The Legal Obligations topic under the Kordsa Code of Business Ethics governs the principles of compliance management in our company. We realize all our domestic and international operations and transactions in line with national and international law, and provide accurate, complete and clear information to the official bodies and institutions in a timely manner.
In 2013, we established the Compliance Management System, which is reviewed every year and approved by the Board of Directors, in cooperation with the Compliance Division of Sabancı Holding, and started implementation in 2014. Holding Compliance Coordinator is responsible for the coordination of compliance management, whereas all Kordsa employees are responsible for its management.
The objectives and targets of compliance management are based on ensuring that the company operates in compliance with the legislation, international law, and the internal rules governing the holding and the company. The goal of the management system includes identifying the risks associated with compliance; taking necessary measures, monitoring 10 key risk indicators (two of which are optional, and eight are required by law); and managing the risks proactively by way of identified thresholds. Compliance risk types concerning Kordsa are defined as follows; Legislation on Labor and Social Security, Legislation on Environment and OHS, Trade Legislation, Financial Legislation Information Security Policy, Agreements and Other Legal Arrangements. The Kordsa departments that have the main compliance responsibility are Finance, Legal, IT and Safety, Health and Environment.
Our management system we follow is the Sabancı Holding Risk and Compliance Portal for our target of 100% compliance. Our measurement and monitoring mechanisms are the audits of Internal Audit Department and Sabancı Holding.
At the end of every quarter, the Compliance Coordinator shares the key risk indicators and the results as Compliance Management Criteria and Results with ELT members and responsible departments. Additionally, compliance management and practices are among audit items in audits throughout the company conducted by the Internal Audit Department. The Committee evaluates the outcomes of the audit and shares the results with the Board of Directors. Moreover, every year, Sabancı Holding makes a periodical Compliance Management assessment and prepares a report.
Compliance Performance in 2019
At Kordsa Turkey we have not received any monetary or administrative penalties during the reporting period for breach of any laws or regulations, including those on the environment. There was not any case brought to our attention through conflict resolution mechanisms, either.
Our 2019 Practices in Turkey
• Personal Data Protection Act (PDPA) compliance work is completed.
• We provided PDPA online and physical trainings to all employees.
• We conducted USA Export Control regulation compliance training.
• We provided training to employees on compliance to Regulation on Registration, Assessment, Permission and Limitations of Chemicals.
• We conducted routine works and information security awareness trainings for the current ISO 27001 certification.
Our 2019 Practices in USA
• We revised Export Control Compliance Program across our all partnerships including the ones that joined in 2018 and 2019.
• We conducted USA Export Control regulation compliance trainings
• We conducted compliance audits of relative regulations at all sites.