Code of Ethics Policy

Ethical Principles Policy

This Code of Business Ethics outlines the principles and rules that Tio Lojistik Ltd. Şti. (hereinafter referred to as “Tio Logistics”) will follow in all activities carried out both internally and with third parties.

This Ethical Principles Policy also represents Tio Logistics’ commitment to being fully aware of its responsibilities, maintaining honest and proper relationships with its stakeholders, and ensuring full compliance with all international, national, and local laws and regulations in its operations.

1. General Commitment and Purpose

Our ethical principles form the foundation of all our business processes and guide our decision-making mechanisms.

This commitment is essential to the reputation and sustainable success of our company.

Tio Logistics undertakes to ensure full compliance with all applicable national and international laws and regulations in all its activities.

The company adopts an ethical structure aligned with its Quality, Safety, Health, Environment (QSHE) and Corporate Social Responsibility (CSR) policies. These principles complement and reinforce the company’s QSHE, Safety, and CSR policies.

All Tio Logistics employees, managers, business partners, and their employees are required to act in accordance with these ethical principles.

2. Human Rights and Employee Rights

Protecting the rights of our employees helps us create an environment of trust and respect. Offering equal opportunities to all employees enables us to build an inclusive corporate culture.

Tio Logistics respects universally accepted human rights. Child labor and forced labor are strictly prohibited. Discrimination based on race, gender, religion, age, disability, or any similar grounds is not tolerated.

3. Fair Working Practices

Tio Logistics is committed to providing a safe, respectful, and equitable working environment for all employees.

Recruitment, promotion, compensation, and termination processes are free of discrimination; decisions are based solely on merit, performance, and job requirements.

Employees are granted access to all legally mandated social rights, and fundamental working conditions—such as working hours and rest periods—are organized in compliance with applicable regulations.

Tio Logistics supports the development of its employees by offering training and development opportunities and adopts an approach that respects work–life balance.

4. Freedom of Choice and Association

Employees are not forced to work at Tio Logistics. Each employee has the right to choose their profession freely and may terminate their employment contract in accordance with applicable laws and regulations.

We respect employees’ rights—within the limits of legislation and employment contracts—to organize, join labor unions, appoint representatives, and engage in collective bargaining. Internal consultation and representation through elected delegates are encouraged.

5. Conduct Toward Society

Our employees reflect the image and values of our company. Employees are expected to maintain polite, respectful, and professional behavior toward each other, our customers, and our business partners at all times.

6. Personal Data and Information Security

Data security is critical to protecting the rights of both our employees and our customers.

All company-related data and employee information are protected in accordance with international privacy laws.

Ensuring the security of personal data and compliance with ethical rules governing electronic communication is essential.

7. Diversity, Equality, and a Harassment-Free Workplace

We value the unique differences of every individual and regard diversity as a corporate asset. Combating harassment and discrimination ensures that our employees feel safe.

Tio Logistics promotes diversity and provides an inclusive working environment. Zero tolerance is applied to bullying, sexual harassment, and any form of physical or verbal abuse. Employees have the right to report unethical behavior anonymously.

8. Occupational Health and Safety

Occupational health and safety practices directly affect the well-being and productivity of our employees.

A safe and healthy working environment is provided, and maximum effort is made to prevent potential accidents.

Compliance with the most up-to-date safety regulations is ensured, including the placement of necessary equipment and the implementation of measures to prevent injuries, illnesses, occupational diseases, and material damage.

9. Environment and Sustainability

Tio Logistics fully complies with environmental regulations and strives to reduce any negative environmental impacts arising from its activities, contributing to a sustainable future. The company supports clean-sweeping programs to prevent plastic pellet and microplastic pollution.

Tio Logistics recommends that its subcontractors operate with more environmentally friendly and fuel-efficient vehicles. Employees actively contribute to achieving these environmental objectives.

10. Business Ethics and Integrity

We operate in accordance with the principles of transparency and accountability in all business relationships. When unethical behavior is identified, appropriate disciplinary processes are initiated immediately.

Tio Logistics conducts its activities in line with the principles of transparency, fair competition, and respect for intellectual property rights.

Fraud, misuse of information, and distortion of facts are not tolerated.

11. Anti-Corruption, Anti-Bribery, and Gift Policy

Integrity and impartiality are fundamental principles in our business relationships. The acceptance of gifts is restricted so that employees’ decision-making processes are not influenced.

Corruption, bribery, embezzlement, and money laundering are strictly prohibited. Symbolic gifts with a maximum value of 200 TRY may be accepted. Cash or cash-equivalent gifts may not be offered or accepted.

12. Conflicts of Interest

Employees are required to prioritize the interests of the company when performing their duties. Personal interests must not conflict with company interests.

Employees must avoid any activity that may lead to a conflict of interest.

13. Implementation, Reporting, and Audit Process

Compliance with ethical principles is supported through regular training and awareness programs.

Audit results are evaluated through feedback mechanisms to support continuous improvement.

All employees are required to adhere to these ethical principles. Serious violations must be reported to management or designated representatives.

Employees who report violations are protected, and all reports are investigated, followed by the implementation of necessary sanctions.

14. Accountability

In the event that non-compliance is identified through legal audits or inspections, the company will investigate the issues and take necessary corrective measures.

If findings confirming non-compliance are verified, Tio Logistics will accept the legal and administrative consequences of such violations.

Human Resources Policy

Human resources is a strategic function that encompasses the management and development of employees—the most valuable asset of any organization. This Human Resources Policy serves as a fundamental framework that supports our people-centric approach, ethical values, and sustainable growth objectives. Designed to strengthen our corporate culture, enhance employee satisfaction, and ensure operational efficiency, this document guides all human resources practices within our company.

The policy section outlines the core principles, values, and strategic approaches adopted by our company in human resources management. Topics such as equal opportunity, respect for employee rights, ethical standards, and training and development are addressed in detail. These principles not only ensure legal compliance but also create a work environment where employees feel safe, valued, and motivated, thus reinforcing corporate commitment.

This document serves as an official reference for ensuring quality, fairness, and continuity in our human resources management. Adherence to this policy supports employees’ individual development and contributes to the long-term success of our company. In order to strengthen the effectiveness of our HR practices and ensure continuous improvement, this document will be reviewed and updated regularly.

1. Purpose and Scope

Our Human Resources Policy defines the fundamental principles, values, and implementation standards applicable to all employees of our company. This policy covers all HR processes, from recruitment to separation, and emphasizes the strategic importance of human capital in our company’s sustainable success. All employees, managers, and relevant stakeholders fall within the scope of this policy.

2. Core Principles and Values

The core principles that guide our human resources management include fairness, transparency, trust, respect, and continuous development. These principles support the foundation required to create a long-term, career-focused workforce built on mutual confidence. We respect the rights of all employees, promote equal opportunities, and support diversity. Our corporate values aim to ensure that employees feel safe and valued in their work environment.

3. Equal Opportunity and Prevention of Discrimination

Our company embraces the principle of equal opportunity in all HR processes, including recruitment, promotion, training, and development. Discrimination based on race, gender, age, religion, disability, or any other factor is strictly prohibited. Ensuring a fair and impartial approach for all employees is one of the core elements of our corporate culture.

4. Employee Rights and Ethical Standards

We respect the fundamental rights and freedoms of our employees and act in accordance with ethical standards. Honesty, confidentiality, mutual respect, and professionalism guide workplace conduct. All employees are expected to comply with company ethics and legal regulations.

5. Recruitment and Placement

Our recruitment processes aim to select qualified, competent, and value-aligned candidates who meet the needs of the company. Objective criteria are used in candidate evaluations, and transparency is maintained throughout the process. Orientation programs are designed and implemented to ensure that new employees adapt quickly and effectively to their roles. Job descriptions are established, and necessary support is provided for their development.

6. Training and Development

We organize continuous training and development programs to support the professional and personal growth of our employees. Training and Behavior-Based Safety (BBS) needs are regularly analyzed, and opportunities that enhance employee competencies are offered. By embracing a learning-organization culture, we aim to maximize the potential of our employees.

7. Performance Management

Our performance management system supports employees in achieving their goals and contributing to the company’s strategic objectives. Performance evaluations are conducted at regular intervals based on objective criteria. Through structured feedback processes, employee development is encouraged, and achievements are recognized and rewarded.

8. Compensation and Benefits

Our compensation policy is fair, competitive, and transparent. We provide various benefits and social programs to enhance employee motivation and strengthen their commitment to the company. Compensation and benefits are reviewed regularly in accordance with market conditions and the company’s financial performance.

9. Employee Communication and Engagement

Open communication and employee engagement are critical to the success of our company. We establish various communication channels through which employees can share their opinions and suggestions. With a participatory management approach, we encourage active employee involvement in decision-making processes.

10. Occupational Health and Safety

The health and safety of our employees are among our highest priorities. Full compliance with occupational health and safety regulations is ensured and risks are regularly assessed. Necessary measures are taken to provide a safe working environment; PPE is supplied where required; and improvement initiatives are continuously carried out across all work areas.

11. Employee Satisfaction and Motivation

Regular surveys and evaluations are conducted to enhance employee satisfaction and motivation. Practices that support work–life balance and overall well-being are implemented. Our company prioritizes the happiness and commitment of its employees.

12. Confidentiality and Protection of Personal Data

All personal data belonging to our employees is protected in accordance with applicable legislation and company policies. Necessary technical and administrative measures are taken to ensure data confidentiality and security. Unauthorized sharing of employees’ personal information is strictly prohibited.

13. Policy Review

Our Human Resources Policy is regularly reviewed in line with changes in legal regulations, sector dynamics, and company needs. When necessary, the policy is updated and communicated to all employees. The effectiveness of the policy is assessed through periodic evaluations.

14. Discipline

All employees may communicate their needs and complaints without hesitation. A Disciplinary Procedure, Confidential Contact Person, and Ethics Committee system are established, and all processes are managed in strict confidentiality.

15. Working Environment

A productive working environment is created by considering social, physical, psychological, and environmental factors while employees perform their assigned duties. Necessary equipment and software are provided. Employees are expected to remain aware of environmental factors affecting their work and to contribute to continuous improvement efforts.

16. Employees with Disabilities and Ex-Offenders

For the purpose of this policy, “individuals with disabilities” refers to those who are certified with a medical board report indicating at least 40% loss of physical function. “Ex-offenders” refers to individuals with final court convictions.

Our company complies with legal obligations for employing individuals with disabilities and ex-offenders. According to Article 50 of the Labor Law:

“Employers who employ fifty or more workers must employ three percent individuals with disabilities in private-sector workplaces, and four percent individuals with disabilities and two percent ex-offenders in public workplaces, or individuals injured during military service as defined in the relevant legislation.”

Accordingly, if the number of employees exceeds fifty, our company employs individuals with disabilities and ex-offenders in the legally required proportions.

In cases where mandatory employment quotas cannot be fulfilled internally, recruitment from the Turkish Employment Agency (İŞKUR) is carried out to fill these positions in compliance with the legislation.

Integrated Management System Policy

At TİO Logistics, we are fully aware of the expectations and needs of our stakeholders, our environmental responsibilities, the importance of protecting the health of our employees, and the significance of our service quality. We aim to continuously improve the knowledge and skills of our employees, ensure their health and safety, maximize customer satisfaction, enhance our quality standards, increase energy efficiency, minimize our environmental impacts, and support sustainable development. This policy has been established to collectively achieve these objectives in an integrated manner.

1. Our Commitments

Establish measurable objectives and targets within the scope of the Integrated Management System, monitor them periodically, and ensure the availability of necessary resources and information to achieve those targets.
Record, report, and communicate performance and implementation data to relevant stakeholders.
Identify risks and opportunities and plan necessary actions.
Ensure compliance with all applicable national and international legal and other requirements related to our services and activities.
Continuously improve the Integrated Management System through project development.
Periodically review and enhance the suitability and effectiveness of our Integrated Management System.
Support and allocate resources for initiatives that instill a behavior-based safety culture among TİO Logistics employees and subcontractors across all work areas.
Lead, implement, monitor, develop, and encourage the application of company policies and ethical principles together with all employees and subcontractors as our top priority.

1.1. Quality

Build strong, long-term relationships with customers and ensure business continuity.
Assess customer needs and expectations and offer appropriate services.
Allocate necessary resources to meet customer requirements.
Provide cost advantages by offering multimodal transport alternatives with flexible routing and pricing solutions.
Evaluate customer feedback promptly and offer solutions.
Continuously monitor and improve customer satisfaction.

1.2. Occupational Health and Safety

Eliminate hazards and reduce OHS risks to ensure a safe working environment.
Prevent injuries and health deterioration of employees.
Establish an OHS culture and ensure employee consultation and participation.

1.3. Environment

Prevent pollution at its source and minimize waste.
Reduce the negative environmental impacts of our activities through life cycle assessment.
Use natural resources efficiently.
Identify activities that generate greenhouse gas emissions and reduce emissions within the scope of climate change actions.
Use appropriately equipped cleaning stations and environmentally suitable cleaning methods both domestically and internationally.

1.4. Energy

Implement energy-saving measures and efficiency-enhancing improvements in all operations, and promote the use of renewable energy sources.
Develop projects to reduce carbon and water footprints.
Prefer environmentally and energy-friendly technologies in new projects and equipment purchases.
Ensure the design or procurement of products and services with high energy efficiency.

1.5. Training

Conduct needs analyses for training activities.
Organize training programs to continuously improve employees’ knowledge and skills.
Develop programs to support employee career development and encourage training participation.
Provide regular training using diverse and innovative methods.
Measure and evaluate the impact of training on employee performance.

1.6. Social Responsibility & Stakeholder Engagement

Act equally and fairly regarding human rights and remain sensitive to the traditions and cultures of all countries where we operate.
Prevent discrimination based on religion, language, belief, sect, race, color, gender, political views, age, disability, or similar grounds.
Avoid all behaviors that violate ethical and conduct rules and train employees accordingly.
Maintain transparent, accurate, stable, and trust-based communication with all stakeholders.

1.7. Alcohol and Drug Policy

Zero tolerance for the use or influence of alcohol or drugs during working hours for all personnel and individuals working on behalf of TİO Logistics; such substances are strictly prohibited.
Apply disciplinary procedures in case of non-compliance.

1.8. Behavior-Based Safety (BBS)

Provide necessary training and accreditation, particularly in behavior-based safety.
Identify, monitor, and eliminate unsafe conditions and behaviors that lead to those conditions.
Ensure voluntary and active participation of employees in BBS practices and create an environment of open communication and trust.
Implement observation and feedback mechanisms that encourage safe behavior and reduce unsafe actions.
Conduct BBS processes in line with national/international OHS standards and SQAS requirements.
Regularly monitor, analyze, and update the effectiveness of BBS applications using a continuous improvement approach.
Ensure that personnel performing observations have appropriate professional qualifications or receive necessary training and competence.
Store observation data confidentially and protect employees’ personal rights.
Provide necessary training and accreditation for behavior-based safety, especially during driving, loading, and unloading operations.
Identify, monitor, and eliminate unsafe situations in driving and loading/unloading areas by implementing corrective actions.
Create positive reinforcement and feedback systems that support safe behavior and reduce unsafe actions.
Ensure that observation personnel are professionally qualified or adequately trained.
Keep observation data confidential and protect employee privacy.
Increase awareness of the use of personal protective equipment (PPE), ensure correct equipment selection, and support complete PPE use through behavior-based observations, training, and feedback mechanisms. PPE use is considered a fundamental indicator of safe behavior and an integral part of BBS processes.

1.9. Security

Ensure the protection of third parties, employees, customer property, and sensitive information.
Protect customer property against losses arising from intentional destruction or theft and ensure safe handling and delivery according to final destination and customer requirements.
Conduct Route Risk Assessments (JRA) addressing environmental, human, and security factors and implement necessary actions.

1.10. Corporate Social Responsibility

Conduct all operations with an integrated business model aligned with the philosophy of Corporate Social Responsibility (CSR).
Avoid discrimination among employees, consult them on important matters, allow flexible working conditions when appropriate, uphold fundamental rights, act honestly, transparently, and proactively, and share company values and ethical rules with relevant stakeholders.

1.11. Nonconformity Reporting

Identify any nonconformities during operations, conduct necessary analyses, determine root causes, implement corrective actions, share the outcomes with relevant parties, and prevent recurrence.

1.12. Information Security

Protect all digital information, including confidential data entrusted to TİO Logistics.
Ensure the confidentiality, integrity, and availability of information.
Limit access rights according to job descriptions and prevent unauthorized access.
Enforce secure password management, multi-factor authentication, and regular password updates.
Implement contractual and technical measures to protect information shared with subcontractors, suppliers, and business partners.
Apply preventive, detective, and corrective controls against information security breaches and cyberattacks.

Personal Data Protection and Privacy Policy

As TIO Logistics, we attach great importance to the confidentiality of your personal data. This policy explains how we collect, use, store, and protect the personal data you share with us. Below, you can find information about the practices we implement to protect your personal data.

This policy is prepared and implemented in accordance with the Law on the Protection of Personal Data No. 6698 (“KVKK”) and the relevant secondary legislation.

In cases not regulated in this policy, the provisions of the Law on the Protection of Personal Data No. 6698 shall apply in a supplementary manner.

1. Collection and Processing of Personal Data

While you are using our services, we may collect personal information from you such as your name, surname, contact details (telephone number, e-mail address), address, and other necessary data. This data may be processed for purposes such as the provision of our logistics services, customer relationship management, evaluation of requests and complaints, and the fulfilment of legal obligations.

Within the scope of the business relationship between our Company and the company you work for, your data is processed to the extent permitted by the applicable legal regulations, in printed and/or wet-signed form or electronically, by automatic or non-automatic means, for the following purposes: fulfilment of obligations arising from labor and social security legislation, ensuring and monitoring compliance with workplace rules of our Company, ensuring workplace security, managing occupational health and safety processes, ensuring the continuity of our Company’s operations, maintaining existing commercial and legal relationships with our business partners, customers and suppliers, managing processes before public institutions and organizations such as İŞKUR, the Ministry of Labor and Social Security, the Social Security Institution and other relevant authorities.

2. Sharing of Personal Data

The personal data collected may be shared with third parties only for the purpose of providing services, within the framework of legal obligations based on applicable legislation, and after necessary security measures have been taken. Your personal data may be shared only with our business partners, suppliers, service providers and relevant institutions.

Our Company may transfer your personal data, within the scope of KVKK and other applicable legislation and for the purposes mentioned above, to relevant persons and institutions. These may be persons designated by law, or persons and institutions determined by contract. Employees consent to the sharing of their personal data.

Your personal data may be transferred to our Company’s direct and indirect shareholders, affiliates and subsidiaries; third parties from whom we receive services and/or consultancy on behalf of our Company; third parties with whom sharing is necessary for the continuation of the service relationship; legally authorized public institutions and private persons; our customers, suppliers, business partners and service providers (such as insurance companies, service providers, travel agencies, technical support companies, etc.) within the scope of the performance of contracts, commercial relationships and commitments relating to our Company’s business and activities; lawyers and mediators for the management of disputes and legal proceedings; the company providing occupational health and safety services, workplace physicians, private and public healthcare institutions, the Social Security Institution and other relevant public institutions and organizations, in order to fulfil our obligations under labor law and occupational health and safety legislation.

3. Storage of Personal Data

Your personal data will be stored only for the period necessary to provide our services and to fulfil our legal obligations, and for the legally required retention periods. At the end of these periods, your data will be securely deleted, destroyed, or anonymized.

4. Security of Personal Data

The security of your data is extremely important to our Company. Physical, technical and administrative security measures are implemented to prevent unauthorized access, loss, or misuse of your personal data. However, as data transmission over the Internet cannot be guaranteed to be absolutely secure, we would like to remind you to exercise caution in such cases.

5. Access to and Correction of Your Personal Data

Pursuant to Article 7 of KVKK, you have rights such as accessing your personal data, updating it, or requesting its deletion. You may contact us to exercise these rights.

In accordance with Article 13(1) of the Law No. 6698, you may submit your requests relating to the exercise of your rights in writing and in Turkish, or via registered electronic mail (KEP), secure electronic signature, mobile signature, or by using the e-mail address previously notified to our Company and registered in our systems, to the e-mail address specified in Article 6.

Our Company will finalize the request, depending on its nature, as soon as possible and at the latest within thirty days, free of charge. However, if the process requires an additional cost, a fee may be charged in accordance with the tariff determined by the Personal Data Protection Board.

Our Company reserves the right to verify your identity before responding.

6. Contact Information

If you have any questions or requests regarding your personal data, you may contact us at: info@tiolojistik.com.tr

7. Confidentiality Obligation

Any and all formulas, know-how, ideas, business information, methods, progress data, procedures, computer programs, customer information, trade secrets, and, in short, all commercial, financial and technical information as well as customer, market and production data belonging to TIO Logistics’ customers or to TIO Logistics itself, which the employee learns in connection with the commercial relationship; and any written and/or verbal commercial, financial, technical information that the parties and their employees learn from each other during the course of the commercial relationship shall be deemed “Confidential Information”.

The Employee:

a. Accepts and undertakes that the confidential nature of the Confidential Information will be preserved, that such Confidential Information will be used only within the scope of the commercial relationship, and that the Confidential Information will not be used for personal or third-party benefit or for commercial gain;

b. Accepts and undertakes not to disclose the Confidential Information to any third party other than its employees, managers, members of the board of directors, shareholders, representatives and professional advisors, as set out in this agreement;

c. Accepts and undertakes that, except where required within the scope of the commercial relationship, no part of the Confidential Information will be reproduced, copied, distributed or put into writing, and that any Confidential Information reproduced, copied or put into writing within the scope of the commercial relationship shall belong to TIO Logistics and remain its property;

d. Accepts and undertakes that the Confidential Information will only be disclosed, within the limits of trust and after obtaining their undertakings to comply with this confidentiality undertaking and the relevant confidentiality terms, to employees, managers, members of the board of directors, shareholders, representatives or professional advisors who need to know such information in order to perform their duties.

A breach of the confidentiality obligation entails the obligation to compensate all damages suffered by TIO Logistics and/or TIO Logistics’ customers or business partners, as well as the obligation to pay TIO Logistics a contractual penalty of USD 10,000.

8. Amendments and Entry into Force

This privacy policy may be updated from time to time in line with legal requirements and changes within our Company. Policy amendments shall become effective upon the entry into force of the relevant legislation, upon your written declaration, or upon publication on our website.

Within the scope of this consent text, the contracts to which our Company is a party, and to the extent permitted by legal regulations, our employees hereby declare that they have been duly informed and that they consent to the recording and sharing of their personal data by our Company.