Corporate

The Code of Ethics is designed to determine the responsibilities of Mass employees, in line with company values and priorities, towards one another, stakeholders, society, customers, and the individuals and institutions with whom they have business relationships, as well as the environment. It is prepared to ensure these rules are embraced, applied, and adhered to by all employees.

Mass commits to conducting its business processes and all relationships with stakeholders in compliance with the adopted ethical values.

All employees, stakeholders, suppliers, business partners, consultants, etc., are expected to comply with the Mass Code of Ethics.

Responsibilities of Our Managers

Leading the implementation and enforcement of the Code of Ethics is one of the primary responsibilities of our managers. In addition to setting an example by adhering to these rules, managers ensure that employees receive the necessary training on ethical guidelines. They also ensure that employees who witness violations can easily report these breaches by providing the appropriate environment and conditions.

Responsibilities of Our Employees

Employees are expected to read, understand, and apply the rules outlined in this guide. Furthermore, all Mass employees are obligated to comply with all company policies, regulations, procedures, and instructions in effect.

Employees work with honesty, discipline, and dedication. They always show respect and compliance with laws and internal company regulations.

In cases of ambiguity or indecision, employees should consult with their department managers, Human Resources, or the Ethics Committee before taking any action. Employees should actively participate in training related to ethical rules.

Employees treat the company’s assets, including information and information systems, as if they were their own property, protecting them from potential loss, damage, misuse, abuse, theft, or sabotage.

Employees who suspect or witness a violation of the rules are expected to report the situation to the Ethics Committee as soon as possible.

Responsibilities of Our Stakeholders and Suppliers

As Mass, we expect our stakeholders to adhere to the ethical rules we commit to following in all relationships with them.

Decisions regarding the selection of suppliers and stakeholders are made within the framework of our company policies. We aim to create mutual value in our relationships.

Legal Responsibilities

Mass employees conduct all domestic and international activities and transactions in accordance with national laws and international law, providing accurate, complete, and understandable information to regulatory authorities in a timely manner.

In conducting all activities and transactions, we maintain an equal distance from all public institutions, administrative organizations, civil society organizations, and political parties, and carry out our responsibilities with this awareness.

Business Behavior
Anti-Corruption and Bribery

Mass is committed to adhering to national and international laws, upholding integrity and fairness standards in all of our internal and international relationships, in line with the fight against corruption and bribery.

Compliance with laws, regulations, and principles against bribery and corruption is essential. Relationships with third parties who request or offer bribery or corruption (including external service providers and business partners) will be terminated. Accepting, offering, or proposing bribery, regardless of its purpose, is unacceptable. No employee may benefit from a third party or institution in connection with their job, enter into personal business relationships, or request or make payments. All employees are required to comply with anti-corruption and bribery rules and report violations to the relevant authorities. Further details are outlined in the Anti-Corruption and Bribery Procedure.

Fair Competition

Mass recognizes the importance of a competitive market and is committed to complying with all competition and transparency laws and regulations in all of its commercial transactions. Employees are obligated to adhere to competition laws in all markets and avoid infringing on third-party intellectual property rights.

Conflict of Interest

Mass employees are expected to prioritize the company's interests in line with the principles of honesty and reliability. Employees should avoid situations that could affect their impartiality due to personal interests.

Employees aim to stay away from relationships or situations that involve potential or actual conflicts of interest and act in Mass's best interests.

Mass employees may not gain personal benefits from individuals or organizations they have business relationships with, either directly or indirectly, through their role at the company.

Employees must obtain written approval from senior management to engage in any other work, consult for another entity, or establish any relationships outside of Mass.

Employees may not personally profit from any transaction or contract related to Mass activities, directly or indirectly.

Information held by employees due to their position within the company cannot be used for personal benefit or anyone else's benefit.

Information Security and Data Protection

At Mass, we prioritize information security and operate in compliance with the Information Security Rules and the Personal Data Protection Law (KVKK).

All employees must act with the awareness that the company's financial and commercial secrets, employee rights and information, agreements with business partners, and other confidential information must be protected and kept confidential. Employees are not allowed to share or disclose any confidential information to unauthorized individuals or entities inside or outside the company.

Mass employees use all written and/or unwritten information, documents, and techniques produced or developed within the company solely for company operations and interests.

Employees must not share, disclose, or use non-public information, such as employee data, inventions, designs, pricing, costs, strategy plans, product details, procedures, regulations, instructions, etc., for personal gain or with third parties.