OUR POLICIES

As a pioneer in the contracting industry, Koloğlu Holding pivots corporate sustainability around its business mentality. Based upon this approach, Koloğlu Holding adopts the strategies that promote sustainable development both in the parent company and subsidiaries and operates in Türkiye and other geographies with raised awareness in communities and environments. 

In this direction, Koloğlu Holding aims at performing its activities within the scope of the following principles: 

• to operate in compliance with relevant local and international legislations, 

• to show an approach that regards the UN Sustainable Development Goals in accordance with sustainability strategies and activities, 

• to conduct its activities in compliance with the ethical code of conduct and pursuant to corporate governance principles, 

• to manage the environmental impacts that originate from its activities at optimum and to take relevant measures to conserve biological diversity and natural resources, 

• to act with the awareness of risks posed by climate change, 

• to operate with business processes and policies that regard human rights, occupational health, and safety based upon a mindset to ensure safe and decent work conditions, to announce its approach with “Human Rights Policy” to its stakeholders, and to relay this approach to its employees and supply chain, 

• to adopt technologies and applications that support energy and resource productivity, 

• to follow R&D and innovation-driven business development approach, 

• to act in countries of operation with a goal to support local communities and regional development, 

• to take into account the expectations of its stakeholders, consider their contributions, and care for building long-term relations with stakeholders, 

• to maintain its support to the community and sustainable development through social responsibility projects, 

• to follow the sustainability approach in the supply chain through “Supply Chain Policy”, and 

• to support sectorial sustainability applications in parallel with membership cooperations and initiatives. 

This policy is followed periodically as per requirements and is updated if and when deemed necessary. Sustainability Committee is responsible for updating this policy. This policy became effective on 02.06.2021 upon approval by the Board of Directors.

Operating in the contracting industry, Koloğlu Holding aims at sustainable growth and development with its activities. Caring about reflecting its sustainability approach to its employees and its regions of operation, human rights is a priority issue for Koloğlu Holding. With this policy, Koloğlu Holding intends:

• to act in compliance with the national legislations about working conditions in force in the countries of operation, 
•  to conduct its activities in line with the Universal Declaration of Human Rights and the International Labor Organization that Türkiye is a party to, 
•  to act in accordance with the national legislations on forced labor and child employment and with the international conventions that Türkiye is a party to, 
•  to avoid discrimination and to respect the employees’ right to organization and bargaining, 
•  to avoid discriminating its employees due to language, religion, gender, ethnicity, marital status, age about matters experienced by employees during their recruitment and their careers, including but not limited to promotion, salary, vested benefits, paid and unpaid leaves, 
•  to adopt a zero-tolerance policy in regards to all kinds of discrimination and physical, sexual, psychological, and/or emotional abuse, 
•  to respect human rights and offer decent work conditions, and take any necessary actions to provide its employees with a healthy and safe working environment, 
•  to encourage employees in their careers and personal development, 
• to respect vested interests in the local communities in its countries of operation, 
•  to consider the expectations of stakeholders, care for stakeholder engagement, and to regard building long-term relations with stakeholders, 
•  to expect subcontractors, suppliers, and service providers to act in compliance with human rights and to issue warnings if any breach thereof is noticed. 

This policy is followed periodically as per requirements and is updated when deemed necessary. The Sustainability Committee is responsible for updating this policy. This policy became effective on 02.06.2021 upon the approval of the Board of Directors.

Operating in the contracting industry, Koloğlu Holding aims at supporting sustainable growth and development through its activities. Koloğlu Holding publishes this policy to reflect its sustainability approach to its suppliers and subcontractors, and to adopt a responsible supply chain policy in this regard. 

In accordance with this policy, Koloğlu Holding expects from its suppliers, subcontractors, and service providers: 

• to act in line with the policies of Koloğlu Holding,

• to respect the relevant laws and legislations in their regions of operation, to act in accordance with the labor legislations in force in their countries of operation about working hours, leaves, wages, and vested rights, and to perform their liabilities of compliance to legal environmental legislations during their activities, 

• to respect the occupational health and safety rules at worksites and production facilities and to take any necessary measures, 

• to avoid forced labor and child employment, 

• to respect the employees’ rights of unionization and decisions to become a union member, and rights of organization and bargaining provided to comply with the laws, to respect human rights, and to act in accordance with the principles of decent work and human dignity, 

• to avoid discrimination based upon race, ethnicity, age, position, gender, gender identity, color, homeland, marital status, pregnancy, dependents, disability, social class, union membership or political views, 

• to follow and manage their environmental impacts originating from their operations within the scope of relevant legislations, 

• to follow applications focused on energy and resource productivity, 

• to respect quality standards in products and services, and 

• to raise their awareness of emissions and carbon footprints. 

With a value-driven sense in the chain of its activities, Kolin Construction respects the progress of its suppliers in sustainability and acts in accordance with a responsible supply chain approach. 

This policy is followed periodically as per requirements and is updated when deemed necessary. The Sustainability Committee is responsible for updating this policy. This policy became effective on 02.06.2021 upon the approval of the Board of Directors.

1. Identity of Data Controller 
Koloğlu Holding Corp., (hereinafter referred to as “Koloğlu Holding” or “Company”) exercises utmost due diligence for the safety and confidentiality of your data. In this sense, we hereby inform you as follows under the capacity of data controller pursuant to the Law on the Protection of Personal Data Nr. 6698 (hereinafter referred to as the “Law”) within the scope of the obligation to clarification to ensure our activities are performed in compliance with the Law related to the personal data we have acquired: 

2. Processing Personal Data and Purposes of Processing 
Your data is processed for the purposes of optimum delivery of the services by our Company, varying from services and commercial activities offered by Koloğlu Holding. In this context: 

If and when you visit our company, your personal identifying information, and physical space safety data may be processed to ensure compliance with the procedures and policies of Koloğlu Holding and to guarantee the security of physical spaces. 
If and when you visit our website, process security data may be processed limited to keeping electronic logs for the purpose of fulfilling the liabilities arising from the legislation pursuant to the law nr. 5651 and to ensure compliance with the policies and procedures of Koloğlu Holding and to execute information security processes. 
In addition to the above, identities, contact information, physical space security, occupational, financial and customer process data and backgrounds of our customers, either natural or legal identities, our subcontractors, suppliers, business partners, and employees/contacts/partners/executives of our consulting companies may be processed limited to ensure business continuity of contracts and/or tender processes and to execute business operations, to conduct financing and accounting and pricing policy, purchase of goods/services and sale of goods/services, audit/ethical activities and internal audit/investigation/intelligence activities, to conduct risk management processes and to organize travels including visa applications upon request, to carry out the activities in compliance with the legislation, to pursue and conduct legal affairs, to ensure continuity of information systems, to execute storage and archive processes, and to ensure compliance with relevant legislations and the policies of procedures of Kolin Construction. 

3. To Whom and for Which Purposes the Processed Personal Data May be Transferred 
Your data collected may be transferred to official institutions and organizations, auditors, group companies, consultants, insurance companies, authorized services, health check companies, arbitration centers, employers, vehicle tracking and fleet management companies, law firms, banks, agencies, business partners and suppliers and local information technology companies that we receive services from and make cooperation and the main shareholder of our company due to operational processes and supports and their group companies and their common databases provided to be for the purposes specified in Article 2 of this Clarification Text and to be within the scope of the relevant legislation and for the reasons and to be limited to the reasons that require the transfer thereof. 

4. The Method and Legal Basis for the Collection of Personal Data 
Your data may be collected through automatic and non-automatic methods, verbal or written information delivered via our electronic mail address by your employer or directly by your party, applications, and software used within the scope of the Company activities, and closed circuit camera system registries provided to be based upon and limited to the legal grounds for your explicit consent and the legitimate interest of data controller or the execution of the agreement, establishing or exercise a right as specified in Article 5 of the Law in accordance with the basic principles stipulated in the Law and for the purposes explained in Article 2 of this Clarification Text. 

5. Other Rights Related to the Protection of Personal Data 
You are entitled, within the legislation on the protection of personal data, to learn whether your data is being processed, to request information if your data has been processed, to learn the purpose of the processing of your data, and whether it has been used for intended purposes, to learn which third parties domestic or abroad your data has been transferred to, to request correction if your data has been processed incompletely or inaccurately and to demand the notification thereof to any third parties that have been transferred such data, to request the deletion or destruction of personal data if the reasons for processing no longer exist and to demand the notification thereof to any third parties that have been transferred such data, to object to any negative consequences against your party due to analysis of processed data only through automatic systems, to claim damages if you suffer any damages due to illegitimate processing of your data. 

Pursuant to the Law, you may make applications regarding your data with the form provided at www.kologluholding.com.tr through one of the following means: 

Personally to 100. Yıl Mahallesi Horasan Sokak No: 14 Çankaya / Ankara through identity verification or 
To our email address at kologluholding@hs03.kep.tr or 
To our company’s kvkk@kolin.com.tr address through secure electronic or mobile signature or 
To our party through other procedures stipulated in the Law and relevant legislation through identity verification. 
Our company shall respond to applications within 30 (thirty) days at the latest depending on the nature of the request in accordance with Article 13 of the Law. In the case where such a request is denied, the ground(s) for rejection shall be provided in written or electronically.