TSKB Anti-Bribery and Anti-Corruption Policy
1.PURPOSE
The purpose of the Anti-Bribery and Anti-Corruption Policy (“the Policy”) is ensuring the compliance of the Industrial Development Bank of Turkey (Türkiye Sınai Kalkınma Bankası A.Ş.) (“the Bank”) with the ethical and professional principles, universal rules and legal regulations against corruption and bribery.
2. SCOPE
The Anti-Bribery and Anti-Corruption Policy covers all employees of the Bank, including the Board of Directors, and its affiliates, intermediaries, assignees, suppliers, contractors, third parties, affiliated agencies, partners working with the Bank.
This Policy is an inseparable part of the Ethical Principles accepted by the Board of Directors and all the employees, and the principles that the Bank agreed to abide by through joining the United Nations’ Global Principles Agreement, the Gifts and Hospitality Policy, the Human Resources Regulation and Donation Regulation of the Bank as well as other internal regulations, by-laws and other legal regulations.
3. DEFINITIONS
Bribery is a person’s acting in violation of the requirements of his/her duty by doing or not doing a work, speeding up or slowing down thereof, etc. within the framework of an agreement reached with a third person and gaining unfair advantage for himself, his family, his surroundings and/or third parties. A gain or facilitation payment via bribery can be in the form of cash, cash convertible vehicles, gifts, invitation for occasion or tickets, debt forgiveness, donation for help.
Corruption is direct or indirect bribery and the act of offering, demanding, giving or accepting bribery or all sorts of other illegal interests, which obstructs the person providing an illegal interest in the execution of his/her duty or the required attitudes in line with the laws.
4. AUTHORITIES AND DUTIES
It is the duty of the Bank’s Board of Directors to ensure the Policy to be established, applied and updated.
The Bank applies disciplinary sanctions if the employees act in violation of these principles. The Disciplinary Board is assigned by the Board of the Directors of the Bank the task of investigating such situations.
The Bank employees shall report anonymously any bribery, corruption or any suspicious activities via complaint form which is available on the Bank’s intranet site or through the contact form which can be accessed on the Bank’s website. These forms generated by the Bank employees are forwarded directly to the Head of Internal Auditors and Head of Internal Control. Depending on the content and nature of the incident, if there shall be any investigation, inspection, etc. it is undertaken and performed by the Board of Internal Auditors, in case of any operational fault, risk, etc., it is undertaken and performed by the Internal Control Department. The incident reported is investigated in a way where it is ensured that the identity of the person who reported and the content of the complaint are kept confidential. At the end of the investigation, if necessary, the reporting employee shall be given a feedback.
5. MAJOR RISK AREAS FOR BRIBERY AND CORRUPTION
The Bank aims full compliance with the relevant regulations, laws and principles and does not ever tolerate any bribery or corruption regardless of its purpose.
Any business relations with third parties that ask or require receiving service from the Bank through bribery shall be terminated.
The major risk areas where bribery and corruption can take place are described in detail below:
a. Gifts and Hospitality
Gift is a product generally given by customers or persons engaged in a business relationship with the Bank as a means of appreciation or commercial courtesy and which does not require a financial payment.
Any gifts given to third parties by the Bank are offered with good will, publicly and unconditionally. Although the same principles apply for accepting a gift, apart from symbolic gifts that comply with these principles, no gift that cause any liability for the employee himself, his family, surroundings and/or third parties should not definitely be accepted.
Within the scope of business to build commercial communication networks and improve commercial relationships, entertainment can be offered to clients, consultants, lawyers, auditors and other companies having a business relationship with the Bank. The Bank offers entertainment to third parties in good will, publicly and unconditionally.
Even if they comply with the matters specified in this Policy, any entertainment offers and gifts that may cause conflict of interest or such situations to be perceived in this way are not offered or accepted.
The Bank employees cannot request or accept gifts in contrary to the provisions of the Bank's Gifts and Hospitality Policy, and cannot act in such a way.
b. Political Donations
There can be no political donations in the name of the Bank.
The Bank cannot utilize its opportunities and vehicles for supporting a political nominee or institution. The principles regarding donations and aids are subject to the Donation Regulation of the Bank.
c. Outsourcing Companies and Business Partners of the Bank
The Bank conducts due diligence before evaluating the companies and business partners from which it shall receive external services, including support services, and does not work with individuals and organizations with negative intelligence about bribery or corruption.
Outsourcing companies and business partners are obliged to comply with this Policy and other relevant regulations. The Bank informs the said companies and its partners of their obligation to follow this Policy. The business relations with any persons and organizations that do not follow the concerned principles and other regulations are terminated.
d. Facilitation Payments
The Bank does not allow the persons or companies covered by the Policy, to offer facilitation payments, which are intended to secure or speed up a regular procedure with the government agencies.
e. Abuse of Title and Duty
The employees of the Bank shall not use their duties and authorities, under any circumstances, for the benefit of themselves, their families or third parties in order to obtain personal or private gains. The employees of the Bank, shall not receive or shall not be promised to receive any kind of benefit under any name or title either directly or via an intermediary for themselves, their families or third parties by consciously or intentionally misusing their title or duties through mutual agreement, inducement or compulsion.
6. POLICY VIOLATIONS AND SANCTIONS
All the Bank employees are obliged to follow this Policy, the relevant legal regulations and all the anti-corruption laws in force.
If the Bank employees violate the principles of this Policy, disciplinary action including up to the termination of employment shall be taken into consideration. In addition, those who fail to follow the legal regulations and the applicable anti-corruption laws might face penal sanctions.
It may never be accepted that an employee is mistreated for refusing to participate in an incident of bribery or corruption, reporting violation of the principles in this Policy or expressing any concerns on a possible corruption in the future.
7. TRAINING
This Policy is accessible by all the staff on the Bank’s intranet site.
The entire Bank staff is regularly provided with the “Prevention of Laundering Proceeds of Crime”, “Competition Law” and “Anti-Bribery and Anti-Corruption Policy” trainings.
The employees shall sign a document declaring that they would comply with the provisions of the Anti-Bribery and Anti-Corruption Policy and accept the results of any violating actions.
8. REVIEW
This Policy are reviewed at least annually in accordance with the needs and changes in operations, updated and announced on the website of the Bank following the approval of the Board of Directors.
9. AUDIT
The audit of compliance with the provisions of this Policy is carried out as part of the internal audit.
10. EFFECTIVE DATE
The Anti-Bribery and Anti-Corruption Policy shall come into effect following its approval by the Board of Directors.
a. TSKB Anti-Bribery and Anti-Corruption Programme
TSKB Anti-Bribery and Anti-Corruption Program click here to access.
b. 2023 Results
2023 Results within the scope of TSKB Anti-Bribery and Anti-Corruption Program click here to access.
