1.PURPOSE

The purpose and scope of the Anti-Discrimination and Harassment Policy is to determine the rules that must be taken into account in order to ensure a workplace free from all forms of discrimination and harassment.
Trasta ESG adopts a zero-tolerance policy against discrimination and harassment to ensure that its employees, collaborators and visitors can work in a safe, respectful and equitable environment. This policy was created to eliminate any form of discrimination or harassment on the basis of race, color, religion, language, sex, age, disability, sexual orientation, gender identity, ethnicity, national origin, marital status, pregnancy status, political opinion, or other personal characteristics.
All employees, directors and officers of Trasta ESG shall comply with this Policy, which is an integral part of the Company. The Company also expects all Business Partners to comply with and/or act in accordance with this Policy and takes the necessary measures to do so.

2.DEFINITIONS

Discrimination

These are unfair behaviors that lead to negative treatment of a person due to reasons such as gender, race, skin color, religion or belief, political opinion, sexual orientation, age, disability or national, social or ethnic origin.

Harassment

Harassment is when a person psychologically, physically, or emotionally harasses another person through disruptive, humiliating, or threatening behavior.

Policy Enforcement and Employee Responsibilities

All of our employees are obliged to act in accordance with these policies. Employees who are discriminated against, witness, or suspect discrimination or harassment can report it by following the steps outlined below:

Complaint Notification and Application Process:

  1. Internal Notification: An employee who detects discrimination or harassment can first apply to their manager, and if the source of the problem is their manager, they can apply to the higher level organizationally.
  2. Written Report: Complaints can be submitted in writing and the situation will be kept confidential. Any complaint will be processed while protecting personal security and anonymity, and an environment suitable for retaliation will not be created.

Responsibility:

Trasta ESG management has the responsibility to evaluate all complaints received seriously and objectively, to impose disciplinary penalties on those who are found guilty after the evaluation, in line with their internal regulations, and to protect the complainant.

3.Education and Awareness

Our company provides trainings to all its employees and managers to raise awareness about discrimination and harassment. The purpose of these trainings is to inform employees about potential discrimination and harassment situations, to guide them on how to prevent such behaviors, and to strengthen the respectful working environment within the company.

4.Relevant Regulations

This Policy; It is an integral part of Trasta ESG’s Code of Ethics, discrimination and harassment regulations and practices in these matters, external legislation and other legal regulations that it has to comply with.

5.Effective

The policy enters into force following the approval of the Board of Directors.