The Koç Group is committed to being transparent, fair and accountable in its dealings with its stakeholders. In performing its activities, the Group complies with the applicable legislation and its contractual obligations, and acts within the frame of its Code of Ethics. In this context, a comprehensive “Compliance Project” has been carried out with the purpose of responding to the fast-evolving needs of the different sectors and geographies that the Group pursues operations in, as well as to domestic and international stakeholders’ expectations.
Within the scope of the “Compliance Project” carried out under Koç Holding’s leadership between 2018 and 2020, one-on-one interviews were held with the Group employees and senior executives, existing compliance activities were evaluated through questionnaires and workshops, and a risk assessment in relation to the Koç Group was conducted. In the light of these outputs, global good practices were studied upon which related policies were finalized, and a “Compliance Program” was put in place with the approval of the Board of Directors of Koç Holding.
The Koç Group Code of Ethics, which was updated as part of the Compliance Program, is intended to provide guidance and direction to all Koç Group companies, their employees, those who act on behalf of and business partners. While compliance with the Koç Group Code of Ethics is the duty of all Koç Group employees, senior executives of the Koç Group companies are expected to lead the way in this respect.
The Koç Group Code of Ethics, which was updated as part of the Compliance Program, is intended to provide guidance and direction to all Koç Group companies, their employees, those who act on behalf of and business partners. While compliance with the Koç Group Code of Ethics is the duty of all Koç Group employees, senior executives of the Koç Group companies are expected to lead the way in this respect.
The Compliance Program is the set of rules, policies and procedures intended to determine and manage compliance matters of the Koç Group with a riskbased approach. The Compliance Program brings together the corporate compliance culture supported by the senior management and monitored by the Legal and Compliance Department with the standards documented across the Koç Group with the involvement of all employees.
The main components of the Koç Group Compliance Program are as follows: prevention, detection and response.
The image below shows the components of the Compliance Program and the composition of these components.
The main components of the Koç Group Compliance Program are as follows: prevention, detection and response.
The image below shows the components of the Compliance Program and the composition of these components.
The Koç Group Code of Ethics provides a comprehensive framework for the Koç Group employees and stakeholders on various matters, mainly human rights, anti-bribery and anti-corruption, prevention of conflicts of interest, economic sanctions, protection of privacy and inside information, and occupational health and safety.
Under the Compliance Program, numerous policies related to compliance have been developed, and approved by the Koç Holding Board of Directors. These policies include, among others, Sanctions and Export Controls, AntiBribery and Corruption, Supply Chain, Human Rights, Personal Data Protection, Donations and Sponsorships. The Koç Group Code of Ethics, Compliance Policy covering the details of the compliance structure, and the supporting policies can be found below.
Under the Compliance Program, numerous policies related to compliance have been developed, and approved by the Koç Holding Board of Directors. These policies include, among others, Sanctions and Export Controls, AntiBribery and Corruption, Supply Chain, Human Rights, Personal Data Protection, Donations and Sponsorships. The Koç Group Code of Ethics, Compliance Policy covering the details of the compliance structure, and the supporting policies can be found below.
| Code of Ethics | DOWNLOAD |
| Compliance Policy | DOWNLOAD |
| Donations and Sponsorship Policy | DOWNLOAD |
| Gifts and Entertainment Policy | DOWNLOAD |
| Whistleblowing Policy | DOWNLOAD |
| Human Rights Policy | DOWNLOAD |
| Competition Law Compliance Policy | DOWNLOAD |
| Anti-Bribery and Anti-Corruption Policy | DOWNLOAD |
| AML-CFT Policy | DOWNLOAD |
| Supply Chain Compliance Policy | DOWNLOAD |
| Community Investment Policy | DOWNLOAD |
| Sanctions and Export Controls Policy | DOWNLOAD |
Koç Group Ethics Hotline
KoçMedikal attaches great importance to being in full compliance with the applicable laws, international conventions of the countries in which it is located, and the UN Global Compact, performs its activities with integrity and according to the highest ethical standards, and supports the culture of “open communication” and “accountability” to prevent unethical or illegal actions.For this reason, KoçMedikal encourages its employees who directly or indirectly witness an illegal or unethical activity performed by a Koç Group company, another employee, or a Business Partner or who obtain information about such a situation through legal channels, or who suspect such a situation, to express their concerns, and encourages its stakeholders to do so.
The Koç Group Ethics Hotline, which is operated by independent service providers 7 days a week and 24 hours a day, is the main reporting method for reporting a disclosable matter.
Koç Group Ethics Hotline can be reached by the following link.
*The Ethics Hotline is not a tool to report service/product concerns.