Cetinkaya ABAC Policy

Cetinkaya does not only provide high quality advice for ABAC compliance & laws, we also place the fight against bribery and corruption at the heart of our business. We comply with all applicable ABAC laws, including but not limited to the U.S. Foreign Corrupt Practices Act (“FCPA”), UK Bribery Act (“UKBA”), French Sapin II, Brasil Clean Company Act and also Turkish Criminal Code and applicable regulations. It is strictly forbidden for all Cetinkaya employees and third parties to give or receive a financial or other advantage in connection with the "improper performance" of a position of trust, or a function that is expected to be performed impartially or in good faith.

This prohibition includes any facilitating, expediting or "grease" payments made to government officials or private parties, directly or indirectly, either in order to expedite any official service or function.

No payment by or on behalf of Cetinkaya shall be approved or made if any part of the payment is to be used for an unlawful or improper purpose, or for any purpose other than that described by valid documents supporting the payment. No false or misleading entries are permitted in any Cetinkaya documents or financial records for any reason.

No funds may be provided to or spent on behalf of a government official or entity, directly or indirectly, without advance written approval from Cetinkaya management. This includes any payments, gifts, donations, charitable contributions, sponsorships, entertainment, travel, meals, or any other items of value.

Please note that the term "government official" is widely defined and may include individuals who are employed by any public or state-affiliated institution or organization or who act in an official capacity in any way, whether full-time, part-time or unpaid.

In addition to prohibiting bribery of government officials, Cetinkaya also prohibits its employees and third parties from engaging in bribery of private parties as outlined in UKBA.

Our reputation is built upon professional and tailor-made services and depends upon the conduct of our employees as well as the conduct of those with whom we do business with. It is our goal to ensure that all Cetinkaya employees and the third parties reflect the same high ethical standards and demonstrate a commitment to compliance with all applicable laws. We further expect our third parties to ensure that their employees and subcontractors understand and comply with this ABAC Policy. Therefore; every employee and third party of Cetinkaya is trained and monitored with respect to this policy during the course of the interaction.