Purpose and Scope Etasis Sanctions and Export Controls Compliance Policy (“Policy“) defines the minimum standards and criteria determined in order to ensure compliance of Etasis Elektronik Tartı ve Sistemler Sanayi ve Ticaret Anonim Şirketi (“Etasis“) with international economic sanctions and export controls obligations. Under this Policy, Etasis aims to ensure that its business processes and operations comply with the economic sanctions and export controls obligations imposed by the Republic of Turkey, the United Nations (“UN“), the United States of America (“US“), the European Union (“EU“), the United Kingdom (“UK“) and, other relevant jurisdictions as may be applicable. Within the scope of this Policy, all employees, directors, shareholders and affiliates of Etasis must comply with the obligations related to international economic sanctions and export controls. In addition, Etasis expects all its business partners to act in accordance with this Policy and takes the necessary steps in this regard.
Definitions EU (European Union): Refers to the European Union. US Sanctions: Sanctions imposed by the US Federal Government and its related bodies. UN Sanctions: Sanctions imposed by the United Nations Security Council and supported by member states. Export Control Regulations: Laws and regulations governing the import, export and re-export of technology, information, products and services for trade, foreign policy and national security reasons. Embargo: The prohibition of trade in goods and services with certain countries for economic or political reasons. Sanctions: Economic or financial sanctions or trade embargoes and Export Control Regulations imposed or enforced by the Sanctions Authorities of the Federal Government of the United States of America, the United Nations Security Council, the European Union, the United Kingdom, the Republic of Turkey or any other authority in the relevant jurisdiction. Sanctions Target: Individuals, organizations, countries and other entities targeted under sanctions. •Any sanctioned individual, organization, vessel or government (“Listed Persons“) •Companies owned directly or indirectly by 50% or more of the Listed Persons; •As of the date of publication of the most current version of this Policy, individuals reşide and/or legal entities registered in Crimea, Cuba, Iran, North Korea, Syria, Venezuela, the so-called Donetsk People’s Republic, the so-called Luhansk People’s Republic, the non-government-controlled regions in the Kherson and Zaporizhia Oblasts of Ukraine, and countries or regions subject to comprehensive sanctions on a country or region-by-country basis (“Embargoed Countries“); and •Persons, companies, ships or aircraft owned or controlled by, or acting as representatives of, the governments of the Embargoed Countries Business Partners: Suppliers, customers, contractors, all kinds of representatives, subcontractors and consultants acting on behalf and account of the company and other third parties entering into a business relationship with Etasis, etc. and the employees and representatives of such parties
General Principles Etasis is committed to taking effective measures to comply with national and international sanctions and export control regulations. Etasis does not establish direct or indirect commercial relations with Sanctions Targets or Embargoed Countries. In case of any hesitation or exceptional circumstances within the company, Etasis carries out the necessary permission and approval processes with the competent administrative authorities to ensure that the relevant transactions do not violate sanctions. Etasis complies with all applicable laws and regulations in the countries in which it operates and avoids activities subject to Sanctions by obtaining the necessary licenses where applicable. In addition, Etasis conducts due diligence and regular monitoring activities to determine whether its Business Partners are subject to Sanctions. In case of any non-compliance, the relevant transaction is immediately suspended, and the necessary reporting is made to the relevant administrative authorities upon request.
Policy Implementation Etasis conducts due diligence practices in order to determine Sanctions Targets and carries out these practices before any legal or commercial relationship is established and regularly during the business relationship. If any violation of sanctions and export control regulations is detected, it informs the authorities and takes the necessary actions as stipulated by national or international administrative authorities. Etasis makes the necessary amendments in the agreements to be signed with its Business Partners to ensure their compliance with this Policy. Etasis ensures that all payment and collection transactions are carried out in accordance with the legislation of the countries in which it operates and are properly recorded. Etasis cannot be a party to activities related to money laundering, terrorism or financing of weapons of mass destruction. For this purpose, it ensures the accuracy of financial and commercial records in accordance with all applicable national and international legislation. It keeps records of all activities in a secure and appropriate manner.
Information Requests Etasis may receive information requests from banks or correspondent banks regarding certain transactions. The responses to sanctions-related information requests must be accurate, complete and must not contain misleading information. Information requests and responses must be recorded and archived in electronic format.
Notification Etasis values the views of its stakeholders. Etasis has reporting mechanisms for business partners, managers and employees that encourage open feedback. In case of any suspicion of any action that constitutes a violation under this Policy or relevant national or international legislation, Etasis strongly encourages you to report this incident through the following reporting channels: Telephone: You can call the number 0222 236 15 53 & +90 531 783 56 13 E-mail: You can send an e-mail to etik@etasis.com.tr.
Discipline Violation of this Policy may result in significant disciplinary action, including dismissal, for Etasis employees and directors. If its Business Partners violate this Policy, their contracts may be terminated. In accordance with the applicable national and international laws and the principles and procedures determined by the applicable national and international laws, acts contrary to this Policy shall be evaluated and concluded by the Etasis Board of Directors.
Document Update, Storage and Publication Etasis ensures that this Policy is the most current version in force and is shared in publicly available resources. This Policy and its previous versions are kept in Etasis document management systems indefinitely. In case this Policy needs to be updated, the Ethics and Compliance Committee is responsible for making the necessary update and announcing the update to all parties related to this Policy.
