As DESIRD DESIGN R&D (shall be hereinafter referred to as "Desird"), we believe that our deep respect for society, people and the environment and our responsible behaviours based on ethical values constitute the milestones of our sustainable success. We are aware that we will be able to reach success not only through our own efforts, but also through the strong and trust-based relationships we establish with our business partners. The “Supplier Code of Conduct Policy” we have created in this regard clearly states that we expect our business partners to adhere to ethical standards, act in accordance with legal obligations and what kind of cooperation we expect from them on issues such as corruption, human rights, occupational health and safety.

This policy is a guiding roadmap on how we should handle potential conflicts and ethical dilemmas that may be encountered in our daily business processes. It is supplemented with internal directives and rules, as well as agreements based on the employment contract.

We kindly request that you carefully review each element of our policy and fully implement it in your daily work life. Do not hesitate to share the rules with your colleagues and do not hesitate to report any uncertainties or questions you encounter immediately. Remember that compliance with this policy is essential for the sustainability of Desird's ethical and responsible business approach.

GENERAL MANAGER

H. EMRE KAZAN

11.10.2024

1. Our Responsibility as a Member of Society
   a. Human Rights
   b. Equal Opportunity and Equal Treatment
   c. Product Suitability and Safety
   d. Environmental Protection
2. Our Responsibility as a Business Partner
   a. Conflicts of Interest
   b. Prohibition of Bribery and Corruption
   c. Prohibition of Money Laundering and Financing of Terrorism
   d. Fair and Free Competition
   e. Purchasing
   f. Export Control
3. Our Responsibility in the Workplace
   a. Occupational Safety and Health Protection
   b. Data Protection
   c. Protection of Intellectual Property
   d. IT – Security
   e. e. Use of Company Assets
4. Support
   a. Help / Contact

1.a. Human Rights

We observe universal and fundamental values such as human rights and children's rights, respect all rules applicable for the protection of these rights, and contribute to the implementation and development of these rules. We absolutely reject child labour, forced labour, modern slavery and all forms of human trafficking. This principle applies not only to internal company relations, but also to our business partners and our interactions with them.

1.b. Equal Opportunity and Equal Treatment

Our fundamental principle is to provide equal opportunities to everyone. We do not accept any discrimination due to ethnic origin, nationality, gender, religious belief, age, disability, political views or any other personal difference and we work to prevent it. We accept diversity as a richness in our company, actively support the participation of individuals and create a working environment that encourages the individuality of everyone. When hiring or promoting our employees, we focus solely on their abilities and competencies.

1.c. Product Suitability and Safety

We meticulously comply with all legal regulations and standards regarding our products. We continuously and systematically monitor the performance of the products on site, and when we detect any deviations, we intervene quickly and take the necessary measures. We expect the same meticulousness from our suppliers and demand that they effectively manage the following processes:

To detect defects, implement corrective actions and ensure delivery of products of a quality that meets or exceeds the contractual terms;
To prevent counterfeit parts and materials from entering the products;
To detect counterfeit materials, notify the buyer when necessary and ensure that such products are removed from the delivery.

1.d. Environmental Protection

Our company and our suppliers must carry out their activities in accordance with national and international environmental legislation. We evaluate the environmental impacts of every decision we make and every transaction we carry out, and take the necessary measures to protect natural resources, reduce waste and prevent pollution. We identify the substances that pose a danger to the environment and meticulously manage the process of safely processing, transporting, storing, recycling and disposing of them. We expect all materials supplied by our suppliers to be in compliance with the European Union 2011/65/EU RoHS Directive and REACH regulations numbered 1907/2006.

2.a. Conflicts of Interest

We respect the personal interests and private lives of our employees, but avoid conflicts of private and commercial interests. We base our decisions on objective criteria and are not influenced by personal interests or relationships.

2.b. Prohibition of Bribery and Corruption

We implement a zero-tolerance policy against all acts of corruption. We provide benefits to our business partners, customers or other third parties only within the legal framework and in line with internal company regulations.

2.c. Prohibition of Money Laundering and Financing of Terrorism

We carefully verify the identities of our customers, business partners and other parties with whom we establish commercial relations. We conduct our commercial activities only on legal grounds and ensure that our business resources are based on legitimate sources. We immediately assign and record incoming payments to the relevant services and ensure that our payment processes are completely transparent.

2.d. Fair and Free Competition

We operate only in accordance with the principles of free market economy and competition. We compete fairly and ethically with our competitors and always act in accordance with the rules of law and ethics.

2.e. Purchasing

We carefully select our suppliers and service providers with whom we prefer to work in long-term and cooperation according to objective criteria, and act honestly, respectfully and fairly in compliance with international and local legislation. We ensure that authorized purchasing units are engaged in product and service purchases in accordance with the relevant procedures. While determining our suppliers and service providers and conducting our relations afterwards; we are transparent, do not accept items that will negatively affect our objective decision-making abilities (gifts, benefits, etc.), and act in a way that will not allow the formation of impressions that there is a relationship of interest.

We expect our suppliers and service providers to continue their activities in accordance with the laws, regulations and Desird Supplier Conduct Policy. In this context; we monitor that they fulfil their legal obligations, respect human rights, comply with standards such as employee rights and environmental protection. We support them to act in accordance with business ethics and anti-corruption principles.

We and our customers shall have the right to audit all pertinent documentation of the supplier, and to make reasonable inspection of the supplier’s premises, in order to verify compliance.

2.f. Compliance with Laws and Legislation

We act in accordance with all legal regulations regarding import and export and we pay attention to these rules.

3.a. Occupational Safety and Health Protection

We take all necessary precautions to protect the occupational safety and health of our employees. We provide our employees with the necessary training, equipment and hardware, and take all necessary precautions to prevent occupational accidents and occupational diseases.

3.b. Data Protection

We protect the personal data of our employees, customers, suppliers and other relevant persons, and collect, process and store this data only within the framework of legal obligations.

3.c. Protection of Intellectual Property

We carefully protect the information accumulated by our company and respect the intellectual property rights of our competitors, business partners and third parties.

3.d. IT – Security

We take care of the security of our information technology and electronic data processing processes, and meticulously comply with the applicable regulations.

3.e. Use of Company Assets e. Use of Company Assets

We meticulously protect the tangible and intangible assets of our company, and do not use these assets for non-business purposes.

4.a. Help / Contact

Suppliers must provide their employees and other relevant persons with secure channels through which they can report any violations of the law or ethical rules. In the event of any violation, we expect suppliers to report this to us immediately. Reporting can be done through our supplier's purchasing contact person or through the ethical violation notification channel info@desird.com. Desird reserves the right to review its relationships with suppliers that do not comply with the Supplier Code of Conduct.