Business Ethics and Code of Conduct

1. Introduction

KJ Power Generator is committed to conducting business with the highest standards of integrity, professionalism, and ethical behavior. This Code of Conduct outlines the principles and guidelines that govern our business practices and interactions with employees, customers, suppliers, and other stakeholders. Our commitment to ethical business conduct is fundamental to maintaining trust, ensuring legal compliance, and achieving long-term success.

This Code applies to all employees, directors, contractors, suppliers, agents, and business partners. Compliance with this Code is mandatory and reflects KJ Power Generator’s core values of integrity, respect, and accountability.

2. Scope

This Code applies to:

• All employees, contractors, and business partners of KJ Power Generator.
• All geographic locations where KJ Power Generator operates or conducts business.
• Any individual or entity acting on behalf of KJ Power Generator.
• Suppliers and subcontractors providing goods and services to KJ Power Generator.

All parties are expected to read, understand, and comply with the requirements outlined in this document. Failure to comply may result in disciplinary action, contract termination, or legal consequences.

3. Ethical Business Conduct

3.1 Integrity and Honesty

• All business decisions and interactions must be conducted with honesty, fairness, and transparency.
• Employees and representatives must avoid misleading statements, misrepresentations, and conflicts of interest.
• KJ Power Generator prohibits fraud, bribery, corruption, and unethical business practices in all forms.

3.2 Conflict of Interest

• Employees and representatives must avoid situations where personal interests conflict with company interests.
• Any potential conflict of interest must be disclosed in writing to management.
• Employees must not use company property or confidential information for personal gain.

3.3 Bribery and Corruption

• KJ Power Generator strictly prohibits any form of bribery, extortion, or corruption.
• Gifts, hospitality, or other benefits must not influence business decisions.
• Payments or incentives to government officials, business partners, or suppliers to secure unfair advantages are prohibited.

4. Labour Standards

4.1 Fair Employment Practices

• KJ Power Generator provides equal opportunities for employment and advancement.
• No discrimination based on race, gender, age, religion, disability, sexual orientation, or nationality.
• All employment terms (including working hours, wages, and benefits) comply with local labor laws and international labor standards.

4.2 Child Labour and Forced Labour

• No employment of individuals below the minimum legal working age.
• No forced, bonded, or compulsory labor under any circumstances.
• Employees have the right to leave employment with reasonable notice.

4.3 Compensation and Benefits

• Wages and benefits must comply with legal standards and industry norms.
• Employees are entitled to receive their wages in full and on time.
• Overtime must be voluntary and compensated in accordance with legal requirements.

4.4 Working Conditions

• Employees are entitled to work in a safe and secure environment.
• Facilities must meet health, safety, and hygiene standards.
• Working hours must comply with local labor laws and allow for adequate rest periods.

5. Health and Safety

• KJ Power Generator is committed to providing a safe and healthy work environment.
• All facilities, equipment, and processes must comply with applicable health and safety regulations.
• Employees must be provided with personal protective equipment (PPE) and training on health and safety protocols.
• Emergency procedures for fire, injury, evacuation, and other risks must be documented and communicated.
• Accidents, injuries, and unsafe conditions must be reported immediately.

6. Environmental Responsibility

• KJ Power Generator is committed to minimizing environmental impact.
• Compliance with all applicable environmental laws and regulations is mandatory.
• Hazardous materials must be stored, transported, and disposed of safely.
• Wastewater and emissions must be treated before discharge.
• Suppliers and partners are expected to adhere to similar environmental standards.

7. Data Protection and Cybersecurity

7.1 Protection of Confidential Information

• All company information, including trade secrets, customer data, and financial information, must be protected.
• Employees must not disclose confidential information to third parties without proper authorization.
• Secure handling of personal and company data is required.

7.2 Cybersecurity Standards

• KJ Power Generator follows market best practices for cybersecurity.
• Systems must be protected from unauthorized access, malware, and data breaches.
• Any suspected breach or vulnerability must be reported immediately.

8. Supplier and Business Partner Conduct

• All suppliers and business partners must adhere to this Code of Conduct.
• KJ Power Generator reserves the right to audit supplier compliance.
• Contracts may be terminated for non-compliance with labor, safety, environmental, or ethical standards.
• Suppliers are expected to adopt similar standards in their operations and supply chains.

9. Human Rights and Fair Treatment

• Respect for human rights is a core principle of KJ Power Generator.
• All employees and contractors must be treated with dignity and respect.
• No harassment, intimidation, or exploitation is tolerated.
• Reporting of human rights violations is encouraged and protected from retaliation.

10. Anti-Corruption and Anti-Fraud Measures

• Fraud, corruption, and misrepresentation are prohibited.
• All financial transactions must be accurately recorded and traceable.
• Employees and contractors must report any suspected cases of corruption or fraud.

11. Gifts and Hospitality

• Gifts of nominal value (under €50) are allowed if not intended to influence business decisions.
• Business entertainment must be reasonable and transparent.
• Employees must decline any gift or benefit that creates a conflict of interest.

12. Whistleblower Protection

• Employees and contractors are encouraged to report suspected violations without fear of retaliation.
• Reports will be handled confidentially and investigated promptly.
• Retaliation against whistleblowers is strictly prohibited.

13. Post-Employment Conduct

• Employees cannot engage in business activities that conflict with company interests for two years after termination.
• Former employees must maintain confidentiality of company information.

14. Compliance and Monitoring

• The Board of Directors is responsible for monitoring compliance with this Code.
• Violations may result in disciplinary action, including termination and legal consequences.
• Annual reviews will ensure the Code remains aligned with legal and ethical standards.

15. Disciplinary Actions and Consequences

• Violations of this Code may result in:
• Formal warnings
• Suspension or termination of employment
• Contract termination
• Legal action, including financial penalties

16. Governance and Review

• This Code of Conduct will be reviewed annually by the Board of Directors.
• Any updates will reflect changes in industry standards and regulations.
• Employees and suppliers will receive updated copies of the Code when revised.

Musa KÜRKÇÜ
Chairman of the Board

March 11^th, 2025