Our Policies
· SUSTAINABILITY POLICY
· QUALITY, ENVIRONMENT, HEALTH AND SAFETY POLICY
· HUMAN RIGHTS AND BUSINESS ETHICS POLICY
· ZERO TOLERANCE TO VIOLENCE POLICY
· INFORMATION SECURITY POLICY
· ROAD TRAFFIC SAFETY POLICY
General Principles:
MRC Turkiye has adopted the UN Global Compact as the basis for its sustainability policy. The ten principles that together constitute the UN Global Compact are widely recognised and have been widely applied by many international companies. The principles reflect MRC Turkiye’s views on human rights, working conditions, the environment and the fight against corruption. MRC Turkiye has zero tolerance to all forms of corruption, extortion and bribery.
UN Global Compact – 10 principles:
Human Rights:
Businesses should support and respect the protection of internationally proclaimed human rights; and
Make sure that they are not complicit in human rights abuse.
Working conditions:
Businesses should uphold the freedom of association and support the right to collective bargaining;
The elimination of all forms of forced labour;
The abolition of child labour; and
The elimination of discrimination in respect of employment and occupation.
Environment:
Businesses should support a precautionary approach to environmental challenges.
Undertake initiatives to promote greater environmental responsibility; and
Encourage the development and diffusion of environmentally friendly technologies.
Anti-Corruption:
Businesses should work against corruption in all its forms, including extortion and bribery.
The MRC Turkiye Sustainability Policy lays down the principles on which the company’s commercial opportunities are to be assessed and evaluated before the business process commences. MRC Turkiye Sustainability Policy applies throughout the entire MRC Group.
MRC Turkiye will not engage in any project where there is a clear risk, in areas that we can influence, that MRC Turkiye’s or its client’s activities can come into
conflict with one or more of the ten principles of the UN Global Compact.
Application
Every commercial opportunity that meets one or more of the criteria below shall be the subject of a sustainability study before involvement in the business process can proceed further:
Criteria
There is reason to believe that project- related activities in areas that MRC Turkiye can influence can come into conflict with one or more of the 10 principles that constitute the basis for the UN Global Compact.
A sanction in some form or other has been imposed by the international community (UN, EU, EFTA, relevant financial institute) against our counterpart in the project.
There is a risk of public criticism, the involvement of voluntary organisations, riot, civil disobedience, criminal activity (organised or otherwise) or any other unwelcome attention or action that may delay or prevent the performance of the project as planned at the tendering stage.
The principles described above are to be included in the relevant routines and tools in every management system and quality manual at MRC Turkiye. Responsibility for this rests with each of MRC Turkiye’s divisions.
MRC Turkiye Sustainability Organisation has produced tools for evaluating the sustainability aspects of projects These tools are available via the MRC Turkiye business support and shared processes system.
MRC Turkey has adopted the following policies to ensure the long-term and sustainable success of its clients:
– Works closely with clients to deliver the best and most sustainable solutions in terms of quality, environment, occupational health and safety, and information security management systems.
– Ensures that our systematic and harmonious working approach also promotes quality, environmental sensitivity, and the reduction of risks that threaten occupational health and information security.
– Gives equal importance to client requirements, quality, environmental, occupational health, and information security criteria.
– Ensures the efficient use of energy and natural resources.
– Takes preventive measures to avoid environmental pollution and complies with all applicable laws.
– Within the scope of our environmental policy, commits to enhancing energy efficiency, adopting sustainable business practices, and acting with environmental responsibility in all activities to minimize climate change risks and contribute to combating climate change.
– Provides training for the sustainable development of employees’ skills and continuously improves working conditions.
– Adheres to all legal requirements and is committed to continuously improving its Quality, Environmental, Occupational Health, and Information Security Management System by ensuring consultation and participation of employees and their representatives.
– Ensures that documented policies for occupational health and safety, quality, environment, and information security are tailored to the organization, appropriate, and accessible to employees and relevant stakeholders.
– Encourages active employee participation in occupational health and safety processes by appointing employee representatives within the scope of the occupational health and safety management system.
– Commits to providing equal opportunities to all employees. Supports workforce diversity without discrimination based on gender, race, or ethnicity and fosters an inclusive and equitable working environment by promoting gender equality.
– Ensures full compliance with the Personal Data Protection Law within the scope of the Information Security Management System. Personal data is protected by adhering to the principles of confidentiality, integrity, and accessibility during processing.
– Integrates business continuity and emergency plans, data backup procedures, protection from viruses and cyberattacks, access control systems, and information security incident reporting as core elements of its operations.
In line with MRC Turkey’s sustainability approach, our goal is to create a modern and human rights-respecting work environment, to communicate our approach and principles in the field of human rights, and to ensure and encourage human rights-consciousness and compliance in our relationships with our employees, customers, suppliers, business partners, and all other stakeholders with whom we are affiliated.
All MRC Turkey employees are obligated to act in accordance with the principles and guidelines set forth in this policy. Furthermore, all our business partners and stakeholders are expected to comply with this procedure for applicable principles, and the necessary mechanisms are established to monitor this process.
1. Ethics Complaint Mechanism and Implementation
MRC Turkey employees and stakeholders can report ethical violations through the anonymous Ethics Complaint Form on the website.
The primary duty of the ethics committee is to ensure that employees feel safe reporting ethical violations and to ensure complete confidentiality and fairness throughout the process. The ethics committee conducts the process with particular emphasis on non-retaliation and confidentiality of information. Ethical violations reported anonymously by employees are monitored and evaluated through the “Ethics Hotline.”
– The individual committing an ethical violation or the relevant parties cannot access the identity of the person making the report. An ethics reporting hotline has been established on our company website for this purpose.
– Reports, investigation reports, and decisions made are stored in a secure system accessible only to authorized individuals.
– The ethics committee acts independently and is obligated to share the details and recommendations of relevant matters with the board of directors.
2. Our Ethical Principles
Privacy and Company Policies
Our employees are obligated to comply with the details outlined in the MRC Turkey Information Security Policy and all company policies regarding Information Security.
Customer, supplier, company, and company financial information must not be used or shared without authorization, permission, or for purposes other than business.
The company reserves the right to monitor employee user accounts and electronic communication channels assigned to them for business purposes, such as email, phone, computer systems, and other electronic records, in accordance with applicable laws.
Bribery
Bribery is an attempt to gain an employee’s benefit, either directly or indirectly, to unfairly influence decisions and practices. These attempts can take various forms, including cash payments, valuable gifts, and personal advantages, and are completely illegal.
Our employees must not borrow money from customers or third parties, provide any benefits, or enter into a surety relationship while performing their duties or in any other situation related to their duties.
If any person, company, or institution makes such an offer to an employee, or if an employee is found to have engaged in bribery and engages in a debt relationship, the situation must be reported immediately.
Avoiding Conflicts of Interest
The Company’s suppliers and business partners base their decisions solely on objective criteria and do not allow personal interests or relationships to influence these decisions.
Business partners or other individuals and organizations with whom they may have a business relationship must not enter into personal relationships that could create, or be perceived as creating, a conflict of interest between the Company (or their relatives) and them, and that could damage the Company’s reputation. The existence of a close relationship, such as family, friendship, or similar relationships, between Business Partners or other individuals and organizations with whom the Company has a business relationship, or who may have a business relationship, and Company employees who employ, approve, or make decisions regarding these individuals and organizations, creates a risk of conflict of interest. Individuals, organizations, and Company employees who are or may be in such a situation are obligated to immediately report the situation to their compliance officers.
Political Activities
Company employees are required not to use the company name to become members of any political organization while performing their duties. Furthermore, they are responsible for refraining from any personal affiliation with any activity that could harm the Company’s interests or reputation, or negatively impact their working hours.
Our employees must not engage in political campaigning, fundraising, or similar activities at work, and must not use company resources for such endeavors.
Media Use
Employees must protect the company’s reputation and refrain from sharing confidential information without permission. Professional language must be used, and discriminatory, offensive, or politically charged content must be avoided. Company names and logos must not be used in a misleading manner outside of official accounts. Colleagues must be treated with respect, and posts that could undermine corporate harmony must be avoided.
Company policies must be adhered to and negative comments about competitors must be avoided. Only accurate and verified information should be shared, and misleading content should be avoided. Legal regulations must be adhered to, and copyrighted materials must not be used without permission. Commenting on social media during times of crisis should be avoided, and only statements should be made by authorized personnel.
External Assignment
Employees may receive offers to participate in external events as paid or unpaid speakers or consultants, drawing on their experience gained throughout their careers. Such opportunities should be discussed with our company’s Deputy General Manager to determine any conflicts between personal and corporate interests.
Respect and Workplace Life
We aim to create a work environment that supports full communication with our employees through a respectful and thoughtful approach. Our employees are expected to foster an atmosphere aligned with the values outlined in this guide to enhance corporate identity and strengthen team spirit.
Our company values diversity and encourages our employees to maintain relationships based on the principles of respect, fairness, equality, and courtesy. Our employees must refrain from disruptive behavior in shared spaces. Behaviors such as harassment, derogatory remarks, negative categorizations, and unwanted sexual advances are completely unacceptable. Employees who experience harassment or inappropriate behavior can report the situation to the Ethics Committee, which is responsible for managing the situation confidentially. No discriminatory or punitive action will be taken against employees who report it.
Managers who coordinate specific tasks or departments must exercise the authority designed for their work with balance, impartiality, and consideration for the personal dignity of their employees. Relationships between different job levels and those created by the hierarchy must be governed by principles of mutual loyalty and respect—within the Company and in a manner that respects the Company’s values and goals. Systematic and planned behaviors that aim to alienate the targeted individual from their job, reduce their performance, or cause them to resign, which could be considered psychological harassment (mobbing), can be reported to the Ethics Reporting Line.
Equal Opportunity/Providing Equal Opportunities in Employment
MRC Turkey aims to create a work environment that values the talents and experience of each individual, respects diversity, and provides employees with the opportunity to freely express their opinions.
Our company does not tolerate any discrimination among employees and conducts all personnel practices based on individual competencies and merits. Discriminatory factors such as race, religion, gender, color, age, national origin, sexual orientation, physical disability, or seniority are not taken into consideration in these practices. All procedures, including recruitment, performance management, promotion, transfer, training, disciplinary processes, and termination of employment, are carried out in accordance with this principle.
Preventing Discrimination Against Women
At MRC, we embrace the prevention of all forms of discrimination against women as a fundamental human right and ethical responsibility, and we take decisive steps to eliminate gender-based discrimination in the workplace. We are committed to ensuring women’s access to equal recruitment, promotion, and training opportunities, increasing their representation in leadership positions, and creating a safe work environment.
Company Resources
All company-owned property, assets, equipment, vehicles, computers, computer programs, kitchen and stationery supplies, office panels, and meeting rooms provided to employees for daily business purposes are primarily for company use. Any use of the aforementioned resources or other company resources for personal purposes must be reported to the relevant manager and human resources department.
Company phone numbers and addresses, email addresses, internal communication, and messaging systems should not be used for personal correspondence and meetings, and should be written in professional language.
Duties and Responsibilities of Managers
Creating and maintaining a company culture and work environment that supports ethical principles is a fundamental responsibility of managers. In this context, managers should set an example in implementing ethical rules and educate their employees on this matter. They should also encourage employees to submit questions, complaints, and reports regarding ethical rules. When consulted, they should provide guidance on appropriate action and acknowledge all submitted information.
MRC Turkey (the “Company”) attaches great importance to the health and safety of its employees. The purpose of the Zero Tolerance Policy against Violence (“Policy”) is to establish the necessary principles and sanctions to create an equitable, safe, and intolerant working environment within the Company. To this end, the Company is committed to working to raise employee awareness of violence, establishing support mechanisms where employees subjected to violence can share their experiences in a safe and confidential manner, and implementing an effective investigation, audit, and sanction system.
2. Scope
This policy covers all of MRC Turkey’s subsidiaries, employees, and senior management. MRC Turkey also expects all suppliers and business partners with whom it collaborates to act in accordance with the principles set forth in this policy.
This Policy is an integral part of:
• the Company’s Code of Business Ethics,
• our commitment to participate in the United Nations Global Compact,
• our Human Rights Policy,
• our Non-Retaliation Policy,
• our Human Resources processes.
3. Definitions
• Physical Violence: Behaviors intended to control the victim through physical aggression. For example, pushing, hitting, raising one’s hand with the intention of hitting, wounding with or without a weapon, throwing objects.
• Psychological Violence: Continuous and systematic application of emotional or psychological pressure. For example, humiliating or threatening behavior, making the person feel inadequate, mocking, swearing, or insulting.
• Sexual Violence: Forcing someone to have sexual intercourse at a time, place, or in a manner they do not want, making sexually explicit remarks, making insinuations, making sexual jokes, or harassing them.
• Economic Violence: Systematic pressure on a person’s economic decisions or actions that restrict their economic freedom. For example, preventing them from working, confiscating income or savings.
• Digital Violence: The use of technological tools to control, humiliate, harass, or punish someone. For example, constant texting or calling, social media monitoring, insulting or hateful posts.
• Stalking: Intentional and repeated behaviors that threaten a person’s safety and cause fear and anxiety. For example, monitoring employees after work and monitoring their destinations.
4. MRC Turkey’s Attitude Against Violence
MRC Turkey recognizes that violence and harassment encountered in the workplace or in private life constitute a human rights violation and a threat to equal opportunity, and that gender-based violence and harassment, in particular, disproportionately affects women. Therefore, to ensure a healthy and safe working environment free from all forms of violence and threats, the Company opposes all forms of violence, abuse, and behavior that undermine trust.
With a fair, human rights-respecting, and sustainable work environment approach, MRC Turkey is committed to:
• Promoting a work culture based on mutual respect and human dignity,
• Raising awareness by providing training to employees to combat violence and harassment,
• Protecting confidentiality by providing information, guidance, and support in reporting violence and harassment,
• Effectively operating complaint, investigation, and disciplinary processes in cases of violence and harassment, guided by the principles of confidentiality and impartiality,
• Collaborating with public institutions, non-governmental organizations, and relevant organizations with a gender-sensitive approach to ending all forms of violence. 5. Workplace Violence
If employees are subjected to violent or harassing behavior that threatens their physical or psychological safety in the workplace, they have the right to seek support through a confidential and impartial support channel. Contact channels include:
• The employee’s manager and/or Human Resources Department
• MRC Turkey Ethics Line
Our company provides services in the fields of “TECHNICAL CONSULTANCY, ENGINEERING, PROJECT MANAGEMENT, PRODUCT AND SYSTEM DEVELOPMENT ACTIVITIES IN THE ENERGY, INFRASTRUCTURE, INDUSTRY, ENVIRONMENT, AND IT SECTORS.” Our company is committed to protecting the confidentiality, integrity, and protection of all physical and electronic information assets. Information and information security requirements will be aligned with our corporate objectives. Our company management will employ a highly trained and competent staff who are open to change, and we will maintain adequate hardware and infrastructure by providing financing to compete with our competitors within the sector. This infrastructure and personnel will also provide the necessary financing.
Business continuity and emergency plans, data backup procedures, protection against viruses and hackers, access control systems, and information security breach notification will form the cornerstones of our core activities. Vulnerabilities and threats identified through risk assessments will be eliminated, ensuring secure access to customer and staff information.
In addition, risk assessments will be conducted. As a result, we will define our objectives and provide the resources and conditions necessary to achieve them.
To implement this policy, we expect our employees to adopt the Information Security Management System requirements as a way of working. All personnel will receive appropriate training on the Information Security Management System.
Our company personnel and all relevant parties will be adapted to the system to meet applicable requirements regarding information security and to continuously improve the Information Security Management System.
The Information Security Management System will be implemented and implemented in accordance with the laws and regulations of the Republic of Turkey, the ISO 27001:2022 ISMS standard, and our policies and procedures. In this context, we are committed to full compliance with the Personal Data Protection Law (KVKK). All data is secured by adhering to the principles of confidentiality, integrity, and accessibility during the processing of personal data. In this context, the necessary technical and administrative measures are taken in accordance with the provisions of the KVKK during personal data processing processes. Company employees receive regular training to increase their awareness of the protection of personal data and are continuously monitored to minimize the risk of data breaches. Improvement efforts are underway.
The Information Security Management System will be managed by considering our relationships with suppliers and subcontractors, their impact on our Information Security, and the risks they pose.
Our Information Security Policy is reviewed annually, or at shorter notice, with the participation of management and department heads to ensure its suitability, accuracy, and effectiveness, and is kept up-to-date.
We are committed to working diligently to be a leading organization in the sector in terms of information security.
This policy applies to all vehicles owned or leased by MRC Türkiye, as well as to all employees, contractors, and third-party drivers operating vehicles on behalf of the company.
- We ensure full compliance with national and international road traffic safety legislation, regulations, and the requirements of the ISO 39001 standard.
- We adopt a risk-based approach with the aim of reducing traffic accidents, injuries, and fatalities to zero.
- We provide regular training to all drivers and personnel operating vehicles on safe driving, traffic rules, and the prevention of risky behaviors.
- We monitor and evaluate data such as vehicle usage, speed, fuel consumption, and driver behavior to measure performance and implement continuous improvement activities.
- We strictly prohibit the use of alcohol and drugs during duty and apply a zero-tolerance policy in this regard.
- We implement plans to reduce the environmental impact of our vehicles and promote environmentally friendly and safe transportation.
- We develop preventive measures to ensure that traffic-related disruptions do not affect business continuity.
- We carry out all our activities in full compliance with applicable legal regulations, sectoral requirements, and other obligations.
- We regularly monitor the performance of our management system, review it against objectives, and ensure continuous improvement.
- We expect all our employees, contractors, and visitors to act in accordance with this policy.
- We ensure full compliance with environmental legislation and support technologies aimed at protecting the environment.