Human Resources Policy

HR Policy
1.1 Purpose and Scope
Runitas Bilisim recognizes that its employees are fundamental to the company’s sustainable growth, service quality, ethical standards, and long-term success.
The purpose of this Human Resources Policy is to establish the principles governing recruitment, employment, development, performance management, employee relations, workplace conduct, occupational health and safety, equality, and pre-employment screening at Runitas Bilisim.
This Policy applies to all employees of Runitas Bilisim and, where appropriate, to candidates, interns, temporary personnel, and other individuals engaged through employment-related arrangements.
Human Resources practices are carried out in accordance with applicable laws and regulations, Runitas Bilisim’s ethical principles, compliance requirements, and internal policies.

1.2 Human Resources Strategy
Runitas Bilisim’s Human Resources strategy is designed to attract, develop, retain, and engage qualified professionals while creating a fair, inclusive, ethical, and high-performance working environment.
Our Human Resources objectives include:
• attracting and retaining qualified and ethical employees;
• supporting continuous professional and personal development;
• maintaining fair and objective recruitment and employment practices;
• promoting accountability, integrity, and responsible business conduct;
• supporting employee engagement and collaboration;
• providing equal employment opportunities;
• maintaining a safe and respectful workplace; and
• ensuring that Human Resources practices support Runitas Bilisim’s compliance and risk-management objectives.
Human Resources processes are periodically reviewed and improved in accordance with organizational needs, applicable legislation, and recognized business practices.

1.3 Recruitment and Selection
Runitas Bilisim aims to recruit candidates based on qualifications, professional experience, competencies, integrity, and suitability for the relevant position.
Recruitment and selection decisions are made objectively and without unlawful discrimination.
Depending on the nature and seniority of the position, recruitment may include:
• review of professional experience and qualifications;
• competency-based interviews;
• technical assessments;
• reference checks;
• verification of relevant education or professional qualifications;
• pre-employment background screening; and
• compliance-related assessments where appropriate.
Recruitment processes shall be conducted in accordance with applicable employment and personal data protection legislation.

1.4 Talent and Career Management
Runitas Bilisim supports the professional development and career progression of its employees in line with individual competencies, performance, organizational requirements, and business objectives.
Talent management activities may include:
• competency assessments;
• career development planning;
• succession planning for critical roles;
• identification of training and development needs;
• professional certification support; and
• leadership development.
The organization periodically reviews its workforce requirements and organizational structure to ensure that it has the appropriate skills and resources to support its business objectives.

1.5 Performance Management
Runitas Bilisim maintains a performance management approach designed to align individual responsibilities and objectives with company goals.
Performance assessments may consider:
• achievement of assigned objectives;
• quality of work and service delivery;
• professional and technical competencies;
• collaboration and communication;
• customer orientation;
• ethical conduct;
• compliance with company policies; and
• contribution to organizational objectives.
Performance discussions are intended to provide employees with constructive feedback, identify development opportunities, and support continuous improvement.

1.6 Learning and Development
Runitas Bilisim encourages continuous learning and professional development.
Employees may participate in internal or external training programs relating to:
• technical competencies;
• professional certifications;
• information security;
• data protection and privacy;
• occupational health and safety;
• ethics and compliance;
• anti-bribery and anti-corruption;
• business partner requirements; and
• leadership and management skills.
Training requirements may vary depending on an employee’s role, responsibilities, seniority, and risk exposure.
Where appropriate, records of required compliance-related training shall be maintained.

1.7 Employee Engagement and Communication
Runitas Bilisim encourages open communication, collaboration, and constructive feedback.
Employees are encouraged to raise questions, concerns, suggestions, and workplace issues through appropriate management, Human Resources, or compliance channels.
The company may periodically assess employee satisfaction, engagement, organizational culture, and workplace practices and may implement improvement measures based on the results.

1.8 Compensation, Recognition and Benefits
Runitas Bilisim aims to maintain fair, competitive, and performance-oriented compensation and benefit practices.
Compensation and benefits may be reviewed periodically by considering:
• responsibilities of the position;
• professional experience;
• employee performance;
• internal equity;
• market conditions; and
• applicable legal requirements.
Recognition and reward practices are intended to support high performance, professional development, collaboration, and contribution to company objectives.

1.9 Labor Relations and Employment Compliance
Runitas Bilisim conducts its employment practices in accordance with applicable labor and employment legislation.
The company monitors relevant legal and regulatory developments and updates its employment practices where necessary.
Employment records and Human Resources documentation shall be maintained in accordance with applicable legal, regulatory, privacy, and record-retention requirements.

1.10 Occupational Health and Safety
Occupational health and safety is an integral part of Runitas Bilisim’s workplace culture.
Runitas Bilisim aims to provide a safe and healthy working environment and to identify, assess, and mitigate workplace risks.
Occupational health and safety activities are carried out in accordance with applicable legislation and may include:
• workplace risk assessments;
• employee health and safety training;
• emergency preparedness;
• incident reporting;
• preventive measures; and
• periodic review of workplace conditions.
Employees are expected to comply with applicable occupational health and safety requirements and promptly report identified hazards or unsafe conditions.

1.11 Equality, Diversity and Non-Discrimination
Runitas Bilisim is committed to providing equal employment opportunities and maintaining a professional working environment free from unlawful discrimination and harassment.
Employment decisions shall not be based on characteristics protected under applicable law.
Recruitment, compensation, development, promotion, and other employment-related decisions are based on legitimate business considerations, including qualifications, competencies, experience, performance, and organizational requirements.
Runitas Bilisim values different perspectives and supports an inclusive working environment based on mutual respect and professional conduct.

1.12 Ethical Conduct and Compliance
All Runitas Bilisim employees are expected to conduct business honestly, ethically, professionally, and in accordance with applicable laws, company policies, contractual obligations, and compliance requirements.
Employees are expected to:
• avoid bribery, corruption, fraud, and other improper conduct;
• identify and disclose actual or potential conflicts of interest;
• protect confidential and proprietary information;
• respect intellectual property rights;
• comply with applicable information security and personal data protection requirements;
• maintain accurate business records; and
• report suspected violations through appropriate internal channels.
Employees are expected to cooperate with legitimate internal compliance reviews and investigations.

1.13 Conflicts of Interest
Employees must avoid situations in which personal, financial, family, government, or other external relationships improperly influence, or appear to influence, their professional judgment or responsibilities.
Employees are expected to disclose actual or potential conflicts of interest to management and/or the Compliance Officer where appropriate.
Identified conflicts shall be assessed and, where necessary, appropriate mitigating measures shall be implemented and documented.

1.14 Employee Data Protection and Confidentiality
Runitas Bilisim processes employee and candidate personal data in accordance with applicable personal data protection and privacy legislation.
Personal information shall be collected and processed only where relevant and proportionate for legitimate employment, Human Resources, legal, security, or compliance purposes.
Access to Human Resources records shall be limited to authorized personnel with a legitimate business need.
Employee and candidate information shall be protected against unauthorized access, disclosure, alteration, or misuse.

1.15 Pre-Employment Background Checks and Screening
Runitas Bilisim is committed to maintaining high standards of integrity, ethical conduct, and regulatory compliance in its recruitment and employment practices.
As part of recruitment and onboarding, Runitas Bilisim maintains a documented, risk-based pre-employment screening process.
The nature and extent of screening shall be proportionate to the responsibilities and risk profile of the position and shall be conducted in accordance with applicable laws, including applicable personal data protection and employment legislation.

1.15.1 Scope of Pre-Employment Screening
Depending on the position, associated risk level, availability of information, and applicable legal requirements, screening may include:
Identity Verification
Verification of the candidate’s identity and relevant information provided during the recruitment process.
Employment History Verification
Review and, where appropriate, verification of previous employment, positions held, responsibilities, and relevant professional experience.
Professional Reference Checks
Professional references may be requested and verified where appropriate for the position.
Education and Professional Qualifications
Relevant academic qualifications, professional certifications, licenses, or other credentials may be verified where material to the position.
Integrity and Compliance Review
Runitas Bilisim may review legally permissible and relevant information relating to a candidate’s professional integrity, ethical conduct, or suitability for the position.
Government Affiliations and PEP Screening
For positions presenting elevated compliance risk, Runitas Bilisim may assess whether a candidate is a Politically Exposed Person (PEP), has relevant relationships or affiliations with government entities or public officials, or has other connections that could create an actual or potential conflict of interest or compliance risk.
Sanctions and Restricted-Party Screening
Where relevant to the position, business activities, or applicable compliance obligations, screening against applicable sanctions or restricted-party lists may be performed.
Conflict-of-Interest Assessment
Candidates may be required to disclose actual or potential conflicts of interest, including relevant external business interests, relationships with customers or suppliers, government relationships, or other circumstances that could affect their independence or responsibilities at Runitas Bilisim.

1.15.2 Risk-Based Screening
Not every screening measure applies to every candidate.
Human Resources, in consultation with the Compliance Officer where appropriate, determines the level of screening based on the responsibilities and risk profile of the position.
Enhanced screening may be appropriate for:
• senior management;
• finance personnel;
• procurement personnel;
• sales and business-development personnel;
• compliance-related positions;
• employees dealing with public-sector or government customers;
• employees with significant financial or decision-making authority;
• employees with access to particularly sensitive information or systems; and
• other positions identified as presenting elevated compliance risk.

1.15.3 Identification and Escalation of Red Flags
Material inconsistencies, adverse information, potential conflicts of interest, relevant government connections, PEP exposure, integrity concerns, or other compliance-related red flags identified during screening shall be documented and appropriately assessed.
Human Resources may refer relevant matters to the Compliance Officer.
Where appropriate, additional information or clarification may be requested from the candidate.
Depending on the circumstances, Human Resources, the Compliance Officer, and/or relevant management may determine that:
• the issue has been satisfactorily explained or resolved;
• additional verification is necessary;
• mitigating measures are appropriate;
• specific management approval is required; or
• the candidate should not proceed further in the recruitment process.
No candidate shall be automatically rejected solely on the basis of a potential risk indicator without appropriate consideration of the circumstances and applicable legal requirements.

1.15.4 Responsibilities
Human Resources is responsible for coordinating and documenting the pre-employment screening process.
The Compliance Officer is responsible for providing compliance guidance and reviewing significant compliance-related concerns, including relevant PEP or government affiliations, conflicts of interest, integrity concerns, or other material red flags.
Relevant management may participate in the review and approval process where the position or identified risk requires additional assessment.

1.15.5 Documentation and Record Keeping
Runitas Bilisim shall maintain appropriate records demonstrating completion of applicable pre-employment screening.
Depending on the screening performed, records may include:
• completed screening or onboarding checklists;
• identity or qualification verification records;
• employment verification records;
• reference-check records;
• candidate declarations and disclosures;
• screening results;
• identified red flags and related assessments;
• Compliance Officer or management approvals; and
• records of mitigating actions where applicable.
Records shall be retained securely and access shall be limited to authorized personnel in accordance with applicable data protection, employment, privacy, and record-retention requirements.

1.16 Background Screening Review and Approval Process
The following general process applies to pre-employment background screening:

1. Human Resources determines the proposed position and applicable screening level.
2. Required checks are identified using the applicable pre-employment screening checklist.
3. The candidate provides information and authorizations where legally required.
4. Human Resources performs or coordinates the applicable checks.
5. Screening results are documented.
6. Any identified compliance-related red flags are referred to the Compliance Officer.
7. The Compliance Officer assesses material compliance concerns and documents the outcome where applicable.
8. Additional information or mitigating actions may be requested where necessary.
9. Required approvals are documented before onboarding is completed.
10. Relevant screening records are retained in accordance with applicable requirements.

1.17 Compliance Training and Awareness
Runitas Bilisim supports ongoing awareness of ethical and compliance responsibilities.
Depending on role and responsibilities, employees may be required to complete training relating to:
• business ethics;
• anti-bribery and anti-corruption;
• conflicts of interest;
• information security;
• data protection and privacy;
• customer and third-party compliance requirements; and
• other compliance topics relevant to their responsibilities.
Employees in higher-risk positions may be assigned additional compliance training.
Where required, completion records shall be maintained.

1.18 Reporting Concerns and Non-Retaliation
Employees are encouraged to report suspected violations of law, company policies, ethical requirements, or compliance obligations through appropriate management or compliance channels.
Reports made in good faith shall be handled appropriately and, to the extent reasonably possible, confidentially.
Runitas Bilisim does not tolerate retaliation against employees who raise legitimate concerns in good faith or cooperate with compliance reviews or investigations.

1.19 Roles and Responsibilities
Human Resources
Human Resources is responsible for administering employment processes, maintaining appropriate HR documentation, coordinating recruitment and pre-employment screening, and supporting implementation of this Policy.
Compliance Officer
The Compliance Officer provides guidance on compliance-related matters, reviews relevant compliance risks and escalated concerns, supports the assessment of conflicts of interest and other integrity risks, and assists in maintaining appropriate compliance documentation.
Management
Managers are responsible for supporting implementation of this Policy within their areas of responsibility and escalating relevant Human Resources or compliance concerns.
Employees
Employees are responsible for complying with this Policy, providing accurate information when required, completing assigned training, disclosing relevant conflicts of interest, and reporting suspected violations or concerns.

1.20 Record Retention
Human Resources and compliance-related records shall be retained for periods consistent with applicable laws, contractual requirements, legitimate business requirements, and Runitas Bilisim’s applicable record-retention practices.
Records containing personal or confidential information shall be stored securely and access shall be restricted to authorized personnel.

1.21 Policy Review and Updates
This Human Resources Policy shall be periodically reviewed by Runitas Bilisim to ensure that it remains appropriate for the company’s activities, organizational structure, applicable laws, contractual obligations, and compliance risks.
The Policy may be amended when necessary as a result of:
• changes in legislation or regulatory requirements;
• changes in business activities;
• identified compliance or Human Resources risks;
• internal or external review findings;
• contractual or business-partner requirements; or
• improvements to Runitas Bilisim’s internal control environment.
Material changes relating to compliance requirements may be reviewed in consultation with the Compliance Officer.