En Antitrust and Competition Policy
1. Purpose
PRM Yazılım Ltd. (MERSİS: 0-7330-2587-3500014) is committed to conducting business in compliance with all applicable antitrust and competition laws including Act No:4054 The Act On The Protection Of Competition of Turkish Law. These laws promote fair competition and prohibit anti-competitive practices such as price-fixing, monopolization, bid-rigging, and unfair trade practices. This policy provides guidance to employees, contractors, and representatives to ensure compliance with these regulations.
2. Scope
This policy applies to all employees, officers, directors, contractors, and agents of PRM in all jurisdictions where we operate.
3. Key Principles of Compliance
3.1 Prohibited Practices
Employees must not engage in or facilitate any anti-competitive behavior, including but not limited to:
Price-Fixing – Agreeing with competitors to set prices or terms of sale.
Bid-Rigging – Coordinating with competitors to manipulate bidding processes.
Market Allocation – Dividing customers, territories, or markets with competitors.
Monopolization – Engaging in conduct that unfairly eliminates competition.
Tying and Bundling – Forcing customers to purchase one product to access another when it limits competition.
Exchanging Competitive Information – Sharing sensitive business information (e.g., pricing, customer lists) with competitors.
3.2 Permitted Activities
Certain interactions with competitors, suppliers, and customers are allowed if they are conducted legally, such as:
Industry Collaboration – Participation in trade associations, provided competitive information is not shared.
Standard-Setting – Engaging in fair and open technology standards development.
Joint Ventures – Entering lawful partnerships that promote efficiency and innovation without restricting competition.
4. Interactions with Competitors
- Avoid discussions with competitors about pricing, customers, or market strategies.
- If a competitor attempts to discuss sensitive information, employees must stop the conversation and report the incident to legal officer of PRM.
- Any proposed partnerships or agreements with competitors must be reviewed by the legal representative.
5. Relationships with Customers and Suppliers
- Employees must not pressure customers into exclusive contracts that could limit competition.
- Discounting and pricing strategies must be determined independently, without coordination with competitors.
6. Reporting Violations
Employees must report any suspected antitrust violations to Legal officer. Reports can be made confidentially and without fear of retaliation. Incidents of non-compliant practices may also be reported to Competition Authority using the portal at https://www.rekabet.gov.tr/
7. Training and Enforcement
- All employees must complete bi-annual antitrust and competition law training.
- Violations of this policy may result in disciplinary action, including termination and legal consequences like fines and jail terms.
8. Contact Information
For any questions regarding this policy, please contact legal officer: Reşit YILDIRIM, Attorney by Bu e-Posta adresi istenmeyen posta engelleyicileri tarafından korunuyor. Görüntülemek için JavaScript etkinleştirilmelidir.