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Anti-Bribery and Anti-Corruption Policy

MOGUL ANTI-BRIBERY AND ANTI-CORRUPTION POLICY

Our Commitment

We safeguard today's success, tomorrow's trust and the sustainability of the future through our responsible

management approach based on continuous improvement.


MOGUL Tekstil is a privately owned, Turkiye-based company with a strong workforce, founded in 1997 by Ekrem Kayalı to manufacture nonwoven products. As the first Turkish company to produce spunbond and meltblown fabric in Turkiye, MOGUL today offers a wide range of nonwoven products for various application areas in the European Union, the United States and other global markets. Thanks to its innovative and entrepreneurial approach, it has been awarded the INDA IDEA Achievement Award twice.

The foundation of our success at MOGUL Tekstil consists of:

  • Building trust-based Long-Term Partnerships with our customers, suppliers and employees, aiming to exceed the expectations of our customers and other interested parties,
  • Sustaining an approach of Innovation and Diversity based on developing and bringing to market existing and new nonwoven concepts, processes and products within a work culture that supports individual development, team spirit and creativity,
  • Developing our Sustainability program, which contributes to the Global Goals, in cooperation with our employees and suppliers,
  • Adopting Ethical Conduct and Trust as a fundamental element of all business relationships we conduct with our customers, employees, suppliers and other stakeholders.
  • Zero tolerance: Bribery, corruption, money laundering, fraud, facilitation payments, improper or secret commissions, off-the-books payments and any form of unfair benefit are prohibited.
  • Prohibition of direct and indirect benefits: Money, gifts, hospitality, commissions, employment opportunities or any other benefit of value may not be offered, promised, given, solicited or accepted with the aim of improperly influencing the decision of a public official, customer, supplier or any other person, or of obtaining an unfair advantage. The use of an intermediary or third party does not remove this prohibition.
  • Facilitation payments: Informal payments made to expedite or secure a routine transaction are not permitted. Mandatory payments made under a genuine and imminent threat to life or serious health and safety are reported to management immediately and recorded.
  • Gifts and hospitality: Only gifts and hospitality that are legal, symbolic, reasonable, transparent and serve a legitimate business purpose may be considered. Cash or cash-equivalent gifts, and benefits that could influence decisions relating to tenders, bids, audits, payments, permits or contracts, may never be accepted or given.
  • Relations with public officials: No improper payment, gift, hospitality, travel, employment or other benefit may be provided to public officials or their relatives. Legal official fees and charges are paid only through authorized channels and against documentation.
  • Conflict of interest: Employees disclose actual, potential or perceived conflicts of interest without delay and do not take part in the related decision, offer, selection or approval process. Relationships involving kinship, partnership, side business, investment or personal benefit may not be concealed.
  • Business partners: Suppliers and other business partners are selected on objective criteria and are subject to ethics and compliance evaluation appropriate to their risk level. No transaction carried out on behalf of the company may be conducted through third parties for the purpose of circumventing the provisions of this policy.
  • Accurate records and transparency: All transactions are recorded accurately, completely, in a timely manner and in an auditable form. False documents, misleading statements, fraudulent invoices, secret funds, improper payments to personal accounts or off-the-books transactions may not be created.
  • Donations and sponsorships: Donations and sponsorships are made only for legitimate, transparent, documented purposes subject to authorized approval; they may not be used to influence a business decision or to provide an indirect benefit. Company resources may not be used for political contributions.
  • Integrity of audits: The outcome of social compliance, quality, environmental, occupational health and safety or other audits may not be improperly influenced; employees' free and confidential communication with auditors may not be obstructed, and records may not be falsified.

REPORTING, CONFIDENTIALITY AND PROHIBITION OF RETALIATION

Employees and relevant parties may report a request for bribery, an improper benefit, a conflict of interest or suspicion of any other ethical violation to their managers, the Human Resources department, or the QMS department. Reports are evaluated in accordance with the principles of confidentiality, impartiality and the protection of personal data.

No retaliation — including dismissal, threats, pressure, exclusion, reassignment, or loss of wages or bonuses — may be applied against a person who reports in good faith, participates in an investigation, or refuses an improper request. Reported allegations are investigated without delay, impartially and fairly.

 

RESPONSIBILITY AND SANCTIONS

Senior Management supports the implementation of this policy, provides the necessary resources and oversees the continuity of the ethical culture. All managers and employees are obliged to comply with the policy, participate in training, keep accurate records, disclose conflicts of interest and report suspicious situations. Business partners are also expected to comply with the same principles.

Violation of the policy may result, depending on the nature of the incident, in disciplinary sanctions, termination of the employment contract or business relationship, compensation for damages and, where necessary, notification to the competent authorities. No duty, title or commercial importance provides an exception for any person or organization.

 

EFFECTIVE DATE, COMMUNICATION AND REVIEW

This policy is communicated to all employees and relevant business partners; the necessary training and awareness activities are carried out. The detailed implementation of the policy is supported by the MOGUL Code of Business Ethics, related procedures, instructions and forms. The policy is reviewed at least once a year and whenever there is a significant change in legislation, standards, the organization, risk, or audit findings.

This policy enters into force upon approval by Senior Management and is binding in all operations.