Anti-Corruption Policy | DenizBank

DenizBank A.S. (“DenizBank”) is determined to comply with national and international legal regulations, ethical and professional principles to prevent bribery and corruption.

It aims to provide the highest standards in its services and activities in line with the principles of honesty, transparency, accountability, objectivity.

DenizBank has defined the main principles of anti-corruption policy which covers its main tasks and purposes related to anti-corruption, process stakeholders, the duties, authorities and responsibilities of the stakeholders, as well as the relations with third parties including individuals, legal entities, public institutions and representatives. Within this scope, it has established “DenizBank Anti- Corruption Policy” as per the relevant Turkish laws, methodologies, principles and best practices.

Through this policy which is approved by DenizBank board of directors, it is ensured that a general methodology regarding anti-corruption and Bank and It’s subsidiaries apply the same approach are provided.

All staff provide service with the awareness of anti-corruption and they will comply with the laws related to anti-corruption, this Policy and ethical principles.

Within the framework of Anti-Corruption Policy, DenizBank has made systematical developments for all of its staff to confirm that they have read and understood the provisions of the Policy and to make necessary declaratives in this scope.

Moreover, classroom and e-learning trainings regarding the Policy provisions and anti-corruption are provided and the announcements are made regularly in order to increase the staff awareness and ensure sustainability on implementation.

“Hotline” has been put into the operation in DenizBank for the staff who need to declare in a secure and confidential way about the transactions that might cause embezzlement, fraud, bribery, corruption and etc. to damage the Bank's reputation, cause conflict of interest and financial losses.

The declarations can be directly made to the Compliance Officer through any way of communication methods including phone, e-mail and intranet portal at the Bank.

In addition to the compliance of the staff with other compliance procedures and ethical rules, the fulfillment of anti-corruption tasks continually and faultlessly by the stuff is taken into consideration for the performance assessments.

DenizBank establishes necessary control mechanisms, procedures and takes actions regarding the results of the controls to be able to detect, assess and decrease corruption risks efficiently.

In this scope, DenizBank defines important functions, operation types, business processes and positions regarding to anti-corruption, takes measures to prevent conflicts of interest, and defines procedures related to gift and hospitalities and all other areas that may be subject to corruption cases.

In case of violation of Anti-Corruption Policy, disciplinary penalties/ judicial enforcements that may cause the termination of labor contract as per the related Turkish Laws and practices of the Bank can be applied.

Within the scope of Anti-Corruption Policy, in addition to the stuff, suppliers, contractors, customers and related third parties must fully comply to subject principles and other related regulations.

The subject provisions are included into the agreements/contracts/protocols, etc. that concluded with counterparties to ensure this compliance.

DenizBank and subsidiaries endeavor the required effort to decrease the risks of business relations with counterparties who are involved in anti- corruption activities or who may be involved in these activities.

As per the anti-corruption and bribery policy, in the light of reliability, accuracy, transparency and responsiveness principles, DenizBank aims to prevent the misuse and abuse of authorities, ensure the use of the sources as per law.

Within the scope of Anti-Corruption Policy, DenizBank has adopted as principle;

  • to comply with laws and arrangements, universal law rules, and ethical principles,
  • to develop anti-corruption culture through briefings and trainings between its stuff and real person/legal entities who/which are its customers or not.
  • to make controls related to the implementation of the policy and procedures,
  • to develop measures and take necessary precautions to define and limit corruption.

With the purpose of preventing corruption and bribery, parties concluding contracts with DenizBank accept and undertake to comply with the below stated “Anti-Corruption Rules” and not to carry out the below stated actions and/or similar actions directly or indirectly, personally or through third parties.


  • To bribe or intermediate bribery; in other words, to gain any financial or other profit/advantage or give promises on this accord in order to encourage a person to violate legislations and international regulations and/or benefit the briber by using their own official post.
  • To make corrupt payments; in other words, by taking into account the status of managers in the Bank and/or Its subsidiaries, to transfer them illegal money, securities or other properties for them to behave/not behave in favor of the briber or presenting managers with said properties or providing managers with property rights.
  • To bribe public servants; in other words, to offer any financial or other profit/advantage or give promises to them on this accord in order to get competitive or other advantages for the Bank and/ or Its subsidiaries or to get/continue a deal by affecting the fulfillment of official duties of a public servant.
  • On behalf of themselves or third parties, Parties cannot do the below acts in relation of money, jewelry, other securities or property rights;
    • They cannot gain profit or abuse their duty to offer this profit to a party illegally, cannot intermediate in abusing duties.
    • They cannot offer, give, promise, ask for, accept bribes and cannot abuse any authority owned directly or indirectly as per the position. They cannot carry out activities by illegal usage of job posts.
    • They cannot carry out activities stated above in the name or on behalf of the Bank and/ or Its subsidiaries.

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