Global Antibribery & Anticorruption Policy

Global Antibribery & Anticorruption Policy

At Suflör Turizm, we are committed to conducting business with integrity, transparency, and accountability. Our Global Antibribery and Anticorruption Policy is designed to ensure that all employees, partners, and stakeholders adhere to the highest ethical standards. We believe in fostering an environment where corruption and bribery are not tolerated and where ethical business practices are the norm.

Scope

This policy applies to all employees, officers, directors, agents, consultants, and any other third-party representatives acting on behalf of Suflör Turizm. It encompasses all activities undertaken in the course of our business operations, both domestically and internationally.

Policy Statement

Suflör Turizm strictly prohibits bribery and corruption in any form. This includes offering, giving, receiving, or soliciting anything of value to improperly influence the actions of others, whether in the public or private sector. Our commitment to ethical business practices is unwavering, and we expect the same commitment from all those with whom we do business.

Definitions

Bribery: The offering, promising, giving, accepting, or soliciting of an advantage as an inducement for action which is illegal, unethical, or a breach of trust.

Corruption: The abuse of entrusted power for private gain. This can take many forms, including bribery, fraud, extortion, and nepotism.

Compliance with Laws

All employees and representatives of Suflör Turizm must comply with all applicable antibribery and anticorruption laws and regulations, including but not limited to the U.S. Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, the Turkish Penal Code, and other relevant local laws.

Turkish Anticorruption Laws and Regulations

In Turkey, anticorruption efforts are governed primarily by the Turkish Penal Code (Law No. 5237), which criminalizes bribery and corruption in both the public and private sectors. Key provisions include:

Article 252: Defines and prohibits bribery, detailing the punishment for those who offer, promise, give, or receive bribes.

Article 250: Addresses the abuse of public duty, including misconduct and exploitation of authority for personal gain.

Article 255: Prohibits the unlawful influence on public procurement processes.

Law No. 3628: On Declaration of Property and Combating Bribery and Corruption, which mandates the declaration of assets by public officials and establishes mechanisms to combat illicit enrichment.

All employees and representatives of Suflör Turizm must be familiar with and adhere to these regulations when conducting business in Turkey.

Gifts and Hospitality

While exchanging gifts and hospitality can be part of building business relationships, it must never influence business decisions or lead to a conflict of interest. All gifts and hospitality must be reasonable, proportionate, and transparently documented. Lavish or excessive gifts and hospitality are strictly prohibited.

Third-Party Relationships

We expect all third-party representatives, including agents, consultants, and contractors, to uphold our antibribery and anticorruption standards. Due diligence must be conducted before engaging third parties to ensure their commitment to ethical business practices. Contracts with third parties must include provisions that mandate compliance with our policy.

Reporting and Whistleblowing

Employees and representatives are encouraged to report any concerns or suspicions regarding bribery and corruption. Suflör Turizm is committed to protecting whistleblowers from retaliation. Reports can be made confidentially through designated channels.

Training and Awareness

Suflör Turizm provides regular training to ensure that all employees and representatives understand their responsibilities under this policy. Ongoing education and awareness programs are essential to maintaining our high ethical standards.

Monitoring and Enforcement

We regularly monitor compliance with this policy and conduct audits as necessary. Any violations of this policy will result in disciplinary action, which may include termination of employment or contracts and legal action.

Conclusion

Suflör Turizm is dedicated to maintaining a culture of integrity and ethical behavior. Our Global Antibribery and Anticorruption Policy is a cornerstone of our commitment to ethical business practices in the tourism industry, specifically in the Meetings, Incentives, Conferences, and Exhibitions (MICE) sector. By adhering to this policy, we ensure that our operations are conducted with the highest standards of honesty and transparency.

For any questions or further information regarding this policy, please contact info@suflorturizm.com