ELIN INC. Anti-Bribery and Anti-Corruption Policy;
Purpose In accordance with universal ethical rules, Elin Inc. was constituted to aim of committing to the continuous improvement in all its commercial activities and relationships with the zero tolerance principle against bribery and corruption with the perspective of accuracy, transparency, clarity, and suitability.
Scope This policy, created based on the Anti-Bribery and Anti-Corruption Management System for Elin Inc. and its subsidiaries, involves all employees, senior management of the company, and third parties with whom we have business relations such as customers, dealers, suppliers, business partners, and subcontractors.
Application Elin provides consciousness-raising and awareness-raising training programs to its employees and business partners about the requirements of the anti-bribery and anti-corruption management system. The Anti-Bribery and AntiCorruption Management System handbook has been prepared to better understand application methods.
Our main principles in all our operation fields towards our policy;
- To obey the anti-bribery laws and regulations in all countries in which it operates.
- To take necessary actions by identifying and evaluating the risks of anti-bribery, and to establish a framework for the purpose of setting and reviewing targets and achieving these targets.
- To prevent any form of bribery including facilitation payments.
- To pay attention not to create any perception of conflict of interest in similar activities such as gift, hospitality, donation, sponsorship, and representation within the limits of the standards determined in our ethical rules.
Gifts, Hospitality, Representations, and Similar Advantages In order to avoid internal and external conflicts of interest, acceptance of gifts and hospitality issues are determined and limited. We do not accept or give any cash or cash equivalent gift (such as gold, jewelry, share certificate, or gift card), which may create the impression of or be perceived as an infraction, in order to influence a decision or get secret information.
A gift is being offered or accepted in good faith only if the gift is able to be explained upon request by management, has reasonable value (not exceeding 100 Euros), and a non-continuous with the condition of registering in the Elin Inc. gift registry without causing any conflict of interest.
Items exempt from the gift restriction are listed below;
- Gifts offered by authorities that cannot be politely declined and exceed a value of 100 Euros are accepted by registering them in the Elin Inc. Gift Registry. These gifts are then distributed among employees through a lottery draw.
- Memorabilia gifts such as plaques and shields given at conferences, meetings, seminars, meals, etc., in which participation is involved.
- Promotional items distributed for promotional purposes, with symbolic value, and prizes or gifts won at events.
- Gifts such as pens, magazines, books, calendars, and agendas.
- Dinner invitations organized during business hours or after working hours for conferences, meetings, seminars, etc., related to business interviews or collaborative activities, provided that they are not requested from our employees during the meeting hours.
Conflict of Interests Elin Inc. employees and all related parties are required to avoid any and all kinds of pecuniary and non-pecuniary benefits which affect or may affect the performance of their duties in accordance with the rules of impartiality and ethics, conflicts of interests relating to these and any other situation which may be perceived as a conflict of interest.
Facilitation Payments Even if it is generally considered different when compared with bribes paid to get a job, it is illegal in many places, and according to purposes of this standard and, Elin Inc’s ethical principles, it is considered as bribery and it is prohibited.
Donations, Aids, and Sponsorships It is forbidden to make political and charitable donations that may affect a decision in favor of Elin Inc.
Charitable donations and sponsorships made by the company must be in accordance with company policies and applicable local laws.
Keeping of Records Elin Inc. preserves all kinds of accounts, bills, and documents by recording them in an appropriate, complete, transparent, precise, fair, and accurate way in accordance with current legal regulations.
It takes the necessary precautions and provides controls in order not to falsify and deflect the truth concerning any transaction on accounting records and other commercial records and documents related to these records.
Violation Notice Evaluation of suspicious status notifications with confidentiality and reliance is carried out by the Ethical Board with the principles of impartiality and independence. Notifications are sent to etik@elinholding-usa.com
