B&A PARTNERS
ANTI-CORRUPTION AND BRIBERY PREVENTION POLICY
1. Purpose and General Principles
B&A Partners conducts its activities in accordance with the principles of integrity, honesty, transparency, professional independence, responsibility, and compliance with applicable laws and regulations.
All persons cooperating with B&A Partners, regardless of the nature of their professional or contractual relationship, are required to act in accordance with these principles and undertake to comply with this Policy, relevant codes of conduct, good practice principles, and applicable professional rules.
B&A Partners adopts a zero-tolerance policy towards all forms of corruption, bribery, trading in influence, and improper conduct.
No person cooperating with B&A Partners may, directly or indirectly, offer, promise, give, request, or accept money, gifts, advantages, or any other undue benefit for the purpose of obtaining a personal, professional, commercial, or other benefit.
This Policy shall be implemented in accordance with the legislation of the Republic of Türkiye and all other regulations applicable to the activities carried out by B&A Partners.
2. Scope
This Policy applies to all persons cooperating with B&A Partners, regardless of the nature of such cooperation. This includes, but is not limited to:
- employees and interns;
- consultants and external collaborators;
- representatives and intermediaries;
- suppliers and service providers;
- all other persons acting on behalf of, for the account of, or in cooperation with B&A Partners.
All persons who commence or maintain a cooperation relationship with B&A Partners agree to comply with the principles set forth in this Policy and with applicable good practice rules relevant to their duties.
Furthermore, third parties having a professional or commercial relationship with B&A Partners are expected to act in accordance with the fundamental principles set forth in this Policy.
3. Bribery and Corruption
The following conduct is expressly prohibited:
3.1. Bribery of Public Officials
It is prohibited to directly or indirectly offer, promise, authorize, give, or provide any of the following to a public official, public authority, or any person performing a public function:
- money;
- gifts;
- commissions;
- free services or improper discounts;
- personal or commercial advantages;
- travel, accommodation, or invitations;
- any other economic or non-economic benefit.
Likewise, it is prohibited to request, offer, or accept any benefit for the purpose of causing a public official to perform, refrain from performing, expedite, or influence an act connected with their duties.
3.2. Corruption Between Private Parties
Persons cooperating with B&A Partners may not offer, promise, give, request, or accept undue benefits in their relationships with clients, suppliers, business partners, or other private individuals or entities.
In particular, it is prohibited to offer or accept undue benefits for the purpose of:
- acquiring or retaining a client;
- securing the award of a contract;
- obtaining preferential services or privileged treatment;
- improperly influencing a professional or commercial decision;
- obtaining any other undue advantage.
3.3. Facilitation Payments
Payments made to public officials, public authorities, or other persons performing public functions for the purpose of ensuring, expediting, or facilitating the performance of an administrative, legal, or routine procedure are prohibited.
This prohibition applies regardless of the amount of the payment and regardless of whether the payment is referred to as a “tip,” “processing fee,” “expense,” “expediting fee,” or under any other name.
3.4. Trading in Influence
It is prohibited for B&A Partners to use an existing or purported personal, professional, family, commercial, or other relationship with a public official, public authority, or third party for the purpose of obtaining an improper decision, action, or advantage for a client, a cooperating person, or any third party.
4. Third Parties and Intermediaries
Any transaction that is prohibited from being carried out directly under this Policy is also prohibited from being carried out indirectly through third parties, intermediaries, consultants, representatives, suppliers, or other cooperating persons.
Where a person acts on behalf of or for the account of B&A Partners, reasonable measures shall be taken to ensure that such person acts with integrity and in compliance with applicable laws, this Policy, and relevant good practice rules.
Any request for a payment, commission, advantage, or benefit that may raise doubts as to its legality, legitimacy, or purpose must be reported to B&A Partners management before the transaction is carried out.
5. Gifts, Invitations and Hospitality
Gifts, meals, invitations, events, travel, and other forms of hospitality must be reasonable and proportionate and must be connected to a legitimate professional or commercial purpose.
Under no circumstances may they be used to improperly influence a decision or create the impression that there is an obligation, commitment, or expectation of reciprocity.
Gifts and hospitality:
- must be based on a legitimate professional or commercial purpose;
- must be reasonable and proportionate under the circumstances;
- must be provided transparently;
- must not be connected with an expectation of obtaining an undue benefit;
- must comply with applicable laws and professional rules.
Giving or accepting cash or cash equivalents as gifts or hospitality is prohibited.
Where public officials, public authorities, or other persons performing public functions are involved, all applicable legal, ethical, and transparency rules must also be complied with.
6. Acceptance of Clients and Professional Relationships
B&A Partners may conduct any reasonable due diligence it deems necessary before accepting certain clients, matters, or professional or commercial relationships.
Particular attention should be paid in the following circumstances:
- where the economic or legal purpose of a transaction is unclear;
- where unusual payment arrangements exist;
- where payments are requested to be made through third parties;
- where there are doubts concerning the identity or beneficial owner of the parties to the transaction;
- where unnecessarily complex payment mechanisms are requested;
- where there are reasonable doubts concerning the integrity of the client or third parties involved in the transaction.
Where there are significant doubts concerning the legality, legitimacy, or integrity of a transaction, B&A Partners may request additional information or documentation, reject the relevant matter, or, where necessary, terminate the professional relationship.
7. Payments and Financial Records
All income, expenses, payments, and other transactions related to the activities of B&A Partners must be recorded accurately, completely, and transparently.
The following transactions are prohibited:
- concealing payments;
- maintaining false or incomplete records;
- using false, misleading, or inaccurate documents;
- recording a transaction for a purpose different from its actual purpose;
- creating undisclosed accounts, funds, or records;
- making payments to third parties without a legitimate and properly documented justification.
Payments made to consultants, intermediaries, representatives, suppliers, or other third parties must be based on genuine and legitimate services and must be appropriately documented.
8. Conflicts of Interest
All persons cooperating with B&A Partners are responsible for identifying and reporting any actual, potential, or apparent conflicts of interest that may arise between their personal interests and those of B&A Partners, its clients, or related third parties.
Personal, economic, family, professional, or commercial interests may not improperly influence decisions made in connection with activities conducted with B&A Partners.
Where a potential conflict of interest exists, it must be reported to B&A Partners management, and the necessary measures must be taken in accordance with applicable laws, professional rules, and good practice principles.
9. Reporting Potential Violations
Any cooperating person or third party who becomes aware of, or has reasonable grounds to suspect, conduct contrary to this Policy must report the matter to B&A Partners management as soon as reasonably practicable.
Reports made in good faith shall be handled confidentially to the extent legally possible.
B&A Partners does not tolerate retaliation against any person who, in good faith, reports a potential violation of this Policy or assists in the review or investigation of potential misconduct.
10. Actions to Be Taken in Response to Suspicious Requests
If any person cooperating with B&A Partners receives a request to:
- make a payment to a public official or public authority;
- make an unofficial payment to expedite a transaction;
- provide a personal benefit to a public official, public authority, or third party;
- conceal the true nature, recipient, or purpose of a payment;
- carry out a transaction without the necessary documentation;
- use a third party as an intermediary to carry out any of the above transactions;
such request must be rejected and the matter must immediately be reported to B&A Partners management.
Where there is any doubt as to the legality or propriety of a transaction, the transaction must not be carried out until the matter has been appropriately assessed.
11. Violations and Applicable Measures
A violation of this Policy may, depending on its nature and severity, result in the implementation of necessary measures, including termination of the relevant professional, contractual, or cooperation relationship.
This shall be without prejudice to any civil, administrative, or criminal liability that may arise under applicable laws.
B&A Partners reserves the right to report the matter to the competent authorities where legally required or appropriate, taking into account the circumstances of the case.
12. Information, Training and Compliance
B&A Partners may provide information, instructions, or training to persons with whom it cooperates and relevant third parties in order to ensure awareness and proper implementation of this Policy.
All persons cooperating with B&A Partners are responsible for knowing the obligations applicable to them and for acting at all times in accordance with:
- applicable laws and regulations;
- this Policy;
- applicable codes of conduct and good practice principles;
- the principles of integrity, transparency, and professional conduct adopted by B&A Partners.
This Policy may be periodically reviewed and updated in response to changes in legislation, regulatory frameworks, professional rules, or the activities of B&A Partners.
13. Effective Date and Acceptance
This Anti-Corruption and Bribery Prevention Policy enters into force on the date it is approved by B&A Partners.
This Policy applies to all persons cooperating with B&A Partners, regardless of the legal, professional, or contractual nature of the cooperation.
Commencing or continuing any cooperation relationship with B&A Partners constitutes an undertaking to be aware of, observe, and comply with this Policy and applicable codes of conduct and good practice principles.
Every person cooperating with B&A Partners is responsible for acting honestly, transparently, and in compliance with applicable laws and for refraining from conduct that may constitute or create the appearance of corruption, bribery, trading in influence, or any other improper practice.