Competition / Antitrust Compliance

1.1 Purpose
The purpose of this Competition / Antitrust Compliance Policy ("Policy") is to ensure that Runitas Bilişim Teknoloji A.Ş. ("Runitas") conducts all business activities in full compliance with applicable competition (antitrust) laws and regulations in every jurisdiction where it operates.
Runitas is committed to competing fairly, independently and ethically. The Company does not tolerate any conduct that may restrict competition or violate applicable competition laws.

1.2 Scope
This Policy applies to:

• all employees;
• members of the Board of Directors;
• managers;
• temporary personnel;
• consultants;
• contractors;
• distributors;
• agents;
• suppliers and business partners acting on behalf of Runitas.

1.3 Legal Framework
This Policy supports compliance with:

• Turkish Competition Law No. 4054;
• EU Competition Rules (Articles 101 and 102 TFEU), where applicable;
• applicable foreign competition laws;
• OECD Guidelines on Competition Compliance;
• internal Code of Business Ethics.

1.4 General Principals
Employees shall:

• compete fairly;
• make independent commercial decisions;
• avoid anti-competitive agreements;
• avoid abuse of market power;
• avoid exchanging competitively sensitive information;
• immediately report suspected violations.

1.5 Prohibited Conduct
Employees shall never engage in:

1.5.1 Price Fixing
Including agreements regarding:

• prices;
• discounts;
• commissions;
• margins;
• fees;
• pricing formulas.

1.5.2 Market Allocation
Including agreements to divide:

• customers;
• territories;
• projects;
• sectors;
• products.

1.5.3 Bid Rigging
Employees shall never coordinate bids in public or private tenders.
Examples include:

• cover bids;
• bid suppression;
• bid rotation;
• predetermined winners.

1.5.4 Output Restriction
Employees shall not agree to:

• reduce production;
• delay services;
• restrict supply;
• limit capacity.

1.5.5 Output Restriction
Employees shall not exchange confidential commercial information with competitors, including:

• future prices;
• costs;
• customer lists;
• strategic plans;
• profit margins;
• capacity information;
• bidding strategy;
• future investments.

1.6 Relations with Competitors
Employees may participate in legitimate industry associations.
However, employees must never discuss:

• pricing;
• tenders;
• customers;
• production;
• commercial strategies;
• market sharing;
• future business plans.

If inappropriate discussions arise, employees shall:

• object immediately;
• leave the meeting;
• request that their objection be recorded;
• notify Legal/Compliance.

1.7 Public Procurement
Employees participating in public procurement shall:

• prepare bids independently;
• avoid contact with competitors concerning tenders;
• never exchange tender information;
• never coordinate pricing or bidding strategy;
• comply with all procurement laws.

1.8 Abuse of Dominant Position
Where applicable, employees shall avoid practices such as:

• predatory pricing;
• unjustified refusal to supply;
• discriminatory treatment;
• tying or bundling;
• exclusive dealing that restricts competition.

1.9 Communications
Written communications (including emails, Teams, WhatsApp, SMS and presentations) shall never contain language suggesting:

• price coordination;
• market allocation;
• elimination of competitors;
• collective boycott;
• anti-competitive cooperation.
  Employees should assume that all written communications may be reviewed by regulators.

1.10 Dawn Raids
If competition authorities visit Company premises:
Employees shall:

• immediately notify Legal/Compliance;
• cooperate professionally;
• preserve documents;
• never destroy records;
• never obstruct inspectors;
• never provide false information.

1.11 Training
Runitas shall provide periodic Competition Law training to:

• management;
• sales;
• procurement;
• business development;
• executives;
• employees whose activities create competition law risk.
  Training shall be documented.

1.12 Reporting
Employees must immediately report suspected violations through:

• Legal Department;
• Compliance Officer;
• Ethics Committee;
• Whistleblowing Channel.
  Good faith reporting shall not result in retaliation.