A. SUBJECT OF THE CODE OF ETHICS
Zen Global undertakes to conduct its activities in compliance with all applicable national and international laws and regulations in the countries where it operates, as well as the Zen Global Code of Business Ethics and other procedures and instructions.
B. CONTENT AND PURPOSE OF THE CODE OF ETHICS
The purpose of the Code of Ethics is to ensure that Zen Global operates in accordance with national and international laws. These rules do not replace other existing rules and procedures already in force within Zen Global. No Zen Global employee may enter into agreements, make decisions, or conclude arrangements that are contrary to the legislation or this Code of Ethics.
1. COMPLIANCE WITH FUNDAMENTAL LAWS
Zen Global pays special attention to compliance with Human Rights, working conditions, and environmental issues as determined by the United Nations Global Compact.
A) CHILD LABOR
Zen Global complies with laws and national regulations regarding the employment of children, and under no circumstances shall children under the age of 18 be employed. Zen Global also ensures that its suppliers and partners show the same sensitivity.
B) EMPLOYMENT OF PEOPLE WITH DISABILITIES
Zen Global complies with laws and national regulations concerning the employment of disabled persons and participates in activities that support their employment.
C) NON-DISCRIMINATION
Zen Global complies with national laws on non-discrimination. In particular, no candidate may be denied employment, internship, or in-company training opportunities, nor subjected to discrimination directly or indirectly, especially on grounds such as salary, education, adaptation, classification, promotion, rotation, ancestry, family, wealth, philosophical beliefs, gender, sexual orientation, age, marital status, genetics, political opinions, trade union activities, religious preferences, physical appearance, health issues or physical disabilities, possible or likely pregnancy, or surname.
D) HARASSMENT
All employees have the right to work in a healthy environment free from physical and psychological harassment, as prohibited by the laws and traditions of the countries where Zen Global operates. Zen Global strictly prohibits any form of physical or psychological harassment among employees, even if there is no hierarchical relationship. All complaints of harassment will be handled confidentially. Any employee who believes they are subject to harassment must immediately notify their line manager or directly the Zen Global Human Resources Department. Any behavior leading to a violation of this rule will be promptly investigated, and the Disciplinary Committee will evaluate the situation.
E) WORKPLACE SAFETY
Acting with the principle of respect for its employees, Zen Global commits to creating a working environment in compliance with health and safety regulations to protect employee health. Zen Global employees also commit to acting in accordance with the regulations and policies set by the company. Employees act responsibly in matters of health and safety and refrain from behaviors that may endanger the workplace and colleagues, even if not explicitly defined.
2. SUPPORT FOR SUSTAINABLE DEVELOPMENT
Zen Global employees consider sustainable success, the company, and its reputation as an inseparable whole. Protecting and ensuring their continuity is among the guiding principles in business. Product and service safety, quality, and customer satisfaction are priorities in line with Zen Global’s vision. In this context, providing production and services at company standards to maintain Zen Global’s market leadership is the foremost ethical responsibility of Zen Global employees.
A) ENVIRONMENT
Zen Global’s priority is to respect and protect the environment by developing continuous improvement methods. Zen Global employees adopt the company’s environmental policies as a business practice, taking on the responsibility of increasing environmental awareness. By implementing an Environmental Management System in accordance with ISO 14001 standards, Zen Global aims to protect the environment during production, distribution, usage, and recycling stages, reduce raw material and energy consumption, use natural resources efficiently, and minimize waste. It considers any form of waste disposal as a loss of natural resources and strives to develop methods to prevent pollution at its source. The production or sale of products that pose unacceptable risks to human health and the environment is strictly prohibited at Zen Global.
B) HUMAN RESOURCES
Freedom of expression and internal communication are important values at Zen Global. To improve the working environment, it is committed to supporting employees in expressing themselves freely and developing a relationship of mutual trust at all levels. Zen Global expects to establish responsible employer-employee dialogue. For this purpose, and within the scope of laws and regulations on employee information and consultation, Zen Global informs employees of its activities when necessary, regardless of hierarchy, through notice boards, planning meetings, social gatherings, etc. Human Resources functions at Zen Global support employees with people-centered internal coaching processes that depart from tradition. Recognizing that its most important capital is Human Resources, Zen Global adopts the principle of listening to and valuing employees’ needs. Based on the principle that termination of employment is a last resort, Zen Global supports employees’ development through training and competency building, fostering responsibility, independence, career growth, equal pay policies, and continuous improvement at all levels. These principles apply to all Zen Global employees, regardless of status or qualification.
3. BUSINESS ETHICS
To sustain its existence, Zen Global aims not only to conduct profitable business activities but also to create value for all stakeholders in its social and economic environment. While creating this value, it considers the social, managerial, and environmental aspects of its commercial activities. Beyond legal procedures, it adopts the principle of providing reliable information by taking into account the prevailing social values.
A) RELATIONS WITH CUSTOMERS AND SUPPLIERS
It is prohibited to accept any gifts or hospitality from customers or subcontractors, regardless of value, including money, goods, services, entertainment, or travel. Similarly, it is prohibited to make any direct or indirect payments (such as bribes) to a customer representative or subcontractor to secure an agreement or obtain commercial or financial benefit. Except for symbolic gestures, no gifts or assistance may be given to existing or potential customers or subcontractors. The selection of suppliers providing goods or services to Zen Global must be based on quality, need, performance, and cost criteria. During negotiations with suppliers, employees must prioritize Zen Global’s interests within the rules, avoid friendship-based relations or prohibited discriminatory criteria, and ensure the best options and conditions. No employee or manager may directly or indirectly invest in or lend to the capital, parent, or subsidiary of a subcontractor related to Zen Global. Employees and managers may not exploit their work at Zen Global to obtain for personal needs the same advantages granted by subcontractors to Zen Global.
B) LEGAL USE OF FUNDS, SERVICES, AND ASSETS
The use of Zen Global’s funds, services, or assets for any illegal or improper purpose is strictly prohibited. No person or organization may benefit from Zen Global through bribery, gifts, or other means. Likewise, no domestic or foreign person or organization may accept money or benefits in violation of the law. Even if permitted by a country’s laws, Zen Global may not provide monetary or service support to political parties, officials, or candidates. No payments may be made to government institutions to gain favorable influence. Since such actions would be perceived as attempts to influence administrative or official decisions, it is forbidden to offer gifts, services, or invitations to employees or managers of these institutions. All Zen Global assets, liabilities, receivables, and other transactions must be recorded and preserved in accordance with accounting principles and laws. Zen Global or its subsidiaries may not hold or maintain any secret or unregistered funds or assets. Business and financial records must transparently reflect all accounting transactions. No payment may be approved or made if it is known or expected to be used, in whole or in part, for purposes other than those stated in the payment document. No false or unverifiable accounts may appear in Zen Global’s books or records.
C) FAIR COMPETITION
Zen Global strongly believes in strict compliance with competition laws and regulations of the European Union and other countries where it operates. Agreements, projects, arrangements, or coordinated practices prohibited by fair competition laws—such as those concerning prices, territories, market shares, or customers—are forbidden. Zen Global managers and employees are prohibited from entering into such agreements with competitors. Zen Global is sensitive to obtaining information about competitors in an ethical manner. Therefore, to continuously improve its operations, it encourages employees to use publicly available information about competitors. Employees may not engage in illegal activities when collecting such information. Integrity, one of Zen Global’s core principles, prohibits any action that would compromise competitors’ information security or damage the company’s reputation.
D) RESPECT FOR THIRD-PARTY INTELLECTUAL PROPERTY RIGHTS
Regardless of circumstances (such as risk of losing market share, business development opportunities, or obtaining an order), the clear violation of third-party intellectual property rights is strictly prohibited by Zen Global.
4. PROFESSIONAL ETHICS
Zen Global adopts principles that emphasize public purpose, intellectual tradition, and trust-based relationships, guiding employees in ethical decision-making processes.
A) PROPER USE OF COMPANY ASSETS
Zen Global employees and managers are responsible for the proper use of company property, technology, computer hardware and software, real estate, equipment, tools, compounds, raw materials, and convertible assets, including copyrights. For this purpose, Zen Global employees and managers must:
Use assets in accordance with Zen Global rules and procedures,
Prevent unauthorized use by third parties (including family members),
Use them only for professional purposes, including in permitted areas and at home,
Keep all passwords and codes confidential to prevent unauthorized access to the Zen Global computer system,
Not copy Zen Global-developed programs, procedures, codes, descriptions, presentations, training materials, or programs without authorization,
Comply with rules regarding the use of new information and communication technologies,
Upon leaving Zen Global for any reason (retirement, end of contract, etc.), return to the Human Resources department all documents containing confidential information without keeping any copies.
B) CONFIDENTIALITY OF INFORMATION
At Zen Global, information concerning employees’ private lives, performance evaluations, assignments, and salaries is strictly confidential. Access to such information is restricted to those with proper authorization. Similarly, each employee must protect the confidentiality of their own data. It is prohibited to seek such information about other employees unless required by duty. Employees may only access their own information unless otherwise authorized. No employee may use or disclose Zen Global’s confidential information during or after employment, regardless of how it was obtained. Violation of this rule may result in legal investigations under labor or criminal law. In particular, Zen Global’s commercial contracts, their outcomes and conditions, financial information, unit costs, technological data, copyrights, computer programs, or hardware used in normal business activities are confidential. Disclosure of such information without the general manager’s approval is prohibited. Persons whose contracts are terminated or no longer linked to Zen Global remain obliged to protect this confidentiality.
C) CONFLICT OF INTEREST
Zen Global employees must prioritize the company’s interests in line with the principles of integrity and reliability. Therefore, they must avoid situations where personal interests may compromise impartiality. A conflict of interest occurs when an employee or relative gains personal benefit from a Zen Global transaction or when an employee conducts a transaction with a company in which they or a relative has financial interests. If an employee suspects that a planned purchase may create a conflict of interest, they must consult their supervisor to clarify.
D) COMMITMENT
Zen Global employees and managers must perform their duties and responsibilities honestly. A managerial position at Zen Global requires full-time work. Therefore, all permanent or managerial employees may not engage in a second professional activity, own or run a business, or engage in any work requiring their or the company’s time outside of their contractual duties. This rule does not apply to temporary work, outside normal working hours, in a non-competing business owned or operated by a spouse or other family members.
5. RESPONSIBILITY FOR COMPLIANCE WITH THE CODE OF ETHICS AND REPORTING VIOLATIONS
Every Zen Global employee and manager is required to read, understand, and comply with this Code of Ethics. If necessary, other individuals may be reminded of these principles depending on their work within the company. Zen Global managers must ensure that all employees are aware of and comply with the rules.
EXCEPTIONS: Unless otherwise specified, exceptions to the principles outlined in the Code of Ethics may only be granted with the written approval of the general manager.
VIOLATIONS: Zen Global employees are advised to discuss with their supervisors or seek guidance from the Human Resources department if they believe their behavior does not comply with the Code or if they have doubts.
COMMITMENT: Employees designated by the general manager may be required to sign a commitment to comply with the Code of Ethics during annual evaluations.
CLARIFICATIONS: Any questions regarding the interpretation, scope, or application of the Code of Ethics should be directed to the general manager and clarified with the Human Resources department.
SANCTIONS: Violations of the Code of Ethics may result in sanctions. Depending on the nature and seriousness of the violation and the laws of the country, these may range from a warning with salary deduction to dismissal.
