Our Policies

• Our organization collects and processes personal data in compliance with the laws of Türkiye and European Union Member States, focusing on protecting the fundamental rights and freedoms of individuals, especially the right to privacy.
• All our personal data processing activities are governed by our policy. This includes the processing of personal and sensitive data related to customers, employees, suppliers, business partners, and any other data collected and processed by the organization from any source.
• Our organization takes necessary technical and administrative measures to ensure an appropriate level of security, preventing unlawful processing of personal data, unauthorized access, and ensuring data preservation, while also carrying out or commissioning necessary audits.
• Regarding personal data processing, we operate in accordance with the law and principles of fairness, ensuring data is accurate and up-to-date when necessary, pursuing specific, clear, and legitimate purposes, and processing data in a purpose-related, limited, and proportional manner.
• Our organization retains personal data for the period required by law or necessary for the purpose of processing the data.
• Our organization informs data subjects and provides necessary information if requested by personal data owners.
• Our organization adheres to regulations regarding the processing of special categories of personal data and does not engage in any actions or activities without explicit consent, except where explicitly required by law.
• Our organization conducts actions and activities in compliance with the regulations set forth in the law regarding the transfer of personal data.
• In our organization, we continue our efforts to protect personal data by setting traceable, measurable, and evaluable targets.
• Our organization raises awareness about personal data protection and communicates the relevant obligations to both internal and external parties.
• Our organization conducts training programs to enhance technical and behavioral competencies, aiming to increase awareness of personal data protection.
• Our organization manages personal data violations, evaluates them according to disciplinary procedures, and immediately informs the relevant authorities for crimes and violations that require penalties.
• Our organization continuously monitors the confidentiality, integrity, timeliness, and access authorizations of personal data through process-based asset inventory and risk assessments.
• Our organization is committed to implementing and systematically managing the Personal Data Protection Management System, ensuring continuous improvement and allocating the necessary resources for the system.

Coşkunöz Holding has conducted all its activities to date within the framework of the ethical elements embedded in its culture, values, and principles.

At this point, all of its activities with individuals and organizations, both in Türkiye and abroad—whether with customers, suppliers, partners, employees, or the society in which it operates—are defined as a whole in line with the Code of Ethics management.

For issues that you do not fully understand or are uncertain about, you can seek help and support from your direct manager or the Ethics Committee. You can also call the independent hotline at +90 (212) 371 07 71 or submit a written notification to coskunoz@etikhat.com, which is an independent address.

Additionally, you can report any concerns at www.etikhat.com using the following username and password.

Click here for the Code of Ethics.

Coşkunöz Holding and its subsidiaries

Coşkunöz Holding and its subsidiaries proactively implement and continuously enhance lean and sustainable Environmental, Energy, and Occupational Health and Safety Management Systems in their production and service activities.

In this direction;

• As Coşkunöz Holding, we commit to: Evaluating Occupational Health and Safety regulations on an equal level with other business interests and processes, and providing all necessary resources to ensure consultation on these matters,
• Continuously improving our performance in environmental, energy, occupational health, and safety activities by considering, above all, legal regulations, stakeholder expectations, best practices in the industry, and other relevant requirements,
• Ensuring the dedicated and active participation of stakeholders in determining and implementing processes, goals, and principles, under the leadership of all employees,
• Encouraging employees to adopt a risk-based thinking model to protect their well-being, health, and safety, identifying hazards, and eliminating them through a risk control hierarchy,
• Actively promoting and enhancing sustainability opportunities by improving energy and water efficiency, reducing waste generation, and minimizing harmful pollutant emissions,
• Ensuring efficient waste management, energy, and natural resource usage,
• Recognizing our interaction with the environment and society, identifying the environmental impacts of our activities, periodically reviewing them, and controlling and minimizing deviations under the principle of continuous improvement by providing necessary resources for this purpose,
• Considering energy performance in the design and revision of our processes and purchasing energy-efficient products,
• Following developing technologies to reduce carbon emissions originating from production and services for a sustainable world,
• Identifying and safely managing prohibited/restricted chemicals and other materials that pose a hazard to the environment, Occupational Health, and Safety,
• Conducting activities to raise awareness and sensitivity among our employees, suppliers, and the community to develop a culture of environmental, energy, and occupational health and safety,
• Providing the resources and information necessary to achieve our goals.

Purpose

The purpose of the Information Security Policy is to prevent information security incidents or minimize the risk of damage, ensuring the business continuity of COŞKUNÖZ HOLDİNG and its affiliated group companies, while also reducing the impact of potential threats.

To achieve this, the Information Security Management System has been established, with the goal of complying with the ISO 27001:2013 standard.

Scope

This policy applies to the information assets within Coşkunöz Holding. It is enforced by employees at all locations, as well as by suppliers and contractors, both on-site and off-site.

Liability

The Information Security Management Board is responsible for ensuring that the risks to the company's information assets are maintained at an acceptable level, as approved by senior management, within the scope of the policy.

Policy

The objective of the policy is to protect the company's information assets from both internal and external intentional or unintentional threats.

This policy has been approved by the Coşkunöz Holding General Coordinator.

The Information Security Policy ensures the following requirements:

• The identification of processes and information assets, along with the methodical execution of risk assessments related to them
• Protection of information from unauthorized access
• Ensuring the confidentiality of information
• Safeguarding the integrity of information
• Ensuring access to information whenever needed for business processes
• Fulfillment of legal and contractual obligations
• Development and improvement of business continuity plans
• Providing Information Security training to all employees
• Ensuring that all Information Security violations or suspected violations are reported to and reviewed by the Information Security Management Board

Procedures and associated instructions have been established to support this policy.

Information security is maintained by considering business needs.

The Information Security Management Board is responsible for the development, documentation, and continuous improvement of this policy, as well as all related documents and the Information Management System.

All management staff are responsible for ensuring that the units they oversee comply with this policy and related procedures.

Compliance with the Information Security Policy is mandatory for all employees.

This Cookie Policy (“Policy”)

This Policy applies to the platforms and websites operated by Coşkunöz and accessed or used over the internet.

Cookies

Cookies are small text files placed on devices such as computers, tablets, or phones which help the website function properly, enhance the user experience, optimize the site, provide more relevant and interest-based content and advertising, create a personalized website/application and advertising portfolio for visitors and customers, and generate traffic statistics.

Cookies and Usage

The content of cookies is determined on the server side, and the cookies placed on users' devices when visiting the site can be accessed by the server. Cookies can be seen as the internet user's identity card, signaling that the user has revisited the website.

Cookies are classified into two categories: 'session' cookies and 'persistent' cookies. Session cookies are temporary and are stored only until the user leaves the website; they contain information that is remembered and used by the website as the user navigates between pages. Persistent cookies remain on the user's device even after they leave the website. These cookies help the web server recognize the user when they revisit the website and do not contain personally identifiable information.

Additionally, cookies can be classified based on their functions as analytical third-party cookies, mandatory cookies, or commercial cookies. Coşkunöz uses cookies, which are typically anonymous, to ensure the proper functioning of the website and to enable users to navigate the site and access its features. It also uses analytical cookies, which may contain personal user information due to their nature.

Editing Cookie Settings in the Internet Browser

Although many browsers automatically accept cookies, you are not obligated to accept them. Users can remove cookies through their web browser settings. The location of these settings may vary depending on the web browser you are using. You can find the relevant settings by using the “Help” option in your web browser.

By using the Coşkunöz website, you consent to the use of cookies in accordance with this Policy. If you do not wish to accept our cookie applications on your electronic device, you can reject them. Please note that rejecting cookies may affect the proper functioning of our website or cause disruptions in the services you request.

Third-Party Cookies for Analytical Purposes

To provide better service to our visitors, we measure various metrics, including the number of page views, visits, actions taken by visitors on our site, their geographical location, and the number of returning visitors. We use three web analytics software tools for this purpose:

Google Analytics Information

We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies, which are text files placed on your computer, to analyze users' behavior on the website. The information generated by these cookies about your use of the website is transmitted to Google servers in the USA and stored there.

If IP anonymization is enabled on this website, your IP address will be truncated within the European Union member states or other parties to the Agreement on the European Economic Area. In exceptional cases, the full IP address may be transmitted to a Google server in the USA and then truncated. IP anonymization is active on this website.

Google will use this information on behalf of the website operator to evaluate your use of the website, compile reports on website activity, and provide other services related to website activity and internet usage.

The IP address transmitted by your browser as part of Google Analytics will not be associated with any other data held by Google. You can refuse the use of cookies by selecting the relevant settings in your browser, but please note that this may affect your ability to use all the features of the website. Additionally, you can opt-out of Google Analytics tracking by downloading the Google Analytics Opt-out Browser Add-on to your existing web browser, which will be effective from that point forward: https://tools.google.com/dlpage/gaoptout?hl=en