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NUROL HOLDING INC. CODE OF GOVERNANCEDocument Code : NH-YS-YK-02Publication No : 03Publication Date : 03.03.2025Page No : 16/18to national or international sanctions, embargoes, compliance, financing of terrorism and money laundering. 2. Nurol also respects to, and complies with, to the extent possible under the circumstances, the sanctions and embargoes imposed on other countries by the countries who are the allies of T%u00fcrkiye and with which T%u00fcrkiye has friendly relations. 3. The details and rules regarding this section are set forth in NUROL's Economic Sanctions and Anti-Money Laundering Policy.x) International Export Controls1. NUROL and its employees are committed to comply with the laws and regulations of the Republic of T%u00fcrkiye, as well as the European Union, the United States of America, the United Kingdom and other countries in which it operates, related to international export controls that restrict international trade of goods, technology, information and services.2. The details and rules regarding this section are set forth in NUROL's International Export Controls Policy. y) Charitable Donations1. Corporate donations may lead to the risk of bribery. Charity donations, like bribery, may also appear in various forms (monetary gifts, donations, scholarships, tips etc.). Charity donations may be misused by some ill-intentioned government officials.The most common bribery scenario involving government officials is the provision of business advantages in return for a donation. Charity donations may also be fronted by terrorists and illegal organizations.2. In order to avoid hidden bribery in these donations, the following points should be considered:(a) Never donate if there is a suggestion or perception that NUROL would receive a benefit in return for donation.(b) Ensure that the donation is not prohibited under local laws.(c) Organizations receiving corporate donations must be approved in advance by NUROL Holding%u2019s Board of Directors.(d) Donations should not be made in cash, in hand or paid directly into individuals' bank accounts.(e) Donations must be confirmed in writing and accurately recorded in NUROL accounts.(f) Donations must be publicly disclosed on NUROL's website or in its annual reports to ensure full transparency.(g) Follow-up measures should be taken to ensure that the donation is used for its intended purpose. In this context, NUROL may request the right to audit the contributions made as a result of its charitable donations. Where the donation is made