OUR CORPORATE VALUES
“ Our corporate values form the foundation of all our operations and social policies.
Responsibility
We fulfill our duties on time, accurately, and to the best of our ability.
Trust
We act with integrity, transparency, and consistency.
Team Spirit
We work collaboratively and achieve success together.
Communication
We communicate openly, respectfully, and effectively.
Solution-Oriented Approach
We remain persistent in the face of challenges and focus on producing solutions.
Agility
We adapt quickly to change and take timely action.
Through our social policies shaped by these values, we aim to create sustainable value for our employees, stakeholders, and society.”
This policy emphasises our corporate social responsibility principles as İLKNAK SU ÜRÜNLERİ SAN. TİC A.Ş, and importance and priority of the subject matter for all our employees and shareholders.
Ilknak considers acting with social responsibility consciousness in all its activities as one of the fundamental and unchangeable elements of management understanding and we determine our understanding of Social Responsibility and our priorities in this regard by taking into account what is best for society and the environment. The fundamental principles, on which we ground for our social responsibility practices are as follows;
CORPORATE POLICIES
This policy emphasizes the corporate social responsibility principles of İLKNAK SU ÜRÜNLERİ SAN. TİC A.Ş and highlights the importance and priority of this matter for the management, employees, and all our stakeholders. İlknak accepts acting with social responsibility awareness in all its activities as one of the fundamental and unchanging elements of its management approach.
We respect Human Rights. We are against forced labor and human trafficking. We treat everyone equally and fairly. We do not accept discrimination among employees within the institution based on language, race, color, gender, political opinion, belief, religion, sect, age, physical disability, or similar reasons. We approach employees honestly and fairly, and we commit to a non-discriminatory, safe, and healthy working environment. Ensuring and protecting the safety of our employees is our primary business goal.
Child labor cannot be employed at any stage of production. İlknak is obliged to comply with the age limits stipulated by ILO practices regarding the employment of children.
Since we are in the dangerous class in terms of occupational safety, young workers are not employed. The age limit at İlknak Su Ürünleri San Tic. A.Ş. is 18.
Wages and social services must be determined in accordance with the applicable fundamental principles regarding minimum wage, overtime, and social services mandated by law. Working hours must comply with applicable laws. Overtime should only be performed when the employee is voluntary, and the employee must be granted at least 1 day of rest after 6 consecutive working days.
Forced labor or compulsory labor is prohibited. Employees must have the right to terminate the employment contract within a reasonable period of time. No form of slave, trafficked, or involuntary labor is utilized.
A staff member is authorized and appointed among the employees for the protection and execution of social rights within the facility. This personnel selection is determined by a vote in a meeting attended by all staff and management regularly every year. The Employee Representative freely reports the requests and complaints of the employees to the senior management without personal sanctions.
Employees have the right to clearly express their requests and complaints on any subject to the senior management, both verbally and in writing. They shall not be subjected to any punishment or ill-treatment.
Our employees should be able to meet frequently with the business management about working conditions without fear of negative consequences of any kind. They have the right to unite among themselves to become a member of a union, appoint a representative, or be elected as a representative.
The institution ensures the safety of the employees in the workplace at least within the framework of the laws, protects their health, and strives for continuous improvement to enhance the working environment. Occupational health and safety training is provided to all personnel. Our company has the "ISO 45001 Occupational Health and Safety Management System."
The highest level of integrity is expected in all business activities and relationships. All forms of corruption, bribery, fraud, embezzlement, extortion, and abuse are strictly prohibited. Company employees cannot request or imply gifts from customers/subcontractor/supplier companies; they cannot accept any gifts, money, or special discounts that would put the company under obligation.
It is prohibited to practice discrimination of any kind against employees. This includes putting individuals at a disadvantage due to their gender, race, social group, color, disability, union affiliation, political opinion, origin, religion, age, or pregnancy.
It manages the environmental impacts that may arise from all kinds of our activities with a sense of responsibility. İlknak is obliged to determine and implement all kinds of improvement and development efforts that will minimize the environmental impacts of its activities. Our company has the "ISO 14001 Environmental Management System."
It evaluates the suppliers, subcontractors, and business partners in terms of Social Responsibility, monitors the reasonable and adequate measures they take, and supports a mutual cooperation approach to continuously improve their Social Responsibility levels. Their willingness for BSCI codes of conduct is questioned.
All our managers and employees, especially the senior management, are responsible for corporate social responsibility practices.
Any violation or suspicion should be reported to: etik@ilknak.com. We commit that anyone who reports any violation will not be subjected to ill-treatment or sanctions.
Turkish Labor Law No. 4857
ILO Fundamental Conventions (No. 29, 87, 98, 99, 100, 105, 111, 138, 182)
- No. 29: Forced Labour
- No. 87: Freedom of Association
- No. 98: Right to Organise and Collective Bargaining
- No. 100: Equal Remuneration
- No. 105: Abolition of Forced Labour
- No. 111: Discrimination (Employment and Occupation)
- No. 138: Minimum Age
- No. 182: Worst Forms of Child Labour
GRASP (GlobalG.A.P. Risk Assessment on Social Practice)
ETI (Ethical Trading Initiative)
Universal Declaration of Human Rights
As ILKNAK SU ÜRÜNLERİ SAN. VE TİC. A.Ş., we are committed to the highest standards of integrity. This policy is an inseparable part of our Business Ethics Rules and our commitment to the United Nations Global Compact.
The aim of this Policy is to outline the anti-bribery and corruption policies of ILKNAK SU ÜRÜNLERİ SAN. VE TİC. A.Ş., which are also included in our Business Ethics Rules.
This policy covers senior management, all employees, and all business partners (suppliers, subcontractors, consultants, etc.) acting on behalf of İLKNAK SU ÜRÜNLERİ SAN. VE TİC. A.Ş.
Corruption: The misuse of authority for personal gain.
Bribery: Offering, promising, or demanding a benefit to influence the performance of a duty. This includes cash, political donations, commissions, gifts, or hospitality.
Senior Management is responsible for establishing an ethical, reliable, and lawful work environment. Employees are required to comply with policies, effectively manage risks in their areas, and report any suspicious behavior.
İLKNAK only works with partners who meet our ethical standards. We do not engage with any organization that has negative intelligence regarding bribery or corruption. Agreements include clauses for termination in case of policy violation.
6.1 Bribery: Absolutely unacceptable regardless of purpose.
6.2 Gifts: Only symbolic, low-value gifts are permitted infrequently; others must be reported to HR.
6.3 Facilitation Payments: Strictly prohibited to secure routine government processes.
6.4 Donations: Charitable activities must comply with İlknak’s Donations policy and be independent of business gain.
All accounts and documents must be maintained accurately and reliably. Regular training programs are provided to raise employee awareness across HR, Accounting, and Management departments.
Violations or suspicions must be reported to senior management. Notifications are kept confidential, and good-faith reporting is encouraged. Non-compliance results in disciplinary action or contract termination for just cause.
At İlknak Aquaculture, we strive to contribute to economic, environmental, and social sustainability. This policy is based on international standards including the Universal Declaration of Human Rights, UN Global Compact, and ILO Conventions. It covers all our facilities and operations.
We provide equal opportunities for all employees. We do not tolerate discrimination based on race, language, gender, sexual orientation, age, physical disability, religious belief, or political opinion. We see diversity as a strength.
We have zero tolerance for physical, verbal, sexual, or psychological harassment and violence in the workplace. We protect the dignity of our employees and ensure they are treated with respect.
We encourage diversity among our employees and create an environment where everyone from different cultural, social, and individual backgrounds can contribute equally to an innovative culture.
Forced labor, human trafficking, and modern slavery are unacceptable in any form. We maintain a zero-tolerance policy against such activities.
We respect our employees' rights to freely organize, unionize, and engage in collective bargaining without fear of discrimination or pressure.
Working hours, wages, and benefits are determined in accordance with legal regulations and international standards. We implement fair wage policies and respect our employees' right to rest and vacation.
Ensuring the safety and protection of our employees is our top priority. We provide a safe, healthy, and non-discriminatory environment with continuous improvement processes.
We treat our employees honestly and fairly. Communication, transparency, and mutual respect are the essential pillars of our management style.
All managers and employees are responsible for the implementation of this policy. Necessary measures and corrective actions are implemented in case of violations.
1. AIM: This procedure aims to regulate the ethical principles that employees of İLKNAK SU ÜRÜNLERİ SAN. VE TİC. A.Ş. must adhere to, and to ensure compliance with laws, universal legal principles, and professional ethics.
2. SCOPE: It covers all ethical principles with a "zero tolerance" approach against bribery and corruption.
3. DEFINITIONS: EYS stands for Integrated Management System (Sedex, BRCGS, ISO, etc.).
4. RESPONSIBILITIES: Senior management and the Human Resources Manager are responsible for implementation.
A. Honesty: Primary value in all business processes.
B. Privacy: Protection of trade secrets, personal data, and inside information ("insider trading" is unacceptable).
C. Conflict of Interest: Avoiding personal gain through family, relatives, or the İlknak name.
D. Our Responsibilities:
1. Legal Responsibilities (Republic of Turkey and International Law).
2. Customers (Satisfaction, respect, and fairness).
3. Employees (Personal rights, non-discrimination, safe environment).
4. Partners (Sustainability, financial discipline, and value creation).
5. Suppliers/Business Partners (Fairness and confidentiality).
6. Competitors (Ethical competition).
7. Society and Humanity (Democracy, human rights, and environmental protection).
8. "İlknak" (Maintaining reputation and professional competence).
Activities That May Create Conflict:
- Doing business with family members or friends (Purchasing, etc.).
- Working for another institution for remuneration without approval.
- Serving as a board member in competing companies.
- Using authority (Abuse of Office) for personal gain.
- Misuse of Company resources (Time, assets, personnel).
- Accepting personal loans from customers or subcontractors.
- Media relations must follow the Company Communication Protocol.
1. No gifts that influence impartiality may be accepted.
2. Gifts must comply with legislation and business objectives.
3. Meals and refreshments are acceptable within business standards.
4. Gifts under 2000 TL (per year/person) may be accepted without approval; New Year items (books, chocolates) are excluded.
5. Bribery and commissions are strictly prohibited.
6. Cash loans or event coverage by suppliers/customers are not permitted.
- Confidential information (trade secrets, financial data, personal data) may not be disclosed to third parties unless required by law.
- Files and passwords must be kept secure; confidential topics should not be discussed in public places (elevators, cafeterias).
- Sharing information with third parties requires a confidentiality agreement.
- Confidentiality obligations continue even after an employee leaves the company.
- Compliance with all employment laws and fair HR practices (recruitment, promotion).
- Zero tolerance for discrimination based on race, gender, religion, etc.
- Protection of physical, sexual, and emotional inviolability.
- Prevention of workplace harassment and mobbing (systematic intimidation).
- Ensuring a healthy and safe work environment with sensitivity to environmental impacts.
- Comply with laws and learn company policies.
- Promptly report potential violations to the Ethics Committee.
- Cooperate in ethical investigations and keep information confidential.
Ethical Decision-Making Steps:
1. Identify the problem. 2. Think before deciding. 3. Decide on an action plan. 4. Test the decision. 5. Persevere.
Managers: Must set an example, support employees in reporting, and minimize ethical risks in business processes.
Senior Management & HR: Responsible for reviewing the Code of Ethics, providing training, guaranteeing the confidentiality of reports, and protecting whistleblowers from retaliation.
Senior Management: Responsible for the effective implementation of ETHICS and fostering a supportive culture.
Human Resources Manager: Reviews and documents the Code of Business Ethics based on Ethics Committee recommendations.
Employee Awareness: HR is responsible for informing employees, providing periodic training, and maintaining continuous communication.
Confidentiality & Safety: Management guarantees the confidentiality of notifications and ensures the occupational safety of whistleblowers, protecting them from any retaliation.
Employees are obligated to report violations to their direct supervisor, the Code of Ethics Advisor, the Hotline, or the General Manager. If unresolved, the matter reaches the Ethics Committee.
- Violators face disciplinary sanctions, including termination.
- Sanctions also apply to those who approve or fail to report inappropriate behavior.
- False or defamatory statements are considered ethical violations and may lead to legal action under the Turkish Penal Code and Labor Law.
The committee resolves conflicts of interest and evaluates ethical violations:
- Chairman: Georgios Meletiadis (General Manager)
- Member: Aslı Oğuz (Human Resources Manager)
- Member: Attorney Ali Can Kahyaoğlu (Legal Advisor)
1. Confidentiality: Identities and reports are kept strictly confidential.
2. Protection: Whistleblowers are protected from pressure, discrimination, or mobbing.
3. Authority: Investigators can request any relevant information/documents directly.
4. Documentation: All processes are recorded in writing and signed.
5. Urgency: Investigations are handled as quickly as possible and decisions are implemented immediately.
6. Independence: Committee members act independently of the organizational hierarchy.
Email: etik@ilknak.com
Telephone: +90 232 330 40 86 (Weekdays 07:30-16:30)
Mail Address:
İlknak Seafood Industry and Trade Inc.
To the attention of the Ethics Committee
Çavuş Neighborhood, Çavuş Yolu Street, İlknak Site
No: 14, 35660, Menemen, Izmir
Process Owners: Senior Management and Human Resources Manager.
Appendices:
- P23-TA01: Instruction on Child Labor Prevention
- P23-TA02: Prevention of Cruel Treatment, Violence and Abuse
- P23-RA01: Corruption Risk Analysis Table
System References: GLOBAL GAP, BRCGS, IFS, ASC, ISO 14001, ISO 45001, ISO 9001, ISO 22000, Smeta Sedex.
Rev 01 (June 11, 2015): Transition to BRC v7 and GlobalGap v5; logo update and document re-coding.
Rev 02 (Dec 01, 2021): General revision and updating of documents.
Rev 03 (Aug 23, 2023): Expanding business ethics rules and defining application areas.
1. AIM: To prevent child labor at İLKNAK SU ÜRÜNLERİ SAN. VE TİC. A.Ş. and to ensure remediation processes comply with national legislation, ILO guidelines, and Sedex/SMETA requirements.
2. IMPLEMENTATION MANAGER: General Manager, Department Managers, and HR Officer.
• Child Labor: A person under the age of 15 employed in any capacity (Turkish Labor Law Art. 71 / ILO No. 138).
• Young Worker: A person aged between 15 and 18.
• Remediation: Implementing a sustainable support plan prioritizing safety, education, and well-being instead of simple dismissal.
4.1 Preventive Measures:
- Age verification via national ID or passports during recruitment.
- "No child labor" commitments in subcontractor contracts.
- Annual internal social compliance audits.
4.2 Detection Protocol:
If child labor is detected:
1. Immediate removal from production to a secure location.
2. Verification of age, identity, and family details.
3. Ensuring physical/psychological safety (no criminal proceedings against the child).
4. Reporting to the local Labour Directorate and/or Social Services Agency.
• Support over Dismissal: Children are not dismissed; they are supported in their best interest.
• Education: Encouragement and support for school registration and continued education.
• Family Cooperation: Alleviating economic hardship through local institutions (NGOs, municipalities).
• Financial Alternatives: Exploring adult employment opportunities for the family members.
• Monitoring: Periodic observation until the individual reaches the age of 18.
• Record Keeping: Confidential storage of all records for at least 5 years.
References:
- ILO Convention No. 138 (Minimum Age) & No. 182 (Worst Forms).
- Turkish Labor Law Article 71.
- Sedex/SMETA 4-Pillar Standards.
Revision History:
Current Revision: 01 - Initial release and integration with the social compliance system.
1. AIM: To ensure that no employee at İLKNAK SU ÜRÜNLERİ SAN. VE TİC. A.Ş. is subjected to physical, psychological, or sexual violence, coercion, force, or degrading treatment, including gender-based violence and harassment.
2. IMPLEMENTATION MANAGER: General Manager, Department Managers, and HR Manager.
• Harassment: Verbal, physical, or behavioral actions that damage dignity or create a hostile environment.
• Gender-based Violence: Assault against a person because of their gender, sexual orientation, identity, or expression.
• Inhuman/Abusive Treatment: Physical punishment, threats, insults, humiliation, forced labor, or mistreatment under the guise of discipline.
- All employees receive and sign the "Human Rights Procedure" upon starting employment.
- The policy is displayed on notice boards, in common areas, and in the employee handbook.
- "Human Rights Policy and Discrimination Training" is conducted at least once a year.
Employees can report incidents through the following channels:
• Internal: Human Resources Department, Suggestion/Complaint Boxes, or managers.
• Email: etik@ilknak.com
• Tesco Protector Line: Call 0800 621 2345 or visit protectorline.ourtesco.com.
• Intertek Compliance Officer: Burcu Turhan Uzuner (Phone: 0212 496 4613 | Email: burcu.turhan@intertek.com).
Confidentiality: All complaints are recorded and evaluated confidentially. Temporary reassignment or leave may be provided for the victim's safety.
Investigation Process:
- Evidence is gathered and parties are heard within 10 business days.
- Parties are granted the right to a fair trial.
- Final report leads to disciplinary actions (warning, reprimand, or termination).
Support Measures:
- Victims are provided with psychological counseling or health support.
- Privacy and the prohibition of retaliation are strictly guaranteed.
- Cooperation with the Ministry of Family and Social Services is established when necessary.
• ILO Convention No. 190 (Violence and Harassment)
• Company Code of Ethics and Human Rights Policy
• Turkish Labor Law
• Sedex/SMETA 4 Pillar Standards
ILKNAK SU ÜRÜNLERİ A.Ş. customers, suppliers and business partners can send their notifications covering ethical issues by sending an e-mail to etik@ilknak.com .
