Grievance and Whistleblower Protection Policy

Effective Date: May 2025
Last Reviewed: May 2025
Applies To: All employees, contractors, clients, partners, and external stakeholders

1. Purpose

This document establishes a comprehensive grievance mechanism and whistleblower protection policy for S360 Sürdürülebilirlik ve İletişim Hizmetleri Anonim Şirketi. Our goal is to create a safe, transparent, and supportive environment where stakeholders can confidentially raise concerns about potential misconduct, unethical behavior, or systemic issues without fear of retaliation.

2. Scope

This policy applies to:

• Current and former employees
• Interns and contractors
• Clients and suppliers
• Business partners and external stakeholders
• Any individual impacted by S360's operations or activities

3. Grievance Mechanism

3.1 Submission Channels

Grievances can be submitted through multiple confidential channels:

Dedicated Grievance Email:

• Email: ethics-grievance@s360.com.tr
• Monitored exclusively by the Ethics Review Committee
• Guaranteed confidential processing

Secure Anonymous Reporting:

• Online Submission Form: [Secure Anonymous Reporting Link]
• Ensures complete anonymity
• Encrypted and secure transmission

In-Person Reporting:

• Direct consultation with the Ethics Representative
• Confidential open-door policy
• Option for face-to-face discussion

3.2 What Can Be Reported?

Individuals can report:

• Workplace misconduct or unethical behavior
• Harassment, discrimination, or bullying
• Violations of internal policies or legal requirements
• Environmental or social risks caused by S360 or its partners
• Adverse impacts associated with work in controversial industries
• Potential conflicts of interest
• Financial irregularities or fraud
• Health and safety concerns
• Violations of human rights

3.3 Grievance Processing

Ethics Review Committee

• Composition:
  • (CEO)
  • (HR Director)
  • (Sustainability Manager)
  • (Legal Counsel / External Ethics Advisor)
  • One rotating independent committee member

Process Overview

1. Acknowledgement of grievance

Confirmation of receipt of grievance

Within 5 working days

2. Initial review and assessment

Initial assessment, request for more info (if needed)

Within 10 working days

3. Investigation (if applicable)

Fact-finding and discussions with relevant parties

Within 20 working days

4. Resolution and feedback

Communication of outcomes and actions taken

Within 30 working days from receipt

3.4 Resolution Principles

• All grievances will be treated with seriousness and confidentiality
• Resolutions will comply with Turkish laws and international standards
• Transparent communication with the complainant (if contact information is provided)
• Clear rationale will be provided if a grievance is not accepted

Potential outcomes may include:

• Internal disciplinary action
• Policy or process improvements
• Mediation
• External expert consultation
• Reporting to appropriate authorities

3.5 Confidentiality and Non-Retaliation

Confidentiality Guarantees:

• Strict protection of complainant's identity
• Explicit consent required to share information
• Anonymity options always available

Non-Retaliation Commitment:

• Zero tolerance for any form of retaliation
• Disciplinary action against anyone attempting to retaliate

Protection extends to:

• Direct employees
• Contractors
• External stakeholders
• Witnesses

4. Whistleblower Protection Policy

S360 is committed to protecting individuals who report concerns in good faith. This policy ensures whistleblowers can report without fear of retaliation.

4.1 Protection Measures

- Strict confidentiality of the whistleblower’s identity
- Consent required to share information with others involved
- Assessment of risks to whistleblowers

4.2 Prohibited Retaliation

- Dismissal, demotion, harassment, or exclusion of whistleblowers is strictly prohibited
- Any act of retaliation will result in disciplinary action

4.3 Investigation and Follow-Up

- Whistleblower reports are treated as formal grievances
- Outcomes may be shared confidentially with the whistleblower

4.4 Roles and Responsibilities

- The Ethics Representative (appointed by management) manages the grievance and whistleblower process
- External experts may be consulted where necessary

5. Review and Transparency

- This policy is reviewed annually. If material changes to operating procedures are required, the procedure may be updated on an “as required” basis.
- Summary data (anonymized) may be published in sustainability reports or on the website

Contact:
For questions or submissions: ethics-grievance@s360.com.tr

S360 Grievance Collection Form