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Hair Styling

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Fonex Brillantine 150 ml
Fonex Hair Spray Ultra Strong 400 ml
Fonex Hair Mousse Ultra Strong Volume 300 ml
Fonex Hair Mousse Milk Protein 300 ml
Fonex Hair Styling Wax Spider 150 ml
Fonex Hair Styling Wax Mega 150 ml
Fonex Hair Styling Wax Gloss Pomade 150 ml
Fonex Hair Styling Wax Hard 150 ml
Fonex Hair Styling Wax Matte 150 ml
Fonex Styling Powder Wax Matte Look 20 g
Fonex Styling Powder Wax Volume Effect 20 g
Fonex Hair Gel Extra Hold & Wet 700 ml
Fonex Hair Gel Mega Hold 700 ml
Fonex Hair Gel Ultra Hold 700 ml
Fonex Hair Gel Extra Hold & Wet 500 ml
Fonex Hair Gel Mega Hold 500 ml
Fonex Hair Gel Ultra Hold 500 ml
Fonex Hair Gel Extra Hold & Wet 300 ml
Fonex Hair Gel Mega Hold 300 ml
Fonex Hair Gel Ultra Hold 300 ml
Fonex Hair Gel Extra Hold & Wet 150 ml
Fonex Hair Gel Mega Hold 150 ml
Fonex Hair Gel Ultra Hold 150 ml

Producing The Cosmetics Of The Future, Today

Contact

İnönü Mahallesi Aşık Veysel Sokak
NO:3/1
Gebze Güzeller OSB
Gebze / Kocaeli

+90 212 618 41 42

Policies

Code of Ethics
Business Ethics Policy
Social Responsibility Policy
FAQs

Code of Ethics

The Company conducts its operations in accordance with the Code of Ethics established by its Board of Directors.

The Company’s Code of Ethics constitutes an essential set of rules governing internal relations and the relationships of the Company and its employees with customers, suppliers and other stakeholders. These rules are designed to improve service quality, ensure the efficient use of resources, prevent unfair competition and promote effective employee relations.

The Code of Business Ethics is consistent with the Company’s policies, values and principles and is binding on all employees, including members of the Board of Directors and managers. All Company personnel must comply with the Code of Business Ethics when performing their duties.

Compliance with Laws and Regulations

The Company ensures the highest level of compliance with all applicable national and international rules, particularly laws and regulations, as well as its internal policies and procedures.
In its relationships with investors and stakeholders, the Company acts without discrimination and complies with all applicable laws, regulations, rules and principles, its internal policies, international legal requirements and ethical values.

Confidentiality and Protection of Trade Secrets

Information and documents provided to employees by virtue of their positions, or accessed or obtained in the workplace, are subject to confidentiality and trade secret protection requirements. These include trade secrets, financial and other information not disclosed to the public, information concerning employees’ employment rights and entitlements, and confidential information contained in agreements with third parties.
The Company takes due care to protect the personal information of its employees and all stakeholders. In this context, personnel records and all email correspondence conducted on behalf of the Company are retained. The Company respects employees’ personal information and private lives. Personnel information is used only when necessary, by authorised individuals acting within their designated authority and for Company purposes.
All employees must protect Company information both during and after their employment and must not use it directly or indirectly without authorisation. Employees must not disclose inside information acquired during their employment unless authorised by the Company, nor may they use such information for personal gain. Obtaining a benefit through stock market transactions or by any other means using inside information is strictly prohibited. These obligations continue after employment ends. No employee may trade in shares of the Company, its associates or its subsidiaries on the basis of inside information.
Employees are informed, through training or other means, of their obligations under applicable legislation concerning inside information and of the sanctions associated with its misuse or improper disclosure.
All official disclosures are made by individuals and/or departments duly authorised by the Company, in accordance with its Disclosure Policy. Information is communicated to investors, shareholders and the public in a complete, simultaneous and understandable manner, ensuring equal access.
When an employee leaves the Company for any reason, due care must be taken to protect all records, documents and confidential information acquired through their role or position. Appropriate measures must also be taken to prevent such materials or information from subsequently being used against the Company.
The “Quiet Period” begins on the day following the end of the accounting period to which the Company’s financial statements, reports and independent audit reports relate and continues until these statements and reports are publicly disclosed in accordance with applicable legislation. During this period, except in relation to information already publicly disclosed on behalf of the Company and participation in conferences, panel discussions and/or seminars, no comments may be made on the Company’s operations, financial performance or financial outlook, and no questions from capital market participants, such as analysts or investors, may be answered.

Customer Relations

The Company acts honestly and fairly in its dealings with customers.
It responds attentively to customer concerns and strives to build relationships based on trust by providing prompt and lasting solutions.
It provides customers with clear and transparent information and offers concerning the products and services it supplies, including the associated rights, obligations, benefits and risks, and makes the necessary efforts to fulfil its commitments.
It protects customers’ rights, takes their objections and complaints into consideration, and has established a customer relations department to conduct the necessary investigations and assessments.
It provides customers with high-quality service of the highest standard.

Employee Relations

The Company ensures that employees work in safe and healthy environments suited to the requirements of their roles.
It treats employees fairly and provides equal opportunities in areas such as training, career development, recruitment and promotion.
It takes care to maintain appropriate staffing levels for each activity and ensures that working hours are duly observed. Recognising the importance of annual leave, it ensures that employees take their leave regularly.
It takes due care to ensure that employees receive all statutory rights and entitlements in full and on time.
Spouses, direct ascendants and descendants, and relatives up to and including the third degree may not work within the same supervisory reporting chain.
Employees are expected to communicate and cooperate with one another on the basis of mutual trust, respect and courtesy.
The Company ensures employee participation in decision-making processes.

Responsibilities towards Stakeholders

The Company bases its decisions on established economic criteria and ensures that its resources and assets are managed as efficiently as possible, with financial discipline and accountability.
With the aim of maximising the value of its shares, the Company implements growth-oriented, value-creating strategies while avoiding unnecessary and unmanageable risks.
All meetings and communications with investors, financial analysts, members of the press and similar parties are conducted in accordance with the Company’s Disclosure Policy.
No employee, other than individuals and/or departments duly authorised to do so, may make oral or written statements on behalf of the Company.

Corporate Governance Principles

The Company informs employees about its Corporate Governance Principles, promotes their adoption throughout the organisation and oversees full compliance with these principles.
It ensures that all information disclosed to the public is understandable, accurate, clear, timely and complete.

Industry and Competitor Relations

The Company takes due care to support the development of the industry, safeguard shared interests and maintain public confidence in the sector.
It observes the principles of fair competition in its relationships with competing companies.

Conflicts of Interest

The Company identifies and prevents situations in which personal interests may conflict with the interests of the Company or its customers. Those acting on behalf of the Company must safeguard its interests when performing their duties and avoid any action or conduct that could confer a personal benefit on themselves or those close to them.
The Company takes all necessary measures to prevent conflicts of interest.

Social and Environmental Responsibility

The Company conducts all its activities with regard for the public good and respect for the environment.
It takes care to conserve natural resources and acts with environmental awareness.
It prioritises developments that improve people’s living standards.

Responsibilities of All Company Employees

Employees are selected from trustworthy individuals who demonstrate strong ethical values, diligence, dedication, honesty and relevant knowledge and experience.
They work to enhance the Company’s value.
They represent the Company in the best possible manner at all times and in all settings.
They respect applicable laws and the Company’s internal policies and procedures.
They act with honesty, discipline, dedication and diligence.
They recognise the importance of ensuring customer satisfaction.
They value training and strive to develop their professional skills and improve their effectiveness in their respective fields.
They do not discuss work-related matters outside the Company or give rise to adverse commentary concerning the Company.
They safeguard the Company’s interests when performing their duties and avoid any action or conduct that could confer a personal benefit on themselves or those close to them.
They comply with the Company’s procedure on the misuse of inside information.
They exercise the utmost care in using Company resources properly and efficiently and avoid unnecessary expenditure. They neither use Company assets or resources for personal benefit nor allow others to do so.
They uphold compliance with the Company’s Code of Ethics and report any identified non-compliance to the appropriate authorities so that the necessary sanctions may be applied.
They maintain careful and professional relationships with customers and strive to provide the best possible service.
They behave towards one another with propriety and respect.

Audit and Reporting

The Company has its accounts audited annually by an independent audit firm in accordance with internationally accepted accounting standards.
Employees who encounter any practice that breaches the Code of Ethics must report it to the Chair of the Board of Directors, in writing and/or verbally. Matters reported are periodically compiled and submitted to senior management.

Breaches and Disciplinary Action

Any failure to comply with the provisions of this Code constitutes a breach of the Company’s mandatory ethical standards, in addition to any administrative or criminal sanctions that may apply under relevant legislation.

Where a breach is established and substantiated, a written warning and/or termination of employment shall apply if the breach involves conduct, circumstances or events that affect the Company’s core operations and result in a violation of applicable laws, materially affect its financial statements, damage its corporate reputation, or are intended to secure a benefit through the individual’s position or duties within the Company.

Business Ethics Policy

CODE OF ETHICAL CONDUCT AND IMPLEMENTATION PRINCIPLES

CODE OF BUSINESS ETHICS

I. OUR CODE OF BUSINESS ETHICS

A. Integrity

Truthfulness and integrity are our core values in all business processes and relationships. We act honestly and with integrity in our dealings with employees and all stakeholders.

B. Confidentiality

Confidential and proprietary information includes information that could place FONEX at a competitive disadvantage if disclosed, trade secrets, financial and other information not yet made public, information concerning employees’ employment rights and entitlements, and information covered by confidentiality agreements with third parties.

As FONEX employees, we respect the confidentiality of our customers, employees and other individuals and organisations with whom we work, and take due care to protect their private information.

We protect confidential information relating to the Company’s operations, use it solely for FONEX business purposes and share it only with relevant individuals within the limits of established authorisation.

When leaving the Company, we do not take confidential information or documents, project materials, internal regulations or similar work acquired or produced in the course of our duties.

C. Conflicts of Interest

As FONEX employees, we seek to avoid conflicts of interest. We do not use our positions to obtain personal benefits from individuals or organisations with whom we have business relationships, whether directly or through family members or other close contacts.

We do not engage in additional business activities for financial gain, either within or outside FONEX. We refrain from using the FONEX name, influence or our affiliation with the Company for personal benefit.

Where a potential conflict of interest arises, we apply lawful and ethical measures when we believe they can adequately protect the interests of the parties concerned. If in doubt, we consult our manager or the Ethics Committee.

D. Our Responsibilities

In addition to our legal responsibilities, we take care to fulfil the responsibilities set out below towards our customers, employees, shareholders, suppliers, business partners, competitors, society, humanity and the FONEX name.

1. Legal Responsibilities

We conduct all domestic and international activities and transactions in accordance with the laws of the Republic of Türkiye and international law. We provide regulatory authorities and institutions with accurate, complete and understandable information in a timely manner.

In all our activities and transactions, we maintain an impartial position towards public institutions, administrative bodies, non-governmental organisations and political parties, without seeking any benefit, and fulfil our obligations with this sense of responsibility.

2. Responsibilities towards Customers

We adopt a proactive, customer-focused approach, responding to our customers’ needs and requests as promptly and appropriately as possible.

We deliver our services on time and under the agreed conditions, treating customers with respect, dignity, fairness, equality and courtesy.

3. Responsibilities towards Employees

We ensure that employees can fully and properly exercise their employment rights and receive their entitlements.

We treat employees honestly and fairly and are committed to providing a safe, healthy and non-discriminatory working environment.

We support employees’ personal development, encourage voluntary participation in appropriate social and community activities and respect the balance between their professional and private lives.

4. Responsibilities towards Competitors

We compete effectively using only lawful and ethical means and avoid unfair competition.

We support initiatives that promote a properly functioning competitive environment.

5. Responsibilities towards Society and Humanity

Protecting democracy, human rights and the environment, supporting education and charitable activities, and combating crime and corruption are of great importance to us.

With a strong sense of corporate citizenship, we take a proactive and responsible approach to social issues and seek to participate in non-governmental organisations, public-interest services and other appropriate activities.

We respect the traditions and cultures of Türkiye and the countries in which we undertake international projects.

We neither offer nor accept bribes or gifts, products or services of excessive value.

6. Responsibilities towards the FONEX Name

Our customers and other stakeholders trust us because of our professional competence and integrity. We strive to uphold this reputation to the highest standard.

We provide our services in accordance with FONEX policies, professional standards, our commitments and ethical principles, and demonstrate the dedication required to fulfil our obligations.

We take care to provide services in areas in which we believe we are, or will become, professionally competent. We aim to work with customers and personnel who meet standards of integrity and lawful conduct.

We do not work with those whose activities undermine public morals or harm the environment or public health.

When speaking publicly, or in settings where listeners may assume that we represent the Company, we express only the Company’s views rather than our personal opinions.

When faced with complex situations that could expose the Company to risk, we first consult the appropriate personnel through the relevant technical and administrative consultation procedures.

II. POLICIES SUPPORTING THE CODE OF BUSINESS ETHICS

A. Conflict of Interest Policy

FONEX employees must avoid situations that may give rise to conflicts of interest.

Among employees’ most important responsibilities are refraining from using the Company’s resources, name, identity or influence for personal benefit and avoiding situations that could adversely affect its name or reputation.

The following implementation principles identify conflicts of interest that employees may encounter while performing their duties or in their private lives as a result of business relationships, and establish the principles to be followed in such circumstances.

Implementation Principles

1. Activities That May Give Rise to Conflicts of Interest

All employees must comply fully with the principles set out below concerning activities that may create conflicts of interest. The Company takes the necessary steps to encourage compliance.

1.1. Abuse of Position

It is unacceptable for employees to misuse their authority for their own benefit or that of people close to them, or to act without the required standard of care in a manner that harms the Company.

Employees may not obtain direct or indirect personal gain from the Company’s purchasing or sales activities, or from any transaction or agreement to which the Company is a party.

Employees must not engage in conduct that violates ethical standards, the law or the Company’s disciplinary rules.

1.2. Use of Resources

Resources used on behalf of the Company must serve the Company’s interests.

Company assets, facilities and personnel may not be used for purposes outside the Company that do not serve its interests, regardless of the stated purpose, beneficiary or party on whose behalf they are used.

All personnel must apply the principle of economy in all areas.

The proper use of resources also requires effective time management. Employees must use working hours efficiently and must not devote working time to personal matters. Managers may not assign employees to carry out their personal tasks.

As a general rule, personal visitors should not be received during working hours. Where a visit is unavoidable, it must be kept to a reasonable duration appropriate to its purpose and must not disrupt workflow.

1.3. Representing the Company

Any remuneration arising from duties performed on behalf of the Company in associations, employers’ organisations or similar non-governmental organisations must be donated to the relevant organisation or through channels designated by that organisation.

Payments made by third parties to employees for speaking at seminars or providing similar services must likewise be donated to the relevant organisation or through its designated channels.

Non-monetary commemorative gifts, such as awards of symbolic value, may be accepted with senior management approval.

In all cases, gifts must be exchanged in a manner appropriate to the local culture.

B. Gifts and Hospitality Policy

FONEX and its employees must not accept gifts or benefits that could influence their impartiality, decisions or conduct. They must likewise not offer gifts or benefits to third parties with the intention of exerting such influence.

The following implementation principles govern the exchange of gifts between employees and third parties with whom they have business relationships.

Implementation Principles

Employees are prohibited from accepting any gift or benefit, whether or not it has monetary value, that affects or could affect their impartiality, performance or decision-making in the course of their duties.
Employees may give and/or receive the gifts described in paragraph 3, or accept special treatment, provided that these are consistent with the Company’s business objectives, comply with applicable legislation and would not place the Company in a difficult position if publicly disclosed.
Subject to the conditions in paragraph 2, employees may offer or accept entertainment, refreshments and meals that fall within accepted business standards and comply with the Company’s Delegation of Authority Matrix. Non-monetary commemorative gifts of symbolic value, such as awards or plaques, may be accepted at seminars and similar events attended on behalf of the Company.
For the circumstances described above, and for other non-monetary gifts, benefits, holidays, discounts and similar items, approval is not required where the conditions in paragraph 2 are met and the total value received from each individual or organisation in a calendar year is less than TRY 300.
Gifts or benefits that are explicitly or implicitly conditional upon something being provided in return must not be accepted.
Accepting, giving or offering bribes and/or kickbacks is unacceptable under any circumstances.
Employees must not accept money as a gift or loan from subcontractors, suppliers, consultants, competitors or customers, or allow such parties to pay their travel costs, event expenses or similar charges.
The types of gifts and promotional items that the Company may provide to customers, dealers and other business contacts must be approved by senior management. No further approval is required for the distribution of items that have already been approved.
Subject to the conditions in paragraph 2, the Company may accept appropriate products or services as gifts. Products or services appropriate to the recipient’s culture and consistent with ethical values may also be given as gifts with senior management’s knowledge and approval.
In exceptional circumstances where local cultural practices require an exchange of gifts exceeding the limits set by Company policy, such gifts may be accepted only on behalf of the Company and with senior management approval. In all cases, gifts must be exchanged in a manner appropriate to the local culture.

C. Protection of Confidential Information Policy

Information is one of FONEX’s most important assets in achieving its vision.

The effective use and appropriate sharing of information, while ensuring its confidentiality, integrity and availability, are shared responsibilities of all our companies and employees.

The alignment of information management and confidentiality systems and processes across our companies is important to maximise benefits for the Group.

Further details are provided in the FONEX Information Security Policy and related documents.

The following implementation principles define confidential information and establish the rules employees must follow when handling it.

Implementation Principles

Confidential information includes, but is not limited to, the Company’s intellectual property rights, such as trademarks; innovations; databases; printed communication materials; processes; advertising; product packaging and labels; marketing, product and technical plans; and other materials written, invented, developed, created or implemented by employees.

It also includes business strategies, strategic partnerships and partner information, financial information, personnel information, customer lists, product designs, know-how, specifications, the identities of prospective and existing customers, supplier information and other information in written, graphic or machine-readable form.

The following rules apply:

Confidential information must not be disclosed to third parties unless disclosure is required by the competent authorities or applicable legislation.
Such information must not be altered, copied or destroyed. Necessary precautions must be taken to ensure its careful handling and storage and to prevent disclosure. Any changes must be recorded together with their revision history.
Confidential files must not be removed from the organisation. Where confidential information needs to be taken outside the organisation, approval must be obtained from the information owner or senior management.
Passwords, user IDs and similar credentials used to access Company information must be kept confidential and must not be disclosed to anyone other than authorised users.
Confidential Company information must not be discussed in shared or public areas such as dining rooms, cafeterias, lifts or employee shuttle vehicles.
Confidential information must be classified according to its level of confidentiality, and its classification must be clearly indicated. Employees must know the classification of information obtained through their duties and handle it accordingly. Where the classification is uncertain, the information must be treated as belonging to the next higher confidentiality category, and the relevant manager must be consulted where necessary.
Before information is shared with third parties in the Company’s interests, a confidentiality agreement must be signed or a written confidentiality undertaking obtained from the recipient. This ensures that recipients understand their responsibilities for the security and protection of the information shared.
Unfounded statements and/or rumours concerning individuals or organisations must not be made or circulated.
Individual salary, benefits and similar employment information reflecting Company policy is confidential and must not be disclosed to unauthorised persons. Personnel information must be communicated privately to the individual concerned. Employees are strictly prohibited from disclosing such information to others or pressuring other employees to disclose it.

D. Policy on Establishing and Maintaining a Fair Working Environment

FONEX regards the establishment and maintenance of a fair working environment as one of its highest priorities.

By providing a fair, respectful, healthy and safe workplace that complies with all applicable laws and regulations, the Company aims to enhance employee performance, development and commitment.

The following implementation principles establish the foundations of a fair working environment.

Implementation Principles

Company practices comply with all applicable employment and labour laws and regulations. Employees must also fulfil all legal requirements relevant to their activities.
FONEX’s human resources policies and practices ensure fairness in recruitment, promotion, transfer, job rotation, remuneration, rewards, employee benefits and all other employment practices.
Discrimination between employees on grounds such as language, race, colour, sex, political opinion, belief, religion, denomination, age or physical disability is unacceptable.
The Company creates a positive, cooperative and harmonious working environment, prevents conflict and enables individuals with different beliefs, ideas and opinions to work together constructively.
Employees’ privacy and personal space are respected. Communications between individuals must not be interfered with by those who are not parties to them. Personal data must not be unlawfully disclosed, distributed or obtained, even where it was originally recorded lawfully. Personnel information required by the nature or continuation of the employment relationship must not be used for other purposes or shared with third parties without the individuals’ consent. All employees’ private and family lives are respected.
Employees’ personal integrity, including their physical, sexual and emotional integrity, is protected. Any violation through physical, sexual and/or emotional harassment in the workplace or at any work-related location is contrary to the law and the Code of Ethics and will not be tolerated. The purpose is to ensure a working environment in which employees’ physical, sexual and emotional integrity is protected. For the purposes of this policy, sexual harassment includes sexual conduct that violates a person’s bodily integrity and/or harassment of a sexual nature without physical contact. Any conduct falling within this definition is prohibited. Adverse treatment of anyone who reports harassment, makes a complaint or assists with an investigation will likewise not be tolerated.
No employee may request, grant or receive preferential treatment on grounds such as sex, religion, language or race. Using such differences to obtain or grant concessions is unacceptable.
The physical workplace and working conditions must be healthy and safe for all employees.

E. Employee Responsibilities

FONEX’s Code of Business Ethics and related policies and procedures set out in detail the ethical standards governing our conduct and the way we perform our work. Compliance is a fundamental responsibility of every employee.

All FONEX employees are responsible for:

Complying with laws and regulations under all circumstances.
Reading the FONEX Code of Business Ethics and knowing, understanding, adopting and applying its rules, principles and values.
Learning the Company’s general policies and procedures and those specific to their roles.
Consulting their manager and Human Resources about potential breaches involving themselves or others.
Promptly reporting possible breaches involving themselves or others, either by name or anonymously, verbally or in writing, to their manager, Human Resources and/or the Ethics Committee.
Following the defined “Steps and Methods for Ethical Decision-Making” to support compliance and resolve problems.
Cooperating with the Ethics Committee during investigations and maintaining the confidentiality of investigation-related information.

F. Management Responsibilities

In addition to the responsibilities applicable to all employees, FONEX managers are responsible for:

Establishing and maintaining a corporate culture and working environment that support ethical conduct.
Leading by example and educating employees about the Code of Ethics.
Encouraging employees to raise questions, complaints and reports concerning ethical matters.
Providing guidance when consulted, considering all reports received and referring them promptly to the Ethics Committee where necessary.
Structuring the business processes under their responsibility to minimise ethical risks and implementing the methods and approaches required to ensure compliance.

G. Addressing Breaches of the Code of Ethics

Individuals who breach the Code of Business Ethics or Company policies and procedures will be subject to disciplinary action, which may extend to termination of employment.

Disciplinary action also applies to individuals who approve or direct misconduct or breaches, or who are aware of them but fail to report them appropriately.

1. Ethics Committee

The Ethics Committee is responsible for investigating and resolving complaints and reports of breaches of the FONEX Code of Business Ethics.

The Committee comprises the General Manager and senior executives.

2. Operating Principles of the Ethics Committee

The Ethics Committee operates in accordance with the following principles:

Reports, complaints and the identities of those submitting them are kept confidential.
Investigations are conducted with the greatest possible confidentiality.
The Committee may request information, documents and evidence directly from the department holding them. It may examine these materials only to the extent relevant to the investigation.
A written record of the investigation is maintained from the outset, with supporting information, evidence and documents attached.
The record is signed by the Committee’s leadership.
Investigations are treated as urgent and concluded as quickly as possible.
Committee decisions are implemented immediately.
Relevant departments and authorities are informed of the outcome.
The Chair and members act independently of their departmental managers and the organisational hierarchy when carrying out their duties. They must not be subjected to pressure or attempts to influence their decisions.
Where necessary, the Committee may seek expert advice and assistance, taking appropriate measures to preserve confidentiality throughout the investigation.

SOCIAL COMPLIANCE POLICY

Our Social Compliance Policy sets out standards developed collaboratively with our business partners, based on our core principles and values.

Our objective is to make social compliance an integral part of FONEX’s corporate culture. Accordingly, social compliance standards have been established and put into practice.

Alongside the provision of services, this policy commits us to ensuring that employees receive all rights arising from these standards within the applicable legal framework, complying with occupational health and safety requirements, acting responsibly towards the environment and creating a workplace characterised by open and honest communication, respect and recognition.

The policy is communicated to all employees through training. Suppliers are informed of its requirements and assessed against these criteria.

Employees who raise concerns or complaints will not be subjected to retaliation or punishment. Suggestion, Request and Complaint Boxes are available for employees to express their views, requests, complaints and recommendations.

Management opens and reviews submissions and implements improvements and corrective and preventive actions where required.

Our fundamental management approach is guided by the principle of “People First” at every stage of service delivery and management. In all our activities, we act with a sense of social responsibility towards employees, society and the environment, in line with the values that form the foundation of our corporate culture.

We believe that our people are our core asset in achieving sustainable growth and enhancing our customers’ competitiveness through high-quality, innovative products, solutions and services.

Our Social Compliance Policy comprises the following commitments:

A. Recruitment

To maintain the Company’s ethical standards, recruitment decisions take into account not only technical knowledge and professional expertise but also the ability to comply with Company rules and social compliance requirements.

The policies on non-discrimination and the prevention of harassment and abuse set out below apply from the recruitment stage onwards.

B. Child Labour

To support children’s healthy development and respect their right to education, we undertake not to employ anyone under the age of 18 and to comply with the rules and principles governing the employment of young workers.

C. Employment of Foreign Nationals

Employment contracts for foreign nationals are prepared in a language they understand.

Original documents must not be taken from employees upon recruitment or at any other time. Under no circumstances may workers be subjected to debt bondage.

The Company protects foreign employees’ statutory employment rights.

D. Employee Awareness

Recognising that informed employees are the foundation of social compliance, we provide information on employment rights, Company rules and working conditions during recruitment and periodically throughout employment.

E. Working Hours

To support productive working practices and respect human rights, we comply with applicable laws and regulations governing working hours and overtime.

F. Wages and Payments

We use the statutory minimum wage as the minimum pay benchmark for meeting employees’ living expenses and ensure that no employee is paid below it.

Overtime is paid at the additional rates required by law.

G. Compliance with Laws and Other Obligations

We comply with applicable laws, regulations and other relevant requirements.

H. Non-Discrimination

Recognising that all employees have equal rights, we prohibit discrimination in recruitment, compensation, access to training and promotion.

Decisions concerning termination or retirement must not be based on race, social class, religion, national origin, sex or political affiliation.

I. Communication

We believe that effective communication is essential to success.

We maintain active communication among employees and between employees and managers, establish and sustain positive working relationships, support teamwork and cooperation, and encourage diligence, discipline, care and patience.

J. Prevention of Harassment and Abuse

We ensure a working environment free from verbal, physical or psychological harassment and coercion, supporting a peaceful workplace and employee well-being.

K. Forced and Compulsory Labour

All work must be voluntary. Forced labour imposed through contractual obligations and labour performed under debt bondage are prohibited.

L. Responsibilities towards Customers

We adopt a customer-focused approach, responding to customers’ needs and requests as promptly and appropriately as possible.

We deliver services on time and under the agreed conditions and treat customers with respect, equality and courtesy.

M. Bribery and Corruption

Giving, receiving or offering bribes or kickbacks, or engaging in corruption, is unacceptable under any circumstances. All conduct must comply with our ethical principles.

N. Supply Chain Management

We support a collaborative approach in which preferred suppliers and contract manufacturers take reasonable and adequate measures to comply with social compliance requirements.

We exchange information with these suppliers to identify, in a timely manner, challenges that need to be addressed or mitigated.

O. Freedom of Representation

We respect employees’ right to representation.

P. Training

We recognise that employees’ level of training shapes the Company’s overall capabilities.

We organise internal and external training to increase occupational health and safety awareness and support professional and personal development.

By supporting employee development, we also promote the Company’s continual improvement.

R. Projects

We undertake to create and develop projects that contribute to society’s economic and social progress.

OCCUPATIONAL HEALTH AND SAFETY, ENVIRONMENTAL AND QUALITY POLICY

Our policy is to:

Increase employees’ awareness of quality, environmental protection and occupational safety through training and communication.
Continually improve the quality of the products and services we provide to meet customer expectations.
Deliver projects on time by providing products and services that comply with international regulatory requirements and standards.
Implement occupational health and safety, quality and environmental management system standards within a structure that supports continual improvement.
Continually improve performance by controlling environmental impacts and occupational safety risks.
Achieve continual improvement through the implementation of quality, environmental and occupational health and safety management system standards and compliance with applicable laws and regulations.

Senior management has documented the Quality Management System (QMS), Environmental Management System (EMS) and Occupational Health and Safety (OH&S) policies in line with legal requirements and customer expectations.

The policies are communicated to employees through training and display in clearly visible locations. Understanding is verified during internal audits, training sessions and individual discussions.

The policies are reviewed at every Management Review Meeting and revised where necessary to reflect changes in the Company’s resources and capabilities, market conditions and national circumstances.

The Occupational Health and Safety, Environmental and Quality Policy is assessed at Management Review Meetings for continuing suitability, and any required revisions are agreed.

ANTI-BRIBERY AND ANTI-CORRUPTION POLICY

1. Purpose and Scope

The purpose of the Anti-Bribery and Anti-Corruption Policy (“Policy”) of Fonex Kozmetik Sağlık ve Eğitim Hizmetleri San. ve Tic. Ltd. Şti. (“Company”) is to ensure that employees comply with anti-bribery and anti-corruption legislation, ethical principles and other relevant international standards in the areas in which they operate.

The Company adopts a zero-tolerance approach to bribery and corruption.

This Policy applies to:

All Company employees, including members of the Board of Directors.
External service providers, business partners and their employees.

This Policy forms an integral part of the Company’s Corporate Governance Principles, Ethical Principles, Employment Contract and applicable legal framework.

2. Definitions

Corruption means directly or indirectly requesting, offering, giving or accepting a bribe or any other unlawful benefit that causes the recipient to depart from the lawful performance of their duties or required conduct.

Bribery means obtaining a benefit under an agreement with a third party in return for acting contrary to the requirements of one’s duties, including by performing, refraining from performing, accelerating or delaying an action.

Bribery and corruption may arise in many forms and contexts, including:

Gifts.
Donations.
Hospitality arrangements.
Dealings with external service providers and business partners.
Facilitation payments.

3. Roles and Responsibilities

This Policy has been approved by the Board of Directors. Its implementation and updating are carried out through assignments made by the Board.

The Company has established the processes, systems and organisational structure necessary to ensure compliance with legal requirements and ethical principles. Relevant roles and responsibilities have been documented.

Accordingly:

Company Management is authorised to establish and amend ethical principles. Employees who breach these principles are subject to disciplinary action.
Managers of all departments are responsible, within their areas of responsibility, for assessing potential risks and taking the measures necessary to ensure that employees, external service providers and business partners comply with this Policy.
Employees are responsible for complying with policies established by senior management, performing their duties within the limits of their authority under applicable legislation and Company rules, and working in accordance with these requirements.

4. Bribery and Corruption

The Company opposes all forms of bribery and corruption and is committed to complying with applicable laws, regulations and principles.

Accepting or giving a bribe is strictly prohibited, regardless of its purpose.

Business relationships must not be continued with third parties that seek to obtain services from the Company through bribery.

5. Principal Areas of Corruption Risk

Measures to ensure effective prevention of bribery and corruption are determined with regard to the sensitivity of employees’ positions and their levels of access.

a. Gifts

A gift is an item provided without payment, generally by a business contact or customer as a gesture of thanks or business courtesy.

Any gift offered by the Company to a third party must be offered openly and in good faith.

The same conditions apply to the acceptance of gifts. Only symbolic gifts of modest monetary value given to the Company, rather than to individual employees, may be accepted.

Even where a gift otherwise complies with this Policy, it must not be offered or accepted if it could create, or be perceived to create, a conflict of interest.

b. Donations

No corporate or personal payment, gift, assistance or donation may be made to a private company, government official or political party candidate to influence a decision relating to the continuation of Company activities or the procurement or provision of services that could benefit the Company.

The relevant requirements are also set out in the Company’s Code of Ethics and Working Principles.

c. Hospitality Policy

Hospitality may be offered to third parties for the purpose of developing commercial relationships and maintaining normal business networks.

Such parties may include customers, consultants, lawyers, auditors and other companies with which the Company has business relationships.

Hospitality offered by the Company must be provided openly, in good faith and without conditions.

Even where it otherwise complies with this Policy, hospitality must not be offered or accepted if it could create, or be perceived to create, a conflict of interest.

d. External Service Providers and Business Partners

External service providers, including support service providers, and business partners must comply with this Policy and other relevant requirements.

Relationships with individuals or organisations that breach the Anti-Bribery and Anti-Corruption Policy will be terminated.

In addition to the usual technical criteria, the selection of service providers and business partners takes into account their track record and whether they have policies equivalent to the Company’s policies and ethical principles.

Payments for outsourced services are also checked to ensure that they are legitimate and proportionate to the services provided.

e. Facilitation Payments

The Company does not permit individuals or organisations within the scope of this Policy to offer facilitation payments to secure or expedite routine business activities or processes.

6. Accurate Record-Keeping

The Company must comply with the legal requirements governing its accounting and record-keeping systems.

All accounts, invoices and documents relating to dealings with third parties, including customers and suppliers, must be recorded and retained completely, precisely and reliably.

Accounting or similar commercial records relating to any transaction must not be falsified, and the underlying facts must not be misrepresented.

7. Training and Communication

This Policy has been communicated to all employees.

Training is provided to ensure that employees adopt its principles and conduct their work in accordance with its requirements.

8. Reporting Conduct or Circumstances Contrary to the Policy

Employees and anyone acting on behalf of the Company must immediately report any individual, organisation, conduct or circumstance that breaches this Policy and comes to their attention in the course of their activities.

Reports must be submitted to Company Management or directly to info@fonex.com.tr.

Reports are kept strictly confidential. The utmost care is taken to preserve confidentiality during any subsequent review or investigation, with priority given to protecting the reporting employee from harm.

9. Support and Protection for Employees Who Comply with the Policy

The Company undertakes to ensure that employees who apply its anti-bribery and anti-corruption rules will not suffer detriment for doing so.

It commits to protecting employees who act in accordance with its policies under all circumstances and to keeping reports made to Company Management confidential.

10. Sanctions for Non-Compliance

All employees must adopt and fully implement this procedure.

FONEX does not tolerate unethical conduct, unlawful activities, prohibited practices, attempts to prevent the reporting of potential breaches, or unethical or obstructive actions.

Employees found to have breached this procedure are subject to disciplinary measures, including termination of employment under Article 25/II of the Turkish Labour Law.

External service providers must sign a version of FONEX’s policy adapted to their activities. If a supplier declines to sign but can confirm adherence to its own Code of Business Ethics containing the same principles, this may be accepted as an alternative.

If a supplier refuses to sign and does not have equivalent principles of its own, an alternative supplier will be considered.

Where a supplier is a large organisation, such as a national telecommunications or energy company, obtaining a signed undertaking may not be practicable. The source policy treats this as an exception on the assumption that such a supplier’s public standing does not give rise to ethical concerns.

Employees are prohibited from offering payments or anything of value to obtain an unlawful or unethical advantage, even where intended to benefit the Company, or from obtaining a similar advantage from other individuals or organisations.

Any unlawful or unethical conduct that could constitute bribery or corruption is prohibited, even where such practices are common in the country or business sector concerned.

An Anti-Bribery and Anti-Corruption Audit Committee has been established to determine whether employees or suppliers engage in such conduct.

The Committee comprises the Ethics Committee Representative, Deputy General Managers and Legal Counsel.

It reviews employees and suppliers quarterly and whenever necessary, without being restricted to the quarterly schedule. Findings are documented and filed, and the necessary complaints are submitted to the relevant Public Prosecutor’s Office.

Where required, action may include criminal proceedings, the imposition of contractual penalties or termination of the relevant agreement.

Social Responsibility Policy

We adopt social responsibility towards our employees, society and the environment as a fundamental principle of our management approach in all our activities. Through sustainable growth, we aim to enhance consumer satisfaction by providing high-quality, innovative products, solutions and services.

Child Labour

To support children’s healthy development and respect their right to education, we do not employ anyone under the age of 18.

Recruitment

To uphold the Company’s ethical standards, we recognise compliance with Company rules and social compliance requirements as essential recruitment criteria, alongside technical knowledge and professional expertise. We undertake to apply our policies on non-discrimination and the prevention of harassment and abuse from the recruitment stage onwards.

Wages and Payments

We use the statutory minimum wage as the minimum pay benchmark for meeting employees’ living expenses. We undertake to ensure that no employee is paid below the statutory minimum wage and that overtime is paid at the additional rates required by law.

Bribery and Corruption

Giving, receiving or offering bribes or kickbacks, or engaging in corruption, is unacceptable under any circumstances.

Employee Awareness

We believe that informed employees are the foundation of social compliance. We therefore inform employees of their employment rights and entitlements, Company rules and working conditions during recruitment and at regular intervals throughout their employment.

Working Hours

In line with efficient working practices and respect for human rights, we comply with all applicable laws and regulations governing working hours and overtime.

Non-Discrimination

All employees have equal rights. We do not discriminate in recruitment, compensation, access to training or promotion. Decisions concerning termination of employment or retirement are not based on race, social class, religion, national origin, sex or political affiliation.

Occupational Health and Safety

We recognise people as our most valuable asset in all our activities. Our priority is to minimise potential harm and losses by creating a safer and healthier working environment.

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