Zero tolerance policy towards violence 

PURPOSE

Our bank guarantees the equality of opportunity for our employees and partners within the framework of our sustainability vision and strategies, and the implementation of policies that raise and maintain awareness of an inclusive corporate culture.

In the light of these commitments and our diversity and inclusion approach, we are aware that it is important for an individual to stay and feel safe at home and work, and, within this scope, we stand against all kinds of violence and exploitation; two critical issues which put safety at risk.

In order to create a safe and supportive working environment for all our employees, we have set out the principles and approaches in this policy document to prevent any kind of violence and the steps to be taken if and when faced with such behavior, towards which we will show zero-tolerance.

SCOPE

The processes, enforcements, and support mechanisms in this document cover all employees of Akbank and its affiliates.

RESPONSIBILITIES

REFERENCES

The zero-tolerance policy towards violence has been designed in consideration of the relevant bank policies and principles, legal regulations, and application resources published by international organizations.

• Bank policies and code of practice
  • Akbank Sustainability Strategy
  • Principles of Corporate Governance
  • Human Rights Policy
  • Policy of Diversity and Inclusion
  • Ethics
  • Code of Practice for People
  • Disciplinary Regulations

• Principles and policies of national and international organizations
  • Practical Guide of the United Nations Global Compact on Women's Empowerment Principles (WEPs)
  • Policy Brief of the United Nations Turkey: The Impact of COVID-19 on Women
  • Handbook for Addressing Violence and Harassment against Women in the World of Work
  • Guide for Safe and Healthy Working Environments Free from Violence and Harassment
  • Republic of Turkey Ministry of Labor and Social Security Information Guide on Mobbing at Workplaces

• Relevant legal regulations

FACTORS THAT HARM SAFETY

A safe living and working space is one of the most important human rights. Violence and exploitation that harm individuals' safety or intrude on their comfort zone through physical or psychological damage or domination can be seen in different forms.

Physical violence: Using physical power as a tool of violence to control, dominate, humiliate, insult, or punish a person. It can be inflicted by gaining physical superiority, touching the body, using an object, or causing fear that these might take place.

Examples of physical violence include yelling at, punching, kicking, injuring with a weapon or knife, throwing an object, depriving someone of their basic needs through physical superiority, or causing fear that these might take place.

Psychological violence: Using emotional power or needs to control, dominate, humiliate, insult, or punish a person.

Examples of psychological violence include exhibiting humiliating and threatening behavior in a systematic way, making a person feel incompetent and weak, making fun of them, swearing and insulting, and isolating them by preventing them from meeting others.

Psychological violence can emerge at a workplace by systematically, constantly, and deliberately:

• Insulting or yelling at a person
• Humiliating, mocking, and making fun of their efforts and ideas in front of their colleagues
• Treating a person differently from everyone else or discriminating against them
• Trying to stigmatize them in their colleagues' eyes
• Ignoring, externalizing, or casting them out
• Threatening or punishing them
• Causing them to fail by assigning tasks that are impossible to complete within the given time
• Manipulating or misleading them into hiding critical information regarding their work, and then accusing them of negligence or professional misconduct.

To prevent psychological violence/mobbing, it is important that psychological safety is ensured. Psychological safety can be defined as minimizing or removing the risk of professional factors being used to harm the employees' mental health.

Sexual violence: Forcing a person to have sexual intercourse in a place, manner, or time that they do not agree to or using sexually explicit language, harassing them, or attacking them.

Likewise, harassing a person physically or verbally, using sexually explicit language, innuendo, or jokes are deemed to be sexual violence.

Examples of sexual violence include physically harassing a person, taking sexually explicit images without their consent, distributing these images or threatening to do so, forcing female individuals to give, or not give, birth to a child. The marital status of a person does not change the definition of violence.

Economic violence: Using financial power and superiority as a tool of violence to control, dominate, humiliate, insult, or punish a person.

Examples of economic violence include preventing a person from wor king or having a profession; seizing, controlling, or trying to control their income and savings; burdening them with debt; and preventing them from making savings or investing in something.

Digital violence: Using technological devices to control, dominate, humiliate, insult, or punish a person.

Examples of digital violence include constantly sending messages or calling a person even though they do not want to be contacted, checking their social media accounts and stalking them using the information on such accounts, threatening them, humiliating them on social media, and sharing content with insults and hateful speech.

SUPPORTIVE POLICIES FOR SAFETY AT HOME

The most important factor which damages or disregards the feeling of safety at home is domestic violence. Domestic violence is considered a global issue affecting numerous people, most of whom are women, all around the world.

That is why Akbank assumes responsibility for the designatio n of the necessary processes and support channels to provide all kinds of assistance and protection for the employees who claim that they have been exposed to domestic violence. In addition to the support provided by social organizations, Akbank, as an employer, guarantees to take the action required to ease the working life of the employees who are victims of violence, and to increase workplace safety.

Within this scope, and in order to encourage the victims of violence among our employees to take the necessary action to rid themselves of the cycle of violence, we have created - and informed our employees of - genuinely private support channels that they can use, without hesitation, to contact us about their situation.

When a victim of domestic violence informs Akbank of such an occurrence and requests support, the supportive actions to be taken are listed below. Supportive processes are carried out with the victim's consent and in complete confidentiality.

• If there is any protection or restraining order in place for the sake of the victim, we also provide the support listed below to implement such orders in the workplace. Workplace safety planning is reconsidered with the employee and based on their needs.
  • Where the location permits, the employee's working space can be re-arranged so as to be invisible from outside or not in a public place.
  • Information regarding the employee, such as working location, office phone number, and email address, can be changed.
  • To prevent the person who uses violence from misappropriating the employee's salary and fringe benefits, employee bank account information can be changed.
  • When possible, the route of the service vehicle that they take to go to work can be re - arranged.
  • Security guards can accompany them to public transportation vehicles or the service vehicles provided by the workplace.
  • Where the location permits, a personal vehicle parking service can be provided and the employee can be accompanied by security guards on the way to their car.

• To meet the security, psychological, or health needs of the victim of violence, their working model (at the office, hybrid, or remote) is re-considered according to their needs.
• The employee can be given paid administrative leave without affecting leave rights. The employee takes part in deciding the duration of such leave.
• If it is a period of performance assessment, a special performance assessment process can be carried out without ignoring the status of the employee, or the performance assessment can be postponed to another date to be determined with the employee.
• Via the contractual applications and platforms of the bank, psychological support can be provided to the employee based on their needs.

Besides, if an employee has been confirmed by a court verdict to have co mmitted domestic violence, the professional relationship between the bank and the employee will be evaluated. Likewise, during the hiring process, the bank will evaluate if a professional relationship between the bank and candidates with such a record can be established.

SUPPORTIVE POLICIES FOR SAFETY AT WORK

Failure to create a physically and psychologically safe working environment has an impact not only at the personal level but also at the corporate and social level.

Actions of violence and exploitation which damage the status and feeling of safety at work might occur from top to bottom (from executives to subordinates), from bottom to top (from subordinates to executives), or horizontally (among those who are in equal level positions).

Employees may keep silent in the face of these behaviors and approaches because they do not want to harm their professional relationships, fear losing their job, worry that nobody will believe them, or want to avoid looking incompetent or lacking in self-confidence.

To prevent such incidents, at Akbank, we implement a “zero tolerance” approach towards any kinds of violence, exploitation, and behavior that damages the creation of a safe working environment.

Within this scope, we have created and informed our employees of genuinely private support channels that they can use, without hesitation, to contact our bank about their situation.

We have set principles for the process to be carried out if violence is faced in the workplace and it is reported:

• Employees can report incidents directly to the Support Line.
• Employees can make their managers aware of the issue. In these cases, the relevant managers should immediately contact the HR department and ask for support to put the necessary process into practice.
• Notifications made directly by the employees to the Support Line or received through their managers are taken under review within 24 hours with the principle of complete confidentiality.
• During the notification review process:
  • Changing the working location, team, or task can be considered based on the needs of the victimized employee.
  • The employee's working model, whether full-time at the office, hybrid, or fully remote can be re-considered.
  • Within the periods to be determined and based on the needs of the employee, paid annual leave or administrative leave can be considered.
  • If it is found that the victimized employee has suffered a loss of material rights due to the act of violence, compensation for the loss of material rights can be considered.
  • If a person who has committed violence is reported, paid annual leave or administrative leave during the process can be considered.

• Via the contractual applications and platforms of the bank, psychological support can be provided to the employee based on their needs.
• If it is a period of performance assessment, the person who will carry out the assessment can be re-considered, or the performance assessment can be postponed to another date to be determined with the employee.
• Assessment results are discussed with the employees who have made the report and information on the results is shared with them.
• The right of the employee to take legal action regarding the subject is always reserved. There is absolutely no direction given to the employee regarding not taking legal action or keeping the matter confidential.
• If necessary, the issue can be transferred to the Inspection Board Unit. As a result of the assessments of the Inspection Board Unit, if an employee is found to have behaved in a way that damages or destroys safety at the workplace, action will be taken within the framework of the codes in our "Disciplinary Regulations" document.

AWARENESS and TRAINING

Raising people's awareness of the issue is a crucial factor in preventing all kinds of violence. To heighten sensitivity among Akbank employees to the issue and inform them of what to do when possible incidents occur:

• "Gender Equality Training" is initiated, and access granted to all employees to raise awareness of gender roles and gender equality.
• "Awareness of Prevention of Violence" training is provided to all employees to strengthen the steps that need to be taken to prevent violence and to provide guidance on what to do in such cases.
• Mandatory training programs regarding "Gender Equality" and "Prevention of Violence" are provided to the staff members who are responsible for implementing the policy.
• Leaders whose important roles and responsibilities include the provision of safety in the workplace and the prevention of all kinds of violence receive mandatory training programs regarding the "Prevention of Violence."

SUPPORT CHANNELS

a.      Support Channels Outside the Company

Some of the support channels outside the company that people can apply for, or direct people to, are as follows:

• Emergency Lines
  • ALO 183 Social Service Line for Family, Women, Children, and the Handicapped
  • ALO 155 Police Emergency Line
  • ALO 156 Gendarmerie Emergency Line
  • ALO 170 Work Life Communication Center
  • ALO 112 Ambulance Emergency Service Line
  • Domestic Violence Emergency Line
  • Istanbul Metropolitan Municipality (IBB) Support Line for Women

• Non-Governmental Organizations
  • Mor Cati Women's Shelter Foundation
  • End Domestic Violence Emergency Line

b.      Corporate Supportive Channels

We have created the "Zero-Tolerance Support Line" for employees who say that they have been subject to domestic violence or violence in the workplace. We work with the principles below for the assessment of reports made to the support line and/or by the relevant managers:

• To contact the support line, please send your email to sifirtolerans@akbank.com.
• Notifications made to the support line are taken under review within 24 hours at the latest.
• All assessments are carried out within the framework of complete confidentiality. No information is transferred to anyone about the person making the report, except for the employees in the assessment team.
• o The issue can be transferred to the Inspection Board Unit, and as a result of the assessments of the Inspection Board Unit, if an employee is found to have behaved in a way that damages or destroys safety at the workplace, action will be taken within the framework of the codes in our "Disciplinary Regulations" document.
  • The assessment is carried out by the EVP of People and Culture, the relevant HR department heads, and the manager responsible for the Work Relations team without favoring any hierarchical level. According to the assessment,
  • The issue can be transferred for review by the CEO and as a result of the assessment, actions will be determined and taken.

• Notices and actions are periodically reported to the Sustainability Committee anonymously.