Gifts and Hospitality Policy

Corporate Expenditures: Corporate expenditures refers to the expenditures that can be incurred within the framework specified in Article 4.12 of this Policy. Conflict of Interest: Conflict of interest refers to the fact that employees have all kinds of benefits or personal interests that can be measured with money or not, provided to them, their relatives, friends or persons or organizations with whom they have a relation, while making a decision or performing their duty. Such situations should be reported to the senior manager immediately, and the senior manager should immediately take the measures to eliminate the same. İşbank Group: It covers T. İş Bankası A.Ş. and its direct and indirect affiliates.

3. CODE OF PRACTICE TO ACCEPT GİFTS 

3.1. Employees may not accept gifts in violation of our Anti-Bribery and Corruption Policy, even when accepting gifts is legal. 

3.2. The Bank's employees cannot accept gifts and cannot make any offers to ask for gifts from customers or business partners or suppliers from whom the Bank purchases goods or services. 3.3. In exceptional cases where the willingness of the employees not to accept gifts is not accepted by the other party and therefore, there is a risk of damage to the business relationship, gifts that are in accordance with business practices and are not of high material value (up to 500 TL) may be accepted. 

3.4. No gifts can be accepted or offered to ask for gifts from İşbank Group companies.

3.5. Cash gifts, precious metals such as gold, diamonds, or gifts that are easily cash-convertible are not acceptable.

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 are not acceptable.

3.7. Promotions that can be given periodically such as agenda, pen, calendar and have a nominal value rather than monetary value can be accepted, provided that they are not asked by employees personally.

3.8. Gifts of low material value (Article 3.3) are recorded in the relevant Unit/Department by indicating information such as the employee name, 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 must be ensured that gifts accepted do not create the impression that the party who gave the gift has received a priority treatment, any privilege, or that this situation does not damage the image of the Bank.

3.10. The above-mentioned provisions also apply to gifts given to family members within the framework of relationships arising from employees' duties.

3.11. The Bank's employees may attend entertainment and catering organizations for representation and entertainment, provided that they are acceptable, reasonable and modest in the business world.

3.12. Managers may accept gifts that are not of high monetary value, either directly or indirectly, from their direct or indirect reports or employees from their managers, provided that they do not ask for such gift themselves and such gifts are only to celebrate on special occasions.

3.13. The necessary disciplinary action, up to the termination of the employment contract, shall be imposed in accordance with the provisions and procedures of the Human Resources Regulation (Collective Labour Agreement, if any) for behaviours that are found to be in violation of the rules of this Policy. Such violations shall be notified to the relevant judicial authorities if legal requirements require to do so.

4. CODE OF PRACTICE FOR REPRESENTATION EXPENDITURES AND CORPORATE EXPENDITURES 

4.1. The Bank's Budget for Representation Expenditures is determined each year by the Board of Directors. If there is a need to exceed the Budget for Representation Expenditures, the power to decide to provide an additional budget rests on the Board of Directors.

4.2. The General Manager shall determine the Authority Limits for Representation Expenditures on the basis of title/position. Any limits which are not unused in any given year cannot be transferred to the next year. 

4.3. Persons authorized to incur representation expenditures are managers and directors with similar titles and higher titles. However, the authority to incur Representation Expenditures may be transferred on a transaction basis, in case of necessity and exceptionally, with the responsibility resting on the manager transferring the authority. For transactions involving more than one person authorized for Representation Expenditures, the Authority Limit of Representation Expenditures of the highest title responsible for the subject matter shall be taken into account.

4.4. If there is a need to exceed the Authority Limit of Representation Expenditures on the basis of title, the approval of a higher title is required.

4.5. In order for the Representation Expenditures to be an expense deductible from the tax base, it must be incurred for the purpose of obtaining and maintaining commercial earnings and must be documented, excluding the exceptions specified in the legislation.

4.6. The Authority Limits of Representation Expenditures must be used by giving priority to the development of relations with existing/potential customers with high efficiency. Representation expenditures to be incurred will be appreciated by our managers in proportion to the actual or expected efficiency.

4.7. The Bank's employees may use the Authority Limits of Representation Expenditures in case of entertainment and catering organizations for representation and entertainment, provided that they are acceptable, reasonable and modest in the business world.

4.8. For representation and entertainment, the province where the head office of the Bank is located shall be preferred.

4.9. No representation or entertainment can be organized for İşbank Group, other than meetings/organizations to be held for training purposes and/or as part of the business.

4.10. For representation and entertainment other than İşbank Group, if there is a commercial justification, a suitable location outside the province where the head office of the Bank is located and within the country may be preferred. Invitations shall not include families and are made only for the people concerned. However, exceptions may be made, taking into account the general practice in the relevant sector, provided that it is submitted to the Board of Directors in advance for approval.

4.11. If the Bank or any party acting on behalf of the Bank hosts an invitation, travel and accommodation expenses shall be covered by the guests. Any travel and accommodation expenses to be incurred by the Bank's employees for invitation and business purposes shall be paid by the Bank. In both cases, if there is a reasonable justification, the invitee may cover the entire travel and accommodation costs.

4.12. In cases where the Bank's employee gets married, gives birth or his/her spouse gives birth, he/she, his/her spouse or child has a serious illness, has an operation and the death of the employee, his/her spouse, child, mother or father, and if deemed necessary, flowers can be sent or donations can be made to the Child Protection Agency, TEMA Foundation and so on reputable institutions on behalf of the Bank within the scope of the Corporate Expenditures. No Corporate Expenditure can be incurred in cases of in-bank promotion, appointment, relocation and similar situations.

The upper limit for such flowers/donations and the officials who can incur expenditures are determined by the Directorate General. In case of collective celebrations/events, organizations etc. planned to be organized for employees. The said Corporate Expenditure item shall be included in the budget as a separate item, or if it is not included in the budget, a pre-approval shall be obtained from the Board of Directors. More than one Corporate Expenditure cannot be incurred for the same item. Those which should be recognized as non-deductible expenses out of Corporate Expenditures shall not be considered as expenses in the tax base calculation. No gifts shall be sent to employees and/or family members of companies within in the Bank and İşbank Group on special days such as holidays and New Year's Day. Gifts and promotions with a nominal value rather than monetary value such as agendas, pens and calendars can be given to the said persons. These practices shall be carried out within the framework of the provisions of Article 3 (Code of Practices to Accept Gifts) of this Policy.

4.14. The reason for the expenditure, the name of the customer or employee subject to the transaction should be clearly written on the back of the payment document of the Representation Expenditures and Corporate Expenditures and be signed by the person authorized to make the expenditure. Employees who carry out the payment transactions are obliged to investigate the existence of the signatures of persons with the titles stated above in the relevant documents of Representation Expenditures and Corporate Expenditures, or of their attorneys in case of power of attorney.

4.15. Representation Expenditures and Corporate Expenditures shall be periodically reported to the Board of Directors within the framework of the budget realizations. 

5. AUDIT The audit for compliance with the provisions of this Policy shall be carried out every year within the scope of internal audit. 

6. EFFECTIVE DATE This Policy and any changes to this Policy will come into effect after its approval by the Board of Directors.