Code of Business Conduct

Our Code of Conduct contains a number of important guidelines of behavior and is intended to guide all of us in our office and construction works but also in our strategic planning and our decision-making processes.

Where appropriate, our Code of Conduct will be modified by host country laws and regulations. Our Code of Conduct is not intended to be a static instrument. It will be continuously developed and adapted to the ever-changing legal and economic environments that affect the ways that we conduct our works in host country.

With this in mind we have revised our Code of Conduct, the foundation of which is our “Vision and Values”. The “Vision and Values” represent the fundamental principles to which Mitaş Energy commits. Mitaş Energy’s image and reputation, as a group that operates in an ethically and legally appropriate manner, is inseparable from the conduct of each of us as we perform our work, everyday.

This Code of Conduct aims to fulfill Mitaş Energy’s below listed intended actions for the implementation of human resources policy and environmental management.

We, the employees of Mitaş Energy, are expected to respect host country laws and regulations, avoid conflicts of interest, protect the Company’s assets, and show consideration and appreciation for the host country local customs, traditions and social mores of host country in which Mitaş Energy conducts business.

In fulfilling our responsibilities within Mitaş Energy, we do not take ethical shortcuts. Improper conduct will never be in Mitaş Energy’s interest.

This Code of Conduct covers every employee of Mitaş Energy and also the employees of our lower tier Sub-Contractor employees.

• Workers’ Code of Conduct will be clearly displayed at the different Project Areas and posted in the Contractor’s vehicles and machinery driving cabs.
• Mitaş Energy commits to implement the ESHS provisions provided for in the Contract.
• Mitaş Energy's personnel are made aware and acknowledge their understanding of the Worker’s Code of Conduct and the associated provisions. The Workers’ Code of Conduct will be initialled by all Mitaş Energy's personnel prior to the start of any physical work at any Project Area.
• Behaviours listed below will considered as dismissal from any Project Area by Mitaş Energy, or by the Implementation Consultant if Mitaş Energy is not acting in due course, if Mitaş Energy's personnel repeatedly commit an offence of serious misconduct despite awareness of the Code of Conduct, and this is without prejudice to any legal action by any public authority for non-compliance with applicable regulations:
  • Drunkenness during working hours, leading to risks for the safety of local inhabitants, customers, users and personnel
  • Punishable statements or attitudes, and sexual harassment in particular
  • Violent behaviour
  • Intentional damage to the assets and interests of others, or the environment
  • Repeated negligence or imprudence leading to damage or prejudice to the environment, the population or properties, particularly breaching provisions intended to prevent the spreading of STD and AIDS
  • Drug use
  • Possession and/or consumption of meat or any other part of an endangered animal or plant as defined in the Washington convention (CITES) and national regulations
  • Entering property of neighbouring people without permission of the landowners or those cultivating/renting the land.

Definition of child is any person less than 15 years of age, unless local minimum age law stipulates a higher age for work or mandatory schooling, in which case the higher age would apply. If, however, local minimum age law is set at 14 years of age in accordance with developing-country exceptions under ILO Convention 138, the lower age will apply.

Definition of young worker is any worker over the age of a child as defined above and under the age of 18.

Mitas Energy; shall not engage in or support the use of neither child labour nor young worker as defined above.

Mitas Energy; shall establish, document, maintain, and effectively communicate to personnel and other interested parties policies and procedures for remediation of children and young worker found to be working in situations which fit the definition of child labour and young worker above, and shall provide adequate support to enable such children to attend and remain in school until no longer a child or a young worker as defined above.

Mitas Energy; shall establish, document, maintain, and effectively communicate to personnel and other interested parties policies and procedures for promotion of education for children covered under ILO recommendation 146 and young workers who are subject to local compulsory education laws or are attending school, including means to ensure that no such child or young worker is employed.

Mitas Energy; shall not expose children or young workers to situations in or outside of the workplace that are hazardous, unsafe or unhealthy.

Mitas Energy; shall not engage in or support the use of forced labour, nor shall personnel be required to lodge “deposits” or identity papers upon commencing employment with Mitas Energy.

Mitas Energy; bearing in mind the prevailing knowledge of the construction industry and of any specific hazards, shall provide a safe and healthy working environment and shall take adequate steps to prevent accidents and injury to health arising out of, associated with or occurring in the course of work, by minimizing, so far as is reasonably predictable, the causes of hazards inherent in the working environment.

Mitas Energy; shall appoint a Contractor’s Health and Safety Officer responsible for the health and safety of all personnel, and accountable for the implementation of the health and safety elements of this policy.

Mitas Energy; shall ensure that all personnel receive regular and recorded health and safety training, and that such training is repeated for new and reassigned personnel.

Mitas Energy; shall establish systems to detect, avoid or respond to potential threats to the health and safety of all personnel.

List of Most Common Hazards:

▪ Slips and falls
▪ Working at heights
▪ Struck-by objects
▪ Moving machineries
▪ Working in excavations
▪ Exposure to chemicals, hazardous or flammable materials
▪ Exposure to electric shocks and burns when touching live components.
▪ Working at heights
▪ Exposure to a variety of hazards such as electric shock, and thermal burn hazards.

Mitas Energy; shall provide, for use by all personnel, clean lavatories, access to potable water, and if appropriate, sanitary facilities for food storage.

Mitas Energy; shall ensure that, if provided for personnel, dormitory facilities are clean, safe, and meet the basic needs of the personnel.

Facilities at site/tower location will be a car parking area, dining and smoking area, toilets. There will be a designated emergency vehicle with first aid kits and fire extinguishers.

All forms related with Health and Safety will be collected at Mitas Energy servers.

Mitaş Energy will share the forms thru this portal with Client and Engineer.

Mitas Energy; shall respect the right of all personnel to join trade unions of their choice and to bargain collectively.

Mitas Energy; shall, in those situations in which the right to freedom of association and collective bargaining are restricted under law, facilitate parallel means of independent and free association and bargaining for all such personnel.

Mitas Energy; shall ensure representatives of such personnel are not the subject of discrimination and that such representatives have access to their members in the workplace.

Mitas Energy; shall not engage in or support discrimination in hiring, remuneration, access to training, promotion, termination or retirement based on race, caste, national origin, religion, disability, gender, sexual orientation, or age.

Mitas Energy; shall not interfere with the exercise of the rights of personnel to observe tenets or practices, or to meet needs relating to race, caste, national origin, religion, disability, gender, sexual orientation.

Mitas Energy; shall not allow behaviour, including gestures, language, and physical contact, that is sexually coercive, abusive or exploitative.

Mitas Energy; shall not engage in or support the use of corporal punishment, mental or physical coercion, and verbal abuse.

Mitas Energy; shall comply with applicable laws and industry standards on working hours. All overtime work shall be reimbursed at a premium rate and under no circumstances shall exceed 12 hours per employee per week.

Other than as permitted, overtime work shall be voluntary.

Where Mitas Energy is party to a collective bargaining agreement freely negotiated with worker organizations representing a significant portion of its workforce, it may require overtime work in accordance with such agreement to meet short-term business demand. Any such agreement will comply with the requirements.

Mitas Energy; shall ensure that wages paid for a standard working month shall always meet at least legal or industry minimum standards and shall be sufficient to meet basic needs of personnel and to provide some discretionary income.

Mitas Energy; shall ensure that deductions from wages are not made for disciplinary purposes, and shall ensure that wage and benefit remuneration are detailed clearly and regularly for workers; Mitas Energy shall also ensure that wages and benefits are rendered in cash (to bank account), in a manner convenient to workers.

Mitas Energy; shall ensure that labour-only contracting arrangements and false apprenticeship schemes are not undertaken in an effort to avoid fulfilling its obligations to personnel under applicable laws pertaining to labour and social security legislation and regulations.

Mitaş Energy HR will not permit any employee work on this project without social security registration.

All employees will have a social security registration in accordance with the host country Laws and Regulations.

Workforce from overseas will at least have a social security registration in host country as well as their International Personal Insurances.

Social security obligation is not just mandatory for Mitaş Energy employees but also a mandatory clause for lower tier sub-contractors.

In case of an incident Mitaş Energy will take full the responsibility of medical treatment of Employees in accordance with the Project Insurance.

Mitas Energy Senior Management shall define Mitas Energy and Metal Construction’s policy for social accountability and labour conditions to ensure that it:

• includes a commitment to conform to all requirements of this policy and requirements to which Mitas Energy subscribes;
• includes a commitment to comply with national and other applicable law, and to respect the international standards (i.e. ISO 9001, 14001, 45001, 37001, 39001) and their interpretation; includes a commitment to continual improvement.
• is effectively documented, implemented, maintained, communicated and is accessible in a comprehensible form to all personnel, including senior management, group presidents, directors, managers, supervisors, and staff, whether directly employed, contracted or otherwise representing Mitas Energy;
• is effectively documented, implemented, maintained, communicated and is accessible in a comprehensible form to all personnel, including senior management, group presidents, directors, managers, supervisors, and staff, whether directly employed, contracted or otherwise representing Mitas Energy;

Mitaş Energy; shall ensure that the worker welfare audit is substantive, Mitaş Energy internal auditors will gather anecdotal evidence through interviews and observation as well as documentary evidence found in Mitaş Energy records. In addition, due to the social objectives of the Mitaş Energy worker welfare accountability system, internal auditors will place a higher priority on verifying the performance of the system than on the existence of documentation.

Pursuant to internal auditor documentation requirements, each worker welfare policy element shall be addressed in the audit report. In addition, internal auditors will include notations on any accepted deviations, a brief overall description of the facility and the format of the interviews. External and internal photographs are encouraged, taking care to not record any proprietary equipment or process.

1. Receive and Register Each grievance is received through the complainant’s written and signed application. As well as that complaints will also be delivered thru internal representative of Labour Union. All complaints and suggestions will be collected at Mitas Energy server.

The application is received either by Suggestion/complaint box or directly by HR staff.

Grievances are received and registered by HR staff. Contact details will be sought from the complainant. The grievance is recorded in the Grievance Application Form and grievance issue is reviewed and investigated. It is important that communication between all interested parties is maintained.

A specific registry number for each grievance is assigned for each GAF (Grievance Application Form). The date of registry (when the application is given to the HR staff) is added to “Status” section of the form. The abbreviations for the status sections are as follows:

REG: Registration
INV: Review and Investigation
RES: Resolution
REP: Reporting

When the GAF is filled a copy of the GAF in which the digital scanned copy of the application letter with complaint’s letter of application is added and it is submitted to Management and to HR manager as well.

The grievance is registered to Grievance Log, with date, name and location/venue of the complaint and full description of the grievance.

Considering the confidentiality, the complainant may have an objection to submitting a written formal application form. In this case.

i) He/she has is offered help by HR staff to write a grievance letter. The grievance letter written by HR staff is read to the complainant and verbally confirmed by the complainant.
ii) The complainant may reject submitting any form of grievance letter. In this case, the GAF is fulfilled by the HR staff and a notice is written on the form that the complainant refused to submit written grievance form.
iii) Grievances are registered and logged regardless of whether they were received in written or verbal forms and whether they are recurrent ones or grievances that are eventually dismissed as unreasonable.

Those who wish to register a grievance can remain anonymous and should feel free to give as little personal information as they wish. 1. Receive and Register Each grievance is received through the complainant’s written and signed application. As well as that complaints will also be delivered thru internal representative of Labour Union. All complaints and suggestions will be collected at Mitas Energy server.

The application is received either by Suggestion/complaint box or directly by HR staff.

Grievances are received and registered by HR staff. Contact details will be sought from the complainant. The grievance is recorded in the Grievance Application Form and grievance issue is reviewed and investigated. It is important that communication between all interested parties is maintained.

A specific registry number for each grievance is assigned for each GAF (Grievance Application Form). The date of registry (when the application is given to the HR staff) is added to “Status” section of the form. The abbreviations for the status sections are as follows:

REG: Registration
INV: Review and Investigation
RES: Resolution
REP: Reporting

When the GAF is filled a copy of the GAF in which the digital scanned copy of the application letter with complaint’s letter of application is added and it is submitted to Management and to HR manager as well.

The grievance is registered to Grievance Log, with date, name and location/venue of the complaint and full description of the grievance.

Considering the confidentiality, the complainant may have an objection to submitting a written formal application form. In this case.

i) He/she has is offered help by HR staff to write a grievance letter. The grievance letter written by HR staff is read to the complainant and verbally confirmed by the complainant.
ii) The complainant may reject submitting any form of grievance letter. In this case, the GAF is fulfilled by the HR staff and a notice is written on the form that the complainant refused to submit written grievance form.
iii) Grievances are registered and logged regardless of whether they were received in written or verbal forms and whether they are recurrent ones or grievances that are eventually dismissed as unreasonable.

Those who wish to register a grievance can remain anonymous and should feel free to give as little personal information as they wish. 2. Review and Investigate After the review, HR Manager decides whether the grievance will be resolved by.

i) Human Resources Team,
ii) Emergency Response Team,
iii) HSE Team,
iv) Other related departments
v) Community Relations Department.

HR Team is responsible for the grievances about employment issues. Employment Strategy Procedure is recognized as guide for solution of employment related grievances.

For those grievances, which falls into responsibility of HR, a field survey for the investigation is done by HR staff.

Once the survey is conducted, comments about the grievance are included in the GAF with photos. The inspection date (INS) is added to GAF and to the Grievance Database.

The proposed action is determined and reported in the GAF and at the same time within TWO DAYS AFTER APPLICATION, the grievance owner shall be informed about the “proposed action”.

It can be the case that a grievance may not have a valid basis, or it can be ineligible, and no further action may be taken. If the response is that the grievance does not require action by Mitaş Energy to resolve it, all considerations are documented and included in both the response and Mitaş Energy systems for grievance tracking for further reference. CRT tells community members that no further action will be taken, including a detailed and respectful explanation, together with compelling evidence of why it cannot be accepted. In this case “Review and Investigation” boxes (INV) of the GAF and the Grievance Log is filled but “Resolution” (RES) boxes are left empty. When the situation is reported in GAF’s “action taken” section, the “Finalization” (FIN) boxes of GAF and Grievance Log are filled as well, which will mean that the file is closed. 3. Resolution The proposed action is taken as soon as possible.

Every stage of the action is reported in “Action taken” part of the GAF with photos.

The timeframe for the resolution of the grievance is FOURTEEN DAYS following the application of the complainant.

If more time is required for more complex and complicated resolutions, it is reported in the GAF with details involving reasons and giving the technical details examining the requirements of the resolution action in terms of time constraint.

All accepted grievances are concluded with a solution which involves a reconstruction, maintenance, or a payment.

When the resolution phase is finished it is reported in GAF “action taken” section with visual documents and “Reporting” boxes in both GAF document and Grievance Log is filled which shows that the file is “closed” and the updated version of the GAF is sent to Mitaş Energy Head Office HR department. Prior to confirmation of Head Office, the hard copy of the document is kept in a folder. 4. Immediate/Urgent Issues Regardless of general response and resolution timeframes, some grievances may require immediate attention, for example, an urgent safety issue or where it concerns the livelihood of vulnerable people in jeopardy. 5. Reporting Apart from sending the updated GAFs during the process of handling each grievance application, the Grievance Log is transmitted to Mitaş Energy HO HR department weekly, which has to be transmitted to project management as well.

Mitaş Energy Project Manager and Head Office are specifically informed about the main issues and significant events in order to make the grievance mechanism function better and to avoid further grievance issues if possible.

One the primary goals of Mitaş Energy, is the preservation of cultural heritage. Cultural heritage consists of individual objects, structures, or aggregate collections. It is material which has significance that may be artistic, historical, scientific, religious, or social, and it is an invaluable and irreplaceable legacy that must be preserved for future generations.

In striving to achieve this goal, Mitaş Energy assumes certain obligations to the cultural heritage, to its Clients and the Engineers, to the construction profession, and to society as a whole. This document, Mitaş Energy Code of Conduct, sets the principles that Mitaş Energy and sub-contractors who are involved in the care of cultural heritage during construction activities.

1. All construction activities are governed by an informed respect for the cultural heritage, its unique character and significance, and the people or person who created it.
2. While recognizing the importance cultural heritage, Mitaş Energy will perform a good practice for the preservation of cultural heritage.
3. Mitaş Energy will strive to select methods and materials that, to the best of current knowledge, do not adversely affect cultural property or its future examination, scientific investigation, treatment, or function.
4. Mitaş Energy will document examination, scientific investigation, and treatment of cultural heritage by expert records and reports.
5. Mitaş Energy will recognize a responsibility for preventive conservation by endeavouring to limit damage or deterioration to cultural property, providing guidelines for continuing use and care, recommending appropriate environmental conditions for storage and exhibition, and encouraging proper procedures for handling, packing, and removal.

Mitaş Energy will warn the inhabitants of local communities in advance about activities that are likely to take place in project, this will help reduce their concerns. Mitaş Energy public liaison officer whom, will be the point of contact for enquiries or complaints, this will stand as a good practice that Mitaş Energy is taking responsibility for its actions and are aware of the inhabitants of local community.

This appointed employee will work with the local residents, the business community and other inhabitants. This liaison officer will be always reachable while the site is in use or not. Mitaş Energy will announce to necessary persons on the site for the officer’s contact information. This will also include information such as Mitaş Energy’s names, the name of the liaison officer, and a contact number and address for complaints. The liaison officer will be responsible for logging complaints and taking appropriate action.

Please remember this code is for guidance only for every corporate project. Every Mitaş Energy employee (including sub-contractor or vendor employees) shall remember to contact their project’s legal adviser if they are not sure of their legal obligations. Mitaş Energy will train their employees about the requirements stated in this code of conduct thus every employee will also confirm that they are working to the standards shown in this code of conduct.

Any enquiries ring the public liaison officer in advance before any work starts, Mitaş Energy will inform related person(s), both residential and commercial, about the proposed work. This information will include a start and likely finish date, and the contact’s name and number of the public liaison officer. If works are to go beyond our standard working hours and we have agreed to this, Mitaş Energy will send further information giving details of the changes.

Cultural Heritage reporting can be made thru Mitas Energy server. Guideline is detailed in “Cultural Heritage and Chance Finds Procedure”.

Prior to any construction works and/or activities the presence of water supplies to properties or for supplying water to livestock will be identified by Mitaş Energy.

Mitaş Energy will either reroute or fence off the water supply and other agricultural water supply pipes in order not to create any harm during construction activities and/or works

In case of a harm to mentioned water supplies; Mitaş Energy will promptly notify Landowners thus Mitaş Energy will provide alternative supplies with plans outlining deemed necessary rerouting or provision of water supplies.