1. Purpose
As Migros, at the core of our corporate responsibility approach lies compliance with laws and corporate governance principles. With our commitment to high ethical standards and the Migros Ethics Rules, we work together as a whole to prevent bribery and corruption.

With this policy, which is a supplemental part of the Migros Ethics Rules, we aim to present our commitment and our approach to this subject very openly and clearly.

2. Scope
The Anti-Bribery and Anti-Corruption Policy does not just concern the company’s employees but all business partners who act on behalf of the company or provide services to the company.

The following groups are within the scope of this policy:
  • All company employees including the Board of Directors,
  • Supplier and contractor companies,
  • Outsourcing companies and employees,
  • People and companies that work directly or indirectly for the company like representatives, distributors and agencies are all in the scope of this policy.

3. Responsibilities
Company Management;
Our Company Management provides the necessary support for this policy to be implemented and creates and develops the internal control systems necessary to prevent bribery and corruption. It makes sure the necessary communication channels for reporting policy violations is established, and takes precautions to maintain the privacy and safety of the individuals who report such violations.

The management makes sure that the necessary examinations and investigations are conducted concerning any complaints, warnings and claims that are submitted. They make sure audits are conducted to check compliance with laws, regulations, procedures and that policies and corrective actions are taken.

The Administrators, Employees and Business Partners;
All of our employees are obligated to accept our Policy on Anti-Bribery and Anti-Corruption and act in accordance with the principles that are specified in our policy.

The administrators are responsible for making sure that the principles in this policy are understood by the employees and business partners under their charge and direction, are implemented and maintained and that any complaints, warnings or claims are notified via our company’s communication channels.

Employees cannot, under any circumstances or by anyone, be forced to act against this policy. All company employees are responsible for reporting violations of this policy and any suspected situations to their administrators and/or the company communication channels.

If people and companies related to Migros are involved in any acts that are not legal or ethical our company will also be liable; therefore all of our business partners, especially suppliers and contractors, are expected to act in compliance with laws and regulations as well as to adopt the Migros Ethics Rules, relevant directives and procedures and this policy’s text and rules.

4. Fighting Against Bribery and Corruption
As Migros, we make it our principle to comply with the universal legal rules, laws and regulations that relate to bribery and corruption and the ethical and professional principles in all of the countries where we operate and are represented.

This policy reinforces the execution of all our operations in compliance with laws, regulations, procedures, the Migros Ethics Rules and other regulations in a correct, fair and honest manner. It has been implemented in line with our sensitivity for making sure the rights of all our stakeholders are protected.

We, as Migros, prohibit all bribery and corruption in our operations in all countries where we operate or are represented. It is prohibited for all those covered by this policy to propose any payment or object of value in order to gain any benefit in an illegal or unethical manner, even if it would be in favor of the company, or to accept such a benefit from other companies or individuals, or to be involved in any illegal or unethical acts that could be considered to be bribery or corruption, even if such practices exist in that country or branch of work.

We protect the legal rights of government agencies, our suppliers, our customers, our employees and our other stakeholders. Regardless of the monetary value or occurrence of the requested favor, even if the value of the benefit is very low or the commitment promised in exchange has not been realized yet, a related subject is considered as an act of violation of the Anti-Bribery and Anti-Corruption Policy.

In addition to bribery and corruption being acts that are a violation of business ethics, any incident would be dealt with punitively by Migros. As a consequence, our employees are expected to treat these topics with vigilance and consider them to be their personal responsibility both in and outside their professional life.

With our open door policy, if the Migros Ethics rules or the Anti-Bribery and Anti-Corruption Policy are violated, our employees and other stakeholders can contact our administration directly through our communication channels. If our company sustains a loss due to the violation of these rules, we also have rules for taking action concerning our employees and protecting their rights.

4.1. Main Areas of Risk concerning Bribery and Corruption Acts
Migros sees bribery and corruption as part of risk management applications and these issues are investigated with a risk focused approach through our internal audit system. The risks that are identified and their potential impacts are subjected to assessment throughout our internal audits. Also our company evaluates corruption risks in the scope of high risk jobs from the aspect of employee bribery.

4.1.1. Gifts and Hospitality
Our employees are responsible for complying with laws and regulations and rejecting any gifts such as objects, services, cash and checks from third parties that could affect the preferences and decisions of our company or are given for this purpose for conducting the work in their own field of responsibility no matter what the value is. Our employees may not propose any gifts, hospitality or other offerings that could be or are given for the purpose of affecting the decisions of other companies concerning our company. All of our employees are responsible for being careful about the issues that are specified in the company publications concerning rules on gifts and hospitality and for acting in compliance with the Migros Ethics Rules.

4.1.2. Intermediaries
Since an act of corruption committed by third parties could even be considered to have been committed by Migros, sufficient and careful monitoring must be done to make sure that intermediary companies have the right qualifications for the work they are conduct and business partnerships need to be established with companies that will act in compliance with our company policy and not damage our reputation.

4.1.3. Those who work in Representation, Suppliers and Contractors
People who work in representing our company by establishing a relationship with Migros and all suppliers and contractors are expected to accept compliance with all legal regulations and all laws on bribery and corruption that are in place.

People acting as an agent of Migros who provide management consultation and are involved in operations like accounting, payroll, information technologies or facilities management must not establish relationships with people and/or companies like suppliers and contractors that they suspect to have offered bribes; and if they have such a relationship should end it immediately upon learning of such a situation.

4.1.4. Political Donations
At Migros, it is illegal to make any payments as well as provide any financial and/or in kind benefit to political parties, politicians or any company to obtain an advantage in procedures.

4.1.5. Contributions for the Purpose of Aid and Sponsorships
Any contributions and sponsorships requested from Migros for the purpose of providing aid must be legal and in accordance with the regulation, policy, directive and rules issued by Migros. All contributions and sponsorships for aid must be made in a transparent and open manner. This is achieved by determining transparent criteria for the selection of recipients and listing large donations that are made publicly.

4.2. Encountering or Suspecting Bribery and Corruption
All of our employees are responsible for reporting any situations of bribery and corruption they encounter or suspect to their supervisors and/or our company communication channels immediately.

Employees are responsible for reporting any of the situations listed below.
  • If a bribe is offered to any of our employees or their colleagues
  • Any relationship of benefit and/or conflicts of interest that our employee witnesses or knows
  • Any kind of non-compliance discovered in the company’s records
  • Any attitude or acts that can be construed as patronage or backing interests in tenders and purchase-sales
  • Providing any benefit to any of our customers or suppliers in violation of legal regulations and our internal procedures
  • Any company or individual within the company or outside forcing our employee or their colleagues to act in violation of the Migros Ethics Rules.
Migros customers and business partners may forward their notifications about ethical issues by e-mail via etik@migros.com.tr.

4.3. Sanctions Against Acts and Attitudes of Violation
Just as all regulations, procedures and instructions are carried out in full, in all jobs, the Anti-Bribery and Anti-Corruption Policy must be adopted and implemented by all stakeholders covered by this policy.

Any violation of our “Anti-Bribery and Anti-Corruption Policy” by suppliers or contractors results in the termination of our work contract.

Any violation of these rules by our employees is handled by our departments including Human Resources, Internal Audit and Legal Department and reported to Migros Management. If these rules are violated by our employees who are union members, disciplinary meetings are called in which union representatives are present in accordance with collective employment contract rules. Any violation of Migros Ethics Rules or our Anti-Bribery and Anti-Corruption Policy by an employee may result in the termination of their employment contract.

4.4 Monitoring and Reporting
The Migros Ethics Committee meets four times a year with the participation of senior level administrators to evaluate internal audit findings on corruption and bribery and issues concerning ethics principles. When high level risks are identified the Migros Ethics Committee that meets with the participation of senior level administrators evaluates these risks.

As part of our corporate governance our Audit Committee and Ethics Committee prepares reports on our policy of combating bribery and corruption for our senior administration.

Migros Ticaret A.Ş. last amendment date: 28.06.2016
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