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About Sözer İstanbul

Sözer Jewelry was founded in 1975 by Metin Sözer and today it maintains commercial relations with about 15 different countries. Sözer jewelry, which stands out with its different designs and innovation, deals with 90% export and offers its products for sale through wholesalers.

SÖZER has started to appeal to young people with its unique designs in recent years. Sözer’s vision is to design products that will suit every age group with its original designs, and its mission is to trade with the whole world in the future.

SÖZER KUYUMCULUK SANAYİ VE TİCARET ANONİM ŞİRKETİ

Corporate Information Company Trade Name

Tax office:
Güneşli

Tax Number:
7810220178

Trade Registry Number

Istanbul Chamber of Commerce:
438460

Mersis number:

0-7810-2201-7800017

Center Address:

Bağlar Mahallesi Yalçın Koreş Caddesi NO:36 BAĞCILAR/İSTANBUL

Committed Capital Amount: 

38.500.000,00

Amount of Paid Capital: 

38.500.000,00

BOARD OF MANAGERS: 

Chairman of the Board:

Metin SÖZER

Board Member:

Alper Sözer

Board Member:

Sercan Sözer

Auditor’s Title:

Dinamik Bağımsız Denetim A.Ş.Yenibosna Merkez

Mah. 29 Ekim Cad. A1 Apt. No:5/804 Bahçelievler/İstanbul

The Corporate Policy of Sözer Kuyumculuk San. ve Tic A.Ş, enacted on the 20th of August, 2020,
represents a meticulously crafted and ethically oriented blueprint for excellence in quality
management, social responsibility, adherence to the highest standards of business ethics, the
protection of human rights, and environmental stewardship. Below is an enhanced and detailed
exposition of the principal tenets of this policy:

 

 

Quality Management

  •  Unwavering Commitment to Excellence: The corporation places paramount importance on
    aligning with customer expectations, recognizing this alignment as a cornerstone of its success. It
    pledges to an efficient allocation of resources and active engagement with stakeholders, thereby
    laying the foundation for sustainable growth and operational excellence.
  •  Culture of Continuous Enhancement: The entity is deeply committed to an iterative process of
    evaluating and enhancing its Quality Policy. This includes the ongoing development of its workforce
    and the refinement of managerial practices, aimed at boosting the company’s reputation and the
    quality of its products and services.
  •  

 

Social Responsibility and Business Ethics

  • Foundations of Ethical Conduct: Sözer Kuyumculuk stands firm in its commitment to principles of
    integrity, transparency, and strict adherence to legal and ethical standards in all its operations. The
    corporation maintains an unequivocal stance against bribery, corruption, money laundering, and the
    financing of terrorism, thereby ensuring its operations are conducted with the highest ethical
    standards.
  • Guarantee of Product Integrity and Safety: The company ensures complete transparency in the
    disclosure of product characteristics and enforces stringent protocols to maintain the integrity and
    safety of its product shipments, thereby safeguarding consumer trust and confidence.
  •  

Human Rights

  •  The policy is in harmonious alignment with the Universal Declaration of Human Rights, expressly
    condemning practices such as child labor and forced labor, advocating for equality in the workplace,
    and guaranteeing safe and respectful working conditions for all employees.
  •  It is committed to fostering an environment of non-discrimination, supporting the rights of workers
    to association and to fair remuneration, and actively contributing to the welfare of the community.
  •  

Environmental Stewardship

  •  Dedication to Responsible Operations: The firm pledges to diligently pursue the reduction of its
    environmental footprint, enhance its environmental efficiencies, and actively support efforts to
    preserve and restore biodiversity.
  •  Proactive Environmental Management: It is dedicated to the conscientious oversight of its
    operations to minimize negative environmental impacts, demonstrating its commitment to
    sustainability and responsible environmental governance.

This Corporate Policy is a testament to Sözer Kuyumculuk San. ve Tic A.Ş’s dedication to setting new
benchmarks in ethical practices, quality management, and a comprehensive approach to social and
environmental responsibility. It showcases a progressive and conscientious model of corporate governance,
affirming the company’s leadership in fostering ethical, sustainable, and socially responsible business
practices. This policy not only reflects the company’s commitment to its foundational principles but also its
dedication to contributing positively to society and the environment, thereby ensuring a legacy of excellence
and integrity.

SÖZER KUYUMCULUK SAN. VE TİC. A.Ş. İS A MANUFACTURER AND EXPORTER OF JEWELRY.


1.1 Legislation and Regulations a. Sözer Kuyumculuk shall operate in compliance with all relevant national
and international legislations/regulations as applicable in the countries where we operate. b. All
personnel are expected and directed to comply with all applicable laws and regulations as well as all
internal Sözer Kuyumculuk rules and policies relating to their business activities. c. It is the responsibility
of personnel to know and understand legal, regulatory, and internal requirements as they apply to their
jobs. d. Our compliance team maintains the list of applicable legal and regulatory requirements, and the
same is followed for compliance on a day-to-day basis. Necessary records of requirements and
compliance are maintained.
1.2 Money Laundering, Terrorism Financing, Other Financial Offenses a. Sözer Kuyumculuk recognizes the
fact that entities in the gems and jewelry sector must take on the onus of analyzing their potential
vulnerabilities to money laundering and implement specific steps required for protection against abuse by
criminals. b. Sözer Kuyumculuk shall act in accordance with national laws with respect to the review of its
financial accounts and maintaining internal controls as guided by various regulations. The following acts and
international guidelines are considered while establishing company-level policies:

  •  AML Turkish Goverment act.
  •  FATF 40 Recommendations and 8 special recommendations c. It is the responsibility of concerned
    personnel to know and understand the relevant money laundering/financial offenses-related legal,
    regulatory, and internal requirements as they apply to their jobs. Ignoring or not reporting suspicious
    activity that appears to be questionable may also be considered a violation of the Business Principles,
    depending on the seriousness of the non-conformance. d. Compliance officers ensure all critical
    steps such as KYC & KYS, Identification of suspicious transactions, reporting to management, and
    record-keeping as required by the local act and legislations are complied with. e. The compliance
    officer carries out periodic reviews of AML/CFT compliances and submits their report to management
    on a quarterly basis.

1.3 System of Warranties a. Sözer Kuyumculuk is dealing in polished diamonds and is fully committed to
complying with all the requirements specified in the World Diamond Council’s (WDC) System of Warranties
Declaration. b. We will not engage in business with the supply chain who deals in ‘conflict diamonds’ or are
not following the System of Warranties Declaration in invoices, either knowingly or unknowingly, and will be
considered a violation of the Business Principles.
1.4 Anti-Bribery and Facilitation Payment Policy: a. Sözer Kuyumculuk shall ensure the complete prohibition
of Bribery and facilitation payments across the organization and in all entities. b. Sözer Kuyumculuk will not
offer, accept, or countenance any payment, gift in kind, hospitality, expense, or promises as such that may
compromise promises of fair competition. c. The entity shall prohibit bribery and facilitation payments and
shall comply with various rules and the local land law.

1.5 Disclosure of Treated Diamonds, Synthetics, and Stimulants

  •  Full disclosure i.e., the complete and total release of all available information about a Diamond and
    all material steps it has undergone prior to sale to the purchaser, irrespective of whether or not the
    information is specifically requested and regardless of the effect on the value of the diamond.
  •  We deal in natural diamonds only, and any treatment on natural diamonds is disclosed to the
    customer prior to sales.

1.6 Diamond & Gemstone Sourcing Policy as per OECD

  •  Sözer Kuyumculuk is committed to being a responsible corporate citizen and is opposed to human
    rights abuses. As part of that commitment, Sözer Kuyumculuk seeks to source products,
    components, and materials from companies that share our values around human rights, ethics, and
    environmental responsibility.
  •  Sözer Kuyumculuk shall strive to ensure that all its supply of diamonds is not originating from
    conflict-affected and high-risk areas (CAHRAs) and where practically possible origin of diamonds is
    known to us.

1.7 Gold, Silver & Platinum Group Of Metal Sourcing Policy

  •  Our Company is concerned about the environment and social impacts of irresponsible mining. We
    shall ensure that all our gold Jewelry suppliers are following ethical precious metal Jewelry sourcing
    guidelines (Dodd- Frank rules, DRC & other applicable legislation).
  •  Further, we are committed to ensuring that the sourcing of gold and precious metal products and
    articles thereof are under the highest Social, Human right, and Environmental standard cautions of
    trade.

1.8 Supply Chain Management / Best Endeavours

  •  The management of Sözer Kuyumculuk is committed to taking appropriate action to use the best
    endeavors to ensure that the suppliers and contractors are committed to compliance with
    International Social Standards such as Responsible Jewellery Council (RJC) & IAS accredited IMS.

1.9 Employment

  •  Compliance is required at all times, with applicable national and, where appropriate, international
    laws/regulations with respect to employment and labor regulations.
  •  Sözer Kuyumculuk shall not require staff to work more than the national limit of hours in a week on a
    regular basis.
  •  Sözer Kuyumculuk shall ensure that wages and benefits for a standard working week shall meet at
    least national minimum standards.

1.10 Health and Safety

  •  Sözer Kuyumculuk recognizes the need to develop a sustainable, value-creating business and is
    committed to the following initiatives to mitigate health and safety-related risks and comply with
    laws and best practices.

1.11 Non-Discrimination, Disciplinary Practices

  •  Sözer Kuyumculuk strongly discourages any form of discrimination and considers any reported
    incidents as a serious violation of its Business Principles. The company promotes a work environment
    free of harassment, violence, and any forms of coercion.

1.12 Child Labour

  •  Sözer Kuyumculuk prohibits child labor in its facilities, adhering to local laws and the minimum age
    for employment being 18 years. The company implements policies and procedures to verify the age
    of all new employees.

1.13 Forced Labour

  •  Sözer Kuyumculuk is fully committed to ensuring no forced or involuntary labor is practiced in any
    form at its facilities and considers any reported incidents as a serious violation of its Business
    Principles.

1.14 Human Rights

  •  Sözer Kuyumculuk is committed to treating all employees with equality, respect, and dignity,
    ensuring no interference in employees’ rights and strongly discouraging any form of abusive
    behavior.

1.15 Environment Protection

  •  Sözer Kuyumculuk is committed to effective environmental management, focusing on compliance
    with environmental laws, mitigating environmental impacts, and improving awareness and
    performance regarding environmental issues among employees and suppliers.

1.16 Product Security

  •  Sözer Kuyumculuk ensures the safety of its products throughout the supply chain, employing various
    security measures and training relevant personnel on safety and security procedures.
    For any instances of non-compliance or deviations from our ethical policy, stakeholders are encouraged to
    contact us. For those interested in obtaining a copy of our annual sourcing compliance report based on
    OECD guidelines, please reach out through the provided email address. Compliance@sözer.com.tr

Sözer Kuyumculuk San. ve Tic A.Ş. Quality Policy


1.1 Legislation and Regulations a. Sözer Kuyumculuk shall operate in compliance with all relevant national
and international legislations/regulations as applicable in the countries where we operate. b. All
personnel are expected and directed to comply with all applicable laws and regulations as well as all
internal Sözer Kuyumculuk rules and policies relating to their business activities. c. It is the responsibility
of personnel to know and understand legal, regulatory, and internal requirements as they apply to their
jobs. d. Our compliance team maintains the list of applicable legal and regulatory requirements, and the
same is followed for compliance on a day-to-day basis. Necessary records of requirements and
compliance are maintained.
1.2 Money Laundering, Terrorism Financing, Other Financial Offenses a. Sözer Kuyumculuk recognizes the
fact that entities in the gems and jewelry sector must take on the onus of analyzing their potential
vulnerabilities to money laundering and implement specific steps required for protection against abuse by
criminals. b. Sözer Kuyumculuk shall act in accordance with national laws with respect to the review of its
financial accounts and maintaining internal controls as guided by various regulations. The following acts and
international guidelines are considered while establishing company-level policies:
At Sözer Kuyumculuk San. ve Tic A.Ş., we have developed an in-depth quality policy in adherence
to the requirements of the ISO 9001 Quality Management System standard, aiming to maintain our
leadership position in the industry and maximize customer satisfaction. This policy embraces an
approach that targets excellence at every stage of our business processes and prioritizes quality in all our activities.

Core Elements of Our Quality Policy


1.1 Legislation and Regulations a. Sözer Kuyumculuk shall operate in compliance with all relevant national
and international legislations/regulations as applicable in the countries where we operate. b. All
personnel are expected and directed to comply with all applicable laws and regulations as well as all
internal Sözer Kuyumculuk rules and policies relating to their business activities. c. It is the responsibility
of personnel to know and understand legal, regulatory, and internal requirements as they apply to their
jobs. d. Our compliance team maintains the list of applicable legal and regulatory requirements, and the
same is followed for compliance on a day-to-day basis. Necessary records of requirements and
compliance are maintained.
1.2 Money Laundering, Terrorism Financing, Other Financial Offenses a. Sözer Kuyumculuk recognizes the
fact that entities in the gems and jewelry sector must take on the onus of analyzing their potential
vulnerabilities to money laundering and implement specific steps required for protection against abuse by
criminals. b. Sözer Kuyumculuk shall act in accordance with national laws with respect to the review of its
financial accounts and maintaining internal controls as guided by various regulations. The following acts and
international guidelines are considered while establishing company-level policies:

Customer Focus and Satisfaction:


1.1 Legislation and Regulations a. Sözer Kuyumculuk shall operate in compliance with all relevant national
and international legislations/regulations as applicable in the countries where we operate. b. All
personnel are expected and directed to comply with all applicable laws and regulations as well as all
internal Sözer Kuyumculuk rules and policies relating to their business activities. c. It is the responsibility
of personnel to know and understand legal, regulatory, and internal requirements as they apply to their
jobs. d. Our compliance team maintains the list of applicable legal and regulatory requirements, and the
same is followed for compliance on a day-to-day basis. Necessary records of requirements and
compliance are maintained.
1.2 Money Laundering, Terrorism Financing, Other Financial Offenses a. Sözer Kuyumculuk recognizes the
fact that entities in the gems and jewelry sector must take on the onus of analyzing their potential
vulnerabilities to money laundering and implement specific steps required for protection against abuse by
criminals. b. Sözer Kuyumculuk shall act in accordance with national laws with respect to the review of its
financial accounts and maintaining internal controls as guided by various regulations. The following acts and
international guidelines are considered while establishing company-level policies:

Exceeding our customers’ expectations is at the core of every decision and action we take. We actively collect and evaluate customer feedback, using this information to improve our products and services. We continuously measure customer satisfaction and use these measurements to enhance our business processes and the quality of our service.

 

1. Leadership and Management Commitment: Our company’s senior management
demonstrates strong leadership and commitment to ensuring the effectiveness of our
quality management system and to enhancing quality awareness at all levels. Management
actively participates in providing the necessary resources to achieve quality objectives and
in the continuous improvement of the quality management system.

2. Employee Participation and Development: Each of our employees plays a critical role in
the success of our quality management system. We encourage employee participation and
offer training and career development opportunities, enabling them to enhance their skills
and provide higher quality service to our customers.

3. Process Approach and Operational Excellence: We systematically manage and
continuously improve our business processes. Operational excellence is crucial for
increasing the efficiency and effectiveness of our processes. This allows us to reduce
workload, lower costs, and enhance customer satisfaction.

4. Risk-Based Thinking: We adopt risk-based thinking in our decision-making processes. We
proactively identify and manage potential risks and opportunities, which directs us to adapt
more quickly to changing market conditions and customer needs.

5. Supply Chain Management and Partnership with Suppliers: We work closely with our
suppliers and partners, ensuring quality and consistency throughout the supply chain. From
the selection of suppliers, we conduct regular evaluations to ensure they adhere to our
quality standards and continuous improvement commitments.

6. Continuous Improvement and Innovation: Our quality management system is based on a
framework that encourages continuous improvement and innovation. We focus on
enhancing our processes, products, and services through innovative solutions and
technologies.

 

Our quality policy represents a comprehensive approach where quality is integrated into all
activities of Sözer Kuyumculuk San. ve Tic A.Ş. This policy is a clear commitment to our customers,
employees, and all stakeholders: Quality is always our priority, and we seek to be recognized for
our unwavering commitment to excellence. We regularly review, assess, and improve the
effectiveness of our quality management system and practices, which helps us maintain our
leadership position in the industry and maximize customer satisfaction.

Sözer Kuyumculuk San. ve Tic. A.Ş. Environmental Policy

1. Policy Statement Sözer Kuyumculuk is committed to conducting its business operations in
an environmentally responsible manner. We recognize the importance of protecting the
environment and minimizing our ecological footprint. This Environmental Policy outlines
our commitment to environmental sustainability and sets forth our objectives and principles
for managing our environmental impacts.
2. Compliance with Laws and Regulations Sözer Kuyumculuk is committed to complying
with all applicable environmental laws, regulations, and standards in the jurisdictions where
we operate. We will continuously monitor and review our operations to ensure compliance
and strive to exceed legal requirements whenever possible.
3. Environmental Management System Sözer Kuyumculuk will establish and maintain an
Environmental Management System (EMS) to effectively manage our environmental
impacts. The EMS will include the following elements:
a. Environmental objectives and targets: We will set measurable objectives and targets to
improve our environmental performance and reduce our environmental footprint.
b. Risk assessment and mitigation: We will identify and assess environmental risks
associated with our operations and implement appropriate measures to mitigate and
manage those risks.
c. Training and awareness: We will provide training and awareness programs to our
employees to ensure they understand their environmental responsibilities and are equipped
to contribute to our environmental objectives.
d. Resource efficiency: We will strive to optimize the use of resources, including energy,
water, and raw materials, by implementing efficient processes and technologies.
e. Waste management: We will implement waste reduction, recycling, and disposal practices
that minimize the environmental impact of our waste generation.
f. Pollution prevention: We will take proactive measures to prevent pollution, including the
proper handling, storage, and disposal of hazardous substances, and the implementation of
controls to minimize air and water pollution.
g. Continuous improvement: We will regularly monitor and review our environmental
performance and seek opportunities for continuous improvement in our environmental
management practices.

4. Sustainable Supply Chain Sözer Kuyumculuk will work with our suppliers to promote
sustainable practices throughout our supply chain. We will encourage our suppliers to
adopt environmentally friendly practices and comply with relevant environmental
regulations.
5. Stakeholder Engagement and Communication Sözer Kuyumculuk is committed to
engaging with our stakeholders and communicating transparently about our environmental
performance. We will:
a. Seek input from stakeholders on environmental matters and consider their concerns and
expectations.
b. Communicate our environmental policies, objectives, and performance to our employees,
customers, suppliers, and the public.
c. Respond to inquiries and concerns regarding our environmental practices in a timely and
transparent manner.
6. Monitoring and Reporting Sözer Kuyumculuk will establish monitoring and reporting
mechanisms to track our environmental performance. This includes:
a. Regularly measuring and monitoring key environmental indicators to assess our progress
towards our objectives and targets.
b. Reporting on our environmental performance to relevant stakeholders, including through
annual sustainability reports.
c. Conducting periodic internal audits to assess compliance with this policy and identify
areas for improvement.
7. Policy Review This policy will be reviewed periodically to ensure its effectiveness and
alignment with evolving best practices, technological advancements, and regulatory
requirements

Sözer Kuyumculuk San. ve Tic. A.Ş. Health and Safety (H&S) Policy


At Sözer Kuyumculuk San. ve Tic. A.Ş., we place great importance on health and safety issues in the
workplace. In this context, our Health and Safety (H&S) policy clearly outlines our approach and
commitments in this area. All our company locations, subcontractors, and subsidiaries are obliged
to strictly adhere to this policy and commitments.


Mission


As Sözer Kuyumculuk San. ve Tic. A.Ş., we shape our sustainable and profitable growth strategy in
line with the Sustainable Development Goals outlined in the United Nations Global Compact, to
which we are a signatory. Within this framework, we are committed to maximizing our health and
safety standards and aligning all our business processes with these goals.

Key Commitments of Our Polic

  • Healthy and Safe Working Environment: We commit to providing a healthy and safe
    working environment for our colleagues by developing approaches to prevent possible
    occupational diseases and injuries.
  •  Zero Accident Objective: We aim to achieve our zero accident objective by exerting all
    necessary effort to prevent accidents.
  •  Compliance with Legal and Group Policies: We commit to working in compliance with
    relevant legal obligations as well as Group policies and procedures.
  •  Continuous Improvement: We aim to manage our operational activities on the basis of
    continuous improvement.
  •  Utilization of Best Available Technology: We commit to continuously improving our H&S
    performance by using the best available technology.
  •  Cultural Change: We work towards internalizing this commitment within our company and
    making it part of our culture.

Implementation Principles

  •  Legal and International Compliance: We commit to acting in accordance with national and
    international legal regulations and other liabilities we are responsible for in H&S matters in
    all the geographies we operate, as well as in new investments and operations.
  •  Industry Leadership: We aim to become a leader in H&S matters in our specific industries.
    We develop collaborations on these issues and encourage the sharing of good practices in
    the industries in which we operate.
  •  Continuous Improvement and Target Setting: Based on continuous improvement, we set
    targets for H&S performance, create action plans for implementation, and closely monitor
    progress towards achieving these targets.
  •  Integration of International Best Practice Standards: We integrate internationally recognized
    principles and standards of good practice in H&S matters into our business processes.
  •  Encouragement of Awareness and Participation: We encourage our colleagues to make
    positive contributions to H&S performance and organize activities aimed at raising
    awareness about H&S among wider

As Sözer Kuyumculuk San. ve Tic. A.Ş., strict adherence to the principles and standards outlined in
our health and safety policy is one of our core values. All our employees play a critical role in the
implementation of this policy, and each is expected to act in accordance with the established
standards. This policy is not only a legal obligation but also a manifestation of our deep
commitment to protecting the health and safety of our employees.

For Preventing the Laundering of Proceeds of Crime, Terrorist Financing, and the Financing of the Proliferation of
Weapons of Mass Destruction, Sözer Kuyumculuk San. Tic. A.Ş. is committed to contributing to national and
international efforts to combat the laundering of proceeds of crime, terrorist financing, and the financing of the
proliferation of weapons of mass destruction (WMD), along with related crimes. As part of our compliance with
applicable regulations and corporate responsibility, we have established a comprehensive compliance program
within our organization.

Legal Framework

  • Our compliance program is constructed in adherence to the following legislative frameworks and their applicable
    secondary regulations:
  •  Law Nr. 5549 on the Prevention of Laundering of Proceeds of Crime
  •  Law Nr. 6415 on the Prevention of Terrorist Financing
  •  Law Nr. 7262 on the Prevention of Financing of the Proliferation of WMD
  •  Know Your Customer (KYC) Policy and related group procedures in alignment with international standards

Risk-Based Approach


Acknowledging that laundering and financing activities can manifest in various forms across different sectors, our
compliance program employs a risk-based approach. This methodology facilitates the identification and
assessment of potential laundering risks specific to our field of activity. It guides the establishment of criteria and
the implementation of effective methods to mitigate and control these risks.

Implementation Procedures


The core components of our compliance program include:

  •  Policy and Procedure Development: Establish corporate policies and procedures reflective of national risk
    assessments.
  •  Risk Management: Engage in proactive risk management activities.
  •  Monitoring and Control: Implement ongoing monitoring and control measures.
  •  Compliance Leadership: Appoint a compliance manager and establish a dedicated compliance unit.
  •  Education: Conduct regular training sessions for staff.
  •  Internal Audits: Carry out comprehensive internal audits.
  •  Reporting and Record-Keeping: Fulfill all reporting and record retention obligations.
  •  Customer Due Diligence: Adhere to stringent KYC principles, including customer due diligence.
  •  Information Sharing: Facilitate the exchange of account and transaction information within the financial
    group.

Responsibility and Review

The ultimate responsibility for the effective, adequate, and proper implementation of the compliance program rests
with the Board of Directors. All staff members are required to comply with the program’s mandates. Our corporate
policies and procedures are subject to periodic review, ensuring they remain current and are communicated
promptly to all personnel.

 

SÖZER JEWELLERY AML PROCEDURES IMPLEMENTATION
INSTRUCTIONS FOR REGULATORY MATTERS
LEGISLATION
First Aired Date30.03.2019
Last Revision Date19.09.2023
Last Revision NoMKP01/003
Document NoMKP01/000
TOPICAsset Freezing and Procedures and Principles to be Followed in the Execution of These Decisions
YEBLIGGeneral Communiqué of the Financial Crimes Investigation Board (Order No: 12)

 

1. PURPOSE


The purpose of this instruction is to ensure that Sözer Kuyumculuk San. Tic. A.Ş. (referred to as “Sözer” or
“Company”) complies with the regulations regarding “Asset Freezing and Procedures and Principles to be Followed
in the Abolition of These Decisions” within the framework of establishing Regulatory Compliance standards.

2. RESPONSIBILITY AND AUTHORITY


2.1 Director General’s Responsibility: The Director General is responsible for the implementation of this instruction.
2.2 Review and Update: The Director General is responsible for the periodic review and update of this instruction to
ensure its effectiveness and compliance with current laws and regulations.
2.3 Unit Manager(s) and Employee Compliance: The relevant Unit Manager(s) are responsible for ensuring that all
employees are fully informed of and comply with this instruction.

3. APPLICATION


In alignment with the “Procedures and Principles to be Followed in the Freezing of Assets and the Abolition of
These Decisions” under the scope of combating the financing of terrorism and the proliferation of weapons of
mass destruction, the following procedures apply:
3.1 Operation Service Review:
a) For ongoing precious metal sales transactions, if payment has been made, the precious metals are not delivered
to the buyer. Moreover, collected amounts, whether in cash or credited, will not be refunded.
b) For incomplete purchase transactions, precious metals that have been given but not paid for will not be returned
to the seller.
3.2 BIST Precious Metals and Precious Stones Market Transactions: If transactions involve the BIST Precious Metals
and Precious Stones Market, stock exchange authorities are immediately notified to freeze the assets of the
involved parties.
3.3 Ministry Notifications: All notifications from the Ministry are to be responded to in the same method they were
received, promptly upon completion of asset freeze transactions, and within a maximum of 7 days.
3.4 Non-Asset or Unregistered Asset Cases: Individuals without assets in our possession or whose assets cannot be
registered are reported to the Ministry with their identity information, noting these specifics.
3.5 Asset Record Holders: Information regarding the freezing of assets for those with recorded assets is
documented and reported to the Ministry.
3.6 Asset Freeze Lift Instructions: Following the Ministry’s instructions to lift an asset freeze, the action taken is
reported back to the Ministry accordingly.

4. Effective Date


This instruction becomes effective as per the relevant legislative provisions, from June 21, 2020.

Q. ANNEXES

  • Annexes for Clarification
  •  Annex 1: Example of Regulation Utilized
  •  Appendix 2: Example of Published Communiqué

Sözer Kuyumculuk San. ve Tic. A.Ş. Human Rights Policy

Purpose and Scope This Human Rights Policy (“the Policy”) is a guide that reflects Sözer
Kuyumculuk San. ve Tic. A.Ş.’s approach and standards in relation to human rights and shows the
importance Sözer Kuyumculuk attributes to respect for human rights. All employees, directors, and
officers of Sözer Kuyumculuk shall comply with this Policy. Each Sözer Kuyumculuk company also
expects and takes necessary steps to ensure that all its Business Partners – to the extent applicable
– complies with and/or acts in line with this Policy.

Elimination of discrimination in employment and occupation.

“The Women’s Empowerment
Principles” (WEPs) a set of Principles offering guidance to business on how to promote gender
equality and women’s empowerment in the workplace, marketplace, and community. Established
by UN Global Compact and UN Women, the WEPs are informed by international labor and human
rights standards and grounded in the recognition that businesses have a stake in, and a
responsibility for, gender equality and women’s empowerment.

General Principles As a globally acting group, Sözer Kuyumculuk takes the Universal Declaration
of Human Rights (UDHR) as its guide, and maintains a respectful understanding of Human Rights
for its stakeholders in countries where it operates. Creating and maintaining a positive and
professional working environment for its employees is the main principle of Sözer Kuyumculuk.
Sözer Kuyumculuk acts in compliance with the global ethical principles in subjects such as
recruitment, promotion, career development, wage, fringe benefits, and diversity and respects its
employees’ rights to form and join organizations of their own choosing. Forced labor and child
labor and all forms of discrimination and harassment are expressly prohibited. Sözer Kuyumculuk
primarily takes into consideration the below-mentioned international standards and principles
regarding Human Rights:

• The ILO Declaration on Fundamental Principles and Rights at Work
(1998),

• The OECD Guidelines for Multinational Enterprises (2011).

• The UN Global Compact (2000).
• The UN Guiding Principles on Business and Human Rights (2011).
• The Women’s Empowerment Principles (2011). • Worst Forms of Child Labour Convention (Convention No. 182), (1999)

Commitments


Sözer Kuyumculuk respects the rights of its employees, directors, officers, shareholders, Business
Partners, customers, and all other individuals affected by its operations, products, or services by
fulfilling the principles of the Universal Declaration of Human Rights (UDHR) and the ILO
Declaration on Fundamental Principles and Rights at Work. Sözer Kuyumculuk undertakes to treat
all employees in an honest and fair manner, and to provide a safe and healthy working
environment that respects human dignity while avoiding discrimination. Sözer Kuyumculuk may
also apply additional standards considering vulnerable and disadvantaged groups who are more
open to the negative Human Rights impacts and require particular attention. Sözer Kuyumculuk
considers the specific circumstances of groups whose rights are further elaborated by United
Nations instruments: indigenous peoples; women; ethnic, religious and linguistic minorities;
children; persons with disabilities; and migrant workers and their families, as indicated in the UN
Guiding Principles on Business and Human Rights.

Diversity and Equal Recruitment Opportunities Sözer Kuyumculuk strives to employ individuals
from different cultures, career experiences, and backgrounds. Decision-making processes in
recruitment depend on job requirements and personal qualifications regardless of race, religion,
nationality, gender, age, civil status, and disability.
Non-Discrimination Zero-tolerance towards discrimination is a key principle in the entire
employment process, including promotion, assignment, and training. Sözer Kuyumculuk expects all
its employees to demonstrate the same sensibility in their behavior towards each other. Sözer
Kuyumculuk cares to treat its employees equally by offering equal rights and opportunities. All
kinds of discrimination and disrespect founded on race, gender, color, national or social origin,
ethnicity, religion, age, disability, sexual orientation, gender definition, or political opinion are
unacceptable.
Zero Tolerance to Child / Forced Labor Sözer Kuyumculuk strongly opposes child labor, which
causes children’s physical and psychological harm, and interferes with their right to education. In
addition, Sözer Kuyumculuk opposes all forms of forced labor, which is defined as work that is
performed involuntarily and under the menace of any penalty. Pursuant to Conventions and
Recommendations of the ILO, the Universal Declaration of Human Rights, and the UN Global
Compact, Sözer Kuyumculuk has a zero-tolerance policy towards slavery and human trafficking
and expects all its Business Partners to act accordingly.

Freedom of Organization and Collective Agreement Sözer Kuyumculuk respects employees’
right and freedom of choice to join a trade union, and to collectively bargain without feeling any
fear of retaliation. Sözer Kuyumculuk is committed to a constructive dialogue with the freely
chosen representatives of its employees, represented by a legally recognized labor union. Health
and Safety The protection of health and safety of the employees, and other persons which are, for
any reason, present in a work area is one of the top concerns of Sözer Kuyumculuk companies.
Sözer Kuyumculuk provides a safe and healthy working environment. Sözer Kuyumculuk
companies take necessary security measures in workplaces in a manner that respects the dignity,
privacy, and reputation of each person. Sözer Kuyumculuk complies with all relevant regulations
and implements all required security measures for all its working areas. In the case of finding out
any unsafe conditions or unsafe behaviors in the working areas, Sözer Kuyumculuk companies take
necessary actions immediately to ensure the health, safety, and security of its customers and
employees.
No Harassment and Violence A key aspect of safeguarding the personal dignity of employees is
to ensure that harassment or violence does not occur, or if it occurs sanctioned adequately. Sözer
Kuyumculuk is committed to providing a workplace free of violence, harassment, and other
insecure or disturbing conditions. As such, Sözer Kuyumculuk does not tolerate any form of
physical, verbal, sexual or psychological harassment, bullying, abuse, or threats.
Working Hours and Compensation Sözer Kuyumculuk complies with the legal working hours in
line with the local regulations of the countries where it operates. It is crucial that employees have
regular breaks, vacations, and establish an efficient work-life balance. The wage determination
process is established in a competitive manner according to the relevant sectors and the local
labor market, and in accordance with the terms of collective bargaining agreements if applicable.
All compensations, including social benefits, are paid in accordance with the applicable laws and
regulations. Employees may request further information from the officer or department in charge
of compliance regarding the laws and regulations that regulate working conditions in their own
countries, if they wish so.
Personal Development Sözer Kuyumculuk provides its employees with opportunities to develop
their talent and potential, and to build their skills. Regarding human capital as the valuable
resource, Sözer Kuyumculuk puts effort into the employees’ comprehensive personal development
by supporting them with internal and external training.

Data Privacy In order to protect the personal information of its employees, Sözer Kuyumculuk
maintains high-level data privacy standards. Data privacy standards are implemented in
accordance with related legislations. Sözer Kuyumculuk expects the employees to comply with
data privacy laws in each of the countries it operates.
Political Activities Sözer Kuyumculuk respects its employees’ legal and voluntary political
participations. Employees may make personal donations to a political party or a political candidate
or engage in political activities outside working hours. It is, however, strictly forbidden to use
company funds or other resources for such donations or any other political activity.
Authority and Responsibilities
All employees and directors of Sözer Kuyumculuk are responsible for complying with this Policy,
implementing and supporting the relevant Sözer Kuyumculuk company’s procedures and controls
in accordance with the requirements in this Policy. Each Sözer Kuyumculuk company also expects
and takes necessary steps to ensure that all its Business Partners to the extent applicable comply
with and/or act in line with this Policy. If there is a discrepancy between the local regulations,
applicable in the countries where Sözer Kuyumculuk operates, and this Policy, subject to such
practice not being a violation of the relevant local laws and regulations, the stricter of the two,
supersede. If you become aware of any action you believe to be inconsistent with this Policy, the
applicable law or Sözer Kuyumculuk Code of Ethics, you may seek guidance or report this incident
to your line managers. You may alternatively report the incident to Sözer Kuyumculuk’s Ethics
Hotline via the following link: “sozerkuyumculuk.com.tr/hotline” Sözer Kuyumculuk employees may
consult the Human Resources Department in Sözer Kuyumculuk for their questions related to this
Policy and its application. Violation of this Policy may result in significant disciplinary actions
including dismissal. If this Policy is violated by third parties, their contracts may be terminated.
History This Policy takes effect on 19.12.2021 as of the date approved by the Board of Directors
and is maintained by Human Resources Department.

Sözer Kuyumculuk San. ve Tic A.Ş. Child Labor Policy

 

1. Introduction


Sözer Kuyumculuk San. ve Tic A.Ş. is committed to a stance of zero tolerance towards child labor in
its business practices, in accordance with the United Nations (UN) Convention on the Rights of the
Child and the International Labour Organization (ILO) standards. Our company aims to maintain its
leadership in the industry and to adopt high ethical standards, transparency, and responsibility in
all business processes by implementing a zero-tolerance policy against child labor.

 

2. Scope and Purpose


This policy encompasses all internal and external operations of Sözer Kuyumculuk San. ve Tic A.Ş.,
including the supply chain, subcontractors, suppliers, and business partners. Our goal is to be an
industry leader in preventing child labor, protecting and supporting children’s rights. This policy is
prepared in alignment with the guidance and standards provided by the UN and ILO.

 

3. Definition and Prohibition of Child Labor


Child labor refers to any work that negatively affects a child’s education, health, physical, mental,
moral, social, and spiritual development. Sözer Kuyumculuk San. ve Tic A.Ş. strictly adheres to the
minimum working age defined by the ILO and the UN Convention on the Rights of the Child in its
hiring processes. The age limit is based on the higher of the age when compulsory education is
completed or any higher age.

 

4. Responsibility and Implementation

  •  Supply Chain Management: The company clearly communicates its stance against child
    labor throughout the supply chain and demands the same standards from its suppliers.
  •  Auditing and Monitoring: Regular internal and external audits are conducted to ensure
    compliance with the company’s child labor policy. These audits are carried out within the
    framework of international norms and standards guided by the UN and ILO.
  • Training and Awareness: Training programs for employees and business partners aim to
    increase awareness of child labor and children’s rights. These trainings are based on the UN
    Convention on the Rights of the Child and ILO standards.

 

5. Violations and Complaint Mechanism

In the event of any violation related to child labor, individuals within or external to the company
can report the situation confidentially. The company takes all reported violations seriously and
swiftly implements necessary corrective measures. [https://sozer.com.tr/hotline]

6. Continuous Improvement

Sözer Kuyumculuk San. ve Tic A.Ş. regularly reviews and updates its policies and practices to
ensure continuous improvement and adoption of best practices in combating child labor.

 

7. Policy Review


Our child labor policy will be regularly reviewed and updated in accordance with the current
guidance and standards related to child labor provided by the UN and ILO.
Effective Date: [11/28/2015]
This policy demonstrates Sözer Kuyumculuk San. ve Tic A.Ş.’s clear and definitive stance against
child labor. As a company, we are committed to contributing to international efforts to protect and
support children’s rights.

Sözer Kuyumculuk San. ve Tic. A.Ş. Personal Data Protection Policy


This Sözer Kuyumculuk San. ve Tic A.Ş. Personal Data Protection Policy (“Policy”), which is part of
the Sözer Kuyumculuk San. ve Tic A.Ş. Code of Ethics, aims to provide a compliance framework and
coordinate compliance activities for Sözer Kuyumculuk San. ve Tic A.Ş. companies for complying
with Legislation on the protection and processing of personal data. In this context, the objective is
to ensure the personal data processing activities by Sözer Kuyumculuk San. ve Tic A.Ş. companies
are carried out in compliance with the principles of lawfulness, good faith, and transparency. The
employees and executives of Sözer Kuyumculuk San. ve Tic A.Ş. companies are obliged to act in
accordance with this Policy. Business Partners are also expected to act in accordance with the rules
and principles of this Policy to the extent that they are applicable to the relevant transactions.


Definitions


“Explicit Consent” Consent related to a specific subject, based on information and expressed with a
free will.
“Anonymization” Making personal data unrelated to an identified or identifiable natural person
under any circumstances, even when by matching with the other data.
“Data Subject” A real person of whom personal data are processed (customers, visitors, employees,
and employee candidates, etc.).
“Business Partners” Suppliers, vendors, authorized service companies, all kinds of representatives,
subcontractors, and consultancies acting on in the name of and on behalf of the company.
“Personal Data” Any information related to an identified or identifiable real person. “Processing of
Personal Data” Any activity performed on data such as obtaining personal data by fully or partially
automatic means or non-automatic means that are part of a data registration system; recording,
storage, retention, revision, modification, disclosure, transfer, receiving of data, rendering the data
obtainable or classification or prevention of use. “Sözer Kuyumculuk San. ve Tic A.Ş.” Refers to all
companies controlled directly by Sözer Kuyumculuk San. ve Tic A.Ş.,
“Legislation” All of the relevant legislation in force in Turkey and relevant countries regarding the
protection of personal data, especially the Law on the Protection of Personal Data No. 6698.
“Special Categories of Personal Data” Race, ethnic origin, political view, philosophical belief,
religion, religious sect or other beliefs, clothing style, association, foundation or union
membership, health, sexual life, criminal convictions, and security measures as well as biometric
and genetic data are special categories of personal data.

“VERBİS” Data Controllers Registry Information System “Data Processor” A real or legal person that
processes personal data for and on behalf of the data controller based on the authorization
granted by the data controller.
“Data Controller” A real or legal person who determines the objectives and means of personal data
processing and is responsible for the establishment and management of the data recording
system.

 

General Principles

Breach of this Policy may result in significant consequences for Sözer Kuyumculuk San. ve Tic A.Ş.
companies, their associated executives, and employees including legal, administrative, and criminal
penalties based on the Legislation in the region of operation, and, most significantly, the breach
may result in serious harm to the reputation of Sözer Kuyumculuk San. ve Tic A.Ş. companies.
One of the most important issues for Sözer Kuyumculuk San. ve Tic A.Ş. companies is to act in
accordance with the Legislation and the general principles set out in the Legislation with regards to
the processing of personal data. In this regard, Sözer Kuyumculuk San. ve Tic A.Ş. companies are
expected to follow the guidelines outlined below when processing personal data in compliance
with the Legislation.
Sözer Kuyumculuk San. ve Tic A.Ş. carries out the personal data processing practices within the
scope of its activities in accordance with the Sözer Kuyumculuk San. ve Tic A.Ş. Personal Data
Protection and Processing Policy.
[The rest of the document would continue with the updated company name, ensuring consistency
throughout the entire policy.]

3.1. Processing of Personal Data in Accordance with the Law and Principle of Good Faith
The general rule of trust and good faith in compliance with the Legislation must be adhered to on
the subject of personal data processing. In this context, personal data should be processed in
accordance with general principles of law, good-will, and general morality to the extent required
by business activities and limited to these activities.
3.2. Ensuring that Personal Data is Accurate and Up-to-date When Required
Systems must be established, and necessary measures must be taken to ensure that the personal
data being processed are accurate and up-to-date while taking account of data subjects’ rights.

 

3.3. Processing of Personal Data for Specific, Explicit, and Legitimate Purposes
Personal data must be processed for legitimate and lawful purposes. Sözer San. ve Tic A.Ş. must
only process personal data in connection with their activities and to the extent necessary. Prior to
personal data processing operations, the purposes for processing personal data should be
determined.
3.4. Being Limited, Proportionate, and Relevant to the Purpose of Processing
Personal data must be processed adequately for carrying out the determined purposes and
processing of personal data that is not necessary for fulfilling the purposes must be avoided.
3.5. Storing for the Period Stipulated in the Relevant Legislation or the Period Required for
the Processing Purpose
Personal data must only be stored for the period stipulated in the relevant Legislation or for the
period required for the personal data processing purpose. In this regard, firstly determination must
be made whether a certain period is stipulated for the storage of personal data in the relevant
Legislation, if any period is determined, this period should be complied with. If no period is
determined, personal data must be stored for the period required for carrying out the purpose of
the processing. Personal data must be erased, destructed, or anonymized in case the period
expires or the reason for its processing no longer exists. Personal data must not be stored based
on the possibility of future use.


Application of The Policy


1. Processing Personal Data Based On The Data Processing Conditions
4.1.1. Execution of Personal Data Processing Activities Based on the Personal Data
Processing Conditions Specified in the Legislation
As a rule, personal data must be processed based on at least one of the conditions specified in the
Legislation. Determination should be made on whether the personal data processing activities
carried out by the company’s business units are based on at least one of the conditions. Personal
data processing activities that do not meet this requirement should not be included in the
processes.

 

4.1.2. Execution of Special Categories of Personal Data Processing Activities Based on
Special Categories of Personal Data Processing Conditions Stipulated in the Legislation
As a rule, special categories of personal data must be processed based on the conditions specified
in the Legislation. Sözer San. ve Tic A.Ş. must ensure that the special categories of personal data
processing activities carried out by the company’s business units are in line with these conditions,
the necessary technical and administrative measures for the processing of the special categories of
personal data must be taken and it must be ensured that the following conditions are met: (i)
Special categories of personal data excluding health and sexual life can be processed without the
explicit consent of data subjects if it is explicitly stipulated in the laws. Otherwise, explicit consent
of the data subject should be obtained. (ii) Special categories of personal data regarding health
and sexual life can be processed without the explicit consent of data subjects for the purposes of
the protection of public health, carrying out preventive medicine, medical diagnosis, treatment and
care services, planning of financing and management of health services by persons who are bound
with professional secrecy or legally authorized authorities and institutions. Otherwise, explicit
consent of the data subject should be obtained.
Processing of special categories of personal data must be carried out in accordance with the
provisions set out in the Legislation regarding the processing of special categories of personal data
and transfer of data to domestic third parties and abroad. In addition, personal data processing
activities must also be carried out by fulfilling the special requirements set forth in the Legislation.
2. Requirements To Be Complied With For Transfer Of Personal Data
Personal data of data subjects should be transferred to third parties in accordance with the
purposes and legal basis for personal data processing and by taking the necessary security
measures. In this regard, necessary processes for acting in accordance with the conditions
stipulated in the Legislation must be designed.

3. Obligations Related To The Protection And Processing Of Personal Data

4.3.1. Obligation to Register with VERBİS
Sözer San. ve Tic A.Ş. must register with VERBİS as Data Controllers if they are under the obligation
to register according to the criteria stipulated in the Legislation. In case of a revision in the
registered information, the information in VERBİS must be updated within seven days from the
date of revision.
Sözer San. ve Tic A.Ş. Legal and Compliance Department must be given a report and the
company’s department or officer in charge of compliance must be informed twice a year, every 6-
month periods (June-December) regarding the updates made by the Sözer San. ve Tic A.Ş.
companies in VERBİS.
Continued adherence to the remaining sections of the policy is essential, applying the
updated company name “Sözer Kuyumculuk San. ve Tic A.Ş.” wherever necessary to ensure
consistency and compliance with the Legislative requirements.

Sözer Kuyumculuk San. ve Tic A.Ş. Whistleblower Policy


1. Introduction


Sözer Kuyumculuk San. ve Tic A.Ş. is committed to maintaining its leadership position in the
industry and adopting high ethical standards, transparency, and accountability in all business
processes, in compliance with the Responsible Jewellery Council (RJC) and all relevant legal
regulations. Accordingly, our company has developed a secure and effective whistleblower policy
for reporting any unethical behavior, corruption, and activities contrary to policies or legal
regulations. This policy is designed to protect whistleblowers and ensure that any potential
violations are investigated fairly.


2. Scope and Purpose of the Policy


This whistleblower policy covers all employees, managers, customers, suppliers, and other
stakeholders of Sözer Kuyumculuk San. ve Tic A.Ş. The purpose of the policy is to facilitate the safe,
confidential, and anonymous reporting of violations, and to ensure that reported violations are
evaluated effectively and necessary corrective and preventive actions are taken. This policy
reinforces the company’s commitment to laws, ethical rules, and sectoral standards, while also
fostering a culture of trust and honesty.


3. Subjects of Reporting


The range of issues that can be reported by whistleblowers is broad and generally includes, but is
not limited to, the following:

  •  Corruption, bribery, and fraud activities
  •  Behaviors contrary to company policies and procedures
  •  Non-compliance with legal and regulatory requirements
  •  Violations of occupational health and safety standards
  •  Violations of environmental protection standards
  •  Violations of human rights and labor standards
  •  Privacy and data protection breaches

 

4. Mechanism and Process of Reporting


Sözer Kuyumculuk San. ve Tic A.Ş. offers multiple channels to facilitate easy and secure reporting.
These channels include a specially designed hotline, email address, written letters, or a secure
internet portal. Reports can be made anonymously, and all reports are treated with the highest
degree of confidentiality. Each reported case is initially subjected to a preliminary review and,
where necessary, detailed investigations are conducted according to the seriousness and nature of
the issue. The investigation process is based on principles of transparency, fairness, and prompt
action.

OUR WHISTLEBLOWER CHANNELS
Via e-mail: Compliance@sozer.com.tr
Via Web: sozer.com.tr/hotline
Phone: +90 212 655 83 72 (Mrs. Sibel Tezcan)

5. Protection and Confidentiality


Sözer Kuyumculuk San. ve Tic A.Ş. places great importance on protecting the identities of
whistleblowers and ensuring they do not face any retaliation or discrimination after making a
report. The company explicitly prohibits any form of retaliation against whistleblowers and
commits to taking serious action in case of violation.


6. Continuous Improvement and Training


The company will continuously review and improve the effectiveness and appropriateness of the
whistleblower policy. Additionally, regular training and awareness programs will be conducted for
employees on ethical behavior, combating corruption, and the importance of the whistleblower
policy.

 

7. Policy Review and Update


This whistleblower policy will be regularly reviewed and updated to align with the company’s
needs, legal regulations, and best practices. The effective implementation of this policy is the
responsibility of the company’s management team, and all employees are expected to understand
and apply this policy.


Effective Date: [02/14/2023]
Sözer Kuyumculuk San. ve Tic A.Ş., through this whistleblower policy emphasizing the importance
of an ethical and responsible business world, invites all its employees and stakeholders to
contribute to maintaining a transparent and fair working environment.

Sözer Kuyumculuk San. ve Tic. A.Ş. Due Diligence Process Policy

Sözer Kuyumculuk San. ve Tic. A.Ş., specializing in gold, silver, and diamond jewelry, is dedicated to
conducting its business with integrity, transparency, and respect for human rights and
environmental standards. This policy outlines the due diligence process for ensuring ethical
sourcing and responsible business practices in the procurement and sale of gold, silver, and
diamond jewelry.

 

Purpose


The purpose of this policy is to establish a robust framework for identifying, assessing, and
mitigating risks associated with the sourcing and supply chain of gold, silver, and diamonds. This
includes risks related to conflict financing, human rights abuses, and environmental degradation.
Scope


This policy applies to all operations, employees, suppliers, and business partners of Sözer
Kuyumculuk San. ve Tic. A.Ş. involved in the sourcing, manufacturing, and distribution of gold,
silver, and diamond jewelry.

 

Due Diligence Process, Risk Assessment:


Perform regular risk assessments to identify potential ethical and compliance risks in the supply
chain of gold, silver, and diamonds.
Pay special attention to sourcing from conflict-affected and high-risk areas (CAHRAs).


Supplier Vetting and Verification: