HEMEL Code of Conduct

Our standards for responsible business

HEMEL Boya ve Kimya San. A.Ş. develops and supplies coatings and wood protection solutions. Our reputation depends on the quality of our products and on the decisions we make every day. We are committed to conducting business honestly, protecting people and the environment, and earning the trust of customers and business partners.

This Code explains the conduct we expect in our operations and relationships. It provides employees, customers, suppliers and other stakeholders with a clear statement of our commitments. Commercial pressure, production targets and individual performance goals never justify unlawful or unethical conduct.

Our values in practice

Excellence: we constantly strive to achieve excellence in all that we do. Innovation: our motto is that it can always be done better, so we always challenge the status quo. Customers: we place them at the heart of our business and work relentlessly to meet their expectations. Experience: we deliver results that enable market success through our sales organization, technical assistance and customer consultation. Ethics: we work together in an open, ethical way. These values guide our work to extend the useful life of wood and support responsible use of resources.

Who this Code covers

This Code applies to HEMEL Boya ve Kimya San. A.Ş. and all of its brands, including Hemel, Prime, Restol and X-Paint. It covers HEMEL directors, managers and employees, including temporary personnel. People acting on HEMEL’s behalf must follow the relevant standards. We expect suppliers, contractors, agents, distributors and other business partners to uphold equivalent standards in their dealings with us. Specific contractual obligations are set out in the applicable agreements.

Following the law and exercising judgment

We comply with the laws and regulations applicable to our activities and markets. Where this Code sets a higher standard and the law permits it, we follow that standard. Where a conflict or uncertainty arises, we seek guidance before proceeding. No one may instruct another person or a business partner to breach the law or this Code.

Before acting, ask whether the decision is lawful, safe, honest and consistent with this Code, and whether it could be explained openly to colleagues, customers and management. If the answer is unclear, pause and seek guidance.

Management systems and continuous improvement

HEMEL supports its commitments through management systems covering quality, occupational health and safety, and customer complaints handling. These systems provide a structured basis for monitoring performance, addressing risks, investigating complaints and implementing corrective actions. Employees must follow relevant procedures, maintain accurate records and contribute to continuous improvement. Public references to certifications must accurately reflect their current validity, certified activities and site coverage.

Leadership responsibility

Managers must demonstrate these standards, explain them to their teams and respond constructively to concerns. They must not discourage reporting, ignore warning signs or reward results achieved through improper conduct.

1 Respecting people and protecting safety

Dignity and equal opportunity

We treat people with dignity and respect. Recruitment, development, pay and promotion decisions must be based on relevant qualifications, performance and legitimate job requirements. We do not tolerate discrimination, harassment, sexual harassment, bullying, threats or violence. Respectful conduct is required at work, during business travel, at work events and in work related communications.

Human rights and fair employment

We prohibit child labour, forced labour, bonded labour and human trafficking. Employment must be voluntary. We do not retain identity documents or use deposits, recruitment fees or threats to prevent workers from leaving employment in accordance with lawful notice requirements. Young workers must receive appropriate protection and must not perform hazardous work.

We comply with applicable requirements on wages, benefits, working hours, overtime, rest and leave. We respect freedom of association and the right to collective bargaining in accordance with applicable law. Employees must be able to exercise these rights without intimidation or retaliation.

Safe operations

We identify and control risks to employees, contractors, visitors and neighbouring communities. Everyone must follow training, operating instructions, permit requirements and emergency procedures, and use the required protective equipment. No task should begin without the competence, equipment and controls necessary to perform it safely.

Particular care is required with chemicals, flammable substances, production equipment, maintenance, confined spaces, lifting and transport. Safety devices and safeguards must never be bypassed without an authorized and properly controlled procedure. Work must not be performed while impaired by alcohol, drugs or any condition that makes it unsafe.

Stop unsafe work and report hazards

Anyone who identifies an imminent danger must stop or withdraw from the unsafe activity, warn those affected and notify the responsible manager or health and safety personnel. Work may resume only when the risk has been assessed and controlled. Good faith safety interventions must not result in retaliation.

Report accidents, near misses, spills and unsafe conditions promptly. Preserve accurate incident information and cooperate with investigations so that root causes can be addressed. In an emergency, use the site emergency arrangements immediately; an ethics report is not a substitute for emergency assistance.

Contractors and visitors

Contractors and visitors must receive safety instructions appropriate to their activities and access only authorized areas. Those engaging contractors must communicate site requirements and ensure appropriate supervision and coordination.

2 Product responsibility and the environment

Quality throughout the product life cycle

We develop, manufacture, store and supply products under approved specifications and controls. We maintain batch identification and traceability, conduct the required tests and keep reliable records. Changes to formulations, raw materials, processes or packaging must undergo the relevant technical, quality and regulatory review before implementation.

Never alter test results, conceal a failed inspection or release a product outside approved requirements. Suspected safety or compliance issues must be escalated promptly to the responsible technical and quality personnel. Where warranted, affected stock or shipments must be held pending review and appropriate corrective action, including customer notification or recall when required.

Chemical stewardship

We assess chemical hazards and comply with applicable requirements for substances, mixtures, biocidal products where relevant, packaging and transport in the markets we serve. We use reliable supplier information and approved technical assessments to support safe handling, classification and regulatory decisions.

Labels, safety data sheets and technical data sheets must be accurate, current and consistent with the product and its intended market. Relevant precautions and limitations must be communicated in the required languages and formats. Staff must not give technical advice outside their competence or contradict approved safety instructions.

Honest product and environmental claims

Performance, durability, coverage, drying and suitability claims must have an appropriate basis. Statements about VOC content, toy safety, food contact, fire performance or certifications must accurately reflect the applicable evidence, test conditions and scope. A result for one product or application must not be presented as proof for an entire range.

Environmental claims must be clear, specific and supported by evidence. We do not describe a product as harmless, sustainable or environmentally friendly in a way that is misleading or omits material limitations. Marketing and sales materials must reflect approved technical information.

Preventing pollution and using resources responsibly

We work to prevent spills, uncontrolled emissions and contamination of water, soil and air. Chemicals and waste must be stored, labelled, handled and disposed of safely through authorized arrangements. Environmental permits, monitoring requirements and reporting obligations must be respected. Incidents and suspected noncompliance must be reported promptly.

We seek practical improvements in energy and water efficiency, material use, packaging and waste reduction. Our product development supports durable protection and responsible use of wood and other substrates. Environmental improvements must be assessed alongside product safety, performance and the impacts of the full intended use.

Listening to customers and communities

We respond fairly to complaints and investigate their causes. We take concerns about our products and operations seriously, communicate accurately and use feedback to improve our practices.

3 Conducting business with integrity

Bribery and improper payments

We prohibit bribery, kickbacks and facilitation payments. No one may offer, promise, give, request or accept money or another advantage to improperly influence a decision or obtain an unfair benefit. This applies to dealings with private businesses and public officials, directly or through intermediaries. Commissions and service fees must relate to legitimate services and be properly documented.

Gifts and hospitality

Cash and cash equivalents, including gift cards, must not be offered or accepted as personal gifts. Modest, occasional business meals and symbolic gifts may be appropriate when lawful, transparent and consistent with a legitimate business purpose. They must not influence, or appear intended to influence, a decision.

Gifts or hospitality beyond this standard require prior written management approval. Offers during tenders, purchasing decisions or sensitive negotiations require particular caution. Dealings with public officials require prior management review and compliance with applicable restrictions. Record relevant expenses accurately and decline or report anything that could compromise independent judgment.

Conflicts of interest

Disclose personal, family, financial or outside business interests that could affect, or appear to affect, a HEMEL decision. Examples include selecting a relative’s company, holding an interest in a supplier or competitor, or taking outside work that conflicts with HEMEL responsibilities. Do not participate in the affected decision until an independent reviewer has assessed the conflict and documented the safeguards.

Fair competition

We make commercial decisions independently. Never agree with competitors on prices, discounts, margins, customers, territories, bids or production levels, or exchange competitively sensitive information. If an inappropriate discussion begins, object, leave and report it. Trade association meetings and informal conversations are subject to the same standards. Distribution arrangements and resale pricing practices must comply with applicable competition rules.

Trade controls and financial crime

We comply with applicable sanctions, export controls, customs and import requirements. Relevant transactions must be checked for restrictions on counterparties, destinations, products and end uses. Never misstate origin, value, classification or the parties to a transaction, or route business through another party to evade restrictions.

We do not facilitate money laundering, fraud or other financial crime. Know who we are doing business with and verify payment details through approved procedures. Unexplained third party payments, unusual refund requests and inconsistent documentation must be referred to Finance and management before proceeding.

Political activity and community contributions

HEMEL does not make financial or in kind contributions to political parties or candidates. Employees may participate personally in lawful political activity using their own time and resources without presenting their views as HEMEL’s. Charitable donations and sponsorships require prior CEO approval, a legitimate purpose, appropriate recipient checks and accurate records. They must never conceal an improper advantage.

4 Protecting information and business relationships

Accurate records and responsible use of assets

All financial, operational and technical records must be complete, accurate and timely. This includes invoices, expenses, working time, quality tests, environmental data and incident reports. Never create false entries, undisclosed accounts or misleading documents. Follow approval controls and retain records under applicable requirements. Do not destroy or alter records relevant to an investigation or legal preservation instruction.

Use company funds, equipment, systems and intellectual property for authorized purposes. Protect assets against theft, fraud, waste and misuse. Purchasing and payment decisions must be supported by genuine business needs and adequate documentation.

Confidential information and intellectual property

Protect formulations, research, manufacturing knowledge, pricing, commercial plans and confidential customer or partner information. Share information only with authorized people who have a legitimate need to know. Confidentiality obligations continue after employment or a business relationship ends, subject to applicable law and protected reporting rights.

Respect the intellectual property and confidential information of others. Do not obtain competitors’ information through deception or ask new employees to disclose a former employer’s secrets.

Personal data and digital security

Collect, use and retain personal data only for legitimate, specified purposes and in accordance with applicable privacy requirements. Limit access, maintain suitable security and use approved transfer and storage arrangements. Report suspected data breaches, phishing, lost devices and unauthorized access promptly through the relevant internal channels.

Use approved systems and follow security instructions. Do not upload confidential formulations, personal data or other restricted information to unapproved cloud services or artificial intelligence tools. Outputs from digital tools must be checked before they are used in technical, commercial or other business decisions.

Responsible business partners

We choose suppliers, contractors, agents and distributors using objective criteria such as quality, safety, reliability, integrity and value. Checks must be proportionate to the relationship and its risks. We communicate relevant expectations on lawful conduct, labour rights, safety and the environment, and do not use third parties to avoid our own responsibilities.

Concerns about a partner must be reviewed and addressed through appropriate corrective action. Serious or unresolved misconduct may lead to suspension or termination of the relationship, subject to applicable law and contractual rights. Partners should raise concerns about conduct connected with HEMEL through the reporting arrangements in this Code.

Clear and authorized communication

We communicate honestly with customers, authorities and the public. Only authorized representatives may speak on HEMEL’s behalf. Personal social media activity must not disclose confidential information or imply unauthorized company endorsement. We cooperate appropriately with lawful requests from authorities and involve the responsible management personnel.

5 Speaking up and making this Code effective

How to raise a concern

Employees, customers, suppliers and other stakeholders may report suspected misconduct connected with HEMEL by email to ethics@hemel.com.tr. Reports sent to this address are received by HEMEL’s Ethics Committee, a small group of designated senior managers. Employees may also speak to their manager or to any member of the Ethics Committee. Reports should describe the concern and provide relevant dates, people and supporting information where available. Proof is not required before reporting a genuine concern.

A person must not review or control a concern about their own conduct. If a concern involves a member of the Ethics Committee, that member is excluded from its handling. Concerns involving the CEO or a member of the Board of Directors are referred by the Ethics Committee directly to an uninvolved member of the Board of Directors, without prior disclosure to the person concerned. No one is required to report through the person concerned.

Confidentiality and protection from retaliation

We handle reports discreetly and limit access to those who need the information to assess and address the concern, subject to applicable legal requirements. Absolute confidentiality cannot be promised where disclosure is necessary for a fair investigation or required by law. A report without a name will be considered, although missing contact details may limit follow up.

HEMEL prohibits retaliation against anyone who raises a concern in good faith, seeks advice or participates honestly in an investigation. Protection applies even when the concern is not substantiated. Retaliation includes threats, dismissal, demotion, harassment and other adverse treatment because of reporting. Suspected retaliation should be reported promptly and will be reviewed separately. Knowingly false allegations are not protected by this principle.

Fair review and corrective action

The Ethics Committee coordinates the initial assessment, except where independence requires another reviewer. Concerns must be handled impartially, promptly and with appropriate expertise. Those involved must cooperate honestly, preserve relevant records and respect the confidentiality and rights of others. Findings should lead to proportionate corrective action and improvements to prevent recurrence.

Breaches may result in disciplinary action, up to dismissal, or action concerning a business relationship, in accordance with applicable law and contractual rights. Serious matters may require notification to authorities. Nothing in this Code prevents lawful reporting to authorities or restricts rights protected by law.

Implementation and oversight

The CEO approves this Code and its material revisions. Human Resources coordinates communication and implementation with the relevant functions. Managers are responsible for applying the Code within their areas. Employees should receive the Code at induction and when it changes, together with guidance appropriate to their roles. Communication, training and acknowledgements should be recorded.

Management reviews this Code periodically and after significant changes in operations or applicable requirements. Interpretations or exceptions must be documented and approved by an uninvolved authorized decision maker. No exception may authorize unlawful conduct, bribery, retaliation or concealment of safety risks.

Policy owner: Human Resources

Approval authority: Chief Executive Officer

Effective date: 13 October 2026