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Meals, Gifts and Entertainment

SGF Energy Ltd (SGF) and its subsidiaries rely on employees to make business judgments based on SGF's best interest. Accepting meals, gifts and entertainment from vendors, contractors, competitors, or customers with whom SGF has a current or potential future relationship (vendors or customers) could adversely affect one's judgment or create the appearance of doing so. As a result, SGF has adopted guidelines in these areas to help employees decide whether those offered by vendors or customers may be accepted as consistent with company policy.

Summary of Guidelines

Meals
Not excessively frequent
Not excessively expensive

Gifts Worth ₺100 Or Less
Not excessively frequent

Gifts Worth More Than ₺100
Supervisor written approval required
Not excessively frequent
Not excessively expensive

Entertainment Worth ₺200 or Less with No Air Travel or Overnight Stay
Not excessively frequent
Not excessively expensive

Entertainment Worth More Than ₺200 or with Air Travel or Overnight Stay
Supervisor written approval required
Not excessively frequent
Not excessively expensive

Prohibited Gifts and Entertainment Items Include:

  • A gift or loan of cash or securities.
  • A gift or entertainment of an unlawful, lewd or offensive nature.
  • A gift or entertainment based on the quantity or volume of merchandise or services purchased or acquired by the company.
  • A gift or entertainment offered in return for a specific decision or outcome, or offered with the expectation that it will unduly influence any decision an employee might make on behalf of the company.