ART Gemi İnşa ve Tersanecilik Hizmetleri A.Ş. is committed to providing its employees with a work environment free from harassment, retaliation, bullying, and discrimination.

We remind our employees to respect each other and to adopt different cultures and diversity as a team in our shipyard. This may mean learning to change behavior to prevent unintentional upset. Our employees should remember that they have a responsibility to each other if they are exposed to harassment, retaliation, bullying, or discrimination.

Such behaviors are unwanted and cause detrimental effects, which may include stress, lack of motivation, reduced work performance, absence from duties, and resignations.

1. Definitions

Harassment is a form of discrimination that has the purpose or effect of violating the dignity of a person and of creating an intimidating, hostile, degrading, humiliating, or offensive environment. It includes any inappropriate and unwelcome conduct that, whether intentionally or not, creates feelings of unease, humiliation, embarrassment, or discomfort for the recipient.

Retaliation is an unacceptable reaction involving inappropriate behaviors that cause discomfort, humiliation, or distress. It will not be tolerated under any circumstances.

Bullying is a form of harassment that includes hostile or vindictive behavior, causing the recipient to feel threatened or intimidated. It may involve misuse of power or position and can be persistent, unpredictable, vindictive, cruel, or even unintentional.

Discrimination is the act of arbitrary or unfair behavior based on any characteristic of a person, resulting in unequal treatment or victimization. It includes actions or attitudes based on race, color, gender, religion, political belief, nationality, or similar factors.

2. Examples of Harassment

• Displaying or circulating offensive or suggestive material
• Lewd, sexist, racist, or homophobic jokes or remarks
• Use of offensive language when describing or mocking someone with a disability
• Comments about a person’s physical appearance or character causing embarrassment or distress
• Unwelcome attention such as spying, stalking, pestering, overly familiar behavior, or unwanted verbal/physical contact
• Sending unwanted, sexually suggestive, hostile, or intrusive messages (calls, texts, emails, letters, etc.)
• Intrusive questioning about personal life, sexual interests, or orientation
• Unwelcome sexual advances or repeated requests for dates or threats
• Suggesting that sexual favors may affect one’s career
• Unnecessary physical contact such as touching, patting, or brushing against others
• Spreading malicious rumors or insulting others regarding protected characteristics

3. Protected Activities Against Retaliation

Situations or behaviors that could lead to an employee engaging in a protected activity against retaliation include, but are not limited to:

• Discrimination or harassment
• Fraud
• Unethical or unprofessional conduct
• Non-compliance with ART policies/procedures, including the Code of Conduct
• Real or potential threats to workers’ or public health/safety
• Violations of local, state, or federal laws and regulations
• Other illegal or improper practices or policies

4. Examples of Bullying

• Verbal or physical threats or abuse (shouting or swearing, in public or private)
• Personal insults
• Belittling or ridiculing someone privately or publicly
• Unjustified displays of temper
• Excessive supervision or constant criticism
• Making unreasonable demands of staff or colleagues
• Assigning demeaning or irrelevant tasks without justification
• Ignoring or excluding someone from meetings, discussions, or decisions
• Making inappropriate threats about job security or career prospects
• Spreading malicious rumors or insults about protected characteristics
• Excluding people from the team (“shunning” behavior)
• Cyberbullying (offensive emails, posts, or messages)

Other examples that may hide bullying behavior include:

• Describing conflicts as “personality clashes”
• Labeling someone “over-sensitive” or “unable to take a joke”
• Calling a person’s behavior an “attitude problem”
• Making fun of mistakes or minor errors
• Overly harsh management or “low tolerance” for minor mistakes

5. Complaint and Reporting Procedure

ART Gemi İnşa ve Tersanecilik Hizmetleri A.Ş. treats all complaints of harassment and bullying seriously and confidentially. A complaint procedure is in place for reporting such occurrences.

The HR Manager is responsible for dealing with complaints of harassment and bullying. Employees may approach HR directly or through a representative to report any incident. Complaints of cyberbullying are also treated as serious issues.

If an employee does not feel comfortable making a complaint personally, they may ask a colleague to do so on their behalf. No one will be penalized for making a genuine complaint.

Each employee should remember: it is the victim’s perception that counts. If you feel you have suffered harassment or bullying, the company will investigate the issue thoroughly.

6. Discrimination – Protected Characteristics

Discrimination is any negative action or attitude directed toward someone because of protected characteristics, such as:

• Age
• Religion
• Ethnicity / Nationality
• Disability / Medical History
• Marriage / Civil Partnership
• Pregnancy / Maternity / Paternity
• Gender Identity / Sexual Orientation

SALİH BOSTANCI
SHIPYARD MANAGER