HUMAN RIGHTS POLICY

The purpose of this Human Rights Policy (“Policy”) is to create a guide that reflects Acacia Maden İşletmeleri A.Ş.’s approach and standards on Human Rights and in this way to emphasize the importance Acacia Maden İşletmeleri A.Ş. attaches to Human Rights.

All employees and managers of Acacia Maden İşletmeleri A.Ş. are obliged to act in accordance with this Policy. Acacia Maden İşletmeleri A.Ş. expects all its business partners to act in accordance with this Policy, to the extent applicable to the relevant party and/or business processes and takes the necessary steps to ensure this.

GENERAL PRINCIPLES

As an organization operating on a global scale, Acacia Maden İşletmeleri A.Ş. takes the Universal Declaration of Human Rights as its guide and adopts an understanding that respects Human Rights towards its stakeholders in the societies in which it operates. Creating and maintaining a positive and professional working environment for its employees is the basic principle of Acacia Maden İşletmeleri A.Ş. Acacia Maden İşletmeleri A.Ş. acts in accordance with global ethical principles in matters such as recruitment, promotion, career development, wages, benefits and diversity, and respects the rights of its employees to establish and join non-governmental organizations of their own choises. It has absolutely no tolerance for any kind of forced labor, child labour, discrimination and harassment.

Acacia Maden İşletmeleri A.Ş. takes into account the following international standards and principles regarding Human Rights:

• UN Guiding Principles on Business and Human Rights,
• UN Global Compact,
• ILO Declaration on Fundamental Principles and Rights at Work,
• Principles of Women’s Empowerment,
• Worst Forms of Child Labor Convention,
• OECD Guide to Multinational Enterprises

COMMITMENTS Acacia Maden İşletmeleri A.Ş., by fulfilling the principles of the UN Universal Declaration of Human Rights and the ILO Declaration of Fundamental Principles and Rights at Work, takes care to respect the rights of its employees, shareholders, business partners, customers and all other stakeholders affected by its products or services in relation to its activities.Acacia Maden İşletmeleri A.Ş. treats all employees honestly and fairly and takes responsibility for providing a safe and healthy working environment that respects human dignity by avoiding discrimination. Acacia Maden İşletmeleri A.Ş. is not complicit in human rights violations.Acacia Maden İşletmeleri A.Ş. may also take into account disadvantaged groups who are more likely to be subjected to Human Rights violations and apply additional standards for them. Acacia Maden İşletmeleri A.Ş., as stated in the UN Guiding Principles on Business and Human Rights, provides services to groups whose rights are explained in more detail in United Nations documents (indigenous peoples, women, ethnic, religious and linguistic minorities, children, people with disabilities, migrant workers and their families) under all circumstances. Diversity and Equal Hiring Opportunities Acacia Maden İşletmeleri A.Ş. tries to employ individuals from different cultures, experiences and backgrounds. Recruitment decision-making processes depend on the job requirements, the employee’s personal qualities, performance and experience, regardless of race, religion, nationality, gender, age, marital status and disability.

Prevention of Discrimination A zero-tolerance policy against discrimination is the fundamental principle in all recruitment, promotion, appointment and training processes. Acacia Maden İşletmeleri A.Ş. expects all its employees to act with the same sensitivity in their behavior towards each other.Acacia Maden İşletmeleri A.Ş. takes care to treat its employees equally by offering equal pay for equal work, equal rights and opportunities. Any form of discrimination or disrespect based on race, gender (including pregnancy), color, national origin, religion, age, disability, sexual orientation, family status, sensitive medical condition and political opinion is not tolerated.

Zero-Tolerance for Child Labor and Forced Labor

Acacia Maden İşletmeleri A.Ş. strongly opposes child labor, which causes physical and psychological harm to children and takes away their right to education. Additionally, Acacia Maden İşletmeleri A.Ş. is against all forms of forced labor, defined as work that is involuntary and under threat.

Acacia Maden İşletmeleri A.Ş. implements a zero tolerance policy against slavery and human trafficking in accordance with the conventions and recommendations of the ILO, the Universal Declaration of Human Rights and the UN Global Compact, and expects all its business partners to act in this direction.

Health and Safety Protecting the health and safety of our employees and other people in the Acacia Maden İşletmeleri A.Ş. work area for any reason is one of Acacia Maden İşletmeleri A.Ş.’s most important priorities. Acacia Maden İşletmeleri A.Ş. provides a safe and healthy working environment. Security services are provided, where necessary, in a manner that respects the dignity, privacy and reputation of each person. As committed in its Integrated Management System Policy, Acacia Maden İşletmeleri A.Ş. complies with the relevant legislation and implements the necessary security measures in all work areas.If unsafe conditions or behavior are detected in the work area, Acacia Maden İşletmeleri A.Ş. immediately takes the necessary measures to ensure the health, safety and security of its employees, visitors and all other stakeholders under its control.

Environment Acacia Maden İşletmeleri A.Ş. adopts a precautionary approach to environmental issues, as defined in the 15th Principle of the Rio Declaration on Environment and Development published by the United Nations. As a requirement of this approach, when a serious and irreversible threat occurs to the environment, it prefers taking precautions to treatment, even if this threat is not fully understood or detected scientifically.Acacia Maden İşletmeleri A.Ş. evaluates corporate environmental responsibility as a fundamental issue of the business world, as a requirement of the “Responsible Mining in Harmony with Nature” principle that it has adopted for every stage of its activities. It is aware that all its stakeholders, including customers, investors, governments, employees and NGOs, expect Acacia Maden İşletmeleri A.Ş. to minimize its environmental impacts and, if possible, create positive impacts.Acacia Maden İşletmeleri A.Ş. environmentally friendly technologies in its fields of activity; It supports, uses and disseminates technologies that protect the environment, reduce pollution, use all resources more sustainably, recycle more waste and products and/or manage waste more effectively than resources that can be used instead. Fighting Against Corruption Acacia Maden İşletmeleri A.Ş. not only avoids bribery, extortion and other forms of corruption, but also fights against corruption through anti-corruption policies and concrete programs. For this purpose, it organizes its activities in accordance with the strategies determined in the Anti-Corruption Policy and shares its experiences with its stakeholders.

Zero-Tolerance for Harassment and Violence An important way to protect the personal reputation of employees is to take the necessary precautions to prevent harassment and violence and to apply appropriate sanctions if such an incident occurs. Acacia Maden İşletmeleri A.Ş. is committed to provide a working environment where violence and harassment are not tolerated and where there are no safety-threatening or disturbing conditions. For this reason, Acacia Maden İşletmeleri A.Ş. does not tolerate physical, verbal, sexual or psychological harassment, bullying, abuse or threats of any kind.

Working Hours and Wages

Acacia Maden İşletmeleri A.Ş. complies with local legal working hours in order not to exceed the maximum weekly working hours in the countries where it carries out mining activities. It attaches great importance to employees taking regular breaks, using their leaves, and establishing a productive work-life balance in order to prevent them from getting injured in accidents due to fatigue and distraction.

The wage determination process is determined competitively according to the relevant sectors and the local labor market and in accordance with the provisions of the collective bargaining agreement, if any. All wages, including social benefits, are paid in accordance with applicable laws and regulations.

Acacia Maden İşletmeleri A.Ş.’s employees may contact the Legal Department to obtain additional information regarding the legislation governing working conditions in the countries where they work.

Self-improvement Acacia Maden İşletmeleri A.Ş. offers its employees opportunities to develop their skills and potential. Considering human capital as a valuable resource, Acacia Maden İşletmeleri A.Ş. strives for the comprehensive personal development of its employees by supporting them with internal and external trainings.

Data Privacy Acacia Maden İşletmeleri A.Ş. implements high-level data privacy standards to protect the personal information of its employees and relevant stakeholders. Data privacy standards are applied in accordance with relevant legislation. Acacia Maden İşletmeleri A.Ş. expects its employees and stakeholders to comply with relevant data privacy laws to the highest possible level in every country in which it operates. Political Activities Acacia Maden İşletmeleri A.Ş. respects all legal and voluntary political participation of its employees. However, employees must carry out their political activities outside working hours and  avoid using Acacia Maden İşletmeleri A.Ş. resources for these activities.

AUTHORITIES AND RESPONSIBILITIES

All managers and employees, especially the senior management of Acacia Maden İşletmeleri A.Ş., are responsible for complying with this Policy and implementing and supporting the relevant instructions and controls of Acacia Maden İşletmeleri A.Ş. in line with the requirements of this Policy. Acacia Maden İşletmeleri A.Ş. expects all business partners to comply with this Policy, to the extent applicable to the relevant party and transaction, and takes the necessary steps to achieve this.

Our managers and employees are required to report violations and possible violations of this Policy to their managers and/or through Acacia Maden İşletmeleri A.Ş. complaint channels. In addition, all stakeholders and business partners are expected to act in accordance with the Policy.

With this Policy, Acacia Maden İşletmeleri A.Ş. , in the event of a difference between the local legislation applicable in the countries in which it operates, the more restrictive Policy or legislation will prevail, to the extent that the relevant practice does not contradict the local legislation.

If employees become aware of any action that they believe is contrary to this Policy or the Integrated Management System Policy, they are expected to submit their notifications through the ethics line specified below:

Acacia Maden İşletmeleri A.Ş. Ethics Line➔ Please click to view the ethics line application form.

The OHS and Management Systems Department is responsible for organizing the Human Rights Policy, reviewing it periodically and revising it when necessary, and the Human Resources and Administrative Affairs Department is responsible for the implementation of this Policy.Acacia Maden İşletmeleri A.Ş. employees may consult the Human Resources and Administrative Affairs Department for questions regarding the implementation of this Policy. In case of violation of this Policy by employees, the steps defined in the Disciplinary Directive are followed. If any stakeholder who is expected to act in compliance with this Policy acts contrary to this Policy, the relevant agreements may be terminated.As Acacia Maden İşletmeleri A.Ş. , we believe that it is one of our most important duties to continuously create the value we add to our customers, employees, shareholders and society by creating not only financial but also social and intellectual capital, and we accept it as one of the basic and immutable elements of the management approach. We support every step aimed at development. We always stand by our stakeholders with our legacy from our past, our people-oriented services, our experience, our technology, our competent team, our intellectual, social and financial power.