Anti-Bribery and Anti-Corruption Policy

Anti-Bribery and Anti-Corruption Policy


1- Purpose

The purpose of the Anti-Bribery and Anti-Corruption Policy is to reveal the anti-bribery and anti-corruption policies of Görsel Reklam A.Ş., which are also included in the Görsel Reklam A.Ş., Business Ethics Rules.

2- Scope

Anti-bribery and anti-corruption policy covers;

All of the Görsel Reklam employees, companies and employees from whom we purchase goods and services, including suppliers, consultants, lawyers, external auditors, and persons and organizations (business partners) working on behalf of Görsel Reklam, including the Board.

This policy;

is an integral part of the principles we commit to comply by participating in the United Nations Global Compact and Human Resources Practices, that are part of Görsel Reklam’s Corporate Governance Principles and Business Ethics Rules approved by the Board of Directors of Görsel Reklam and disclosed to the public.

3- Definitions

Corruption is the misuse of the authority held due to the position, directly or indirectly, to gain any kind of profit.

Bribery is the provision, offer or promise of benefits directly or through intermediaries in order for a person to do, make someone else do, not do, accelerate, slow down a job related to the performance of his / her duty; request or acceptance; It means providing benefits to itself or to the party requesting it, or to another person due to this relationship, within the framework of an agreement reached with another person in order to act contrary to the requirements of his / her duty by means of mediating them.


Bribery and corruption can be carried out in many different ways, including:

Cash payments, political or other donations, commission, social rights, gifts, entertainment, other benefits.

4- Duties and Responsibilities

The implementation and updating of the Anti-Bribery and Anti-Corruption Policy is under the authority, duty and responsibility of the Board of Directors.

In this context;

The Corporate Governance Committee advises the Board of Directors to establish an ethical, reliable, lawful and controlled working environment, Senior management evaluating the risks in accordance with the principles to be determined by the Board of Directors and establishing the necessary control mechanisms,

Monitoring whether Visual Advertising activities are carried out safely and in accordance with legal regulations in their field of duty,

Determination and operation of notification, review and sanction mechanisms in case of failure to comply with policies, rules and regulations is required.

In addition, all the Görsel Reklam employees are obliged,

To comply with the policies determined by the Board of Directors, to effectively managing the risks related to their field of activity, to work in accordance with the relevant legal regulations and Görsel Reklam practices, to notify the Ethics Committee in case of any behavior, activity or practice contrary to the Policy.

5- Firms and Business Partners from which Goods and Services are Purchased and Sold

Companies and business partners from which goods and services are purchased and sold are obliged to comply with the principles of the policy and other relevant legal regulations and works with persons and organizations that do not comply with these will be terminated.

5.1- Selection of Companies and Business Partners

At the stage of selection of companies and business partners from which goods and services are purchased and sold, criterias such as experience, financial performance, technical competence, ethical levels and a positive history in this field are also taken into consideration by the senior management. Companies or business partners that have a negative reputation regarding bribery or corruption are not worked with, even if they meet other criteria. In this context, the responsibility for conducting the necessary research and evaluations before entering into any business relationship lies primarily with the senior management. The Audit Department evaluates in its audits whether such matters are complied with.

5.2- Establishing an Agreement with the Company and Business Partners

Ensuring full compliance with the principles specified in the Policy and other relevant regulations in agreements and contracts to be made with companies and business partners that have positive intelligence and meet other criteria,

Employees’ assimilation of these principles and acting accordingly,

Ensuring that employees receive policy-related training periodically,

Reminding its employees about their reporting obligations and Ethics Line regularly and encouraging them to notify in case of such situations.

The conditions related to it are included. In the event that these are not complied with or there is a situation contrary to the Policy, the provisions stating that the work and the contracts in force will be terminated for just cause.

6- Our Policies and Procedures

6.1- Bribery and Corruption


Görsel Reklam is against all kinds of bribery and corruption. Receiving or giving bribes for whatever purpose is absolutely unacceptable.

Business relations with third parties who want to do business with Visual Advertising through bribery or corruption should not be continued and it is absolutely unacceptable to give a job.

6.2- Gift

A gift is a product that does not require any monetary payment and is generally given by people or customers with whom we have business relations as a thank you or business courtesy.

Any gift offered or given to third parties by Görsel Reklam must be offered in good faith and unconditionally. The gifts that can be given within this scope and the principles regarding their recording have been written in the Gift Acceptance and Giving Policy included in the Visual Advertising Business Ethics Rules.

The same principles apply to the acceptance of a gift, and gifts should not be accepted except for the symbolic gifts of low material value. In addition, even within this scope, gift acceptance should not be frequent, and the receiver should notify the HR and senior management of the company through the first supervisor about the gifts accepted.

6.3- Facilitation Payments


Persons and organizations covered by this policy are not offered to facilitate or expedite a routine transaction or process (obtaining permits and licenses,  documents, etc.) with government agencies.

6.4- Donations

Certain legal restrictions have been imposed on donations and aids with the Capital Market Law and related legislation that Görsel Reklam is subject to.

According to this; The Donation and Aid Policy prepared was announced on the website and passed the approval of the General Assembly.

Görsel Reklam employees’ support to charities with the amounts they collect independently from their jobs is excluded from the Görsel Reklam Donation and Aid Policy.

However, at this point, the principles in the Visual Advertising Business Ethics Rules are also valid.

7- Error-free Record Keeping


The issues that Görsel Reklam has to comply with regarding the accounting and recording system are regulated by legal regulations.

According to this;

Reliable recording and keeping of all kinds of accounts, invoices and documents related to relations with third parties (customers, suppliers, etc.) no falsification of the accounting or similar commercial records for any transaction and no distortion of the facts is required.

8- Education and Communication


Anti-Bribery and Anti-Corruption Policy has been announced to Görsel Reklam employees and is continuously and easily accessible through communication methods.

Trainings are an important instrument to increase the awareness of employees. In this context, together with System Management and Accounting; Human Resources designs training programs in which the participation of all employees is mandatory.

9- Notification of Policy Violations


If there is an opinion or suspicion that an employee or a person acting on behalf of Görsel Reklam, acts contrary to this policy, it should be conveyed to the Ethics Committee.

Görsel Reklam employees are periodically reminded about the issues regarding Görsel Reklam Business Ethics Rules.

Görsel Reklam promotes an honest and transparent approach; supports any employee or person acting on behalf of Görsel Reklam who in good faith raises sincere concerns and keeps reports confidential.

 No employee can be subjected to pressure or punishment due to a report that s/he believes has been a violation of the Code of Ethics to the Ethics Committee, and no changes can be made to the scope or place of duty without the written consent of the Ethics Committee.

In case the notifying person is subjected to such a treatment, he / she should notify this to the Ethics Committee.

Companies or business partners from whom goods and services are provided should also regularly remind their employees about the Ethics Line and encourage them to notify them in case they encounter such situations. This issue is also guaranteed by the contracts made.

10- Policy Violations

In cases that are or are likely to be against the policy, the issue is reviewed by the Ethics Committee and necessary sanctions are applied in case of detecting inappropriate behavior.

In the contracts made with companies from which goods and services are purchased and sold, or with persons and organizations working on behalf of X, provisions regarding the unilateral termination of the works / contracts in force by X for a just cause, if it is determined that there is a behavior, attitude or activity contrary to the Policy, and In case of a policy violation, these provisions are applied without exception.