As a rule criminal liability is personal. Under the Turkish Penal Code (No. 5237) a manager is punished only for culpable participation in the act — committing it, inciting it or assisting in it — and holding a title, by itself, creates no criminal liability at all.
In practice the risk is still real. Where an incident falls inside your duties, your authority or your area of oversight — a transaction carrying your signature, or a process you were expected to supervise — you can be drawn into the investigation as a party to it. Some fields carry their own special liability regimes as well: occupational health and safety, tax, and the environment. Managing that exposure comes down to documenting decisions and approvals — who approved what, on what information — putting delegations of authority in writing, and getting legal support the moment a suspicion arises rather than once it has hardened. What your position actually is can only be assessed against the detail of the incident and the documents.
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