Privacy Policy

Introduction and Contact Information

This privacy statement tells you what to expect when we collect your personal information. We will explain what data we hold about you, how we collect and use your data and whether we share it with other organizations.
Petrogas Petrol Gaz ve Petrokimya Urun. Ins. San. ve Tic. A.S. (“Pgas”, “us” or “we”) will be the organization which has control of your data (the data controller). If you want to ask us for information about your data or this privacy policy, please contact PGAS’s company secretarial team at Gaziosmanpasa Mah. Karum Is Merkezi F Blok No:21/363 Cankaya Ankara or by telephone on +90 312 263 5252 or by email at info@pgas.com.tr and we will respond to you directly.
We have purposely drafted this notice to be clear and concise, so it is a summary of how we collect and use your personal information. If you would like more details about how we collect and use your personal information you will find this on our website terms of use. If you can’t find the information you would like, please contact us.

This privacy notice applies to:

  • Visitors to our websites and use of cookies
  • Information we obtain about you
  • How we use your information
  • Sharing your information
  • Where we store your personal information
  • International data transfers
  • Your rights of access to information
  • Other rights you might have
  • Complaints
  • Changes to this policy statement

Visitors to Our Websites and Use of Cookies

When someone visits our websites we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. Cookies help us to provide you with a good experience when you browse our website and allow us to improve our site. You can read more about how we use cookies and Google analytics on our Disclaimer page.

Information About You

We will generally only collect data about you directly from you and this will be done when you communicate with us and is likely to include your name, address, e-mail address, telephone numbers and if you are a vendor or customer, information about your current or past business activities and (if you elect to receive payment by bank transfer) your bank account details. If we have asked for your consent to use your data you may withdraw that consent at any time by contacting company secretarial team on +90 312 263 5252 or at info@pgas.com.tr.

Pre-Employment Data

During our recruitment process we may collect information directly from you, from other organizations and/or from publicly available information, including media profiles. If necessary, we will share your information in order only to assess your application, equality monitoring and to meet legal or policy requirements for pre-employment checks. This may include checking your identity, work and education activity, criminal record and credit history. Your information will be securely stored. Unsuccessful applicant details are held for 12 months and then destroyed.

How We Use Your Information

If you are a party which has direct or indirect business relationship with Pgas, we use your information to keep track of your activities with us, to pay your invoices and to deal with enquiries you make of us. In any other circumstances we will only use your data in connection with any business that we or our subsidiaries might have with you.

Sharing Your Information

We will only share data about you where we have a legitimate interest to do so. Other than in a purely business context we are only likely to share details of our shareholders with companies that process your data on our behalf or our business advisers such as Sworn Public Accountants, Auditors, consultants or with other parties instructed by you (such as your accountants or advisors). We may have to disclose, or allow inspection of, our share register where such a request is made in the form laid down by statute and we have to comply unless we can prove that the information is not being requested for a “proper purpose” (a broad term that is not defined in the relevant legislation).

There may be occasions when we must share information (including with regulators) about you so that we comply with a legal obligation, to enforce or apply our website terms of use, other agreements or to protect the rights, property, or safety of ourselves or someone else. We will also exchange information with other companies and organizations for the purposes of fraud protection, crime prevention or detection and credit (and other) risk reduction.

Where We Store Your Personal Information

All information you provide to us is stored securely. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

International Data Transfers

We do not generally process personal information outside of the Republic of Turkey but should this occur from time to time, it will be done only in a way that complies with current laws and regulations.

Access to Information

You may obtain the information we hold about you by making a written request to us using the contact details above.
Subject to compliance with any laws and regulations, when you ask us about the information we hold on you we will give you confirmation that your data is being processed, access to it and any other supplementary information we consider relevant to your request.

Your Other Rights

In addition to having access to your information (see above) and your right to the information set out in our privacy statements you have the rights to ask us to rectify any incorrect information about you, to delete information we hold about you, to restrict what we do with information about you, to require us to send information we hold about you either to you (or someone you designate) in a commonly used machine readable form, additionally you may object to how we are using information about you and the right not to have automated decisions made about you.

The above rights are not all absolute and whether you can use one of these rights may depend on the way we obtained your information or the legal basis on which we use your personal information. More information about how and when you can exercise these rights is available from the Information Commissioner’s Office.

Complaints

We are committed to protecting and respecting information about you in compliance with relevant laws and regulations and for this reason we take complaints we receive about this very seriously. Please address any concerns to us at the contact address given above or to info@pgas.com.tr. We encourage you to contact us directly if you are unhappy, but if you are not satisfied with our response or if you prefer not to raise the issue with us you may at any time complain to the Information Commissioner’s Office.

Links to other sites

This privacy notice does not cover the links within this site linking to other websites. These websites have their own privacy statements, and we encourage you to read the privacy statements on the other websites you visit.

Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page.

Anti-Corruption Policy

General 

This Anti-Corrupt Policy (the “Policy”) applies to Petrogas Petrol Gaz ve Petrokimya Ürünleri İnş. San. ve Tic A.Ş. and all of its divisions and subsidiaries (the “Company”) and all directors, officers, employees and agents of these entities. Persons who violate this Policy and any policies related hereto are acting outside the scope of their employment and are subject to the full range of disciplinary action, including termination. This Policy forms a part of the overall corporate compliance policies of the Company, and was adopted pursuant to, and should be read in conjunction with, the Code of Ethics of Petrogas Petrol Gaz ve Petrokimya Ürünleri İnş. San. ve Tic A.Ş. 

The Company maintains a corporate policy prohibiting all improper or unethical payments to government officials anywhere in the world. The Company’s policy is: 

No Company director, officer, employee, or agent has authority to offer payments to a foreign official to induce that official to affect any government act or decision in a manner that will assist the Company or any of its subsidiaries or divisions to obtain or retain business. Furthermore, every director, officer, employee, and agent of the Company is obligated by this Policy, the Company’s other corporate compliance policies keep books, records and accounts that accurately and fairly reflect all transactions and disposition of Company assets. 

Anti-Bribery Provisions 

It is prohibited any payment or offer of payment to a “foreign official” for the purpose of influencing that official to assist in obtaining or retaining business for a company. Also, it is prohibited “payment” covers not only the actual payment of money but also an offer, promise or authorization of the payment of money and an offer, gift, promise or authorization of the giving of “anything of value.” 

Record Keeping 

In addition to its anti-bribery provisions, it is imposed certain accounting requirements on companies. Specifically, company maintain books, records, and accounts that, in reasonable detail, accurately reflect the transactions and dispositions of that company. In order to comply with these requirements, it is imperative that Company employees, agents and others acting on the Company’s behalf maintain complete and accurate records with respect to all transactions undertaken on behalf of the Company. 

General Rules 

The following rules have been established for all directors, officers, employees and agents acting on behalf of the Company: 

  • Except as expressly provided elsewhere in this Policy, no payment or gift of any kind whatsoever may be promised, offered, or made to any foreign official. 
  • Notwithstanding the foregoing, expenditures for meals, entertainment and other normal social amenities with respect to foreign officials are permitted, provided they are not be extravagant and otherwise conform to the laws and customs of the country in which the expenditures are incurred. 
  • Similarly, gifts may be given to foreign officials only if the gifts are of modest value and conform to laws and normal social customs in the official’s country. 

Other Considerations 

Facilitating Payments. In certain parts of the world, it is common for government employees to receive so-called “facilitating” or “expediting” payments to expedite or secure the performance of routine governmental action by a foreign official. The exception, however, does not cover any payment intended to influence the decision or action of a foreign official in a decision concerning the awarding of new business or continuation of existing business. 

Because the legality of a “facilitating payment” is very fact-intensive and difficult to determine, no director, officer, employee, or agent of the Company is authorized to make any such payments without receiving the approval of the Chief Executive Officer of Petrogas Petrol Gaz ve Petrokimya Ürünleri İnş. San. ve Tic A.Ş.. In the event the Chief Executive Officer approves such a facilitating payment, he or she must ensure that the nature of the payment is accurately reported to the Company’s accounting department so the transaction may be properly recorded. 

Retention of Professionals. No person acting on behalf of the Company may enter into any transaction with agents, contractors, consultants, lawyers or other persons that is intended or designed to permit such persons to circumvent currency, tax or other laws of any foreign country. Any transaction that has the appearance of permitting any person to circumvent such laws must be avoided. 

Reporting Requirements

All reports will be treated as confidential, to be used only for the purpose of addressing the specific problem they address. Such reports will be shared by Chief Executive Officer only on a “need-to-know” basis. As long as a report is made honestly and in good faith, the Company will take no adverse action against any person based on the making of such a report. Employees must note, however, that failure to report known or suspected wrongdoing of which an employee has knowledge may, by itself, subject that employee to disciplinary action. 

ANTI-CORRUPTION PRACTICES ACT POLICY CERTIFICATION 

A director, officer, employee or agent of Petrogas Petrol Gaz ve Petrokimya Ürünleri İnş. San. ve Tic A.Ş. or one of its subsidiaries (the “Company”) is at all times expected to comport with high ethical business standards. In connection with this standard, the Company has adopted its Code of Ethics Policy, a copy of which is attached to this Certification. 

 

Code of Ethics

PETROGAS PETROL GAZ VE PETROKİMYA ÜRÜNLERİ İNŞ. SAN. ve TİC A.Ş 

and its subsidiaries (the “Company”) ethics business in a manner that complies with both the letter and the spirit of the law. As an employee or contractor of the Company you are receiving this Code of Ethics as a reminder of some of the Company’s policies that are particularly important. 

The Company’s standards of Ethics are summarized below: 

CONFIDENTIAL INFORMATION 

It is imperative that you keep confidential all information about Company operations and business activities that have not been made public. 

You must not disclose to others, or use for yourself or others, any confidential Company information or information about others entrusted to the Company. In addition, you must not take personal advantage of opportunities that are discovered while working for the Company. 

These opportunities belong to the Company. 

CONFLICTS OF INTEREST 

You should avoid situations where your interests conflict with the Company’s interests. These include investments, business interests, or other associations which interfere with or influence your objective judgment in furtherance of your responsibility to act in the Company’s best interests. If you wish to do something that may present a potential conflict, please raise it with your supervisor. It is possible that there may not be a conflict, or the Company may be willing to waive the conflict. 

ACCEPTANCE OF PAYMENTS 

You shall not directly or indirectly seek or accept any payments, fees, services, or other gratuities of any size or amount from any person, company, or organization doing, or seeking to do, business with the Company. Gifts of cash or cash equivalents of any amount are strictly prohibited. However, it is not inappropriate to receive common courtesies, sales promotion items of small value, occasional meals, or reasonable entertainment appropriate to our business relationships and associated with business discussions. 

IMPROPER PAYMENTS

You are not to make any improper payment or offer any improper inducement, such as a bribe or kickback to any person, official, company or organization in any country, which is designed to secure favored treatment for the Company.

BUSINESS ENTERTAINMENT

Solicitations of or dealings with suppliers, customers, or others doing, or seeking to do, business with the Company shall be Ethicsed solely on a basis that reflects both the Company’s best interests and our high ethical standards.

COMPANY RECORDS

Company business records must be prepared accurately and reliably. Records are to be kept in accordance with accepted accounting rules and controls, fully and accurately reflecting all transactions. No unrecorded fund or asset may be maintained. No false or misleading entry, record, or report may be made or permitted to go uncorrected.

STOCK TRANSACTIONS

If you have or know material information about the business of the Company, you are prohibited from buying or selling stock of the Company until such information has been made public.

HEALTH AND SAFETY

Your health and safety is a top priority. You are to take all necessary precautions to perform your job safely. Our health and safety programs are designed for your protection. You should be familiar with them and follow proper safety procedures at all times.

COMPANY FUNDS AND ASSETS

You are personally accountable for Company funds or assets over which you have control, including use of a Company credit card. Protection of Company property and services is vital to our business. Company property must not be used for improper personal benefit or any other improper purpose.

APPLICATION OF THIS CODE OF ETHICS

It is our expectation that you will Ethics yourself in an honest and ethical manner. If you are uncertain if certain behavior or actions are proper, it is best to avoid the appearance of impropriety.

REPORTING VIOLATIONS

If you believe someone else is not Ethicsing him or herself properly, you should bring that to our attention. In general, you should bring that to your supervisor’s attention. Under certain circumstances, such as improper payments, theft, or acceptance of improper payments, you should contact the Chief Executive Officer, dial +90 312 263 52 52.

Alternatively, you can report a violation by accessing the following website: www.pgastr.com