Otokar Otomotiv ve Savunma Sanayi A.Ş.

Based on public information, there is no readily available evidence that the company publishes a statement from the Chief Executive Officer or the Chair of the Board supporting the ethics and anti-corruption agenda of the company. Statements from the company’s Chairman and the Koç Group’s Chairman are insufficiently focused on the company’s ethics and anti-corruption agenda. Furthermore, the preface to the Code of Conduct appears to have been published in 2010.

Based on public information, there is no readily available evidence that the company’s Chief Executive Officer or Chair of the Board demonstrate a strong personal, external facing commitment to the ethics and anti-corruption agenda of the company.

Based on public information, there is no readily available evidence that the company’s Chief Executive Officer demonstrates a strong personal, internal-facing commitment to the ethics and anti-corruption agenda of the company, actively promoting the ethics and anti-corruption agenda at all levels of the company structure.

Based on public information, there is evidence that the company publishes a statement of values representing high standards of business conduct, including honesty and integrity. The company explains what it means by these values and shows how they are translated into company policies, while referencing transparency and accountability.

Based on public information, there is evidence that as the Koç Group has signed the UN Global Compact, the company is bound to its 10 principles.

Based on public information, there is some evidence that the company has appointed a committee with overall corporate responsibility for its ethics and anti-corruption agenda. The company has a Code of Conduct Board that is responsible for auditing breaches and ensuring compliance. Despite evidence not suggesting that the Code of Conduct Board is a Board level committee, the terms of reference are explicit, with responsibilities clearly stated. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company has appointed a person at a senior level within the company to have responsibility for implementing the company’s ethics and anti-corruption agenda.

Based on public information, there is no readily available evidence of regular Board level monitoring and review of the performance of the company’s ethics and anti-corruption agenda.

Based on public information, there is no readily available evidence of a formal, clear, written plan in place on which the review of the ethics and anti-corruption agenda by the Board or senior management is based, or evidence of improvement plans being implemented when issues are identified.

Based on public information, there is some evidence that the company has a formal process for review and where appropriate updates its policies and practices in response to actual or alleged instances of corruption. If a Code of Conduct violation is detected in a periodic audit, the case will be reported to senior management and preventive measures are taken. The results are then given to the Audit Group and Human Resources Directorate to be archived centrally. If a manager becomes aware of alleged instances of corruption they will inform their General Manager, who will inform the business Unit Presidency and the Audit Group Presidency at Koç Hol. The company states that in 2013 no corrective actions were taken, as no instances of corruption were discovered. The company therefore scores 1. To score higher the company would need to provide evidence that preventive measures include updates to policies and practices, rather than solely disciplinary measures.

Based on public information, there is no readily available evidence that the company has a formal anti-corruption risk assessment procedure implemented enterprise-wide. The Risk Management Committee is responsible for the company’s Enterprise Risk Management system. The company identifies legal risks at the strategic level, and the company’s internal audit team and Koç Group’s audit teams perform audits to identify any incidences of corruption. However, there is no evidence that corruption is an identified risk at the strategic level, which is mitigated throughout the company. In the 2013 Sustainability Report the company states it does not publicise the number of business units that were analysed for corruption risks.

Based on public information, there is no readily available evidence that the company has a formal anti-corruption risk assessment procedure for assessing proposed business decisions, with clear requirements on the circumstances under which such a procedure should be applied.

Based on public information, there is no readily available evidence that the company conducts due diligence that minimises corruption risk when selecting or reappointing its agents.

Based on public information, there is no readily available evidence that the company has contractual rights and processes for the monitoring, control, and audit of agents with respect to countering corruption. TI notes that evidence shows the company expects its business partners to behave in conformity with its Ethical Principles.

Based on public information, there is evidence that the company makes clear to contractors, sub-contractors, and suppliers, through policy and contractual terms, its stance on bribery and corruption. Suppliers must act in accordance with the UN Global Compact and the company’s business practices. However, despite the company auditing suppliers for compliance with the UN Global Compact, the purchase contract does not contain a clause that if the supplier fails to adhere to agreements in regard to business ethics and the UN Global Compact, it will suffer sanctions. The company therefore scores 1. To score higher the company would need to provide evidence that it has contractual rights to apply sanctions in the event of a breach of its contract.

Based on public information, there is no readily available evidence that the company engages in offset contracting.

Based on public information, there is no readily available evidence that the company engages in offset contracting.

Based on public information, there is some evidence that the company has an anti-corruption policy that prohibits corruption. This includes the giving and receiving of bribes and corrupt gifts and hospitality. The company therefore scores 1. To score higher the company would need to provide evidence that it prohibits other forms of corruption such as kickbacks and facilitation payments.

Based on public information, there is evidence that the company has a zero tolerance policy for violations of its Code of Ethics and Business Conduct. All employees must comply with the Code and violations result in disciplinary actions. The company therefore scores 1. To score higher the company would need to have an explicit zero tolerance policy of corruption or bribery. The company states that it is tackling bribery and corruption, but this is insufficiently strong to be applicable for this question.

Based on public information, there is evidence that the company’s ethics and anti-corruption policies are easily accessible to Board members, employees, contracted staff and third parties. Both the company’s Ethical Code and the Koç Group’s Code of Ethics and Business Conduct are available respectively on their websites, in English and Turkish. Koç Group’s Code of Ethics and Business Conduct is provided to every Group company employee.

Based on public information, the company’s ethics and anti-corruption policies are easily understandable and clear to Board members, employees and third parties. Both the company’s Ethical Code and the Koç Group’s Code of Ethics and Business Conduct are written using accessible, comprehensible language.

Based on public information, there is evidence that the company’s ethics and anti-corruption policies apply to all employees. The company therefore scores 1. To score higher the company would need to provide evidence that its ethics and anti-corruption policies also apply to Board members.

Based on public information, there is evidence that the company has a policy on potential conflicts of interest. The policy includes a definition of conflicts of interest and a range of examples. Evidence does not show that the policy applies to Board members. However, the policy is assessed to be sufficiently strong to score full marks here.

Based on public information, there is evidence that the company has a policy for the giving and receipt of gifts, to ensure that such transactions are bona fide and not a subterfuge for bribery. Gifts may only be accepted or given if they are of a low value and do not give the impression of corruption. Cash, gift checks and precious metal can never be accepted as gifts. The company therefore scores 1. To score higher the company would need to provide evidence that it sets clear upper limits on the acceptable value of a gift and/or has the requirement for senior management authorisation if a value threshold is exceeded.

Based on public information, there is no readily available evidence that the company has a policy for the giving and receipt of hospitality, to ensure that such transactions are bona fide and not a subterfuge for bribery. The company discusses the regulations in regard to employees receiving a gift or favour, but it does not explain that a favour can be defined as hospitality.

Based on public information, there is no readily available evidence that the company has a policy that explicitly prohibits facilitation payments.

Based on public information, there is evidence that the company prohibits political contributions in order to prevent undue influence or other corrupt intent.

Based on public information, there is no readily available evidence that the company has a clear policy on engagement in lobbying activities, in order to prevent undue influence or other corrupt intent, or discloses the issues on which the company lobbies. TI notes that the company states that it is not an active participant in the political and public policy making process. However, the Koç Group 2013 Corporate Social Responsibility Report details that Group companies comunicate with public authorities in regard to commercial and social responsibility projects.

Based on public information, there is some evidence that the company regulates charitable contributions in order to prevent undue influence or other corrupt intent. The company has a donations policy, but this is not publically accessible. However, the company states that all employees may not give support to any society or entity, without prior approval from Human Resources. The company details the annual donation amount in its annual report. The company therefore scores 1. To score higher the company would need to provide further evidence of the donations policy, for example due diligence on potential recipients, and publically declare recipients.

Based on public information, there is no readily available evidence that the company provides written guidance to help Board members and employees understand and implement the firm’s ethics and anti-corruption agenda.

Based on public information, there is no readily available evidence that the company has a training programme that explicitly covers anti-corruption. TI notes that in its ethical code the company states that it provides training to ensure job and personal development for employees. However, it is unclear if this includes a focus on ethics and compliance.

Based on public information, there is no readily available evidence that anti-corruption training is provided in all countries where the company operates or has company sites.

Based on public information, there is no readily available evidence that the company provides targeted anti-corruption training to Board members.

Based on public information, there is no readily available evidence that the company provides tailored ethics and anti-corruption training for employees in sensitive positions.

Based on public information, there is evidence that the company has a clear and formal process by which employees declare conflicts of interest. Employees must disclose any potential conflicts of interest to a member of the Board of Ethics. The Board of Ethics must inform the Audit Group of all matters that are evaluated, and notify the Human Resources Director of any disciplinary action taken.

Based on public information, there is evidence that the company has an explicit commitment to apply disciplinary procedures to employees found to have violated the Code of Ethics and Business Conduct, which includes an anti-corruption policy. The company therefore scores 1. To score higher the company would need to provide evidence that disciplinary procedures are applied to Directors and Board members found to have violated the Code of Ethics and Busines Conduct.

Based on public information, there is some evidence that the company has accessible, secure and confidential channels, for employees to report concerns or instances of suspected corrupt activity. Channels include the General Manager, the President or the Koç Holding Audit Team. The company therefore scores 1. To score higher the company would need to provide evidence that it has at least one independent channel for employees to report to, which facilitates anonymous reporting.

Based on public information, there is evidence that across geographies, all employees have access to more than one reporting channel. These channels include their local General Manager, President or the Koç Holding Audit Team.

Based on public information, there is no readily available evidence that the company has formal and comprehensive mechanisms to assure itself that whistleblowing by employees is not deterred, or that whistleblowers are treated supportively. TI notes that the company carries out an annual employee survey, but there is no evidence that this includes questions on the whistleblowing process.

Based on public information, there is limited evidence that the company has well-publicised resources available to all employees, where help and advice can be sought on corruption-related issues. Employees have access to mid-level and senior managers, but there is no evidence that they are trained for the advisory job. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company has a commitment to non-retaliation for bona fide reporting of corruption.