1. Purpose

The purpose of Anti-Bribery and Anti-Corruption Policy (the Policy) is to disclose Anti-Bribery and Anti-Corruption policies contained of Rx Corporate Communications Training Consultancy Services Trade and Marketing Ltd. (“Rx Corporate Communications”)

2. Scope

Anti-bribery and anti-corruption policy covers: All Rx Corporate Communications employees including the Company Manager, companies from which we outsource good and services and their employees, people and agencies working on behalf of Rx Corporate Communications including consultants, lawyers, external auditors

3. Definitions

Corruption is the misuse of the authority held due to the position for the purpose of gaining advantage directly or indirectly.
Bribery is aperson’s obtaining, offering or promising benefits directly or through intermediaries for the purpose of performing, having, doing, not performing, accelerating, slowing down a task related to the performance of its duty; request or acceptance; to act in violation of the requirements of the task by means of mediation such as the other person within the framework of an agreement with itself or the party requesting it, or because of this relationship is to benefit someone else.
Bribery and corruption may occur in various different ways, among these: Cash payments, political or other donations, commission, social benefits, gift, hosting, other benefits can be mentioned.

4. Duties and Responsibilities

All Rx Corporate Communications employees are responsible for; ensuring compliance with established policies of the Company Manager, effectively managing the risks associated with their business operations, working in a manner consistent with the relevant legal regulations and the applications of Rx Corporate Communications, informing the Company Manager if they encounter with a conduct, activity or application which are in breach of the Policy.

5. Our Policies and Procedures

5.1 Bribery and Corruption

Rx Corporate Communications is against all kinds of bribery and corruption. Accepting bribes or bribing can never be accepted under any purpose.
Business relationships with third parties wishing to get business from Rx Corporate Communications through bribery or corruption have to be terminated.

5.2 Gift

A gift is a product generally given by customers or persons with which a business relationship is established as a means of thanking or commercial courtesy and which does not require a financial payment.
All kinds of gifts offered or given to third parties by Rx Corporate Communications must be offered in public, with good faith and unconditionally. Principles regarding gifts which can be given within this scope and recording are possible with the written approval of the Company Manager.
The same principles apply for accepting a gift and no gift must be certainly accepted apart from the symbolic gifts included in these principles, with low financial value. In addition, even within this scope, gift acceptance must not become frequent and Company Manager have to be informed about the gift by the who accept gift.

5.3 Facilitation Payments

The persons and institutions within the scope of this Policy must not offer facilitation payments to guarantee or speed up a routine transaction or process (obtaining authorization and license, obtaininga document, etc.) with government agencies.

6. Training and Communication

Anti-Bribery and Anti-Corruption Policy has been announced to employees of Rx Corporate Communications and it can be continuously and easily accessed.
Trainings are important instruments for increasing awareness of employees. Within this scope, Rx Corporate Communications designs training programs including the Company Manager which are compulsory for all employees.

7. Notification of Policy Breaches

If opinion or suspicion exists that an employee or a person acting on behalf of Rx Corporate Communications is acting in breach of this Policy, the issue must be submitted to the Company Manager. Policy issues are reminded to employees of Rx Corporate Communications in certain periods.
Rx Corporate Communications encourages an honest and transparent approach; supports any employee or person acting on behalf of Rx Corporate Communications who expresses his/her sincere concerns with good faith, and keeps notifications secret. None of the employee shall be subject to pressure or punishment of the Company Manager for the a violation notification, the scope of the duties or place of job shall not be changed for this reason without written consent of the Company Manager.

8. Policy Breaches

In cases which are or could be in breach of the Policy, the matter is reviewed by the Company Manager and necessary sanctions are implemented if inappropriate acts are detected.
In contracts made with the companies from which goods and services are bought and to whom goods and services are sold and with persons and institutions carrying out duties on behalf of Rx Corporate Communications, the provisions stating that if conducts, attitudes or activities in breach of Policy are detected, business will be terminated unilaterally, need to be included and in case of breach of policy business shall be terminated.