principles of transparency and accountability and in a way that does not lead to a risk of bribery and corruption. Such donations and support cannot be used for the purpose of establishing, maintaining or influencing any business relationship.
4.13. Gifts cannot be sent to the Bank employees and/or their family members and to the employees of İşbank Group companies and/or their family members on special occasions such as holidays and New Year's Eve. These persons may be given gifts and promotions such as diaries, pens and calendars which have a nominal value rather than a monetary value. Such practices shall be delivered pursuant to the provisions of Article 3 (Code of Practice on Accepting Gifts) of this Policy.
4.14. On the reverse side of the payment document for Representation Expenditures and Corporate Expenditures, the reason for the expenditure must be clearly written, including the name of the customer or employee involved in the transaction, and the document must be signed by the person authorized to make the expenditure. The employees who carry out payment transactions shall be obliged to check the presence of the signatures of the persons with the aforementioned titles or, in case of proxy, the signatures of their proxies on the relevant Representation Expenditure and Corporate Expenditure document.
4.15. Representation Expenditures and Corporate Expenditures shall be periodically reported to the Board of Directors as part of budget realizations.
5. AUDIT
The auditing of compliance with the provisions of this Policy shall be carried out annually as part of internal audit.
6. ENTRY INTO FORCE
This Policy and any amendments thereto shall enter into force on the date they are approved by the Board of Directors.
