ETHICS & COMPLIANCE

CODE OF BUSINESS CONDUCT

At ENKA we work to sustain a culture in which behaviors and decisions at all levels are fully aligned with ENKA’s core values and business principles.

Our Legal Department monitors external legal and regulatory developments and provides legal advice. ENKA Employees implement required policies, standards and procedures and embed requirements in day-to-day processes, with support from Corporate Quality, HSE and HR Departments.

Our leaders play an essential role, setting the right example through their own behavior. They also lay out the clear expectation that all business plans and activities are undertaken in a responsible, safe and compliant manner.

Our company-wide Code of Conduct helps staff put our Vision and Values into practice. The code defines basic rules, standards, and behaviors for ENKA employees and directs them to available resources and support.

We also expect that subcontractors and suppliers understand and meet ENKA’s robust requirements. Our contracts with them include requirements for adherence to the ENKA business principles or equivalent, and that staff working on behalf of ENKA behave in a manner that is consistent with the ENKA Code of Conduct and ENKA Supplier Code of Conduct.

Download Our Code of Conduct

Download Supplier Code of Conduct

HUMAN RIGHTS APPROACH

Respect for human rights is a fundamental value of ENKA İnşaat ve Sanayi A.Ş. (ENKA). At ENKA, we strive to respect and promote human rights in accordance with the UN Guiding Principles on Business and Human Rights. Our aim is to create a positive presence and legacy on the communities and societies in which we operate for having a required degree of social performance. Our Code of Business Conduct, Sustainability Policy and Health, Safety and Environment Polices as well as ENKA Social Community Engagement Management principles are corner stones in these endeavors.

The latest version of our Code of Business Conduct was launched on 27/ 12/ 2018. It is available in Turkish, English, Russian and Arabic for all countries we operate in and distributed throughout the Company. It reflects an in-depth global consultation on the salient human rights risks of the Company, which are the most severe potential impacts associated with our business. Our Code of Business Conduct applies to all projects and business units (i.e. corporate offices, representative offices and group companies) under the administrative control of ENKA and is consistently monitored throughout our operations.

It includes the following eleven components:

  • Respect for Human Rights
  • Community and Stakeholder Engagement
  • Diversity and Inclusion
  • Freedom of Association and Collective Bargaining
  • Safe and Healthy Workplace
  • Workplace Security
  • Forced Labor and Human Trafficking
  • Child Labor
  • Fair Employment Practices
  • Employee Personal Information
  • Guidance and Reporting for Employees

At ENKA, it is every employee’s responsibility to maintain a work environment that reflects respect for human rights and is free from all discrimination and harassment, aligned with our Code of Business Conduct. If any employee believes that someone is violating the Code and/or the law, they are asked to report it immediately to their manager, Corporate Sustainability Department, ENKA Legal Department or Ethics Hotline. Potential issues or received allegations will be addressed and investigated internally, as well as co-operative participation with internal investigations if needed. In cases of violating the law, our Code and human rights values may lead to disciplinary, legal or criminal action being taken against individuals. We also perform ethics & compliance audits against the ENKA Code of Business Conduct, within the Company and third party premises, having a business relation with ENKA, in order to ensure compliance. Our goal is to reach the targets we set by the year 2027.

ENKA considers audits and assessments as a core element of continual improvement and risk identification. Internal and external audits that are performed by ENKA in the course of year 2018 are listed as follows:

  • ENKA Internal Audit Team conducted 4 Project and 1 Subsidiary Audits within the framework of ISO 9001:2015, Corporate Quality Requirements, Corporate Finance & Accounting Requirements, Corporate Human Resources and Administration Requirements and compliance to local and international laws and regulations.
  • ENKA Corporate Quality Team performed 4 Quality Audits to Projects within the framework of ISO 9001:2015, Corporate Quality Requirements and Customer Requirements.
  • ENKA Internal Audit Team performed 4 Corporate Department Audits within the framework of ISO 9001:2015, Corporate Quality Requirements, ENKA Internal Procedures and compliance to laws and regulations.
  • ENKA Corporate HSE Team performed 18 HSE Audits to Projects and 4 to Subsidiaries within the framework of ISO 14001, OHSAS 18001 and Corporate HSE Requirements.

We also use Supplier Sustainability Audit Program as a tool to manage the supply chain risks and ensure that our suppliers and subcontractors complies with ENKA’s and international standards. We performed 2 supplier sustainability audits to assess their compliance on environmental, social and ethical management, human rights and labor, occupational health and safety and anti-bribery and anti-corruption policies. We aim to widen our area of assessment with more suppliers and subcontractors with the contributions of our subsidiaries each year.

In addition to the audits performed by our audit teams, ENKA’s Management Systems are assessed by 3rd party auditors. Accordingly each year;

  • BSI performs Quality Management and HSE Management systems audit annually against ISO 9001, ISO 14001 and OHSAS 18001 standards
  • TÜV Nord and ASME perform Quality Control Management audits pertaining to technical capacity of business applications and workforce of the company against ASME codes and standards
  • KPMG performs annual financial statements audits against the requirements of International Financial Reporting Standards (“IFRS”), United States Generally Accepted Accounting Principles (“US GAAP”) and other standards promulgated by the regulators.

We are also working with our peers and other parties of the industry, governments and non-governmental organizations to support the integration of sustainability practices and business ethics into business strategies. Within this context, ENKA became an official member of the Business Council for Sustainable Development Turkey (BCSD) as of August 2018 and Ethics and Reputation Society (TEİD) as of September 2018.

Please be advised that ENKA İnşaat ve Sanayi A.Ş. (ENKA), as Data Controller, collects, processes and, in case of need, transfers the personal data of its employees. ENKA, as a responsible employer, displays sensitivity at highest level to the protection of your personal data, and, in compliance with the principles of good governance, attaches great importance and acts with discernment in the processing and storage of the personal data of all its employees in accordance with the provisions of the Law No. 6698 on Protection of Personal Data.

Beyond the personal identification information, the communication information as well as the information on age, gender and state of health, marital status and demographic information such as country of origin of the employees of our Company, which are considered as personal data in the relevant laws, also any further information thereon such as their history of employment by our Company, their levels of education, any seminars and any in-works trainings they participated in as well as any information needed for the fulfillment of our legal taxation and social security obligations, are processed and stored by our Company always in compliance with the relevant applicable legal provisions.

ENKA performs the collection and processing of the personal data of its employees only on the condition that it is:

  • mandatorily provided for by the applicable laws to do so;
  • directly related to the conclusion or fulfillment of a contract;
  • mandatory for us to be able to perform our legal obligations;
  • mandatory for the establishment, exercise or protection of any rights of ENKA;
  • based on the existence of a legitimate interest of ENKA, provided that your fundamental rights and freedoms are not violated thereby;

and, moreover, any personal data are only then transferred by ENKA if it is mandatory for the protection of the life or of the bodily integrity of its employees or of any other person.
Any specific information that is identified as private information of confidential and special nature in the Law on Protection of Personal Data are processed and transferred only if clearly provided for by laws to do so, and any information on the state of health or the sexual life just for the purposes of protecting the public health, operations of preventive medicine, medical diagnosis, treatment and nursing services, planning and management of health-care services as well as their financing.

Your personal data are either provided to us by yourself in the documents you presented at the time of your job application such as your curriculum vitae (CV), copy of your identity card, your medical report, criminal record etc., or requested by us from yourself for the completion of your employment process, or collected by us by virtue of correspondence with public agencies and institutions or via third party firms involved in.

For employment abroad in any overseas projects of ENKA, our expatriate employees’ various documents such as passports, diplomas, identity cards, medical reports and any additionally requested health test reports containing personal data thereof, may be required, due to legal requirements, to be forwarded to any host countries of employment with insufficient protection of personal data, for the purpose of conclusion of overseas employment contracts between ENKA and its expatriate employees as well as for the issuance of the required work permits for them in such host countries employment where their personal data are subject to sharing with several authorities involved in the process of issuance of such work permits as provided for in the respective laws thereof. If in any host country of employment no sufficient protection is provided for personal data, the data controller assigned by ENKA for such host country of employment will guarantee in writing that sufficient protection will be provided by our Company for the personal data, and thus the necessary authorization procedure will be completed. Personal data containing personal files of our expatriate employees working in our overseas jobsites, are physically safekept by the Human Resources Departments of our overseas jobsites for such limited period of time as legally provided, and that under consideration of our legal obligation to provide such personal data to public agencies and institutions and judicial authorities if so requested by the same.

Please be advised that your personal data will be processed, stored and safekept by our Company throughout your term of employment if no longer period of time is provided by the applicable laws, without prejudice to the statute of limitation for legal proceedings, i.e. the prescription. Moreover, please be also advised that our Company will not use your personal data, without your explicit consent, for any other purpose as provided herein, and that your personal data will be made available and transferred, in accordance with the applicable legal provisions, only to public agencies and institutions and judicial authorities if so requested by them within the applicable legal periods of time, as well as to our business partners and group companies in compliance with our human resources policies.

The necessary safety and security measures required to be taken for preventing any unauthorized access to and any illegal processing of your recorded and safekept personal data are duly identified, and for the purpose of preventing any illegal disclosure and any misuse of your personal data by the personnel having access thereto for processing purpose, all the necessary administrative and technical measures such as limitation of the authorizations of and conclusion of confidentiality agreements with such personnel having access to your personal data, are duly taken. Should any amendments be made in the applicable legislation, also the principles specified hereunder will be amended accordingly. In case of any such amendment, you will be informed properly thereabout.

Please be advised that you are entitled, in accordance with the provisions of the Law No. 6698 on Protection of Personal Data, Article 11, regarding your rights on the protection of your personal data, to apply to our Company via e-mail to “enka@enka.hs03.kep.tr” in order to:

  • get detailed information about your rights on the protection of your personal data;
  • learn whether your personal data are processed or not;
  • request information if your personal data are processed;
  • learn the purpose of processing of your personal data and whether they are used for the intended purposes;
  • learn whether your personal data are transferred or not, and if transferred, the third party(ies) to whom they are transferred;
  • request the rectification of any incomplete or inaccurate personal data, if any;
  • request the erasure or destruction of your personal data under such conditions as laid down in the applicable legislation;
  • request the notification of your aforementioned requests for rectification, erasure or destruction of your personal data to such third party(ies) to whom your personal data is transferred to;
  • request compensation for any damage, if any, arising from any unlawful processing of your personal data.

Wishes and Demands of Data Subjects (i.e. persons whose personal data are processed)

In accordance with the provisions of the Law on Protection of Personal Data, Article 10, ENKA informs the Data Subjects about their rights on the protection of their personal data and leads them the way how to make usage of such rights. For the purpose of assessment of the rights of Data Subjects and providing them the necessary information, all required company-internal steps are being taken and all administrative and technical regulations are being made by ENKA in compliance with the provisions of the Law on Protection of Personal Data, Article 13.

In this respect, Data Subjects may lodge, in writing, to ENKA their applications about their demands concerning their rights specified in the ENKA Personal Data Protection and Processing Policy, by filling in and signing the so-called Data Subject Personal Data Application Form provided at the address www.enka.com and following such method as stated therein or designated by the Personal Data Protection Board, and adding thereto their identification information and documents.

Such application may also be made by virtue of a third party for and on behalf of the Data Subject upon presentation of a notarial authentication, i.e. power of attorney by the Data Subject to such third party.

Data Subject Personal Data Application Form