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Corporate

Code Of Conduct

At CBC Law, we are fully committed to the highest ethical and professional standards. Our law firm’s reputation is based on ethics, quality, integrity, transparency and accountability. We believe how we achieve success is more important than just achieving that success. Our principle is “doing the right thing even when nobody is watching”. As the core principle of our culture, we put business ethics, ethical decision making and ethical leadership at the heart of what we do. We maintain the highest standards of honesty, integrity and fairness, make the right decisions, take responsibility and are accountable, to achieve our vision of being one of the trusted global legal organizations of choice to positively impact our clients, stakeholders and society. Our value and understanding of compliance go beyond just rules and regulations, but nourished with the highest standards of ethics. 

We are committed to be aware of and to fully comply with applicable laws, regulations and the values, principles and rules of the communities and organizations we are serving for. We always keep in mind that we are representing our clients in various legal venues in which our operations are subject to a wide variety of laws, regulations (including guidance issued by regulatory authorities), and industry codes. This Code of Conduct (“Code”) is based on our values and ethical culture, and sets out our core standards for how we conduct business – every day, everywhere across a broad range of subject areas. Our Code is intended to promote a compliance culture within CBC Law helping to guide us to make the right decisions when we encounter ethical dilemmas. The Code is not an exhaustive description of our expected behavior and is supported by additional policies and procedures. We expect everyone working in our firm, business partners, clients, and all our external stakeholders to respect and comply with the fundamental values, standards, and principles stated under our Code, to take personal responsibility to act with the highest sense of integrity, transparency, accountability and use of good judgment. Our Code is an evolving document and may be updated over time to reflect changing laws or expectations of stakeholders.

Our Culture:

  • People: Our team culture values difference, fosters inclusion and promotes collaboration and diversity.
  • Integrity and Transparency: We build trust within our organization, with our clients and with society by being honest and open about what we do and how we do it. We are duty bound by our strong moral principles to do the right thing for clients in all circumstances.  We recognize the paramount importance of integrity, transparency, the highest standards of ethical conduct, and accountability in all our activities, and believe that integrity and transparency are essential to building and maintaining trust with our clients, regulatory authorities, and the public. We are committed to upholding these values in all aspects of our business operations and to continuously improving our performance to meet the highest ethical standards. To this end, we,:
    • Foster a culture of transparency, accountability, and continuous improvement within the firm, where ethical behavior is valued, encouraged, and rewarded.
    • Provide regular training and education to our partners, employees, and stakeholders on the importance of integrity, transparency, and ethical behavior in all our business activities.
    • Encourage the reporting of any concerns or suspicions about potential breaches of our ethical standards, without fear of retaliation or discrimination.
    • Establish and maintain appropriate internal controls, conduct regular reviews and assessments of our compliance with this commitment and make necessary adjustments to ensure ongoing effectiveness.
  • Ethical Leadership: We are committed to upholding the highest standards of ethics, ethical decision making and ethical leadership in all of our business dealings, both inside and outside the firm. We think beyond the laws and regulations, and take ethics as the benchmark for our way of thinking and behaving. We treat our clients, colleagues, and competitors with respect, fairness, and honesty.
  • Compliance with Laws and Regulations: We comply with all applicable laws, regulations, and ethical guidelines governing our profession. We do not engage in any unlawful or unethical conduct, including any form of discrimination or harassment.
  • Continuous Learning and Improvement: We continuously improve our knowledge, skills, and abilities, and stay up-to-date with the latest developments and trends in our profession. Our commitment to the growth and development of our people is paramount. We hold our lawyers and other business services personnel to a high standard of familiarity with their respective expertise areas, personal qualities, and performance expectations for their level of work. Our supervisors are responsible for providing clear performance expectations, offering training and development opportunities, and delivering regular feedback. We ensure that everyone under our supervision receives a formal performance review at least once a year. We regularly encourage and support all our lawyers to undertake both internal and external training appropriate to their roles and responsibilities.
  • Diversity, Inclusion and Equality:  We treat our employees, interns, business partners, clients, and all other stakeholders fairly, equally and respectfully. We expect all of our stakeholders to demonstrate respect toward each other and we do not tolerate any form of harassment or discrimination. We seek to create an inclusive work environment where our employees regardless of their backgrounds can contribute fully. We appreciate the diversity and individuality of our stakeholders and do not discriminate based on personal characteristics such as nationality, gender, age, ethnicity, religion, sexual orientation, or disability. We attract, develop, and retain highly talented people with diverse backgrounds and inclusive mindsets.
  • Healthy and Safe Work Environment:
    • CBC Law is committed to provide a healthy and safe workplace that is free from all forms of harassment. We believe that every employee should be able to come to work without fear of intimidation, discrimination or any other form of misconduct.
    • We expect all our employees to adhere to the highest standards of professionalism and ethical conduct. We do not tolerate any behavior that may lead to harassment or create a hostile work environment. This includes, but is not limited to, harassment based on race, ethnicity, gender, sexual orientation, age, disability or any other protected status.
    • We provide training and education to our employees, promoting an open-door policy for reporting incidents and promptly investigating all complaints of harassment or other misconduct. We encourage all employees to speak up if they experience or witness any inappropriate behavior in the workplace. We take all complaints seriously and take appropriate action to address any reported incidents of harassment, discrimination or retaliation.
    • We are committed to promoting a work environment that is respectful, inclusive and supportive of all our employees. We believe that fostering a culture of mutual respect and understanding is essential to the success of our firm, and we strive to ensure that every employee feels safe, valued and empowered to contribute to our shared goals.
  • Conflict of Interest: CBC Law is committed to conducting its business throughout the world in accordance with high ethical standards and applicable laws, regulations, industry codes, policies and procedures. Our policy is designed to ensure that all CBC Law personnel act in the best interests of CBC Law and its clients, avoiding situations that present or create the appearance of actual, potential or perceived conflicts of interest. We avoid any conflict of interest in our work, and disclose any potential conflicts to our clients promptly. We do not represent any client whose interests conflict with those of another client, or the firm itself.
  • Speak-Up Policy: At CBC Law we believe that every employee within our organization has the right and obligation to report their concerns without any reprisals. We operate in a transparent environment with an ethical decision-making process in every phase of our services. Our firm truly values the help of employees who identify and speak up about potential concerns. Speaking up is encouraged and employees who speak up are protected. CBC Law does not tolerate any form of retaliation against our employees for speaking up. Speaking up is essential for us to sustain our reputation, long-term success and proactive risk management process.

CBC and Clients:

  • Client Focus: We strive to offer the best legal and compliance services for the long-term benefit of our clients.
  • Accountability and Responsibility: We take responsibility for our actions and decisions, and are accountable to our clients, colleagues, business partners and all of our stakeholders for the quality of our work and the outcomes we achieve.
  • Quality: Our strength comes from the quality of our people, experience, service, and diligence. Our principle of assignment is based on experience, legal sufficiency, and proficiency. In every step, we instruct, supervise and appropriately ensure we do the things in the right way. 
  • Independence and Objectivity: Independence is the core of our standards. We are committed to protect our independent and unbiased approach to our clients. We maintain the highest level of objectivity in our work, and avoid any actions that could compromise our professional judgment or reputation.
  • Confidentiality and Privacy: We maintain the strictest confidentiality and respect the privacy of our clients, their businesses, and their personal affairs. We do not disclose any confidential information to any third party without the client's express consent, except as required by law.
  • Communication:  We communicate clearly, openly, regularly, and timely with our clients, colleagues, and stakeholders, and maintain ongoing and transparent communication in the overall of our actions and decisions. We ensure that all communications and representations made to clients, regulatory authorities, and the public are truthful, accurate, and complete.
  • Time Recording and Billing:  At CBC Law, we are committed to providing fair and transparent billing to our clients. We charge only for the work performed and provide clear, itemized invoices that accurately reflect the time and expenses incurred. We strive to work efficiently and effectively to provide cost-effective solutions for our clients' legal needs.
  • Chinese Wall Policy: We recognize the importance of maintaining strict confidentiality and protecting sensitive information from any potential conflict. Our lawyers work in different teams with restricted communication and access between the teams. We prevent confidential information from being improperly disclosed, accessed, or shared between individuals within the firm. We ensure that confidential information is not shared between teams working on different matters, particularly if those matters may create a conflict of interest. 
  • Third Party Risk Management - A Chain is as Strong as the Weakest Link: 
    • A globalized economy means globalized regulations. More organizations need to examine their third-party vendors, service providers and supply chain in order to assess the level of risk, inform their decisions and to ensure they comply with laws. Failure to adequately assess third-party and fourth-party risk exposes organizations to reputational risk, operational risk, cyber risk, government inquiry, monetary penalties and criminal liability. Third party actions are deemed to be the actions of the organization so: “We weren’t aware of that” is no longer a valid defense.
    • At CBC Law we provide third party risk management solutions to our clients and apply the same principles when interacting with third parties. Our vendors and strategic partners are subject to third party risk management and constant due diligence. We are aware that we are not only defending best legal interest of our clients but also their reputation.

CBC and Responsible Business

Human Rights: 

At CBC Law, we believe that respect for human rights is fundamental to our business and the communities where we serve. We are committed to upholding the principles of human rights in all aspects of our services, and to promoting human rights among our clients and partners. At CBC Law, we recognize that the protection and promotion of human rights is a shared responsibility. We are committed to working with our employees, clients, partners, and other stakeholders to ensure that our operations are in alignment with human rights principles and to continuously improve our human rights performance.

To demonstrate our commitment, we:

  • Respect Human Rights: We respect the human rights of all individuals, including our employees, clients, partners, and the communities where we operate. We do not tolerate any form of discrimination, harassment, or abuse, and we strive to ensure that our operations do not contribute to human rights violations.
  • Conduct Due Diligence: We conduct due diligence to identify and assess any actual or potential adverse human rights impacts of our operations. We take appropriate steps to mitigate these impacts and continuously monitor and evaluate our efforts to ensure that we are upholding our commitment to human rights.
  • Provide a Safe and Fair Workplace: We provide a safe and fair workplace for all employees, free from discrimination, harassment, and abuse. We respect the rights of our employees to freedom of association and collective bargaining, and ensure that our employment practices are in compliance with applicable laws and regulations.
  • Support Human Rights Initiatives: We support human rights initiatives that align with our values and contribute to the well-being of the communities where we operate. We work with our clients and partners to promote respect for human rights in their operations and encourage the adoption of ethical business practices.
  • Speak-Up: We maintain an open and transparent dialogue with our employees, clients, and stakeholders about human rights issues. We encourage and support employees to raise concerns about potential human rights violations without fear of retaliation, and we take appropriate action to address any such concerns.

Modern Slavery and Human Trafficking Statement:

We recognize the importance of taking a strong stance against modern slavery and human trafficking. We are committed to ensure that our business practices and operations are free from any form of exploitation, including forced labor, human trafficking, and other human rights abuses.  As a responsible business, we take our responsibilities seriously to prevent modern slavery and human trafficking in our business, conduct due diligence and ongoing monitoring to identify any potential risks of modern slavery and human trafficking in any chain of the business. We expect the same high standards from all of clients and business partners. 

Sustainability:

At our firm, we are committed to sustainability and recognize the importance of incorporating sustainable practices into our operations. We believe that a responsible business approach, which prioritizes environmental, social, and governance considerations, is critical to creating a sustainable future for our company and the communities in which we operate.  We understand the significance of environmental sustainability to our workforce, clients, and the societies where we conduct our operations. As a result, we collaborate with our best endeavors to minimize energy consumption and conserve natural resources by reducing, reusing, and recycling. We also encourage the integration of sustainability into our business strategies, service models, and internal processes to help achieve our environmental goals. 

Environmental, Social, & Governance:

Our team of highly experienced lawyers support organizations and high net worth individuals who are active in Turkey, helping them to meet their Environmental, Social, & Governance (“ESG”) focused business needs and goals.

As a leading full-service law firm in Turkey working across a range of industries, we anticipate the changes that arise from an ever-evolving ESG landscape, which allows us to develop effective solutions for our clients. We achieve this by having a considered understanding of all the regulatory and legislative drivers of the market in Turkey across a wide range of sectors. We take a holistic approach, that embodies everything from climate change and resource efficiency to human rights, anti-bribery and anti-corruption, responsible corporate governance, data privacy, business ethics and general risk management.

We advise a diverse range of clients on varied ESG initiatives helping them to meet and exceed new and evolving standards across a broad range of industries. We collaborate with third-party ESG experts to provide clear, versatile, and integrated advice on various ESG relevant topics, including but not limited to the following: 

  • Evaluating due diligence processes for clients on ESG focus areas with a view to advising on developing ESG governance roadmaps and strategies.
  • Compliance with a range of environmental regulations, including those relating to climate change, water, waste and air toxics, etc.
  • The adoption and implementation of global ESG standards considering their potential foreign investment opportunities.
  • Developing and implementing ESG-related investment policies and investor engagement documentation with respect to ESG matters in Turkey.

CBC Law’s ESG priorities comprise, but are not limited to:

  • Prioritizing our team’s health and wellbeing. Taking action to help and collaborate with the wider communities that we engage with.
  • Transparency in how we help our clients to improve their business performance with an ESG-focused approach that encourages financial stability, and responsible long-term growth.
  • Ownership and accountability for the way that we conduct business.
  • Increasing our work focus on ESG and the changing expectations of the corporate world so that we respond appropriately in a variety of situations.
  • Committing to consistent high performance, specifically in terms of delivering sustainable ESG strategies to clients.
  • Doing the right thing in every situation defines who we are. Integrity is a key component of everything we do.
  • Client guidance that is based on extensive legal, compliance and consulting experience along with key external research benchmarks and standards.
  • Continually seeking opportunities to reduce our own environmental impacts through energy and resource efficiency, waste prevention, sustainable travel, and supply chain engagement.

Anti-Bribery-Anti-Corruption (“ABAC”) Commitment: 

CBC Law is fully committed conducting business with integrity and in compliance with all applicable laws and regulations. We recognize that bribery and corruption pose serious risks to our business, reputation, and the communities where we operate. CBC Law does not only provide high quality advice for ABAC compliance & laws, we also place the fight against bribery and corruption at the heart of our business. We comply with all applicable ABAC laws, including but not limited to the U.S. Foreign Corrupt Practices Act (“FCPA”), UK Bribery Act (“UKBA”), French Sapin II, Brasil Clean Company Act and also Turkish Criminal Code and applicable regulations. 

It is strictly forbidden for all CBC Law employees and third parties to give or receive a financial or other advantage in connection with the “improper performance” of a position of trust, or a function that is expected to be performed impartially or in good faith. This prohibition includes any facilitating, expediting or grease payments made to government officials or private parties, directly or indirectly, either in order to expedite any official service or function.

We recognize that our reputation and success depend on our commitment to conducting business with integrity and transparency. We are committed to upholding high ethical standards in all of our operations and continuously monitor and evaluate our efforts to ensure that we are upholding our commitment to anti-bribery and anti-corruption.

To uphold our commitment to anti-bribery and anti-corruption, we adopted the following principles:

Zero Tolerance:

We have a zero-tolerance policy for bribery and corruption in all of our business activities, and we do not tolerate any form of bribery or corruption, either directly or indirectly.

Maintaining Accurate Books and Records:

No payment by or on behalf of CBC Law shall be approved or made if any part of the payment is to be used for an unlawful or improper purpose, or for any purpose other than that described by valid documents supporting the payment. No false or misleading entries are permitted in any CBC Law documents or financial records for any reason.

Expenditures related to Government Officials:

No funds may be provided to or spent on behalf of a government official or entity, directly or indirectly, without advance written approval from CBC Law management. This includes any payments, gifts, donations, charitable contributions, sponsorships, entertainment, travel, meals, or any other items of value.

Please note that the term "government official" is widely defined and may include individuals who are employed by any public or state-affiliated institution or organization or who act in an official capacity in any way, whether full-time, part-time or unpaid.

Commercial Bribery:

In addition to prohibiting bribery of government officials, CBC Law also prohibits its employees and third parties from engaging in bribery of private parties as outlined in UKBA.

Zero Gifts Policy:

We have a zero-gift policy for all employees, clients, and partners to prevent any influence that gifts may have on decision-making processes. We believe that our work should be based on professional skills, not on the exchange of gifts or favors.

Conduct Due Diligence:

We conduct due diligence to identify and assess any actual or potential risks of bribery or corruption in our operations. We take appropriate steps to mitigate these risks and continuously monitor and evaluate our efforts to ensure that we are upholding our commitment to anti-bribery and anti-corruption.

Third-Party Due Diligence:

We conduct due diligence on all third parties with whom we do business, including suppliers, vendors, and contractors, to ensure that they share our commitment to anti-bribery and anti-corruption. We include anti-bribery and anti-corruption clauses in our contracts with third parties.

Training and Awareness:

We provide regular training and awareness programs for our employees, clients, and partners to promote an understanding of our anti-bribery and anti-corruption policies and procedures. We encourage the reporting of any concerns or suspicions of bribery or corruption, and we investigate all reports in a timely and confidential manner.

Our Expectations: Our reputation is built upon professional and tailor-made services and depends upon the conduct of our employees as well as the conduct of those with whom we do business with. It is our goal to ensure that all CBC Law employees and the third parties reflect the same high ethical standards and demonstrate a commitment to compliance with all applicable laws. We further expect our third parties to ensure that their employees and subcontractors understand and comply with this ABAC Policy. Therefore; every employee and third party of CBC Law is trained and monitored with respect to this policy during the course of the interaction.

Anti-Money Laundering: 

CBC has a strict policy regarding the prevention of money laundering. We only engage in business with clients who operate within legal parameters and acquire funds from legitimate sources. It is our utmost priority to comply with all anti-money laundering and anti-terrorism laws. We do not partake in any money laundering activities nor do we assist clients in such activities, including concealing the sources of funds to evade disclosure, taxes, or financing of terrorism. We strictly avoid any transactions that involve the proceeds of criminal activities, such as terrorism, narcotics, tax evasion, and fraud. Furthermore, we do not provide aid to any individual or entity seeking to finance terrorist activities.

It's important to note that the threshold for suspicion or knowledge of money laundering is low. If there is any suspicion of a client or business partner engaging in money laundering activities, employees are required to report their concerns immediately to their supervisors or partners. Any failure to report potential incidents of money laundering will be considered a violation of our policy.