I- Introduction

Ethics is a set of standards that investigates the values, norms, and rules that form the basis of ethical considerations in individual and social relationships, exploring criteria such as right-wrong or good-bad. Professional ethics regulate the relationships among individuals forming the professional group and their relationships with society, while organizational ethics define the organizational behavior culture by establishing certain rules for solving problems arising from within and outside the organization.

Banks, which play a unifying and intermediary role between parties supplying and demanding funds in society, fulfill investment and savings functions while also aiming for profitability and efficiency principles, necessitating their work in accordance with ethical principles in the professional and organizational fields.

In order to expand the banking system, improve the quality of banking services, utilize resources in the best possible way, ensure a fair and honest competitive environment among banks, and prevent unfair competition, it is necessary for banks to regulate their relationships with each other and with other institutions, as well as with their customers, shareholders, and employees in accordance with these Ethical Principles.

II. General Provisions

Purpose and Scope

Article 1 - The fundamental purpose of the Banking Ethics principles to be applied in all kinds of transactions and operations of banks, whether among themselves, with customers and shareholders, or with employees and other institutions, is to ensure the continuity of the respect and trust in the banking profession in society, to develop and maintain this respect and trust, known as professional dignity, and to preserve stability and trust in the banking sector.

In this regulation, the term "bank" refers to member banks of the Association, and the term "Association" refers to the Turkish Banks Association and the Turkish Participation Banks Association.

Legal Basis

Article 2 - These Ethical Principles have been prepared based on the provisions of the second paragraph of Article 75, and subparagraphs (c) and (e) of Article 80 of Law No. 5411 on Banking.

General Principles

Article 3 - Banks are required to operate in accordance with the following general principles in order to protect the rights and interests of depositors, ensure confidence and stability in financial markets, ensure the effective functioning of deposit, credit, and payment systems, prevent transactions and practices that could cause significant harm to the economy, as well as to consider the public interest and protect the environment.

(*): Amended by the Banking Regulation and Supervision Agency's Decision No. 5903 dated June 19, 2014, and approved by the Board of Directors of the Turkish Banks Association on August 20, 2014.

Banks,

• a. Honesty

  They shall adhere to the principle of honesty in their relationships while performing their activities.

  b. Impartiality

  Based on the principle that "respect for people is the basis of success," they shall not discriminate or show biased behavior among their employees or customers, regardless of nationality, religion, financial or social status, gender, etc., and shall avoid prejudiced behavior. They shall not discriminate or show biased behavior among their employees or customers, regardless of nationality, religion, financial or social status, gender, etc., and shall avoid prejudiced behavior.

  c. Reliability

  In all services and transactions, they shall provide clear, understandable, and accurate information to customers in a mutual trust context, and fulfill customer services promptly and completely.

  d. Transparency

  They shall inform their customers clearly, understandably, and precisely about their rights and obligations, benefits and risks regarding the products and services offered to them. Before offering a product, service, or advice, they shall effectively assess their customers and their financial capacities, situations, and needs within this framework, and make product and service recommendations accordingly.

  e. Consideration of Social Benefit and Respect for the Environment

  In addition to profitability in all their activities, they shall strive to support social and cultural activities in the light of the principles of considering social benefit and respecting the environment.

  f. Combating Money Laundering and Financing of Terrorism

  They shall adopt combating money laundering, corruption, and similar crimes as an important principle in accordance with international norms and national legislation, and strive to cooperate with each other, as well as with other institutions and authorities concerned with the matter. They shall also take necessary measures within their organizations for this purpose and organize training programs for their staff.

  g. Insider Trading

  They shall take all necessary measures to prevent the misuse of insider information belonging to themselves and their customers.

III. Banks' Relations with Public Institutions and Organizations

Relations with Public Institutions and Organizations

Article 4 - Banks act in accordance with the principles of honesty, accountability, and transparency in their relations with public institutions and organizations, and take care to ensure that the information, documents, and records requested for inspection and control purposes are provided accurately, completely, and on time in accordance with the legislation.

IV. Interbank Relations

Banks,

• Information Exchange

  Article 5 - They exchange information among themselves on every subject within the limits permitted by the legislation, accurately and systematically.

  Personnel Movements

  Article 6 - They avoid any practices regarding personnel employment that may lead to unfair competition.

  Although there is contract and movement freedom in personnel employment in accordance with the Labor Law and related legislation, they take care to ensure that personnel employment does not disrupt the services of other banks.

  They act objectively and honestly when responding to requests for information about former employees from other banks.

  They take all necessary measures to ensure that employees who have previously worked in other banks perform their duties in compliance with the obligations regarding the preservation of secrets under banking regulations.

  Competition

  Article 7 - They consider competition as a free economic decision-making process among all relevant institutions in the sector, which enables decisions to be made freely. Therefore, in their activities within the framework of a free market economy, they avoid statements and behaviors that constitute unfair competition, taking into account not only their own interests but also

  • a) the continuous trust in the banking sector,
  • b) efforts for the development of the sector,
  • c) observing the environment required by competition law
  • ilkeleri çerçevesinde haksız rekabet oluşturan beyan ve davranışlardan kaçınırlar.
  • This principle is valid not only for bank legal entities but also includes the statements and behaviors of banks' employees. Banks cannot offer/provide benefits to another bank's employee while serving customers.
  Advertisements and Announcements

  Article 8 - In their announcements, advertisements, and promotions related to their financial structures and the promotion and marketing of banking products and services, they act in accordance with legal regulations and general ethics, honestly and realistically, and avoid any actions that could harm the reputation of the banking profession.

  In their announcements, advertisements, and promotions, they do not include expressions or statements that denigrate other institutions or the products and services of other institutions.

V. Relations with Customers

Banks,

• Customer Information

  Article 9 - They provide accurate, consistent, complete, and timely information at every stage and on every subject of the service relationship regarding all products and services they offer to their customers, adhering to the limitations specified in the legislation.

  Customer Confidentiality

  Article 10 - Except for persons and authorities explicitly authorized by law to request information and documents, they are obliged to keep confidential and carefully store all kinds of information and documents regarding customers.

  Service Quality

  Article 11 - They consider service quality as a prerequisite for meeting customer needs and expectations with qualified service. They take care to use the technological infrastructure and qualified human resources, the two basic elements of this concept, in a manner suitable for continuous improvement in service quality.

  They provide all their customers with the same quality and level of service. However, determining the target market, differentiating the organizational structure and product range according to the target audience, or taking different approaches to customers in a separate risk group should not be interpreted as discrimination among customers or categorization of customers.

  Customer Inquiries

  Article 12 - They establish an effective system that can respond to all kinds of questions from their customers arising from the services provided and inform their customers about this service.

  They investigate the reasons for the disputes with their customers and take necessary measures to prevent them from recurring. They correct erroneous practices that cause complaints, if any, and take all necessary measures to prevent their recurrence.

  Security

  Article 13 - They acknowledge that the concept of "security" includes not only measures for the protection of service environments owned by the bank against any kind of negativity but also the prevention of any kind of technical infringement that may cause harm in the services provided to customers in the banking sector.

  They take all necessary technical and legal measures to ensure transaction and information security in all kinds of service environments due to technological development and evolving services parallel to electronic banking and changing service channels. They inform their customers about the measures they have taken and the precautions that customers need to take.

VI. Relations with Employees

General Qualities of Employees

Article 14 - They take care that their employees are individuals with the knowledge, experience, and sense of responsibility required by their duties. Banks cannot employ personnel who do not meet the legal requirements specified in the legislation, including Banking Law No. 5411.

Recruitment and Career Development

Article 15 - They strive to provide equal opportunities for all employees, regardless of discrimination, both in recruitment and in career development. Based on the principle of managing human resources in the best way possible, they provide opportunities for their employees to reach the level of knowledge required by the current age and banking profession.

In the professional development and advancement of their employees, they take into account not only knowledge, skills, and personal success but also commitment to Banking Ethical Principles and diligence in applying these principles.

Principles of Representation and Working Environment

Article 16 - They make internal regulations requiring their employees to be clean and well-groomed, in accordance with the dignity of the banking profession and the awareness that they represent the bank.

They take measures to increase the motivation of their employees in all service units and to provide services under better conditions, and ensure the creation of a healthy and safe working environment.

They take necessary measures to prevent all types of harassment, including psychological harassment (mobbing), and conduct necessary investigations if there are allegations. As a result of the investigation, in case of determination of psychological harassment (mobbing), they take measures to remedy it and apply possible sanctions within the scope of the legislation.

Working Hours

Article 17 - They make maximum effort to employ a suitable number of employees according to the workload, to organize their employees' working hours to achieve the highest efficiency, to ensure that working hours are not exceeded, to respect the rights of employees in situations requiring overtime, and to ensure that their employees take regular annual leave.

Employee Rights

Article 18 - They take care to provide their employees' rights arising from Labor Law provisions and other applicable legislation, especially to prevent unfair termination of employment contracts, in a timely and complete manner.

VII. Rules of Conduct and Ethical Principles for Bank Employees

Rules of Conduct and Ethical Principles

Article 19 - Bank employees;

• a) Shall comply with the applicable legislation while performing their duties,
• b) Shall inform their customers about the benefits and risks of the products and services offered to them,
• c) Shall provide impartial and fair service to customers receiving the same service,
• d) Shall not disclose the secrets learned about banks or their customers to anyone other than the authorities explicitly authorized by law in this regard,
• e) Shall not cause reputational harm to the bank in their work and behavior,
• f) Shall not engage in activities that would require them to be considered as merchants or tradesmen, directly or indirectly,
• g) Shall not engage in behaviors contrary to the principles of justice, truthfulness, honesty, reliability, and social responsibility,
• h) Shall collaborate with other employees towards common goals by establishing respectful and careful communication,
• ı) Shall not use the assets and resources of the bank inefficiently and for purposes other than their intended use,
• j) Shall not personally benefit from themselves or others by using their duties and titles, either from their own work environments or from the opportunities of their customers,
• k) Shall immediately reject and report any offers aimed at benefiting them, to the competent authorities and their superiors,
• l) Shall primarily direct potential customers to their own bank,
• m) Shall not engage in relationships such as borrowing-lending, guaranteeing, and opening joint accounts with customers that are inconsistent with ethical principles,
• n) Shall not accept gifts from existing or potential customers outside of customary practices,
• o) Shall be accountable for the tasks they undertake in the performance of services,
• p) Shall not serve in any private or public institution without the approval of their bank, except for associations, foundations, cooperatives, and similar places,
• r) Shall not harm the reputation of the bank and other financial institutions in their media and social media profiles or posts, by using their own identities or using deceptive identities, and shall not engage in behaviors that denigrate or belittle their business partners, shareholders, employees, or customers,
• s) Shall not act on behalf of the bank by exceeding their authority or giving deceptive and untrue statements.
• They are obliged to comply with the above-mentioned obligations.
• Banks make internal regulations to ensure that their employees work in accordance with the obligations set forth above.

Development of Banking Ethical Principles

Article 20 - Banks may submit proposals to the Board of Directors of the Association at any time in order to improve this Code of Banking Ethics and to make amendments when necessary.

VIII. Application Procedure and Principles

Right to Apply and Time Limit

Article 21 - Banks, bank employees, and bank customers may apply. Applications cannot be made alleging violation of Union Ethical rules regarding acts and actions regulated and penalized by the Banking Law and other laws, including disputes pending in judicial bodies or concluded by judicial bodies.

Applications not made within one year from the date of the act are not taken into consideration.

Application Procedure

Article 22 - Applications are made in writing to the Union. Applications should include clear and detailed information and documents regarding the alleged violation of these Ethical Principles, and it should be specified in the application letter which article of these Ethical Principles has been violated. The alleged violation of conduct should be clearly demonstrated by specifying the person, time, and place in the application.

Acceptance and Examination of Applications

Article 23 - Applications are checked by the Union in terms of quality, information, and documentation. Applications that are deemed inappropriate in terms of quality, information, and documentation are not processed. The situation is communicated to the applicant with a clear and understandable rejection reason. Accepted applications are forwarded to the Union Ethics Commission by the Union.

The formation and working procedure and principles of the Union Ethics Commission are determined by the Union Board of Directors.

Actions Regarding the Decision of the Union Ethics Commission

Article 24 - The Union Ethics Commission may decide that there is no violation of the Ethical Principles in a submitted application or may decide to submit the application to the Board of Directors.

Decisions of the Union Ethics Commission determining that there is no violation of the Ethical Principles in the applications are communicated to the parties in writing.

IX. Detection of Non-Compliance and Sanctions and Other Provisions

Detection of Non-Compliance and Sanctions

Article 25 - In relation to applications submitted to the Union Board of Directors by the Union Ethics Commission, the Board of Directors decides whether there is a violation of these Ethical Principles and communicates the decision to the parties in writing. In case the Board of Directors determines a violation of the Ethical Principles, those who act in violation of these Ethical Principles are reported to the Banking Regulation and Supervision Agency, and the provisions of the third paragraph of Article 81 of the Banking Law No. 5411 are applied.

Execution

Article 26 - The General Secretariat of the Union shall execute this regulation.

Effective Date

Article 27 - These Banking Ethics Principles shall enter into force on the date of publication.