TOHUM A.Ş.® – HUMAN RIGHTS POLICY

TOHUM Defence Aerospace Strategy Development and Advanced Research Projects Inc.

HUMAN RIGHTS POLICY

1.0 Objective

The purpose of this policy is to demonstrate the position of TOHUM Savunma Uzay Havacılık Strateji Geliştirme ve İleri Araştırma Projeleri A.Ş. (hereinafter referred to as TOHUM Inc. or TOHUM), its affiliated institutions and organizations, TOHUM ‘s position that observes international humanitarian law and human rights in the context of its business and activities and respects all these laws and regulations. This policy constitutes a source of human rights principles that guide TOHUM ‘s performance.

2.0 Policy

TOHUM treats each and every individual working under its structure with common sense and respect for human rights. TOHUM is based on the United Nations Universal Declaration of Human Rights and other fundamental human rights principles and documents in the management of its activities. All TOHUM employees and anyone acting on behalf of TOHUM are required to act in accordance with these standards.

TOHUM’s most fundamental activity is to ensure the safety of people and property. However, it is important to note that TOHUM employees may need to risk lives or property to ensure the safety of customers. The purpose of this policy is to indicate the appropriateness of the activities involved in the business process rather than to restrict the services TOHUM provides to its customers.

3.0 Scope

This policy covers all employees under the TOHUM structure, particularly contracted parties operating in opposition areas or carrying weapons.

4.0 Human Rights Principles

4.1 Human Rights Obligations

TOHUM supports the implementation of the fundamental human rights contained in the UN Universal Declaration of Human Rights and other recognized fundamental human rights. TOHUM values its employees, contracted parties and all individuals in the course of its business. In line with this commitment, TOHUM supports all human rights, including the following:

Right to life, liberty and security of person : Supports the right to life and liberty; values personal safety. The safety of its employees and business partners is its priority. It is TOHUM ‘s policy to provide a safe, healthy and productive working environment.

Refusal to accept torture or inhuman treatment or punishment : TOHUM does not tolerate cruel or inhuman treatment of individuals. Any form of torture (as defined in the UN Convention against Torture and Other Cruel) is also among the behaviors it does not tolerate.

Opposition to sexual abuse : All acts of a sexual nature are strictly prohibited, whether direct or threatened, through the use of force, creating inequality, actual or perceived, or even through the use of force majeure. This prohibition includes being with sex workers, regardless of whether sex work is legal in the area of operation.

Right to recognition : TOHUM supports the recognition of private individuals as equal persons before the law, but also states that it is aware of the processes that precede due process of law.

Freedom of expression of opinion : TOHUM believes that individuals have the right to express their opinions freely.

Anti-discrimination / Equal opportunity : TOHUM values and supports diversity, and equally values the efforts and participation of every constituent with whom it works and who strives to keep their workplace free from all forms of discrimination and bullying while working for TOHUM. It prohibits and does not support the bullying or discrimination of its employees based on their personal beliefs, opinions or characteristics. Job decisions should be based on skills, performance, competencies and experience.

Freedom of Participation : TOHUM respects the right of our employees to decide whether to form, join or not to join a union, with the commitment that they will not face any anxiety, fear, threat or retaliation. TOHUM does not support and prohibits forced labor, slave labor, slavery and other forms of labor incompatible with human morality.

In addition to these fundamental human rights, which are grounded in the International Declaration, TOHUM is guided by what it believes to be reasonable principles, responsibilities, voluntary commitments and good practices in general:

Montreux Document on Pertinent International Legal Obligations and Good Practices for States Related to Operations of Private Military and Security Companies During Armed Conflict (2008);
International Code of Conduct for Private Security Service Providers (2010);
United Nations Guiding Principles on Business and Human Rights;
The Voluntary Principles on Security and Human Rights (2000);
UN Guiding Principles on Business and Human Rights; Implementing the United Nations “Protect, Respect and Remedy” Framework (2011);
Management System for Quality of Private Security Company Operations (PSC.1);
Management System for Private Security Operations (ISO 18788:2015).

The above list provides examples of commonly-recognized human rights standards and is not intended to be exclusive or exhaustive. Other commonly-recognized sources of international human rights include: the Chemical Weapons Convention; the International Convention on the Elimination of All Forms of Racial Discrimination; Convention on the Rights of the Child; Covenant on Economic, Social, and Cultural Rights; the Convention against Torture; and The Geneva Conventions (including Protocols Additional to the Geneva Conventions).

4.2 Additional Liabilities

In addition to the human rights principles defined above, TOHUM is guided by the following fundamental principles:

TOHUM supports fundamental human rights and does not engage in business activities that may be considered human rights violations or in areas where its actions may directly lead to human rights violations;
TOHUM acts within legal, moral and ethical values in a manner that does not contradict the laws, customs and traditions of the region in which it does business;
TOHUM pledges to support international and local efforts to combat and end financial crime and corruption;
TOHUM respects the values, culture and traditions of the communities in which it does business;
TOHUM regularly reviews the human rights impacts of its operations using human rights impact assessment tools;
TOHUM supports any individual who seeks to raise public awareness of any human rights violations and prohibits any form of retaliation for such efforts;
TOHUM ensures that its personnel are continuously informed and trained on how to work and act correctly, including TOHUM ‘s commitment to protect human rights and prevent human trafficking.

5.0 Human Rights Related Reports

In accordance with the requirements set forth in this Code of Conduct and TOHUM ‘s Whistleblowing Policy, all staff members who suspect or know of a human rights violation, based on what is stated in this document, are required to inform their managers and Authorized Juridical Managers.

They may also contact TOHUM ‘s founders directly. Employees or third parties have the opportunity to report TOHUM in complete confidence and anonymously online at etik@tohum.com.tr. Reports made to this address will be investigated directly by the founders or their authorized personnel.

Due to TOHUM ‘s compliance with its responsibilities under this policy, all reports of potential violations will be thoroughly investigated. All employees must be willing to provide honest and accurate information so that TOHUM can identify any illegality or unethical behavior.

6.0 Potential Infringements and Discipline

Any employee or third party working within TOHUM or for TOHUM who directly or indirectly violates this policy will face disciplinary action up to and including termination of employment.