Compliance

1. Commitment to Compliance

Asatoil is committed to conducting business with integrity, transparency and full compliance with all applicable laws and regulations.

2. Legal and Regulatory Framework

2.1 Primary Applicable Laws

Turkish Commercial Code No. 6102
Turkish Code of Obligations No. 6098
Turkish Penal Code No. 5237
Law on Protection of Personal Data No. 6698 (KVKK)
Turkish Customs Law No. 4458
Foreign Trade Law No. 8/9333
Capital Markets Legislation
Tax Procedure Law No. 213
Anti Money Laundering Law No. 5549

2.2 International Regulations

EU Regulations (where applicable)
UN Sanctions and Embargoes
International Maritime Organization (IMO) Regulations
Incoterms® 2020
UCP 600 (Uniform Customs and Practice for Documentary Credits)
Basel Accords (for financial transactions)
OECD Guidelines for Multinational Enterprises

3. Sanctions and Embargoes Compliance

3.1 Prohibited Parties and Transactions

Asatoil strictly complies with all applicable sanctions and embargoes issued by:

United Nations Security Council
European Union
United States Office of Foreign Assets Control (OFAC)
United Kingdom Office of Financial Sanctions Implementation (OFSI)
Turkish Ministry of Trade
Other relevant national and international bodies

3.2 We Do Not Engage In

Transactions with sanctioned countries, entities, or individuals
Trade in embargoed goods or services
Transactions involving prohibited commodities
Dealings with entities owned or controlled by sanctioned parties
Facilitation of sanctions evasion

3.3 Screening Procedures

All counterparties are screened against sanctions lists before contracting
Ongoing monitoring of business relationships
Transaction screening for high risk jurisdictions
Vessel and shipping party due diligence
End user verification

3.4 Restricted Jurisdictions

We maintain enhanced due diligence for transactions involving:

Countries subject to comprehensive sanctions
High risk jurisdictions per FATF (Financial Action Task Force) listings
Countries with strategic AML/CFT deficiencies
Conflict affected and high risk areas

4. Anti Money Laundering (AML) and Counter Terrorist Financing (CTF)

4.1 Commitment

Asatoil maintains a zero tolerance approach to money laundering and terrorist financing.

4.2 Know Your Customer (KYC) Requirements

Before establishing any business relationship, we require:

Certified copies of incorporation documents
Proof of identity for directors and beneficial owners
Business registration and tax documentation
Bank references and financial statements
Source of funds verification
Business purpose and nature of transactions
Organizational structure and ownership charts

4.3 Enhanced Due Diligence (EDD)

Enhanced measures apply for:

Politically Exposed Persons (PEPs)
High risk jurisdictions
Complex or unusually large transactions
Transactions with no apparent economic purpose
Cash transactions or cash equivalents
High value commodity trades

4.4 Beneficial Ownership

We identify and verify the ultimate beneficial owners (UBOs) of all counterparties who:

Own or control 25% or more of shares or voting rights
Exercise control through other means
Benefit from the transaction

4.5 Suspicious Transaction Reporting

Employees must report suspicious activities immediately
Reports are submitted to the Financial Crimes Investigation Board (MASAK)
Tipping off is strictly prohibited
Records are maintained for minimum 10 years

5. Anti Bribery and Anti Corruption

5.1 Zero Tolerance Policy

Asatoil prohibits all forms of bribery, corruption, and improper payments, in line with:

Turkish Penal Code Articles 252 to 254
UK Bribery Act 2010
US Foreign Corrupt Practices Act (FCPA)
OECD Anti Bribery Convention

5.2 Prohibited Conduct

We do not:

Offer, promise, or provide bribes or kickbacks
Make facilitation payments
Provide improper gifts or hospitality
Engage in bid rigging or market manipulation
Conceal or disguise corrupt payments
Use third parties to circumvent anti corruption laws

5.3 Gifts and Hospitality

Must be nominal in value
Must be properly recorded
Must not influence business decisions
Must comply with local laws and recipient's policies
Pre approval required for gifts exceeding USD 100

5.4 Third Party Due Diligence

We conduct due diligence on:

Agents and intermediaries
Consultants and advisors
Joint venture partners
Suppliers and contractors
Logistics providers

5.5 Books and Records

All transactions must be accurately recorded
No off book accounts or slush funds
Supporting documentation must be maintained
False or misleading entries are prohibited

6. Trade Compliance and Export Controls

6.1 Export/Import Licensing

We ensure compliance with all export control and import regulations, including:

Obtaining necessary licenses and permits
Proper classification of commodities
Accurate customs declarations
Compliance with preferential trade agreements
Rules of origin requirements

6.2 Dual Use Goods

For commodities with potential dual use applications:

We verify end use and end users
Obtain end user certificates where required
Screen against military end use/user lists
Comply with export control classifications

6.3 Sanctions on Specific Sectors

We monitor and comply with sectoral sanctions affecting:

Energy sector transactions
Financial services
Defense and security
Technology transfers

6.4 Customs Compliance

Accurate valuation of goods
Proper tariff classification
Country of origin marking
Compliance with free trade agreements
Duty optimization within legal frameworks

7. Environmental, Health, and Safety (EHS)

7.1 Environmental Compliance

Asatoil is committed to environmental protection and compliance with:

Turkish Environmental Law No. 2872
International environmental conventions
MARPOL (Marine Pollution) regulations
REACH (Registration, Evaluation, Authorisation of Chemicals)
Climate change and emissions regulations

7.2 Responsible Trading

We ensure:

Commodities are sourced responsibly
Environmental permits are valid and current
Environmental impact assessments are conducted where required
Spill response and contingency plans are in place
Proper handling, storage, and transportation of hazardous materials

7.3 Health and Safety

Compliance with occupational health and safety laws
Risk assessments for all operations
Training for employees and contractors
Incident reporting and investigation
Continuous improvement in safety performance

7.4 Climate and Sustainability

Monitoring carbon footprint
Supporting transition to cleaner energy
Compliance with carbon pricing mechanisms
Participation in emissions trading schemes where applicable

8. Data Protection and Privacy

8.1 Compliance Framework

We comply with data protection laws including:

Turkish KVKK Law No. 6698
EU GDPR (for EU data subjects)
UK Data Protection Act 2018
Other applicable data protection legislation

8.2 Data Security

Implementation of technical and organizational measures
Encryption of sensitive data
Access controls and authentication
Regular security audits
Breach notification procedures

8.3 Data Subject Rights

We respect and facilitate:

Right to access personal data
Right to rectification and erasure
Right to data portability
Right to object to processing
Right to lodge complaints

Refer to our Privacy Policy for detailed information.

9. Market Conduct and Fair Trading

9.1 Market Integrity

Asatoil is committed to fair and transparent markets:

No market manipulation or price fixing
No insider trading
No abuse of dominant position
Compliance with competition laws

9.2 Accurate Reporting

True and accurate market reporting
No false or misleading information
Compliance with price reporting obligations
Transparent transaction documentation

9.3 Conflicts of Interest

Identification and disclosure of conflicts
No undisclosed conflicts
Recusal from decisions where conflicts exist
Maintenance of Chinese walls where necessary

10. Supply Chain Due Diligence

10.1 Responsible Sourcing

We conduct due diligence on our supply chain to ensure:

No conflict minerals or commodities
No involvement in human rights abuses
No child labor or forced labor
Fair labor practices
Environmental responsibility

10.2 Supplier Standards

Our suppliers must:

Comply with all applicable laws
Adhere to ethical business practices
Maintain adequate quality standards
Provide safe working conditions
Respect human rights

10.3 Audit and Monitoring

Regular supplier assessments
On site audits where appropriate
Corrective action plans for deficiencies
Termination for serious violations

11. Tax Compliance

11.1 Tax Obligations

Asatoil complies with all tax laws and regulations:

Accurate tax reporting and filing
Timely payment of taxes
Proper transfer pricing documentation
Compliance with tax treaties
Cooperation with tax authorities

11.2 Transparency

No aggressive tax planning
No tax evasion or avoidance schemes
Proper documentation of transactions
Disclosure of reportable arrangements

12. Human Rights and Labor Standards

12.1 Commitment

We respect and support internationally recognized human rights:

Universal Declaration of Human Rights
ILO Core Labor Standards
UN Guiding Principles on Business and Human Rights

12.2 Prohibited Practices

We do not tolerate:

Child labor
Forced or compulsory labor
Human trafficking
Discrimination or harassment
Unsafe working conditions
Excessive working hours

12.3 Diversity and Inclusion

Equal opportunity employment
Non discrimination in all dealings
Respect for freedom of association
Collective bargaining rights

13. Whistleblowing and Reporting

13.1 Reporting Mechanisms

Employees and stakeholders may report concerns through:

Direct reporting to management
Compliance hotline
Anonymous reporting channel
Direct contact with Board of Directors

13.2 Protection

No retaliation against good faith reporters
Confidentiality of reports
Investigation of all reports
Disciplinary action for violations

13.3 Investigation

Prompt and thorough investigations
Documentation of findings
Remedial action where necessary
Reporting to authorities when required

14. Training and Awareness

14.1 Employee Training

Mandatory compliance training for all employees
Role specific training for high risk functions
Regular refresher courses
Training on new regulations and policies

14.2 Communication

Regular compliance updates
Policy distribution and acknowledgment
Compliance newsletters and bulletins
Access to compliance resources

15. Monitoring and Auditing

15.1 Compliance Monitoring

Regular risk assessments
Transaction monitoring
Counterparty screening
Ongoing due diligence

15.2 Internal Audits

Periodic compliance audits
Testing of controls
Identification of gaps
Corrective action plans

15.3 External Audits

Independent compliance reviews
Regulatory examinations
Third party assessments
Certification where required

16. Records Retention

16.1 Retention Periods

Trade documentation: 10 years (Turkish Commercial Code)
AML/KYC records: 10 years from end of relationship
Tax records: 10 years
Employment records: As per labor law requirements
Contracts and agreements: 10 years after expiration

16.2 Storage and Security

Secure storage (physical and electronic)
Access controls
Backup and disaster recovery
Proper disposal at end of retention period

17. Enforcement and Disciplinary Action

17.1 Violations

Violations of this Compliance Framework may result in:

Disciplinary action up to and including termination
Civil liability for damages
Criminal prosecution
Regulatory penalties
Reputational damage

17.2 Accountability

All employees are responsible for compliance
Managers are accountable for their teams
Board oversight of compliance program
Regular reporting to senior management

18. Compliance Officer

18.1 Role and Responsibilities

Asatoil maintains a Compliance Officer responsible for:

Implementing and maintaining the compliance program
Providing guidance and advice
Monitoring compliance
Investigating violations
Reporting to the Board of Directors
Liaison with regulators

18.2 Contact Information

Compliance Officer
Email: compliance@asatoil.com
Address: Şişli, Istanbul, Turkey

19. Policy Review and Updates

This Compliance Framework is reviewed regularly and updated to reflect changes in applicable law, regulation and business practice.