The bioactive ingredients behind better products.

Our vision is to reach our goals and fulfil our mission, to work in cooperation with our internal and external partners, to develop our sector, our environment and our people, to produce efficiently in order to increase our profitability, and to do all of this while remaining conscious of our responsibilities towards the resources of the world.

Our mission is to share our understanding of sustainability, reliability and innovation through our products, our brands and our position, and to create difference and value for our customers while increasing our profitability.

In order to meet customer expectations, our organisation has adopted continuous improvement as a principle, remaining committed to the legal legislation and regulations that comply with quality, halal and food safety standards. To this end;

• Regular support and training opportunities are provided so that employees can contribute to the system,
• Customer satisfaction is monitored regularly,
• By monitoring product quality and production conditions, sustainability and continuous improvement are targeted,
• Product quality and food safety are always kept at the forefront and the related activities are supported. The hazard analyses and risk management carried out for healthy and safe food production are conducted in compliance with good manufacturing practices and legal requirements.

Our Quality, Halal and Food Safety Management Systems have been established in accordance with the ISO 9001:2015 (QMS), FSSC 22000 (FS), ISO 22000:2018 (FS) and TS OIC/SMIIC 1:2019 (Halal) Standards.

While carrying out our production activities, our company attaches importance to compliance with the relevant legal legislation and standards, to raising employee awareness for this purpose, and to auditing the applications. Efforts are made to meet the health and safety needs of our employees, our visitors, the subcontractors operating within our company and our environment. To this end;

• The implementation, development and continuity of the occupational health and safety management system are ensured,
• Through continuous training, a safe working awareness is created and developed in our employees,
• Stakeholders who will operate within our company are informed before work begins,
• Activities are planned and implemented to meet customer expectations related to OHS,
• Measures are planned to prevent accidents, occupational diseases and material damage,
• The monitoring, auditing and continuous improvement of our OHS practices are ensured,
• We undertake to comply with the relevant laws, regulations and legislation, and we manage the work in this direction as a whole together with our quality system.

Environment Policy

In the production of our products, we prioritise not harming the environment, preventing environmental pollution, complying with the relevant legal regulations and standards, raising employee awareness for these purposes, and following up the applications.

Our company supports its environmental policy through the following activities:

• Zero waste targets are taken into account in the planning of activities, the possibilities of re-evaluating the waste generated are investigated, and the efficient use of resources is ensured,
• The implementation of a sustainable environmental system is targeted,
• In all activities carried out, care is taken to meet the environmental expectations of our customers,
• Environmental legal requirements and standards are fulfilled, and work is carried out to raise the awareness of both our employees and our stakeholders on this matter,
• In the design of our Environment and Quality systems, the protection and sustainability of natural resources are prioritised.

Climate Change Policy

Our company undertakes to adopt a long-term and comprehensive approach in the fight against climate change and to minimise its environmental impact.

• By integrating renewable energy sources into our production processes, we aim to increase energy efficiency and reduce carbon emissions. At the same time, various strategies that will accelerate the transition to sustainable production methods will be developed, and in line with these strategies, targets aimed at reducing our environmental impact will be set and implemented systematically.
• A zero waste approach has been adopted in waste management, and environmentally friendly materials have begun to be used in packaging at our facility. Work will be carried out to minimise the waste generated during production and to increase recycling rates. In order to minimise plastic use, a transition to biodegradable and recyclable materials will be made, aiming to reduce the negative impact on nature.
• Advanced water saving systems will be installed for the efficient use of water resources, and where possible, modern treatment systems will be planned for the reuse of water.
• A sustainable approach will be adopted by encouraging environmentally friendly practices in the supply chain. By developing collaborations with suppliers, the spread of sustainable and environmentally sensitive processes will be ensured.
• Regular training aimed at raising environmental awareness will be provided to our employees. Through this training, active participation in environmentally friendly practices will be ensured, and the culture of sustainability at our factory will be strengthened.
• In the future, modern systems will be established to calculate and track our carbon footprint. Concrete steps will be taken for the regular measurement, monitoring and reduction of greenhouse gas emissions. Thanks to this infrastructure, we will evaluate our environmental impact more transparently and be able to apply the necessary corrective measures quickly.
• Our factory will implement continuous monitoring and performance evaluation systems to achieve these targets. Annual environmental reports will be shared transparently with all stakeholders and will contribute to evaluating the effectiveness of internal sustainability strategies.

All these steps will encourage an environmentally sensitive production understanding, and at the same time contribute to our goal of leaving a healthier, greener and more sustainable planet to future generations.

1. Land Rights

As SEL Sanayi, we undertake to use land in accordance with the applicable legal requirements, to respect local activities within this scope, to stand against any unlawful occupation of land, and to remain committed to these principles in land use and in any change relating to land.

We carry out assessments in order to determine land ownership and/or land use rights, and we declare that these rights will be protected.

We protect the land rights of individuals, peoples and communities; we respect their rights over property and land. In all negotiations, including the use and transfer of their property or land, we act in accordance with the principles of free, prior and informed consent, contractual transparency and disclosure.

Our company has designated authorised persons to listen to and evaluate the problems experienced by rights holders, and declares that it will establish a resolution mechanism for the problems evaluated.

Our company declares that, in property acquisition processes, including land and facility changes, it will avoid activities that may create a negative impact on forest assets or lead to high carbon emissions.

2. Water Resources

As SEL Sanayi, in order not to create a negative impact on water resources, we take care to use water resources correctly and efficiently, and we make the necessary effort to secure the future of water.

We declare that wastewater discharges do not contain any element (chemicals, solid waste and similar) that could harm water resources or the environment, and that we are faithful to all legal regulations.

3. Prevention of Deforestation

As SEL Sanayi, we respect forest habitats and undertake to make the utmost effort to fulfil the requirements for the protection of forests.

We declare that, in the stages of acquiring land ownership, including land and facility changes, we will avoid activities that may create a negative impact on forest assets or lead to high carbon emissions.

We declare that, during forestry activities, we will act in accordance with regional rules and human rights, and that within the scope of forestry activities we will not be directly or indirectly involved in the destruction of environmental values.

We declare that, during forestry activities, we will not be directly or indirectly involved in the use of forests for non-forest purposes, their conversion into plantations, or the release of genetically modified organisms into the market.

Against increasing resource scarcity, we support the restoration of forests, and we expect the same care from our suppliers. We do not tolerate unfair land acquisition and deforestation within the supply chain.

All our stakeholders who encounter a violation of this text are required to report the violations to the ethics reporting channel of Sel Sanayi. The Sel Sanayi Ethics Reporting channel can be reached at the email address bilgi@selsanayi.com. In accordance with our company policy and information security principles, all reports are kept confidential. Confidentiality rules are also observed during the process of reviewing, investigating and reporting the notifications.

As SEL SANAYİ Ürünleri Ticaret ve Pazarlama A.Ş., our social compliance/responsibility policy contains the standards we have established as follows, based on our fundamental principles and values, together with all our business partners. This policy has been prepared to share the Social Compliance commitments of SEL Sanayi with all relevant parties (employees, business partners, stakeholders). Our goal is to ensure that the Social Compliance Policy becomes part of the company culture within the organisation.

Through its social compliance standards, SEL SANAYİ undertakes to grant employees all their rights within the framework of the law, to comply with occupational health and safety rules, to be sensitive to the environment, and to create a workplace with open and honest communication, respect and appreciation among employees.

Our company also expects its business partners and suppliers to work in compliance with the principles of these policies and other relevant legal regulations, and to commit to this. In this scope;

1. Human Rights

As SEL Sanayi, we adopt respect for human rights as a fundamental value. In our relations with our employees, our suppliers, our business partners and the communities in which we operate, we work to act in accordance with human rights and to encourage them to be sensitive on this matter.

This Policy is guided by international human rights principles, including those contained in the International Bill of Human Rights, the International Labour Organisation Declaration on Fundamental Principles and Rights at Work, the United Nations Global Compact and the United Nations Guiding Principles on Business and Human Rights.

This policy has been prepared to share our company commitment to respect for universal human rights with all relevant parties (employees, business partners, stakeholders). Our goal is to ensure that respect for human rights becomes part of the company culture within the organisation and spreads throughout the supply chain.

In this scope, in the planning and implementation stages of all its activities, it takes the following international references as a basis;

• ILO 29 and 105: Prohibition of forced and compulsory labour
• ILO 87 and 98: Freedom of association and the right to collective bargaining
• ILO 100: Equal pay for equal work
• ILO 111: Prevention of discrimination
• ILO 138: Minimum working age
• ILO 182: Prohibition of the worst forms of child labour
• United Nations Universal Declaration of Human Rights
• United Nations Guiding Principles on Business and Human Rights (UN Guiding Principles)

Mechanisms have been established to enable employees to report any human rights violation without any reservation.

2. Prevention of Forced and Compulsory Labour

2.1. Practices such as forced labour, compulsory labour or paying off debt through work cannot be applied.

2.2. Workers have the right to leave their employment provided that they give reasonable prior notice.

2.3. Employment relationships are based on the principle of voluntariness and are carried out on the basis of mutual consent among employees. Practices indicating forced or compulsory labour, including the following elements, are never applied;

• Compulsory labour,
• Physical, psychological or sexual violence,
• Restriction of movement or freedom,
• Retention of passports and identity documents,
• Elements such as the threat of denunciation to the authorities,
• Withholding wages or requiring a deposit to start work.

3. Prevention of Child Labour and Employment of Young Workers

The employment of child labour is not permitted in our organisation.

Within the framework of respect for the healthy development and right to education of children, we undertake not to employ any worker under the age of 16 and to act in accordance with the procedures and principles for employing young workers who have not yet completed the age of 18.

3.1. All workers must be at least 18 years of age or at the legally minimum working age under national legislation (whichever is higher). For young workers whom our suppliers may wish to employ within the scope of the exemptions under ILO Convention 138, they are expected to obtain approval from our company.

3.2. By signing a contract with SEL Sanayi, suppliers, even if they do not employ child workers or minors within their organisation, have accepted the principles of remediation programmes that will make it possible for children and minor employees to attain quality education.

3.3. If it is determined that a minor worker is employed, it is essential that this be managed within the scope of appropriate remediation programmes.

4. Working Environment, Health and Safety

All workers have the right to work in a safe and hygienic working environment, and SEL Sanayi undertakes that working environments meet the following standards;

4.1. Compliance with all national laws related to health and safety and with the standards regulated under ILO Convention 155,

4.2. Establishment of an active health and safety committee. Representation of workers on this committee.

4.3. Appointment of a senior manager responsible for safety and health matters, including the establishment and announcement of written health and safety policies, in compliance with the relevant requirements of the ethical rules.

4.4. Workers cannot be employed under potentially dangerous conditions without regular and appropriate safety training or supervision. They must not be exposed to unsafe or unhealthy working conditions, and all necessary safety equipment must be provided free of charge.

4.5. Training must include evacuation procedures in emergencies and first aid for personnel designated within an appropriate framework. Adequate first aid services must be accessible to all workers.

4.6. Workplaces must be created in the form of ergonomic working conditions and well-lit, well-ventilated work stations.

4.7. Offices, factories and sites (including production and storage facilities, and the offices and living areas used by employees), and all buildings must be safe and hygienic facilities that are safe, easily accessible and have a sufficient number of clearly marked fire exits.

4.8. Where living areas are provided, they must be separate from the other buildings in the workplace and located in buildings equipped with an adequate fire alarm system.

4.9. In any case, clean showers, access to drinking water, and appropriate food storage facilities and means must be provided.

5. Working Hours, Wages and Payments, Rest and Holidays

Our company undertakes that working conditions comply with local laws and meet the following standards;

5.1. Employment, working hours, minimum payments and all payments, including social benefits (leave, sick leave, childcare, maternity leave and benefits, social security and similar), must comply with local legislation, and the legal obligations that must be fulfilled towards workers must in no way be avoided.

5.2. Clear and understandable written information about the terms of employment (including wages and working hours) must be given to workers before they start work, and records related to these must be kept.

5.3. Workers must not be forced to work for very long periods and, under normal conditions and on a regular basis (including overtime), must not be made to work more than 60 hours per week.

5.4. All workers must be ensured at least one day of leave every 7 days, and overtime work must be on a voluntary basis and at premium wage rates.

5.5. When no work is carried out on official holidays, no deduction is made from employees; if work is carried out, overtime payments must be made in full as determined by law.

5.6. Deductions from wages must be of a reasonable amount and related to the service provided for those deductions. The explicit consent of workers must be obtained regarding each deduction; such consent does not have to constitute an integral part of the employment contracts. The use of fines as a disciplinary measure is not permitted.

6. Prevention of Discrimination and Harassment

6.1. All individuals have the right to equal treatment, respect and dignity, and to work in an environment free from any harassment, physical or verbal abuse, threats or intimidation policies.

6.2. Disciplinary practices are carried out fairly and transparently. The privacy rights of individuals are protected, and the procedure is clearly expressed and announced to workers.

6.3. Workers have the right to object to disciplinary actions and to be represented in this process.

6.4. No discrimination may be applied against workers in any way on grounds such as gender, religion, race, caste, age, disability, sexual orientation, union membership, political opinion, or national or ethnic origin.

7. Prevention of Bribery and Corruption

SEL Sanayi complies with the legal regulations related to bribery and corruption in all countries where it operates and is represented, and works with a principle of "zero tolerance" on this matter. In addition, our company undertakes to conduct its activities in a fair, honest, lawful and ethical manner. Within the scope of this policy, our employees;

7.1. Cannot provide material benefit under the name of commission or any other name while performing their duties, and cannot make an offer in this direction.

7.2. Cannot make any direct or indirect offer of advantage, or make a verbal or written agreement, in order to obtain any advantage related or unrelated to work from public or private persons or institutions.

7.3. Cannot create an advantageous situation in return for providing privilege in their relations with third persons and institutions, and cannot accept offers in this direction.

7.4. Shows the utmost care so that even behaviour carried out with a different intention does not create suspicion or an impression in this direction.

It is mandatory for business partners to comply with the principles of the policy and other relevant legal regulations. The implementation and updating of the policy is within the authority, duty and responsibility of the board of directors. In this scope, the board of directors:

• Establishes and develops the necessary control mechanisms to prevent bribery and corruption.
• Ensures the establishment of communication channels for reporting behaviour contrary to the policy, and takes measures to ensure the confidentiality and security of those who report.
• Ensures that the necessary reviews and investigations are carried out regarding complaints, reports and allegations received on the matter.
• Ensures that audits are carried out and corrective measures are taken to ensure compliance with the policy.
• Is responsible for determining and operating reporting, review and sanction mechanisms in the event of non-compliance with the policies, rules and regulations.

8. Freedom of Association and the Right to Representation

8.1. All workers have the right to establish or join existing trade unions and to conduct collective bargaining negotiations in a peaceful and lawful manner.

8.2. The freedom of association of workers and the right of workers organisations to establish their own statutes and rules must be respected.

8.3. Workers are not discriminated against or punished for joining or not joining workers organisations.

8.4. Where these rights are restricted by law, alternative legal options must be allowed for the representation of independent workers.

9. Fair Remuneration

In our company, wages are determined by considering the training of employees, their seniority, the title and grade arising from the job evaluation results of their position, their personal performance, and the sectoral evaluation of the job they perform.

Within the scope of these policies, in the sustainability of our company activities, an equality policy is applied that provides equal opportunity to everyone within the framework of the constitution, laws and relevant legislation, regardless of language, race, colour, gender, political thought, belief, religion, sect, age, physical disability and similar characteristics, starting from the recruitment process throughout all Human Resources management.

The performance and career development of employees at every level are managed and supported by the established Human Resources systems. All employees benefit from equal rights within the framework of the principles determined in working conditions and in all other facilities and social benefits provided.

At the same time, through this policy, it is aimed that employees have an income at a level that is the reward of their labour and that enables them to provide for their family and to make a certain amount of savings for the future.

10. Regular Employment

Our company undertakes to employ its workers in a way that meets real and continuous business needs.

All employees are employed with written and transparent employment contracts in accordance with the applicable labour legislation. Fixed-term, temporary or subcontracted employment practices are not misused for the purpose of avoiding legal rights, reducing social security obligations or weakening employment continuity.

Probationary periods, contract renewals and termination processes are carried out in accordance with legal requirements. Our business is based on fair, ethical and sustainable working practices that support regular employment.

11. Rights of Vulnerable Groups

Our company undertakes to protect the legal and fundamental rights of young workers, women, individuals with disabilities, migrant workers and all other vulnerable groups, and to prevent any kind of discrimination, mistreatment and abuse against these groups.

12. Foreign Employees

Although there are no foreign national employees in our company, if there are, we undertake that all personnel procedures will be carried out in accordance with the applicable legal legislation.

13. Commitment to Stakeholders

Our company undertakes to build a bond with its stakeholders on the basis of good faith and to act fairly and at an equal distance towards all its stakeholders.

14. Protection of the Environment

All applicable local regulations and environmental standards related to the environment must be observed.

Our company and our suppliers must, in any case, be wholeheartedly committed to environmental awareness and to improvements related to environmental standards (including but not limited to reducing waste, increasing recycling, reducing pollution, and increasing the use of environmentally friendly products obtained from sustainable sources).

15. Supplier Management

With the belief that all suppliers have equal responsibility, we aim to evaluate the social compliance/responsibility activities of supplier companies, to follow up the results with action plans, and to control social compliance/responsibility activities through management systems.

16. Legal Compliance

Our company undertakes to achieve full compliance with all applicable national legislation and relevant regulations.

International conventions, customer requirements and sectoral standards are taken into account in our activities.

Legal changes are monitored regularly and the necessary updates are applied in a timely manner.

Legal compliance is accepted as a binding fundamental principle for all employees.

17. Training

Our company regularly provides training aimed at developing the knowledge, skills and competencies of employees.

Training is planned in accordance with job descriptions, legal requirements and occupational health and safety needs.

Orientation and basic training are provided in full to newly recruited employees.

Training activities are recorded and their effectiveness is evaluated periodically.

18. Auditing

18.1. Our company undertakes to establish and implement a system for the application of the provisions of the ethical rules and for auditing compliance with them.

18.2. Documentary records that may be evidence of compliance with the relevant legal and social compliance requirements (or that are directly or indirectly related to the application of the rules) are kept and stored for three years. Among these are verifiable, accurate and complete records of the hours worked and the wages paid for each employee.

18.3. Our company (or its representatives or agents) reserves the right to carry out an audit in order to check whether the supplier meets the necessary requirements (and at any other workplace used by or on behalf of the supplier, regardless of whether it is under the control or ownership of the supplier).

18.4. Just as we expect these standards from our suppliers, they are also expected to audit the compliance of their own suppliers.

19. Non-Compliance

19.1. Suppliers who will work with our company are expected to accept compliance with the terms of these policies.

19.2. Without prejudice to the provisions of the rules or the terms of any agreement that may have been signed between the supplier and our company, our company will have the right to immediately terminate all contracts it has signed with suppliers in the following cases:

• The failure of suppliers to fully comply with the fundamental requirements at any time,
• Their failure to show willingness to work and make an effort to fulfil all provisions of the rules within a reasonable period,
• The failure to provide clear and understandable evidence that will enable their work-related practices to be soundly verified,
• The failure to carry out all necessary corrections and corrective actions to eliminate the matters that raise concern for our business regarding the identified incomplete/incorrect practices.

20. Ethical Business Conduct and Ethical Rules (Codes of Ethics)

In our company, fairness, compliance with the law, accountability and commitment to ethical principles are essential in all activities.

Mutual trust, respect, courtesy, impartiality and open communication between management and employees are taken as a basis.

All kinds of discrimination are prohibited; merit, equal opportunity and respect for personal rights are observed.

Duties and authorities cannot be used for personal benefit; confidential information is protected and cannot be transferred outside the organisation.

While success and performance are encouraged, the physical and psychological health and development of employees are supported.

SEL Sanayi Ürünleri Ticaret ve Pazarlama A.Ş. has determined the critical violation matters (Fundamental Requirements) and the ethical conduct rules for its employees as follows, and shares them with all its stakeholders;

1. The Right to Free Employment
2. The Right to Collective Bargaining and Representation
3. Safe Working Conditions
4. Prevention of Child Labour
5. Wages and Payments in Compliance with the Law
6. Working Hours in Compliance with the Law
7. Prevention of Harassment and Discrimination
8. Regular Employment
9. Prevention of Harsh and Inhumane Treatment

Our company undertakes not to work with suppliers who do not meet these 9 fundamental requirements. Our company will have the right to terminate the contract between it and a supplier that is determined not to comply with any one of the fundamental requirements.

Our company may terminate the contract without prior notice and will not be responsible for making any explanation (to the supplier or to third parties who have contracted with the supplier).

21. Management Systems

In line with legal requirements and customer expectations, our company undertakes to establish and maintain an effective Social Compliance Management System integrated with the other management systems it applies. Processes are monitored, measured and developed regularly with a continuous improvement approach. Risks and opportunities are evaluated and preventive and corrective activities are applied. The effectiveness of the management systems is under the responsibility and supervision of senior management.

All our stakeholders who encounter a violation of these policies are required to report the violations to the ethics reporting channel of Sel Sanayi. The Sel Sanayi Ethics Reporting channel can be reached at the email address bilgi@selsanayi.com. In accordance with our company policy and information security principles, all reports are kept confidential. Confidentiality rules are also observed during the process of reviewing, investigating and reporting the notifications.

1. Purpose and Scope

This Privacy and Personal Data Protection Principles ("Principles") specify the principles adopted by Sel Sanayi Ürünleri Pazarlama ve Ticaret A.Ş (hereinafter referred to as "SEL SANAYI", "Company" or "Data Controller") regarding the protection of personal data, while aiming at establishing personal data processing principles for personal data pertaining to individuals groups consisting of Visitors, Customers, Potential Customers, Suppliers, Third Parties and Online Visitors/Members ("Individuals Groups") and informing the said groups regarding processing of their personal data.

2. Principles Relating to Processing of Personal Data

As SEL SANAYI, we process your personal data in the capacity of Data Controller according to the following principles.

2.1 Processing in Compliance with Law and Principles of Honesty. Your personal data are processed in accordance with the principles which have been introduced by legal regulations, and the rule of general trust and honesty.

2.2 Ensuring that Personal Data are Accurate, and Up-To-Date, when Necessary. By taking your legitimate interests into consideration, periodical verifications and updates are made in order to ensure that the data processed are accurate and up-to-date, and the necessary measures are taken accordingly. In this context, systems for controlling the correctness of personal data and making necessary corrections are set up within the corporate body of SEL SANAYI.

2.3 Processing for Specific, Clear and Legitimate Purposes. Your personal data are processed in accordance with clear, specific and legitimate data processing purposes.

2.4 Personal Data Being Relevant, Limited and Proportionate to their Purpose of Processing. Your personal data are processed proportionately to the extent necessary for achieving the envisaged purpose/purposes, and in a manner that is relevant and limited to the purpose, and we abstain from processing any personal data which are not related to achieving the purpose or which are not needed in that respect.

2.5 Retaining the Personal Data for the Period Stipulated in the Relevant Legislation or the Period Required for the Purpose of Processing Thereof. Your personal data are preserved only for the period prescribed in the relevant legislation or the period required for the purpose of processing thereof. In this context, first of all we identify whether a period is stipulated in the relevant legislation for the preservation of personal data, and if such a period is prescribed, we act in accordance with it, and if no such period is prescribed, we preserve the personal data for the period required for the purpose of processing thereof. In case of expiry of such period or in case the reasons requiring them to be processed cease to exist, provided that there is no legal reason for allowing them to be processed for longer periods, your personal data are deleted, destroyed or anonymized in accordance with SEL SANAYI's Policy on Preservation and Destruction of Personal Data.

3. Personal Data Processing Conditions

Your personal data are processed by SEL SANAYI in accordance with the following conditions.

3.1 Explicit Stipulation by the Laws. Your personal data may be processed if it is explicitly required by the law to process such personal data.

3.2 Inability to Obtain Express Consent of the Relevant Person Due to Actual Impossibility. Where the relevant person cannot give his/her consent or his/her consent is deemed non-admissible due to actual impossibility, but his/her personal data must be processed in order to protect the life or bodily integrity of such person or any other person, then the personal data of such person may be processed.

3.3 Direct relationship with the Conclusion or Performance of a Contract. Where the processing of personal data belonging to the parties to a contract is necessary, such personal data may be processed provided that it is directly related to the conclusion or performance of the said contract.

3.4 Performance by SEL SANAYI of its Legal Obligation. Your personal data may be processed, if the processing thereof is compulsory in order for us, as the Data Controller, to fulfil our legal obligations.

3.5 Personal Data that Became Public. If your personal data has been made public by you, we will be able to process them.

3.6 Obligation to Process Data for Securing or Protecting a Right. In case data processing is mandatory for securing, exercising or protecting a right, your personal data may be processed.

3.7 Processing of Data Based on Legitimate Interest. Your personal data may be processed if it is necessary based on the legitimate interests of SEL SANAYI.

3.8 Processing of the Data Based on Express Consent. Your personal data may be processed on the basis of express consent in cases where they cannot be processed based on any of the conditions specified in these principles.

4. Categorization of Personal Data

5. Purpose of Processing of Personal Data

SEL SANAYI may process personal data for the purposes set out below and based on the relevant individuals group, under the personal data processing conditions specified in Article 5 and 6 of the Law no. 6698.

5.1 Customers. Personal data of Customers may be processed according to the personal data processing conditions specified in Articles 5 and 6 of the Law no. 6698, in order to carry out the necessary business and operational procedures for ensuring that the products and services offered by the Company can be benefited from; to ensure the performance of the contract; to monitor financial and accountancy affairs; to plan and execute customer relations management and customer satisfaction processes; to monitor the contract processes, customer's requests and complaints; to plan and perform transfer processes; to plan data security processes; and to establish, manage, audit and perform information technologies infrastructure.

5.2 Potential Customers. Personal data of Potential Customers may be processed according to the personal data processing conditions specified in Articles 5 and 6 of the Law no. 6698, in order to make the necessary efforts to plan and execute the activities necessary for customizing, recommending and promoting the products and services of the Company in accordance with preferences, usage habits and needs of data subjects; to carry out the necessary activities for realizing the commercial activities of the Company and to conduct the related business processes therefor; to carry out the necessary works and related business processes for ensuring that products and services offered by the Company can be benefited from, to plan and execute the necessary activities for customizing the products and services to be offered by the Company and for recommending and promoting the same, and to plan and execute customer relations management processes.

5.3 Visitors. The personal data of Visitors may be processed according to the personal data processing conditions specified in Articles 5 and 6 of the Law no. 6698, in order to ensure the safety of buildings, establishments and/or plants; to create and monitor the visitor records; to ensure the safety of fixtures and/or resources; to ensure the technical and commercial occupational safety, to ensure the security of organizational operations; and to inform the authorized institutions and organizations pertaining to the legislation.

5.4 Third Parties. The personal data of Third Parties may be processed according to the personal data processing conditions specified in Articles 5 and 6 of the Law no. 6698, in order to carry out the necessary business and operational procedures to ensure that the products and services offered by the Company are benefited from; to carry out the necessary activities for realizing the commercial activities of the Company and to conduct the related business processes therefor; to make the necessary efforts and conduct the relevant business processes to ensure that the products and services offered by the Company are benefited from; to customize the products and services to be offered by the Company and to recommend and promote the same; and to perform the contract.

5.5 Suppliers / Business Partners. Personal data of Suppliers / Business Partners may be processed according to the personal data processing conditions specified in Articles 5 and 6 of the Law no. 6698, in order to carry out the necessary business and operational procedures to ensure that the products and services offered by the Company are benefited from; to carry out the necessary activities for realizing the commercial activities of the Company and to conduct the related business processes therefor; and to make the necessary efforts and conduct the relevant business processes to ensure that the products and services offered by the Company are benefited from.

5.6 Online Visitor / Member. Personal data of Online Visitors/Members may be processed according to the personal data processing conditions specified in Articles 5 and 6 of the Law no. 6698, in order to carry out marketing analysis works, advertisement/campaign/promotion processes, communication works, to carry out product and service development works, and to fulfil legal obligations.

6. Transfer of Personal Data

Your personal data may be transferred in a restricted manner to our business partners, suppliers, affiliates and group companies, and legally authorized public institutions and private persons, domiciled in Turkey or abroad, according to the principles and for the purposes set out in articles 3 and 5 of hereof and personal data processing conditions and purposes specified in Articles 8 and 9 of the Law no. 6698.

7. Method of and Legal Grounds for Collection of Personal Data

Your personal data transmitted to SEL SANAYI electronically are processed as follows based on the relevant individuals groups.

7.1 Customers. The personal data of the Customers are processed by automated means by obtaining such data directly from the person or third person as part of a data recording system by using written and verbal data transmission tools in physical and electronic media according on the legal grounds stipulated in the provisions of Article 5 of the Law no. 6698, namely "there is a necessity to process personal data belonging to the parties of a contract, provided that it is directly related to the conclusion or performance of the contract", "data processing is mandatory for data controller's fulfilment of its legal obligation", and "provided that it does not harm the fundamental rights and freedoms of the relevant person, the data processing is mandatory for the legitimate interests of the data controller".

7.2 Potential Customers. The personal data of the Potential Customers are processed by automated means by using written and verbal data transmission tools in physical and electronic media as part of a data recording system by obtaining such data directly from the persons or third parties on the legal grounds stipulated in Article 5 of the Law no. 6698, namely "the personal data has been made public by the relevant person itself", "data processing is mandatory for securing, exercising or protection of a right", "provided that it does not infringe the fundamental rights and freedoms of the relevant person, the data processing is mandatory for the legitimate interests of the data controller", and "data processing is mandatory for data controller's fulfilment of its legal obligation".

7.3 Visitors. The personal data of the Visitors are processed by automated means by recording footages of security cameras located at the entrance doors, external facade of the building, meeting rooms and event rooms, dining rooms, cafeterias, entrance waiting area, parking area, elevators and floor corridor service areas, on the legal grounds stipulated in the provisions of Article 5 of the Law no. 6698, namely "data processing is mandatory for data controller's fulfilment of its legal obligation", and "provided that it does not infringe the fundamental rights and freedoms of the data subject, the data processing is mandatory for the legitimate interests of the data controller".

7.4 Third Parties. The personal data of Third Parties are processed by automated means by obtaining such data directly from the persons or third parties by using written, verbal, physical or electronic data transmission tools as part of a data recording system, on the legal grounds stipulated in Article 5 of the Law no. 6698, namely "provided that it does not infringe the fundamental rights and freedoms of the data subject, the data processing is mandatory for the legitimate interests of the data controller" and according to the data processing conditions specified in article 6 thereof.

7.5 Supplier / Business Partner. The personal data of the Suppliers / Business Partners are processed by automated means by obtaining such data directly from the person or third parties by using written and verbal data transmission tools in physical and electronic media as part of a data recording system, on the legal grounds stipulated in Article 5 of the Law no. 6698, namely "there is a necessity to process personal data belonging to the parties of a contract, provided that it is directly related to the conclusion or performance of the contract", "data processing is mandatory for data controller's fulfilment of its legal obligation", and "provided that it does not harm the fundamental rights and freedoms of the relevant person, the data processing is mandatory for the legitimate interests of the data controller".

7.6 Online Visitor / Member. The personal data of the Online Visitors / Members are processed by automated means, pursuant to the Law No. 5651 on Regulation of Online Publications and Fighting Against Crimes Committed Through Such Publications, and on the legal grounds stipulated in Article 5 of the Law no. 6698, namely "provided that it does not infringe the fundamental rights and freedoms of the data subject, the data processing is mandatory for the legitimate interests of the data controller", and "data processing is mandatory for data controller's fulfilment of its legal obligation".

8. Security of Personal Data

8.1 In order to ensure the safety of personal data and prevent unlawful processing thereof, SEL SANAYI takes reasonable measures, which will prevent risks of unauthorized access, accidents and data losses, deliberate deletion of data or damages to data.

8.2 For prevention of access to personal data by the persons other than those who are authorized to access thereto, all the necessary technical and physical measures are taken. In this context, the authorization system in particular is designed in such a way that it will be impossible for anyone to access personal data to an extent which is more than required.

8.3 SEL SANAYI performs and procures the performance of necessary audits within its own body or organization in order to ensure implementation of the provisions of the Law no. 6698.

9. Undertakings with Regards to Third Party Personal Data

The relevant Individuals Groups agree and consent to processing by SEL SANAYI of their 3rd party personal data delivered by them to SEL SANAYI. The relevant Individuals Groups also undertake that they have performed the necessary information duties and have received the required consents with respect to the persons whose information has been transferred, and their information, pursuant to the Law No. 6698 on the Protection of Personal Data. Otherwise, all damages to be incurred shall belong to the relevant Individuals Group.

10. Application Procedures and Principles

As the data subject, you may submit an application in relation to your requests regarding your rights under article 11 of the Law No. 6698, in line with the procedures and principles provided in the Application Form for Protection of Personal Data available on the website www.selsanayi.com, by filling in the said form and submitting it as a written application bearing wet signature in person or through the notary public to the address Haciahmet mahallesi, Irmak caddesi No. 1-9, DLP Is Merkezi Ic kapi: 19, 34440 Beyoglu, İstanbul, or sending the application form to the KEP (registered electronic mail) address selsanayi@hs06.kep.tr, and the e-mail address kvkk@selsanayi.com by using mobile signature/e-signature. SEL SANAYI will conclude your application on a free-of-charge basis, within the shortest time possible depending on the nature of the request, but in any event within no later than thirty days. However, in case the process requires any additional cost, SEL SANAYI shall receive the fee specified in the tariff determined by the Personal Data Protection Board.

We would like to emphasize your rights in this context as the data subject; you have the right:

• To learn whether or not your personal data are being processed,
• To request information on the procedure, if your personal data have been processed,
• To obtain information on the purpose of processing of personal data and whether or not personal data has been used in line with their purpose,
• To obtain information about the third persons to whom personal data were communicated domestically or abroad,
• To request the correction of personal data that may have been incompletely or inaccurately processed,
• To request the deletion or destruction of personal data within the framework of the conditions set forth in the applicable legislation,
• To request notification of the procedures set out under the last two sub-paragraphs above to third parties to whom the personal data has been transferred,
• To object to the occurrence of a result which is detrimental to the person concerned as a result of analysing of the processed data exclusively through automatic systems,
• To request indemnification for damages in the case that damages are sustained as a result of unlawful processing.