CODE OF CONDUCT

CODE OF CONDUCT

BE MINDFUL

EVERYTHING WE DO REFLECTS OUR BRAND,
AND OUR CODE SHOWS US THE WAY TOward SUSTAINABLE BUSINESS.

WHY WE HAVE A CODE?

What makes Çekinmez one of the pioneer law firms in the region? It is not just our services but also how we do our work and the integrity of our actions. As part of our firm’s business culture, integrity inspires our work and strengthens our reputation as a firm.

Being mindful of our value system also means taking part in a global movement that puts our planet and people’s lives and their communities at the center. When we work with you, we are mindful of who you are and your values as well. This ethos helps us achieve extraordinary things for you and always do what is right for your community. Integrity is the essential ingredient to our success.

Sometimes, one might face a situation where the right thing to do is not obvious. That is where our Code of Conduct can help. It is a guide that helps us find the appropriate course of action; it also helps us hire the right people. While the Code cannot answer every question, it can show you where to go for guidance when the answer is not clear.

How Can the Code Help You?

The Code enables you to…

  • Conduct yourself honestly and ethically.
  • Uphold our values and protect our reputation.
  • Understand what Çekinmez expects from you.
  • Make good decisions every day.
  • Comply with the laws, regulations and standards that apply to our Firm.
  • Understand where to go for assistance or guidance if you have questions.

Administering the Code

The Ethics & Compliance Committee is responsible for administering the Code in an independent, objective and consistent manner. The Committee is made up of a group of senior lawyers who enforce the Code.

Policy Modifications and Waivers

We realize that the Code will not cover every possible circumstance, so our Firm may modify the Code, as necessary. Any waivers of the Code, however, must be approved by the Ethics & Compliance Committee.

WHO IS COVERED UNDER THE CODE?

It does not matter where you work or what you do for the Firm – you have a responsibility to use good judgment and follow our Code. That includes every full-time or part-time employee at every level of the Firm, all the way up to the Executive Partners. All employees, and any others subject to the Code, must acknowledge that they have read and agree to uphold the Code.

Anyone who works on the Firm’s behalf (including our external stakeholders and business partners) must share our commitment to integrity by following the principles of our Code when providing goods and services to the Firm or acting on our behalf.

Uphold the Law

Laws and regulations can vary widely from country to country. Because our Firm is incorporated in Turkey and we operate abroad, knowing which laws to follow can be complicated, so be sure you know the laws and regulations related to your job in the country (or countries) where you provide service. Sometimes local customs or practices can conflict with our Code or the law. In cases like these, follow the law and our Code. Contact your manager and a local legal counsel for guidance.

Your Rights as an Employee

While we expect you to follow our Code, we also recognize your rights as an employee. Nothing in this Code or in any firm policy is intended to limit or interfere with your rights under the law.

When a Code Violation Occurs

When one of our employees fails to follow our Code or applicable laws, ignores someone else’s failure to follow the Code or pressures someone else to violate the Code, a violation has occurred. This can harm the Firm’s reputation and our bottom line.

We take all potential Code violations seriously. Code violations may lead to disciplinary action that matches the nature and circumstances of the violation, up to and including suspension without pay, loss of merit increases or annual incentives, and termination of employment. If an act violates the law, it could result in fines or criminal prosecution. Code violations are also documented in your employee record.

The Firm has other policies and processes governing performance, conduct and behavior. Policy violations that are not Code violations will be handled under the appropriate policy or procedure.

WHAT YOU NEED TO DO?

As employees, each of us has as a responsibility to…

  • Know and live the Code. Read it and follow it, along with any other policies that apply to your job.
  • Think before you act. Use good judgment, being honest and ethical in every action you take. If you are asked to violate the Code, do not do it. Report the concern as soon as possible using the resources available to you.
  • Follow the law. Understand laws that apply to your job and our business.
  • If you are ever unclear about a law or regulation, contact with your superior.
  • Ask for help. When an answer is not clear, ask for guidance before taking action.
  • Stay alert. Pay close attention to any activity that is inconsistent with our Code, our policies or the law.
  • Report concerns. Do not ignore a violation. Prevent harm to our Firm and its reputation by reporting your concerns immediately.

If you are a manager, you have additional responsibilities…

  • Model the Code and our values. Promote a culture of integrity by making ethical decisions and showing honesty and integrity in everything you say and do. Never encourage or direct any employee to achieve a business result at the expense of violating our Code or the law.
  • Talk about the Code. Read the Code and understand it. Refer to it, your Ethics Officer or the Ethics & Compliance Committee to answer questions. Make ethics conversations part of your routine.
  • Be informed. Recognize that you may not always find the answers that you need in the Code, so know where to go for answers when there are questions.
  • Expect the best. Discuss the importance of ethics and compliance and let employees know you expect them to always do what is right.
  • Be responsive and create a “speak up” culture. Encourage employees to come to you with questions or concerns. Listen to them carefully and offer guidance when they need help, including identifying available resources for reporting. Also, be careful not to create an environment where employees feel they can only bring concerns to management.
  • Take action. Look out for misconduct and report it to your manager, Ethics Officer or the Ethics & Compliance Committee if you see it.

HOW TO MAKE GOOD DECISIONS?

Doing what is right is our goal. If the right thing to do is not clear, ask yourself:

  • Is it consistent with our Code?
  • Is it legal?
  • Does it follow our policies?
  • Does it benefit the Firm as a whole – not just a certain individual or group?
  • Would I be comfortable if my actions were made public?

If you can answer “YES” to all of these questions, the action is probably okay. But any “no” or even “maybe” answers are a signal to stop and get advice or ask questions. After all, it is always better to ask before you act, especially when you are not sure. Contact any of these resources:

  • Your Manager
  • Ethics Officer
  • The Ethics & Compliance Committee 

Your Ethics Officer

Think of your Ethics Officer as a keeper of the Code – a resource for you if you have questions or want to raise a concern. In some situations, you will need written approval from your Ethics Officer before you take action. Examples of situations that may require written Ethics Officer approval:

  • Use of Assets / Anything of value
  • Conflicts of Interest (or the appearance of a conflict)
  • Gifts, Meals and Entertainment

Some situations are ongoing over a long period of time and will require approval at least annually, when circumstances change or at other more frequent intervals as required by the Ethics Officers.

Who Is My Ethics Officer?

The Firm appoints an employee to support its operation as Ethics Officer who is authorized to give written approvals and offer guidance on ethics and compliance issues.

How Can I Reach My EO?

You can reach Ethics Officer from ethics.officer@cekinmez.com

How Do I Get Approval?

When seeking approval from your Ethics Officer, your best option is to use email.

What If I Am an Ethics Officer or an Executive Partner and Need Approval?

When an Ethics Officer or Executive Partners needs approval under the Code, approval must come from the Ethics and Compliance Committee.

REPORTING CONCERNS

Maybe you sense that something is not right at work. Maybe you saw something or heard about an act that may violate our Code, our policies or the law. If so, you have a responsibility to share your concerns by reporting right away – even if you are not sure that a Code violation has occurred.

When you report concerns, you help us handle issues properly, fix problems before they occur and remedy situations that have already happened.

You also help build trust with each other and with our clients, external stakeholders and business partners.

How Do I Share My Concerns?

Talk to either your Ethics Officer or email at: ethics.officer@cekinmez.com

What Happens When You Report a Code Concern?

We will do all we can to protect your identity consistent with conducting a thorough investigation. We take every report seriously and Ethics Officer will investigate it thoroughly and as confidentially as possible. We expect everyone involved to cooperate fully and honestly.

To ensure consistency in analyzing matters, outcomes from the investigation are presented to the Ethics & Compliance Committee who will determine, based on the investigatory facts presented, if there has been a violation of the Code.

If the Ethics & Compliance Committee determines that the Code has been violated, it will determine a fair and consistent disciplinary action in accordance with applicable law.

No Retaliation

You are the eyes and ears of our Firm, and we value your help in avoiding and uncovering possible misconduct. We strictly prohibit retaliation of any kind against anyone who shares a good-faith concern or participates in a Code investigation. Sharing a good-faith concern about the Code honestly, even if it turns out to be unfounded, is never an excuse for any kind of retaliation.

What is Retaliation?

We define retaliation under our Code as any action that would likely deter someone from reporting a Code concern or participating in a Code investigation. Examples of retaliation might include demotion, firing, a reduced salary, job reassignment, threats, harassment or any other action taken against someone because they raised a Code concern, participated in a Code investigation, or attempted to deter someone from violating the Code. While we take the anti-retaliation provisions of our Code very seriously, these provisions do not protect you from disciplinary action for your own misconduct, meaning you should not report a Code concern simply to avoid discipline for your own violation of the Code or other Firm policy.

No False Accusations

As much as we encourage honest reporting, we do not tolerate knowingly false reports. Making a false accusation can divert investigatory resources away from credible good-faith concerns and damage morale. Report what you have a reasonable, good-faith belief be true, but never knowingly make

a false accusation lie to investigators or refuse to cooperate in an investigation, as these actions may also violate our Code.