Yes. We adapt group policies — the code of conduct, the gifts and benefits policy, anti-bribery and anti-corruption, the whistleblowing hotline — to Turkish legislation and to local business practice. The anti-bribery part is aligned with the bribery and abuse-of-office provisions of the Turkish Penal Code (No. 5237); the hotline is aligned with the Personal Data Protection Law (No. 6698), both for the personal data it collects and for the protection of the person who reports.
What we do is a legal adaptation rather than a literal translation, because thresholds, approval mechanisms and penalty frameworks that hold in Germany are different here. Done that way, the policy keeps the group standard and is still something that can actually be applied and audited in Türkiye. We plan the training and the rollout that follow the adaptation as well — a policy nobody has been trained on is not a control.
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