PURPOSE

The purpose of the Anti-Bribery and Anti-Corruption Policy (hereinafter referred to as the Policy) is to clearly define the attitude of Yaşamdan Yana Derneği (Stand with Life Association) (hereinafter referred to as the Association) in combating bribery and corruption by ensuring compliance with anti-bribery and anti-corruption legal regulations, ethical and professional principles, and universal rules.

The Policy also serves as a guide for all persons, institutions, and organizations with which the Association has or will have a relationship and contains ethical principles that constitute the essence of the work related to the cooperation to be carried out by the parties.

SCOPE

The Anti-Bribery and Anti-Corruption Policy covers all members of the Association, including the Board of Directors, employees, all collaborators acting on behalf of the Association and providing services to the Association, and the companies from which services and goods are purchased, employees, suppliers, consultants, lawyers, external auditors, and persons and organizations working on behalf of the Association (cooperation partners). This Policy is an integral part of the Individual Ethical Code of Conduct adopted by the Board of Directors and all members, internal regulations regarding bribery and corruption, the Association’s legislation, and other legal regulations.

DEFINITIONS

Bribery is when a person acts contrary to the requirements of their duty and obtains a certain benefit by doing, not doing, speeding up or slowing down a job within the framework of an agreement with a third party.

Corruption is the solicitation, offering, giving or accepting of bribes or any other illegal benefit, which directly or indirectly leads to deviations in the lawful performance of the duties or required behavior of the person who directly or indirectly obtains a bribe or illegal benefit.

AUTHORITY and RESPONSIBILITIES

The Board of Directors of the Association is responsible for establishing, implementing, and updating the Anti-Bribery and Anti-Corruption Policy. Sanctions are imposed as a result of members of the Association acting in violation of these principles. The Board of Directors of the Association is authorized to investigate such cases. The Board of Directors of the Association shall scrutinize any suspicious or doubtful situation, including bribery and corruption, or any complaint submitted in this regard, submit a report on this matter and impose the necessary sanctions.

POLICY PRINCIPLES

All members accept the Anti-Bribery and Anti-Corruption Policy and act in accordance with the principles in the policy text. Managers ensure that the principles in this policy text are understood, implemented, and maintained by the members. The Association is against all kinds of bribery and corruption. It is absolutely unacceptable to take or give bribes regardless of the purpose. Individuals and organizations covered by this policy may not offer facilitation payments to secure or accelerate a routine transaction or process.

The main purpose of donations and aids is to fulfil social responsibilities, to meet social needs and to benefit the public, and it is essential that donations and aids are used in line with the purpose. The issues that the Association has to comply with regarding the accounting and recording system are regulated by legal regulations, and it is essential that all kinds of accounts, invoices and documents related to relations with third parties are recorded and maintained in a complete, accurate and reliable manner, and that accounting or similar commercial records related to any transaction are not falsified and the facts are not distorted.

The Anti-Bribery and Anti-Corruption Policy has been announced to the members of the Association and is constantly and easily accessible on the Association’s website. The Board of Directors of the Association is responsible for the Anti-Bribery and Anti-Corruption Policy. The Board of Directors of the Association accepts this policy text and provides the necessary environment for its implementation. It establishes and develops internal control systems to prevent bribery and corruption. All members of the Association are responsible for ensuring compliance with the policies, managing these risks in the areas they are responsible for, and reporting to the Board of Directors in case of any behavior or practice contrary to the policy.

POLICY VIOLATIONS AND SANCTIONS

All Association members are obliged to comply with this Policy, relevant legal regulations, and all applicable anti-corruption legislation. In the event that members of the Association act contrary to the rules in this Policy, the necessary sanctions will be imposed. In addition, those who do not comply with the relevant legal regulations and anti-corruption legislation in force may be subject to criminal liability.

TRAINING

This Policy is publicly available on the Association’s website. Due to the importance the Association attaches to the subject, all members are encouraged to receive anti-bribery and anti- corruption training.

BOOKS AND RECORDS

Our applicable anti-bribery and anti-corruption legislation has developed criteria for books, records, and internal financial controls to prevent hidden bribery through incomplete and inaccurate financial records. The Association has records and books that are kept in an orderly manner to accurately reflect the Association’s transactions and assets.

NOTIFICATION AND APPROVAL

When members of the Association encounter a suspicious situation, they are required to report anyone involved in the suspicious behavior in question to the Board of Directors of the Association at yasamdanyanadernegi@gmail.com, even if they are members or managers. The Board of Directors of the Yana Yaşamdan Yana Association guarantees that the persons who report and complain about situations contrary to legal regulations, ethical rules and association legislation will not be harmed for their complaint. It is essential that the identities of these persons are kept strictly confidential and that they are prevented from suffering any damage due to their complaint or denunciation – unless it is a situation that can be defined as intentional or slander.

REVIEW

This Policy is reviewed at regular intervals and necessary updates are made and announced on the Association’s website.

EFFECTIVENESS

The Anti-Bribery and Anti-Corruption Policy enters into force upon approval and publication by the Board of Directors of the Association.