Code of Business Conduct

Our Code of Conduct contains a number of important guidelines of behavior and is intended to guide all of us in our office and construction works but also in our strategic planning and our decision-making processes.

Where appropriate, our Code of Conduct will be modified by host country laws and regulations. Our Code of Conduct is not intended to be a static instrument. It will be continuously developed and adapted to the ever-changing legal and economic environments that affect the ways that we conduct our works in host country.

With this in mind we have revised our Code of Conduct, the foundation of which is our “Vision and Values”. The “Vision and Values” represent the fundamental principles to which Tecnolines Italia commits. Tecnolines Italia’s image and reputation, as a group that operates in an ethically and legally appropriate manner, is inseparable from the conduct of each of us as we perform our work, everyday.

This Code of Conduct aims to fulfill Tecnolines Italia’s below listed intended actions for the implementation of human resources policy and environmental management.

We, the employees of Tecnolines Italia, are expected to respect host country laws and regulations, avoid conflicts of interest, protect the Company’s assets, and show consideration and appreciation for the host country local customs, traditions and social mores of host country in which Tecnolines Italia conducts business.

In fulfilling our responsibilities within Tecnolines Italia, we do not take ethical shortcuts. Improper conduct will never be in Tecnolines Italia’s interest.

This Code of Conduct covers every employee of Tecnolines Italia and also the employees of our lower tier Sub-Contractor employees.

• Workers’ Code of Conduct will be clearly displayed at the different Project Areas and posted in the Contractor’s vehicles and machinery driving cabs.
• Tecnolines Italia commits to implement the ESHS provisions provided for in the Contract.
• Tecnolines Italia personnel are made aware and acknowledge their understanding of the Worker’s Code of Conduct and the associated provisions. The Workers’ Code of Conduct will be initialled by all Tecnolines Italia personnel prior to the start of any physical work at any Project Area.
• Behaviours listed below will considered as dismissal from any Project Area by Tecnolines Italia, or by the Implementation Consultant if Tecnolines Italia is not acting in due course, if Mitaş Energy's personnel repeatedly commit an offence of serious misconduct despite awareness of the Code of Conduct, and this is without prejudice to any legal action by any public authority for non-compliance with applicable regulations:
  • Drunkenness during working hours, leading to risks for the safety of local inhabitants, customers, users and personnel
  • Punishable statements or attitudes, and sexual harassment in particular
  • Violent behaviour
  • Intentional damage to the assets and interests of others, or the environment
  • Repeated negligence or imprudence leading to damage or prejudice to the environment, the population or properties, particularly breaching provisions intended to prevent the spreading of STD and AIDS
  • Drug use
  • Possession and/or consumption of meat or any other part of an endangered animal or plant as defined in the Washington convention (CITES) and national regulations
  • Entering property of neighbouring people without permission of the landowners or those cultivating/renting the land.

Definition of child is any person less than 15 years of age, unless local minimum age law stipulates a higher age for work or mandatory schooling, in which case the higher age would apply. If, however, local minimum age law is set at 14 years of age in accordance with developing-country exceptions under ILO Convention 138, the lower age will apply. Definition of young worker is any worker over the age of a child as defined above and under the age of 18.

Tecnolines Italia; shall not engage in or support the use of neither child labour nor young worker as defined above. Tecnolines Italia; shall establish, document, maintain, and effectively communicate to personnel and other interested parties policies and procedures for remediation of children and young worker found to be working in situations which fit the definition of child labour and young worker above, and shall provide adequate support to enable such children to attend and remain in school until no longer a child or a young worker as defined above. Tecnolines Italia; shall establish, document, maintain, and effectively communicate to personnel and other interested parties policies and procedures for promotion of education for children covered under ILO recommendation 146 and young workers who are subject to local compulsory education laws or are attending school, including means to ensure that no such child or young worker is employed. Tecnolines Italia; shall not expose children or young workers to situations in or outside of the workplace that are hazardous, unsafe or unhealthy.

Tecnolines Italia; shall not engage in or support the use of forced labour, nor shall personnel be required to lodge “deposits” or identity papers upon commencing employment with Tecnolines Italia.

Tecnolines Italia; bearing in mind the prevailing knowledge of the construction industry and of any specific hazards, shall provide a safe and healthy working environment and shall take adequate steps to prevent accidents and injury to health arising out of, associated with or occurring in the course of work, by minimizing, so far as is reasonably predictable, the causes of hazards inherent in the working environment.

Tecnolines Italia; shall appoint a Contractor’s Health and Safety Officer responsible for the health and safety of all personnel, and accountable for the implementation of the health and safety elements of this policy.

Tecnolines Italia; shall ensure that all personnel receive regular and recorded health and safety training, and that such training is repeated for new and reassigned personnel.

Tecnolines Italia; shall establish systems to detect, avoid or respond to potential threats to the health and safety of all personnel.

List of Most Common Hazards:

▪ Slips and falls
▪ Working at heights
▪ Struck-by objects
▪ Moving machineries
▪ Working in excavations
▪ Exposure to chemicals, hazardous or flammable materials
▪ Exposure to electric shocks and burns when touching live components.
▪ Working at heights
▪ Exposure to a variety of hazards such as electric shock, and thermal burn hazards.

Tecnolines Italia; shall provide, for use by all personnel, clean lavatories, access to potable water, and if appropriate, sanitary facilities for food storage.

Tecnolines Italia; shall ensure that, if provided for personnel, dormitory facilities are clean, safe, and meet the basic needs of the personnel.

Facilities at site/tower location will be a car parking area, dining and smoking area, toilets. There will be a designated emergency vehicle with first aid kits and fire extinguishers.

All forms related with Health and Safety will be collected at Tecnolines Italia servers. Tecnolines Italia will share the forms thru this portal with Client and Engineer.

Tecnolines Italia; shall respect the right of all personnel to join trade unions of their choice and to bargain collectively.

Tecnolines Italia; shall, in those situations in which the right to freedom of association and collective bargaining are restricted under law, facilitate parallel means of independent and free association and bargaining for all such personnel.

Tecnolines Italia; shall ensure representatives of such personnel are not the subject of discrimination and that such representatives have access to their members in the workplace.

Tecnolines Italia; shall not engage in or support discrimination in hiring, remuneration, access to training, promotion, termination or retirement based on race, caste, national origin, religion, disability, gender, sexual orientation, or age.

Tecnolines Italia; shall not interfere with the exercise of the rights of personnel to observe tenets or practices, or to meet needs relating to race, caste, national origin, religion, disability, gender, sexual orientation.

Tecnolines Italia; shall not allow behaviour, including gestures, language, and physical contact, that is sexually coercive, abusive or exploitative.

Tecnolines Italia; shall not engage in or support the use of corporal punishment, mental or physical coercion, and verbal abuse.

Tecnolines Italia; shall comply with EU directives, applicable laws and industry standards on working hours. All overtime work shall be reimbursed at a premium rate and under no circumstances shall exceed 12 hours per employee per week.

Other than as permitted, overtime work shall be voluntary.

Where Tecnolines Italia is party to a collective bargaining agreement freely negotiated with worker organizations representing a significant portion of its workforce, it may require overtime work in accordance with such agreement to meet short-term business demand. Any such agreement will comply with the requirements.

Tecnolines Italia; shall ensure that wages paid for a standard working month shall always meet at least legal or industry minimum standards and shall be sufficient to meet basic needs of personnel and to provide some discretionary income.

Tecnolines Italia; shall ensure that deductions from wages are not made for disciplinary purposes, and shall ensure that wage and benefit remuneration are detailed clearly and regularly for workers; Tecnolines Italia shall also ensure that wages and benefits are rendered in cash (to bank account), in a manner convenient to workers.

Tecnolines Italia; shall ensure that labour-only contracting arrangements and false apprenticeship schemes are not undertaken in an effort to avoid fulfilling its obligations to personnel under applicable laws pertaining to labour and social security legislation and regulations.

Tecnolines Italia HR will not permit any employee work on this project without social security registration.

All employees will have a social security registration in accordance with the host country Laws and Regulations.

Workforce from overseas will at least have a social security registration in host country as well as their International Personal Insurances.

Social security obligation is not just mandatory for Tecnolines Italia employees but also a mandatory clause for lower tier sub-contractors.

In case of an incident Tecnolines Italia will take full the responsibility of medical treatment of Employees in accordance with the Project Insurance.

Tecnolines Italia Senior Management shall define Tecnolines Italia and Metal Construction’s policy for social accountability and labour conditions to ensure that it:

• includes a commitment to conform to all requirements of this policy and requirements to which Tecnolines Italia subscribes;
• includes a commitment to comply with national and other applicable law, and to respect the international standards (i.e. ISO 9001, 14001, 45001, 37001, 39001) and their interpretation; includes a commitment to continual improvement.
• is effectively documented, implemented, maintained, communicated and is accessible in a comprehensible form to all personnel, including senior management, group presidents, directors, managers, supervisors, and staff, whether directly employed, contracted or otherwise representing Tecnolines Italia;
• is effectively documented, implemented, maintained, communicated and is accessible in a comprehensible form to all personnel, including senior management, group presidents, directors, managers, supervisors, and staff, whether directly employed, contracted or otherwise representing Tecnolines Italia;

Tecnolines Italia; shall ensure that the worker welfare audit is substantive, Tecnolines Italia internal auditors will gather anecdotal evidence through interviews and observation as well as documentary evidence found in Tecnolines Italia records. In addition, due to the social objectives of the Tecnolines Italia worker welfare accountability system, internal auditors will place a higher priority on verifying the performance of the system than on the existence of documentation.

Pursuant to internal auditor documentation requirements, each worker welfare policy element shall be addressed in the audit report. In addition, internal auditors will include notations on any accepted deviations, a brief overall description of the facility and the format of the interviews. External and internal photographs are encouraged, taking care to not record any proprietary equipment or process.

Whistleblowing is when a Tecnolines Italia employee reports suspected past, present or imminent wrongdoing, or an attempt to conceal wrongdoing. Officially this is called ‘making a disclosure in the public interest’. Whistleblowing is important to safeguard the effective delivery of public services, and to ensure value for money. It serves to protect and reassure the workforce, increasing public confidence and to maintain a healthy working culture and an efficient organisation.

This procedure outlines the process that employees should follow when reporting a perceived wrongdoing within Tecnolines Italia, including something they believe goes against the core values in the EU Staff Regulations and the EU Code of Good Administrative Behaviour i.e. integrity, honesty, objectivity and impartiality. This procedure has been written in accordance with the process set out in the EU Staff Regulations and EU Code of Good Administrative Behaviour. Under the Code, civil servants have a right and a responsibility to speak up and report behaviour that contravenes the Code’s values.

The reporting, under this procedure, of wrongdoing may be covered by the law concerning protected disclosures of information. The procedure has therefore been written with reference to the Italian Legislation and EU Code, which offers protection to those in both the private and public sectors, who ‘blow the whistle’, in certain circumstances. The Code provides more information.

It is important that this procedure is followed when raising any concerns, to ensure that the matter is dealt with correctly. Where a concern is raised using the correct procedure, the individual will be protected from any unfair or negative treatment. As set out in this procedure, employees can raise concerns through a number of internal routes and can also approach the independent Civil Service Commission directly.

Tecnolines Italia wishes to encourage all employees and other workers (see ‘Scope’ in Whistleblowing Policy), who have concerns about wrongdoing or malpractice involving any aspect of the department’s work, to feel able to come forward and voice these without fear and in confidence. It is important that concerns are raised at the earliest time possible as this will allow the opportunity to address and resolve any concerns quickly. Employees will be able to do this through using this procedure to alert the appropriate people about such issues.

Sources of advice and support can be found in the procedure document.

One the primary goals of Tecnolines Italia, is the preservation of cultural heritage. Cultural heritage consists of individual objects, structures, or aggregate collections. It is material which has significance that may be artistic, historical, scientific, religious, or social, and it is an invaluable and irreplaceable legacy that must be preserved for future generations.

In striving to achieve this goal, Tecnolines Italia assumes certain obligations to the cultural heritage, to its Clients and the Engineers, to the construction profession, and to society as a whole. This document, Tecnolines Italia Code of Conduct, sets the principles that Tecnolines Italia and sub-contractors who are involved in the care of cultural heritage during construction activities.

1. All construction activities are governed by an informed respect for the cultural heritage, its unique character and significance, and the people or person who created it.
2. While recognizing the importance cultural heritage, Tecnolines Italia will perform a good practice for the preservation of cultural heritage.
3. Tecnolines Italia will strive to select methods and materials that, to the best of current knowledge, do not adversely affect cultural property or its future examination, scientific investigation, treatment, or function.
4. Tecnolines Italia will document examination, scientific investigation, and treatment of cultural heritage by expert records and reports.
5. Tecnolines Italia will recognize a responsibility for preventive conservation by endeavouring to limit damage or deterioration to cultural property, providing guidelines for continuing use and care, recommending appropriate environmental conditions for storage and exhibition, and encouraging proper procedures for handling, packing, and removal.