Zero Tolerance for Violance Policy

PURPOSE

Within the scope of its sustainability vision and strategies, Aklease is committed to ensure equal opportunities for our employees and stakeholders, raising awareness for an inclusive corporate culture and implementing policies that support its sustenance.

In accordance with these commitments and our approach to diversity and inclusion; we know that it is important for a person to feel safe and secure at home and at work, and in line with this we stand against all kinds of violence and abuse, which are the most critical factors that damage safety.

In this policy, in order to create a safe and supportive work environment for all our employees, the principles, approaches and processes to be implemented in case of zero-tolerated behaviours regarding the prevention of all kinds of violence are set out.

SCOPE

The processes, sanctions and support mechanisms in this policy applies to all Aklease employees.

LIABILITIES

Prepared By : Department of People and Culture
Opinion Issued By : Compliance Department
Approved By : Board of Directors
Published By : Department of People and Culture
Users : All Aklease employees

REFERENCE SOURCES

• Zero-tolerance for violence policy is prepared by way of evaluating the relevant company policies and principles, legal regulations and reference sources published by international institutions.
• Aklease policy and implementation principles
• Aklease Sustainability Strategy
• Corporate Governance Statement
• Human Rights Policy
• Diversity and Inclusion Policy
• Ethical Principles
• People and Culture Practice Principles
• Disciplinary Regulations
• Principles and policies of national and international institutions
• United Nations Global Agreement Women's Empowerment Principles (WEPs)
• United Nations Policy Brief: The Impact of COVID-19 on Women
• ILO Handbook Addressing Violence and Harassment against Women in the World of Work
• ILO Guide to a Safe and Healthy Working Environment Free From Violence and Harassment
• T.C. Ministry of Labour and Social Security Information Guide for Psychological Harassment (Mobbing) at Workplace Practical Guide
• Relevant legal regulations

FACTORS THAT DAMAGE SAFETY

The right to live and work safely is one of the most crucial human rights. Violence and abuse that damage people's safety or sense of security through physical or psychological harm or through domination can occur in different types.

Physical violence: It is the use of bodily strength as a means of violence to control, dominate, humiliate, insult or punish the person. It can be perpetrated by gaining physical dominance or by creating a fear of gaining physical dominance, by touching body or by creating the fear of touching body, or by using things or creating a fear of using things.

Shouting, punching, kicking, wounding with a gun or knife, throwing objects, depriving a person of their basic needs by physical dominance or creating the fear that these may happen are examples of physical violence.

Psychological violence: It is the use of emotional strength or needs for the purpose of controlling, dominating, humiliating, insulting, punishing.

Exhibiting humiliating and threatening behaviour in a systematic way, making the person feel inadequate and weak, mocking, swearing and insulting, isolating them by preventing them from meeting with others are examples of psychological violence.

Psychological violence at workplace takes place with the systematic, constant and deliberate display of behaviours such as:

• Shouting and insulting the person
• Making fun of, mocking, belittling their work and ideas in the presence of their colleagues
• Treating or discriminating against the person differently
• Trying to stigmatize in the eyes of colleagues
• Ignoring, excluding or keeping out the person
• Constantly threatening or forcing
• Intentionally leading to failure by giving tasks that cannot be completed within the given time
• Hide or manipulate information important to their business to mislead, then accuse them of negligence or professional misconduct

Providing psychological security is important for the prevention of psychological violence. Psychological safety can be defined as minimizing the risk of work-related factors harming the mental health of the employee or eliminating the risk of harming the employee.

Sexual violence: Force a person into having sexual intercourse in a place, in a way or time that they do not want, or saying sexual words to a person, to harass or to attack a person.

In the same way, physical or verbal abuse of a person, being exposed to sexually explicit words, innuendos or jokes are sexual violence.

Examples of sexual violence are physically harassing, taking sexually explicit images without consent, spreading or threatening to spread sexually explicit images, forcing a woman to give birth or not to give birth to a child. The marital status of the person, whether the person is married or not, does not change the definition of violence.

Economic violence: The use of material power and superiority as a means of violence to control, dominate, humiliate, insult and punish.

Preventing a person from working or getting a job, seizing or controlling or trying to control his income and savings, endebting, preventing him from saving or investing are examples of economic violence.

Digital violence: The use of technological tools to control, dominate, humiliate, insult and punish the person.

Continuously sending unwanted messages or making unwanted calls, stalking social media accounts and following or threatening the person with the information therein, posting humiliating, insulting and hateful posts on social media are examples of digital violence.

POLICIES TO SUPPORT SAFETY AT HOME

The most important factor that damages or ignores the state and feeling of being safe at home is domestic violence. Domestic violence affects many people, predominantly women, around the world and stands out as a global problem.

For this reason, Aklease considers it a responsibility to establish the necessary processes and support channels for the protection of employees who share that they are exposed to domestic violence and to provide all kinds of support. In addition to the support that can be received from social institutions, as an employer, it undertakes to take the necessary actions to ease the working life of the employee who is a victim of violence and to increase workplace safety.

In this context, in order to encourage our employees who are victims of domestic violence to get out of the cycle of violence and to take action, it has been shared with employees that they can inform our company of the situation without hesitation.

The support actions that can be taken if the employee who is a victim of domestic violence, shares this information with Aklease and if the employee requests such support, are given below. Support processes are operated with the consent of the employee who is a victim of violence, and by completely adhering to the principles of confidentiality.

• If the victim has a protection or removal order given by the courts, the support listed below is given to the employee for the enforcement of the removal order in the workplace. Workplace safety planning is re-evaluated with the employee for the needs of the employee.
• Where possible, the area where the employee sits at the work location can be rearranged so that it is not visible from the outside or open to the public.
• Information such as the employee's work location, work phone, e-mail address may be changed.
• In order to prevent the perpetrator from being garnished, the employee's salary and benefits account information may be changed.
• When possible, the service routes used for transportation to the workplace may be rearranged.
• Where possible, the employee may be accompanied to his/her vehicle by private parking and security guards.
• In order to meet the security, psychological or health-related needs of the employee who has been victim of violence, the working model (from the office, hybrid or remote) is re-evaluated according to the needs of the person.
• Paid administrative leave can be given to the employee without affecting his/her leave rights. The duration of the leave is evaluated together with the employee.
• In case of performance evaluation period, a special performance evaluation process can be applied without ignoring the status of the employee, or the performance evaluation action may be postponed until a different time to be determined with the employee.

On the other hand, the employment relationship is evaluated with the employees whose use of domestic violence is proven by the court decisions, likewise, it is evaluated whether any employment relationship will be established with the candidates who have court decisions in this regard during the recruitment phase.

POLICIES TO SUPPORT SAFETY AT WORK

Failure to create an environment of physical and psychological trust in the workplace has an impact, not only at the personal level, but also at the institutional and social level.

Acts of violence and abuse that damage the state and feeling of safety in the workplace, take place in downstream direction (from superiors to subordinates), upstream direction (from subordinates to superiors), or horizontally (between equals).

Employees may remain silent against these behaviours and approaches for reasons such as damage to employment relationships, fear of losing their job, concerns that they will not be believed, avoiding appearing inadequate or lack of self-confidence.

In order to prevent such situations, Aklease adopts a "zero tolerance" approach against all kinds of violence, abuse and behaviour that harms the creation of a trust environment in the workplace.

In this context, support channels based on confidentiality have been created and shared with employees, through which our employees can communicate without hesitation about situations that harm physical and psychological trust in the workplace.

The principles regarding the process to be applied in case of encountering violence in the workplace and making the necessary notifications have been determined as follows:

• Employees can request support by reporting directly to the Company Ethics Line.
• Employees can convey their notifications in this regard to their directors. In this case, the relevant directors contact HR directly without wasting time and ask for support for the commencement of the relevant processes.
• The notifications that the employees convey directly to the Ethics Line or received through their directors are evaluated as soon as possible, strictly adhering to the principles of confidentiality.
• During the notification evaluation,
• According to the needs of the victim employee change of work location, change of team or change of position may be considered.
• The way the victim employee works as completely from the office, hybrid or completely remote can be re-evaluated.
• The use of paid annual leave or administrative leave by the victim employee may be considered within the periods to be determined according to the needs.
• In case it is determined that the victim employee has suffered a loss of material rights due to the act of violence, compensation for the loss of material rights may be considered.
• It may be considered that the person who is reported to have committed violence takes compulsory paid annual leave or administrative leave throughout the process.
• If there is a performance evaluation period, who will carry out the evaluation can be re-evaluated or the performance evaluation may be postponed until a different time to be determined with the employee.
• Information about the evaluation results are discussed with the employees and the relevant information is conveyed.
• The employee's right to initiate legal proceedings regarding the subject is always reserved. There is absolutely no guidance given not start the legal process or to keep it confidential.
• When necessary, the issue is reported to the Akbank Board of Internal Auditors by the Aklease Internal Control Department, and action is taken within the framework of the rules set forth in our "Discipline Regulation" regarding the person who is determined to behave in a way that damages or destroys trust in the workplace.

AWARENESS and EDUCATION

In order to prevent all kinds of violence, raising consciousness about the issue and raising the awareness of the public are very important factors. In order for Aklease employees to become more sensitive about the issue and to know what to do in such situations:

“Gender Equality Training” is prepared and made accessible to all employees to raise awareness on gender roles and equality.
“Awareness of Prevention of Violence” training is made available to all employees in order to strengthen the steps to be taken to prevent violence and to provide guidance on what to do if violence is encountered.
Compulsory trainings on “Gender Equality” and “Prevention of Violence” are provided to the employees of the team who will implement the policy.
Compulsory trainings on “Prevention of Violence” are provided especially for leaders who have important duties and responsibilities in ensuring trust in the workplace and preventing all kinds of violence.

SUPPORT CHANNELS

External Support Channels

Some of the external support channels that people can apply to or lead relevant people to apply are listed below:

• Emergency Hotlines
• ALO ​​183 Social Counselling Line for Family, Women, Children and Disabled People
• 112 Emergency Call Centre
• ALO ​​170 Work Life Contact Centre
• Domestic Violence Hotline
• İBB Women Support Line
• Non-Governmental Organizations
• Mor Çatı Women's Shelter Foundation
• End Domestic Violence Hotline

Internal Support Channels

Our employees who declare that they have experienced violence in the family or at work will be able to receive support from the Company Ethics Line. The following principles are applied in the evaluation of the notifications sent to the Company Ethics Line and/or by the managers:

• The Company Ethics Line can be reached via e-mail at etik@aklease.com.
• Notifications to the ethics line are taken into consideration immediately.
• All evaluations are carried out in complete confidentiality. Information regarding the notifier is not transferred to anyone other than the employees in the Evaluation team.
• Evaluation is carried out by the Department of People and Culture, without any hierarchical privileges. According to the evaluations, the issue
• Can be conveyed to the opinion of the General Manager, the actions to be taken according to the evaluation results are determined and implemented.
• notifications and actions taken are periodically reported to the Sustainability Committee no name and anonymously.

EFFECTIVENESS AND REVISION

This document and the amendments to be made in the document enters into force on the date approved by the Board of Directors.