Company Policies
Horoz Lojistik Kargo Hizmetleri ve Ticaret A.Ş. (“the Company”) dividend distribution policy has been prepared in accordance with the provisions of the Turkish Commercial Code No. 6102, the Capital Markets Law No. 6362 (“CMB”), the Capital Markets Board’s Dividend Distribution Circular (II-19.1) (“the Circular”), and our Articles of Association.
Purpose
The purpose of the dividend distribution policy is to enable shareholders to foresee the procedures and principles for the distribution of the Company’s future profits, in compliance with the regulations to which the Company is subject and the provisions of its Articles of Association. The Company exercises utmost care to ensure a balance between the interests of shareholders and the interests of the Company in dividend distribution.
Authority and Responsibility
The Board of Directors is responsible for monitoring, overseeing, developing, and updating this Dividend Distribution Policy. This policy, including the dividend distribution decision, the method and timing of dividend distribution, is approved by the General Assembly upon the recommendation of the Board of Directors and publicly disclosed on the Company’s website.
Dividend Distribution Principles
The company may decide to distribute dividends, provided that the net profit for the period, calculated within the framework of the articles of association, the Turkish Commercial Code, the Capital Markets Law, Circular No. II-19.1 on Dividend Distribution, and tax regulations, is approved by the general assembly and there are no legal restrictions. The rate of dividend to be distributed depends on the company's investment and financing strategies and needs, market expectations, regulations stipulated in the relevant legislation, the capital requirements of the company and its subsidiaries and affiliates, company policies, profitability, the company's financial situation, economic conditions, and a number of other factors, including but not limited to these. The rate of distributable profit may be reduced or even decided not to distribute dividends, upon the proposal of the board of directors and the approval of the general assembly. If the board of directors proposes to the general assembly that no dividend be distributed, the reasons for this and where the undistributed profit will be used will be explained in the agenda item. This situation will be presented to the shareholders for their information and approval. Dividends may be distributed in cash or as bonus shares. As of the distribution date, dividends will be distributed equally to all existing shares in proportion to their shareholdings, regardless of their issuance and acquisition dates. Rights regarding dividend privileges are reserved. Dividend distribution procedures shall commence no later than the end of the fiscal year in which the general assembly meeting decided on the distribution, on the date specified at the general assembly meeting.
Dividends may be paid in equal or different installments, provided that this is decided upon at the general assembly meeting where the distribution is decided. The number of installments shall be determined by the general assembly or, with the explicit authorization of the general assembly, by the board of directors. The payment times determined by the board of directors shall be announced to the public by the company within fifteen days following the general assembly meeting, in accordance with the Board's regulations on the public disclosure of special circumstances. Unless the reserves required under the Turkish Commercial Code and the dividends determined for shareholders in the articles of association or the dividend distribution policy have been set aside, no decision can be made to set aside other reserves, to carry forward profits to the following year, or to distribute profits to holders of usufruct certificates, members of the board of directors, company employees, and persons other than shareholders; and profits cannot be distributed to these persons unless the dividends determined for shareholders have been paid in cash.
The board of directors' proposal regarding profit distribution or the board of directors' decision regarding the distribution of advance dividends, along with the profit distribution table or advance dividend distribution table, the form and content of which are determined by the Board, are announced to the public within the framework of the Board's regulations on the public disclosure of special circumstances. The profit distribution table must be announced to the public no later than the date on which the agenda of the ordinary general meeting is announced. Furthermore, if any changes are desired in this profit distribution policy, the board of directors' decision regarding the change and the justification for the change must also be announced to the public.
The general meeting may decide to distribute advance dividends to shareholders within the framework of the relevant provisions of the Turkish Commercial Code and capital market legislation; companies may distribute advance dividends in cash based on the profits shown in their interim financial statements. Advance dividends relating to a specific interim period cannot be distributed in installments. Companies wishing to distribute advance dividends must have a provision in their articles of association and authorize the board of directors, by a general meeting resolution, to decide on the distribution of advance dividends, limited to the relevant accounting period. At the aforementioned general assembly meeting, it must also be decided that in the event of insufficient profit or a loss at the end of the relevant accounting period, the advance dividend to be distributed will be offset against the sources of dividend distribution listed in the annual financial statement for that accounting period. The advance dividend is distributed equally to all existing shares as of the distribution date, regardless of their issuance and acquisition dates. Advance dividends cannot be distributed to persons other than shareholders. The advance dividend to be distributed cannot exceed half of the amount remaining after deducting the reserves required to be set aside according to the Turkish Commercial Code and the articles of association, as well as losses from previous years, from the net profit for the period as shown in the interim financial statements. The total amount of advance dividends to be given in an accounting period cannot exceed the lower of half of the net profit for the previous year and the other sources of dividend distribution, excluding the net profit for the period, as shown in the relevant interim financial statements.
The company's dividend distribution principles are regulated in Article 18 of the Articles of Association, titled "Determination and Distribution of Profits".
Purpose
The purpose of this disclosure policy is to share information and disclosures that are legally required to be disclosed or have become discloseable, in accordance with the Turkish Commercial Code No. 6102 (“TCC”), the Capital Markets Law No. 6362, the Capital Markets Board’s (“CMB”) “Special Circumstances Communiqué” No. (II-15.1) (“Special Circumstances Communiqué”) and “Corporate Governance Communiqué” No. (II-17.1), and other capital market legislation, with the public and existing and potential investors in an equal, effective, and timely manner.
The Company complies with the Capital Markets Law No. 6362 (“CMB”), the Turkish Commercial Code No. 6102 (“TCC”), capital market legislation, other relevant legislation and regulations, and the regulations of Borsa Istanbul A.Ş. (“BIST”) regarding public disclosure. The Company takes utmost care to ensure the implementation of the principles set forth in the Corporate Governance Principles, as regulated in the Capital Markets Board's ("CMB") Communiqué on Corporate Governance, which may be amended and changed from time to time.
This Company Information Policy has been prepared in accordance with Article 17 of the CMB's Communiqué on Special Circumstances (II 15.1) and the Corporate Governance Communiqué (II-17.1).
Authority and Responsibility
The Company's Board of Directors is responsible for the creation and necessary updates of the information policy. The information policy approved by the Board of Directors ("Information Policy") is publicly disclosed on the corporate website. The policy has been presented to shareholders as a separate item on the agenda of the Company's general assembly meeting. The Investor Relations Department is responsible for monitoring and overseeing all matters related to the Information Policy. All questions regarding the principles and procedures for the implementation of this policy should be directed to the Investor Relations Department.
Information Tools
The Company uses the following tools for informing and educating the public:
(a) Special disclosure statements, financial reports, and the KAP Company General Information Form published on the Public Disclosure Platform ("KAP")
(b) The investor relations section of the Company's corporate website
(c) Prospectuses, circulars, announcements, and other documents required to be prepared in accordance with capital market legislation
(d) Announcements and notices made through the Turkish Trade Registry Gazette ("TTSG") and, if deemed necessary, daily newspapers
(e) General assembly meetings
(f) Press releases issued by the Company through written, visual, and social media
(g) Information and promotional documents prepared for investors; presentations introducing the company
(h) MKK's e-Company and e-GKS platforms
Without being limited to the above, the Company may use other communication tools permitted by legislation for communication with investors.
Monitoring News and Rumors in Press and Media Outlets or on Internet Sites and Principles for Making Statements Regarding Them
The Company is obligated to monitor news and rumors about the Company that appear in press and media outlets or on internet sites. Statements regarding news and rumors shall comply with the provisions of the Special Circumstances Notice and other relevant legislation.
Disclosure of Forward-Looking Assessments
If Company officials wish to disclose forward-looking assessments to the public, they shall comply with the principles set forth in the relevant legislation.
Responding to Written Information Requests
The Company's Investor Relations Department is obligated to respond to shareholders' written information requests regarding the Company, excluding information that is confidential and not publicly disclosed. In accordance with legislation, the Company responds to information requests from investors in writing via the email address yatirimci.iliskileri@horoz.com.tr.
Monitoring News and Rumors in Press and Media Outlets or on Internet Sites and Principles for Making Statements Regarding Them
The Company is obligated to monitor news and rumors about the Company in press and media outlets or on internet sites and for making statements regarding them. Presentations and Reports Disclosed at Investor Information Meetings or Press Conferences
The Company may organize investor information meetings or press conferences and disclose presentations and reports at these meetings, as deemed necessary to ensure that stakeholders are informed equally and effectively. These presentations and reports may be published on the Company's website and on the Public Disclosure Platform (KAP) if deemed necessary, provided that they contain information of a special nature.
If the content of the presentations and reports disclosed at these meetings contains information of a special nature, these presentations and reports will be published on the Company's website simultaneously with the meeting. Before or simultaneously with the public disclosure of matters subject to special circumstances, an announcement will also be made on the Public Disclosure Platform (KAP), and the relevant announcement will also be published on the Company's website.
Protection of Inside Information Confidentiality
The Board of Directors shall establish effective regulations to ensure the confidentiality of inside information and other special circumstances that have not yet been publicly disclosed and that may affect the value of the capital market instrument and investors' investment decisions, and shall take all necessary measures, using all available technical means, when necessary. The Company shall take the necessary measures, as required by legislation, to ensure that persons with access to inside information are aware of their legal obligations regarding inside information and the sanctions related to the misuse of this information. In accordance with Article 7 of the Special Circumstances Communiqué, the Company shall prepare a list of persons with access to inside information and notify the Central Registry Agency. The list shall be updated within the period stipulated by legislation whenever there are changes to this information.
Principles for Determining Persons with Administrative Responsibility
In addition to the members of the Board of Directors, individuals who have regular direct or indirect access to the Company's internal information, who have the authority to make administrative decisions affecting the Company's future development and commercial objectives, and who have individual signing authority in accordance with the provisions of the current internal regulations/signature circular, are considered "Persons with Administrative Responsibility". These individuals are determined by the Investor Relations Department, taking into account the Company's organizational structure and the job descriptions of the positions.
In accordance with Article 11 of the Special Circumstances Communiqué, transactions carried out by persons with administrative responsibility within the Company, persons closely related to them, and the Company's main shareholder regarding shares representing the capital and other capital market instruments based on these shares are disclosed to the public within the framework of the principles set forth in the said communiqué.
Prohibition Period Application
The Company implements a "Prohibition Period" during which Persons with Access to Inside Information may not buy or sell Company shares prior to the public disclosure of its financial statements. Accordingly, Persons with Access to Inside Information may not buy or sell Company shares during:
(a) January 1st, until the day following the date of public disclosure of the year-end financial statements,
(b) July 1st, until the end of the day following the date of public disclosure of the six-month financial statements.
Purpose
This policy has been prepared in accordance with Article 4.6.2 of the Corporate Governance Principle, annexed to the Corporate Governance Communiqué, to regulate the remuneration principles of board members and executives with administrative responsibilities, and was presented to shareholders as a separate item on the agenda of the general assembly meeting held on August 28, 2024.
Authority and Responsibility
The Remuneration Policy was created by the Board of Directors within the framework of the Capital Markets Board's Corporate Governance Principles, presented to shareholders as a separate item on the agenda of the Company's general assembly meeting, and their opinions were sought. The monitoring, oversight, development, and necessary updates of the Company's remuneration policy are under the authority and responsibility of the Board of Directors. Changes to the Remuneration Policy will be presented to shareholders for their information and opinion at the general assembly meeting following the approval of the Board of Directors, and will be published on the Company's website.
Remuneration Principles
According to Article 7 of our Articles of Association, the General Assembly is authorized to determine the remuneration to be paid to the members of the Board of Directors and any financial rights other than remuneration to be granted to the members of the Board of Directors, in compliance with the regulations of the Capital Markets Board. Performance-based payment plans cannot be used for the remuneration of independent board members.
In our company, managers with administrative responsibilities are designated as directors, and their remuneration is calculated using two components: fixed and performance-based.
Purpose
The purpose of the Donation and Aid Policy is to define the principles of donation and aid within the Company, in accordance with the regulations to which the Company is subject and the provisions of its Articles of Association.
The Company complies with the Capital Market Law No. 6362, the Turkish Commercial Code No. 6102, capital market legislation, and other relevant legislation and regulations regarding donations and aid. The Company takes utmost care to implement the principles set forth in the Corporate Governance Principles regulated in the current Corporate Governance Communiqué of the Capital Markets Board ("CMB").
The Company's Donation and Aid Policy has been prepared in accordance with capital market legislation and is announced to all stakeholders, primarily shareholders, through the Company's website and the Public Disclosure Platform (KAP).
Authority and Responsibility
The Donation and Aid Policy has been established by the Board of Directors within the framework of the CMB Corporate Governance Principles and has been submitted to the shareholders for approval as a separate item on the agenda of the Company's general assembly meeting. The monitoring, oversight, development, and necessary updates of the Company's Donation and Aid Policy are under the authority and responsibility of the Board of Directors. Changes to the Donation and Aid Policy will be submitted to the shareholders for approval at the general assembly meeting following the decision of the Board of Directors, and will be published on the Company's website and on the Public Disclosure Platform (KAP).
Principles Regarding the Donation Policy
As stated in Article 3 of the Company's Articles of Association titled "Purpose and Subject"; "The Company may make donations or provide aid in a manner that does not violate the provisions of the Capital Markets Law regarding disguised profit transfers and other relevant legislation, and provided that the necessary special situation disclosures are made and donations made during the year are presented to the shareholders at the general assembly meeting, without disrupting the Company's purpose and subject. The upper limit for the amount of donations or aid to be made is determined by the general assembly. Donations or aid exceeding this limit cannot be made, and donations or aid made are added to the distributable profit base. The Capital Markets Board ("SPK" or "Board") has the authority to set an upper limit on the amount of donations or aid to be made."
In line with its corporate responsibility principles, and in compliance with capital market legislation and company policies and practices, the Company may make donations and contributions as deemed appropriate by the Board of Directors, provided that these do not disrupt the Company's objectives and purpose. Donations and contributions may be made in cash or in kind to any legal or natural person.
Donations and payments made by the Company within the framework of the above-mentioned Articles of Association are publicly disclosed in accordance with the Capital Markets Board's regulations on public disclosure of special circumstances. Information regarding the total amount of all donations and contributions made during the relevant period, the beneficiaries, and any policy changes will be provided to shareholders as a separate agenda item at the general assembly meeting. It is mandatory to present donations and contributions to the shareholders at the ordinary general assembly meeting.
Regarding donations and contributions, compliance with relevant legislation, primarily the Capital Markets Board's regulations on the prohibition of disguised profit transfers and mandatory corporate governance principles, is ensured.
The Ethical Code of Horoz Logistics Cargo Services and Trade Inc. described in this document applies to all employees, Board Members, Shareholders, Affiliates, Dealers, Suppliers, Agents, Contractors, agents, and all third parties with whom Horoz Logistics Cargo Services and Trade Inc. conducts business.
Employees of Horoz Logistics Cargo Services and Trade Inc. are obligated to comply with the Ethical Code of Horoz Logistics Cargo Services and Trade Inc.
Horoz Logistics Cargo Services and Trade Inc. commits to and expects compliance with the non-discrimination rules defined in the Universal Declaration of Human Rights in all its operations, processes, and working hours in its employment relationships.
Horoz Logistics Cargo Services and Trade Inc. Communicating the Company's Code of Ethics to all employees, ensuring that employees give due importance to these rules, and demonstrating the necessary effort and leadership in complying with these rules are among the primary duties and responsibilities of middle and senior management working in the company and its subsidiaries.
Our Code of Ethics Policy is published on our company's website and on the QDMS digital platform.
Furthermore, our company's "Anti-Bribery and Corruption Policy," created to identify, reduce, and manage the risks of bribery and corruption in compliance with legal regulations, ethical and professional principles, and universal rules, is an integral part of these Company Codes of Ethics, and employees and business partners are obliged to comply with this policy.
1. EMPLOYEE PRINCIPLES
Horoz Lojistik Kargo Hizmetleri ve Tic. A.Ş;
Values its employees and respects their rights.
Uses suitability for the job as the sole criterion in recruitment and employment and provides equal opportunity without discrimination. Horoz Lojistik Kargo Hizmetleri ve Tic. A.Ş. aims to attract the most qualified young people and experienced professionals. It aims to maximize the benefits of its employees' talents, strengths, and creativity. It provides equal opportunities for employee training, guidance, and development. It rewards success with fair and competitive wage policies and effective and objective performance evaluation systems and practices. It aims to increase employee loyalty by providing equal opportunities for promotion and reward. It ensures the continuity of workplace peace. It provides employees with clean, healthy, and safe working conditions. It creates and maintains a transparent and mutually respectful work environment where cooperation and solidarity are the most important elements. It does not tolerate harassment in the workplace. It evaluates and responds to employees' opinions and suggestions and takes measures to increase motivation. It does not share private information about employees with third parties without the employee's permission and knowledge, except in cases of legal obligation. It respects human rights, constitutional rights to organize, and collective bargaining. Not employing child labor and not accepting its employment.
2. EXTERNAL RELATIONS
The fundamental principles guiding the relationships of Horoz Lojistik Kargo Hizmetleri ve Tic. A. Ş. are listed below.
2.1. COMMUNICATION WITH OUR BUSINESS PARTNERS
To represent all brands owned by Horoz Lojistik Kargo Hizmetleri ve Tic. A. Ş. positively in the eyes of the public and to enhance its reputation,
To keep communication channels open with our business partners and benefit from their criticisms and suggestions, and to ensure the continuation of positive relationships,
To avoid expressing personal opinions when sharing views with the public.
2.2. SHAREHOLDER RELATIONS
To protect the legally defined rights and interests of its shareholders,
To make the utmost effort to create value in return for the resources provided by its shareholders,
To ensure that information regarding the company is disclosed fully, timely and accurately to its shareholders and the public,
To ensure that the company is managed within the framework of trust and honesty principles, and to manage company resources, assets and working time with a sense of efficiency, aiming for sustainable growth and profitability.
**2.3. COMPLIANCE WITH LAWS AND LEGAL PROCEDURES
To act in accordance with the laws and international agreements to which the Republic of Turkey is a party in all matters within its field of activity,
To manage, record, and report all business activities and accounting systems fully and appropriately in accordance with the law,
To ensure that contracts with other individuals and organizations are in compliance with laws and ethical rules, clear and understandable,
To ensure that employees whose authorization is defined in the Signature Circular or relevant special authorization document act in accordance with the specified principles and limitations.
2.4. SOCIAL RESPONSIBILITY
To support activities that will contribute to economic and social development,
To show sensitivity to issues concerning society and to support the positive development of society,
To encourage employees to volunteer for appropriate social activities in which they can participate with a sense of social responsibility.
2.5. CUSTOMER RELATIONS
Creating value for customers, meeting their demands and requirements at the highest level,
Providing quality products and services and following stable policies,
Establishing a long-term environment of trust in customer relationships,
Avoiding misleading and incomplete information for customers
2.6. SUPPLIER AND DEALER RELATIONSHIPS
Creating mutual value in business relationships with suppliers and dealers,
Conducting communication with suppliers and dealers in an open, direct and accurate manner,
Making decisions based on objective criteria in supplier and dealer selection,
Complying with reasonable confidentiality and business security rules requested by the supplier or dealer in supplier and dealer relationships
**2.7. COMPETITION
Not to enter into any agreements or concerted conduct with competitors or other individuals or entities, directly or indirectly, that aims to prevent, distort, or restrict competition, or that has or may have such an effect, except for exceptions recognized within the framework of relevant laws and regulations.
Not to abuse the dominance it holds, alone or together with other undertakings, in a particular market.
Not to engage in discussions or exchange information with competitors aimed at jointly determining market and/or competition conditions.
2.8. CORPORATE INFORMATION
To make statements or announcements regarding public disclosure in accordance with the law through legal representatives, in compliance with the law and regulations.
To ensure that news-related or promotional statements are made only by designated company and firm representatives.
2.9. QUALITY
To aim for excellence in processes for customer satisfaction and world-class production/service,
To support the participation of our business partners in the quality culture, their competence and creativity in this regard,
To continuously improve the quality level of products and services to reach the most competitive level,
To update the quality management system according to developing technology and customer expectations and to provide customer-oriented answers,
To ensure the continuous effectiveness of processes and increased efficiency in order to achieve quality and cost targets.
2.10. ENVIRONMENT
To aim to provide services by choosing methods that have low natural resource consumption, use more recycled materials, produce less waste, and have low emission and noise levels,
To develop methods to prevent pollution at the source by perceiving all waste disposal processes as a loss of natural resources,
To fulfill all legal requirements and other environmental protection obligations related to the environment in its processes,
To increase environmental awareness by training its employees and business partners, and to minimize the need for natural resources, energy losses and waste.
3. ETHICAL CONDUCT RULES THAT EMPLOYEES MUST FOLLOW
Horoz Logistics Cargo Services and Trade The following are the expectations of the company's employees:
Always comply with the law,
Performing their duties within the framework of fundamental moral and human values,
Acting fairly, in good faith, and with understanding in all relationships with the aim of achieving mutual benefit, not obtaining unfair gain from individuals or organizations for any purpose whatsoever, not accepting or giving bribes or facilitating payments,
Acting in accordance with the relevant Code of Ethics and all supporting principles of practice in the duties performed, avoiding behaviors that would damage the company's reputation in both professional and private life,
Not engaging in any behavior, statement, or correspondence that would obligate the company unless explicitly authorized,
Not engaging in behaviors that would disturb and/or harm other employees, not disrupting the harmony of the workplace,
Not using working time and company resources directly or indirectly for personal gain and/or political activity and interest,
Taking ownership of the service provided by the company and standing by its customers even after the service is provided,
Not engaging in activities outside the company that would generate income in areas within their profession or expertise. Taking a position in an institution or organization, or working outside the company, is subject to the approval of the company management.
3.1. AVOIDING CONFLICTS OF INTEREST
A conflict of interest refers to any benefit provided to employees, their relatives, friends, or individuals/organizations with whom they have a relationship, and any material or personal gain related to them, that affects or may affect employees' ability to perform their duties impartially.
3.2. NOT ENGAGING IN TRANSACTIONS FOR ONE'S OWN BENEFIT OR THE BENEFIT OF RELATIVES
Not to obtain unfair advantage for oneself, relatives, or third parties by using title and authority,
To take care not to create a conflict of interest with the company,
To ensure that personal investments or any activities outside of business do not interfere with the performance of current duties in terms of time and attention, and to avoid such situations that prevent focusing on main duties,
To inform the senior manager/Human Resources if the employee and the person in a primary decision-making position in the customer or supplier company regarding the same business are first-degree relatives,
Employees are required to declare any ownership of shares or participation in investments in another company that may be considered a conflict of interest upon their initial employment.
3.3. GIVING AND RECEIVING GIFTS
In conducting relations with private or public individuals and organizations wishing to establish or maintain a business relationship with our company;
Except for promotional materials, not to accept or offer any gift that creates the impression of impropriety, may cause or be perceived as a dependent relationship,
Not to request or offer any discounts or benefits from suppliers, dealers, authorized service centers, customers, group companies or third parties that may be perceived as inappropriate, and not to accept such offers if they are made.
4. OCCUPATIONAL HEALTH AND SAFETY
Horoz Lojistik Kargo Hizmetleri ve Tic. A. Ş. adopts the principle that occupational health and safety improvement activities are the shared responsibility of all employees by fulfilling all legal and other obligations regarding occupational health and safety, and uses a proactive occupational safety approach in all its activities.
The company aims to fully ensure occupational health and safety in the workplace and on the job. Employees act in accordance with the rules and instructions set for this purpose and take the necessary precautions.
Employees shall not bring any items or substances that pose a danger to the workplace and/or workers or that are illegal in the workplace.
Employees; Except for those possessed based on a valid doctor's report, it is forbidden to possess or use drugs, addictive substances, or substances that impair or eliminate mental or physical faculties in the workplace, and it is forbidden to work in the workplace or within the scope of work while under the influence of such substances.
5. PROHIBITION OF POLITICAL ACTIVITY
Horoz Lojistik Kargo Hizmetleri ve Tic. A. Ş. does not make donations to political parties, politicians, or political candidates. Demonstrations, propaganda, and similar activities for political purposes are not permitted within the boundaries of the workplace. Company resources (vehicles, computers, e-mail, etc.) cannot be allocated to political activities.
6. ETHICAL CONDUCT RULES AND APPLICATION PRINCIPLES
**6.1. OBLIGATION TO REPORT VIOLATIONS
Employees are obligated to report any violations of company laws, regulations, or rules to their immediate supervisor (primary manager) or, depending on the situation, to the Ethics/Disciplinary Board via email or in writing.
Disclosure to third parties of any report that negatively impacts workplace harmony or work relationships will be strictly prevented.
The reporting mechanism must serve the company's best interests.
It is crucial that the person making the report is free from any intentions such as spreading gossip or attempting to negatively impact the career of the person being reported. Therefore, confidentiality, objectivity, and adherence to ethical rules are extremely critical in the reporting and investigation process. Both those making the report and those managing the process must give utmost importance and attention to this matter.
Deliberate reports that are false and/or defamatory will be interpreted as a violation of ethical rules.
6.2. DISCIPLINARY PROCEDURES
Disciplinary penalties to be applied following violations of the Code of Ethical Conduct are specified in the Disciplinary Regulations.