Ferro Castings acknowledges social responsibility awareness as one of the fundamental and invariable elements of its management approach.

Our fundamental principles on which we base our social responsibility practices are as follows:

• Emphasizing human rights and equality; trying to instill in society the awareness that there should be no discrimination based on language, race, color, gender, political thought, belief, religion, sect, age, physical disability and similar reasons,

• Providing our employees with a safe and peaceful working environment where human rights are recognized to the fullest extent,

• Adding positive value to our society,

• Prioritizing environmental awareness within the scope of our activities,

• Carrying out activities to increase awareness on social issues,

• Establishing healthy communication with our stakeholders within the framework of transparency and ethical values.

We are an institution that is sensitive to the Occupational Health and Safety culture and aware of its responsibility in the production and development activities of gray and spheroidal cast iron parts. We adopt the principle of protecting our employees, subcontractors, customers, suppliers and neighboring businesses while producing, complying with the legal conditions in force, customer requests and expectations and other conditions, providing and maintaining a safe working environment, and preventing work accidents.

     In line with this principle;     

• Preventing danger and risk at source,
• Replacing the dangerous with the non-dangerous,
• Preventing with engineering applications,
• Adhering to procedures and instructions,
• To use collective protection measures,
• To use collective protection measures,
• Ensuring the use of personal protective equipment and ensuring that employees internalize this use

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• To increase Occupational Health and Safety awareness by training our employees and employee representatives on the Occupational Health and Safety effects of all in-house processes,
• To make emergency Planning, establish preventive systems for fire hazards, and take all possible precautions,
• To make decisions with a proactive approach by conducting risk and opportunity assessment studies and to ensure effectiveness in process management mechanisms,
• To raise awareness among our suppliers and customers from whom we purchase goods and services regarding Occupational Health and Safety,
• To continuously improve, develop and ensure the continuity of our Occupational Health and Safety Management System with the participation of all our employees,
• To identify all relationships between people and work in the workplace, along with all factors that affect this relationship, and to make the job more suitable (ergonomic) for employees and employees more suitable for the work,
• To continuously ensure a safe working environment and protect employees’ health from the current or potential risks arising from the effects of chemical and biological substances required by the process.
• Contributing to raising awareness in society by carrying out social projects.
• We undertake to be accountable in this regard when necessary within the scope of the Occupational Health and Safety Management System and the principle of transparency

Ferro Castings is aware that achieving sustainable success in the business world depends not only on financial performance but also on social responsibilities and ethical values. As a company, we attach great importance to conducting our activities in a transparent, fair and reliable manner. Our ethical values ​​form the basis of our way of doing business in order to protect the rights of both our employees and stakeholders and to be sensitive to society and the environment.

As Ferro Döküm, we are committed to adhering to the following ethical principles in all our operations:

Main Articles of Ferro Casting Ethics Policy:

Honesty and Transparency: Our company remains loyal to the principles of honesty and transparency in business relations. We take care to provide clear and accurate information in our communications with all stakeholders.

Respect for Human Rights: Respecting the human rights of all our employees and business partners and preventing negative behaviors such as discrimination and harassment are among our basic principles.

Justice and Equality: We continuously work to ensure equal opportunities, treat all employees fairly, and prevent discrimination in the workplace.

Environmental Awareness: By supporting sustainable environmental policies, we develop production processes that will not harm nature and aim to protect natural resources.

Confidentiality and Information Security: Our company is highly sensitive about protecting the confidential information of our customers, employees and business partners. We act in accordance with all legal regulations regarding information security.

Compliance with Laws: We act in accordance with local and international laws in every country we operate in. We create a harmonious business environment by closely following legal regulations and sector standards.

Fighting Bribery and Corruption: Our company has a zero tolerance policy against all kinds of bribery and corruption attempts. We avoid any activities that are against business ethics.

Social Responsibility: Ferro Döküm actively participates in social responsibility projects to contribute to the general welfare of society. It has adopted the principle of supporting the development of local communities.

These ethical principles determine the way Ferro Döküm does business, and all our employees are expected to act in accordance with these values.

You can access our ethical procedure in the attached file.

We believe that the responsible and ethical sourcing of minerals in our supply chain is critical to both environmental sustainability and respect for human rights. Tantalum, tin, tungsten and gold (3TG) the illegal mining of minerals such as sulfur can finance conflict and potentially lead to human rights violations. Therefore, adhering to the principles of conflict-free and responsible mining at all levels of our supply chain is a key priority.

Our aims:

· Not contributing to human rights violations, illegal activities and situations that may harm the environment,

· To ensure sustainable and ethical supply chain management.

As Ferro Döküm, with this policy we aim to increase the sustainability of our supply chain, ethics and social responsibility we are committed to acting in accordance with the principles. With our responsible sourcing approach, we aim to strengthen our long-term relationships with our business partners and respectful of human rights aims to maintain a production process.

Ferro Döküm expects our business partners to share the same responsibilities in order to avoid any actions that contribute to the financing of conflict. In this context, we expect our business partners to act in accordance with the standards of “OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas”.

We expect our suppliers and business partners to fulfill the following:

1. Collaboration, Transparent Supply Chain

· Use only minerals from conflict-free areas,

· Transparent reporting of the country where the minerals are extracted, mine location and smelting facilities from suppliers,

· We aim to minimize risks by cooperating with suppliers that carry potential risks. If these risks cannot be reduced, we recommend that they terminate their cooperation with such suppliers.

· When a situation related to conflict minerals is detected in the supply chain or a risk is foreseen, ethical reporting channels should be used and, if necessary, cooperation with risky suppliers should be stopped.

2. Ethical Standards and Legal Compliance

· Resist any offer of bribery to conceal or alter the origin of minerals in our supply chain.

· We also require our suppliers to act ethically in this regard, bribery, money laundering and illegal activities to stand against unethical practices such as,

· All necessary measures are taken to prevent money laundering in the trade of conflict minerals; and in accordance with international and local regulations to be moved

Ferro Dokum offers the opportunity to report non-compliance with its conflict minerals policy using ethical reporting channels. All reports regarding ethical violations can be made to the relevant ethics lines.

AIM

Creating a contemporary and human rights-respecting work environment in line with the understanding of sustainability, conveying the approaches and principles in these areas, ensuring and encouraging our employees, customers, suppliers, business partners and all other stakeholders we are associated with to act with sensitivity to human rights and within the framework of these principles.

With these values ​​at the center of our mission, we believe that all employees, customers and stakeholders should be treated with dignity and respect, regardless of their background, identity or belief. With this policy, which is designed to contribute to the sustainability steps of our company and to ensure that fundamental human rights are supported in all company activities, we undertake to act for the benefit of our country and the world by carrying out all our activities within the framework of the Universal Declaration of Human Rights and the United Nations (UN) Global Compact.

SCOPE

This policy applies to all employees, contractors, consultants, trainees and partners of Ferro Döküm. Everyone is expected to comply with this policy and conduct their activities on behalf of Ferro Döküm in accordance with this policy. Ferro Döküm is also committed to working with joint venturers, suppliers and third parties who support the principles in this policy or who have adopted similar policies in their own businesses.

This Policy shall enter into force upon approval of the Board of Directors from the date of publication and its validity shall continue as long as the Policy remains published.

RESPONSIBLE PERSONS

Preparer : Strategy Unit (Human Resources Department and Sustainability Department)

Approved by: Board of Directors

Published by: Human Resources Directorate

BASIC PRINCIPLES, COMMITMENT AND IMPLEMENTATION PRINCIPLES

We are aware that human rights are universal and indivisible, and we are determined to promote and protect these rights in every area of ​​our activities.

Our Human Rights Policy outlines our commitment to:

1. Commitment to Human Rights:

Ferro Döküm is committed to respecting and promoting human rights as set out in the Universal Declaration of Human Rights and relevant international and national laws. This commitment covers all aspects of our operations.

2. Working Conditions, Compensation and Benefits:

Ferro Döküm operates in compliance with applicable laws on wages, working hours, overtime and fringe benefits. It aims to prevent overtime work by carrying out studies to increase the productivity of employees during working hours and supports the preservation of work-life balance. Ferro Döküm and its subsidiaries create wage policies and personal rights competitively in accordance with the sectoral, local labor market and the terms of applicable collective labor agreements. Operations are carried out in compliance with applicable laws on wages and working hours. Employees are provided with opportunities to develop their talents and potential and to advance in their professional and private lives.

3. Diversity, Equity and Inclusion:

Ferro Döküm values ​​the diversity and contributions of our people. We believe that a diverse and inclusive workplace is essential to fostering innovation, creativity and growth. Our diversity, equity and inclusion policy is designed to ensure that all employees, regardless of background, have equal opportunities to succeed. We have a deep-rooted commitment to fair treatment and equal opportunity, and we do not tolerate discrimination or harassment of any kind. Ferro Döküm is committed to creating and maintaining workplaces that are free of discrimination or harassment on the basis of race, color, religion, gender, gender identity, sexual orientation, national origin, age, disability or any other status protected by applicable law.

This policy covers:

• This policy covers:
• Equality: Equal opportunities and support are provided to all employees so that the communities served have the tools and resources they need to thrive.
• Inclusivity: The aim is to create an environment where every individual feels valued, listened to and has the right and authority to realize their full potential.

In Ferro Döküm;

In our work areas and all business processes, we aim to create an inclusive, social and fair world in line with the following sustainable development goals.

• Gender Equality
• Decent Work and Economic Growth
• Reducing Inequalities
• Industry, Innovation and Infrastructure

The principles contained in the Universal Declaration of Human Rights are taken as basis throughout the value chain.

• All employment decisions are made based on qualifications and business needs without regard to race, color, religion, gender, gender identity, sexual orientation, national origin, age, disability or other protected characteristics. The awareness-raising process is led by the management team.
• Ferro Döküm provides all employees with a safe, healthy, clean working environment that meets or exceeds current occupational safety standards.
• Ferro Döküm attaches importance to collaborating with institutions that have a fair, equal and flexible structure. It sets an example with its diversity, equality and inclusiveness practices and supports all stakeholders it cooperates with to adapt to this process.
• We adopt the concepts of “Diversity”, “Equality” and “Inclusivity” in our communication language and apply them in our business processes, and aim to be a pioneer in social awareness with this language structure.
• Ferro Döküm and its Affiliates aim to be an institution that supports continuous, inclusive and sustainable economic growth and creates efficient and suitable working conditions by adopting the principles of diversity, equality and inclusiveness.
• Our employees are informed that they can forward their questions, suggestions or concerns regarding this policy to the Human Resources Department or the relevant company Human Resources Managers. Any complaints or suggestions are treated confidentially and objectively.

Ferro Döküm is committed to being and maintaining a workplace that complies with legal requirements and at the same time embraces and exemplifies the highest standards of ethical behavior, and believes that by adhering to policies, a more inclusive, equitable and fair environment for all can be created.

4. Freedom of Association and Collective Bargaining:

Ferro Döküm respects the right of employees to join unions and participate in collective bargaining. Ferro Döküm is committed to a constructive dialogue with freely chosen representatives of employees who are represented by a legal union.

5. Safe and Healthy Workplace:

Ferro Döküm is determined to provide a safe and healthy working environment by aiming to fully ensure occupational health and safety in the workplace and on the job. It takes all reasonable steps to prevent accidents, injuries and work-related illnesses and to comply with all relevant health and safety laws. In parallel, it expects its employees to act in accordance with the rules and instructions set for this purpose and to take the necessary precautions.

6. Zero Tolerance for Harassment and Violence

Ferro Döküm is committed to providing a safe environment for all employees and with zero tolerance for discrimination and/or violence resulting from any form of harassment, including sexual harassment.

Sexual or other types of harassment may include one or more incidents and the actions that constitute harassment may be physical, verbal. Sexual harassment is unwanted conduct of a sexual or other nature that makes a person feel humiliated and/or intimidated and/or uncomfortable, and may be non-verbal. Anyone who is subjected to and/or witnesses harassment (even if it does not escalate into physical violence or abuse) understands that this is undesirable behavior by the relevant Ferro Döküm and is a violation of this Policy.

Recognizes that harassment can occur in unequal relationships (i.e., between a manager and a direct report) and that the victim may be hesitant to report the alleged harasser, so reminds the victim that she is on her side and that the company will support her if she decides to report it, and that she will not experience any loss of employment, etc. Employees or other stakeholders are free to use this policy’s complaint mechanism if they learn of an ethical violation that may violate this policy.

The person or authority receiving the harassment complaint;

– Immediately records the dates and times of the incident(s),

– Ensures that the victim understands the company’s complaint handling procedures,

– Keeps records of all discussions confidential,

– Respects the victim’s choice to resolve the incident through company procedures and/or legal means.

In addition to the internal investigation, it is clearly stated to the victim that there is no obstacle to exercising his/her legal rights. The company is obliged to establish, operate and make open and accessible to its stakeholders a complaint mechanism with the above qualifications at a minimum level.

7. Freedom of Expression

Ferro Döküm has adopted the principle of preventing any situation that would hinder employees’ exercise of their right to freedom of expression in the work environment, and provides the necessary tools and environments for employees to express themselves freely.

8.    No Child Labor

Ferro Döküm and its subsidiaries oppose the use of child labor, comply with relevant laws and regulations, and act in a manner consistent with the Minimum Age Convention (ILO Convention 138). Minors under the age of 18 are not employed except in education and apprenticeship programs approved by official authorities.

It undertakes to develop procedures to avoid child labor practices and to conduct studies to evaluate the performance of the parties from which it receives services within the scope of the commitments it has made to international organizations.

9.  No Forced Labor

Ferro Döküm and its subsidiaries comply with the prohibitions against any form of forced labor, exploitation or slavery. Disciplinary measures based on physical or mental torture are not permitted. They ensure that their suppliers also comply with this rule.

Ferro Döküm is committed to complying with the Modern Slavery Act 2015 and to the recognition and protection of human rights in all countries in which we operate, providing global support to eradicate slavery and human trafficking. Our Human Rights Policy is guided by international human rights principles as contained in the Universal Declaration of Human Rights.

Employees and those working on behalf of Ferro Döküm are expected to comply with this policy and our code of ethics, which requires adherence to ethical business practices and integrity at all times.

• Providing Development Opportunities

Ferro Döküm; It provides its employees with opportunities and facilities to develop themselves personally and professionally. With the principle of continuous development, it supports the development of our employees with innovative training methodologies and experience sharing that are suitable for today’s and tomorrow’s requirements.

11.  Protection of Personal Data

Ferro Döküm takes the necessary measures in accordance with the relevant legal regulations to protect the personal information and data of its employees, customers and business partners in accordance with the principle of protecting the privacy of private life and the fundamental rights and freedoms of individuals and to prevent this information from being shared with unauthorized persons, and is committed to applying high-level standards in this field.

Employees are expected to comply with the measures and regulations regarding the protection of personal data during their daily work, and in this context, our employees are supported with training activities.

OUR EXPECTATIONS FROM OUR STAKEHOLDERS

• Our managers, employees and those acting on behalf of Ferro Döküm are required to comply with the policy; they are also required to communicate any violations or potential violations to their relevant managers and/or report them through company complaint channels.
• Our suppliers and business partners are expected to act in accordance with the policy.
• Our stakeholders are encouraged to provide feedback on the policy.
• All employees, stakeholders and partners are encouraged to adopt the company’s human rights policy and take an active role in promoting human rights compliance within the organization.

FERRO DÖKÜM SANAYİ VE DIŞ TİCARET A.Ş.

If you have any questions or need further information regarding the policies and practices described above, please do not hesitate to contact the Human Resources Department.

0262 653 42 60

insan.kaynaklari@efesan.com.tr

Purpose and Scope

We are committed to carrying out the purchasing processes in our supply chain in accordance with environmental, social and ethical values. Our Responsible Supply Chain Policy aims to create a supply chain that respects human rights, is environmentally sensitive and supports ethical business practices by adopting sustainability principles.

This policy aims to ensure that our suppliers and business partners promote responsible sourcing and sustainable supply chains, and act in accordance with international standards on important issues such as women’s rights, equality, diversity, human rights, environmental protection and combating corruption. This policy also aims to guide the selection and monitoring of Ferro Casting Business Partners. Responsible Supply Chain

All business partners and suppliers of Ferro Döküm are expected to comply with the following principles:

1.      Human Rights and Social Responsibility:

Our Business Partners are expected to carry out their commercial activities in accordance with Ferro Döküm Human Rights Policy.

• Women’s Rights: All business partners in our supply chain are expected to respect the rights of women and promote gender equality in their workplaces.
• Recruitment All recruitment processes are expected to be carried out ethically and transparently, and employees are expected to adhere to the principles of fair treatment, equal opportunities and respect for human rights.
• Diversity, Equity and Inclusion: Our suppliers are expected to implement policies that prevent any form of discrimination and to support diversity, equality and inclusion in the workplace.
• Land, Forest and Water Rights and Involuntary Evictions: Our suppliers are expected to respect land, forest and water rights and oppose forced evictions.
• Child Labour and Young Workers: Ferro Döküm takes a firm stance against human rights violations such as forced labor and child labor in its processes. Our suppliers are expected to take measures to prohibit child labor and respect the rights of young workers.
• Fair Wages and Benefits: Çalışanların adil bir şekilde ücretlendirilmesi ve sosyal haklarının sağlanması beklenmektedir.
• Working Hours and Leaves: Our suppliers must set working hours in accordance with legal regulations and are expected to respect workers’ rest periods.
• Modern Slavery: Our suppliers are expected to adopt a zero tolerance policy towards modern slavery and forced labour practices.
• Freedom of Association and Collective Bargaining: Employees’ freedom of association must be respected and their right to collective bargaining is expected to be respected.
• Non-Discrimination and Harassment: Our suppliers must develop and implement policies that prevent discrimination and harassment. Any form of physical, verbal, sexual or psychological harassment, bullying, abuse or intimidation is expected to be non-tolerated.
• Health and Safety: Our suppliers are expected to take the necessary precautions regarding occupational health and safety and to ensure the safety of their employees.
• Conflict Minerals Policy: Suppliers and business partners are expected to comply with the Ferro Casting Conflict Minerals Policy. Necessary measures are expected to be taken to prevent the use of conflict minerals.

2.   Ethical Business Practices and Legal Compliance:

• Fighting Corruption and Money Laundering: Our suppliers are expected to adopt a zero tolerance policy against all forms of corruption and money laundering and to act in accordance with the principle of transparency.
• Financial Responsibility (Accurate Records): Our suppliers are expected to ensure that financial records are kept accurately and transparently.
• Disclosure of Information: Our suppliers are expected to disclose the information required for business processes in a transparent manner and maintain confidentiality.
• Replica/Copy Parts: We ensure that measures are taken against the supply of fake/copied/replica parts in our supply chain. Suppliers are expected to supply their products and services in accordance with the criteria specified in the contract and in their original form, and not to use fake/copied/replica parts and materials.
• Export Control and Economic Sanctions: Our suppliers are requested to comply with export controls and national/international economic sanctions and are expected to do what is necessary.
• Protection Against Whistleblowing and Retaliation: All stakeholders in our supply chain are expected to develop policies that ensure the protection of whistleblowers.
• Data Protection and Data Security: Our suppliers are required by law to comply with national and international regulations on the protection of personal data and information security, and they are expected to comply with this situation.
• Fair Competition and Antitrust: Our suppliers are expected to take responsibility for conducting fair competition and complying with antitrust laws.
• Conflict of Interest: Our suppliers are expected to implement policies that do not permit conflicts between personal and business interests.
• Intellectual Property: Our suppliers are expected to respect and protect the intellectual property rights of Ferro Döküm and third parties.

3.      Environmental Sustainability

Ferro Döküm is expected to comply with all applicable environmental regulations, including the Environmental and Energy Policy.

• Greenhouse Gas Emissions: Our suppliers are expected to take measures to reduce greenhouse gas emissions and set targets in this regard.
• Energy Efficiency and Renewable Energies: Our suppliers are expected to adopt energy efficiency practices and invest in renewable energy sources.
• Decarbonization: Reducing the carbon footprint and developing decarbonization strategies are expected to be among the priorities of our suppliers.
• Water Quality, Consumption and Management: Our suppliers are expected to work towards efficient use of water resources, reduction of water consumption and protection of water quality.
• Air Quality: Our suppliers are expected to take measures to minimize air pollution.
• Responsible Chemical Substance Use Management: Our suppliers are expected to develop appropriate management policies to ensure the safe use of chemicals and the prevention of harmful effects on the environment.
• Sustainable Resource Management: Our suppliers are expected to develop practices that promote responsible use of resources and sustainability.
• Waste Reduction and Recycling: Our suppliers are expected to adopt sustainable waste management strategies and recycling practices to reduce waste.
• Reuse: Our suppliers are expected to develop processes that encourage the reuse of products and materials.
• Animal Welfare: Our goal is to ensure that practices that protect animal welfare are adopted in our supply chain, and our suppliers are also expected to care about this issue.
• Biodiversity, Land Use and Deforestation: Our suppliers are expected to develop strategies to protect biodiversity and take measures against deforestation.
• Soil Quality: All stakeholders in our supply chain are expected to implement practices that will protect soil quality.
• Noise Emissions: Our suppliers are expected to develop policies that reduce noise pollution.

4.   Supply Chain Management:

• Maintaining Standards Throughout the Supply Chain: Our suppliers are expected to meet the binding requirements with their own suppliers (Tier-1 suppliers) in line with the principles of sustainability and responsibility.

Violation Cases and Sanctions:

Ferro Döküm reserves the right to terminate any business relationship with any supplier or business partner that does not comply with this policy. In the event of non-compliance, necessary corrective measures will be taken and, if necessary, business relationships may be terminated. Ferro Döküm ethical reporting channels are used for reporting violations and communication. Business partners are also expected to establish effective communication channels to report violations and take the necessary measures in a timely manner.