CODE OF CONDUCT

PURPOSE OF CODE OF BUSINESS CONDUCT & ANTI – BRIBERY AND CORRUPTION (‘’ABC’’) POLICY

Tekfen Engineering Co. Inc., is an international engineering company operating in a very complex, challenging and varying international environment surrounded by a multitude of risks which need to be avoided or otherwise reasonably minimised through implementation of corporate policies and procedures. In this connection, it is vital for Tekfen to maintain an undisputed good reputation and to be considered a reliable business partner both domestically and in the international engineering arena.

This Code of Business Conduct & Anti Bribery and Corruption Policy is intended to help preserve and improve the reliability of the Company, its operations and reputation and to indicate non-limitative requirements for its employees and business associates to abide by in order to avoid and/or minimize the risks and to maintain the very significant values indicated.

It is very important for each Tekfen employee, including the upper management, i.e. the Board of Directors, to understand the “spirit” of this Business Code, and exercise that “spirit” in all the Company operations worldwide. Any absence of an example or circumstance in this Business Code shall not be construed as the absence of any risks with regard to the matters similar to those addressed in this Business Code.

This Code of Business Conduct & ABC Policy reflects Tekfen’s commitment and requirements regarding ethical business practice and personal behavior of its employees and business associates. This Business Code applies to Tekfen, any of its branches and subsidiaries, its and their upper management including Board of Directors, it’s or their employees, hired personnel, subcontractors and suppliers, business partners, intermediaries, lobbyists, and any others who may act for or on Tekfen's behalf, or in business association of any form with Tekfen. Tekfen is implementing this Business Code due to its commitment to comply with all applicable laws and regulations, without omitting the universal human rights and the ethical values irrespective of the magnitude of any of its businesses or the location of its operations.

This Business Code may not  answer all questions to the risk matters that could be faced in the operations carried out worldwide; nevertheless it intends to be a reliable source for guidance to act ethically, responsibly, within the legal boundaries of whatever the region or area of the World in which Tekfen is, and will be, operating.

1- Sound Off should only be used when all other avenues which are defined in Code Of Conduct have been exhausted.

2- Sound Off should be used with honesty, fairness and goodwill.

3- Subject matter of Sound Off submitted should be provided in a detailed manner to help assure an effective investigation.

4- If you prefer your ID to be kept confidential, please leave “Your Name“ box empty in mailing page.

5- Tekfen Engineering commits that this Sound Off that you will be submitting as per the foregoing shall not be used against you or detrimental to you in any manner.

Sound Off Form

* If you prefer your ID to be kept confidential, do not fill the name field.