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Anti – Corruption Policy

DenizBank A.Ş (“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 and objectivity.

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

Through this policy approved by DenizBank Board of Directors, it is ensured that a general methodology is established regarding anti-corruption and the same approach is implemented by the Bank and its subsidiaries as a whole. All staff of the Bank and subsidiaries shall provide service with the awareness of anti-corruption and comply with the laws related to anti-corruption, this Policy and ethical principles.

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

Furthermore, to ensure sustainability in practice and enhance employees’ awareness,staff are provided with classroom and e-learning trainings related to Policy terms and anti-corruption, and announcements are made on a regular basis.

DenizBank has put into service the “Ethics Notification Line” to ensure that employees can securely and confidentially report transactions that might cause harm to the Bank’s reputation, conflicts of interest and financial losses such as embezzlement, fraud, bribery, corruption, etc. It is possible to report directly to the Compliance Officer via all kinds of communication methods including telephone, e-mail and Bank portal.

In addition to the compliance to other compliance procedures and ethical rules, the fulfilment of anti-corruption tasks continuously and faultlessly by the staff is taken into consideration for their performance assessments. DenizBank establishes necessary control mechanisms, creates procedures and takes actions regarding the results of the controls to be able to detect, assess and reduce corruption risks efficiently. In this scope, the Bank defines important functions, operation types, business processes and positions regarding anti-corruption, takes measures to prevent conflicts of interest, and defines procedures related to gift and hospitality expenditures and all other areas that may be subject to matter of corruption.

In case of violation of Anti-Corruption Policy, disciplinary penalties/ judicial enforcements that may cause the termination of labour 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 staff, suppliers, contractors, customers and related third parties must fully comply with these principles and other related regulations.

To be able to ensure policy compliance, the relevant provisions are included in the agreements/contracts/protocols etc. concluded with counterparties.

The Bank and its subsidiaries endeavour to reduce the risks of business relations with counterparties who are or who may be involved in corruption activities.

Within the scope of prevention of corruption and bribery, in the light of reliability, accuracy, transparency and accountability 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 the following as principle:

  • to comply with laws and regulations, global legal rules, and ethical principles,
  • to develop anti-corruption culture among staff, customer and non-customer real persons/legal entities through notifications and trainings,
  • to perform controls related to the implementation of policies and procedures,
  • to develop measures and take necessary precautions to detect and prevent corruption cases.

With the purpose of preventing corruption and bribery, parties concluding contracts with DenizBank hereby 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.

Anti-Corruption Rules

  • Bribing or intermediating bribery; in other words, gaining any financial or other profit/advantage or promising on this accord in order to encourage a person to violate legislations and international regulations and/or benefiting the briber by using their own official duty.
  • Making corrupt payments; in other words, by taking into account the managerial status of the Bank and/or subsidiaries, receiving transfer of illegal money, securities or other properties for them to behave/not behave in favour of the briber or presenting said property services or providing property rights to managers.
  • Bribing to government official; in other words, offering any financial or other profit/advantage or promising them on this accord in order to get competitive or other advantages for the Bank and/or Bank’s subsidiaries or to get/continue a deal by affecting the fulfilment of official duties of government official.
  • Parties cannot conduct the below acts in relation to money, jewellery, other securities or property rights on behalf of themselves or third parties.
    • They cannot make profit or abuse their duty to offer this profit to any party illegally, cannot intermediate any misconduct.
    • They cannot offer, give, promise, ask for, accept bribe and cannot abuse any authority owned directly or indirectly as per the position. They cannot carry out activities by other illegal use of their titles.
    • They cannot carry out activities stated above in the name or on behalf of the Bank and/or subsidiaries.