Compliance

Compliance Framework

TURKSIB operates a comprehensive compliance management system that integrates regulatory requirements, industry standards, and ethical principles into all aspects of our operations. Our compliance framework is built on three core pillars:

Key Regulatory Areas

As a global refining corporation, we comply with numerous regulatory requirements across multiple jurisdictions. Our compliance program addresses the following key areas:

Regulatory Area	Key Regulations	Compliance Status
Environmental Protection	Clean Air Act, Clean Water Act, EPA regulations, EU ETS	Fully Compliant
Health & Safety	OSHA, Process Safety Management, ISO 45001	Certified & Compliant
Financial Reporting	SEC regulations, Sarbanes-Oxley, IFRS, GAAP	Fully Compliant
Trade Compliance	Export Administration Regulations, OFAC, Customs	Fully Compliant
Anti-Corruption	FCPA, UK Bribery Act, OECD Anti-Bribery Convention	Fully Compliant
Data Protection	GDPR, CCPA, Data Privacy Laws	Fully Compliant

Compliance Certifications

TURKSIB maintains the following certifications demonstrating our commitment to compliance and quality standards:

• ISO 9001:2015: Quality Management Systems
• ISO 14001:2015: Environmental Management Systems
• ISO 45001:2018: Occupational Health and Safety Management
• ISO 37001:2016: Anti-Bribery Management Systems
• API Q2: Quality Management for Service Providers
• Responsible Care®: Chemical Industry Initiative
• EcoVadis Gold: Sustainability Rating

Compliance Training & Education

We invest in comprehensive compliance training programs for all employees, contractors, and business partners:

• Mandatory Training: All employees complete annual compliance training covering ethics, anti-corruption, and regulatory requirements.
• Role-Specific Training: Specialized training for employees in high-risk functions such as procurement, sales, and operations.
• Leadership Training: Advanced compliance training for managers and executives focusing on governance and oversight responsibilities.
• Contractor Training: All contractors working at TURKSIB facilities complete compliance orientation and safety training.
• Continuous Education: Regular updates on regulatory changes and emerging compliance risks.

Compliance Monitoring & Auditing

Our compliance program includes robust monitoring and auditing mechanisms:

• Internal Audits: Regular compliance audits conducted by our internal audit department.
• External Audits: Independent third-party audits of compliance programs and certifications.
• Regulatory Inspections: Proactive engagement with regulatory authorities and support for official inspections.
• Compliance Metrics: Tracking and reporting of key compliance indicators to management and the Board.
• Whistleblower Program: Confidential reporting channel for compliance concerns with non-retaliation protection.

Reporting Concerns

TURKSIB encourages the reporting of any compliance concerns or suspected violations. We provide multiple confidential reporting channels:

• Ethics Hotline: 24/7 confidential hotline for reporting concerns (phone and web-based)
• Management Reporting: Direct reporting to supervisors, managers, or compliance officers
• Board Reporting: Direct reporting to the Audit Committee of the Board of Directors
• External Reporting: Secure online portal for external stakeholders to report concerns

All reports are investigated promptly and thoroughly, with appropriate action taken when violations are confirmed.

Compliance Contact

For compliance-related inquiries or to report concerns, please contact:

Documentation & Disclosures

Key compliance documents and disclosures are available for review:

• Code of Conduct and Business Ethics
• Anti-Corruption and Anti-Bribery Policy
• Compliance Program Description
• Whistleblower Protection Policy
• Conflict of Interest Policy
• Annual Compliance Reports