2022 Communication on Progress

Akkok Holding A.S.

Published date

June 30, 2022

No. of questions

59

Supplemental files

CEO Statement

Signed

  • Governance

    Policies and Responsibilities

    1. Does the Board / highest governance body or most senior executive of the company:

    Optional comment
    Akkök Report 2021 (https://www.akkok.com.tr/Sustainability/Reports)

    2. Does the company have a publicly stated commitment regarding the following sustainability topics?

    No, this is not a current priority

    No, but we plan to have a commitment within 2 years

    Yes, and the commitment is focused on our own operations

    Yes, and the commitment includes our own operations and the value chain

    Yes, and the commitment includes our own operations and the value chain along with communities and society

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    Sustainability Policy (https://www.akkok.com.tr/Sustainability/AkkokHoldingSustainabilityPolicy) Ethical Principles (https://www.akkok.com.tr/Kurumsal/AkkokIsEtigi)

    3. Does the company have in place a code of conduct regarding each of the following sustainability topics?

    No, this is not a current priority

    No, but we plan to have a code of conduct within two years

    Yes, focused on employee conduct

    Yes, focused on employees and suppliers

    Yes, focused on employees, suppliers, and other business relationships

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    Sustainability Policy (https://www.akkok.com.tr/Sustainability/AkkokHoldingSustainabilityPolicy)

    4. Has the company appointed an individual or group responsible for each of the following sustainability topics?

    No one is specifically responsible for this topic

    Yes, with limited influence on outcomes (e.g., limited access to internal information, limited decision-making authority)

    Yes, with moderate influence on outcomes (e.g., has access to relevant information, reports to senior manager)

    Yes, with direct influence of some outcomes (e.g., has access to relevant information, includes one or more senior manager with decision making rights

    Yes, with direct influence at the highest levels of the organization (e.g., has access to relevant information, includes most senior members of organization)

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    Group companies also monitor environmental performance via their own environmental management structure.

    5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?

    No formal structure

    Yes, and with limited influence on outcomes (e.g., limited access to internal information necessary to understand risks, poor representation from relevant departments or functions)

    Yes, with moderate influence on outcomes (e.g., it includes representatives of some functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, reports to senior manager)

    Yes, with direct influence on some outcomes (e.g., it includes representatives of functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, it involves one or more members of senior management)

    Yes, and with direct influence at the highest level of the organization (e.g., full access to relevant information, it involves members at highest level of organization)

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    There is an early detection of risk committee reporting to executive committee. Akkök Report 2021 (https://www.akkok.com.tr/Sustainability/Reports) p.8

    Prevention

    6. Does the company have a process or processes to assess risk?

    No, this is not a current priority

    No, but we are planning to develop one in the next two years

    Yes, related to our own operations

    Yes, related to our own operations and entire value chain and other business relationships

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    Optional comment
    Akkök Report 2021 (https://www.akkok.com.tr/Sustainability/Reports) p.8

    6.1. During the assessment of risk, which business relationships are reviewed?

    A few suppliers or business relationships [approximately less than 25 %]

    Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]

    Most suppliers / relevant business relationships [approx. 51 - 99 %]

    All suppliers / relevant business relationships outside the supply chain

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    7. Does the company have a due diligence process through which it identifies, prevents, mitigates, and accounts for actual and potential negative impacts on sustainability topics?

    No, this is not a current priority

    No, but we are planning to develop one in the next two years

    Yes, related to our own operations

    Yes, related to our own operations and entire value chain and other business relationships

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    Concerns and grievance mechanisms

    8. Are there any processes through which members of the company’s workforce can raise concerns about the company’s conduct related to human rights, labour rights, environment, or anti-corruption?

    Optional comment
    Akkök Report 2021 p.10 (https://www.akkok.com.tr/Sustainability/Reports)

    8.1. Please provide additional detail regarding the process(es) the company has through which members of the company’s workforce can raise concerns about the company’s conduct.

    No

    Yes

    Is the process communicated to all employees/workers in local languages?

    Is the process available to non-employees (e.g., contractors, vendors, suppliers)?

    Is the process confidential (e.g., whistleblowing process)?

    Are there processes in place to avoid retaliation?

    Can concerns be raised about suppliers or other business relationships (e.g., clients, partners, etc.)

    Other (Please provide additional information)

    Akkök Report 2021 p.10 (https://www.akkok.com.tr/Sustainability/Reports)
    Optional comment
    Akkök Report 2021 p.10 (https://www.akkok.com.tr/Sustainability/Reports)

    9. Does the company provide or enable access to effective remedy to right holders / stakeholders where it has caused or contributed to the adverse impact?

    No process to enable remedy to stakeholders

    Remedy available to some stakeholders (i.e., some geographies, employees only)

    Remedy is available to all affected stakeholders

    Remedy is available to all stakeholders, and suppliers are expected to have similar policies

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    No complaints received during the reporting process. In order to combat violations, an Ethics Hotline has been established for all stakeholders, especially employees, where they can report violations of principles.

    Lessons

    10. How does the company capture lessons regarding each of the following sustainability topics?

    No lessons are regularly captured

    Conducts root cause analyses/investigation of major incidents

    Conducts root cause analyses/investigation and changes organizational policies, processes, and practices accordingly

    Systematically conducts root cause analyses/investigation and leverages learnings to influence both internal and external affairs

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Executive Pay

    11. Is executive pay linked to performance on one or more of the following sustainability topics?

    No, and we have no intention to change

    No, but we plan to within two years

    Yes

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Board Composition

    12. Percentage of individuals within the company’s Board / highest governance body by:

    Number/Percentage

    Not applicable (Please provide additional information)

    Total number of board members (#)

    8

    Male (%)

    50

    Female (%)

    50

    Non-binary (%)

    0

    Under 30 years old (%)

    0

    30-50 years old (%)

    38

    Above 50 years old (%)

    62

    From minority or vulnerable groups (%)

    0

    Executive (%)

    100

    Independent (%)

    0
    Optional comment
    More information about Board of Directors and Executive Board: https://www.akkok.com.tr/Corporate/BoardofDirectors https://www.akkok.com.tr/Corporate/ExecutiveBoard

    13. Do you produce sustainability reporting according to:

    Optional comment
    https://www.akkok.com.tr/Sustainability/Reports

    Data Assurance

    14. Is the information disclosed in this questionnaire assured by a third-party?

    Data for Aksa: ISO14064 & ISO 14064 Verifications Data for Akkim: Scope 1 and 2 Emissions Verification
    Optional comment
    While the consolidated data of Akkök Holding and all its subsidiaries were included for social and financial performance indicators, environmental indicators in COP report include data only for subsidiaries carrying out sustainability reporting practices, namely Aksa Akrilik, Ak-Kim and Akenerji.

  • Human Rights

    Materiality / Saliency

    1. Which of the following has the company identified as material human rights issues connected with its operations and/or value chain, whether based on their salience (i.e., the most severe potential negative impacts on people) or another basis?

    Response

    8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the human rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

    Akkök Report 2021 p.20 (https://www.akkok.com.tr/Sustainability/Reports) No complaints received during the reporting period. In order to combat ethical violations, an Ethics Hotline has been established for all stakeholders, especially employees, where they can report violations of principles.

  • Labour

    Commitment

    1. Does the company have a policy commitment in relation to the following labour rights principles?

    No, and we have no plans to develop a policy

    No, but we plan to in the next two years

    Yes, included within a broader policy

    Yes, articulated as a stand-alone policy

    Not applicable (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    2021

    Forced labour

    2021

    Child labour

    2021

    Non-discrimination in respect of employment and occupation

    2021

    Occupational safety and health

    2021

    Working conditions (wages, working hours)

    2021
    Optional comment
    Akkök Sustainability Policy (https://www.akkok.com.tr/Sustainability/AkkokHoldingSustainabilityPolicy)

    1.1. For each labour rights policy, is it:

    Aligned with international labour standards?

    Publicly available?

    Approved at most senior level of the company?

    Applied to the company’s own operations?

    Applied to the company’s supply chain and/or other business relationships?

    Developed involving labour rights expertise from inside and outside the company?

    Other (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Optional comment
    Akkök Sustainability Policy (https://www.akkok.com.tr/Sustainability/AkkokHoldingSustainabilityPolicy)

    Prevention

    2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following labour rights issues?

    No engagement on this topic

    To better understand the risks/ impacts in question

    To discuss potential ways to prevent or mitigate the risks/ impacts in question

    To agree on a way to prevent/ mitigate the risks/ impacts in question

    To assess progress in preventing/ mitigating the risks /impacts in question

    To collaborate in the prevention/ mitigation of the risks/ impacts in question

    Other (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Optional comment
    On the reporting period we did not receive any negative feedback from related stakeholders. Akkök Group and Group Companies have several channels effectively used to receive stakeholder feedbacks.

    3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this labour rights issue?

    Provided internal training/ capacity building for the direct workforce

    Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)

    Conducting an audit process and/or corrective action plan

    Collective Action with peers or other stakeholders, in particular workers' organizations, to address the issue

    Collaboration with governmental or regulatory bodies

    Other (Please provide additional information)

    No action within reporting period

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    https://www.akkok.com.tr/Sustainability/AkkokHoldingSustainabilityPolicy

    Child labour

    https://www.akkok.com.tr/Sustainability/AkkokHoldingSustainabilityPolicy

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    https://www.akkok.com.tr/Sustainability/AkkokHoldingSustainabilityPolicy

    Working conditions (wages, working hours)

    Optional comment
    Freedom of association and collective bargaining rights of employees are respected to maintain work welfare. Akkök Holding and the Group companies also follow a similar approach with respect to its value chain. While we take the necessary measures to avoid child labor or forced/compulsory labor in any part of our operations, we also perform regular controls on the supply chain to eliminate any such risky activities.

    4. Who receives training for the following labour rights issues?

    No training provided

    Select employees

    All employees

    Contractors

    Direct suppliers of the organization

    Indirect suppliers of the organization

    Other – such as partners, clients, etc.

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    5. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights issues?

    No monitoring of progress

    Review issues on ad-hoc basis

    Set annual targets/ goals, track progress over time (internal programs only)

    Set annual targets/ goals, track progress over time (internal and external programs)

    Other (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Performance

    6. What is the percentage of employees covered under collective bargaining agreements?

    Percent of employees (%)

    Unknown

    Employees covered under collective bargaining (%)

    0
    Optional comment
    There are collective bargaining agreements on a sectoral basis. Related processes are managed by group companies.

    7. What is the percentage of employees in a trade union or other workers' organization?

    Percent of employees (%)

    Unknown

    Not applicable (Please provide additional information)

    Employees in a trade union or on a worker committee (%)

    0
    Optional comment
    There are collective bargaining agreements on a sectoral basis. Related processes are managed by group companies.

    8. In the course of the reporting period, what was the percentage of women in:

    Percent of women (%)

    Unknown

    Senior leadership level position

    50

    Non-executive board

    0
    Optional comment
    %50 represents executive board+directors+coordinators

    9. What was the average ratio of the basic salary and remuneration of women to men (comparing jobs of equal value) during the reporting period?

    Salary ratio (%)

    Unknown

    Choose to not disclose

    Women / Men (%)

    100
    Optional comment
    Equal pay for equal work

    10. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?

    Frequency of injury

    Unknown

    Choose to not disclose

    Frequency of injury

    Optional comment
    Accident frequency rates for Group companies in reporting scope are as below: Aksa: 2,0 Akkim: 4,03 Akenerji: 8,2

    11. In the course of the reporting period, what was the company’s incident rate?

    Incident rate

    Unknown

    Choose to not disclose

    Incident rate

    Optional comment
    Accident severity rates for Group companies in reporting scope are as below: Aksa: 0,22 Akkim: 159,76 (based on 1000000 working hours) Akenerji: 247,7

    Response and Reporting

    12. In the course of the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to the adverse impact associated with the following labour rights issues?

    Yes

    No

    Choose to not disclose

    Not applicable (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Optional comment
    No negative impact during the reporting period.

    13. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the labour rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

    The Holding utilizes communication and audit mechanisms to ensure widespread adoption of respect for human rights in the value chain. For this purpose, Akkök Holding and the Group companies also evaluate the human rights performance of their suppliers, contractors, and subcontractors when auditing them. When negotiating and executing procurement contracts, Akkök Group Companies include an article in such contracts that specifically prohibits child labor and illicit employment. When any non-compliance is detected, the respective supplier is notified and all purchases from that supplier are suspended until such non-compliance is corrected. The Holding continuously strives to build a work environment that respects human rights and is democratic, fair, and protects the dignity of its employees. It puts forth great effort to offer equal opportunities for everyone and takes a proactive attitude to prevent discrimination in terms of religion, language, race and gender. For this purpose, Akkök Holding and the Group companies also evaluate the human rights performance of their suppliers and subcontractors during audits.Any disrespectful behavior and other forms of behavior, such as psychological abuse, harassment, intimidation, threats, bullying, humiliation, and exclusion that could harm the reputation of employees in the society are not tolerated at work. Managers and employees are not engaged in any behavior that could cause a person to feel under threat or insecure as a result of intimidation or humiliation. This includes verbal abuse and threats as well as any form of hostility, intimidation, and aggression.

  • Environment

    Commitment

    1. Does the company have a formal policy on the following environmental topics?

    No, and we have no plans to develop a policy

    No, but we plan to in the next two years

    Yes, included within a broader policy

    Yes, articulated as a stand-alone policy

    Not applicable (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    Prevention

    2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following environmental issues?

    No engagement on this topic

    To better understand the risks/ impacts in question

    To discuss potential ways to prevent or mitigate the risks/ impacts in question

    To agree on a way to prevent/ mitigate the risks/ impacts in question

    To assess progress in preventing/ mitigating the risks/ impacts in question

    To collaborate in the prevention/ mitigation of the risks/ impacts in question

    Other (Please provide additional information)

    Climate Action

    We did not receive any negative feedback from related stakeholders in the reporting period.

    Water

    We did not receive any negative feedback from related stakeholders in the reporting period.

    Oceans

    We did not receive any negative feedback from related stakeholders in the reporting period.

    Forests / Biodiversity / Land Use

    We did not receive any negative feedback from related stakeholders in the reporting period.

    Air Pollution

    We did not receive any negative feedback from related stakeholders in the reporting period.

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    We did not receive any negative feedback from related stakeholders in the reporting period.

    Energy & Resource Use

    We did not receive any negative feedback from related stakeholders in the reporting period.

    3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with these environmental topics?

    Provided internal training/ capacity building for the direct workforce

    Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)

    Conducting an audit process and/or corrective action plan

    Collective Action with peers or other stakeholders to address the issue

    Collaboration with governmental or regulatory bodies

    Other (Please provide additional information)

    No action within reporting period

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?

    No monitoring of progress

    Review issues on ad-hoc basis

    Set annual targets/ goals, track progress over time (internal programs only)

    Set annual targets/ goals, track progress over time (internal and external programs)

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    5. In the course of the reporting period, has the company been involved in providing or enabling remedy for any actual impacts associated with the following environmental issue(s)?

    Yes

    No

    Choose to not disclose

    Not applicable (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    Climate Action

    6. What were the company’s gross global greenhouse gas emissions for the reporting period?

    Scope 1 Emissions

    Emissions (tCO2e)

    2811105

    Scope 2 Emissions

    Emissions (tCO2e)

    155145

    Scope 3 Emissions

    Emissions (tCO2e)

    1121985
    Optional comment
    Scope 1 and Scope 2 Emissions includes Aksa Akrilik, Akkim and Akenerji which comprises the scope of Akkök COP Report. For Scope 3 Emissions Ak-kim data excluded since the verification process is still on progress.

    7. What percentage of the company's revenue was invested in R&D of low-carbon products/services during this reporting period?

    Percent of revenue (%)

    8. Has the organization acted to support climate change adaptation and resilience?

    Energy / Resource Use

    9. Please report the company's renewable energy consumption as a percentage of total energy consumption in the reporting period.

    % of total energy consumption

    0
    Optional comment
    The amount equals to the renewable energy consumption of Akenerji (%0,00025295)

    Technology

    10. What percent of the company's revenue came from environmentally friendly products / services during this reporting period?

    Percent of total revenue (%)

    Sector-specific Questions

    11. Which sector(s) does the company operate in? If diversified, choose top 3 by revenue.

    Optional comment
    Since there is no option for energy sector we choose industrial goods and services.

    Sector-specific: Water

    12. Please provide details regarding the company's water withdrawal and consumption (own operations) during the reporting period.

    Water withdrawal (volume of water in megaliters):

    Mega-liters

    Unknown

    Not applicable (Please provide additional information)

    Total

    8893

    Groundwater:

    Surface water:

    Rainwater:

    Wastewater:

    Percentage of water withdrawn in regions with high or extremely high water stress (%)

    Water consumption (volume of water in megaliters):

    Mega-liters

    Unknown

    Not applicable (Please provide additional information)

    Total

    8893

    Groundwater:

    Surface water:

    Rainwater:

    Wastewater:

    Percentage of water consumed in regions with high or extremely high water stress (%)

    Optional comment
    Since water resources changes for companies in reporting scope total number is disclosed.

    13. Please provide details about the company’s water intensity of products in regions with high or extremely high water stress.

    Water intensity of products (cubic meter/$):

    This information is applicable to each Group company and depends on type and amount of production.

    Sector-specific: Air pollution

    17. Where applicable, please report the company's emissions of the following pollutants during the reporting period.

    Emissions (tCO2e)

    Unknown

    Not applicable (Please provide additional information)

    NOx

    SOx

    Volatile Organic Compounds (VOC)

    Hazardous air pollutants (HAP)

    Particulate matter (PM10)

    Persistent organic pollutants (POP)

    Other (please specify in text box)

    Optional comment
    NOx and SOx emissions are sum of Aksa Akrilik and Ak-Kim.

    Sector-specific: Waste

    18. Please report the company's total weight of waste generated in metric tonnes during the reporting period.

    Waste Generated (t)

    203696

    19. Please report the percentage of the company's waste that was hazardous waste (i.e., hazardous waste ratio) during the reporting period.

    Hazardous Waste Ratio (%)

    17

    20. Please report the company's estimated metric tonnes of single-use plastic consumed wherever material along the value chain during the reporting period.

    Single-use plastics (tonnes)

    14

    Overall Environment

    21. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the environment principles, including any challenges faced and actions taken towards prevention and/or remediation.

    Climate change and the rapid depletion of natural resources pose serious threats worldwide. The support of the business world in the fight against these environmental risks is of great importance in terms of sustainability. In this context, minimizing environmental impacts, effective use of natural resources, efficient waste, energy and emission management are aimed in all activities of Akkök Holding and Group companies. All operations in Akkök Holding and Group companies are carried out within the framework of national and international quality systems; environmentally friendly materials and technology are used, and it is aimed to continuously improve environmental performance by monitoring. In the reporting period Group companies carry out projects to reduce energy consumption and increase efficiency in line with Akkök Holding’s sustainability approach.

  • Anti-corruption

    Commitment

    1. Does the company have an anti-corruption compliance programme?

    2021

    2. Does your company have policies and recommendations for employees on how to act in case of doubt and/or in situations that may represent a conflict of interest, e.g. with regard to gifts and hospitality, donations, sponsorship, or interactions with public officials?

    Optional comment
    Akkök 2021 Report p.20 https://www.akkok.com.tr/Sustainability/Reports Akkök Holding Anti-Bribery and Anti-Corruption Policy (https://www.akkok.com.tr/Sustainability/AkkokHoldingSustainabilityPolicy)

    Prevention

    3. Who receives training on anti-corruption and integrity?

    3.1. How often is such training provided?

    One time only

    Every year

    Every two or more years

    We do not collect this data

    All employees

    Select employees

    Contractors

    Direct suppliers of the organization

    Other – such as partners, clients, etc.

    Indirect suppliers of the organization

    4. Does the company monitor its anti-corruption compliance programme?

    Response and Reporting

    5. Please report the company's total number and nature of incidents of corruption during the reporting year.

    Number of incident(s)

    Unknown

    Choose to not disclose

    Confirmed during the current year, but related to previous years

    Confidential company information

    Confirmed during the current year, and related to this year

    Confidential company information

    6. Within the reporting period, what measures has the company taken to address suspected incidents of corruption independently or in response to a dispute or investigation by a government regulator?

    7. Does your company engage in Collective Action against corruption?

    8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the anti-corruption principle, including any challenges faced and actions taken towards prevention and/or remediation.

    The "Akkök Group of Companies Anti-Bribery and Anti-Corruption Policy" sets out the rules that the Group companies must follow in their relations with stakeholders. The Holding has designed the necessary organizational structure to effectively implement the Code of Conduct and the Anti-Bribery and Anti-Corruption Policy. Akkök Holding understands that it must fight against bribery and corruption as a basic responsibility towards the society. Therefore, effective communication, training and audit practices are carried out at both the Holding level and the Group companies level.Akkök Holding pays special attention to communication and training activities in order to ensure that all Group companies act with the same approach and diligence. The Holding aims to ensure that the principles are adopted across all of the Group companies and viewed as a core cultural value. Through internal audit teams and independent auditors, the Akkök Holding Internal Audit Group performs various controls in order to improve the efficiency of operations and ensure financial reliability and compliance with the laws and regulations.