QUALITY SYSTEM

Business Sustainability Policy

In order to ensure business sustainability, Altay, commits itself to prevent all kinds of internal or external events and their effects, to comply with international standards, relevant legal regulations, contract requirements, to support business sustainability policies continuously and to provide the needed resources, within the scope of confidentiality, integrity and accessibility of information.

In accordance with this commitment, it is based on the following strategies:

Identifying and managing current and future threats that will hinder business sustainability,

Preparing business sustainability plans,

Managing the risks and developments related to Altay services that may cause reputational loss of the company,

Enabling fast and determined intervention,

Managing internal and external communication regarding business sustainability issues,

Informing and train employees about business sustainability,

Fulfilling the requirements of customers, shareholders, solution partners, suppliers, local and national legislators and employees and to take care of their interests.

Information Security Management Policy

The threat of illegal or unauthorized access to computer systems dramatically increase with new digital age so we know that a well-organized management system for information security system is very important.We are aware of that the maintaining confidentiality of technical information resources are significantly fundamental to for reliability of our company since its establishing.

Our information security policy is to ensure the confidentiality and integrity of information; the protection from and of the unauthorized persons and changes, and to allow availability of information to authorized users.

Anti-Bribery & Anti-Corruption Policy

The aim of the Anti-Bribery and Anti-Corruption Policy of Altay Yazılım Savunma Endüstriyel Sanayi ve Ticaret. A.Ş. (Altay) is to ensure that Altay employees behave in accordance with the legal regulations on the fight against bribery and corruption in force at the relevant date when working in accordance with the Altay ethical principles. As Altay, we adopt a zero-tolerance approach to bribery and corruption.

Anti-bribery and anti-corruption policy covers;

• All the Altay employees, including the Board of Directors,
• The companies and employees from whom we procure goods and services, persons and organizations working on behalf of Altay, including suppliers, consultants, lawyers, external auditors (business partners).

This policy is part of;

• Altay Business Ethics Rules approved and published by the Altay Administration,
• The legal regulations and principles of Altay regarding bribery and corruption in all countries where it operates and is represented,
• The human resources practices.

The implementation and updating of the Anti-Bribery and Anti-Corruption Policy is the authority, duty and responsibility of the Altay Administration. Within this framework;

• Altay Management adopts the principles contained in this policy, provides the necessary environment for its implementation, conducts audits and takes corrective measures to ensure compliance with legal regulations and directive, processes and policies, and provides trainings to Altay employees and managers.
• Altay Management and all its employees, including its senior managers, may not offer, receive and corrupt bribes to any natural/legal person or public institution while performing their duties.
• All employees are obliged to act in accordance with the rules of the fight against bribery and corruption and the Altay Business Ethics Rules.
• The principle in the text of this policy under the administration of senior managers understood by the employees, allows them to be applied and sustained; and to evaluate the effects of identified risks and their possible risks and financial reputation management takes the necessary measures for the implementation and establishment of control mechanisms.

All the Altay employees;

• To comply with the policies determined by the Altay Administration,
• Effectively manage risks related to their field of activity,
• To work in accordance with the relevant legal regulations and Altay processes,
• In case of any behavior, activity or practice contrary to the policy, it is responsible to notify the Altay Administration of this.

Companies and business partners that buy and sell goods and services are required to comply with the Policy principles and other relevant legal regulations, and work with people and organizations that do not comply with them is terminated.

Bribery and Corruption

Altay is against all kinds of bribery and corruption. It is strictly not accepted to take or give a bribe, regardless of its purpose.

The business relationship with third parties who want to do business with Altay through bribery or corruption is not maintained. In case of strong suspicion, the judicial authorities are informed.

Gift

A gift is a product that does not require material payment and is usually given as a thank-you or commercial courtesy by people or customers with whom it is a business relationship.

Any gift offered or given by Altay to third parties must be offered publicly, in good faith and unconditionally. The same principles apply to the acceptance of a gift, and a gift that is not of high material value, other than symbolic gifts contained in these principles, should definitely not be accepted. In addition, even if this is the case, the acceptance of gifts should not be frequent, and the acceptor should notify Human Resources Department about the accepted gifts. If necessary, Senior Management is informed by Human Resources Department.

Facilitation Payments

Facilitation payments are not offered by persons and organizations covered by this Policy to secure or speed up a routine transaction or process (obtaining permits and licenses, providing documents, and the like) with government agencies.

Donations

A meal allowance (1 meal) can be made upon the death of a first-degree relative of an Altay employee, or a wreath donation of the same amounts can be made to the Turkish Education Association.

Other than these, no donations or relief can be made. In case of need, donations can be made by the Decision of the Board of Directors.

Environment Management Policy

Environmental management in Altay is carried out within the framework of the strategies and policies. The principles of Altay’s environmental management policy constitute the framework of international conventions, standards, initiatives and national legislation for environmental management, especially regarding the UN Global Compact and Sustainable Development Goals, as well as the environmental legislation of the countries where we operate.

The main principles of Altay Software Defence Company for the Environmental Management Policy:

Being a pioneer in making environmentally friendly investments

Following all innovations, research and development activities closely

Providing emergency and environmental risk management at the advanced level

Ensuring efficient use of natural resources by using clean technologies for waste minimisation Controling and reduce the environmental impacts that may arise from our activities with scientific and economic solutions

Carrying out activities that support the sustainable development

Compling with national and international legal regulations and other obligations for the protection of the environment

Preventing environmental pollution by following technological developments

Ensuring the sharing and dissemination of practices regarding environmental management within the framework of the principle of continuous improvement

Protecting natural resources and to use them in the most efficient way

Reducing and recycle waste at source as much as possible

Increasing the environmental responsibility awareness of all our employees, from top management to the bottom, by providing environmental training to all our employees