1. About this policy
It is Bidebunuizle Basın Yayncılık ve Gazetecilik Limited Şirketi (“Bidebunuizle”) and its trademark online newspaper ”Gazete Pencere”’s policy to conduct all of our work in an open, honest and ethical manner. We take a ‘no tolerance’ approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships and in the dissemination of news.
Any Bidebunuizle and Gazete Pencere employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. Any non-employee (such as an intern or contributor) who breaches this policy (or we have reasonable suspicion to believe this is the case) may have their contract terminated with immediate effect. This policy does not form part of any employee’s contract of employment and we may amend it at any time.
2. Who this policy applies to?
This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.
3. How do we define BRIBERY?
Bribery means a financial or other inducement or reward for action which is illegal, unethical, a breach of trust or improper in any way. Bribes can take the form of money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or any other advantage or benefit.
Bribery includes offering, promising, giving, accepting or seeking a bribe.
All forms of bribery are strictly prohibited. If you are unsure about whether a particular act constitutes bribery, raise it with your manager or Operations Director at Bidebunuizle (email@example.com).
Specifically, you must not:
a. give or offer any payment, gift, hospitality or other benefit in the expectation that a business advantage will be received in return, or to reward any business received;
b. accept any offer from a third party that you know or suspect is made with the expectation that we will provide a business advantage for them or anyone else; or
4. Gifts and hospitality
This policy does not prohibit the giving or accepting of reasonable and appropriate hospitality for legitimate purposes such as building relationships, maintaining Bidebunuizle or Gazete Pencere’s image or reputation, or fact gathering for news dissemination in the course of our ordinary business.
A gift or hospitality will not be appropriate if it is unduly lavish or extravagant, or could be seen as an inducement or reward for any preferential treatment (for example, during contractual negotiations or a tender process).
Gifts must be of an appropriate type and value depending on the circumstances and taking account of the reason for the gift. Gifts must not include cash or cash equivalent (such as vouchers), or be given in secret. Gifts must be given in the name of Bidebunuizle or Gazete Pencere – not your own name.
Promotional gifts of low value such as Bidebunuizle free newspaper subscriptions or related merchandise may be given to our existing suppliers and business partners and we can accept equivalent gifts from them.
5. Keeping records
Our employees must declare and keep a written record of all hospitality or gifts given or received. Our employees must also submit all expenses claims relating to hospitality, gifts or payments to third parties in accordance with our expenses policy and record the reason for expenditure.
All accounts, invoices, and other records relating to dealings with third parties including suppliers should be prepared with strict accuracy and completeness. Accounts must not be kept “off-book” to facilitate or conceal improper payments.
6. How to raise a concern
If you are offered a bribe, or are asked to make one, or if you suspect that any bribery, corruption or other breach of this policy has occurred or may occur, you must notify firstname.lastname@example.org, Director of Operations at Bidebunuizle on email@example.com immediately.