MING TEKNOLOJI A.S.

CODE OF CONDUCT AND BUSINESS ETHICS

1. Purpose and Scope

At Ming Teknoloji A.S. (https://www.mingapp.co), while creating technology-driven added value, we are committed to conducting all our business processes with the highest moral, legal, and corporate governance standards.

This document is binding for company founders, full-time employees, independent contractors, outsourced consultants (Certified Public Accountants, External HR, External Consultants, etc.), and all business partners acting on behalf of our company.

2. People-Centric Workplace, Diversity, and Inclusion

Ming Teknoloji places the sanctity and dignity of human life above all commercial goals.

Equal Opportunity and Diversity: We believe that our employees, customers, and business partners have equal rights regardless of race, ethnic origin, religion, language, gender, sexual orientation, age, lifestyle, cultural background, political opinion, or disability. We view diversity as our corporate wealth and guarantee equal opportunity.
Work-Life Balance and Health: The physical and mental health of our employees, the protection of family life, respect for personal time, and psychological safety are our indispensable core values.

3. Unacceptable Behavior and Zero Tolerance

The following behaviors are strictly not tolerated in our work environment and in any area we represent:

Discrimination and Hate Speech: Any alienating, exclusionary, or degrading attitudes based on any grounds.
Mobbing and Intimidation: Any psychological harassment (mobbing) that pressures individuals, disrupts their psychological comfort, and systematically breaks their motivation.
Verbal, Physical, and Sexual Harassment: Unwanted physical contact, sexual innuendos, or threatening behaviors that make the other party uncomfortable.
Illegal Activities: No action considered a crime by national and international legislation can be carried out under the corporate umbrella or using company resources.

4. Professional Communication and Conflict Management

Respectful Communication: A constructive, empathetic, honest, and courtesy-oriented language is used in all written and verbal communications with teammates, customers, suppliers, and ecosystem partners such as SAP. Rude, slang, condescending, or aggressive expressions are unacceptable.
Disagreements and Conflict Resolution: Differences of opinion on technical or operational matters are not turned into personal arguments; they are resolved with mutual understanding, based on data, logic, and shared business goals.

5. Integrity, Anti-Corruption, and Conflict of Interest

Prevention of Bribery and Corruption: Ming Teknoloji strictly prohibits giving, offering, or accepting bribes directly or indirectly to gain an unfair commercial advantage. Inappropriate benefits that would change the course of business cannot be provided to public officials or private sector representatives.
Gift and Entertainment Policy: Employees cannot accept any gifts or hospitality that may influence their independent decisions. With the exception of symbolic promotional items, no gift, discount, or personal hospitality with a monetary value exceeding 50 USD may be accepted; such instances must be reported to the company management immediately.
Personal Interests and Relationships: The personal, financial, or family interests of employees must not conflict with the interests of the company. In cases of first-degree kinship or romantic relationships that may arise between internal employees, there can be no subordinate-superior relationship, performance evaluation, or financial approval authority between the parties. The parties are obliged to transparently report this situation to the management to prevent potential conflicts of interest.

6. Insider Trading

Ming Teknoloji employees and consultants, due to their duties, may have access to non-public, financially or strategically critical confidential information (Material Non-Public Information - MNPI) of business partners, customers, or ecosystem stakeholders (e.g., SAP). The use of such information to gain personal benefit in stock market transactions directly or indirectly through third parties (insider trading) is strictly prohibited and subject to severe legal sanctions.

7. Information Security, Customer Data, and Privacy

Confidentiality and Non-Disclosure (NDA): Every employee and business partner within our company signs a Non-Disclosure Agreement (NDA). Trade secrets, source codes, and operational data belonging to our customers and projects cannot be shared with unauthorized persons.
Data Protection (KVKK and GDPR): Strict compliance with personal data protection laws is essential. Data is processed, stored, and anonymized/destroyed solely for legitimate business purposes.
ISO 27001 Standards: The principles of the ISO 27001 Information Security Management System implemented in our company are strictly followed; IT assets, authorizations, and device security are audited with strict protocols.

8. International Trade and Export Controls

Ming Teknoloji strictly complies with international trade regulations, sanctions, and export control legislation. Our company does not engage in any direct or indirect software, product, license, or consultancy trade with countries, organizations, or individuals that are embargoed or on the sanction lists of the United Nations, European Union, United States (OFAC), or local authorities.

9. Grievance and Reporting Mechanism (Whistleblowing)

Open Communication Channel: Suspicions, testimonies, or complaints regarding the violation of the rules in this document are submitted in writing directly to the etik@mingapp.co address, which is jointly accessed by the company founders (CEO & CTO) and External HR consultancy.
Confidentiality and Non-Retaliation: The identity of employees making a report is protected with absolute confidentiality. No retaliatory actions, such as termination of employment contract, promotion barrier, or mobbing, can be taken against any employee who reports an ethics violation in good faith. Any such retaliation attempt is in itself a severe disciplinary offense.

10. Disciplinary Process and Sanctions

Every reported complaint is promptly investigated by an evaluation group formed with the participation of the CEO, CTO, and, when deemed necessary, External HR and Legal Consultants. In the event of a violation; steps such as verbal/written warning, change of position, termination of the employment or consultancy contract for just cause without compensation, and filing a criminal complaint with the legal authorities are uncompromisingly implemented.