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Information Policy | Olmuksan

Information Policy

QUALITY POLICY

Through adopting the total quality approach,

  • Business is performed on a customer-focused basis,

  • Constant improvement of customer satisfaction is aimed,

  • An effective quality management system is implemented for incessant development,

  • We accurately accomplish our work at one go, (Do the right at the first time)

  • Applicable conditions are taken into account and fulfilled.

Total quality is the responsibility of all employees.

Rev: October.2017

 

ENVIRONMENTAL, WORKPLACE HEALTH & SAFETY POLICY

The most fundamental value of our main strategies; to produce our products in a healthy and safe working environment, to use natural resources wisely, to protect the environment, to reduce environmental impacts, and to continuously improve our OHS and environmental management system performance.

We adopt the following principles in order to achieve these goals in all our processes of our activities:

  • To comply with all legal and other requirements (compliance obligations) regarding occupational health and safety and environment,

  • By eliminating the dangers for everyone we work with, to prevent accidents, injuries and health losses, to determine our risks and environmental impacts, to reduce them to an acceptable level,

  • To prevent environmental pollution, to adopt the principle of sustainability in resource use, to protect the environment and ecosystem,

  • To ensure that our employees consult and participate in the occupational safety management system,

  • Compliance with all our stakeholders within the framework of our environmental, occupational health and safety policy
    to work in it.

Rev:June.2020

 

DISCLOSURE POLICY

Formation of Olmuksan International Paper Disclosure Policy as mentioned below and the announcement to the public.

1. Purpose

The management of Olmuksan International Paper Ambalaj San. ve Tic. A.Ş. is proud of being in a transparent and close communication with its shareholders. The main aim of the Management is to make the shares of Olmuksan International Paper Ambalaj San. ve Tic. A.Ş. attractive investment instruments for potential investors while increasing the value of Olmuksan International Paper Ambalaj San. ve Tic. A.Ş. for current shareholders. The principal target of Olmuksan International Paper Ambalaj San. ve Tic. A.Ş. Management is to share information on the performance and forward looking developments within the scope of the Generally Accepted Accounting Principles (GAAP) and the Capital Market Legislation (CML), in a fair, complete, accurate and comprehensive way with the shareholders, investors and the Capital Market experts (together with capital market participants) equally.

Olmuksan International Paper Ambalaj San. ve Tic. A.Ş. complies with the CML, Capital Market Board (CMB) and Istanbul Stock Exchange (ISE) Regulations with respect to public informing and also applies the Corporate Governance Principles of CMB with maximum care.

Disclosure Policy applies to all employees and advisers of Olmuksan International Paper Ambalaj San. ve Tic. A.Ş. and it regulates the written and oral communication between Olmuksan International Paper Ambalaj San. ve Tic. A.Ş. and the Capital Market participants.

2. Authority and Responsibility

Disclosure Policy is prepared and approved by the Board of Directors within Corporate Management Principles of the CMB. Monitoring, controlling and development of policy of Olmuksan International Paper Ambalaj San. ve Tic. A.Ş. for informing and disclosing the public is under the authority and responsibility of the Board of Directors.

Finance Director within the Company organization is in-charge of observing and controlling all issues concerning public informing.

3. Tools and Method to Public Informing

Disclosure is performed by means of information tools such as special case public disclosers, financial statements and reports, annual reports, internet page, presentations, investor meetings and teleconferences, information letters and press releases. Basic tools and methods used to inform the public by Olmuksan International Paper Ambalaj San. ve Tic. A.Ş. while saving the provisions of CML and Turkish Commercial Code are listed below:

  • Special case public disclosures forwarded to ISE (notifications are made simultaneously in electronic environment to Public disclosure project (KAP))

  • The financial tables and footnotes, independent audit report, declarations and activity report forwarded to ISE, (KAP notifications are made simultaneously in electronic environment)

  • Announces and notifications made by means of Turkish Trade Registry Journal and Daily Newspapers (guidelines, circular, calls for general assembly etc.)

  • Press statements made by means of written and visual media,

  • Disclosure meetings and interviews made face to face or via tele-conferences with capital market participants

  • Corporate Website (www.olmuksan-ipaper.com),

  • Disclosures made over Communication mediums and methods like phone, cell phone (wap and similar technologies), e-mail, fax etc

4. Disclosure of Financial Reports To The Public

The financial statements and footnotes of Olmuksan International Paper Ambalaj San. ve Tic. A.Ş. are prepared on a consolidated basis and comply with the International Financial Reporting Standards (IFRS); audited independently with respect to International Audit Standards (IAS) and disclosed to the public by being forwarded to ISE. Before disclose, financial reports and disclosures are approved by the Board of Directors after the Audit Committee within the CML.

After the approval of the Board of Directors, the financial reports, disclosures, independent audit report and other attached documents are sent to ISE with a closed envelope as the CMB and ISE regulations order. At the moment when financial reports, disclosures, and independent audit board are disclosed, they are published in KAP project electronically as well.

5. Public Disclosure of the Annual Report

The annual report prepared according to the CML and the Corporate Governance Principles of CMB; it is approved by the Board of Directors and is disclosed to public with the financial tables via our corporate web page (www.olmuksan-ipaper.com).

6. Public Disclosure of Special Cases and Responsible People

Public disclosure of Olmuksan International Paper Ambalaj San. ve Tic. A.Ş. is prepared by Finance Directorate.

Declarations of public disclosure of Olmuksan International Paper Ambalaj San. ve Tic. A.Ş are forwarded to ISE after being signed by General Manager, Finance Director on principle. If that is not possible, the public disclosure is sent to ISE after being signed by General Manager or Finance Director and Sales and Marketing Director. The disclosure of special cases is sent to ISE by fax. It is also sent as KAP Information electronically.

Any information is counted as special and important information when there is a great chance that any reasonable investor might find it important and special.

If any employee of Olmuksan International Paper Ambalaj San. ve Tic. A.Ş. finds out that important information, which has not been disclosed before, has been disclosed involuntarily, the employee immediately reports the situation to General Management. In this case, General Management ensures that the appropriate special position disclosure is prepared in line with provisions of CML and is forwarded to ISE by preparing the same.

Olmuksan International Paper Ambalaj San. ve Tic. A.Ş. broadcasts public disclosure in its internet site (www.olmuksan-ipaper.com) within business day after public is disclosed information at the latest and maintains the said disclosures for five years in its internet site.

7. People Authorized To Inform The Public

Apart from the disclosures given above, written and oral requests for information given by capital market participants or any institution/person are processed within the authority of General Management. In conducted assessment, according to the content of request, it is checked if it is commercial secret and if it is any type that may affect the investment decisions and the value of capital markets instruments within the scope of Capital Markets Board's Communiqué of VIII Serial and No 54 on Essentials of Public Disclosure of Special Cases. The written and oral requests of information are answered by relevant unit after the assessment of General Manager.

Press statements for written and visual media and to data distributors like Reuters, Forex etc can only be made by Chairman of the Board of Directors and General Manager.

Despite that without being specially charged, employees of Olmuksan International Paper Ambalaj San. ve Tic. A.Ş. cannot answer questions coming from capital market participants. Incoming requests for information are forwarded to General Management.

8. People who have administrative responsibility

People who have administrative responsibility are people who access to insider information related either directly or indirectly to Olmuksan International Paper Ambalaj San. ve Tic. A.Ş. moreover, who are authorized to have administrative decisions affecting the future development and commercial targets of Olmuksan International Paper Ambalaj San. ve Tic. A.Ş..

9. Communication with Capital Market Participants

Olmuksan International Paper Ambalaj San. ve Tic. A.Ş. never comments on expectations about interim periods and annual results. Instead of this, Olmuksan International Paper Ambalaj San. ve Tic. A.Ş. comments on critical subjects affecting activity results, strategic methods and subjects that make the sector and the activities more understandable and informs the capital market participants. Only authorized individuals who do public disclosures can make comments to the public in name of Olmuksan International Paper Ambalaj San. ve Tic. A.Ş. unless otherwise specified in the disclosure policy.

10. Market Rumors

Olmuksan International Paper Ambalaj San. ve Tic. A.Ş. does not generally comment on market rumors or speculation as a rule. Follow up of the news and rumors included in press-media organs and at internet sites about Olmuksan International Paper Ambalaj San. ve Tic. A.Ş. is made by Finance Directorate and they are informed to General Management. General Management decides if these news and information would make any impact on capital instruments.

It is decided by Finance Directorate if it is necessary to make a public disclosure within the framework of 18th article of Capital Markets Board's Communiqué of VIII Serial and No 54 on Essentials of Public Disclosure of Special Cases. However, the Company responds to rumors or speculation in certain circumstances including upon request by CMB and or ISE within the framework of provisions of CML or if the Company determines such response is appropriate.

11. Meetings and Interviews with Investors and Analysts

In Olmuksan International Paper Ambalaj San. ve Tic. A.Ş. the General Manager is responsible for carrying out relations with either present or potential shareholders in a regular manner, responding the questions of investors in a most effective manner and performing studies for rising the value of the company.

General Manager and/or Finance Director use various tools such as roadshow, teleconference, e-mail, fax, analyst presentations, explanation/announcement for direct disclosure that are necessary for making Olmuksan International Paper Ambalaj San. ve Tic. A.Ş. reputable and preferable in international investment area and emphasizing the advantageous features of it when compared to similar institutions and making Olmuksan International Paper Ambalaj San. ve Tic. A.Ş. more preferable than other companies for institutions investing in emerging markets. All incoming meeting requests from shareholders are positively responded and interviews at the highest level possible to provide opportunities.

Olmuksan International Paper Ambalaj San. ve Tic. A.Ş. regards analyst reports as proprietary information belonging to the analyst's company and will not provide such reports on the Company's website (www.olmuksan-ipaper.com). Olmuksan International Paper Ambalaj San. ve Tic. A.Ş. will not review, confirm, endorse, adopt or disseminate analysts' reports or earnings models. However, in certain limited circumstances, upon request, the Company may review specific factual assertions that an analyst intends to include in a report for the factual accuracy of historical information that is publicly available.

12. Quiet Period

Olmuksan International Paper Ambalaj San. ve Tic. A.Ş. in order to prevent asymmetric information distribution and unauthorized disclosure about annual reports, avoids talking in specific periods of the calendar year about financial results and about other subjects with capital market participants. These periods are called "quiet periods". For Olmuksan International Paper Ambalaj San. ve Tic. A.Ş. the quiet period starts at the 15 of the following month after the three-month period and annual accounting period ends and will end one business day after when financial reports and footnotes are disclosed to the public.

Olmuksan International Paper Ambalaj San. ve Tic. A.Ş. during the quiet period;

  • Will not talk about the financial status of Olmuksan International Paper Ambalaj San. ve Tic. A.Ş. at one to one meetings or group meetings with capital market investors except the information that has been disclosed before,

  • Except it is required and the CML are followed, it will not comment about its activities and financial status,

  • Except the information disclosed before, questions will not be answered in one to one meetings or meetings with small groups. If such a situation is possible, the disclosure will be made on the website (www.olmuksan-ipaper.com).

13. Olmuksan International Paper Ambalaj San. ve Tic. A.Ş.'s Website (https://www.olmuksan-ipaper.com)

Olmuksan International Paper Ambalaj San. ve Tic. A.Ş.'s Website, which is in (https://www.olmuksan-ipaper.com) internet address, as recommended by CMB Corporate Management Essentials is actively used in informing the public. The information available on Olmuksan International Paper Ambalaj San. ve Tic. A.Ş.'s Website does not represent the disclosure of special case announcements regarding CML. All disclosure of Olmuksan International Paper Ambalaj San. ve Tic. A.Ş. can be accessed through the webpage. The webpage is based on this and it includes sections. All precautions are taken for the security of the webpage. The webpage is prepared and designed in Turkish and in English as CMB Corporal Management Essentials claim. Especially the announcements for General Assembly meetings and for agenda and other information, documents and reports are available on the webpage very clearly. Activities for the development of the webpage are kept running.

Important headings that may be seen at website are summarized as follows:

  • Detailed information related to corporate identity

  • Vision and main strategies

  • Information about Members of Board of Directors and top management

  • Organization and partnership structure of the company

  • Articles of Association of the company

  • Trade Registry information

  • Financial Information

  • Press disclosures

  • CMB Public Disclosures

  • Explanations about General Assembly meeting date, agenda and agenda items

  • Minutes of General Assembly meeting and list of participants

  • Specimen of Power of Attorney

  • Corporate Management Applications and compliance report

  • Profit distribution policy, history and capital increases

  • Disclosure policy

  • Frequently Asked Questions section

INFORMATION SECURITY POLICY

Olmuksan considers corporate information as a valuable asset. All types of corporate information and the medium where such information is kept that belongs to Olmuksan and/or our business partners which is used during our activities, sustains critical significance with regard to our business and responsibilities and its security has to be provided appropriately.

The concept of security is made of three (3) components consisting of confidentiality (preventing possession of information by unauthorized third parties), integrity (precise information which is not altered by any unauthorized persons), and availability (readiness for use whenever required), and any security vulnerability occurring in any of these components can have a serious impact on integrity of Olmuksan’s business activities and reputation.

Irrespective of their functions and positions, all Olmuksan employees and suppliers are obliged to fully comply with the applicable statutory regulations, policies, procedures and directives, diminish the relevant risks and operate within the framework of generally accepted good manufacturing practices.

With the Information Security Management System, Olmuksan targets to protect information and data assets the Company and its stakeholders possess. In order to attain this target Olmuksan management commits itself to provide all necessary sources to establish, implement, operate and continuously improve an ISMS and meet all applicable conditions relating to information security.

Breach of any policies regarding information security and failure to implement the required controls against any viable risks may cause Olmuksan to sustain serious tangible and intangible damages. Therefore, any beaches concerning information security and/or relevant policies/procedures discovered as a result of surveillance, inspection and/or reporting by employees may merit taking inter-company disciplinary action that may range from dismissal through initiation of judicial and criminal actions against the perpetrators.

Olmuksan’s Information Security Management System Policies/Procedures are applicable and obligatory for all full-time, part-time and permanent Olmuksan employees who use Olmuksan information or operating systems, regardless of their geographical location or business unit. Any third party service providers and their associates, such as support personnel, etc. who are not included in such classification but need to have access to Olmuksan’s information are also obliged to strictly abide by the general principles of this policy and all other obligatory responsibilities to ensure information security.

The IP Way Forward

The IP Way Forward is our strategic framework to pursue our vision to be one of the most successful, sustainable and responsible companies in the world and create value for all stakeholders for generations to come.

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