About Us

Code of Ethics and Compliance Policies

The Koç Group is committed to being transparent, fair and accountable in its dealings with its stakeholders. In performing its activities, the Group complies with the applicable legislation and its contractual obligations, and acts within the frame of its Code of Ethics. In this context, a comprehensive “Compliance Project” has been carried out with the purpose of responding to the fast-evolving needs of the different sectors and geographies that the Group pursues operations in, as well as to domestic and international stakeholders’ expectations.

Within the scope of the “Compliance Project” carried out under Koç Holding’s leadership between 2018 and 2020, one-on-one interviews were held with the Group employees and senior executives, existing compliance activities were evaluated through questionnaires and workshops, and a risk assessment in relation to the Koç Group was conducted. In the light of these outputs, global good practices were studied upon which related policies were finalized, and a “Compliance Program” was put in place with the approval of the Board of Directors of Koç Holding.
The Koç Group Code of Ethics, which was updated as part of the Compliance Program, is intended to provide guidance and direction to all Koç Group companies, their employees, those who act on behalf of and business partners. While compliance with the Koç Group Code of Ethics is the duty of all Koç Group employees, senior executives of the Koç Group companies are expected to lead the way in this respect.

The Compliance Program is the set of rules, policies and procedures intended to determine and manage compliance matters of the Koç Group with a riskbased approach. The Compliance Program brings together the corporate compliance culture supported by the senior management and monitored by the Legal and Compliance Department with the standards documented across the Koç Group with the involvement of all employees.
The main components of the Koç Group Compliance Program are as follows: prevention, detection and response.

The image below shows the components of the Compliance Program and the composition of these components.

The Koç Group Code of Ethics provides a comprehensive framework for the Koç Group employees and stakeholders on various matters, mainly human rights, anti-bribery and anti-corruption, prevention of conflicts of interest, economic sanctions, protection of privacy and inside information, and occupational health and safety.        
Under the Compliance Program, numerous policies related to compliance have been developed, and approved by the Koç Holding Board of Directors. These policies include, among others, Sanctions and Export Controls, AntiBribery and Corruption, Supply Chain, Human Rights, Personal Data Protection, Donations and Sponsorships. The Koç Group Code of Ethics, Compliance Policy covering the details of the compliance structure, and the supporting policies can be found below.