Conflict of Interest Policy

1- Purpose
The Hilf al-Fudul Foundation carries out its activities in line with the principle of ensuring that decision-making and evaluation processes remain free from personal interests. A conflict of interest arises when personal interests influence, have the potential to influence, or create the perception of influencing the decision-making process. This policy outlines the principles, rules, and procedures for preventing and managing situations involving conflicts of interest.

2- Scope
Unless otherwise stated, this policy applies to all members of the Hilf al-Fudul Foundation, including the Board of Directors, employees, volunteers, partner institutions and their associates, as well as consultants, financial advisors, lawyers, external auditors, and any individuals authorized to represent the foundation. All such individuals are required to comply with the Conflict of Interest Policy. The term “interests of persons associated with the Hilf al-Fudul Foundation” also includes the interests of their immediate family members. The Hilf al-Fudul Foundation’s Anti-Bribery and Anti-Corruption Policy is included within the scope of this policy.

3- Duties and Responsibilities
The implementation, monitoring, and updating of the Hilf al-Fudul Foundation Conflict of Interest Policy, as well as the establishment of systems to ensure compliance with this policy, fall under the authority, duty, and responsibility of the Hilf al-Fudul Foundation Board of Directors. The Conflict of Interest Policy is included among the official policies of the Hilf al-Fudul Foundation. Every employee, volunteer, contracted expert, and partner is personally responsible for being familiar with and adhering to this policy.

4- Conflict of Interest Policy
It is essential that employees of the Hilf al-Fudul Foundation avoid any situations that could create a conflict of interest. One of the foremost responsibilities of all employees is to ensure that the foundation’s resources, name, reputation, and influence are never used for personal gain and to avoid any conduct that could negatively affect the foundation’s image or integrity. The following implementation principles define the types of conflict of interest situations that employees of the Hilf al-Fudul Foundation may encounter while performing their duties or in their private lives due to professional relationships, as well as the principles to be followed in such cases. In situations of uncertainty, employees are expected to consult their supervisors, the Board of Directors, or the Audit Committee.

5- General Policy on Engaging in Activities That May Create a Conflict of Interest
All employees of the Hilf al-Fudul Foundation are required to fully comply with the situations and principles listed below that may lead to potential conflicts of interest.

a. Employees shall not engage in any business relationship—whether for mutual or unilateral benefit—with family members, friends, or any third parties with whom they have personal connections. For example, an employee with purchasing authority must avoid conducting business with a supplier that employs a family member. Exceptional cases are subject to the knowledge and approval of the Chairman of the Board of the Hilf al-Fudul Foundation. Employees may not obtain any commercial benefit or enable others to benefit by disclosing or using any internal information belonging to the Hilf al-Fudul Foundation.
b. It is essential that employees of the Hilf al-Fudul Foundation do not, directly or indirectly, engage in any activities that would classify them as “traders” or “merchants.” Under no circumstances may they work for another person and/or organization—whether during or outside of working hours—in return for payment or any other form of benefit. However, if employees wish to work outside of regular working hours for another person (such as a family member, friend, or third party) and/or organization in return for payment or a similar benefit;

1. it must not create a conflict of interest with their duties at the foundation or with other Hilf al-Fudul Foundation activities,
2. it must not conflict with other business ethics rules or the policies that support those rules,
3. Vakıftaki görevlerini sürdürmelerini olumsuz yönde etkilememesi,
4. and it is only permissible with the written approval of the Board of Directors.

c. Employees may take part in the activities of a political party only under the conditions stated below and with the written approval of the management:
1. Employees may not engage in any political activity during working hours, nor may they use their colleagues’ time for such activities.
2. During their political activities, employees may not use the foundation’s name, their position or title within the foundation, or any resources belonging to the Hilf al-Fudul Foundation.

d. Conflict of interest situations may arise when individuals’ financial interests or personal benefits interfere with their ability to act in the best interests of the foundation, or when such interests influence their activities and decisions. As stated in the first section, individuals associated with the Hilf al-Fudul Foundation must avoid all potential, actual, or perceived conflicts of interest. They must also openly acknowledge and declare any potential or actual conflicts of interest that may arise due to their relationship with the foundation.
e. Companies or institutions affiliated with individuals serving in the elected bodies of the Hilf al-Fudul Foundation are encouraged to collaborate with the foundation, support its projects, and participate in its activities. However, these companies and institutions may not derive any commercial or reputational benefit from the Hilf al-Fudul Foundation’s name, brand, or reputation.
f. These individuals must declare any financial or non-financial interests that could be perceived as a conflict of interest. Such declarations must be submitted to the Board of Directors for impartial review and for appropriate measures to be taken. If the conflict of interest concerns a member of the Board of Directors, that individual shall not participate in the meetings where their conflict of interest declaration is being evaluated.
g. In the event of a conflict between personal interests and the interests of the foundation, the conflict shall be openly disclosed and declared transparently in accordance with the foundation’s interests and resolved appropriately.
h. Individuals associated with the foundation may not use the foundation’s relationships in their private lives to seek or grant favoritism, special treatment, or any improper or unauthorized advantage.
i. Individuals associated with the foundation must not allow their political affiliations, relationships, opinions, or activities to influence or compromise one of the foundation’s core principles — political neutrality.
j. It is unacceptable for employees to misuse their authority for their own benefit or that of their relatives, or in any way that deviates from the expected standard of conduct, resulting in harm to the foundation.
k. Çalışanlar Vakfın satın alma ve faaliyetleri ile taraf olduğu tüm işlemler ve sözleşmelerden doğrudan ya da dolaylı olarak kişisel kazanç elde edemez.
l. Employees may not engage in any acts or behaviors that are contrary to morality, the law, or the disciplinary rules of the foundation.

6- Use of Resources

a. In all uses of resources on behalf of the foundation, the interests of the foundation must be prioritized. Under no circumstances may the foundation’s assets, facilities, or personnel be used outside the foundation — regardless of the purpose, name, or beneficiary — unless it directly serves the foundation’s interests.
b. Proper use of the foundation’s resources also requires the effective use of time. During working hours, foundation employees must manage their time efficiently and refrain from attending to personal matters. Managers may not assign employees to perform personal tasks on their behalf.
c. It is essential that private visitors are not received during working hours. In cases where employees must meet with necessary visitors, such meetings should be related to the purpose of the visit and completed within a reasonable time so as not to disrupt the workflow.

7- Relations with Other Individuals, Institutions, and/or Organizations in Cooperation with the Foundation

a. In relationships with partner institutions or organizations providing services, it must be evaluated whether any situations defined in the Hilf al-Fudul Foundation’s Conflict of Interest Policy exist for the foundation’s employees. If a declared conflict of interest is present and it hinders the cooperation, adjustments may be made to the individual’s role or position within the partnership. Each situation should be assessed on a case-by-case basis.
b. Foundation employees may not enter into private business relationships with subcontractors, suppliers, or any other individuals and/or organizations with which the foundation has commercial relations. They may not borrow or receive money, goods, or services for personal purposes from such parties, nor may they lend or provide money, goods, or services to them.
c. Foundation personnel may not request or imply the desire for gifts from individuals and/or organizations with which the foundation has commercial relations. They may not accept any gifts, money, checks, property, free vacations, special discounts, or similar benefits that could place the foundation under any obligation. No personal aid or donations may be accepted from any person or organization engaged in a business relationship with the foundation. The Gift Acceptance and Giving Policy applies to this matter.

8- Relations with the Media

In all relations with the media, actions must be taken in accordance with the Foundation’s Communication Strategy. Providing statements to any media outlet, giving interviews, or participating as a speaker at seminars, conferences, or similar events requires the approval of the Foundation’s Board of Directors. No personal gain may be derived from any of these activities.

9- Paid Employment Contracts and Consultancies

a. If individuals associated with the foundation receive payment for participating in a speech, publication, media program, or project work, and the foundation’s core information or activities are used, the payment must be made directly to the Hilf al-Fudul Foundation. The Board of Directors may decide to transfer part or all of this payment to the relevant individual.
b. Individuals associated with the foundation, as well as their affiliated companies or organizations, may apply for and compete in the foundation’s paid employment contracts, provided they are not granted any advantage unavailable to competitors. During the application process, they must not use any privileged, non-public information belonging to the foundation and must take all necessary measures to avoid the perception that they have benefited from such information. In other words, their relationship with the Hilf al-Fudul Foundation does not disqualify them from applying, but they will not be given any special advantage. While engaging in work unrelated to the foundation, board members or their affiliated companies must not use privileged foundation information and must remain sensitive to any perception that they might do so.
c. The foundation will manage decision-making processes, tenders, and procurement activities related to paid assignments in a transparent manner.
d. Foundation employees may undertake short-term consultancy or expert assignments for other organizations and receive payment in return. In such cases, employees are required to disclose the relevant contracts and all related details to the Board of Directors.

10- Favoritism and Nepotism in Recruitment

a. All appointments to positions shall be made on the basis of merit, without discrimination based on gender, region, religious belief, physical disability, family status, sexual orientation, or similar grounds. Recruitment and procurement processes shall be conducted in accordance with the principles of openness, fairness and transparency.
b. Persons associated with the foundation shall not adopt an approach that shows favoritism or grants privileges to the relatives, friends, or organizations affiliated with such persons; treatment that could be perceived as nepotism shall be avoided.
c. Appointments to all positions shall be made in line with the principle of merit after internal and external announcement processes are completed and all applications have been taken into account.
d. Persons associated with the foundation must disclose any personal connections they are aware of with job applicants and candidates in order to avoid possible or potential conflicts of interest. Such persons are obliged to refuse to participate in any recruitment or contracting process in which they would be in a conflict of interest. Relatives or persons with close personal relationships shall not be permitted to be in hierarchical working relationships with one another.

11- Record Keeping
Compliance with this policy must be demonstrable. Therefore, the foundation must record and retain all organizational and administrative arrangements related to conflicts of interest, as well as incidents, reports, and corrective measures taken in response to policy violations, for a minimum of 10 years. The Audit Committee participates in the workflow and is responsible for reviewing and verifying these records.

12- Reporting Policy Violations
a. If there is an opinion or suspicion that an employee or a person acting on behalf of the Hilf al-Fudul Foundation has acted contrary to this Policy, it must be reported to the Foundation’s Ethics Representative and the Ethics Committee. Matters related to the Code of Ethics are periodically reminded to Foundation employees.
b. The Hilf al-Fudul Foundation promotes an honest and transparent approach and supports any employee or person acting on behalf of the Foundation who, in good faith, raises sincere concerns, and it keeps such reports confidential. No employee may be subjected to pressure or retaliation due to a report made to the Ethics Representative and/or the Ethics Committee regarding a suspected breach of the Code of Ethics; no change to role or place of duty may be made for this reason without the written approval of the Ethics Committee.
c. If the reporting person is subjected to such treatment, they must inform the Ethics Committee. Firms supplying goods or services and business partners are also expected to regularly remind their employees of the role of the Foundation’s Ethics Representative and to encourage reporting should such situations arise.

13- Policy Violations
In cases where situations arise that are contrary to or potentially in violation of the policy, the matter shall be reviewed by the Hilf al-Fudul Foundation Ethics Representative and the Ethics Committee, and appropriate disciplinary actions shall be taken if any misconduct is identified.