POLICIES

Labor and Human Rights Policy

1. OBJECTIVE

The purpose of this policy is to express the way we prioritize, support, and protect human rights and social responsibilities in all Semtrio’s activities. Our main objectives are to maintain the highest ethical standards and humane working conditions in our business processes, to provide a fair and respectful working environment for all employees and business partners, and to contribute to the general welfare of society.

2. SCOPE

This policy covers all operations of the company, its employees, business partners, suppliers, stakeholders, and relations with customers. Respecting human rights and fulfilling social responsibilities are prioritized at every stage of the business processes. It also includes raising awareness of social rights and humane working conditions among employees, business partners, and society at large. Semtrio reserves the right to impose legal and economic sanctions on the relevant persons and institutions as a result of violations of labor and human rights, the relevant policy, and supplier codes of conduct.

3. OUR VISION

By placing respect for labor and human rights at the core of our business strategy, we are leading positive change in the business world and contributing to a sustainable future.

4. OUR MISSION

Our mission is to help individuals and organizations achieve their goals in sustainable living and business practices by providing in-depth consultancy services to our clients on employee and human rights and social responsibility issues. One of our main tasks is to develop strategies for corporate social responsibility and human rights and to lead companies to improve their social and environmental impact.

5. SOURCE

Semtrio supports ways of working that comply with all national and international standards and legislations, including

Republic of Türkiye Occupational Health and Safety Law No. 6331
Republic of Türkiye Labor Law No. 4857
UNSDG (United Nations Sustainable Development Goals)
UN Global Compact
UN Universal Declaration of Human Rights,
Worst Forms of Child Labor Convention (Treaty No. 182)
ILO (International Labor Organization)
ILO Declaration on Fundamental Principles and Rights at Work
Universal Declaration of Human Rights
WEPs (Women’s Empowerment Principles)
SASB (Sustainability Accounting Standards Board)
ETI Base Code (Ethical Trading Initiative)

The policy implemented by our company complies with the standards of B-Corp (Benefit Corporation) and the United Nations Global Compact (UNGC), which are globally-recognized standards in the field of sustainability and corporate responsibility. B-Corp is a comprehensive certification system that assesses companies’ social labor, human rights and social performance, transparency, and accountability. By meeting high standards in this assessment process, our company has proven its commitment to ethical business practices, environmental responsibility, and the benefit of society. Furthermore, by fully complying with the UNGC’s ten principles in the areas of human rights, labor standards, environment, and anti-corruption, we demonstrate that we have adopted sustainable and responsible business practices on a global level. This reflects our company’s commitment and dedication to making a social and environmental impact both locally and globally.

6. RESPONSIBLE PERSONS, MONITORING AND REVIEW

This policy has been developed by the Labor and Human Rights Committee of Semtrio Eğitim ve Danışmanlık Hizmetleri A.Ş. by accounting for the opinions of the employees, stakeholders, suppliers, customers and business partners of the organization. It will be reviewed annually, considering stakeholder feedback, continuous monitoring, tracking of targets and KPIs, tracking awareness, innovative approaches, research, and data analysis. Necessary revisions will be made in cases such as organizational changes and changes in local and international legislation.

LABOR AND HUMAN RIGHTS COMMITTEE

CEO

Climate Solutions Director

Human Resources Executive

Sustainability Solutions Department - Project Manager

Climate Solutions Department - Project Manager

Employee Representatives

7. IMPLEMENTATION

7.1. Employee Health and Safety

Ensuring, protecting, and monitoring the psychological and physiological health, safety, and well-being of its employees is one of the top priorities for Semtrio. Through risk assessments, emergency response/ action plans and continuous training programs, efforts are made to provide a safe working environment for all employees. Measures are taken against possible work accidents and near misses, and continuous improvements are made through root cause analysis. Employees are informed about appropriate sitting posture for remote work, and ergonomic chairs, tables, and equipment to support spinal health and protect the musculoskeletal system are provided for office work. Employees undergo health examinations during the recruitment phase and on a regular basis. Training on combating work-related stress, time management, proper management techniques, and effective communication is provided.

Employees are encouraged not to use tobacco products, and employees who do not use tobacco products are provided with 5 days of extra leave in addition to all leave.

7.2. Working Conditions - Working Hours, Payments, Annual Leaves, etc.

In business activities, working hours that comply with the law and respect human rights are applied. It is considered a priority for employees to take regular breaks, use their annual leaves, and establish a productive work-life balance. Wage payments and social benefit payments are paid in accordance with the law, on time, and fairly, following the scales based on numerical data obtained through market research, and each employee is informed with payrolls. Types of leave, such as maternity leave, sick leave and administrative leave, are also enacted within the framework of legal provisions.

Annual performance targets are set, and meetings are organized based on these targets. At the end of the year, performance evaluations and interviews are held, and employees are informed about what is expected of them throughout the year, what has been achieved, targets, etc. Employees reserve the right to make comments during performance interviews.

7.3. Social Dialogue

Open, honest, fair, and two-way communication is established with all employees, and their opinions and suggestions are integrated into business processes. The company adopts an open-door policy and evaluates complaints/suggestions and feedback through regular monthly business development meetings and an online platform where employees can anonymously submit their complaints and suggestions. The Company also adopts an employee representation system, organizes meetings with representatives, and evaluates their opinions and suggestions. Quarterly surveys are organized, and the results of the surveys are shared with the employees themselves, and mutual opinions are exchanged on the points open to improvement. The right of employees to bargain collectively and become a member of trade unions is respected.

7.4. Career Management

The career development of employees is actively supported, and their individual talents and professional goals are taken into consideration. Cross-skill training outside the position and job description is organized for the company. Annual performance evaluations are conducted, and feedback on positive or improvable aspects of employees’ performance is shared with them during these evaluations. Employees are encouraged to follow ongoing research and innovations. Reasonable career development plans are created, and position-based leadership, coaching, and mentoring training are provided, as well as effective trainings (use of artificial intelligence, effective communication, use of software, etc.) that are not career-oriented, which are thought to be beneficial for the personal development of employees, and which they can apply and use in their daily lives.

During recruitment, employees are provided with a reasonable career plan. In this process, goals are set, in-house training, meetings, etc., are organized for full compliance with the goals, and processes are evaluated with the principle of objectivity and transparency.

7.5. Working Age

Semtrio fights against the participation of children in the labor force and does not tolerate any practice that causes psychological and physical harm to children and interferes with their right to education and training. The company verifies identity and age in its recruitment processes and is committed to full compliance with the laws regarding the age of employment.

7.6. Forced Labor

The principle of zero tolerance for forced, bonded, restrictive, coercive, or unfree labor is adopted. Employees’ rights to freedom and independence are respected. Employees can leave their jobs freely. Any form of restrictive and involuntary regular and overtime work is strictly opposed.

7.7. Cruel and Inhuman Treatment

A tolerant work culture is offered. We are committed not to exposing any employee or business partner to an oppressive, stressful, discomforting, or tense work atmosphere. Reasonable and measurable targets and performance expectations are set and acted upon. Mobbing and psychological harassment are unacceptable. Respectful and supportive work environments are provided. In addition, there is absolutely no place in our company for inhumane treatment, i.e., all kinds of treatment that are humiliating, degrading, and contrary to human rights. Any case of inhumane treatment will be immediately investigated and taken seriously, and necessary steps will be taken within the relevant legal framework.

7.8. Harassment

In business processes, no form of harassment (verbal harassment, physical harassment, bullying, threats, misconduct, abuse of office, etc.) is accepted by the organization. At Semtrio, we respect the private lives of all our employees and are committed to providing them with a work environment that is peaceful, safe, and does not tolerate disruptive behavior. Harassment cases are investigated immediately and taken seriously by the relevant units of the company. Victims are provided with support, and perpetrators are dealt with fairly. Our company culture is based on respect, integrity, and equality.

7.9. Discrimination

We do not discriminate against our employees on the basis of religion, language, race, age, gender, disability, marital status, HIV/AIDS, ethnic origin, pregnancy, union membership, political opinion, sexual orientation, form of worship, family responsibilities, socioeconomic status, education type and level, unconscious bias, status of being a local or foreign immigrant or refugee, etc. in any of the recruitment, disciplinary processes, promotion and raise, training rights, and dismissal processes. Citizens of different countries who have come to our country and work with appropriate documentation in forms recognized by the law have equal rights with everyone else within the company. Our organization is against all forms of discrimination; gender or gender roles are not one of the parameters in matters such as wages, recruitment, dismissal, etc. We adopt equal work, equal pay, equal social rights, and fair wage policies, and disciplinary procedures are carried out in case of discriminatory practices.

7.10. Human Trafficking

Our organization opposes all forms of slavery and human trafficking and approaches this issue with a zero-tolerance perspective.

7.11. Diversity, Equity, and Inclusion

Semtrio recognizes the right of every individual to equal rights and equal opportunities. Semtrio supports a participatory, inclusive, and diverse work environment and living standards where different cultures and ethnicities come together and where different experiences and perspectives can be freely shared, independent of gender roles, sociocultural background, and disability status within the framework of the importance given to gender equality. The importance of women’s participation in the workforce and equal opportunities are also emphasized in business relationships with stakeholders. The company is committed to providing a working environment that embraces all this diversity and where everyone can make their opinions and voices heard.

7.12. Human Rights Relations with External Stakeholders

Semtrio’s Supplier Code of Conduct, which is presented to customers at the beginning of the business relationship, conveys Semtrio’s perspectives and expectations regarding environmental, social, and ethical business rules and responsible purchasing and business partnerships. In addition, stakeholders’ land rights are protected within the legal framework, safety and security rights are respected, sustainability awareness is raised, and employees adopt and implement ethical approaches that respect human rights.

7.13. Freedom of Association, Representation, and Expression

Employees are free to belong to and operate in structures where they feel they can express their thoughts, beliefs, and interests more freely. Semtrio supports activities at the individual and collective level without using corporate resources and outside working hours. The company respects the freedom of employees to organize/unionize without any concerns.

7.14. Unhealthy Substance Use and Betting

Prohibited substances and betting jeopardize the health of individuals and the general well-being of society. Therefore, Semtrio attaches great importance to employee awareness programs on such risks. The health of society and the well-being of individuals are our top priorities, and tackling such risks is part of our social responsibility.

8. GOALS

1. Continuing to provide 100% of our employees with training where we can express in detail our perspective on the importance of social rights, human rights, oppression, harassment, discrimination, forced labor, and child labor in 2024.

2. Providing information security and confidentiality training to all our employees in 2024.

3. Organizing a satisfaction survey every month in 2024 to increase social dialogue. Continuing to hold meetings where views can be sought on the results.

4. Providing training on certain internationally recognized programs (finance training, AI training, etc.) in addition to mentorship training that will contribute to the personal development of our employees.

5. Continuing the social events planned by the the Event Club on a monthly basis in 2024.

6. Making donations to non-governmental organizations working on human rights.

7. Organizing morning activities (online/face-to-face) that we think will benefit the physical health of employees (sports, yoga, etc.) in 2024, on the last Friday of every month.

9. DISCLOSURE AND RESPONSIBILITY FOR ETHICAL RULES AND ETHICAL VIOLATIONS

There is an ethics hotline where employees can express their opinions and complaints at any time, either anonymously or openly. This system allows for anonymous feedback and follow-up on relevant issues. At the same time, an open-door policy is in place to ensure open and comfortable communication with our managers and committee members. At the business development meetings held regularly every month, employees can discuss their suggestions and complaints anonymously or openly. The issues are evaluated, and improvements are made.

Information for contacting the Ethics Hotline to report violations that may occur in labor and human rights practices (child labor, oppression, harassment, discrimination, forced labor, inhumane treatment, human trafficking, prevention of freedom of association, practices against ethical business trade, etc.) is as follows:

Complaint and Whistleblowing Hotline: 00902168070248
E-mail Address: [email protected]