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TACCS CODE OF ETHICS & NDA

As a member of TACCS you are expected to :
• Learn and commit – Be aware and understand our Code and commit by signing the acknowledgement.
• Lead by example – Communicate, educate and remind our code to all.
• Be keen and communicate – Report any violations to our ethics committee and cooperate fully in our
investigation process.
• For all questions, please be sure to get in touch with our Ethics and Compliance Committee.

Ethics and Compliance Committee Contact Information: ethicsandcompliance@taccs.us

Build Trust and Credibility
The success of our organization is dependent on the trust and confidence we earn from members, potential clients
{individual or personal} of our businesses {individual or personal} and all stakeholders. We gain credibility by
adhering to our commitments, displaying honesty and integrity and reaching our goals of growth solely through
honorable conduct. It is easy to say what we must do, but the proof is in our actions. Ultimately, we will be judged
on what we do.

When considering any action, it is wise to ask: will this build trust and credibility for TACCS? Will it help create an
environment in which Turkish American Chamber of Commerce of the South can succeed over the long term? Is
the commitment I am making one I can follow through with? The only way we will maximize trust and credibility is
by answering “yes” to those questions and by working every day to build our trust and credibility.

Respect for the Individual

We all deserve to work in an environment where we are treated with dignity and respect. TACCS is committed to creating such
an environment because it brings out the full potential in each of us, which, in turn, contributes directly to our business success.
We cannot afford to let anyone’s talents and business opportunities not to be fully utilized.
Turkish American Chamber of Commerce of the South is an equal opportunity organization and is committed to providing an
environment that is free of discrimination of all types from abusive, offensive or harassing behavior. Any member who feels
harassed or discriminated against should report the incident to Ethics and Compliance Committee.
TACCS prohibits discrimination and harassment based on the following characteristics: race, color, religion, religious sect,
religious belief and practices, (including religious dress and grooming practice) national origin, ancestry, citizenship, physical or
mental disability,medical condition (including cancer and genetic conditions), genetic information, marital status, sex (including
pregnancy, childbirth, breastfeeding, or related medical conditions), gender, gender identity, gender expression, age (40 years
and over), sexual orientation, veteran or military status, domestic violence victim status, and any other characteristic protected by
federal and Florida anti- discrimination law as they might be amended. TACCS prohibits retaliation against a person who engages
in activities protected under this policy. Reporting, or assisting in reporting, suspected violations of this policy and cooperating in
investigations or proceedings arising out of a violation of this policy are protected activities under this policy.

Turkish American Chamber of Commerce of the South members are also expected to support an
inclusive workplace by adhering to the following conduct standards:
•Treat others with dignity and respect at all times
•Address and report inappropriate behavior and comments that are discriminatory, harassing, abusive,
offensive or unwelcome.
•Foster teamwork and member participation, encouraging the representation of different employee
perspectives.
•Seek out insights from members with different experiences, perspectives and backgrounds.
•Avoid slang or idioms that might not translate across cultures.
•Support flexible arrangements for all members with different time zones, needs, abilities and/or
obligations.
•Be open-minded and listen when given constructive feedback regarding others’ perception of your
conduct.
TACCS will not tolerate discrimination, harassment or any behavior or language that is abusive, offensive
or unwelcome.

Create and Sustain a Culture of Open and Honest Communication

At Turkish American Chamber of Commerce of the South everyone should feel comfortable to speak his or her
mind, particularly with respect to ethics concerns. The Board of Directors have a responsibility to create an open
and supportive environment where all members feel comfortable raising such questions. We all benefit
tremendously when our members exercise their power to prevent mistakes or wrongdoing by asking the right
questions at the right times.
TACCS will investigate all reported instances of questionable or unethical behavior. In every instance where
improper behavior is found to have occurred, the organization will take appropriate action. We will not tolerate
retaliation against employees who raise genuine ethics concerns in good faith.
For your information, TACCS ’s whistleblower policy is as follows:
Employees are encouraged, in the first instance, to address such issues with the Board of Directors, as most
problems can be resolved swiftly. If for any reason that is not possible or if a member is not comfortable raising the
issue with the Board of Directors, TACCS’s President and CEO, does operate with an open-door policy.

 

Set Tone at the Top


The Board of Directors has the added responsibility for demonstrating, through their actions, the importance of this
Code. In any business, ethical behavior does not simply happen; it is the product of clear and direct
communication of behavioral expectations, modeled from the top and demonstrated by example. Again, ultimately,
our actions are what matters.
To make our Code work, Board of Directors must be responsible for promptly addressing ethical questions or
concerns raised by members and for taking the appropriate steps to deal with such issues. Board of Directors
should not consider members ethics concerns as threats or challenges to their authority, but rather as another
encouraged form of business communication. At TACCS, we want the ethics dialogue to become a natural part of
daily interactions.


Uphold the Law


TACCS’s commitment to integrity begins with complying with laws, rules and regulations where we do business.
Further, each of us must understand the company policies, laws, rules and regulations that apply to our specific
roles. If we are unsure of whether a contemplated action is permitted by law or TACCS policy, we should seek the
advice from the resource expert. We are responsible for preventing violations of law and for speaking up if we see
possible violations.

Competition

We are dedicated to ethical, fair and vigorous competition. TACCS members will sell products and services based
on their merit, superior quality, functionality and competitive pricing. They will make independent pricing and
marketing decisions and will not improperly cooperate or coordinate our activities with their competitors. They will
not offer or solicit improper payments or gratuities in connection with the purchase of goods or services for TACCS
Members or the sales of their products or services, nor will they engage or assist in unlawful boycotts of particular
clients {individual or personal} of our members.


Proprietary Information


It is important that we respect the property rights of others. Our members will not acquire or seek to acquire
improper means of their competitor’s trade secrets or other proprietary or confidential information. Our members
will not engage in unauthorized use, copying, distribution or alteration of software or other intellectual property.

Selective Disclosure

Our members will not selectively disclose (whether in one-on-one or small discussions, meetings, presentations,
proposals or otherwise) any material nonpublic information with respect to TACCS and its members, its securities,
business operations, plans, financial condition, results of operations or any development plan. We should all be
particularly vigilant when making presentations or proposals to clients {individual or personal} to ensure that our
presentations do not contain material of nonpublic information.


Health and Safety


TACCS is dedicated to maintaining a healthy and safe environment.

Avoid Conflicts of Interest

Conflicts of Interest
All TACCS members must avoid any relationship or activity that might impair, or even appear to impair, their ability to make
objective and fair decisions when performing their jobs. At times, we may be faced with situations where the business actions
they take may conflict with their own personal or family interests. TACCS members owe a duty to our organization to advance its
legitimate interests when the opportunity to do so arises. We must never use TACCS property or information for personal gain or
personally take for ourselves any opportunity that is discovered through membership with TACCS.
Here are some other ways in which conflicts of interest could arise:
1. Being employed (you or a close family member) by, or acting as a consultant to, a competitor of our members or potential
competitor of our members , supplier or contractor, regardless of the nature of the employment, while you are a member of
TACCS.
2. Hiring or supervising family members for paid positions at TACCS or closely related persons.
3. Serving as a board member for an outside commercial company or organization.
4. Owning or having a substantial interest in a member’s competitor, supplier or contractor.
5. Having a personal interest, financial interest or potential gain in any TACCS transaction.
6. Accepting gifts, discounts, favors or services from a member/potential client, competitor or supplier, on behalf of our
organization TACCS unless equally available to all TACCS members.


Determining whether a conflict of interest exists is not always easy to do. Members with a conflict of interest question
should seek advice from Board of Directors. Before engaging in any activity, transaction or relationship that might give
rise to a conflict of interest, members must seek review from Board of Directors.

Gifts, Gratuities and Business Courtesies


TACCS members are committed to competing solely on the merit of their products and services. They should avoid any actions
that create a perception that favorable treatment of outside entities by their company was sought, received or given in exchange
for personal business courtesies. Business courtesies include gifts, gratuities, meals, refreshments, entertainment or other
benefits from persons or companies with whom TACCS members do or may do business. We will neither give nor accept
business courtesies that constitute, or could reasonably be perceived as constituting, unfair business inducements that would
violate law, regulation or polices of TACCS members or their clients {individual or personal}, or would cause embarrassment or
reflect negatively on TACCS’s member’s reputation.


Accepting Business Courtesies


Most business courtesies offered to our Board of Directors and our members during their roles and membership are offered
because of our positions at TACCS. We should not feel any entitlement to accept and keep a business courtesy. Although we
may not use our positions at TACCS to obtain business courtesies, and we must never ask for them, we may accept unsolicited
business courtesies that promote successful working relationships and good will with the companies that TACCS and its
members maintains or may establish a business relationship with.
TACCS members who award contracts or who can influence the allocation of business, who create specifications that result in
the placement of business or who participate in negotiation of contracts must be particularly careful to avoid actions that create
the appearance of favoritism or that may adversely affect our member’s company reputation for impartiality and fair dealing. The
prudent course is to refuse a courtesy from a supplier when TACCS members are involved in choosing or reconfirming a supplier
or under circumstances that would create an impression that offering courtesies is the way to obtain business with TAACS
members.

Meals, Refreshments and Entertainment


TACCS members may accept occasional meals, refreshments, entertainment and similar business courtesies that are shared
with the person who has offered to pay for the meal or entertainment, provided that:


• They are not inappropriately lavish or excessive.
• The courtesies are not frequent and do not reflect a pattern of frequent acceptance of courtesies from the same person or entity.
• The courtesy does not create the appearance of an attempt to influence business decisions, such as accepting courtesies or
entertainment from a supplier whose contract is expiring soon.
• The TACCS member accepting the business courtesy would not feel uncomfortable discussing the courtesy with the Board of
Directors or having the courtesies known by the public.
Gifts
TACCS members may accept unsolicited gifts, other than money, that conform to the reasonable ethical practices of the
marketplace, including:
• Flowers, fruit baskets and other modest presents that commemorate a special occasion.
• Gifts of nominal value, such as calendars, pens, mugs, caps and t-shirts (or other novelty, advertising or promotional items).
Generally, TACCS members may not accept compensation, honoraria or money of any amount from entities with whom TACCS
members does or may do business. Tangible gifts (including tickets to a sporting or entertainment event) that have a market
value greater than $100 may not be accepted unless approval is obtained from the Board of Directors.
TACCS members with questions about accepting business courtesies should talk to a member of our Board of Directors.

Offering Business Courtesies


TACCS member who offers a business courtesy must assure that it cannot reasonably be interpreted as an
attempt to gain an unfair business advantage or otherwise reflect negatively upon TACCS.
Board of Directors may approve courtesies, including meals, refreshments or entertainment of reasonable value,
provided that:
• The practice does not violate any law or regulation or the standards of conduct of the recipient’s organization.
• The business courtesy is consistent with industry practice, is infrequent in nature and is not lavish.
• The business courtesy is properly reflected on the books and records of the TACCS member organization.

Set Metrics and Report Results Accurately

Accurate Public Disclosures
We will make certain that all disclosures made in financial reports and public documents are full, fair, accurate, timely and
understandable. This obligation applies to all members, including all our financial executives, with any responsibility for the
preparation for such reports, including drafting, reviewing and signing or certifying the information contained therein. No business
goal of any kind is ever an excuse for misrepresenting facts or falsifying records.
Employees should inform Board of Directors if they learn that information in any filing or public communication was untrue or
misleading at the time it was made or if subsequent information would affect a similar future filing or public communication.
Recordkeeping
We create, retain and dispose of our records as part of our normal course of compliance with all TACCS policies and guidelines,
as well as all regulatory and legal requirements.
All TACCS records must be true, accurate and complete, and data must be promptly and accurately entered in our books in
accordance with TACCS and other applicable accounting principles.
We must not improperly influence, manipulate or mislead any unauthorized audit, nor interfere with any auditor engaged to
perform an internal independent audit of TACCS books, records, processes or internal controls.

Set Metrics and Report Results Accurately

Promote Substance Over Form
At times, we are all faced with decisions we would rather not have to make and issues we would prefer to avoid. Sometimes, we
hope that if we avoid confronting a problem, it will simply go away.
At TACCS, we must have the courage to tackle the tough decisions and make difficult choices, secure in the knowledge that
TACCS and its member organizations are committed to doing the right thing. At times this will mean doing more than simply what
the law requires. Merely because we can pursue a course of action does not mean we should do so.
Although TACCS guiding principles cannot address every issue or provide answers to every dilemma, they can define the spirit in
which our member organizations intend to do business, and this should guide us in our daily conduct.
Accountability
Each of us are responsible for knowing and adhering to the values and standards set forth in this Code and for raising questions
if we are uncertain about our organization’s policy. If we are concerned whether the standards are being met or are aware of
violations of the Code, we must contact a member of the Board of Directors.
TACCS takes seriously the standards set forth in the Code, and violations are cause for disciplinary action up to and including
termination of position or membership.

Be Loyal


Confidential and Proprietary Information
Integral to TACCS and its members’ success is our protection of confidential company information, as well as nonpublic
information entrusted to us by our members and their clients {individual or personal} . Confidential and proprietary information
includes such things as pricing and financial data, client names/addresses or nonpublic information about other member
companies, including current or potential supplier and vendors. We will not disclose confidential and nonpublic information
without a valid business purpose and proper authorization.
Use of TACCS Resources
Organizations resources, including time, material, equipment and information, are provided for the use of our organization.
Nonetheless, occasional personal use is permissible as long as it does not cause a disruption to our operations.
Board of Directors, members and their organizations and those who represent TACCS are trusted to behave responsibly and use
good judgment to conserve organizational resources. Board of Directors are responsible for the resources assigned to their
departments and are empowered to resolve issues concerning their proper use.
Generally, we will not use organizational resources to conduct of an outside business or in support of any religious, political or
other outside daily activity, except for TACCS-requested support to businesses and nonprofit organizations.
We will not tolerate the use of organizational resources to create, access, store, print, solicit or send any materials that are
harassing, threatening, abusive, sexually explicit or otherwise offensive or inappropriate.
Questions about the proper use of resources should be directed to Board of Directors.

Media Inquiries

TACCS is a high-profile organization in our community, and from time to time, our Board of Directors and members may be
approached by reporters and other members of the media. In order to ensure that we speak with one voice and provide accurate
information about the organization, we should direct all media inquiries to the Board of Directors.
No one may issue a press release without first consulting with the Secretary General of Turkish American Chamber of Commerce
of the South .

Do the Right Thing

Several key questions can help identify situations that may be unethical, inappropriate or illegal.
Ask yourself:
• Does what I am doing comply with the TACCS guiding principles, Code of Conduct and policies?
• Have I been asked to misrepresent information or deviate from normal procedure?
• Would I feel comfortable describing my decision at a meeting?
• How would it look if it made the headlines?
• Am I being loyal to my family, this organization and myself?
• What would I tell my child to do?
• Is this the right thing to do?

Information and Resources

President and CEO of TACCS
Erhan Cevikel: erhan.Cevikel@taccs.us
Senior Vice President of TACCS
Selen Timur: selen.timur@taccs.us
General Secretary of TACCS
Gokhan Yavuz: gokhan.yavuz@taccs.us
Ethics and Compliance Committee of TACCS
ethicsandcompliance@taccs.us