Our Policies

Türkiye's first transit container port, Asyaport Liman A.Ş. Contributing to the country's economy with its continuous growth and investments as a logistics center; It is Turkey's gateway to the World, which takes care of the environment and people in every period of its main business, and thinks of expansion as well as today. In this direction;

• To meet the requirements of customers and all interested parties and to provide customer visits,

• To provide human, information, technology and financial resources for the effective use of Integrated Management Systems,

• To fully comply with all legal and other eligibility requirements in our activities,

• Achieving measurable targets related to Environmental Quality, Occupational Health and Safety, Energy Management Systems and the continuous results of our management systems by making good use of port industry and transportation practices,

• To reduce the Occupational Health and Safety risks to an acceptable level,

• To create a safe working environment by considering the Occupational Health and Safety hazards and risks,

• To take measures to reduce our wastes and to ensure that they are recovered through recycling,

• To reduce greenhouse gas emissions,

• Focusing on people and assignment by targeting our environment,

• Efficient use of raw materials, energy and natural resources,

• To ensure the protection of ecosystems, sea creatures and all biodiversity,

• To be prepared at the maximum level in order to minimize an accident or incident that may occur in the port,

• To ensure that our employees and employees benefit and contribute,

• To ensure that our employees have certificates from the degrees brought by their duties,

• Developing projects to minimize the load in the protective port area,

• It is in cooperation with other ports around the world by using a common automation system,

• To contribute to sustainable production by following the technology and choosing equipment, systems and services with high energy costs,

• Publishing annual reports, promoting good interpretation environments of port developments,

• To raise awareness of our employees, subcontractors and consumption through trainings, to create efficient and to develop consumers in a positive way,

• To keep the Integrated Management System Policy up-to-date according to the Quality, Occupational Health and Safety, Environmental and Energy Management Systems audit results and result requirements,

• It undertakes to announce this committed and implemented policy to all our employees and to make it accessible to the public and third parties.

ASYAPORT defines and carries out the Human Resources Policy in accordance with the law, the legislation, the social, cultural and economic conditions of our country and respect for human rights. ASYAPORT prepares the health and safety of its employees and gives training to all employees for quality, job security and environmental awareness. It creates an equal opportunity environment among all its employees in the process of recruitment, promotion and compensation. It does not discriminate on the basis of fair behaviors, language, race, color, sex, religion, sect, political thought, age, physical disability and the like. ASYAPORT directs the applications to be done by taking opinions from employees through questionnaires, proposal-request boxes and similar ways. ASYAPORT adopted the seven internationally recognized principles of Social Responsibility and published its Social Responsibility Policy. ASYAPORT respects human rights, constitutional organizations and collective aggreement rights.

Recruitment Practices;
The principle of equal opportunity for people with equal conditions on recruitment has been adopted and in practice the criteria set out in writing for each title are complied with; T. C. to be a citizen, to be 18 years old, to fulfill military service in men, not to be deprived of public rights, not to have a criminal record, to be in compliance with the position of health status, to have professional qualification certificates according to the nature of the job and to be successful in the exam and / or interview.

Job application;
For open positions, business applications are announced on our corporate website and in various career sites, and are collected by hand or by gathering them in the job application pool through our corporate website. Acceptance of applications to be realized in our company, work flows towards employment are carried out within Human Resources.

Job security;
Employees who are more than 6 months old in the framework of ILO Convention No. 158 and Labor Law No. 4857 benefit from the provisions of job security.

Wage Policy;
The wages of our employees are adjusted by the annual rate of increase determined by the conditions of the day. In addition to wages, social assistance such as provision of a shuttle service and lunch is also available.

Education;
Training plans are made in order to identify, implement and evaluate the results for the benefit of the company in order to provide the knowledge, skills, attitudes and behaviors necessary for the improvement of the duty satisfaction and to be more successful in the business environment. Trainings for vocational and personal development are implemented as in-house or out-of-school trainings and these training programs are benefited from domestic and international sources. The main purpose of our training activities is for our employees to improve their work competencies in the preparation of orientation training programs and annual training programs given at the start of work and to prepare them for future tasks. Trainings are often planned, implemented, and implemented to meet today's needs so as not to diminish the resources of future generations, to create sustainable insight in employees, to create value in the long run, to promote awareness of their environmental and socio-economic dimensions in their goals, to prevent occupational accidents, and to improve health- security-environment the results are measured.

Work Ethics;
We work with integrity and honesty, in our relationships with employees, customers, suppliers, shareholders and all stakeholders. Special attention is paid to protect the private information of employees, customers and suppliers, and this information is not allowed to be shared with third parties. Relations with official institutions are always transparent and clear. All kinds of documents and information demanded by official institutions are provided in a correct, complete and timely manner. Asyaport employees act in accordance with the principles of legality, justice, equality and honesty in all of their actions and transactions, cannot treat discriminatorily and practice against the principle of equality, they cannot act in a manner that targets the benefit or harm of any person or group. They have personal responsibility in the conflict of interest, they are careful about any potential or actual conflict of interest. They take the necessary steps to avoid conflict of interest, inform their superiors as soon as they become aware of the conflict of interest and keep themselves away from personal benefits and favors. The main principle is that all employees don’t receive gifts, no gifts are given to Asyaport employees, and they don’t use their professional titles for personal benefits. No gift is requested or implied from customers, subcontractors and contractors. All employees avoid wasting any of Asyaport goods and resources, and acts effectively, efficiently and sparingly while using the office hours, resources, labor, and facilities. They cannot make statements, commitments, promises or attempts out of of their responsibilities or perform deceptive or untrue statements when performing their duties. They cannot keep their personal interests ahead of company interests. Violations of the law on harassment and violence are in no way acceptable. In this context, Code of Conduct training is given and employees are expected to believe in these rules and to adapt to the culture. Follow-up to the rules is monitored and if contradictions are identified, the Disciplinary Regulation is applied.

Sustainable development for ASYAPORT has three dimensions: economic, social and environmental. These dimensions are taken into consideration by ASYAPORT, which adopts to act responsibly with the value it gives to people and the environment, and is seen as a way of bringing together the broad expectations of the society. While we carry out our activities as ASYAPORT, we take our social and environmental responsibilities towards collecting; we are committed to cooperating with our shareholders, employees, the public, non-governmental organizations and other stakeholders in a harmonious manner.

ASYAPORT conducts its business activities and operations within the basic principles of "accountability, transparency, ethical behavior, respect for stakeholder interests, respect for legal rules, respect for international norms of behavior, respect for human rights". It is committed to being an organization that responds to all its stakeholders by declaring continuous improvement through its Integrated Management System Policy.

Our Responsibilities to Our Employees:
The work is as determined by age laws and child labor is not allowed or supported. We will continue our activities within the framework of human rights and global principles, and fully fulfill the personal rights of all our employees. The wage policy is evaluated according to the knowledge and skills of our employees and there is no payment under the minimum wage. We do not employ our employees under any pressure. All of our employees are employed under equal conditions in their positions with their own pace. To create a safe and healthy working environment, we maintain all our activities under the Occupational Health and Safety policy. Supports teamwork and collaboration; we are encouraged to be hard-working, disciplined, rigorous and patient. In all the activities we have undertaken within the institution and institutionally; we do not accept discrimination by reason of honesty and fairness, language, race, color, sex, religion, sect, political thought, age, physical disability and so on. Management listens to all employees' requests and complaints. The employees report their requests and complaints to the management and the solutions of these issues are analyzed and finalized by the management.

Our Responsibilities to Nature and the Environment:
We perform the Environmental Requirements of all our activities at the highest level within the scope of our Environmental Policy. We are guided by our work on environmental issues with a sensitivity awareness above legal obligations. In our Service and Process designs, we consider Reducing Environmental Impact, Protection of Energy and Natural Resources as one of our most important tasks for our priority and sustainable world in all our activities.

To Our shareholders our responsibilities:
ASYAPORT takes its decisions based on known economic criteria in the direction of its goal of creating value for its shareholders, giving priority to the continuity of ASYAPORT and ensures that resources and assets are managed in the most efficient way with an understanding of fiscal discipline and accountability.

Our Responsibilities to Our Customers:
We have an understanding that is focused on customer satisfaction and responds to the needs and demands of our customers as soon as possible and in the right way. We offer our services on time and on the terms we promise; we are approaching our customers with respect, equality and courtesy.

Our Legal Responsibility:
ASYAPORT complies with national and international legislation and regulations and applies in all its activities.

Our Responsibility Towards Society:
For the solution of the problems that humanity faces ASYAPORT education, science, health, environmental protection projects, social relations, and provides support to sport. ASYAPORT as a social responsibility management system and social responsibility results of the audit we will undertake to update our policy periodically in the future to changing circumstances.

TABLE OF CONTENTS

I. PREAMBLE

II. OBJECTIVE

III. PRINCIPLES FOR PROCESSING OF PERSONAL DATA

1. Performing personal data processing in compliance with the Law and the Rule of Integrity

2. Ensuring that personal data are correct and updated when needed

3. Processing for specific, clear and legitimate purposes

4. Ensuring that personal data are related, limited and proportionate to the purposes for which they are processed

5. Ensuring that personal data are kept for the time period provided for in the relevant legislation or for the purposes for which they are processed

6. Ensuring that personal data processing is carried out in compliance with all the Basic Principles of Article 4 of the Law based on one or more than one of the Personal Data Processing Requirements as specified in Article 5 of the Law

7. Personal data transfer requirements

IV. REQUIREMENTS FOR PROCESSING OF PERSONAL DATA

1. Identification and processing of personal data

2. Processing of special personal data

3. Transfer of personal data

4. Personal data processing activities in building entrances and network and website users

5. Deletion, disposal, anonymization of personal data

V. OBLIGATIONS OF ASYAPORT LİMAN A.Ş.

1. Obligation to disclose to personal data owner

2. Obligation to respond to applications of personal data owners

3. Obligation to ensure security of personal data

3.1. Taking technical and administrative measures to ensure that data processing is in compliance with the law

3.2. Taking technical and administrative measures to prevent unlawful access to personal data

3.3. Auditing of measures taken on the protection of personal data

3.4. Measures to be taken in case of unauthorized disclosure of personal data

4. Obligation to register with the Data Controllers Registry

VI. ORGANIZATIONAL STRUCTURE WITHIN ASYAPORT LİMAN A.Ş.

ANNEX-1 DEFINITIONS

I. PREAMBLE

With this Policy, the principles adopted and rules to be followed by ASYAPORT LİMAN A.Ş. on the collection, processing, transferring, updating and disposing of personal data within the framework of the Law No. 6698 on the Protection of Personal Data (LPPD) and the relevant international and national legislation has been determined.

II. OBJECTIVE

This Policy is intended to make disclosures about systems adopted by ASYAPORT LİMAN A.Ş. for personal data processing activity and personal data protection and in this context, to inform, in particular, our business partners, current and candidate employees, current and potential customers, company shareholders, visitors and third-parties and people whose personal data are processed by our company and thus, to achieve transparency.

III. PRINCIPLES FOR PROCESSING OF PERSONAL DATA

ASYAPORT LİMAN A.Ş. shall process personal data in accordance with the general principles and provisions provided for in the legislation in order to ensure compliance with the LPPD. In this context, ASYAPORT LİMAN A.Ş. shall act in compliance with the following principles when processing personal data in accordance with the international and national legislation related to the LPPD.

1. Performing personal data processing in compliance with the Law and the Rule of Integrity

ASYAPORT LİMAN A.Ş. shall be obliged to act in compliance with the law and the rule of integrity within the scope of personal data processing activities. In this context, proportionality requirements shall be taken into consideration and shall not be used for purposes other than processing of personal data.

2. Ensuring that personal data are correct and correct when needed

ASYAPORT LİMAN A.Ş. shall be obliged to ensure that any personal data it processes are correct and up-to-date taking into account the fundamental rights and the legitimate interests of personal data owners and to establish the necessary systems to take the necessary measures in this context.

3. Processing for specific, clear and legitimate purposes

ASYAPORT LİMAN A.Ş. is obliged to determine the purposes for which personal data will be processed and to disclose these purposes to data owners before the personal data are processed. Personal data shall not be processed except for legitimate and lawful purposes specified.

4. Being related, limited and proportionate to the purposes of processing

ASYAPORT LİMAN A.Ş. shall process personal data in a manner appropriate to achieve the purposes specified and shall refrain from the processing of personal data that is not related to or necessary for achieving the said purposes.

5. Ensuring that personal data are kept for the time period provided for in the relevant legislation or for the purposes for which they are processed

ASYAPORT LİMAN A.Ş. shall keep personal data only for such a time period provided for in the relevant legislation and laws or as required by the purpose of personal data processing in accordance with Article 138 of the Turkish Penal Code and Articles 4 and 7 of the LPPD. ASYAPORT LİMAN A.Ş. shall first determine whether any time period is provided for in the relevant legislation for retaining of personal data and shall observe the time period if it is provided for in the relevant legislation and if no such time period provided, shall keep personal data for a time period necessary for the purposes for which they are processed. If the said time period expires or reasons for processing of personal data disappear, personal data shall be deleted, disposed or anonymized by ASYAPORT LİMAN A.Ş.

As a rule, personal data shall be processed in accordance with one or more than one of the requirements specified in Article 5 of the LPPD, ASYAPORT LİMAN A.Ş. shall determine whether personal data processing activities carried out by the Company's business units are carried out based on one or more than one of these requirements, and personal data processing activities that do not meet one or more than one of these requirements shall not be included in the processes. In addition to ensuring that personal data processing activities are carried out based on one or more than one of the personal data processing requirements, all personal data processing activities shall be carried out in compliance with the principles specified in Article 4 of the LPPD and in Section III of the Policy and shall incorporate the said principles. Personal data processing activities shall be performed by observing the special provisions provided for in the LPPD on the processing and transfer to third-parties and abroad of special personal data, and personal data processing activities shall be carried out by fulfilling the special requirements required by the law in such cases in addition to those mentioned above.

IV. REQUIREMENTS FOR PROCESSING OF PERSONAL DATA

1. Identification and processing of personal data

Pursuant to the LPPD, personal data is defined as “any and all information concerning an identified or identifiable real person. The concept of personal data is not only information that defines and identifies persons such as name, surname, place of birth, date of birth, but also all physical, social, cultural, economic and psychological information of the persons.

In addition to identity information of person, any and all information that makes a person defined or identifiable, such as citizenship number, tax number, passport number, social security number, driver's license number, license plate, home address, business address, e-mail address, telephone number, fax number, resume, photograph, video, genetic details, blood group, criminal background and criminal record, are personal data and fall into the scope of the Law on the Protection of Personal Data.

According to this definition, ASYAPORT LİMAN A.Ş. business partners, employees and customers, including third-parties, shall determine whether any information they have collected are covered by the concept of personal data and shall process these data in accordance with the rules specified in the LPPD.

Processing of personal data covers all types of actions carried out on data such as obtaining personal data through means that are fully or partially automated or that are non-automated, subject to being part of any data recording system, recording, storing, maintaining, altering, rearranging, disclosing, transferring, making obtainable, classifying or preventing the use of personal data.

Pursuant to the LPPD, ASYAPORT LİMAN A.Ş. shall process personal data only with the express consents of the persons concerned. However, personal data can be processed without seeking for such express consent in the event of the existence of any of the following.

- If the processing is clearly provided for in the applicable law,

- Any circumstance that is mandatory to protect life or body integrity of any person(s) who is unable to disclose his/her consent due to actual impossibility or whose consent is not considered legally valid or any other person,

- If the processing of personal data of contracting parties is necessary, provided that the processing is directly related to the execution or performance of a contract,

- In circumstances where it is mandatory for the data controller to fulfil his/her legal obligation,

- Making of personal data public by the relevant person,

- If the processing is compulsory in order to establish, exercise or protect a right,

- If the processing is mandatory for the legitimate interests of the data controller, provided that the fundamental rights and freedoms of the person concerned are not damaged.

2. Processing of special personal data

Certain personal data are considered as special data within the scope of the Law, and ASYAPORT LİMAN A.Ş. shall not process such data without the express consent of the person concerned or without the presence of the exceptions set out in paragraph three of Article 6 of the Law. Express consent refers to obtaining a detailed consent from the person whose personal data will be collected after making a disclosure to the said person about the purposes for which the data are collected.

The LPPD considers data on a person's race, ethnic origin, political thought, philosophical belief, religion, sect or other beliefs, costume and attire, membership to any association, foundation or trade union, health, sexual life, criminal conviction and security measures as special data.

When processing personal data, ASYAPORT LİMAN A.Ş. shall also take adequate measures as specified by the Personal Data Protection Board.

3. Transfer of personal data

ASYAPORT LİMAN A.Ş. shall be able to transfer personal data to third-parties with the express consent of the relevant data owner for legitimate personal data processing purposes, provided that ASYAPORT LİMAN A.Ş. takes the necessary security measures. However, ASYAPORT LİMAN A.Ş. shall be able to transfer data which can be processed without express consent and data on health and sexual life to third-parties without express consent, subject to compliance with the limitations provided for in the LPPD.

ASYAPORT LİMAN A.Ş. shall take the necessary administrative and technical measures in order to transfer any data it will transfer without express consent in accordance with the limitations in the LPPD.

ASYAPORT LİMAN A.Ş. shall be able to transfer personal data to countries which have been declared to have adequate protection by the Personal Data Protection Board or if no such protection exists, to countries which the data controllers in Türkiye and in the relevant countries have committed an adequate protection in writing and to which the Personal Data Protection Board has permitted such transfer.

4. Personal data processing activities in building entrances and network and website users

ASYAPORT LİMAN A.Ş. process personal data for the purposes of monitoring through surveillance cameras and follow-up of visitor entrance/exit in the building and facilities of ASYAPORT LİMAN A.Ş. in order to provide security.

The personal data processing activity is carried out by ASYAPORT LİMAN A.Ş. through the use of surveillance cameras and recoding of visitor entrance/exit.

In this context, ASYAPORT LİMAN A.Ş. acts in accordance with the Constitution, the LPPD and other relevant legislation.

Camera records of our visitors are taken through the cameras and surveillance system in the entrances of the buildings, facilities and within the facilities of ASYAPORT LİMAN A.Ş.

Monitoring activities via surveillance cameras carried out by ASYAPORT LİMAN A.Ş. are intended to improve the quality of, and to ensure the reliability of, the service provided, to ensure the safety of ASYAPORT LİMAN A.Ş., its customers and third-parties and to protect the interests of customers relating to the service they receive.

Monitoring activities via surveillance cameras carried out by ASYAPORT LİMAN A.Ş. for security purposes are performed in accordance with the provisions of the LPPD and the Law on Private Security Services and the relevant legislation.

Records recorded and stored in digital media are accessible only by limited number of employees of ASYAPORT LİMAN A.Ş.

ASYAPORT LİMAN A.Ş. takes the necessary administrative and technical measures to ensure the security of personal data obtained as a result of the monitoring activities via surveillance cameras in accordance with Article 12 of the LPPD.

Other than the recording by surveillance cameras specified above, ASYAPORT LİMAN A.Ş. processes personal data for the follow-up of visitor entrance/exit in the buildings and facilities of ASYAPORT LİMAN A.Ş. for security purposes and for the purposes specified in this Policy.

Visitors are provided with access to the Internet for the duration they spend within the buildings and facilities of ASYAPORT LİMAN A.Ş. for security purposes and for the purposes specified in this Policy. In this case, log records related to their access to the Internet are recorded according to the mandatory provisions of the Law No. 5651 and the legislation enacted in accordance with this Law, and these records are processed only if requested by authorized public institutions or organizations or in order to fulfil the relevant legal obligations during auditing processes to be carried out within ASYAPORT LİMAN A.Ş.

Only a limited number of employees have access to the log records obtained.

ASYAPORT LİMAN A.Ş. records any internet activities on web-sites it owns through technical means in order to ensure that persons visiting these web-sites achieve their purposes of visiting the web-sites, to display those customized contents and to engage in online advertising activities.

5. Deletion, disposal, anonymization of personal data

Any personal data shall be deleted, disposed or anonymized upon its own decision of ASYAPORT LİMAN A.Ş. or upon the request of the owner of the personal data if the reasons requiring the processing of the personal data disappear, despite the fact that the same have been processed as provided for in Article 138 of the Turkish Penal Code and Article 7 of the LPPD.

In this context, ASYAPORT LİMAN A.Ş. takes the necessary technical and administrative measures in order to fulfil its obligations related thereto, develops the necessary mechanisms in this regard, trains and appoints the relevant business units to ensure them to comply with these obligations and raises their awareness.

V. OBLIGATIONS OF ASYAPORT LİMAN A.Ş.

1. Obligation to disclose to personal data holder

ASYAPORT LİMAN A.Ş. shall enlighten personal data owners on the following matters during the acquisition of personal data:

- Identity of data controller and data representative, if any;

- Purpose for which personal data will be processed;

- To whom and for what purposes personal data may be transferred;

- Method and legal grounds for collection of personal data;

- Rights of personal data owner under Article 11 of the LPPD;

In accordance with this obligation, ASYAPORT LİMAN A.Ş. publishes the disclosure text it has prepared on its web-sites and designs appropriate processes to enlighten data owners during data collection activities.

2. Obligation to respond to applications of personal data owners

Personal data owners may apply to and request information from ASYAPORT LİMAN A.Ş. in writing using the application form attached herewith or sending their requests to “medloglojistik.gemicilik@hs03.kep.tr” KEP address in accordance with the LPPD or using other methods to be determined by the Personal Data Protection Board.

ASYAPORT LİMAN A.Ş. has established and implements the procedures relating to responding to the applications of personal data owners in accordance with Article 13 of the LPPD for the purposes of evaluating the rights of, and making the required disclosures to, personal data owners and relating to other administrative and technical arrangements.

Personal data owners have the following rights;

- To find out whether your personal data has been processed;

- If your personal data has been processed, to request information related thereto;

- To find out the purpose of processing of your personal data and whether or not your personal data is used properly;

- To know about third-parties to whom your personal data is transferred home or abroad;

- If your personal data has been processed in an incomplete and incorrect manner, to request for correction of them;

- To request for deletion or disposition off of your personal data in accordance with the provisions provided for in the relevant legislation;

- To request that any transactions made on your personal data in accordance with the relevant legislation be notified to third-parties to whom your personal data has been transferred;

- To object to the emergence of any consequences against you through the analysis of your personal data processed exclusively by means of automatic systems;

- If you suffer any loss and/or damage due to the unlawful processing of your personal data, to claim indemnification of losses and/or damages you have suffered.

ASYAPORT LİMAN A.Ş. only processes requests transmitted to it via its registered e-mail addresses in writing or signed with secure electronic signature. If the Personal Data Protection Board determines further application methods, ASYAPORT LİMAN A.Ş. will also accept applications made through such methods.

ASYAPORT LİMAN A.Ş. shall respond to any request as soon as possible and within 30 (thirty) days at the latest, depending on the nature of the request. ASYAPORT LİMAN A.Ş. shall accept the applications and take the necessary actions or reject the applications by providing the grounds of its rejection.

If the application of a personal data owner is rejected, he/she finds the response given unsatisfactory or his/her application is not responded, he/she may file a complaint to the Personal Data Protection Board within 30 (thirty) days from the date of receipt of the answer and in any case, within 60 (sixty) days from the date of the application.

ASYAPORT LİMAN A.Ş. shall respond to personal data owners in a timely and justified manner as stipulated by the Personal Data Protection Board in order to prevent complaints.

3. Obligation to ensure security of personal data

ASYAPORT LİMAN A.Ş. ensures that the necessary technical and administrative measures are taken to achieve the appropriate security level for the purposes of preventing illegal processing of, and illegal access to, and protecting, any personal data it processes.

The Personal Data Protection Board shall be able to implement detailed regulations on data security obligations in the future. Therefore, ASYAPORT LİMAN A.Ş. shall exercise due diligence in order to ensure compliance with the obligations in this scope and achieve the security of personal data.

ASYAPORT LİMAN A.Ş. carries out the necessary audits for the functioning of technical and administrative measures to be taken and establishes the systems for the conduct of the said necessary audits. Results of such audits shall be examined by the authorized units within ASYAPORT LİMAN A.Ş. and the necessary measures shall be taken accordingly.

ASYAPORT LİMAN A.Ş. shall be obliged to notify the personal data owner and the Personal Data Protection Board, if required by the legislation, if the personal data of the personal data owner processed are obtained by others by unlawful means. The necessary mechanisms have been established within ASYAPORT LİMAN A.Ş. in this context.

If any situations posing a security risk is identified by ASYAPORT LİMAN A.Ş., measures to eliminate such risk shall be taken with no delay.

3.1. Taking technical and administrative measures to ensure that data processing is in compliance with the law

All processes related to personal data processing activities carried out by the business units within ASYAPORT LİMAN A.Ş. are analysed and all activities carried out by the business units from the collection to the deletion of personal data are made subject to legal compliance audit.

Personal data processing activities carried out within ASYAPORT LİMAN A.Ş. are audited by technical systems established.

The technical measures taken are reported on a regular basis and any deficiency or illegality is notified to the person concerned upon the discovery thereof and is eliminated.

ASYAPORT LİMAN A.Ş. informs and trains its employees about the personal data protection law and the processing of personal data in compliance with the law.

ASYAPORT LİMAN A.Ş. İncludes in contracts and documents governing the legal relationship between ASYAPORT LİMAN A.Ş. and its business partners, employees and customers, provisions imposing obligations not to process, disclose and use personal data in violation of the provisions in the LPPD.

ASYAPORT LİMAN A.Ş. limits the access to personal data only with the relevant company employee(s) for the purpose of processing.

Actions to ensure that the activities of each business unit are in compliance with the personal data processing requirements set forth in the LPPD are determined specific to each business unit and the activity carried out by that business unit. Implementing rules are determined specific to business units, and the administrative measures are taken, the procedures are established and the training are provided necessary to ensure the audit of these rules and the continuity of the implementation.

3.2 Taking technical and administrative measures to prevent unlawful access to personal data

ASYAPORT LİMAN A.Ş. takes the necessary administrative and technical measures in order to prevent unlawful acquisition of personal data, disclosure of personal data to third-parties and access to and transfer of personal data.

Technical measures according to technological developments are taken and the measures taken are updated and renewed periodically.

ASYAPORT LİMAN A.Ş. designs and implements access- and authorization-related technical processes in accordance with the legal compliance requirements.

The technical measures taken are periodically reported to the person(s) concerned and technological solutions are produced for matters posing security risks.

Related software and systems are installed, including software and hardware incorporating virus protection systems and firewalls.

Employees of ASYAPORT LİMAN A.Ş. are given training on technical measures and knowledgeable personnel are employed for technical issues.

ASYAPORT LİMAN A.Ş. takes a commitment from its employees that they will not disclose any personal data they have obtained to third-parties in breach of the provisions of the LPPD and will not use the same for any purposes other than the purpose of processing. ASYAPORT LİMAN A.Ş. ensures that this commitment remains in force even after the cease of the employment of the employees.

ASYAPORT LİMAN A.Ş. adds articles that will protect personal data to contracts entered into between ASYAPORT LİMAN A.Ş. and persons to whom personal are transferred.

3.3. Auditing of measures taken on the protection of personal data

ASYAPORT LİMAN A.Ş. designs the necessary audits for the functioning of technical and administrative measures to be taken and establishes the systems for the conduct of the said necessary audits. Results of these audits are reported to the relevant department within the scope of the internal functioning of ASYAPORT LİMAN A.Ş. and the necessary activities are carried out to improve the measures taken.

3.4. Measures to be taken in case of unauthorized disclosure of personal data

ASYAPORT LİMAN A.Ş. shall be obliged to notify the personal data owner and the Personal Data Protection Board if the personal data of the personal data owner processed are obtained by others by unlawful means. In this context, the necessary internal structure is established.

4. Obligation to register with the Data Controllers Registry

ASYAPORT LİMAN A.Ş. Will, by submitting the application information and documents, register with the Data Controllers Registry within the time period determined and announced by the Personal Data Protection Board before engaging in any data processing activity. The documents to be submitted are as follows:

- Identity and address details of ASYAPORT LİMAN A.Ş., as the data controller, and its representative, if any;

- Purposes for which personal data will be processed;

- Explanations on group(s) of data subjects and data categories of such data subjects;

- Recipients or recipient groups to which personal data can be transferred;

- Personal data allowed to be transferred to other countries;

- Measures taken for personal data security;

- Maximum time period required for the purpose for which personal data are processed.

VI. ORGANIZATIONAL STRUCTURE WITHIN ASYAPORT LİMAN A.Ş.

The ''Personal Data Protection Committee'' or a person responsible for carrying out the actions determined for compliance by the senior management has been appointed within ASYAPORT LİMAN A.Ş. to manage this policy and other policies associated with or related to this policy.

In this context, the following actions are taken by the Committee or the person to be appointed:

- To determine the basic policies related to the processing and protection of personal data and the actions to be taken in order to ensure compliance with the legislation;

- To submit the basic policies and action steps determined to the senior management for approval, to supervise the implementation and ensure the coordination thereof;

- To decide on how the policies related to the processing and protection of personal data will be implemented and how the audit will be carried out and to make the necessary appointments after obtaining the approval of the senior management;

- To identify risks that may occur in personal data processing activities by ASYAPORT LİMAN A.Ş., to ensure that necessary measures are taken and to submit improvement proposals to the senior management for approval;

- To ensure that employees are given training on the protection of personal data and company policies;

- To resolve on the applications of personal data owners at the highest level;

- To make the necessary arrangements within the company in order to ensure that ASYAPORT LİMAN A.Ş. fulfils its obligations under the LPPD;

- To follow developments on the protection of personal data and to provide recommendations to the senior management about what needs to be done related to such developments;

- To manage relations with the Agency and the Board.

ANNEX-1 DEFINITIONS

Express Consent	Express Consent refers to any consent that is based on informing a person on a specific subject and is disclosed with free will.
Anonymization	Anonymization refers to that a personal data is changed in such a way that it will irreversibly loose its nature of being personal data. For example: Changing personal data in such a manner that it cannot be associated with a real person using masking, aggregation, data corruption and so on techniques.
Candidate Employee	Candidate employee refers to natural persons who have applied to our company for a job in any way or who have opened their resumes and related information for review by our company.
Business Partners	Business partners refer to real persons employed in companies with whom our Company has any business relationships, including the shareholders and officials of such companies, (including, but not limited to suppliers).
Processing of Personal Data	Processing of personal data covers all types of actions carried out on data such as obtaining personal data through means that are fully or partially automated or that are non-automated, subject to being part of any data recording system, recording, storing, maintaining, altering, rearranging, disclosing, transferring, taking over, making obtainable, classifying or preventing the use of personal data.
Personal Data Owner	Personal data owner refers to any real person whose personal data are processed. For example; customers and employees.
Personal Data	Personal data refer to any information relating to an identified or identifiable real person. Therefore, the processing of data of legal persons is not covered by the Law. For example; name-surname, identity number, e-mail, address, date of birth, credit card number, bank account number, etc.
Customer	Customer refers to any real person who uses or has used the products and services offered by our Company, regardless of whether he/she has any contractual relationship with our Company.
Special Personal Data	Special personal data refer to data on ethnic origin, political thought, philosophical belief, religion, sect or other beliefs, costume and attire, membership to any association, foundation or trade union, health, sexual life, criminal conviction and security measures and biometric and genetic data.
Potential Customer	Potential customer refers to any natural person who has requested to use or has been interested in using our products and services or who has been considered to have such interest in accordance with the commercial customs and the rules of integrity.
Company Shareholder	Company shareholder refers to any real person who is a shareholder of our Company.
Company Official	Company official refers to any board member(s) and other authorized real person(s) of our Company.
Third-Party	Third-party refers to any third-party real person(s) (e.g., guarantors, companions, family members and relatives) with whom our Company has relationships with in order to ensure the security of the transaction between our Company and the above-mentioned parties or to protect the rights of those persons and to derive benefits from them.
Data Processor	Data processor refers to any real and legal person who processes personal data based on the power granted by the data controller on behalf of the data controller. For example, the cloud computing company that maintains the data of our Company, the interviewers through whom our Company has the customers sign the forms, the call-centre company that makes calls within the framework of the instructions, etc.
Data Controller	Data controller refers to any person who determines the purposes and means of processing personal data and manages the place where the data are systematically kept (data recording system).
Visitor	Visitor refers to any real person(s) who has entered into the physical sites owned by our Company for various purposes or who has visited our websites

ASYAPORT has adopted as Information Security Policy to protect to information assets it owns, managing these assets in a way to serve company strategies, operating and continuously improving the Information Security Management System that will ensure customer satisfaction.

• Protect to ASYAPORT's information assets against any threat that may occur intentionally or unintentionally from internally or externally, provide accessibility to information through business processes as required,meet the requirements of legal legislation,
• Provide continuity of three basic elements of the Information Security Management System in all activities;

Privacy: Prevent unauthorized access to important information,
Integrity: Display that the accuracy and integrity of the information is ensured,
Accessibility: Display the accessibility of information to the authorized persons when necessary,

• Not only the data that is kept electronically; to take care of the security of all data in written, printed, verbal and similar media.
• Giving Information Security Management educations and trainings to all personnel for increase their awareness
• All weaknesses related with Information Security , report them to the ISMS Board and ensuring that investigated by them,
• Prepare, maintain and test to business continuity plans,
• Doing periodically considering to determine Information Security risks. Review and follow-up the action plans according to result of the consideration
• Prevent any disagreements and disputes that may arise from contracts,
• Accessibility of information and meeting business requirements for information systems.
• To apply the information security management system based on ISO 27001 Information Security Management System Standard,
• To follow up all legal terms and regulations within the scope of the Information Security Management System and to make people comply with them,
• To develop solutions by following up-to-date technologies and innovations about information security,
• To take due precautions to ensure that all shareholders comply with the issues determined regarding information security.

Asyaport Liman A.Ş. give due importance to your personal data as the data responsible defined in the Personal Data Protection Law 6698. We would therefore like to inform you about the processing of your personal data.

PURPOSE OF PROCESSING YOUR PERSONAL DATA AND THE LEGAL REASON

Your personal data is processed in accordance with the Personal Data Protection Law No. 6698 and secondary regulations for the following purposes and legal reasons: The received identity and contact information is processing for the draw up a contract or discontinuance of the contract in order to enable you to become a member of website and benefit from membership services under protection of the Personal Data Protection article 5/2C of Law No. 6698.

TRANSFER OF PERSONAL DATA

Your personal data is recorded for purposes above by Asyaport Liman A.Ş. by this context your personal data may be shared with the Service Provider companies with domestic and / or foreign partners and affiliates (and / or third-party business partners who need to be shared for the performance of the business) in accordance with the law.

GATHERING METHODS OF PERSONAL DATA

Asyaport Liman A.Ş. collects your personal data by subscribing to the website. In addition, your personal data is collecting by Asyaport Liman A.Ş. when you share information by other communication methods.

STORAGE OF PERSONAL DATA

Your personal data will be processed on the basis of the legal reasons in article 5/2-c of Law No. 6698 and will be processed for legal periods and limited time will be kept.

RIGHT OF PERSONAL DATA HOLDER

Appling to Asyaport Liman A.Ş. as personal data holder;

• Find out if your personal data is being processed,
• Request information if your personal data has been processed,
• Learning the purpose of processing your personal data and whether they are used properly,
• Knowing the third parties to whom your personal data is transferred at domestic or abroad,
• If your personal data is missing or incorrectly processed, request that it be corrected and request that any transactions made within this scope be notified to third parties to whom your personal data has been transferred,
• To request the deletion or destruction of your personal data in case the reasons that require processing are eliminated and to notify the third parties to whom the personal data has been transferred,
• Object to the occurrence of a disadvantage by analyzing your processed data exclusively through automated systems,
• To request the deletion or destruction of personal data in accordance with the provisions of Article 7 of the Law, and to notify the third parties to whom the personal data is shared about the correction, deletion or destruction of the data,
• You have the right to claim compensate the damage if you suffer damage due to unlawful processing of your personal data,

If you submit your requests regarding your rights mentioned above to Asyaport Liman A.Ş. in accordance with the application procedures stipulated in the Communique on Application Procedures and Principles to the Data Officer, your request for Asyaport Liman A.Ş. will conclude it free of charge. However, if the transaction requires additional costs, Asyaport Liman A.Ş. will be able to claim the fee in the tariff set by the Personal Data Protection Board.

You may visit the www.asyaport.com website for more information about our Personal Information Protection Policy.

I was informed by Asyaport Liman A.Ş. about the methods, purposes and legal reasons and the rights I have regarding the processing and transfer of my personal data.

PURPOSE

Harassment, sexual harassment and assault is a form of discrimination arising from gender inequality among other reasons and is a common phenomenon in all areas of social life in different forms and levels. In addition, harassment, sexual harassment and assault constitute a crime because it is a violation of rights that can negatively affect victims in many ways. Workplace harassment negatively affects the working lives of people in various forms and levels. In corporate environments dominated by hierarchical relationships, harassment is often rendered invisible due to the difficulties faced by those who have been harassed in expressing it, and both the individual and the corporate environment suffer from this situation. Although it is clear that it is mostly committed as a form of discrimination against women, some people are also affected by harassment due to sexual orientation and gender identity. It is also possible that sexual harassment and assault can also be directed against men and occur between people of the same sex.

The purpose of this policy is to establish principles and promote regulations for the creation of a professional environment free from sexual harassment and assault. With this policy, Asyaport Port CO. INC. informs that it is ready to make efforts to raise awareness about harassment, sexual harassment and sexual assault, to prevent such incidents, and to operate an effective investigation and sanction mechanism in case of such allegations and complaints. Asyaport Port CO. INC. undertakes to inform and support victims about harassment, sexual harassment and assault, to take steps to provide restorative justice depending on the consent of the parties, to effectively handle all allegations and complaints regarding harassment, sexual harassment and assault.

This policy aims to contribute to the creation of a work environment where free of harassment, sexual harassment and assault, and to prevent such incidents. However, the purpose of the document is not to strictly discipline relations between the sexes, to prevent consensual relations, to impose a certain sexual morality, to prevent freedom of expression and free discussion, to include all kinds of personal tensions and discomfort with a sexual content in official processes and to face harsh sanctions. This document mainly aims to raise awareness on the issues of harassment, sexual harassment and assault, prevent behaviour that may be considered as harassment, and support victims. In addition, this document aims to empower victims of sexual harassment to express themselves more clearly and to stop unwanted relations.

SCOPE

Provisions in the policy cover all Asyaport Port CO. INC. and its subcontractors. This regulation applies to all situations where employees are together, without restriction of place and time.

With this policy, it undertakes to evaluate all allegations of harassment, sexual harassment and assault, to take administrative measures in accordance with the relevant legislation in cases where the investigation requires the proper functioning of the investigation and / or the protection of the complainant.; especially

2.1. Unwanted sexual attitudes and approaches that occur between people with an institutional hierarchy and asymmetry of power and that this situation negatively affects the administrative career and employment status of the abused person,

2.2. Unwanted sexual approaches that are used as a means of rewarding or retaliation, revenge, seriously disrupt the work environment because of their frequency or severity.

DESCRIPTIONS
Harassment

Any visual / verbal or physical behaviour that is directed against race, ethnicity, religion, sexual orientation, gender and personal characteristics, humiliating a person or people, using force or not, are within the definition of harassment. The element that determines the harassment is not the intention, but the effect the other person has on them.

Harassment is also included in the definition of harassment when an individual is disturbed in a way that affects his productivity, dignity and honor within the organization. This type of harassment manifests itself with examples such as isolating the person within the organization, not including them in projects, and preventing them from using communication and other personal rights.

Among the abusive behaviors, the most difficult to define is sexual harassment. Sexual harassment is mainly determined by the subjective circumstances of the event. There are many forms of sexual harassment, explicitly or implicitly; Although it is generally seen in subordinate-superior relations or male-female relations, it is also found among individuals in the same position.

Sexual Harassment

Sexual harassment includes non-consensual, sexual speech, attitude, or other forms of behaviour without body contact. Depending on the setting and the "context" of the event, persistent repetitive actions or a single action can be considered as sexual harassment. "Continuity" is not a prerequisite.

Depending on the intensity and nature of sexual harassment, abusive acts; It is divided into three categories: simple harassment, constant harassment, and severe harassment. While not limited to this list, the following examples can constitute the types of sexual harassment mentioned:

1) Simple Harassment: They are acts that do not contain threats, blackmail or insults, but create disturbing and undesirable environments. For example, catcalls, making sexual jokes and compliments or using slang words, using unusually persistent behaviours to flirt, harassing with pornographic material, asking questions about one's sexual life, or producing gossip.

2) Constant Harassment: Occurs if simple harassment is done continuously despite warnings.

3) Severe Harassment: It is the actions that appear with threats, blackmail or insults and similar acts and are aimed at controlling the person's behavior. It may be related to the person's abuse of his professional position, as well as severe cases of harassment among those of equal status. In cases where it is stated explicitly or implied that the person will pay the costs related to his / her business life in cases where he / she does not comply with the sexual content offer, and if he / she does not comply, he / she will gain unworthy earnings.

C. Sexual Assault

Sexual assault is the violation of a person's body immunity by non-consensual sexual behavior. Sexual assault can occur in two forms:

In its first form, sexual assault occurs without intercourse in violation of one's body immunity. Examples of such sexual assault include; According to the characteristics of the situation, hugging, touching, caressing and touching can be counted.

In the second type of sexual assault, the person's body immunity is violated by inserting a sexual organ or other object into the body.

D. Child Sexual Abuse

Sexual assault and sexual harassment against those under the age of 18 are considered “child sexual abuse”.

E. Recompense

Denial of sexual or emotional attempts and offers or wanting to complain about being harassed, implicitly or explicitly, making a person's work life difficult for revenge is also considered a form of harassment.

RESPONSIBLE

All Asyaport Port CO. INC. employees and subcontractors are responsible for the implementation of this policy.

RESTORATIVE JUSTICE

Restorative justice is aimed at fully understanding the needs of the victim, and aims to reach solutions by including the victim and his / her environment and the person alleged to be abusing in the process. These kinds of solutions may be provided by Asyaport Port CO. INC. recommended by the complainant. However, such remedies are foreseen as an in-house solution that does not result in the suspension or interruption of the statute of limitations on disciplinary and criminal investigations or other legal remedies, which is not an alternative to existing application possibilities or a prerequisite for resorting to such remedies. Restorative justice does not necessarily mean mediation or conciliation.

5.1. PRINCIPLES

5.1.1. Privacy Policy

Asyaport Port CO. INC. At all stages of handling allegations of harassment and sexual harassment, the applicant will act in accordance with the principle of confidentiality of the private lives of the person and the person complained of. The principle of confidentiality is also important in terms of resolving sexual harassment allegations and details of the private lives of the people in dispute without moving to the social environment.

5.1.2. Elaborate Principle

Asyaport Port CO. INC. pays attention and care to avoid all kinds of behavior that may cause the victim to be victimized again and that may damage the human dignity of the parties and to prevent such behaviors from occurring in the face of sexual harassment allegations. Especially in the application process regarding sexual harassment and assault allegations, this principle is intended to prevent the victim from being victimized again

5.1.3. Trust Principle

Asyaport Port CO. INC. behave in a way that does not damage the trust of the parties by respecting the principles of confidentiality and care.

5.2. Statement and Disclosure

Sexual harassment is often a phenomenon that takes place between two people and is difficult to prove, which pushes those who are abused to remain silent and thus creates an environment suitable for harassment. The prevention mechanisms introduced with this document will operate on the principle of understanding the nature of the incident with a more holistic reasoning about the nature of the harassment, the context of the incident and the persons, even in the absence of clear evidence. However, since the suspicion that will arise due to insufficient evidence in administrative and judicial investigation processes is interpreted in favor of the defendant, it is important that the abused people be sensitive about collecting and storing various types of materials that can be used as evidence in the investigation, provided that it is in compliance with the law.

Intentional Misrepresentations

Disciplinary sanctions will be imposed in cases where it is clearly understood that the claimant has deliberately lied and made false statements in the process after the applications made to the unit. This policy, Asyaport Port CO. INC. warns against emotional and other personal settlements over allegations of sexual harassment.

5.3. Precautions that can be taken by a person who thinks he / she has been subjected to sexual harassment

5.3.1. Avoiding situations and people that they think may be open to sexual harassment

5.3.2. Explicitly warn the person that the behavior is not welcome, and openly say "no" about unwanted sexual intimacy.

5.3.3. Notifying the person who commits an offensive behavior that they will take formal action if they do not stop

5.3.4. From the first moment, to collect whatever material can be used as evidence in the investigation, to keep a record of the events, to keep the evidence, and to share the incident with close people

5.3.5. Applying to the police for prevention and protection.

5.4. Precautions that can be taken by a person who thinks he / she is exposed to sexual assault

5.4.1. Avoiding situations, places and people that they think may be open to sexual assault

5.4.2. To clearly warn the person that the behavior is not welcome, and if it continues, to inform that official action will be taken if they do not stop

5.4.3. From the first moment, to collect whatever material can be used as evidence in the investigation, to keep a record of the events, to keep the evidence, and to share the incident with close people

5.4.4. Applying to the police for prevention and protection.

5.5. Suggestions for the Person Who Realizes that he / she is Engaging in Disturbing Behavior

5.5.1. To be sensitive about the requests, consent, attitudes and verbal expressions of others and not to proceed without being sure about the consent of the other party in sexual approaches.

5.5.2. Apologizing as soon as you realize that the behavior is offensive, not trivializing or ignoring the inconvenience

5.5.3. To avoid similar behaviors and attitudes that will make the person uncomfortable with his/her behavior

5.5.4. If the person concerned is in a superior position or if there is any kind of hierarchy relationship between them, to transfer the person to another person,

With this Policy, Asyaport Port CO. INC. declares that it is ready to increase its awareness of harassment, sexual harassment and sexual assault and to prevent such incidents within the framework of the purposes, principles and recommendations described above and endeavor to prevent such incidents.

APPLICATION

Asyaport Port CO. INC. personnel who are responsible for receiving complaints and delivering trainings on combating harassment are appointed. The appointment is announced to the staff and, in possible cases, the people they will apply to and their contact information are explained.

Within the scope of combating harassment, all personnel are informed about this policy. At the end of the training, a questionnaire is organized on the subject. The survey results are evaluated by authorized personnel and necessary actions are taken.

After providing training on harassment prevention and policy, a brochure on the subject is distributed to employees. This brochure contains contact information to use in cases of possible harassment. In addition, the Harassment Complaint Forms included in the policy's annex are placed in complaint boxes. In the organized trainings, all contact information is clearly and clearly explained to the staff.

In addition, it is aimed to raise awareness of the personnel on this issue by hanging information posters on the subject of harassment prevention in the work areas.
ANNEXES

ANNEX-1 Harassment Complaint Form

CORPORATE

E-MAIL

PHONE

INFORMATION SOCIETY SERVICES

CORPORATE

Our Policies

ADDRESS

E-MAIL

PHONE

INFORMATION SOCIETY SERVICES