Code of Business Ethics and Conduct

Our Ethics and Compliance Policy

1. Introduction

These principles have been adopted to define the standards that employees of SABAH YATAK SAN. VE TİC. A.Ş. (hereinafter referred to as “Sabah Bedding”) are required to adhere to.

The principles outline what is expected of Sabah Bedding employees, regardless of their identity, background, or place of work.

The standards are based on the following core values:

Internationally recognized human rights
Ethical and legal conduct
Professionalism

These rules apply to all levels of management and employees at Sabah Bedding. All employees must adhere to these principles and requirements, and they should refer to these rules as guidance when acting on behalf of Sabah Bedding.

This policy has been prepared to outline the fundamental ethical rules that all Sabah Bedding employees must follow and is intended to guide their decisions and behavior while fulfilling their responsibilities. Employees are expected to act in accordance with general moral principles and with common sense. This policy may be updated or changed at any time. Sabah Bedding is always open to suggestions for changes regarding these rules from employees.

2. Employee Rights and Our Work Relations

The respectable image and corporate brand that Sabah Bedding has built as a result of its 40 years of experience are its most valuable assets. To protect and enhance Sabah Bedding’s corporate reputation, the fundamental business principles that all employees across the company must adhere to in their activities are listed below.

Sabah Bedding expects all of its employees to understand and embrace the company’s values and ethical principles as they carry out their duties.

2.1. Honesty

Sabah Bedding places honesty, transparency, and high business ethics above all in all its activities and expects the same values from all parties it collaborates with.

Sabah Bedding does not engage in any behavior that could undermine mutual trust in its business relationships with its employees, suppliers, competitors, the environment, society, and humanity.

2.2. Confidentiality

Confidential information includes any financial, strategic, technical, or commercial information that belongs to the company and is unknown to third parties, the disclosure of which could cause harm to the company and/or its stakeholders or provide benefits to others. This also includes matters regulated under confidentiality agreements made with third parties.

Sabah Bedding expects its employees to take care in protecting information related to Sabah Bedding and all its stakeholders. Employees should only share this information with authorized individuals within the scope of designated permissions.

Confidential information must not be shared with third parties upon leaving Sabah Bedding. Employees are required to return all documents or electronic copies belonging to Sabah Bedding that they received during their employment.

New employees joining Sabah Bedding are also prohibited from sharing any confidential information related to their previous employers within Sabah Bedding.

Sabah Bedding expects its employees to protect the confidentiality of sensitive financial information, trade secrets, information and documents related to personnel rights, agreements made with business partners, and any other information or documents that could potentially weaken Sabah Bedding's competitive strength.

Sabah Bedding expects its employees to refrain from sharing obtained or possessed information with unauthorized individuals, whether internally or externally, or from using such information for speculative purposes (directly or indirectly).

2.3. Fair Working Environment

Sabah Bedding believes in and supports the rights and freedoms of individuals wherever it operates.

In line with this, Sabah Bedding does not discriminate under any circumstances based on individuals' ethnicity, gender, race, nationality, economic status, religion, or other beliefs. This applies to recruitment and promotions, working conditions, and all relationships with customers and suppliers.

Sabah Bedding is responsible for ensuring that working conditions and the products it manufactures comply with standards for human health and safety.

Every employee has the right to be treated fairly, courteously, and respectfully by

Our Ethics and Compliance Policy

1. Introduction

These principles have been adopted to define the standards that employees of SABAH YATAK SAN. VE TİC. A.Ş. (hereinafter referred to as “Sabah Bedding”) are required to adhere to.

The principles outline what is expected of Sabah Bedding employees, regardless of their identity, background, or place of work.

The standards are based on the following core values:

Internationally recognized human rights
Ethical and legal conduct
Professionalism

2. Employee Rights and Our Work Relations

Sabah Bedding expects all of its employees to understand and embrace the company’s values and ethical principles as they carry out their duties.

2.1. Honesty

Sabah Bedding places honesty, transparency, and high business ethics above all in all its activities and expects the same values from all parties it collaborates with.

Sabah Bedding does not engage in any behavior that could undermine mutual trust in its business relationships with its employees, suppliers, competitors, the environment, society, and humanity.

2.2. Confidentiality

New employees joining Sabah Bedding are also prohibited from sharing any confidential information related to their previous employers within Sabah Bedding.

2.3. Fair Working Environment

Sabah Bedding believes in and supports the rights and freedoms of individuals wherever it operates.

Sabah Bedding is responsible for ensuring that working conditions and the products it manufactures comply with standards for human health and safety.

Every employee has the right to be treated fairly, courteously, and respectfully by their subordinates, supervisors, and colleagues. A fair, healthy, and safe working environment, where respect for employees and compliance with all relevant legal regulations is ensured, will enhance employees' performance, development, and commitment.

2.4. Compliance with the Law

Sabah Bedding operates in compliance with the laws of the country and is obligated to adhere to the laws and regulations of different legal systems in the countries where it conducts business worldwide. Sabah Bedding recognizes and respects the laws, regulations, relevant legislation, and traditions of all the countries in which it operates. It organizes training sessions and conducts necessary audits to ensure that all employees act in accordance with the legal processes and social norms of both the countries they serve and the host countries.

2.5. Human Resources and Human Rights

The fundamental principles of Sabah Bedding, which are indispensable for ensuring quality management of human resources and protecting human rights, are summarized below:

Sabah Bedding respects human rights and ensures that all employees have a working environment that is in line with these rights.
Discrimination against refugee and migrant workers is not permitted, and necessary policies are implemented to protect their rights.
Sabah Bedding supports employees' freedom of association and their right to collective bargaining, taking necessary steps to protect these rights.
Sabah Bedding does not permit any practices involving forced labor or child labor.
It protects employees' rights through fair compensation policies and ensures a balance between work and life.
Sabah Bedding promotes collaboration among employees in the workplace.
When hiring and promoting employees, Sabah Bedding bases its decisions primarily on the qualifications, skills, and competencies required for the job.
It ensures that employees are in positions where they can utilize their potential, create value, and contribute to achieving the company's goals.
It ensures that employees fully exercise their personal rights.
It provides the necessary training and development opportunities within its resources to help employees improve themselves and perform their jobs better.

2.6. Quality, Environment, Occupational Health and Safety, and Continuous Improvement

In the areas of Quality, Environment, Occupational Health, and Safety, Sabah Bedding has established and implemented an integrated management system based on a management-by-objectives approach, aligned with risks and the environmental impacts of our activities, to prevent pollution, injuries, and health issues.

2.6.1. Energy Efficiency and Combating Climate Change

Sabah Bedding continuously undertakes improvement efforts to increase energy efficiency and support programs aimed at combating climate change.

2.6.2. Sustainable Supply Chain

Sabah Bedding adopts sustainable practices with its suppliers and promotes high standards in waste management, energy efficiency, and environmental performance.

2.6.3. Occupational Health and Safety

Sabah Bedding conducts its activities in accordance with occupational health and safety standards to create a safe and healthy working environment.
Sabah Bedding regularly provides occupational health and safety training to its employees and ensures that this training remains up to date.

2.6.4. Monitoring Occupational Health and Safety Performance

Sabah Bedding regularly monitors and reports on the health and safety performance of its employees.

2.7. Public Activities

Sabah Bedding conducts its relations with official institutions and organizations within the framework of ethical principles and in compliance with laws and regulations.

3. Relationships with Business Partners, Customers, Suppliers, and Other Representatives

The following core principles guide Sabah Bedding's relationships with its stakeholders:

3.1. Human Rights

Sabah Bedding expects its business partners, customers, and suppliers to support and respect internationally recognized human rights.
Sabah Bedding does not participate in human rights violations and ensures that the parties it collaborates with act in accordance with these values.

3.2. Relations with Government Institutions

Complying with the legislation of the countries where business relationships are conducted or considered.
Managing, recording, and reporting business and accounting systems in compliance with the law.

3.3. Social Responsibility

Supporting efforts that contribute to economic and social development.
Being sensitive to issues concerning society and supporting efforts for improvement.

3.4. Community Support

Participating in projects and social responsibility activities that benefit society and actively supporting local communities.

3.5. Customer Relations

Creating value for customers and meeting their needs and demands at the highest level.
Producing high-quality products.
Establishing a long-term environment of trust in our relationships with customers.
Aiming to become a preferred brand among customers by enhancing sales and post-sales customer satisfaction.
Avoiding providing misleading or incomplete information to customers.

3.6. Supplier Relations

Collaborating to create value in supplier business relationships.
Establishing open, direct, and proper communication with suppliers.

3.7. Competitor Relations and Competition

Avoiding, under all circumstances, any direct or indirect behaviors that aim to prevent, distort, or limit the competitive power of competitors or other individuals or companies, except as permitted by law.
Avoiding information exchange or discussions with competitors for the purpose of creating competitive conditions.

3.8. Transparency and Accountability

Sabah Bedding is committed to ensuring transparency in all its activities and prioritizing accountability in its financial relationships with business partners.

4. Responsibilities of Employees

The primary responsibility of Sabah Bedding employees is to ensure that the name “Sabah” is synonymous with professionalism, integrity, and honesty, and to elevate it to the next level. In this context, the following behaviors are expected from Sabah Bedding employees:

Always complying with the laws.
Conducting their work and transactions within the limits of their given authority, and consulting their managers on matters beyond their authority.
Performing their duties within the framework of fundamental moral and human values.
Acting fairly, in good faith, and with understanding in all relationships for the purpose of common benefit.
Avoiding any form of unjust gain, accepting bribes from any person or organization, or offering bribes to any person or organization, regardless of the circumstances.
Acting in accordance with all principles and practices that support the relevant rules of business ethics in all activities.
Refraining from any actions, statements, or written communications that could bind the company without authorization.
Avoiding behaviors that could disturb or harm other employees or disrupt the harmony of the working environment.
Protecting all of the company’s assets, including document and information systems, from damage, misuse, theft, and sabotage.
Avoiding the use of working hours and company resources, directly or indirectly, for personal gain.

4.1. Asset and Information Management

4.1.1. Use of Company Resources

The comprehensive Sabah Bedding Policies regarding the use of company resources are outlined below:

4.1.1.1. Internet and Email Policy

Employees should use internet access and email for business purposes only.
Sabah Bedding’s internet access and email system are company resources. Sabah Bedding reserves the right to read, monitor, and copy internet usage and emails.
Employees must exercise due care to prevent the disclosure of confidential information and to avoid obtaining illegal information.

4.1.1.2. Compliance with Information Technology Policies

Employees are always required to comply with Information Technology policies. The policies are as follows:

Not using unlicensed software.
Not compromising on connection security.
Not accessing or downloading content from adult, gambling, harmful, or illegal websites.

4.1.1.3. Equipment and Devices

Office equipment, office furniture, fax machines, computers, software, hardware, devices, and similar equipment are the property of Sabah Bedding and may not be used for personal purposes.

4.1.1.4. Personal Affairs

Sabah Bedding employees may not use company resources for conducting personal affairs.

4.1.2. Information Management

Ensuring that all legally required records are maintained.
Avoiding responding to requests for confidential information about the company's affairs from third parties without approval from senior management.

4.1.3. Security and Crisis Management

Taking necessary measures to protect company employees, information, information systems, and administrative facilities from natural disasters.
Taking all personal precautions to prevent theft or loss of company assets.

4.2. Avoiding Conflicts of Interest

A conflict of interest is defined as a situation where the interests of an employee's family, friends, or associated individuals and organizations may come into conflict with the interests of the company, preventing the employee from performing their duties impartially.

Sabah Bedding expects its employees to avoid working conditions that may lead to conflicts of interest and to immediately inform their manager in the event of a potential conflict of interest.

4.2.1. Avoiding Related Party Transactions or Personal Interest Transactions

Avoiding the use of one's position or power to gain unfair advantage or income for third parties, related parties, or any individual.
Avoiding involvement in conflicts of interest related to the responsibilities undertaken.
Avoiding actions that waste other employees' time or distract them during the execution of work, as well as situations that hinder concentration on primary tasks.
Immediately notifying the relevant manager if an employee has a first-degree family relationship with a decision-maker in the same industry, whether a customer or supplier.
Employees must disclose if they hold shares in another company or investment. Employees are required to promptly inform at least two levels of their supervisors of any status changes in this context or similar situations that could be perceived as a conflict of interest.

4.2.2. Receiving and Giving Gifts

When establishing or maintaining business relationships with individuals or organizations intending to do business with Sabah Bedding:

Except for gifts and activities based on business tradition, general culture, and customs, any gift or activity that could compromise independent thinking and decision-making should be avoided, whether accepting or offering.
It is essential to avoid requesting discounts or materials from suppliers, customers, or third parties that could be perceived as inappropriate or outside of normal business practices; similarly, avoid offering such to third parties or accepting them if offered.

4.2.3. Information Leakage

Employees must refrain from disclosing any confidential information belonging to Sabah Bedding to third parties. Employees will be personally responsible for all consequences arising from violations of this provision. They must fully understand that trading in confidential information constitutes a violation of the law. Additionally, any such behavior would breach the employee's employment contract, and such actions should never be carried out under any circumstances.

4.3. Records and Files

4.3.1. Accurate and Complete Business Records

Employees must act in good faith to prevent any deviation from the accuracy of information in Sabah Bedding’s records and documents, in internal and external relations, or in the use of any communication channels, including telephone and electronic communication tools.

4.3.2. Financial Reporting

All resources, assets, liabilities, and documents of Sabah Bedding are recorded in accordance with the relevant legal provisions and Generally Accepted Accounting Principles (GAAP).

4.3.3. Cooperation with Auditors

Sabah Bedding employees must cooperate with internal and external auditors during the review of Sabah Bedding’s books, records, and activities.

5. Responsibilities of Managers

Ensuring the establishment and continuity of a company culture and working environment within the framework of ethical rules.
Representing ethical rules through their behavior and attitudes, and communicating the ethical rules to employees.
Being open and receptive to questions, complaints, suggestions, and feedback regarding ethical rules.
Guiding employees on necessary actions and promptly reporting feedback to the Ethics Committee.
Establishing and improving a structure within their area of responsibility that minimizes risks related to ethics.
Implementing the necessary methods and practices to ensure compliance with ethical rules.

6. Reporting and Resolving Non-Compliance to the Ethics Committee

Any actions that fall outside the scope of the Code of Business Ethics or the legal regulations to which our company is bound must be reported by our employees to their managers, the Human Resources Department, or the Ethics Committee as soon as they are identified. Reports are resolved through the evaluation of the company's internal processes and mechanisms, and the resulting decision is implemented. Actions related to violations of company principles and policies, the Code of Business Ethics, or procedures are handled according to the Disciplinary Management Procedure.

Disciplinary management sanctions are also applied to individuals who approve, neglect, or fail to report improper behaviors and activities that deviate from the rules, despite being aware of such matters. Our zero-tolerance policy is strictly enforced against those who display negative attitudes or behavior towards members of the disciplinary review committees.

Non-compliance with the Code of Business Ethics and Conduct is reviewed and resolved within Sabah Bedding's Ethics Committee. Our Ethics Committee is established to prevent conflicts of interest within the scope of Sabah Bedding's Code of Business Ethics and Conduct and to evaluate reports regarding violations of ethical rules.

Our employees and all stakeholders can easily submit any opinions, requests, or complaints directly to the Ethics Committee via email at [email protected]

7. Ethics Committee Working Principles

The identity of individuals who make notifications or complaints to the Ethics Committee is kept confidential.
Individuals who make notifications or complaints to the Ethics Committee are protected under the committee's confidentiality policy and cannot be subjected to pressure, discrimination, or mobbing as a result of their reports.
The Ethics Committee manages the evaluation and decision-making process with a sensitivity to confidentiality.
The Ethics Committee has the authority to request information, documents, and evidence directly from the relevant unit involved in the investigation. It may review all obtained information and documents only in relation to the specific evaluation or complaint.
The evaluation process is documented in writing from the moment a notification or complaint is received. Information, evidence, and documents are attached to this record.
The relevant record is signed by the Ethics Committee chairperson and its members.
The evaluation is handled as quickly as possible, and a conclusion is reached promptly while ensuring accuracy.
The decisions made by the committee are implemented immediately.
Detailed information about the decision is provided to the relevant departments and authorities.
The committee chairperson and members perform their duties independently and without influence from their department managers or the internal hierarchy of the organization. They are not subject to any external pressure or persuasion.
The committee may seek expert opinions when necessary and, while maintaining confidentiality, utilize these expert insights during the evaluation process.
The evaluation process is carried out in accordance with the "Discipline Management Procedure."

8. Other Responsibilities

The Board of Directors is responsible for ensuring the effective implementation and enforcement of Sabah Bedding's ethical principles or the Business Ethics created in this context, as well as supporting these rules within the company's specific regulations.

All policies related to Ethical Principles are reviewed, revised, documented, and announced to Sabah Bedding upon the recommendation of the Board of Directors by the Management Systems Manager, with revisions approved by the Board of Directors.

9. Failure to Comply with Ethical Rules

Those who do not comply with the principles of business ethics and/or company policies and procedures will be subject to a disciplinary investigation that may lead to the termination of their employment contract. The investigation in the discipline process also applies to those who approve or manage inappropriate behaviors that violate ethical principles, as well as to those who fail to report a possible violation they are aware of and initiate the necessary process.

Non-Retaliation Policy

Employees cannot be subjected to retaliation for reporting a suspected or actual violation of the ethical policy in good faith. Retaliation is a serious violation of Ethical Principles and should be reported promptly.

10. Rules Violations Zero Tolerance Policy

Sabah Bedding, Ethical Principles violations, failure to report violations correctly, or retaliation against those who report violations with a zero tolerance approach. Sabah Bedding may apply disciplinary measures to employees who violate these rules or retaliate against whistleblowers.

APPROVAL

CHAIRMAN OF THE BOARD

LEVENT SOLMAZ

CHAIRMAN OF THE BORD