Code of Conduct





High standards of professionalism and ethical behavior are essential to implement our strategy, stand by our values ​​and achieve our goals. This Code of Conduct describes the basic principles that each of us must follow when acting on behalf of the company. It explains what we are committed to as an employee and what is expected of you.

Our employee must act in compliance with applicable laws and regulations, with integrity and ethics in business conduct and in maintaining company reputation in all cases. Our employee must, above all, comply with the standards and principles in this Code of Conduct, while respecting the traditions and customs of the company and Broadview's customers, business partners and employees around the world.



This Code of Conduct applies to all employees, regardless of their contract type or location of their work. This includes management and temporary employees. The employee must both comply with this Code of Ethical Conduct and notify the relevant authorities as stated in the "5-Way to Follow" section below, if she/he detects any person or institution within the scope of violating this Code of Ethical Conduct.



3.1. Always Be Respectful and Do Not Discriminate

All employees and managers must treat all stakeholders with respect, regardless of the "superior-subordinate relationship" or "customer-supplier" relationship. All employees must always establish relationships and communicate respectfully, whether through spoken words, tone of voice or body language, without harming the people and institutions with whom they have a business relationship in any way. Discrimination and oppression cannot be made against the people we work with, for any reason. Any attitude or behavior that causes individuals to feel alone, excluded or threatened within the community is unacceptable in any way.


3.2. Protect Company Assets and Resources

All employees should regard the company's assets and resources as a trust and protect those trusts at the highest level. Time, money or anything measurable in money belonging to the company, workforce, machines, goods, equipment, consumables, information, cyber data, patents, projects, intellectual and industrial rights, reputation of the company, customers of the company, suppliers of the company and similar things to the all company resources belonging to it cannot be abused, wasted or used for personal purposes by anyone. The financial records of the company (balance sheets, invoices, financial reports, personnel entry and exit records, payrolls, etc.) are created in the most accurate way and no financial irregularities are allowed.


3.3. Stay Away from Situations That May Create a Conflict of Interest

All employees stay away from situations where the company's interests and personal interests conflict (intersect). It does not accept any benefit offered by employees, customers, suppliers or similar persons and institutions, or potential candidates for these roles, and is aware that this benefit carries the risk of turning into a claim against the company in the future. Establishing distant and objective relationships with people who may cause a conflict of interest and with institution officials protects employees from possible negative situations and accusations.


3.4. Adhere to the Law

All employees must fully comply with applicable local and international laws. Acting against the law should be avoided in relations with government officials. In government affairs, business should always be carried out through legal means, completely avoiding bribery and corruption. In case of any violation of law by mistake, the employee must report this mistake to the company management as soon as possible.


3.5. Comply with Occupational Health and Safety Measures and Protect the Environment

All employees must fully comply with the measures taken regarding occupational health and safety. Behaviors that may harm the employee or other employees of the company or the employees of people and institutions with whom the company has business relations in terms of health and safety should be avoided. Likewise, all employees must comply with the directives set by the company in terms of environment and sustainability. Risks identified regarding occupational health, safety and the environment should be reported to the company's Occupational Health, Safety and Environment department.


3.6. Do not do or get work done in exchange for bribes, gifts or entertainment

Any bribery is not allowed anywhere and at any time in all company-related processes. This means that we cannot give or receive anything of value (including any payment, charitable gift or entertainment), directly or indirectly, to obtain or retain business, influence business decisions or obtain an improper advantage in the conduct of our business. This rule also includes making facilitation payments, giving gifts, providing benefits such as entertainment (fantastic meals, holiday opportunities, etc.) to expedite or secure the performance of a routine government procedure through third parties such as agents and distributors.

The exchange of gifts, party and entertainment can contribute to establishing and maintaining good relationships with customers, suppliers and other partners, as long as they remain modest and do not continue on an ongoing basis. However, this should never be done, or appear to be done, to obtain or retain business, influence business decisions, or gain an improper advantage in the conduct of our business. In this context, representative gifts (agenda book, normal stationery pen, etc.) that do not provide any financial benefit can be received or given.


3.7. Be Open and Fair in Competition

True and honest competition is one of the important elements for the development of the company and the sector in which it operates. Employees must act within the framework of fair competition conditions in the sector in which they operate. Competitive behavior that may cause detriment and/or unfair benefit to the company is not allowed. It is unacceptable to share competitively sensitive information with a competitor, such as market pricing information, customer information or the business's future plans, or to share competitively sensitive information of business partners or other third parties with competitors. Employees' obligations in terms of fair competition continue after they leave the company.



In case of violation of the law or rules, the company may apply serious sanctions, such as suspending or terminating the service contracts of individuals and institutions that violate this violation, or resorting to legal and criminal litigation. The employee must always behave and act with awareness of this sanction.



If the employee witnesses or obtains information about a violation of the law or company rules, or is concerned about a possible violation, or if the employee himself commits a violation for any reason, he must report this situation in good faith and with full details without delay, using one of the options below.

- Notifying the first manager or the next level manager in writing, or

- To notify in writing directly via

The manager who is notified of a violation of the Code of Conduct by any employee then must notify the situation to  without delay. After the information is provided, the persons who obtain the information, the persons who provide the information, and the persons whose testimony is consulted in case of a possible investigation are obliged to fully comply with the principles of confidentiality and not share the information they have obtained with anyone other than the above-mentioned authorities and e-mail accounts.

It is not right for the employee to investigate the issue himself or to seek evidence regarding the issue. In cases where an investigation is required, the investigation is managed meticulously and confidentially through the Ethics Committee, which will be invited by the Human Resources department. The company may use independent outsourcing support and/or legal support when deemed necessary.



An Ethics Committee is appointed by the company management to examine, evaluate and decide on all situations (complaints, notifications, determinations, etc.) regarding violations of the Code of Conduct. The Ethics Committee consists of the following members:


- Human Resources department officer

- Company Lawyer

- An impartial department official to be determined by the CEO or the Human Resources department official

In order for the Ethics Committee to meet, it is sufficient for the majority of the above members to be present. All evaluations and studies carried out within the scope of the Ethics Committee are kept confidential. Ethics Committee decisions are taken by majority vote of the participants. Decisions taken by the Ethics Committee are made in writing. All records, correspondence and decisions taken by the Ethics Committee are meticulously kept by the Human Resources department.