Anti-Corruption Policy

PRM YAZILIM DANIŞMANLIK TİC. LTD.

Effective Date: 01.01.2024

1. Purpose

PRM YAZILIM DANIŞMANLIK TİCARET LİMİTED ŞİRKETİ (PRM) is committed to conducting business with integrity, transparency, and in full compliance with all applicable anti-corruption laws and regulations. As a partner of Oracle Corporation, we uphold the highest ethical standards and align our practices with Oracle’s policies, including the Oracle Partner Code of Conduct and Business Ethics. This policy establishes guidelines to prevent bribery, corruption, and unethical business practices in all company operations.

2. Scope

This policy applies to all employees, officers, directors, contractors, consultants, and any third parties acting on behalf of PRM. It covers interactions with public officials, private entities, customers, vendors, and other stakeholders in all jurisdictions where we operate.

3. Prohibited Conduct

PRM strictly prohibits:

• Bribery & Kickbacks: Offering, giving, receiving, or soliciting anything of value (cash, gifts, favors, or hospitality) to improperly influence a business decision.

• Facilitation Payments: Small payments made to expedite routine government actions.

• Conflicts of Interest: Engaging in activities that create a conflict between personal interests and the company’s best interests.

• Fraud & Misrepresentation: Falsifying records, financial statements, or engaging in deceptive practices.

• Improper Charitable Contributions & Sponsorships: Using donations or sponsorships to disguise bribery.

• Third-Party Violations: Ignoring corruption risks associated with business partners, resellers, suppliers, or intermediaries.

4. Compliance with Laws

PRM complies with all applicable anti-corruption laws, including but not limited to:

• U.S. Foreign Corrupt Practices Act (FCPA)

• TCK article 252 in Turkey and local anti-bribery laws in the regions where we operate

As an Oracle Partner, we also adhere to the Oracle Partner Code of Conduct and Business Ethics, ensuring compliance with Oracle’s policies regarding ethical business practices and anti-bribery measures.

5. Gifts, Hospitality, & Entertainment

Employees may provide or accept modest business courtesies only if they:

• Are reasonable, transparent, and appropriate under local laws and customs.

• Do not influence, or appear to influence, business decisions.

• Are not given in exchange for an unfair advantage.

All gifts and hospitality above a 50 USD threshold must be pre-approved by management.

6. Due Diligence on Third Parties

Before engaging with third parties, PRM conducts risk-based due diligence to ensure compliance with anti-corruption laws and Oracle policies and public sector addendum to Oracle partner agreements. Business partners must certify adherence to our anti-corruption policy and applicable laws.

7. Reporting & Whistleblower Protection

Employees and stakeholders are encouraged to report suspected corruption or unethical behavior via Esta dirección de correo electrónico está siendo protegida contra los robots de spam. Necesita tener JavaScript habilitado para poder verlo.. Reports will be treated confidentially, and retaliation against whistleblowers is strictly prohibited.

8. Training & Enforcement

• All employees receive regular anti-corruption training.

• Violations may result in disciplinary action, including termination and legal consequences.

9. Policy Review & Updates

This policy is reviewed annually and updated as needed to comply with evolving legal and business requirements.