Migros Ticaret A.Ş. attaches importance to use natural resources efficiently and economically by keeping impacts on the environment under control in order to leave a healthier, livable environment for future generations. As an environmentally friendly company, we carry our social sensitivity and responsibility to future generations with works that will be good for our world facing problems such as climate change, depletion of natural resources and decrease in biodiversity. Within the framework of Migros Better Future Plan, we aim to reduce waste and create shared value with all our stakeholders by using today's resources effectively and efficiently, and to minimize the environmental impacts that may occur during our operations by monitoring these impacts.
2. Our Practices
One of the main objectives of our operations is to maintain environmental sustainability. As a company holding TSE EN ISO 14001 environmental management system certification, all our environmental activities and risks are managed, measured, reported and verified by independent audit institutions according to environmental aspects and environmental impact assessment procedures.
Our environmental management approach includes the continuous management of environmental impacts, working to improve the value of biodiversity, establishing collaborations with suppliers to manage impacts across the value chain, and executing various projects and campaigns to raise awareness across the society.
Migros Environmental Policy envisages that we work together with our stakeholders to raise environmental awareness, protect the environment, prioritize the needs of future generations and leave them a clean world. With this perspective, activities are planned in a way that takes into account the whole ecosystem and considers the holistic health of ecosystems.
2.1 Stakeholder engagement
At Migros, we involve our employees, customers, suppliers and all other stakeholders in our environmental efforts to create a sustainable value chain. While we raise awareness among our customers with waste collection and recycling projects in our stores, we question the environmental impact of our suppliers in the quality audits we carry out for them, and we demand improvement from suppliers that do not meet our expectations.
We communicate the Migros Environmental Policy to all our employees and all persons under the responsibility of our organization. We are committed to increasing the environmental responsibility awareness of all our employees from senior management to all units by providing environmental training to all our employees, communicating with all stakeholders and sharing information when necessary.
3. Combating climate change
In order to leave a livable world for future generations, we continuously monitor, control and reduce the environmental impact of our operations by using our resources responsibly and complying with environmental laws.
We identify risks and opportunities related to climate change annually with the relevant teams from the Sustainability Committee, make assessments in this context and report these assessments to senior management. This risk assessment is also a focus of global initiatives such as The Task Force on Climate-related Financial Disclosures (TCFD).
In order to increase our impact by creating a multiplier effect in the combat against climate change, we organize awareness trainings for our suppliers and transparently share our know-how in this field.
3.1 Energy management
Since most of the greenhouse gas emissions in the food retail sector are caused by cooling systems, we pay particular attention to the preference of efficient natural coolers and new generation systems to reduce our greenhouse gas emissions. In this context, we reduce the use of hydrofluorocarbons (HFCs) by 90% through aqueous systems in the cooling systems in our distribution centers and stores, and we use natural refrigerants in some of our distribution centers. Through our patented water-cooling system, we circulate cold water instead of gas to cool the cabinets in our stores. By implementing innovative applications such as water-cooling systems in our cooling systems, we strive for the use of natural coolers and environmentally friendly systems that can work in harmony with the "climate of our country".
We also increase our operational efficiency with the energy saving efforts we carry out as part of our efforts to combat climate change. Accordingly, we prefer to use "variable current controlled" and "highly automation efficient" systems for air conditioning and industrial cooling systems in our newly opened and renovated stores.
We measure our energy consumption in daily, weekly and monthly periods through our energy monitoring system. We monitor our cooling, air conditioning and lighting systems from a center with the automation system we have installed to monitor our energy consumption. In our stores where we can use daylight lighting systems efficiently, we make maximum use of sunlight. To prevent the formation of heat islands, we prefer paints that reflect the sun rays and provide thermal insulation on our store roofs. In addition, we use lighting units with motion sensors in the warehouses of our stores.
At the same time, we carry out energy efficiency activities such as the replacement of old and outdated air conditioners, automation works, frozen and glass-door cabinet conversions, new generation lighting systems, turning off lights when not used, and we regularly invest in this area.
In order to reduce our energy consumption arising from our distribution and logistics activities, we work on route optimization, opening of distribution centers at strategic points, capacity optimization, transportation of products with fully loaded trucks, and the use of new methods to reduce truck traffic solutions, the use of electric vehicles and bicycles in virtual market deliveries, and the use of collapsible crates suitable for multiple use in fruit, vegetable and red meat shipments.
In addition, we install solar energy panels at our Distribution Centers to obtain our electricity consumption from renewable energy sources, and by obtaining international renewable energy certificates we prefer renewable sources in electricity consumption whenever possible.
3.2 Sustainable agriculture
We know that ensuring the sustainability of the ecosystem and natural resources against the increasing negative effects of climate change will contribute to economic and social development and we continue to work with this awareness.
In order to protect our fertile and abundant soils, we are taking initiatives to empower farmers and producers and to promote sustainable production methods and traceability. We are the first retailer to bring consumers with products produced in accordance with the "Good Agricultural Practices (GAP)", which the Ministry of Agriculture and Forestry started to implement in fruit and vegetables in 2010 and in animal food products in 2013. In order for products to have the İTU certification, they must successfully complete annual audits by organizations assigned by the Ministry, verify food safety through analysis and have a traceability system.
At Migros, we prefer to supply GAP-certified plant and animal products. We contribute to the creation of a quality and efficient production system and to the provision of safe and healthy food consumption. In addition, we are working to develop alternative pest control methods to prevent biodiversity loss and to eliminate the use of pesticides through biological control techniques. Moreover, we calculate the adequate amount of fertilizer to be used thanks to the soil analyses carried out within the scope of the ITU, thus preventing excessive fertilizer use.
We support and work to disseminate regenerative agriculture practices, which are practices that contribute to reversing climate change by reorganizing the content of soil organic matter and restoring soil biodiversity. In this context, the production process, social, economic and environmental compliance of the producers included in the certification process are regularly audited by independent auditors. Data-based certification programs and agricultural trainings ensure the continuity of the system. We contribute to the protection of natural vegetation, wildlife and biodiversity while efficiently using soil and water resources in production, which is carried out in line with the sustainability of agriculture, the labor of producers and human rights. Through certification programs, we support land management methods that increase carbon storage while combating deforestation.
3.3 Biodiversity conservation
Migros values environmental protection efforts greatly. All our operations are located in urban areas and authorized by public authorities. We do not have any operational units operating in high biodiversity lands and wetlands. Accordingly, we have not recorded any significant impact on water resources, soil and natural habitats.
Türkiye signed the Convention on Biological Diversity drafted by the United Nations Environment Program (UNEP) in 1992, ratified it in 1996 and put into effect in 1997.
The main issues that the Convention on Biological Diversity focuses on are;
- Biodiversity conservation;
- Sustainable use of biological resources;
- Fair and equitable sharing of benefits arising from the use of genetic resources.
As a party to this convention, all legal permits issued by the state cover the issue of biodiversity. At Migros, we open all our stores after obtaining legal permits and licenses. In this context, the opening of our stores is permitted after all environmental assessments have been completed.
We have a separate policy on this issue, the details of which can be reached at the "Biodiversity Policy" document.
3.4 Effective Waste Management
We strive to protect natural resources and carry out resource recycling initiatives. We encourage "reduction, reuse and recycling" of all the resources we use. Through our waste management efforts to reduce our environmental footprint with a circular economy approach throughout our operations, we aim to prevent or minimize waste generation by ensuring efficient use of resources in all our business processes.
In line with our zero-waste target, we are working to dispose of all waste from our operations, convert it into energy and recycle it into the economy. We aim to reduce waste at source and ensure efficient use of natural resources. With our effective waste management practices, we aim to obtain Zero Waste Certification in all our facilities and new stores.
Considering the Food Recovery Hierarchy, we carry out measurement, categorization, analysis and improvement studies and various projects to reduce food loss and disposal. We also carry out communication activities to raise awareness among consumers.
Within the framework of the motto 'Less plastic will be better for our world', in order to reduce plastic waste, we work on reducing the plastic weight of plastic bags, on reducing plastic waste in supplier shipments and in original branded products, on developing product packaging, reducing the use of foam plates, organizing the bag-free shopping movement, on refill units, self-service jet aisles, and generally commit to do better in this area.
While creating collection points in our stores to recycle packaging waste, vegetable waste oil, waste batteries and waste electrical and electronic equipment, we set an example for the sector with innovative works such as; repairing and reselling toys that have lost their quality, supporting schools with bookshelves made from nut shells, and producing eco-hangers obtained by recycling of non-food products.
3.5 Sustainable Water Management
At Migros, as part of our environmental awareness, we work to ensure water efficiency in all our operations to protect natural resources.
We are aware of the critical importance of water for human health, and Migros places great importance on providing clean water to its employees and all of its stakeholders in line with its commitment to human rights.
Throughout Migros, water is used to meet employee needs and for cleaning purposes in stores, Head Office, branch directorates, distribution centers, fruit and vegetable warehouses, MİGET and Gebze Meat Production Center.
Our environmental management procedure focuses on studies to ensure the efficient use of water and to guarantee that the wastewater released as a result of our activities is treated legally to prevent environmental impacts. As part of our efficiency efforts, we closely monitor innovative practices and implement them in our stores, production facilities, distribution centers, Head Office and Branch Directors. Accordingly, the water used in all our business units is recorded, monitored and reported to senior management on a monthly basis.
The majority of the water used in our operations is supplied from municipal water networks. There are no water resources that are significantly affected as a result of the Company's water use. Waste water from the stores is discharged into the sewerage system.
In addition, we monitor the positive and negative changes in our water consumption that may arise from the activities carried out to improve other Migros activities and take the necessary actions.
Our company acts with the goal of reducing 'daily water consumption per square meter of sales' and sets short and medium/long targets for this purpose.
At Migros, while we continue to work in compliance with all legal requirements, we also carry out voluntary efforts to reduce water consumption in absolute terms. We conduct awareness-raising activities for all our stakeholders to improve their environmental awareness and water consumption habits.
In the annual audits we organize for our suppliers, environmental and water issues are included as follow-up topics. We encourage agriculture in accordance with Good Agricultural Practices in order to reduce the water used in agricultural activities, especially in fruit and vegetable production, and to reduce water losses caused by unconscious irrigation.
4. Auditing of Supplier Companies
In order to improve the sustainability of the products we offer to our customers across the entire life cycle, we are committed to further enhancing supplier performance and thereby protecting biodiversity. As an organization that wants to create impact, we build purpose-oriented collaborations. With the audits we conduct, we follow the practices of our supplier companies and monitor their development.
Within the framework of the GC Ethical Standards audit conducted for our suppliers, assessments are made regarding the training of relevant employees on climate change impacts including CO2 emissions, environmental issues including water use, soil and biodiversity, pollution control, waste management, natural resource utilization.
We share the findings identified in the audit with our unsuccessful suppliers as nonconformities and carry out awareness-raising activities for areas open to improvement. We give our supplier candidates a certain amount of time to eliminate nonconformities and then we conduct follow-up audits. We grant a maximum of 3 follow-up audits to our suppliers whose audits are not successful. If the expected success is not achieved within the framework of our evaluation system after our follow-up audits, we terminate the commercial relationship according to the evaluation.
At Migros, we set targets in line with our sustainability strategy and the UN Sustainable Development Goals in accordance with the requirements of the organizations of which we are a member and/or signatory, and we disclose our performance in this direction to the public every year through our sustainability reports.
In this context, we set our environmental targets and plans to reduce carbon emissions in line with our sustainable ecosystem strategy in accordance with national targets and global initiatives, particularly the Paris Agreement. In the long term, we manage our operations in line with all these frameworks. In addition, we report our results on climate change and water management to the Carbon Disclosure Project (CDP), an international organization that stirs companies to disclose their environmental impact.
We implement an environmental management system to support continuous improvement, ensure periodic reviews and take measures. For this purpose, we base our work on TSE EN ISO 14001 Environmental Management System Standard.
We continue to be the first and only brand from the retail sector to be continuously included in the 'BIST Sustainability Index' since 2014 thanks to the activities we have carried out under the umbrella of sustainability.
Migros Biodiversity Policy
1. Our Purpose
We carry out studies to support the protection of biodiversity in our operations and in the areas where we operate within our value chain. In addition, as a food retailer, our focus is on the conservation of sustainable agriculture-oriented biodiversity to ensure that food production is uninterrupted, while protecting natural resources and on the basis of efficiency.2.Our Practices
The opportunities provided by biological diversity and ecosystems are extremely important for the continuity of human life. Today, as biodiversity is under threat there are species that are in danger of extinction. Biodiversity is essential to maintain quality of life and a healthy environment. In this context, protecting biodiversity and preventing deforestation among top priorities of Migros’ environmental protection activities.
Migros' operational units do not operate in lands and wetlands with high biodiversity. Accordingly, no significant impact on water resources, soil and natural habitats has been recorded. All operations are in urban areas and are permitted by public authorities. These permissions also cover the conservation of biological diversity and the sustainable use of biological resources, which are the main issues covered by the United Nation Environment Programme (UNEP) Convention on Biological Diversity.
We work with our stakeholders to protect biodiversity in Migros' operations and areas of operation, including our supply chain.
As Migros, we aim to implement our activities outside of critical areas, to protect biodiversity in our current operations and fields of activity, and to minimize our impact in these areas to prevent deforestation.
In order to fulfill this commitment:
- We integrate the protection of biodiversity into our Company's sustainability strategy and decisions.
- We adopt a proactive approach to minimize biological biodiversity and ecosystem risks in the areas we have an impact on within the scope of our activities.
- We aim to have a positive impact on biodiversity in our fields of activity by supporting regenerative, organic, and good agricultural practices.
- We carry out studies to reduce the use of pesticides in primary food production and their negative impact on soil and nature by using them in a right and balanced way.
Sustainability Policy1. Objective
Our sustainability activities, carried out within the framework of the Migros Better Future Plan, which is shaped by Migros Ticaret A.Ş.'s vision, mission, strategy and values, are planned to cover our entire ecosystem and are at the center of our value-oriented business model.
It is one of our top priorities to carry out activities that will "be better for" our world, employees, our customer and other whole stakeholders, technology and innovation, in short, for the entire ecosystem. In this context, we are identifying different focus areas planning activities and investments with Board-approved targets and commitments. While the focus areas are determined, they are regularly updated according to national and international developments, trends and regulations.
Our Company's environmental, social and corporate governance approaches and practices are also explained in detail in its corporate policies such as Environment, Code of Ethics, Human Rights and Equal Opportunities, Anti-Bribery and Anti-Corruption, Health and Food, Responsible Sourcing, Occupational Health and Safety, Biodiversity.
You can find our remedial activities, targets, key performance indicators and roadmap in detail in our Migros Better Future Plan, which are in line with our sustainable growth target and our sustainable ecosystem strategy that integrates our targets.
In this direction, the main practices and activities carried out by our company to achieve its sustainability goals are:
- To reduce carbon emissions of our activities based on the framework of Science Based Targets (SBT) in order to effectively fight against climate change.
- To reduce our carbon footprint through the deployment of sustainable, efficient and renewable energy systems.
- To carry out improvement activities by setting a common goal together with our stakeholders through the "Sustainable Business Partners Network" in order to reduce emissions from the products we sell and to increase the impact created.
- To put forward studies that will reduce our water consumption, which we mainly use for hygiene purposes, and ensure efficient use of water.
- To minimize food disposal in accordance with the food recovery hierarchy, to carry out works to prevent food waste and to organize awareness-raising activities.
- To reduce and recycle all waste such as plastic waste, waste oil and batteries within the scope of effective waste management.
- In order to sustain agriculture and prevent biodiversity loss, we provide farmers and producers with fertile soil and support, protecting our local seeds, combating deforestation, and supporting the bee population.
- To regularly work and invest in the health, safety, welfare and development of our employees, our most important stakeholders.
- To contribute to the transformation of both the company and society through works on gender and equal opportunity.
- To procure products and services from companies that respect people and the environment, identify the value, reputation, positive and negative impacts of our suppliers in environmental, social and governance areas, and support our suppliers in their areas of development within the framework of our responsible business approach.
- To carry out social work using our resources and in cooperation with stakeholders, and to put forward products, services and projects that will promote the healthy development of society.
- To follow the advances in technology and encourage innovative transformation through innovative works.
Migros Board of Directors guides the strategic approach to sustainability issues. Our Chief Executive Officer (CEO) is the authority for the issues of sustainability as a member of the Board of Directors and as the chief executive officer. On behalf of the Board of Directors, the Sustainability Committee is authorized by the CEO to manage, implement, monitor and measure the Company's sustainability efforts.
3.1. Working Principles of the Sustainability Committee:
- The Chair of the Sustainability Committee is appointed by the CEO.
- Directors/group managers of all departments of the company are natural members of the Sustainability Committee. In addition, people who are actively involved in sustainability, as directed by department senior managers, also participate in the Committee. To this end, it is ensured that the Sustainability Committee includes at least one representative from each of the main functions and that discussions take place in a democratic framework based on equal participation.
- The Committee sets short and medium/long term targets in line with the Company's main strategies and presents them to the Senior Management. The main targets are then presented to the Board of Directors, finalized in line with the opinions received, and committed to with the decision of the Board of Directors.
- Sustainability is a core responsibility of all our employees and this responsibility is distributed in a top-down and bottom-up manner.
- At least one of the annual targets of all departments is expected to be in the field of sustainability, in a way that supports the company's main objectives.
- All decisions and activities in the field of sustainability are evaluated in line with national and international performance indicators (KPIs) and annual performances are transparently reported to stakeholders and sustainability indexes.
- All members of the Committee come together twice a year for a major evaluation meeting. In addition, subject-oriented studies are carried out in the subcommittees which were established on dedicated topics and the results are reported to the Sustainability Committee. Sub-Committees may meet more frequently in line with the needs.
The Sustainability Committee and its subcommittees report the company's sustainability efforts, process evaluations and result analyses to the Chief Executive Officer and senior management four times a year.
Human Rights and Equal Opportunity Policy1. Purpose
Migros Ticaret A.Ş. serves with a work force that includes a variety of languages, religions and ethnic origins in both Turkey and foreign subsidiaries. In this context the subjects of “Human Rights” and “Equal Opportunity” are among the main policies of our Migros Human Resources management approach. As Migros we respect human rights and we work proactively to identify and prevent any adverse human rights impacts that may be generated from our operations.2. Equal Opportunity
Migros is devoted to the UN Human Rights Universal Declaration recognized on an international scale and the ILO labor standards and observes all relevant activities.
In all of our human resources processes from employment to wages there is no discrimination based on age, gender, race, religion, language, ethnic origin, sexual preference, belief, marital, social or economic status, disability, pregnancy or military service status.
Migros Integrated Human Resources Systems measure and monitor the abilities, skills and performance of our employees with general and objective criteria in the framework of the equality principle. As Migros, we provide equal training, promotion, career development and salary opportunities to all our employees based on objective evaluation results.
We support the participation of women in professional life and organize trainings and projects to increase the number of women employees and administrators in the company. We act in compliance with laws on the employment of disabled and disadvantaged individuals.3. Collective Agreement and Unionization
Migros has respectful work environment to the rights of unionization of its employees. We support the unionization of our employees; we make collective agreement with the Union within constructive dialogue and carry out the requirements of this agreement.4. Forced Labor
We do not allow our employees to be forced to work against their will. None of our employees are ever pressured for any reason and all our employees are employed under equal conditions, by their own free will in positions that are suitable to them.
Within this scope, Migros also accepts and carry out the Three Priority Industry Principles of Consumer Goods Forum (CGF).
- Every worker should have freedom of movement (retention of identity papers)
- No worker should pay for a job (demanding recruitment fees)
- No worker should be indebted or coerced to work (withholding of wages)
Migros determines its employees according to relevant procedures and principles. The employment of child labor is never allowed at our stores, our headquarters and our regional directorships.6. Prevention of Mistreatment and Abuse
We treat our employees with respect and honor and never allow any of our employees to be mistreated. We do not allow our employees to be exposed to any verbal and physical abuse.7. Working Hours, Salaries and Benefits
We manage the total income package of employees based on job evaluation results and ensure that the remuneration package is competitive by distinguishing and rewarding performance as well as the remuneration packages being offered in other leading companies in Turkey. We conduct our operations incompliance with the valid laws about salary, working hours, overtime and fringe benefits. We conduct the studies to reduce the overtime period of our employees and also support to maintain their work-life balance.8. Work Health and Safety
Migros has TS ISO 45001 OHSAS Work Health and Safety Management System certificate and meets the requirements of this certificate. We provide our employees with a safe and healthy work environment and comply with the safety and health laws and regulations in force and our in-company requirements. We constantly work to improve health and safety conditions in our workplace including identifying danger and finding solutions to health and safety problems.Migros Ticaret A.Ş. last amendment date: 18.06.2021
Human Resources Policy1. Purpose
Migros Ticaret A.Ş. structures its strategies with a customer satisfaction approach that raises the retail standards in the countries it operates in order to achieve sustainable quality, reputability and sector leadership. Migros Human Resources aims to provide the human resource that will create a competitive advantage in our company on realizing these strategies, to develop the systems to constantly motivate and manage human resources and implement these systems in line with the corporate principles. It aims to establish and implement Human Resources Systems that correspond with the company strategies, values and serve for employees’ happiness and engagement.
Migros Human Resources aims to provide the human resource that will create a competitive advantage in our company on realizing these strategies, to develop the systems to constantly motivate and manage human resources and to make sure these systems operate in integration with each other.2. Our Employer Brand
As Migros Ticaret A.Ş. our employer value proposition (EVP) for existing and potential employees is “Good Job, Good Future”. Our main employer qualities that we have determined together with our employees and capitalized on are as follows:
- We are a reliable and corporate family
- We aim for the top
- We are constantly developing
- We are innovative
- We provide all our employees equality of opportunity and strong career development opportunities.
The main purpose of Search and Selection is to provide the human resource that will create a competitive advantage in realizing the corporate strategies within the necessary time using the most objective and effective evaluation tools to the company.
It covers all the human resource needs and completion of them within the organization.
In our recruitment process, there is no discrimination based on age, gender, race, religion, language, ethnic origin, sexual preference, belief, marital, social or economic status, disability, pregnancy or military service status. In the candidate selection process, they are selected according to their experiences, skills, competencies required by the position.4. Internal Application System
The purpose of our internal application system is to provide for our workforce needs from internal sources and thus give our own employees different career opportunities in the company to increase their motivation and engagement.5. Performance Management System
Through our Performance Management System, it is aimed to guide our employees’ career development/back up, income package and development plans in line with evaluation results by making sure that the goals to be reach in line with the company strategies are embraced by all our employees and the performance of our employees are monitored in a fair and productive manner.
Our Performance Management System, in which KPI (Key Performance Indicators) and OKR (Objectives & Key Results) structures are used together has transparent and dynamic features and increases the common goal and cooperation with its infrastructure that supports instant feedback and cross-functional teamwork. The personal performance notes achieved as a result of the Performance Evaluation comprise the input for career development/back up, income package and development plans.6. Job Evaluation System
The purpose of our Job Evaluation System is to determine the relative contributions of work to the results of the organization in a fair and methodological manner and to assess the relative size of jobs.
According to the job evaluation methodology each varying position in our company is evaluated according to the size of the job, knowledge-skill, responsibility and problem-solving criteria. Job families and a level structure were formed unique to the company by forming groups of roles which have common characteristics taking into consideration with vision, strategy and goals; and these groups have been organized into levels according to objective criteria.
Job Evaluation provides critical input for Performance Management, Reward and Remuneration, Search and Selection, Training Development and Career Planning/Back Up processes. It is a platform that can be used as the infrastructure for all “Integrated Human Resources Systems” and impacting remuneration in particular.7. The Remuneration System
The main purpose of Remuneration Management is to manage the total income package of employees based on job -evaluation results and outside and inside of company salary balances with fair and competitive salary policies distinguishing and rewarding performance.
The Remuneration System is based on the salary policies which are determined annually according to job family/level of positions, the salary market, the existing salary structure of the company and the ability to pay. The employee raises are determined according to the PIR (position in range) calculated with these salary principles and the results of individual performance evaluations.
Within the framework of our remuneration policy, which covers our employees in our operations, there is no difference in salary and fringe benefits among employees with similar duties, seniority and performance. Starting level pricing in our stores is based on minimum wage and fringe benefits, regardless of gender.
The salaries and benefits of blue-collar workers are evaluated in the scope of the Collective Labor Contract.
The salaries determined according to the above procedures are then approved by Migros Human Resources & Industrial Relations Assistant General Manager and our General Manager.8. Competency / Potential Evaluation / Strategic Human Resources
Competency is the observable behavior that includes the knowledge, skill and attitude that distinguishes the highest level of performance.
The purpose of our Competency Evaluation process is to determine the individual competency profile that is compatible with our company culture and to match the requirements of a job with the qualified employee. Also, the purpose is to create the human resources necessary to support the strategic human resources planning of our company and maintain it as well as determine the backup for key positions and identify the Potential & Star candidates.
The compatibility of our employees to the position profiles are evaluated in line with the organizational needs planning that supports our company’s productive growth strategy; critical position backups and potential & star candidates are determined, they are approved by management decision in Strategic Human Resources Planning Meetings and then finalized.9. Development Planning
The Development Planning process planned each year for Store Management and every 2 years for Administrative Units starts with the announcement of competency evaluation results. Our employees, who can view their evaluation results on the system, fill out the Development Agreement on the system and determine which skill they will improve and which development activities (in class training, online training, article, book, complementary activity) they will participate in and enable the evaluations to provide input for the development process. The filled form is first submitted to the manager of the employee then to the Training Department for approval.
While the requests in Development Plans of employees for the development tools such as online training, article, book, –complementary activity are automatically assigned, in class training is organized by the “Migros Retail Academy” and announced by email.10. The Reward Systems
Migros Reward and Premium Systems aims to reward differentiated individual/team work, customer admiration and appreciation through differentiated branches in Reward System to recognize the achievements of employees and increase their company engagement and motivation in line with the company goals.
11. Career Planning Management (Appointment/Promotion Processes)
The Career Planning Process; is a fair and reliable process that is carried out at certain periods to support the company’s productive and profitable growth strategy by appointing/promoting qualified candidates suitable to the profile of the positions within the framework of a certain standard depending on the principles of objectivity and transparency.
In the promotion processes; for our store employees, being successful in the results of the competency & performance evaluations in the Store Career Recipes booklet and in the results of Migros Development Center are taken into account. They are expected to meet the training and seniority criteria sought for each position and not to have any warning/caution. They are also required to be successful in exams and interviews for some positions.
This process is evaluated for our employees in HQ within the framework of the job analysis forms created by their job size and according to the headcount situation. The career development of our employees is impacted by the requirements of the position they are in, the level definitions of job families they are depending on and changes of their job size. Job Evaluation provides critical input for Performance Management, Reward and Remuneration, Search and Selection, Training Development and Career Planning/Backup processes.12. Employee Relations Management
The aim of our Working Life Evaluation Survey is conducted by an independent company is to measure the level of satisfaction and engagement of our employees, to identify what needs to be improved and prioritize them. The results of this survey guide our improvement activities on working life.Migros Ticaret A.Ş. last amendment date: 18.06.2021
Anti-Bribery and Anti-Corruption Policy
As Migros, at the core of our corporate responsibility approach lies compliance with laws and corporate governance principles. With our commitment to high ethical standards and the Migros Ethics Rules, we work together as a whole to prevent bribery and corruption.
With this policy, which is a supplemental part of the Migros Ethics Rules, we aim to present our commitment and our approach to this subject very openly and clearly.
The Anti-Bribery and Anti-Corruption Policy does not just concern the company’s employees but all business partners who act on behalf of the company or provide services to the company.
The following groups are within the scope of this policy:
- All company employees including the Board of Directors,
- Supplier and contractor companies,
- Outsourcing companies and employees,
- People and companies that work directly or indirectly for the company like representatives, distributors and agencies are all in the scope of this policy.
Our Company Management provides the necessary support for this policy to be implemented and creates and develops the internal control systems necessary to prevent bribery and corruption. It makes sure the necessary communication channels for reporting policy violations is established and takes precautions to maintain the privacy and safety of the individuals who report such violations.
The management makes sure that the necessary examinations and investigations are conducted concerning any complaints, warnings and claims that are submitted. They make sure audits are conducted to check compliance with laws, regulations, procedures and that policies and corrective actions are taken.
The Administrators, Employees and Business Partners;
All of our employees are obligated to accept our Policy on Anti-Bribery and Anti-Corruption and act in accordance with the principles that are specified in our policy.
The administrators are responsible for making sure that the principles in this policy are understood by the employees and business partners under their charge and direction, are implemented and maintained and that any complaints, warnings or claims are notified via our company’s communication channels.
Employees cannot, under any circumstances or by anyone, be forced to act against this policy. All company employees are responsible for reporting violations of this policy and any suspected situations to their administrators and/or the company communication channels.
If people and companies related to Migros are involved in any acts that are not legal or ethical our company will also be liable; therefore all of our business partners, especially suppliers and contractors, are expected to act in compliance with laws and regulations as well as to adopt the Migros Ethics Rules, relevant directives and procedures and this policy’s text and rules.
4. Fighting Against Bribery and Corruption
As Migros, we make it our principle to comply with the universal legal rules, laws and regulations that relate to bribery and corruption and the ethical and professional principles in all the countries where we operate and are represented.
This policy reinforces the execution of all our operations in compliance with laws, regulations, procedures, the Migros Ethics Rules and other regulations in a correct, fair and honest manner. It has been implemented in line with our sensitivity for making sure the rights of all our stakeholders are protected.
We, as Migros, prohibit all bribery and corruption in our operations in all countries where we operate or are represented. It is prohibited for all those covered by this policy to propose any payment or object of value in order to gain any benefit in an illegal or unethical manner, even if it would be in favor of the company, or to accept such a benefit from other companies or individuals, or to be involved in any illegal or unethical acts that could be considered to be bribery or corruption, even if such practices exist in that country or branch of work.
We protect the legal rights of government agencies, our suppliers, our customers, our employees and our other stakeholders. Regardless of the monetary value or occurrence of the requested favor, even if the value of the benefit is very low or the commitment promised in exchange has not been realized yet, a related subject is considered as an act of violation of the Anti-Bribery and Anti-Corruption Policy.
In addition to bribery and corruption being acts that are a violation of business ethics, any incident would be dealt with punitively by Migros. As a consequence, our employees are expected to treat these topics with vigilance and consider them to be their personal responsibility both in and outside their professional life.
With our open-door policy, if the Migros Ethics rules or the Anti-Bribery and Anti-Corruption Policy are violated, our employees and other stakeholders can contact our administration directly through our communication channels. If our company sustains a loss due to the violation of these rules, we also have rules for taking action concerning our employees and protecting their rights.
4.1. Main Areas of Risk concerning Bribery and Corruption Acts
Migros sees bribery and corruption as part of risk management applications and these issues are investigated with a risk focused approach through our internal audit system. The risks that are identified and their potential impacts are subjected to assessment throughout our internal audits. Also, our company evaluates corruption risks in the scope of high-risk jobs from the aspect of employee bribery.4.1.1. Gifts and Hospitality
Our employees are responsible for complying with laws and regulations and rejecting any gifts such as objects, services, cash and checks from third parties that could affect the preferences and decisions of our company or are given for this purpose for conducting the work in their own field of responsibility no matter what the value is. Our employees may not propose any gifts, hospitality or other offerings that could be or are given for the purpose of affecting the decisions of other companies concerning our company. All of our employees are responsible for being careful about the issues that are specified in the company publications concerning rules on gifts and hospitality and for acting in compliance with the Migros Ethics Rules.
Since an act of corruption committed by third parties could even be considered to have been committed by Migros, sufficient and careful monitoring must be done to make sure that intermediary companies have the right qualifications for the work they conduct and business partnerships need to be established with companies that will act in compliance with our company policy and not damage our reputation.4.1.3. Those who work in Representation, Suppliers and Contractors
People who work in representing our company by establishing a relationship with Migros and all suppliers and contractors are expected to accept compliance with all legal regulations and all laws on bribery and corruption that are in place.
People acting as an agent of Migros who provide management consultation and are involved in operations like accounting, payroll, information technologies or facilities management must not establish relationships with people and/or companies like suppliers and contractors that they suspect to have offered bribes; and if they have such a relationship should end it immediately upon learning of such a situation.4.1.4. Political Donations
At Migros, it is illegal to make any payments as well as provide any financial and/or in-kind benefit to political parties, politicians or any company to obtain an advantage in procedures.4.1.5. Contributions for the Purpose of Aid and Sponsorships
Any contributions and sponsorships requested from Migros for the purpose of providing aid must be legal and in accordance with the regulation, policy, directive and rules issued by Migros. All contributions and sponsorships for aid must be made in a transparent and open manner. This is achieved by determining transparent criteria for the selection of recipients and listing large donations that are made publicly.4.2. Encountering or Suspecting Bribery and Corruption
All of our employees are responsible for reporting any situations of bribery and corruption they encounter or suspect to their supervisors and/or our company communication channels immediately.
Employees are responsible for reporting any of the situations listed below.
- If a bribe is offered to any of our employees or their colleagues
- Any relationship of benefit and/or conflicts of interest that our employee witnesses or knows
- Any kind of non-compliance discovered in the company’s records
- Any attitude or acts that can be construed as patronage or backing interests in tenders and purchase-sales
- Providing any benefit to any of our customers or suppliers in violation of legal regulations and our internal procedures
- Any company or individual within the company or outside forcing our employee or their colleagues to act in violation of the Migros Ethics Rules.
Migros customers and business partners may forward their notifications about ethical issues by e-mail via firstname.lastname@example.org. Sanctions Against Acts and Attitudes of Violation
Just as all regulations, procedures and instructions are carried out in full, in all jobs, the Anti-Bribery and Anti-Corruption Policy must be adopted and implemented by all stakeholders covered by this policy.
Any violation of our “Anti-Bribery and Anti-Corruption Policy” by suppliers or contractors results in the termination of our work contract.
Any violation of these rules by our employees is handled by our departments including Human Resources, Internal Audit and Legal Department and reported to Migros Management. If these rules are violated by our employees who are union members, disciplinary meetings are called in which union representatives are present in accordance with collective employment contract rules. Any violation of Migros Ethics Rules or our Anti-Bribery and Anti-Corruption Policy by an employee may result in the termination of their employment contract.4.4 Monitoring and Reporting
The Migros Ethics Committee meets four times a year with the participation of senior level administrators to evaluate internal audit findings on corruption and bribery and issues concerning ethics principles. When high level risks are identified the Migros Ethics Committee that meets with the participation of senior level administrators evaluates these risks.
As part of our corporate governance our Audit Committee and Ethics Committee prepares reports on our policy of combating bribery and corruption for our senior administration.Migros Ticaret A.Ş. last amendment date: 18.06.2021
Migros Competition Law Compliance Policy
Migros Competition Law Compliance Policy
The purpose of Competition Law Compliance Policy (the "Policy") is to set the principles for ensuring of all activities of Migros in compliance with the competition law legislation.
1. Core Principles
The main purpose of competition laws is to protect and foster the free and fair competition. Competition laws prohibit agreements and regulations that prevent, restrict, or distort competition between competitors. Migros undertakes to strictly comply with all applicable competition laws within the scope of its activities. Migros employees, executives and business partners (all other third parties with whom Migros have business relationship) must conduct their work in accordance with legislation and Migros Policies. In this regard, acting in accordance with competition law regulations is an important part of the role and work of all executives and employees.
We expect from all our executives and employees to know and question any situation that may violate the law. In this regard, Migros monitors the compliance of the activities in terms of competition law, takes the necessary actions regarding possible risks, and carries out the necessary training and audit activities on a continuous basis in order to ensure awareness of all employees.
Under this Policy, Migros’ employees, executives and business partners are obliged not to communicate in a way that may be uncompetitive, not to act in line with anti-competitive decisions taken by Association of Undertakings , and not to share information that may cause a violation of competition law.
Any violation of this Policy may result in severe consequences, including legal, administrative and criminal penalties on Migros’ related executives, employees and business partners.
2. Implementation of The Policy
2.1 Rules to Be Considered in Relations with Competitors
Agreements that may be directly constituted between competitors or indirectly through suppliers, in particular, to influence the sales conditions, may lead to a breach of competition law. Migros’ employees are not permitted to communicate in such a way as to prevent, distort or restrict competition between competitors directly from their competitors or through their suppliers. In this regard;
- Without the approval of Migros Legal Directorate, business-related negotiations cannot be held with competitors.
- As part of Migros’s activities (not limited to these), any information that may be considered commercially sensitive, such as prices, timing and rates of pricing changes, costs, profitability, strategies, campaigns, marketing plans and strategies, investments, future sales, customer/supplier information, cannot be shared directly or indirectly with competitors through suppliers.
- Meeting minutes shall be written down, indicating that the meeting has a legitimate purpose and is not being used as a forum against competition law between competitors when associations of undertakings meetings are held on a lawful purpose. If there is any content contrary to the Competition Law, the meeting shall be declined by the Migros’ representative and annotated in the meeting minutes that the representative left.
- Migros’ employees explicitly respond to anti-competitive proposals or suggestions by stating that they will not participate in any anti-competitive activity.
As to compete effectively, our activities on collecting information are only based on public information, press releases, public annual reports, official records, trade journals and speeches from company executives.
2.2 .Rules to be Considered in Relations Between Suppliers and Other Third Parties
Migros acts in compliance with competition rules within the frame of agreements and communications in relations with all its suppliers and business partners. Knowing the fact that suppliers and other business partners are sometimes competitors of each other, any sensitive information to competition among these businesses shall not be shared. In order to not be a party to any declarations or actions that may be called a violation of competition with competitors, Migros also requests from its suppliers or business partners not to share the information of Migros with its competitors.
2.3 Use of Communication Channels
As part of compliance with the Policy, Migros’ employees and executives must act very carefully regarding their posts in all kinds of communication channels. In this regard, competitively sensitive information such as future prices, stock, campaign, investments cannot be shared in any communication channel.
Corporate communication tools for Migros’ employees and executives are Microsoft Outlook, Microsoft Teams and telephone, where Migros e-mail addresses are registered. Communication with these tools must always be carried out in accordance with competition compliance rules and Migros’ corporate identity.
Our business partners are also required to use these corporate communication tools in all kinds of communication with Migros as a part of our activities. It is forbidden to communicate with Migros’s employees through instant messaging programs or similar applications about business.
3. Authorities And Responsibilities
All employees and executives of Migros are responsible for complying with this Policy, implementing Migros’ relevant procedures and controls in accordance with the requirements in this Policy.
In case of Migros’ employees and executives deem that a certain action is inconsistent with this Policy or the legislation in force, Competition Compliance Department under Migros Legal Directorate should be contacted immediately.
Migros’ employees may consult to the Competition Compliance Department for their questions related to this Policy and its application. Violation of this Policy may result in significant disciplinary actions including dismissal. If this Policy is violated by any third parties, the related agreements may be terminated.
4. Effective Date
This Policy takes effect on 01.02.2022 and is maintained by Migros Legal Directorate.
Health and Nutrition Policy
As Migros, we have a major role in better life quality with our customer-oriented, people-focused approach, sensitive to the community and environment, reliable, innovative and efficient in both our national and international operations. In line with this approach, we provide a wide product portfolio that supports a healthy and good life ensuring the high level of quality expected by Migros’ customers.
We provide a diverse portfolio of quality products for our customers in order to meet the expectations for a healthy and good life. We aim to make products that support good living more accessible to our customers, thanks to our increasing number of stores, as well as the product range and brand selections we offer.
In our stores that have a suitable place for such a section, we create “healthy and good living” sections for our customers.
We have a variety of brands and products that offer easy access to foods that are organic, sugar-free, gluten-free, lactose free, or with reduced sugar, fat, salt or calories and portions that have been adjusted for a single serving.
At occasions such as World Celiac Day and Diabetes Week, we organize campaigns with relevant products to create consumer awareness.
2.1. Certified Product Activities
As Migros, we aim to cooperate with our suppliers and government agencies to provide our consumers with healthy and safe products and to contribute to the healthy nutrition of future generations, to develop methods of production that are sensible to people’s welfare, to the environment and animals and we encourage our suppliers to do the same.
Some examples of standards and certifications that Migros utilizes to achieve product safety are organic product certification, the Good Agricultural Practices certification in vegetable and animal production, the Ecotex certification, standards such as ISO 9001- GMP - ISO 22000 - ISO 14001 - OHSAS 18001 - SA 8000, the FSC certification, the Palm oil and Soya certification and the CE- LVD - EMC certifications.
We consider it a priority to work with companies that produce and supply according to the criteria specified in the “The Good Agricultural Practices – GAP” project conducted in collaboration with the Ministry of Food, Agriculture and Livestock. We are the first retail company in Turkey to implement a control system with GAP in fruits and vegetables, based on safety criteria on issues like farming models that protect human, animal and environmental health; and agricultural pesticide analysis and traceable products.
With our “Good Agricultural Practices in Animal Production,” we provide our customers with white meat and eggs bearing the ‘Good Agriculture’ logo that have undergone inspections based on human health and animal welfare sensitivity.
2.2. Private Label Products
For the purpose of meeting the good living demands of our customers, we have private label brands produced by our contracted suppliers under the name of “Migros, M-Life, and Anadolu Lezzetleri”.
The M Life product portfolio offers products in categories such as organic, limited calories, gluten-free that support good living, and it has been designed for customers who wish to maintain their health, as well as customers who have health issues.
2.3. Anadolu Lezzetleri (Tastes of Anatolia)
Our Anadolu Lezzetleri product line is comprised of products that are unique with their regional or cultural features, produced through traditional methods and “have a story”. With this project that has been brought to life after an identification of special tastes and local seeds in an in-depth scan of all regions throughout Turkey, we aim to embrace the cultural wealth of Anatolia and pass it onto future generations. At the same time, by allocating a special Anadolu Lezzetleri section in suitable stores, we are offering our customers access to these special products that can only be produced by a small number of local chefs or farmers.
2.4. Red Meat Products
At MİGET, Turkey’s largest meat processing facility in the food sector, we produce all of our own meat needs and inspect the red meat products at every stage from the farm to the dinner table. Laboratory analyses and veterinary inspections are carried out at our facility and all of our production processes are TSE certified. Our products are developed according to the expectations of Turkish consumers and produced in hygienic conditions. You can reach our products with adjusted portions for one meal-consumption in all our stores. We use state-of-the-art food packaging in our packaged products. We carried the immune and collagen content, which entered our lives even more in the Covid period, to our communications and supported these products with campaigns.
As Migros, we have information on the packaging of all the food products we sell, including energy and nutrients in accordance with the “Turkish Food Codex Labeling and Consumer Information Regulation”. In addition, all of the label information (ingredients, allergens, energy and nutrients, origin, etc.) of all the food products we sell on our online sales channels as Migros Virtual Market, Macro-online and Taze Direkt are presented to our customers.
As Migros, we play an important role in improving the health and fitness of the communities we serve. We develop important projects for community health with our “balanced nutrition” and “take action” activities under our motto of “Good Living” to encourage our customers to embrace a healthier lifestyle. We conduct communication and education programs to raise consumer awareness on the importance of healthy living, balanced nutrition and physical activity and regarding the need to have a balanced calorie intake.Migros Ticaret A.Ş. last amendment date: 18.06.2021
Food Loss and Waste Policy
It is estimated that close to 1 billion tons of food goes to waste in the world, which corresponds to 1 out of every 3 food produced. Raw materials, water, soil, labor and time are used in food production, and when food is thrown away, all these resources are also thrown away. Reducing food loss and waste has multiple benefits for both people and the planet we live on: for the economy, food security, water consumption, climate change, greenhouse gas emissions, biodiversity, agricultural land use and cost reduction. As a food retailer, reducing food loss and waste is a priority on Migros Ticaret A.Ş.'s agenda. Since the efforts of any organization acting alone will not be sufficient to solve the problem of food loss and waste in the world, we see preventing the loss and waste of food products in addition to supporting sustainable agriculture as responsibilities that we undertake together with all of our stakeholders.
2. Our Practices
We carry out our work in accordance with the requirements of the Food Loss and Waste Accounting and Reporting Standard (FLW) in order to develop policies, strategies and programs, and support investment programs and projects carried out by the private and public sectors, to increase awareness of the effects of food loss and waste and the create solutions to the problems related to this issue by closely following the activities within the scope of 'Responsible Production and Consumption', which is the 12th Sustainable Development Goal of the United Nations, and increasing the coordination and coordination of initiatives to reduce food loss and waste worldwide. We carry out measurement, analysis, categorization and improvement studies and collaborate throughout our value chain in order to prevent food loss from our operations and to ensure the reuse of consumable food in accordance with the food recovery hierarchy. In addition to these, we are expanding the impact area to reduce food loss by collaborating with suppliers and customers in solving this problem. We work with our suppliers and encourage them to reduce food loss and guide them to take actions in this regard. We raise awareness of our customers by informing them on this issue and offer them ideas that they can easily implement in their own lives to prevent waste.
We see reduction at source as one of the most important methods in the fight against food waste, and we are launching new projects and studies in line with our food waste reduction target.
2.1. Operational improvements for reduction at source:
Thanks to the system we developed to prevent losses due to overstocking, we prevent overstocking and ensure accurate ordering by using an automatic ordering system with a smart algorithm that can calculate fruit and vegetable orders, previous orders, stock status and sales. In addition to these efforts, we minimize food waste by offering our consumers on Expiry Date approaching products and ripe fruits and vegetables with a 25-50% discount.
2.1.1. Extending product shelf life with technological methods:
During the packaging of our red meat products, we use Skinpack Packaging Technology, which completely removes the air through vacuuming, thus protecting our products from environmental impacts and increasing their shelf life.
2.1.2. Delivery of food to those in need:
We ensure that healthy foods that retain their nutritional value but do not turn into sales are matched and delivered to those in need through an online platform.
2.1.3. Feeding stray animals:
In cooperation with non-governmental organizations, we deliver foods that are not eligible for human consumption but are not expired to street and forest animals.
2.1.4. Collecting the whole crop from the field and utilizing it:
In order to prevent post-harvest food loss, we are working to collect all crops from the fields and utilize those that do not meet the sales criteria in the production area.
2.1.5. Energy production from organic waste:
In cases where waste recycling is not possible, we implement biogas and composting practices to minimize environmental impacts. In this context, we provide compost and energy recovery from organic waste that is not suitable for consumption, and separate food waste at source.
2.2. Raising awareness of our consumers:
In order to prevent food waste, we not only support our producers but also raise awareness among consumers to make the right choices. We lead research on consumer perceptions and behaviors that lead to food waste. We have been supporting the Save Your Food campaign launched by the Food and Agriculture Organization of the United Nations (FAO) and the Ministry of Agriculture and Forestry to raise public awareness on food waste since day one. We provide information through infographic and video content at our stores and through social media channels. We support kitchen workshops organized for consumers. In addition, through innovative practices such as the "Surprise Box", our customers have access to a variety of products with a 50% discount, and we prepare guides to reduce food waste.
2.3. Reducing food waste of our suppliers:
As the first Turkish retail company to join the '10x20x30' initiative launched by the World Resources Initiative (WRI), we are ensuring that our supply chain supports the goal of reducing food disposal by 50% by 2030. As part of this project, we come together with WRI to provide training to our suppliers and share best practices.
3. Performance and Targets
In line with the Sustainable Development Goals and as the only Turkish Retailer to be a member of the Food Waste coalition within the Consumer Goods Forum (CGF), a platform that shapes global retailing and food production, we have committed to reduce our food waste by 50% by 2030. In order to minimize food loss and waste, we lead our works through projects on Consumer Collaborations, Upstream Food Loss (from farm to retail), Carbon Footprint Linkage, Harmonized Reporting and 10x20x30. At Migros, we will continue to contribute to the entire ecosystem with our values surrounding it, aware of the limits of our world and the importance of time.
Animal Welfare Policy1. Our Purpose
Paying utmost attention to animal health and welfare, we closely follow the legislation and practices in the European Union, in our country and globally, and continuously improve our practices.
In addition to being a company that works based on the principle of maximum benefit to our customers within our value chain with the aim of improving animal health and welfare, we also aim to raise the awareness of our suppliers through training and audits.2. Practices
2.1. Cattle & Small Cattle
Believing that we have a responsibility to improve the health and welfare of animals, we are increasing our good practices day by day, taking a holistic and inclusive approach to make a positive impact in this area. By fulfilling the traceability requirement determined by the Ministry of Agriculture and Forestry; we provide the quality and food safety requirements of the products, and support the development of growers by informing them of our findings. These issues, which are monitored within the scope of our own operations, are also questioned in the annual audits conducted for our suppliers.
In order to meet the physiological and behavioral needs of livestock, we provide appropriate lighting and ventilation conditions, taking into account climatic conditions, as well as adequate rest periods.
We organize regulations, practices and procedures in a way that does not harm animals and does not restrict their freedom of movement. We make sure that the living spaces are clean and comfortable, and that the litter is appropriate for their species and age.
We ensure that animals meet their nutritional and fluid needs in a healthy way by feeding them with appropriate and sufficient amounts of feed in proportion to their physiological needs, age, weight and behavior, and by providing regular access to fresh water.
We provide quick care to animals that appear sick or injured and provide veterinary surgeon support in the fastest way if professional treatment is required.
We provide practices that will ensure the safety of animals transported in clean and disinfected vehicles with official certificates, and meet their nutritional and water needs properly during transportation.2.2. Poultry
We support our farmers to adopt a sustainable production approach through training, consultancy, audits and bulk purchases through practices that aim to ensure that our farmers continue their business efficiently without harming nature, the environment and living creatures.
Since 2013, we have adopted Good Agricultural Practices (GAP), which is an agricultural practice determined by the Republic of Türkiye Ministry of Agriculture and Forestry that prioritizes traceability and sustainability of agriculture and food safety, also for poultry. Within the scope of GAP, producers fulfill the audit, analysis and traceability requirements and receive product certifications by authorized institutions based on 317 query criteria. All chickens and turkeys we sell are organic or GAP certified.
Our company is the first retailer in Turkey to sell cage-free eggs. Since 2018, 100% of our private label eggs (M Life eggs) are organic chicken eggs. In addition, all of the eggs sold in Macrocenter stores are cage-free.
Products from the organic egg center established through our incentives in Ordu are available in our stores. We continue to provide the necessary incentives and support to expand this transformation and increase production capacity.2.3. Aquaculture
To support sustainable fishing methods and provide consumers with reliable products, we launched the 'Good Fish Project' by supporting producers who use good agricultural practices in aquaculture.
We pay attention to expanding our work with suppliers who have completed 193 checks and abide by compliance criteria determined by the Republic of Türkiye Ministry of Agriculture and Forestry and who are entitled to receive the Good Agricultural Practices certificate. All the fish we sell are supplied in the season and in the sizes specified within the scope of the relevant regulations.
We also work to increase the share of seafood and aquaculture products with sustainability certificates such as Global G.A.P and ASC.2.4. Our Original Branded Products
Within the scope of the Cosmetics Regulation, which is in line with the European Union and prepared by the Ministry of Health, cosmetic products such as toothpaste, creams, shampoos, shower gels, cologne, etc. are prohibited from being tested on animals. In compliance with our regulations, no private label cosmetics are tested on animals.
Responsible Sourcing Policy1. Purpose
With this policy we, as Migros, present all the rules that we expect our suppliers to comply with in light of our responsible sourcing principles, as well as our policy for conducting supplier audits.
Migros publishes its Responsible Sourcing Policy on the website, as well as all online and mobile platforms that it uses for communicating with suppliers.
2. The Principles that Suppliers are expected to Comply with
Migros procures services from companies that have been established according to laws and operate with respect for laws and makes payments to all companies, including agencies, that they are involved in representation/proxy and business partnership relations with in compliance with laws.
As Migros we expect the suppliers that we work with;
- To be respectful to human rights principles,
- To comply with national and international ethical rules,
- To comply with work health and safety rules,
- To protect the environment and natural resources,
- To act according to all national and international regulations in all processes they provide like products and services, commercial, logistic, production and financial work and human resources.
We, as Migros, expect all our suppliers to not only comply with mandatory requirements but also to work on constantly improving themselves over time in the scope of the “Migros Quality Protocol” and we
provide all the information support that suppliers may need.
2.1 Compliance with the Human Rights Principles
As Migros we are a member of the Consumer Goods Forum – CGF Board of Directors. The CGF board of directors accepts responsible forms of working that comply with and encourage human rights and reasonable working conditions in parallel with the United Nations Guideline Principles on Professional Life and Human Rights and the ILO Declaration and Basic Principles and Rights in Professional Life. Within the scope of Social Sustainability work the board has focused on its members complying with supply chain labor standards and developing solutions to the issue of members preventing forced labor and abuse in their supply chains. As Migros we not only comply with the international principles of Human Rights as a CGF member, but we take on responsibility and demand that our suppliers comply with these standards as well.
2.1.1 The Freedom to Organize and the Right to Collective Labor Contracts
Our suppliers must respect the rights of their employees to join or not join unions and their freedom to organize and must act in accordance with all local and national laws regarding collective labor contracts.
2.1.2 Prevention of Forced Labor and Abuse
Our suppliers must prohibit any kind of forced labor and abuse including labor under imprisonment, labor under military, slavery or human trafficking and must act in compliance with national and international laws concerning forced labor and abuse.
2.1.3 Child Labor
Our suppliers must act in compliance with national and international laws and regulations concerning the prohibition of child labor.
2.1.4 Combating Discrimination
Our suppliers must prevent discrimination and verbal and physical harassment in the work place. Discrimination must be prevented in all employment activities. Processes that are based on talent, performance and experience should be implemented. Our suppliers must act in compliance with national and international laws and regulations concerning discrimination and harassment.
2.1.5 Work Hours & Salaries
Our suppliers must act in complete compliance with laws and regulations concerning salaries, overtime and other benefits.
2.2 Compliance with Codes of Conduct (Combating Bribery and Corruption)
Our suppliers must not act in any way that could compromise the mutual trust in their business relations against employees, stakeholders, business partners, suppliers, customers, rivals, the environment and the community.
Our suppliers are obligated to keep the information they have learned about Migros during their business relations with us as confidential. They may not share this information without the permission of Migros Ticaret A.Ş. with any private individual or legal entity.
Any connection between our suppliers and corruption, money laundering or bribery incident is unacceptable. Our suppliers must not offer gifts, monetary benefits or invitations to civil servants or other representatives of public agencies that would influence their objectivity or violate existing laws.
Migros Ticaret A.Ş. may not offer any gift, benefit, right or assistance to its employees or other suppliers that they work with, which may overshadow their impartiality and be considered bribes. Therefore, the offer to employees of any special organization, holiday or arrangement other than business meals cannot be accepted. Other than the chocolates and daybooks that are presented at holidays and New Year the presentation of large gifts is prohibited.
2.3 Compliance with Occupational Health and Safety Rules
Our suppliers must provide their employees with a safe and healthy working environment. They must act in compliance with all national and international laws, regulations and rules concerning health and safety.
2.4 Protection of the Environment and Natural Resources
For the purpose of yielding a healthier and more livable environment to future generations, we expect all of our suppliers to keep their environmental impact under control and place importance on production and efficient use of resources.
2.5 Constant Improvement Principle
In line with the “Migros sustainability strategies,” in addition to monitoring the “Good Quality and Safe Product” production of our suppliers, we follow their performance concerning employee rights, work health and safety, work conduct, environmental impact and safe production. In this context, we are audited by audit companies that are certified as per ISO 17020 regarding the requirements of product risk analysis covered by the Migros Protocol. Audits comprise both those that are announced with prior notice and those where no prior notice is given. We expect our suppliers to constantly improve their audit performance and we provide assistance and guidance to our suppliers to contribute to their constant improvement.
During the procurement of local, national and international products we provide support for constantly developing our suppliers though guidance on product quality and compliance with legal regulations.
Migros supports its suppliers to develop products that are produced according to sustainability principles. In this regard, we determine suppliers with national and international certificates and encourage those of our suppliers who are not certified to start the process.
Production in accordance with sustainability principles is supported and importance is placed on products that have certifications for palm oil, cocoa, soy, coffee, paper and wood products.3. Supplier Selection Processes
Before deciding to work with our business partners, we conduct a thorough review and investigation of financial, legal and ethical risks and opportunities associated with companies. We investigate the commercial history of related
companies through official registrations and bribery, corruption and ethics through digital platforms. In addition to these studies, supplier candidates are pre-audited through quality control criteria and question lists used in the
existing supplier audits and the decision to work with them is taken according to the results of these audits. Candidate suppliers undergo both product safety audits and ethical/social audits. We do not work with the candidate
supplier who fail these audits.
We don't cooperate with the supplier companies when we ascertain their noncompliance with national laws, regulations and international norms within the scope of bribery, corruption and ethics, and with our company's Anti-Bribery and Anti-Corruption Policy and Code of Ethics. We also add these companies to our Black List.
As Migros, we follow a special audit program for our suppliers and inspect the production facilities of our suppliers in line with a Migros protocol that has been prepared especially with independent external companies.
Suppliers’ product safety practices are audited under the ‘IFS Global Market’ audit control list recognized by GFSI (Global Food Safety Initiative). Operational activities of suppliers are monitored and their impacts on humans and the environment and sensitivity to ethical and social issues are audited in the context of SEDEX criteria which includes environmental management, occupational health and safety, ethical and social compliance requirements. According to their success in the audits, suppliers approved by Migros were evaluated in three categories as “Gold”, “Silver” and “Bronze” and also, they had the opportunity to announce their successes on the GC Portal.
Our supplier companies that do not achieve a sufficient number of points as a result of the audits are issued a warning and requested to correct the issues that are deemed insufficient. Suppliers that fail to achieve an improvement in 3 consecutive audits are no longer purchased from and the commercial relationship is terminated.
We use global standards as our guide for product safety and aim to provide products in healthy conditions to maintain the unconditional trust of our customers. In this context, not only do we inspect production facilities, but we also inspect all of the stages of procurement until the product reaches the consumer through using both the laboratories, we have established within the Distribution Centers and contracted Accredited Outside Laboratories. As a result of these inspections, products that conform to legal regulations and the Migros standards are presented for sale. All of our stores are inspected without notice by our own staff and Independent Outside Companies to maintain the continuity of the Quality Management System.Migros Ticaret A.Ş. last amendment date: 18.06.2021
Privacy and Data Security Policy
Migros Ticaret A.Ş. Privacy and Data Security Policy
Migros Ticaret A.Ş. (“Migros”) Privacy and Data Security Policy (“Privacy and Security Policy”) aims to assist you in understanding why, how we collect data and what data we collect, what we do with this data and how we
ensure its security. This information is important. Therefore, we recommend you to take the time to read our Privacy and Security Policy carefully. Also, if you are a member of a Migros web site, application or Money
Club Card, we remind you that you can find the controls necessary to manage your information, to protect your privacy in Membership Procedures section of your relevant membership, which you access with your password.
You can utilize Membership Procedures section of our service channel that you share this information, or this link or our following service to correct/update your personal data:
Our Customer Services Centre: 444 10 44
Migros Management considers the application of Migros Information Security Policy as one of the vital processes of the company.
It is important for us you to know clearly how we use your information, how we you ensure your security and how you protect your privacy while you are using our services.
Our Privacy and Security Policy explains the following:
• What information we collect and how we use it?
• How our customers access and update their information?
• How we protect the collected information?
You can let us know your questions, concerns or complaints regarding Our Privacy and Security Policy through our 444 10 44 call centre. Please contact us for all your requests and questions in this respect.
What information we collect and how do we collect it?
As Migros, we collect your personal information from you with the intention of offering better services to you, our customers. Personal information we collect enables us to notify you about the latest products, shopping
deal opportunities, personal deal offerings and future activities of Migros. Moreover, the data we collected from you also enable us to receive feedback from you in the most accurate way about our services and departments
by maintaining information exchange with you, the customers.
If you want to take a look at our Migros web sites, e-trade sites of Migros, Money Club card privileges and/or our applications, we do not request any personal information from you; however, if you want to participate in any features and services offered by our websites, applications and/or services, we may ask you to provide various personal or demographic information. Any information defining you personally and/or being used for communication is defined as personal information in our Privacy and Security Policy. These may include, for example, your name, postal address, e-mail address, telephone number, date of birth, age, sex or fields of interest and preferences associated with your personal data.
Your personal data is only collected with your consent (for example, if you provide them deliberatively by using online forms found on our websites and/or applications or during Money Club card application) and information collection process is generally materialized as follows:
• When you enrol in/become a member of websites or applications
• When you take part in message boards and other online activities
• When you send an announcement or notice to your friend
• When you participate in questionnaires/votes
• When you send feedback through "Contact Us" form
• When you enter information with respect to business (for example, curriculum vitae delivery, media requests, etc.)
• When you have request of any kind requiring personal data input
• When you are spotted out by in-store camera recording system
Type and amount of information collected with respect to abovementioned characteristics will vary depending on the activity. The data we collect during Migros service and website memberships (Apart from credit card information) are stored by us. This information may contain the following (but not limited to these):
• Name, surname
• Postal address
• E-mail address
• Telephone number
• Shopping information
You may be asked to create a user name and/or password for some activities or memberships. Moreover, you may be obliged to provide additional demographic information. This information may include the following:
• Your age or date of birth
• Your gender
• Your frequency of use
• Other information about you
Mobile applications prepared within Migros may collect some information from the users automatically. This information includes;
• Brand-model of your mobile phone,
• Internet Protocol address (IP) of your mobile phone,
• Operating system of your mobile phone,
• Location information
(Within the framework of permission you have given on your phone for use of location information). You can stop this information flow at any time by removing the application from your phone (You can adjust the data collected through your phone from the application settings and permissions section on your phone).
Cookies and Other Technologies
internet site, and they keep various information concerning your visit.
Nowadays, many internet browsers have cookie blocking mode while visiting internet sites. If you activated cookie blocking mode on your web browser, you may not benefit from some features we developed for you on our web site.
As in the case of many websites, some information such as Internet Protocol (IP) addresses, browser type and license, internet service provider (ISP), referring and exit pages, operating system, date/time stamp and clickstream data are collected and saved automatically.
Another technology we use on our website is the “web beacon”. Web beacons (pixel tag), collect information such as the number of times our web site being displayed.
Link clicking URLs connecting to the content on the Migros web site are used in some of our e-mail messages. When customers click on one of these URLs, they pass through a separate web server before reaching target page on our web site. These link clicking data are monitored with the intention of determining interest in certain subjects and measuring the effectiveness of our customer communication. If you do not want to be monitored in this manner, you must not click on the text or graphic link incoming in e-mail messages.
In-store Camera Recording System
Camera recording system is used in our stores for the safety of our customers and operational purposes (for example, state of in-store traffic, etc.). Relevant recordings may be shared with the official authorities under circumstances requiring legal procedures.
How Do We Use the Collected Information?
The information being collected from you is used in line with the purpose you provided us your information, during collection of information or in line with the purposes explained in our Privacy and Security Policy. Option
may be offered to use of your information for a different activity or service other than the activity or service you requested while enrolling to our websites and/or applications, providing information or updating your
Also, we may use your personal and/or demographic information for our analysis works. In this way, we can continually improve, personalize, customize the products and services we offer you and meet your requirements in a better way. These include merging, updating or expanding in different ways sometimes the data we obtained from external sources and/or third parties and your personal data collected through our websites and/or applications. We do not sell, rent and/or exchange your personal data.
We use and store your personal data in compliance with the statues at large with the intention of;
• Making our website and application easier to use,
• Promoting our products and services,
• Sending your online and mobile orders to your address,
• Acquainting ourselves with our members and improving our communication,
• Offering general and special campaigns/advantages,
• Running marketing activities and advertising campaigns,
• Making our departments and services customer specific and personalized,
• Performing data analysis, research, surveys and other customer satisfaction applications/notifications
We need your information in order to exceed customer expectations, to ensure their satisfaction expected from us by reaching out to them and to remain closer to the people we serve. Your personal data is not used aside from the purposes indicated above.
Migros Customer Communication Program (“Program”) is customer oriented marketing program offering general and special campaign, promotion, discount, introduction, opportunity to benefit from clubs-specific advantages and similar benefits that may also be performed together with the Program partners included in;
• Money Club Program Partners
• Migros E-Trade Sites Program Partners
and updated list, to the program members in all places of business including those in the electronic environments operated by Migros.
By becoming a member of our service and departments, our customers warrant commercial electronic message to be sent to them through all kinds of electronic media by Migros and Program partners, within the framework of the applications that may be carried into effect directly or indirectly by the Program, with respect to general and special campaigns, advantages, product, service introductions, advertising, market research surveys and other customer satisfaction applications, notices.
Members give permission for their personal data such as shopping information, name, surname, mobile phone numbers, date of birth, home city, sex, etc., location information that can be accessed due to electronic programs and non-personal information to be collected in order to be used with the intention of good and service promotion, image building, product, service and communication improvement, getting acquainted with its members, auditing, data analysis, research, understanding trends, and also to be used in marketing and advertising services, being stored in data recording systems, being shared with the execution partners such as Program partners, GSM Operators / Social Networking Sites / Cargo companies, etc. for the abovementioned purposes. Unless member indicates otherwise, he/she acknowledges his/her current data to be stored, shared, processed, in line with similar purposes listed within the scope of this article, also after the expiry of his/her membership.
Migros may share cumulative (batch) customer statistics with third parties such as its business partners (including its investors), press, etc. in a manner not to contain the personal data in the individual detail.
The Principles We Observe When Processing Your Data
When we are processing your data, we observe:
• Data to have specific scope,
• Procedures to be performed for legal purposes,
• Procedures being in compliance with law and good faith,
• Data being related, limited and restrained with the purposes that its being collected or processed,
• Processing being performed with up-to-date data,
• Data being stored throughout the necessary period for the purpose of processing.
Accessing and Updating Information
You can make sure that your contact information, preferences and other personal data are correct, complete and up-to-date by accessing your account through our websites and/or applications. Password, user name, credit card
information or other personal data are never requested from you through e-mail. This method aimed at stealing and using your personal data in bad faith is called “Phishing”. When you receive a message appearing to be
sent by us, but requesting your personal data, you must not reply to such message.
We are aiming to enable you access your personal data whenever you use our services. If this information is incomplete or inaccurate, we run the process necessary for you to update or delete this data (if it is not required to be retained for a justified ground concerning the company or legal purposes). We may ask you to verify your identity first to fulfil your request when you update your personal data.
You can use the membership section with a password on the website of our service channel that you share this information or this link or our following services to query your information saved in our database or to correct/update your personal data:
Our Customer Services Centre: 444 10 44
Your Rights Concerning Your Data Being Collected
You have certain rights concerning the data we collected within the framework of this policy. You can;
• Find out whether the data was processed or not,
• If processed, obtain information concerning this,
• Find out the purpose of processing and whether used in compliance with the purpose or not,
• If any, find out the third parties it is being shared with domestically and abroad and the data being shared,
• Ask for it to be corrected in the case of it being inaccurate or incomplete,
• In the case of the reasons necessitating its processing being removed or data losing its actuality, ask for your data to be deleted or destroyed,
• If you have requests concerning its deletion or correction, you can ask your request to be notified to the third parties to which the data being transferred.
You can contact us through our 444 10 44 call centre or this link for your relevant requests.
Our Data Security Criteria
Migros takes all the necessary technical and organizational precautions in order to ensure privacy and security of sensitive personal data and your personal data collected over our websites and/or other applications. These
precautions feature various subjects also including the following:
• Storage of your personal data in a secure, non-public working environment that can be accessed only by Migros employees (within the scope of nondisclosure agreement made with our employees), our intermediaries and contractors
• Authentication of identity of our users, of whom we store personal data, through website or application before accessing this information
Migros takes the relevant precautions including administrative, technical and physical precautions for the protection of your personal data against loss, theft and misappropriation, and also against unauthorized access, sharing, amendment and destruction. Migros uses Secure Sockets Layer (SSL) protocol encryption in online services such as E-Trade sites and on all websites, where personal data being collected. You must use a SSL-supported browser such as Safari, Firefox, Chrome or Internet Explorer to purchase products from these services. By this means, you can protect privacy of your personal data transmitted over internet.
Migros Privacy and Security Policy and practices applied to ensure privacy are explained to the customer/individual upon the request of the customer/individual. Migros abides by the PCI DSS (Payment Card Industry Data Security Standard) regulations established with the intention of ensuring data security in card payment systems and ensures secure data transmission and operation in card payment systems. Your credit card number is transmitted to your bank after being encrypted by our online credit card application and never shared with third parties. Your credit card information is not stored/retained by Migros.
Migros, at its sole discretion, may require 3D payment option for the customers to complete their orders.
Validty of Privacy and Security Policy
Our Privacy and Security Policy is valid for all services offered by Migros (including advertising and research services, etc.).
Leaving Information and Announcement List
If you do not want to take part in our announcement and information list, you can leave any time by updating your preferences. Accessing and controlling authority of the commercial-electronic messages sent from Migros for notification and communication purposes is in your hands. If you do not want us to contact you while your membership to our service and departments continues, you can use your “CANCEL” right in digital media, and actualize your cancellation procedure by sending free SMS to 7447 or contacting our call centre. You will not be contacted until an approval invalidating this being sent by you. If you do not want to benefit from our services any longer and select to drop out of the membership, you can call our customer services line or apply to information departments found in our stores.
Privacy Questions and Reminders
This policy is subject to change due to continuous changes in internet technologies and internet-based business models not having a constant structure. All kinds of changes within the scope of our Privacy and Security Policy
will be announced to our visitors over our websites and/or applications. We recommend you to visit our website periodically to follow the changes to be made on our Privacy and Security Policy.
Please contact us, if you have any questions or concerns about Migros Privacy and Security Policy or data processing.
Spamming is sending e-mail with the intention of advertising, marketing or promotion against your will and without your consent.
As Migros, we do not send spam e-mail. Sending advertising intended e-mail without the consent of the other party is illegal. We do not use your personal data (also including your e-mail address) directly for marketing or advertising purposes without your consent. At the same time, we do not share your personal data with any third party, who may use it for spam e-mails.
Our websites, services and applications offer you opportunity to receive marketing information through e-mail. Each e-mail sent to you by Migros offer you the opportunity to stop receiving marketing e-mails at any date.
If you believe for any reason that you are receiving spam e-mail from a Migros company, please contact us immediately.
Causes of Action and Miscellaneous
Migros may be obliged to disclose your personal data due to law, judicial process, actions and/or demand incoming from the public authorities within or outside the country. When it is deemed necessary or appropriate to share your data for national security, enforcement of law or other issues of importance for the public, your data may be disclosed to the relevant official authorities.
Migros Ticaret A.Ş. last amendment date: 18.06.2021
Occupational Health and Safety Policy1. Purpose
Migros aims to provide a safe workplace environment to protect its employees, business partners and customers against health and safety risks that could occur in the workplace; and follows a proactive approach to sustain this practice.
With the belief that providing a healthy and safe working environment is important for a sustainable future in professional life, Migros works to create a common ‘safety culture’ with all its employees, business partners and customers.
Migros aims to reduce possibilities of accidents and improve on the number of work days lost by providing employees with occupational health and safety training, information, site inspections, equipment and improved physical conditions.2. The Occupational Health and Safety Management System
Migros has created the occupational safety concept in the framework of the Quality Management Systems together with the quality and productivity principles. By standardizing all of the processes being implemented at all locations and establishing the Occupational Health and Safety Management System, Migros has earned a TS ISO 45001 Occupational Health and Safety Management System certificate.
Migros carries out the conditions of the Occupational Health and Safety Management System standards that it manages. By providing its employees with a healthy and safe workplace, Migros complies with the health and safety regulations in force and the internal company requirements. By making sure that resources are used efficiently the company increases management and communication efficiency.
With the external and internal auditing processes conducted by Migros the company validates the efficiency of its management system, determines areas of improvement, detects possible hazards, and finds solutions to health and safety issues and works for improvement.3. Occupational Health and Safety Processes
3.1. The Occupational Health and Safety Board:
In order to monitor and report on the workplace’s compliance with healthy and safe working conditions Migros established the Occupational Health and Safety Board, which is comprised of the senior management at the Migros General Headquarters and reports directly to the Company General Manager, in 2013. The board represents the entire Migros work force and is responsible for facilitating and monitoring occupational health and safety concerning all the activities of the company.
The Occupational Health and Safety Board holds regular meetings in the general headquarters structure, with the participation of occupational safety experts, workplace physicians and the managers of relevant departments in accordance with regulations to monitor the situation and make decisions. The decisions made in the board are implemented in the field. The evaluations of the board and the decisions that are made cover all the activities of the company.
3.2. Occupational Health and Safety Training
Migros provides its employees with occupational health and safety training before they start working and periodically during their employment. At locations where services are purchased and at start of employment on the job and periodic OHS training is provided by occupational safety experts and workplace physicians. Additionally, training that is provided to employees at all locations is reinforced with remote training. In this scope employees are given basic occupational health and safety, occupational health and safety management system, emergency, employee representative, board member, safe use of equipment, first aid and hygiene training.
3.3. Occupational Health And Safety Risk Assessments
Migros prepares risk assessment and analysis reports at all workplaces in the scope of the occupational health and safety regulations and management system work and renews its risk assessments according to legal terms and conditions.
The risk assessment reports are followed by corrective and preventative actions and constant improvement work.
3.4. Occupational Health And Safety emergency action plans
Migros prepares emergency action plans at all workplaces in the scope of the occupational health and safety regulations and management system work and renews these plans according to legal terms and conditions.
In the scope of the Prepared Emergency Plan training is provided to firefighting, search-rescue-evacuation, first aid and power source response teams by local firefighting organizations, specialist companies and occupational health and safety experts and annual drills are organized.
3.5. Occupational Health And Safety environment and health monitoring
Occupational health and safety experts, workplace physicians and freelance consultants will make visits to all Migros locations to inspect OHS processes and applications and enforce corrective/preventive activities when necessary.
The records of work accidents and near miss incidents are kept, reviewed and reported by the occupational safety experts. Workplace physicians conduct inspections on the workplace conditions, tests on new hires and periodic physical examinations.
3.6. Occupational Health And Safety Control and Measurements
In order to make sure that the work equipment being used by general headquarters and branches, shops, distribution centers, fruit-vegetable warehouses and MİGET employees meet OHS conditions periodic inspections are done by authorized companies on the work equipment. Improvements are made on the equipment according to periodical inspections.
Workplace physicians and occupational health experts make sure measurements of conditions are taken in response to the determinations they make during site inspections.Migros Ticaret A.Ş. last amendment date: 18.06.2021
Our company applies the severance and notice compensation provisions of the Labor Law no 4857. Employees - or the legal heirs thereof in the event of such employee’s death - whose employment contracts have been terminated
in accordance with one of the circumstances requiring payment of a severance compensation and who have been employed with our company for at least one year, shall receive a severance payment based on their term of employment
with our company.
Article 17 of the Labor Law no 4857 is applied in those circumstances requiring the service of a notice. The principles outlined in the Collective Bargaining Agreement are applied to those of our employees who are included within the scope of the collective bargaining agreement. The dismissal severance is paid by serving notice on the employee that his/her employment contract is to be terminated and either granting the employee leave to find other employment as per the time periods specified in the Labor Law no 4857 based on such employee’s seniority or payment of the employee’s salary for the duration of such notice period.
Migros Ticaret A.Ş. last amendment date: 18.06.2021
Internal Audit Quality Policy
1. Vision: To provide futuristic assurance and consultancy with proactive activities in accordance with international standards.
2. Mission: To maintain and improve organizational values with advice and foresight by carrying out assurance and consultancy activities in accordance with international standards and professional ethical values.
3. Internal Audit Quality Principles
Internal Audit Directorate is reponsible for the internal audit processes of Migros Ticaret A.Ş. As Migros, in the retail sector where we are leader with our pioneering and innovative practices, our indisputable principles are to make a difference and improve business processes by creating high employee awareness, audit, assurance and consultancy activities.
We aim to provide fair, high quality, reliable and efficient audit services that will carry our service quality forward, adhering to the legal regulations and corporate governance principles.
As a company that has achieved to reflect our understanding of sustainability on our business formation; our leadership on growth, productivity and profitability in the retail sector is the assurance of our internal audit understanding. We have an understanding that is based on our internal customers, our business partners and employees as being honest with each other, trusting and protecting ethical values.
We record all kinds of transmissions that reach us from our communication channels with the awareness that it will carry our quality service forward. We use recorded data in monitoring and reporting, and aim for continuous improvement. We evaluate the communications in the privacy-oriented direction, update our way of doing business by offering objective and fair solutions.
We ensure continuous improvement by achieving the results of International Auditing Standards by providing training and resources necessary for our employees who perform internal audit activities.
We regard our effort on establishing, developing and maintaining Quality Management Systems as the most important value to carry Migros Ticaret A.Ş forward.
Migros Ticaret A.Ş. last amendment date: 18.06.2021
Personal Data Protection and Processing Policy
As a part of its legal and social responsibility; Migros Ticaret A.Ş. ”) (hereinafter referred to as “Migros” or “Company”), is obliged to act in accordance with the current legislation on the protection of personal data, particularly the Constitution of the Republic of Turkey (“Constitution”), International Conventions and the Law on the Protection of Personal Data No. 6698 (“the PDPL) by making compliance with the relevant legislation a life cycle. Migros carries out the necessary studies on the protection of personal data in order to protect the privacy of the person and ensure data security. As part of these efforts, Migros has prepared a Compliance Policy (Policy) with the Law on the Protection of Personal Data.
As a part of its legal and social responsibility Migros; With this Policy, Migros aims to inform its customers, potential customers, employees, employee candidates, suppliers, tenants, lessors, Company shareholders, Institution officials, visitors, service providers, 3rd parties with whom it works, employees of private and public legal entities and its shareholders about the compliance of the processes related to the protection and processing of personal data of the authorities and third parties with the legislation and these processes.
Migros; In cases where the personal data of the parties to the contract is required to be processed, provided that it is directly related to the establishment or performance of a contract, in cases expressly stipulated in the law, in cases where it is necessary to fulfill its legal obligation as a data controller, it is compulsory for the establishment, exercise or protection of a right, in cases where data processing is mandatory for legitimate interests, provided that it does not harm the fundamental rights and freedoms of the person concerned, and in cases where explicit consent is sought, it operates with explicit consent.
Migros processes personal data for the following purposes;
- To promote the goods and services offered by our company, to get to know the members and/or customers, to increase communication, to increase the image, to develop and improve its products, services and communication, to register members in clubs established by Migros (for example, Migros Family Club), general or member-specific personalized preparing and sending promotions/promotions/campaigns/advantages and announcements, providing a better shopping experience to customers, performing customer surveys, customer satisfaction applications and information, auditing, data analysis (clustering, data analysis such as credit scoring within the framework of collaborations, modeling, statistical calculations) studies), research, understanding trends, marketing and advertising services
- Ensuring participation in campaigns with automatic participation, benefiting from these campaigns and informing if there are any gains as a result of the campaign, communicating about the gain and announcing this achievement in various channels,
- In order for you to use the advantages of the Money program with your memberships in our company's www.migros.com.tr, www.macrocenter.com.tr, Migros Virtual Market mobile application, Macroonline mobile application and Money Pay, one of our program partners, within the scope of the above-mentioned Customer Communication and Satisfaction Programs to be matched.
- Providing personalized shopping service
- To provide general and personalized campaign information through commercial communication channels, to carry out commercial communication activities if you agree to be made, to inform about new features and changes in websites and mobile applications.
- Creating general or personalized advertisements, segmentation and marketing analysis studies, advertisements and marketing/communication activities (mobile application and internet) of Migros, suppliers and other 3rd parties in mobile applications, websites, social media or other 3rd party environments. notifications on the websites, pop-up display, personalized offers, customizing user screens, advertising, etc.),
- If location sharing is turned on on your mobile device, creating and delivering the closest and most suitable offers to you.
- To ensure that the necessary work is carried out by our relevant business units in order to carry out the commercial activities carried out by the Company and that the related business processes are carried out,
- To plan and execute the commercial and/or business strategies of the Company,
- To ensure the legal, technical and commercial safety of the Company and the persons who have a business relationship with the Company.
- To record and confirm the identity, address, contact and other necessary information of the shopper/shopper via the website/mobile applications, and to issue all records and documents that will form the basis of the transaction in electronic (internet/mobile etc.) or paper media,
- To carry out the consultancy service procurement process of our customers and suppliers,
- To fulfill the obligations undertaken in accordance with the contracts we have concluded in accordance with the provisions of the relevant legislation, to fulfill our legal obligations and to use our rights arising from the current legislation,
- To provide information to public officials on matters related to public safety upon request and in accordance with the legislation,
- To use as evidence in disputes that may arise
- Planning of company recruitment and employee processes Planning and execution of market research activities for sales and marketing of products and services,
- Planning and execution of corporate communication activities,
- Planning and execution of logistics activities,
- Creation and follow-up of visitor records,
- Ensuring transaction and information security, preventing transactions that may include fraudulent or illegal activities,
- Providing customers with a better shopping experience,
- Providing personalized shopping services (customer surveys, customer satisfaction applications and notifications, auditing, data analysis, research, statistical studies, understanding trends, using in marketing and advertising services),
- The proper and proper performance of Migros' services;
- Fulfillment of obligations within the scope of legal legislation,
- To make our website and applications easier to use,
- Information storage, reporting, informing and providing information to audit companies, the relevant attorney or proxy, as stipulated by the regulatory and supervisory authorities.
- Planning, auditing and execution of information security processes,
- Preparation and submission of various reports, studies and/or presentations;
- Collecting, evaluating and responding to the complaints, questions, requests and suggestions of the person concerned;
- Planning and execution of customer relationship management processes
- Planning and execution of sales and marketing processes of products and/or services
- Fulfilling the requirements of the contracts concluded with the customer,
- Follow-up and execution of legal affairs
- Follow-up of contract processes and/or legal requests,
- Getting to know our members and improving our communication,
- To provide better and reliable service to our customers, to develop more suitable services and products and to maintain them uninterruptedly.
- Customizing and recommending the products and services offered by Migros according to customers' tastes, usage habits and needs,
- Visiting the Company or its website, attending trainings, seminars or organizations organized by the Company, when call centers or website are used to use Migros services.
- Management of relations with business partners and/or suppliers,
- Company Headquarters, Branch offices, warehouses, stores and Miget etc. ensuring the security of its facilities,
- Planning and execution of emergency management processes,
- Planning and execution of personnel processes for subcontractor employees,
- Follow-up of finance and/or accounting works,
- Planning and monitoring of building and/or construction works,
- Execution of management activities,
- Providing information to authorized persons, institutions and organizations,
- Execution of talent / career development activities,
- Execution of investment processes,
- Ensuring the security of data controller operations,
- Execution of the wage policy,
- Execution of supply chain management processes,
- Ensuring the security of movable property and resources,
- Follow-up of requests / complaints,
- Execution of strategic planning activities,
- Execution of sponsorship activities
- Conducting Social Responsibility and Civil Society Activities
- Execution of Storage and Archive Activities
- Execution of Performance Evaluation Processes
- Organization and Event Management
- Execution of Activities for Customer Satisfaction
- Execution of Customer Relationship Management Processes
- Execution of Goods / Services Production and Operation Processes
- Execution of Goods / Services Sales Processes
- Execution of Goods / Services After-Sales Support Services
- Execution of Goods / Services Procurement Processes
- Execution of Business Continuity Ensuring Activities
- Receiving and Evaluating Suggestions for Improvement of Business Processes
- Execution of Occupational Health / Safety Activities
- Execution / Supervision of Business Activities
- Planning of Human Resources Processes
- Execution of Communication Activities
- Carrying out Internal Audit / Investigation / Intelligence Activities
- Execution of Assignment Processes
- Ensuring Physical Space Security
- Execution of Company / Product / Services Loyalty Processes
- Execution of Finance and Accounting Affairs
- Execution of Access Authorizations
- Execution of Training Activities
- Execution of Audit / Ethical Activities
- Execution of Benefits and Benefits Processes for Employees
- Fulfilling Employment Contract and Legislative Obligations for Employees
- Execution of Employee Satisfaction and Loyalty Processes
- Execution of Application Processes of Employee Candidates
- Execution of Employee Candidate / Intern / Student Selection and Placement Processes
- Execution of Information Security Processes
- Execution of Collective Bargaining Agreement activities concluded with the union
In this Policy, detailed explanations are provided by Migros regarding which data is personal data, which personal data is stored, administrative and technical measures taken for the protection of personal data, and the processing and preservation of personal data, enlightening and informing the relevant persons, transferring them to third parties and their protection.
This Policy applies to all personal data that are processed automatically or non-automatically, provided that it is a part of any data recording system of; customers, potential customers, employees, employee candidates, suppliers, tenants, lessors, service providers, 3rd parties and 3rd party employees, shareholders and partners, visitors, employees of private law and public law legal entities/institutions that cooperate, its shareholders and officials, third parties.
The following entities that process and store personal data within Migros and all processes related to these entities are within the scope of this Policy;
- All printed or written documents, documents, files containing personal data
|Open Consent||Consent on a particular subject, based on information and expressed with free will.|
|Personal Data||Any information relating to an identified or identifiable natural person. For example; name- surname, T.C. Identification Number, e-mail address, phone information, address, date of birth, credit card number, etc.|
|Special Qualified Personal Data||Data on race, ethnicity, political thought, philosophical belief, religion, sect or other beliefs, dress, membership in associations, foundations or trade unions, health, sexual life, criminal convictions and security measures, and biometric and genetic data|
|Related person||Natural person whose personal data is processed|
|Anonymization||Making personal data not to be associated with an identified or identifiable natural person in any way, even by matching with other data.|
|Employee Candidate||Natural persons who have applied for a job at Migros by any means or have opened their CV and related information to Migros' review.|
|Constitution||Constitution of the Republic of Turkey|
|the PDPL||Law No. 6698 on the Protection of Personal Data|
|the PDP Board||Personal Data Protection Board|
|the PDP Institution||Personal Data Protection Authority|
|Processing of Personal Data||Obtaining, recording, storing, preserving, changing, rearranging, disclosing, transferring, taking over, making available, classifying or using personal data in whole or in part by automatic or non-automatic means provided that it is a part of any data recording system. Any operation performed on the data, such as blocking.|
|Customer||Real persons who use or have used the products and services offered by our Company, regardless of whether they have any contractual relationship with our Company.|
|Data Processor||It is the natural and legal person who processes personal data on behalf of the data controller based on the authority given by him. For example, the cloud computing company that keeps the data of our Company, the interviewers who have the customers sign the forms, the call center that makes calls within the framework of the instructions, etc.|
|Data Recording System||The registration system in which personal data is processed and structured according to certain criteria|
|Data Controller||The natural or legal person who determines the purposes and means of processing personal data, establishes and manages the place where the data is kept systematically (data recording system) is the data controller. The data controller is Migros, our company.|
|Data Controllers Registry||The Data Controllers Registry, which is open to the public and kept by the Presidency of the PDP Institution under the supervision of the PDP Board|
|Visitor||Real persons who have entered the physical campuses owned by the institution for various purposes or visited the websites|
|Employees, Shareholders and Officials of the Institutions We Cooperate With||Real persons who are employees, shareholders and officials of institutions (including but not limited to performance assistant, business partner, supplier, program partner, etc.) that have a business relationship with Migros|
|Suppliers||Third parties from which Migros purchases products and/or services on a contract basis|
|Potential Customer||Real persons who have requested to purchase and/or use our products and services, or who have been evaluated in accordance with commercial practices and honesty rules|
|Policies and Procedures||Policies and procedures prepared by Migros to comply with the Personal Data Protection Law|
|Company||Migros Ticaret A.Ş.|
|Company Shareholders||Migros shareholder real persons|
|Company official||Migros board member and other authorized natural persons|
|Migros Personal Data Application Form||The application form that data owners will use when using their applications regarding their rights in Article 11 of the PDPL|
|Third Party||Third real persons who are in relationship with these parties in order to ensure the security of commercial transactions between the parties described above and Migros or to protect the rights of the said parties and to obtain benefits.|
|PERSONAL DATA CATEGORY||PERSONAL DATA CATEGORY DISCLOSURE|
|Credentials||In documents such as driver's license, identity card, residence, passport, attorney's ID, marriage certificate, T.C. identification number, nationality information, mother's name, father's name, place and date of birth, gender, SSI number, signature information, vehicle license plate etc. all information|
|Communication information||It is clear that it belongs to a real person; information such as phone number, address, e-mail, fax number|
|Special Qualified Information||“Racial, ethnic origin, political thought, philosophical belief, religion, sect or other belief, costume and dress, association, foundation or union membership information, health and sexual data on life, criminal convictions and security measures, and biometric and genetic data.|
|Location Information||Location data obtained through the applications used by customers, obtained during the use of company vehicles, and digital cards given to visitors, employees and employee candidates|
|Physical Space Security Information||Personal data such as camera records, fingerprint records, retna scanning, records taken at the security point, records taken at the entrance to the physical space and during the stay in the physical space processed to be kept in the data recording system, to ensure our security in every aspect while carrying out our commercial activities.|
|Customer information||Information obtained and produced from real person customers as a result of our commercial activities and the operations of the relevant units within the scope of these activities.|
|Customer Transaction Information||The information obtained within the scope of the records for the purchase of our products and services and the instructions required for the purchase of our customer in the data recording system, and the personalization of the usage and purchasing habits in line with the taste and needs of the personal data subject who purchases and/or uses our products and services. Personal data processed for|
|Request/Complaint Management Information||Personal data regarding the receipt and evaluation of all kinds of requests or complaints directed to Migros communication channels by real persons, whether they are Migros customers or not.|
|Reputation and Incident Management Information||In order to protect the commercial reputation of Migros and to ensure that the public is informed correctly, social media etc. related to events that have the potential to affect Migros employees and shareholders. Personal data collected from media, evaluations (posts about Migros, etc.)|
|Financial Information||IBAN number, credit card information, financial profile, income information etc. personal data processed within the scope of the records showing all kinds of financial results within the framework of the legal relationship established by Migros with the personal data subject.|
|Marketing Information||Personal data processed for tailoring and marketing our products and services in line with the usage habits, tastes and needs of the person concerned, and reports and evaluations created as a result of these processing results|
|Risk Management Information||In order to manage our commercial, technical and administrative risks, personal data processed through the methods used in accordance with the generally accepted legal, commercial practice and good faith in these areas|
|Transaction Security Information||Your personal data processed in order to ensure our technical, administrative, legal and commercial security during the execution of our activities (for example, log records, IP information, identity verification information)|
|Audio/Visual Information||Photographs and camera recordings (excluding recordings included in the Physical Space Security Information) and sound recordings|
|Audit and Inspection Information||Personal data processed for the execution of our company's operational, financial, fraud and compliance audit activities|
- All applications containing personal data
- All databases containing personal data
- All systems containing personal data,
- All devices containing personal data,
- All audio recordings containing personal data,
- All logs containing personal data (audit traces),
- All image records containing personal data,
Anonymized and unidentifiable data such as data obtained for statistical evaluations or studies that do not contain personal data, data relating to legal entities and data that are not considered personal data pursuant to Law No. 6698 are not subject to this Policy.
3.ENFORCEMENT AND UPDATES
Policies and procedures will be published by Migros on the Corporate website and made available to all employees and the public. In case of conflict with the legislation in force, especially the Law No. 6698, and the regulations included in this Policy and procedures, the provisions of the legislation shall apply. The Company reserves the right to make changes in this Policy and procedures in line with the legal regulations. In case of a change in this Policy or in the matters in the Policy and procedures, or in case of new processes coming to the agenda, the Policy will be updated immediately and the updated version will be published on the Corporate website.
In order to be kept in the data recording system, camera records, fingerprint records, retna scanning, records taken at the security point, records taken at the entrance to the physical space, records taken during the stay in the physical space, etc. personal data to ensure our security in every aspect while carrying out our commercial activities.
5. CATEGORIZATION OF PERSONAL DATA
Within the scope of data processing activities carried out by Migros, the categories and explanations of personal data, which are processed partially or completely automatically or non-automatically as part of the data recording system, to which the real person belongs and/or can be determined, are as follows:
6. PROCESSING OF PERSONAL DATA
Migros takes technical and administrative measures according to technological possibilities and implementation costs in order to ensure that personal data is processed in accordance with the law. Employees are informed that they cannot disclose the personal data they have learned to others in violation of the provisions of the PDPL and cannot be used for purposes other than processing, and that this obligation will continue after they leave their job, and necessary commitments are taken from them in this direction.
Migros' personal data processing activity includes any action taken towards data using automatic, semi-automatic or non-automatic means, without any restrictions.
Migros has the right to process the information of a data subject during the use of its services and after the termination of the relationship, by complying with the principles set out below.
Migros protects the personal data of the person concerned or the third parties specified by the person concerned, with the measures/actions it has taken;
- Migros raises awareness among data processing institutions, such as business partners and suppliers, to which personal data has been transferred, on the prevention of unlawful processing of personal data, the prevention of illegal access to data, and the provision of legal protection of data.
- Obligations that Migros has to comply with when processing personal data as a data controller and the obligation to comply with the legal, administrative and technical measures it has developed in this regard are consistent with the nature of the data processing activities performed by the 3rd parties with whom Migros has relations with various titles, such as suppliers and business partners and it is checked whether these obligations are fulfilled.
- Migros takes the necessary technical and administrative measures, according to technological possibilities and implementation costs, in order to store personal data in secure environments and to prevent their destruction, loss or alteration for unlawful purposes. In addition to the PDPL technical measures, Migros also takes the necessary security measures regarding current threats in order to protect the data in question in the field of cyber security.
- Migros carries out the necessary inspections within its own body or has it done, in accordance with Article 12 of the PDPL. The results of these audits are reported and necessary activities are carried out to improve the measures taken.
- Migros operates the system that ensures that the personal data processed in accordance with Article 12 of the PDPL is obtained by others illegally, and this situation is reported to the relevant person and the PDP Board as soon as possible.
6.1. Scope of Processing of Personal Data
The scope of the processing of personal data is as in the 2nd and 6th headings. Migros shall have the right to process the information of the person concerned during the period of using Migros services and after the termination of the relationship, in accordance with the principles set forth in this Policy.
Personal data processing by Migros includes any action taken towards data using automatic, semi-automatic or non-automatic means, without any restrictions. In other words, personal data processing; Receiving, collecting, recording, photographing, sound recording, video recording, organizing, storing, modifying, transferring, disseminating or presenting, grouping or combining, blocking, deleting or destroying data from related persons or third parties, reinstatement, retrieval or disclosure, obtaining, recording, storing, preserving, changing, rearranging, disclosing, transferring, transferring abroad, acquiring data by fully or partially automatic or non-automatic means provided that it is a part of any recording system means making it available, classifying, or preventing its use.
6.3. Processing of Personal Data in Compliance with the Principles Established in the Legislation
Pursuant to Article 5 of the PDPL, personal data can only be processed in accordance with the procedures and principles stipulated in the PDPL and other relevant legislation. As Migros, personal data is processed in accordance with the procedures and principles set forth in the PDPL and other relevant legislation; Within the scope of the PDPL, it is clearly regulated that the following principles must be complied with in the processing of personal data.
- Processing of Personal Data in Compliance with the Law and the Rules of Integrity
Migros carries out the processing of personal data in accordance with the Constitution of the Republic of Turkey, the PDPL and other relevant legal regulations, legal regulations, within the principle of honesty and based on the relationship of trust.
- Ensuring the Accuracy and Up-to-Dateness of Processed Personal Data
Migros; While executing personal data processing activities, it has established systems and processes to ensure the accuracy and up-to-dateness of the personal data it processes. In this context, Migros takes the necessary measures to correct the personal data of the persons concerned and confirm their accuracy.
- Processing of Personal Data for Specific, Explicit and Legitimate Purposes
Migros, within the scope of the disclosure obligation in Article 10 of the PDPL, clearly and precisely determines the purpose of processing personal data before starting the processing of personal data, and processes it for clear and lawful purposes (For detailed information on the obligation to clarify, see. Policy section 9.1)
- Purpose-Related, Limited and Moderate Processing of Personal Data
Migros processes personal data to the extent necessary and in connection with the purpose of realizing the service it has determined and provided before starting the processing activity. Migros does not process personal data with the assumption that it is not related to the realization of the purpose or that it will be needed in the future. The processing of personal data is limited to Migros' activities and legal obligations.
- Retention of Personal Data for the Period Envisioned in the Relevant Legislation or Required for the Purpose of Processing
Migros retains personal data for a limited period of time stipulated in the PDPL and the relevant legislation or required for the purpose for which they are processed. In this respect, Migros stores personal data for a period of time, if it is stipulated in the relevant legislation, and for the period required for the purpose for which it is processed, if a period is not foreseen. Migros does not store personal data for future use.
Migros deletes, destroys or anonymizes personal data in the event that the period expires or the reasons for its processing disappear.
6.4. Terms of Processing Personal Data
In accordance with the regulation in Article 5 of the PDPL, Migros processes personal data only in cases stipulated in the law or in cases where explicit consent is required, with the explicit consent of the data subject. However, in accordance with paragraph 2 of Article 5 of the PDPL; The Legislator has allowed the processing of personal data even in the absence of explicit consent. According to this; Personal data may also be processed by Migros in the presence of one and/or several of the other conditions specified in the following clauses: "Explicitly Prescribed by Law" and "Mandatory Data Processing for the Legitimate Interest of Migros, Provided Not to Harm the Fundamental Rights and Freedoms of the Data Subject". Although the existence of only one of the conditions stated below is sufficient for personal data processing; More than one of the aforementioned conditions may also be the basis for the same personal data processing activity.
In case the processed data is special quality personal data, the conditions to be applied are specified in 7.1 of the Policy. It is also mentioned in the section.
- 6.4. Terms of Processing Personal Data
The personal data of the data owner may be processed by Migros without the explicit consent of the data owner, in accordance with the law, if it is expressly stipulated in the law. For example; Personal data is processed while keeping the workplace registry file of the employees within the framework of the Labor Law and relevant legislation.
- The Person Who Is Incapable of Expressing His Consent Due to Actual Impossibility or For whose Consent is Not Legally Recognized Being Obligatory for the Protection of Himself or Another Person's Life or Bodily Integrity
The personal data of the data owner may be processed if it is necessary to process the personal data of the person who is unable to express his or her consent due to actual impossibility, or whose consent cannot be validated, in order to protect the life or physical integrity of himself or another person.
In cases where the personal data owner cannot explain his consent or his consent cannot be validated, the personal data of the data owner may be processed if it is necessary to process the personal data of the person himself or another person in order to protect his life or physical integrity. For example; The family of our customer, who had an accident in the sales store operated by Migros, was given to the store officials by his family.
- It is Necessary to Process the Personal Data of the Parties to the Contract, Provided that it is Directly Related to the Establishment or Performance of a Contract
Provided that it is directly related to the conclusion or performance of a contract, personal data may be processed by Migros if it is necessary to process the personal data of the parties to the contract. For example, informing the name, surname, address and telephone information of the customer shopping on the e-commerce site of Migros to the employees of the company carrying the products for the delivery of the products ordered.
- The Personal Data Owner Has Made His Personal Data Public by Himself
If the data owner has personally made his personal data public (social media, etc. in any way or form), the relevant personal data may be processed without seeking explicit consent.
- Mandatory Data Processing for the Establishment or Protection of a Right
If data processing is necessary for the establishment, exercise or protection of a right, the personal data of the data owner may be processed. For example, keeping the sales contract with evidence and using it when necessary.
- Obligatory Data Processing for the Legitimate Interest of Migros, Provided Not to Harm the Fundamental Rights and Freedoms of the Related Person
Although the protection of personal data is a constitutional right; Provided that the fundamental rights and freedoms of the personal data owner are not harmed, the personal data of the data owner may be processed if data processing is necessary for the legitimate interests of Migros. For example, personal data processing activities in the calculations to be made by the financial affairs department.
- Finding the Explicit Consent of the Personal Data Owner
One of the conditions for the processing of personal data is the explicit consent of the personal data owner, in the absence of the exceptions specified in Article 5 of the Law. The personal data owner must declare that he has been sufficiently informed about a particular subject and, based on this information, he has consented to the processing of his personal data with his free will and without hesitation.
7. PROCESSING OF SENSITIVE PERSONAL DATA
7.1. Conditions of Processing of Sensitive Personal Data
Personal data determined as "sensitive" within the scope of the PDPL due to the risk of causing victimization or discrimination of individuals when processed unlawfully, are also specified in this Policy due to this sensitivity.
The processing of sensitive personal data defined in paragraph 1 of Article 6 of the PDPL is prohibited without the explicit consent of the data owner, as stated in the second paragraph of Article 6 of the PDPL. Paragraph 3 of Article 6 of the PDPL regulates the exceptions to this rule.
Sensitive personal data are processed in accordance with the above-mentioned law, provided that adequate measures to be determined by the PDP Board are taken by Migros.
7.2. Protection of Sensitive Personal Data
With the Personal Data Protection Law, some personal data are also stated in this Policy due to the risk of causing victimization or discrimination when processed unlawfully. Processing of Sensitive Personal Data, 7.1 of the Policy clearly stated in the article.
For employees involved in the processing of special categories of personal data; Regular trainings are provided on the law and related regulations as well as special quality personal data security, confidentiality agreements are made, the users who have access to data, the scope and duration of their authorization are defined clearly, authorization checks are carried out periodically, and the employees who have a change of job or quit their job are given regular training. Their authorizations in the field are immediately revoked and in this context, necessary measures are taken to return the inventory allocated to the employee by Migros as the data controller.
Environments where sensitive personal data are processed, stored and/or accessed, and electronic media; keeping data using cryptographic methods, keeping cryptographic keys secure and in different environments, securely logging all access to data and transaction records of all movements on the data, constantly monitoring security updates for the environments in which the data is located, regularly performing/performing the necessary security tests, testing Necessary measures are taken to record the results of the test, to close the security gaps in the test results as soon as possible, to authorize the user for this software if the data is accessed through a software, to record the test results, if remote access to the data is required, it is taken to necessary measures to provide at least a two-stage authentication system.
Environments where sensitive personal data are processed, stored and/or accessed, and physical environment; Necessary measures are taken to ensure that adequate security measures are taken (against situations such as electricity leakage, fire, flood, theft, etc.) according to the nature of the environment in which special quality personal data is located, to prevent unauthorized entries and exits by ensuring the physical security of these environments, and to record the access of authorized persons.
8. TRANSFER OF PERSONAL DATA
In accordance with the purposes of Migros to serve the data owner properly, transfer/sharing of data related to the data owner and/or third parties indicated by the data owner may be required within the scope of data processing.
Personal data, the business units to carry out the necessary work to benefit from the products and services offered by Migros, the products and services offered are customized according to the tastes, usage habits and needs of the customers, and the legal and commercial security of those who have a business relationship with Migros (for the communication carried out by Migros) administrative operations, ensuring the physical security and supervision of Migros' locations, business partner/customer/supplier (authorized or employee) evaluation processes, reputation research processes, legal compliance process, audit, financial affairs, etc.), Migros' commercial and business operations To business partners, suppliers, Authority officials, shareholders, affiliates, subsidiaries, legally authorized public institutions and private individuals, MİGROS Family (Migros' Management Shareholders, Management Shareholders) for the purposes of determining and implementing strategies and ensuring the execution of human resources policies. and Migros' affiliates, subsidiaries, businesses) service providers and/or subcontractors and GSM Operators in the country and abroad due to information technologies, cloud service providers and social networking sites (due to the relevant servers being abroad). It can be transferred within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9.
Migros may transfer the personal data and sensitive personal data of the personal data owner to third parties (third party companies, group companies, third real persons, public institutions within the scope of relevant laws) by taking the necessary security measures in line with the personal data processing purposes in accordance with the law. In this regard, Migros acts in accordance with the regulations stipulated in Article 8 of the PDPL.
Migros applies the exceptions for the transfer process specified in this Policy article, as specified in the 2nd paragraph of Article 8 of the PDPL.
Provisions in other laws regarding the transfer of personal data are reserved.
8.1. Domestic Transfer of Personal Data
Migros' ability to provide better service to the personal data owner, to meet their demands more accurately, to improve their service and communication, to provide customer satisfaction practices and information, and to eliminate technical problems, etc. In accordance with the purposes of data processing, it may be necessary to transfer/share the data related to the data owner and/or the third parties indicated by the data owner to third parties. In this regard, Migros acts in accordance with the regulations stipulated in Article 8 of the PDPL and the regulations in this Policy within the scope of the said article. 8.3 of this Policy. The table in the article contains the transfer purposes.
8.1.1. Domestic Transfer of Private Personal Data
Migros can transfer the sensitive data of the personal data owner to third parties by showing the necessary care and taking the necessary security measures, by taking the adequate measures prescribed by the PDP Board; in line with its legitimate and lawful purposes while taking into account the conditions set out in the 7th section of this Policy.
8.2. Transfer of Personal Data Abroad
Migros may transfer the personal data and sensitive personal data of the personal data owner to third parties by taking the necessary security measures in line with its lawful purposes. Personal data processed by Migros can be transferred, provided that the data controllers in Turkey and in the relevant foreign country undertake in writing to provide adequate protection and have the permission of the PDP Board; In accordance with Article 9 of the PDPL, provided that adequate measures are taken with the 2nd paragraph of the 5th article of the PDPL, in case one of the conditions specified in the 3rd paragraph of the 6th article of the PDPL is met, and adequate protection is provided by the PDP Board of the foreign country to which the personal data will be transferred.
8.2.1. Transfer of Private Personal Data Abroad
Migros can transfer the sensitive data of the personal data owner to the countries that are declared to have sufficient protection or to which adequate protection is committed by the data controller located in a foreign country, taking into account the conditions regulated in the 7th section of this Policy by showing due diligence, taking the necessary security measures and taking the adequate measures prescribed by the PDP Board; In line with the legitimate and lawful personal data processing purposes.
If sensitive personal data needs to be transferred via e-mail, it will be transferred cryptically with a corporate e-mail address or by using a Registered Electronic Mail (KEP) account; if it is transferred via media such as portable memory, CD, DVD, it will be encrypted with cryptographic methods and the cryptographic key is kept in a different environment; If transferring is carried out between servers in different physical environments, performing data transfer between servers by establishing a VPN or using SFTP method, taking necessary precautions against risks such as theft, loss or viewing of documents by unauthorized persons if data is required to be transferred via paper media, and sending the document in "confidential documents" format. Necessary precautions and measures are also taken if a transfer is required by a method other than the methods mentioned.
8.3. Third Parties and Purposes of Transfer of Personal Data
In accordance with Articles 8 and 9 of the PDPL, Migros may transfer the personal data of its customers to the following categories of persons:
(i) Business partners,
(ii) its suppliers,
(iv) To the holding to which it is affiliated,
(v) Other companies belonging to the holding to which it is affiliated,
(vi) To its shareholders,
(vii) Legally authorized public institutions and organizations,
(viii) Legally authorized private legal persons,
(ix) To other third parties in accordance with the data transfer terms,
(x) Lawyers/Law firms/Consultants.
The scope and data transfer purposes of the persons mentioned above are stated below; Migros acts in accordance with the issues regulated in Section 10 of the Policy.
|Persons to whom Data Transfer can be made||Definition||Purpose of Data Transfer|
|Business partner||It defines the parties with which Migros establishes business partnerships for purposes such as sales, promotion and marketing of Migros products and services, after-sales support, and execution of joint customer loyalty programs.||In order to ensure the fulfillment of the purposes of the establishment of the business partnership, the necessary works are carried out by the business units in order to benefit from the products and services offered,|
|Supplier||It defines the parties that provide services to our Company on a contractual basis in accordance with the orders and instructions of our Company while carrying out the commercial activities of Migros.||In order to ensure that Migros provides the services that are outsourced by Migros from the supplier and necessary to carry out the commercial activities of Migros.|
|Our Affiliates||Companies of which Migros is a shareholder||Limited to ensuring the execution of commercial activities that require the participation of Migros' subsidiaries.|
|Affiliated Holding||Fatih Sultan Mehmet Mahallesi, Balkan Caddesi No. 58 Buyaka E Blok Tepeüstü, Umraniye||Limited to use for planning and auditing the strategies of Migros regarding its commercial activities.|
|Other Companies belonging to the Holding to which it is Affiliated||Anadolu Grup Holding A.Ş., located at 34771 Istanbul, TURKEY.|
|Our Shareholders||Other companies of Anadolu Grubu Holding A.Ş. operating in various sectors||Limited to the purposes of designing strategies and auditing of Migros' commercial activities in accordance with the provisions of the relevant legislation.|
|Legally Authorized Public Institutions and Organizations||Our shareholders, who are authorized to design strategies and audit activities regarding Migros' commercial activities in accordance with the provisions of the relevant legislation||Limited to the purpose requested by the relevant public institutions and organizations within their legal authority.|
|Legally Authorized Private Law Persons||Public institutions and organizations authorized to receive information and documents from Migros in accordance with the provisions of the relevant legislation||Limited to the purpose requested by the relevant private legal persons within the scope of their legal authority.|
|Lawyers/Law firms/Consultants||Private law persons authorized to receive information and documents from Migros in accordance with the provisions of the relevant legislation||For the resolution of disputes that may arise with real person customers / business partners / suppliers, etc.|
|Other Third Parties in Compliance with Data Transfer Terms||Private law persons that Migros receives support in resolving legal disputes||Private law persons|
The scope and data transfer purposes of the persons mentioned above are stated below; Migros acts in accordance with the issues regulated in Section 10 of the Policy in the transfers made.
9. RIGHTS AND OBLIGATIONS REGARDING PERSONAL DATA
9.1. Obligation to Inform Relevant Persons by Migros
Pursuant to Article 10 of the PDPL; Migros is obliged to inform the relevant persons during the acquisition of personal data.
In this context, Migros informs the data owners that during the collection of personal data, the personal data will be processed by it, the purposes for which the personal data will be processed, to whom and for what purpose the processed personal data can be transferred, the method of personal data collection and legal reasons and the rights of the data owner in accordance with Article 11 of the PDPL informs what is going on and obtains explicit consent if necessary.
9.2. Rights of Relevant Persons
The personal data owner may apply to Migros in accordance with Article 11 of the PDPL and make the following requests:
1. To learn which of their personal data are kept in Migros or not,
2. To learn whether personal data is processed or not,
3. If personal data has been processed, requesting information about it,
4. To learn the purpose of processing personal data and whether it is used in accordance with its purpose,
5. To know the third parties to whom personal data is transferred in the country or abroad,
6. To request correction of personal data if it is incomplete or incorrectly processed,
7. Within the scope of Article 7 of the PDPL, although it has been processed in accordance with the provisions of the PDPL and other relevant laws, to request the deletion or destruction of personal data in the event that the reasons requiring its processing are eliminated, and to request the notification of the transaction made within this scope to the third parties to whom the personal data has been transferred,
8. To request notification of the transactions made in accordance with subparagraphs (d) and (e) above, to third parties to whom personal data is transferred,
9. To object to the emergence of a negative result due to the analysis of the processed personal data exclusively with automated systems,
10. To request the compensation of the damage in case of damage due to unlawful processing of personal data
9.3. Circumstances Excluded from the Rights of the Personal Data Owner
It has been regulated that the provisions of the PDPL will not be applied in case of the existence of the conditions specified in the first paragraph of Article 28 of the PDPL. In this context, it is not possible for the persons concerned to assert their rights listed in the PDPL regarding the personal data processed by Migros.
Except for the right of the persons concerned to demand the compensation of the damage in the cases specified in the 2nd paragraph of Article 28 of the PDPL; They cannot claim their other rights listed in the PDPL.
9.4. Right of Application of Personal Data Owner to Migros
Related persons, in accordance with the 1st paragraph of Article 13 of the PDPL and the "Communiqué on the Procedures and Principles of Application to the Data Controller", can submit their requests regarding the exercise of the rights legally granted to them in writing at www.migroskurumsal.com. They must fill the form and submit it to Migros with a wet signature or a secure electronic signature. Requests with secure electronic signatures are sent to email@example.com, and requests with wet signatures to Atatürk Mah. Turgut Özal Bulvarı No: 7 Ataşehir-İSTANBUL address. Again, by filling out the Migros Personal Data Application Form available at www.migroskurumsal.com, it should be sent via e-mail to firstname.lastname@example.org using the e-mail addresses previously notified to Migros and registered in the Migros system.
In the application;
i) Name, surname and signature if the application is written,
ii) For citizens of the Republic of Turkey, T.R. identification number, nationality for foreigners, passport number or identification number, if any,
iii) Domicile or workplace address for notification,
iv) E-mail address, telephone and fax number, if any, for notification,
v) The subject of the request must be present. Information and documents related to the subject must be attached to the application.
It is not possible to make a request by third parties on behalf of the Relevant Persons, and in order for a third party to make a request, the personal data owner must be authorized with a special power of attorney issued on behalf of the third party to apply.
9.5. Responding to Applications of Relevant Persons by Migros
Pursuant to Article 13 of the PDPL; The requests included in the application submitted by the personal data owner in accordance with the above procedure, will be concluded free of charge by Migros as soon as possible and within thirty days at the latest, depending on the nature of the request. Migros may accept the application or reject it by explaining the reason. Migros notifies the reply in writing or electronically (via e-mail) to the contact address provided to it. The person making the request did not provide the contact information, verification could not be made, the Migros Personal Data Application Form was not filled in completely and completely as specified, the information was incomplete, Migros is also not obliged to respond in cases where the requester does not provide the contact information, verification cannot be made, the Migros Personal Data Application Form is not filled in completely and completely as specified, the information is incomplete and the application is not made through the channels specified in Article 9.4. and in the specified ways. In cases where the contact address given by the relevant person cannot be reached, the relevant person will be deemed to have responded to his/her application. In case the transaction to be carried out requires a separate cost, Migros may charge the applicant the fee in the tariff determined by the PDP Board. If the application is due to Migros' fault, the fee will be refunded to the person concerned.
Migros may request information from the relevant person in order to determine whether the applicant is the relevant person and to clarify the requests included in the application.
Migros' responsibility cannot be mentioned in case the requests that are not delivered in accordance with the procedure specified in section 9.4 of the Policy and/or with a legally valid notification do not reach Migros or if the response does not reach the applicant.
9.6. Right of Personal Data Owner to Complain to the PDP Board
The personal data owner can make a complaint to the Board as specified in Article 14 of the PDPL. Personal data owner, Article 13 of the PDPL and 9.4 of this Policy. Without using the right of application set out in the section of the PDPL, the applicant cannot apply to the PDP Board.
10. Technical and Administrative Measures Taken to Safely Keep Personal Data and to Prevent Unlawful Processing and Access
In accordance with Article 12 of the PDPL, Migros takes all kinds of technical and administrative measures to ensure the level of security, and in this context, it carries out the necessary audits or has it done within the framework of contracts made with third party companies. The incompatibilities emerging as a result of these studies are tried to be closed as soon as possible based on risk analyzes such as cost, effort, and the criticality of the non-compliance.
10.1. Confidentiality in the Processing of Personal Data
Personal data processed by Migros in accordance with the law are subject to data security. Migros takes all necessary technical and organizational measures to ensure the confidentiality and security of sensitive personal data and your personal data collected through our websites and/or other applications.
It is prohibited for any Migros employee to access, process or use this data for private or commercial purposes, to share this data with unauthorized persons or to make this data accessible by any other method. Migros employees can access personal data only in accordance with the type and scope of their duties. For this, roles and responsibilities are detailed and separated. Any employee of Migros who is not authorized within the framework of their legitimate duty to process this data means an unauthorized transaction.
Managers should inform their employees about the obligation to protect data privacy at the beginning of the employment relationship. This obligation will continue after the termination of employment.
10.2. Security in the Processing of Personal Data
Personal data is protected by Migros against unauthorized access, illegal data processing or disclosure, and accidental loss, alteration or destruction of data. Personal data is stored in secure working environments that are not open to the public and can only be accessed by authorized Migros employees (within the scope of the Confidentiality Agreement with our employees), our agents and contractors.
For our customers whose personal data are stored before accessing personal data (for e-commerce sites and Money program applications), the identity information of the data owner is verified via the website or application. Again, identity information is verified through the HR portal used by our employees.
This provision shall apply whether the data is processed electronically or on paper. Until the emergence of new data processing methods, especially new information technology systems, the following technical and administrative measures are defined and implemented to protect personal data. These measures have been designed taking into account the most advanced technology available, the risks of data processing and the need to protect data.
10.3. Technical Measures
Within Migros, personal data processing activities and their storage in a secure environment are carried out with technical systems, and technical solution applications are made. Technical measures are taken in accordance with the developments in technology, the measures taken are periodically updated and renewed.
The technical measures taken are periodically reported to the relevant person in accordance with the internal control mechanism, and the necessary technological solutions are produced by re-evaluating the risky issues.
In addition, knowledgeable and experienced personnel in technical matters are employed. When necessary, knowledgeable and experienced employees are also utilized through service procurement from 3rd party companies.
On the other hand, the main methods regarding the technical measures to be taken by the data controllers in order to prevent the illegal processing of personal data by the Personal Data Protection Authority and illegal access to personal data and to ensure the protection of personal data are listed in the "Personal Data Security Guide (Technical and Administrative Measures)" guide has published. In addition to taking the precautions in this guide, Migros also takes the necessary security measures based on other published standards regarding security and current threats.
10.4. Administrative Measures
Employees are informed and trained about the law of protection of personal data and the processing of personal data in accordance with the law, that they cannot be disclosed to others in violation of the legislation and cannot be used for purposes other than processing.
Except for Migros instructions and exceptions made by law, records and commitments are added to the contracts and documents between Migros and its employees, which impose an obligation not to process, disclose or use personal data.
Necessary administrative measures are taken to monitor the compliance of the employees with the obligation not to process, disclose and use personal data and to ensure the continuity of the application.
In case of receiving technical services from third parties regarding the storage of personal data and persons to whom personal data is transferred by Migros in accordance with the law; Provisions are added regarding the prevention of unlawful processing of personal data, the prevention of illegal access to data, and the provision of necessary measures to ensure that the data is kept in accordance with the law, and that these measures will be complied with in its own organizations.
Migros provides trainings and seminars for its business partners to prevent unlawful processing of personal data, prevent unlawful access to data, and ensure data protection.
On the other hand, the main methods of administrative measures to be taken by data controllers in order to prevent the illegal processing of personal data and illegal access to personal data by the Personal Data Protection Authority and to ensure the preservation of personal data are listed in the "Personal Data Security Guide (Technical and Administrative Measures)" guide has published.
10.5. Execution of Audit Activities
Migros, in accordance with Article 12 of the PDPL, carries out the necessary audits within its own and its business partners or has it done within the framework of contracts made with third party companies. The results of these audits are reported to the relevant department within the scope of the internal operation of the company and necessary activities are carried out to improve all the measures taken.
10.6. Measures to be Taken in Case of Unlawful Disclosure of Personal Data
In the event that personal data processed in accordance with the PDPL and the relevant legislation are obtained by others illegally, Migros is obliged to do what is stated in accordance with the 5th paragraph of Article 12 of the PDPL; The necessary system has been established in order to ensure that the necessary determination and notification are made. An emergency committee has been assigned and authorized in this regard, and this committee will convene urgently as soon as possible after the occurrence of the incident and will carry out the first response and effectiveness with the decision taken at this meeting. The process will be monitored and managed by this committee, and the necessary precautions and measures will be taken within 72 hours at the latest, and the PDPL will be notified.
Following the notification made to the PDP Board, the PDP Board may announce this situation as specified in the 5th paragraph of the 12th Article of the the PDPL.
11.1. Store, Headquarters Building etc. Registration and Tracking of the Entry and/or Inside
Personal data processing activities are carried out by monitoring with security cameras in stores, buildings and facilities for the purposes of increasing the quality of the service offered by Migros, ensuring its reliability, ensuring the safety of the company, customers and other persons, and protecting the interests of customers regarding the service they receive. The camera monitoring activity carried out by our company is carried out in accordance with the Law on Private Security Services and the relevant legislation. Areas that may result in interference with the privacy of the person exceeding the security objectives (for example, toilets) are not subject to monitoring.
In accordance with Article 10 of the PDPL, the personal data owner is clarified by Migros by publishing the Privacy and Data Security Policy on the website and by posting a notification letter stating that monitoring will be carried out at the entrances of the areas where the monitoring is performed, and the personal data obtained is in the administrative and protected by technical measures.
11.2. Store, Headquarters Building etc. Guest Entry/Exit Tracking
Migros carries out personal data processing activities by obtaining the identity information of the visitors and logging into the Visitor Program in order to monitor visitor entries and exits in Migros buildings and facilities for the purposes specified in this Policy and to ensure security.
11.3. Ensuring Institutional Facility Security and Website Visitors
In order to ensure security by the institution, personal data processing activities are carried out in order to monitor the entrance and exit of guests with security cameras in the buildings and facilities of the institution.
Video recordings of the visitors are taken through the camera monitoring system at the building, facility entrances and inside the facility of the Institution. In addition, the identity information of the visitors is obtained, and they are entered into the Visitor Program and stored.
The institution, within the scope of monitoring activity with security cameras; It aims to increase the quality of the service provided, to ensure its reliability, to ensure the safety of the Institution, customers and other persons, and to protect the interests of the customers regarding the service they receive.
In accordance with Article 12 of the PDPL, the Authority takes necessary technical and administrative measures to ensure the security of personal data obtained as a result of camera monitoring.
Log records regarding internet access are recorded in accordance with the Law No. 5651 and the mandatory provisions of the legislation regulated according to this Law; These records are only processed when requested by authorized public institutions and organizations or for the purpose of fulfilling the relevant legal obligation in the audit processes to be carried out within the Agency.
On the websites owned by Migros; to ensure that the visitors of these sites perform their visits on the sites in accordance with the purposes of their visit; Internet movements within the site are recorded by technical means (such as cookies) in order to show them customized content and to engage in online advertising activities.
Detailed explanations regarding the protection and processing of personal data regarding these activities are included in the texts of the “Migros Website Privacy and Data Security Policy” of the relevant websites.
11.4. Roles and Responsibilities
Although the General Manager is responsible for the implementation of this Policy in the operation, activities and processes of Migros; In the implementation of the regulations, procedures, guidelines, standards and training activities prepared in accordance with this policy, the relevant Deputy General Directorates and Directors department/unit/person will be the source of advice and guidance.
All of our employees, stakeholders, guests, visitors and related third parties across Migros are obliged to cooperate with the Personal Data Protection Committee team in order to prevent legal risks and imminent danger, along with compliance with this policy. All organs and departments of Migros are responsible for overseeing compliance with this policy. In case of non-compliance, the Personal Data Protection Committee must be informed.
12. INTER-COMPANY GOVERNANCE WITHIN THE PROTECTION AND PROCESSING OF PERSONAL DATA
The Personal Data Protection Committee ("Committee") has been established within Migros in order to monitor and manage the actions necessary to comply with the Law No. 6698. The main duties of the Committee are as follows:
1. To prepare the basic policies regarding the protection and processing of personal data and, if necessary, to prepare and submit them to the approval of the senior management,
2. To decide how to implement and control the policies regarding the protection and processing of personal data, and to distribute and coordinate the necessary tasks within the company within this framework.
3. To determine the issues that need to be done in order to ensure compliance with the legislation numbered 6698 and to submit the necessary actions to the approval of the senior management; to monitor and coordinate its implementation,
4. To raise awareness within the Company and before the Company's business partners about the protection and processing of personal data,
5. To determine the risks that may arise in Migros' personal data processing activities and to ensure that the necessary measures are taken; submitting improvement suggestions to the top management for approval,
6. To follow the relevant legislation on the protection of personal data, to update the prepared texts and policies,
7. To design trainings on the protection of personal data and the implementation of policies and to carry out the trainings after obtaining the necessary approvals,
8. Establishing a mechanism to quickly meet the applications of Relevant Persons and deciding on them,
9. Related persons; To coordinate the execution of information and training activities to ensure that they are informed about personal data processing activities and their legal rights,
10. To follow the developments and regulations on the protection of personal data; To advise senior management on what needs to be done in accordance with these developments and regulations,
11. Coordinating the relations with the PDP Board and the PDPInstitution,
12. Fulfilling other duties assigned by the senior management regarding the protection of personal data.
13. To determine the risks that may arise in the personal data processing activities of the Company and to ensure that the necessary measures are taken; presenting improvement suggestions.
This policy is reviewed once a year by the Personal Data Protection Committee and necessary updates are made. After the approval of the senior management, the updated policy is started to be used by informing the relevant persons/parties.
14. FINAL PROVISIONS
This Policy was prepared and approved by the Personal Data Protection Committee and was last updated on 30.11.2021. In case this policy is translated into a language other than Turkish, the Turkish text should always be taken into account in the different expressions between the two policies. This policy cannot be reproduced or distributed without the written permission of Migros Ticaret A.Ş.
Own Brand Products Quality Policy
Quality, Food Safety, Customer Satisfaction, Occupational Health and Safety, Environmental Management Systems Policy
As Migros Ticaret A.Ş.;
In the Turkish Retail Industry, where we lead with our pioneering and innovative practices, it is our indisputable principle to make a difference and provide services that exceed expectations by creating high consumer awareness, and to ensure continuous improvement by adhering to legal legislations and regulations and corporate governance principles.
We aim to provide contemporary, high quality, reliable and affordable service that will improve the quality of life of our customers. The uncompromising basis of our understanding of service is to provide healthy products under healthy conditions to our customers. << /p>
As a company that has succeeded in reflecting our understanding of sustainability to our way of doing business, our sector leadership in sustainable growth, efficiency and profitability is the assurance of our understanding of quality. We adopt a working culture based on being honest with each other as our customers, business partners and employees, providing trust and protecting ethical values.
We record, monitor, report and aim for continuous improvement, with the awareness that all kinds of messages that reach us through our communication channels will advance our service quality. We evaluate the messages in line with the principle of confidentiality. By offering objective and fair solutions to the messages, we improve our way of doing business in line with the suggestions.
We aim to create a safe working environment in order to protect our employees, business partners and customers against workplace health and safety risks. We follow proactive approaches to ensure the continuity of our workplace environment.
We value experience and creativity of our employees. We provide the necessary resources and technology to support their behavioral and professional development, and ensure that they receive training and gain know-how.
We take the responsibility of being sensitive to social and cultural issues and contributing to social values.
In order to leave a healthier and livable environment to future generations; we attach importance to the efficient and economical use of natural resources by keeping our environmental impacts under control. As an environmentally friendly company, we aim to transfer our social
We see the effort that we spend on establishing, maintaining and developing Quality Management Systems as the most important value for carrying Migros Ticaret A.Ş to the future.
Migros Code of Ethics
1.Migros's Responsibilities Towards its Employees
Migros completely fulfills all of its legal obligations towards all of its employees. In situations where the requirements of law are not sufficiently clear, Migros consults those who have specialized knowledge on the matter.
Migros is mindful of the rights of its employees within the framework of its rules of business ethics in situations where the rule of law provides for less.
In all hirings, promotions, and appointments, the only criteria to be taken into account are the qualifications for the position: Migros creates equality of opportunity among its employees.
Migros does not involve itself in the personal affairs or private lives of its employees and holds all of the information it has about its employees in strict confidence.
Migros provides training opportunities for its employees to improve themselves professionally and personally.
In all of its dealings with its employees, Migros does not discriminate in any way on the basis of sex, age, ethnic origin, or creed.
In matters that are related to employees, Migros seeks to include their opinions as much as possible in any decisions that are concerned with the Company's future.
Migros provides healthy and safe working conditions as dictated by the requirements of law and of the Company's business and it seeks to improve them to the best of its ability.
Migros holds in strict confidentiality and does not divulge any private information (such as medical records, shopping habits, economic circumstances etc) about its employees that it may come into possession of in any way whatsoever.
2. The Responsibilities of Employees Towards the Company
Migros employees strictly reject any offers of material or moral benefits from third parties made to influence their conduct of activities falling within the areas of their individual responsibility.
Migros employees inform their immediate superior whenever entering into a one-on-one business relationship with any company in which a close relative works, has a partnership interest, or is the owner and they take action with his knowledge.
Migros employees exhibit maximum attention and care when fulfilling the duties given to them and they make every effort so that the work they do can be of higher quality, faster, and more economical.
Migros employees refrain from any act or behavior that would damage the Company's image and reputation. During working hours they remain within the modes of dress and behavior that have already been established by company management or are generally accepted.
Migros employees are neither indifferent nor unresponsive when confronted by any situation that is contrary to the Company’s interests and they notify the appropriate Company units instead
Migros employees avoid waste and use all of the Company's fixtures, tools, and equipment for the purposes for which they are intended. They do not make use of anything the Company provides them to do their jobs for their own private benefit.
Migros employees do not divulge outside the Company any confidential or private information that they become aware of as a consequence of their position or the work that they do. Without the written approval of the Company's management they do not give interviews or make statements of any kind to any media organization.
3. Migros's Responsibilities Towards Other Companies
Migros complies with the requirements of law in all its activities.
No unjustified gain may be secured from any individual or organization for any reason whatsoever. Migros makes all its goods and services procurement decisions in line with established and publicly disclosed criteria.
It is important for Migros that its business partners refrain from tarnishing the image and reputation of Migros in their own business activities and that they give importance to Migros's proven business values.
Migros checks to ensure that the services it obtains on a continuous basis from other organizations are provided in compliance with the requirements of law and it takes necessary action accordingly.
Migros does not divulge confidential information it receives from a company that serves it to third parties without that company's permission.
4. Migros's Responsibilities Towards the Community
Migros makes every effort to uphold the standards that its customers expect of it.
Migros seeks to fulfill all of its tax and other obligations in full and on time and to be an example to the community on such matters.
Migros does not make humiliating, derisory, or offensive statements concerning other companies, organizations, products, or individuals.
Migros takes care in all its activities to avoid causing harm to the natural and historical legacy and to behave in accordance with customs, mores, and traditions and it complies with all the requirements of law on such matters.
Migros defends its business ethics in its sector and strives for calcification, furtherance, and acceptance of these principles.
5. The Responsibilities of Employees Towards Employees
Migros employees do not divulge private information concerning other company employees that they come into as a consequence of their jobs except where it is a requirement of their jobs.
6. In General
The Migros Committee on Business Ethics set up within the Company is responsible for dealing with and clarifying any issues that are not dealt with by the principles set forth above.
Information Security Policy
Migros Ticaret A.Ş. management;
Undertakes to ensure that the controls geared toward safeguarding the confidentiality, integrity and accessibility of information systems and the data found on such information systems for the purpose of processing, transmission and storage are developed, operated and up to date and to delineate the required managerial responsibilities in order to make sure that the security risks arising from information systems are being managed sufficiently.
Within the scope of information security controls, for each control process; clearly shall define process owners, their roles, activities and responsibilities, and periodically reviews these powers, roles and responsibilities.
Undertakes to provide the resources and environment necessary to produce the targeted goals in relation to information security controls. Shall implement regular controls in order to determine whether the targeted goals have been achieved and for continual improvement.
Establishes information security policies related to the management of information systems, reviews them at least once a year and ensures them to be up-to-date in line with the changes or technological developments in this particular field of business and notifies them to all relevant stakeholders.
Shall continually monitor and evaluate the effectiveness, adequacy and suitability of information security controls as well as the anticipated risks and the activities aimed at mitigating the effects of such risks. Shall repeat risk analysis related to information systems at least once a year or in case of significant changes in information systems. Shall ensure that major deficiencies in controls as may have been identified as a result of the evaluation are reported to the senior management and that the necessary measures are implemented.
Shall prepare business continuity plans to ensure continuity of all critical business processes according to risk priorities. Determines acceptable downtime and maximum acceptable data loss for critical business processes in business continuity plans.
Is aware of the importance of the human factor in the approach to information security. As a result, it shall support the provision of the training necessary to ensure that employees’ awareness of information security is cultivated and technical competence is achieved. Shall implement the activities necessary to ensure that all personnel are aware of Migros Ticaret A.Ş. Information Security Policy and act in accordance therewith. Shall ensure that the disciplinary process will become applicable in the event of risks intentionally created by people despite such efforts to raise awareness on information security.
The Information Security Manager is responsible for updating and providing the security of the Information Security Policy, defining roles related to the information security process, and preparing and publishing of sub-procedures related to this policy. Within this context, Migros Ticaret A.Ş. is obligated to:
- Ensure the confidentiality, integrity and accessibility of information assets; take the appropriate physical and logical security measures suitable for the value of the information in its possession;
- Assign access rights and prevent unauthorized access in line with the “need to know” principle in order to control access to the information;
- Identify risks at certain time intervals and manage the risks by taking the actions necessary in order to protect the information and information assets;
- Ensure the confidentiality and integrity of Migros employees and customer information; within this context to implement the necessary measures with the Law no 6698 on the Protection of Personal Data as its basis;
- Arrange training seminars to increase the information security awareness primarily of its employees and all other critical stakeholders with the knowledge that humans are the most important factor in ensuring information security and to follow up on the results thereof;
- Provide the necessary infrastructure for guaranteeing the continuity of its services;
- Prepare business continuity plans to prevent the interruption of its activities and responsibilities toward its stakeholders in the event of any negative instances and to test such plans;
- Develop an intervention process for any information security breach incidents in order to manage and prevent the recurrence of information security gaps and breach incidents;
- Keep security needs in mind when developing software;
- Take precautions to protect information assets against harmful codes such as viruses and cyberattacks from outside of the Company;
- Ensuring that penetration testing is carried out by real persons or legal entities having national or international competence on penetration testing in order to obtain timely information on technical openings of information systems and to determine the vulnerability of the institution against such openings;
- Adhere to all domestic and/or international statuary legislation and agreements in support of information security controls.
The Company Information Security Policy is applicable to and mandatory for all personnel who use Company information or business systems regardless of whether they are full time or part time employees, on the payroll or on contract and independent of geographic location or business department. It is essential that third person service providers who do not fall within this classification and persons affiliated therewith such as their support personnel comply with and remain bound by the general principles of this policy and other security obligations and liabilities with which they are required to comply.
Migros Ticaret A.Ş. last modified date: 18.06.2021
WORKPLACE POLICY ON DOMESTIC VIOLENCE AND ABUSE
In parallel with the Human Rights and Equal Opportunity Policy, Migros adopts policies based on gender and equal opportunity in recruitment, contribution to personal and professional development, performance, remuneration,
career development, training and leave. We do not discriminate against gender in any way. As part of our understanding of contributing to society, which is one of the most important indicators of our people-oriented approach, we
implement projects that support gender equality.
The purpose of the domestic violence policy is to raise awareness about domestic violence among all our employees, to create a work environment that does not tolerate any form of violence, and to enable employees who are exposed to violence to recognize this situation and take the necessary steps. Violence is a violation of human rights. Violence affects a worker's ability to work, creating both economic and attendance problems.
Domestic Violence:It is the physical, sexual, psychological, economic or cyber dominance of individuals living in the same household against another member or former member, and the use of coercive behavior to gain power and control.
Physical Violence:Violence is the perpetrator's attempt to control the victim through aggressive behavior. Physical violence includes, but is not limited to, hitting, pushing, slapping, punching, threatening with cutting, piercing or burning instruments, wounding, causing injury or death to the victim by throwing an object.
Sexual Violence:This includes, but is not limited to, unwanted sexual attention and forced sexual contact, including rape. Sexual harassment, threats and insults also constitute sexual violence. This behavior is also considered sexual violence when done verbally, in writing or through cyberspace.
Psychological Violence:This includes, but is not limited to, emotional violence by controlling, limiting, humiliating, insulting or threatening a person in order to establish control.
Economic Violence:This includes, but is not limited to, systematic pressure on another person in their economic decisions, limiting their freedom of movement, controlling their income, taking away their income, damaging their property and confiscating their assets.
Cyber Violence:This includes, but is not limited to, control, surveillance and threats via e-mail, text messages, phone messages, social media accounts.
Migros provides training to its employees to prevent domestic violence, provides information to victims of domestic violence, and, upon request, referres to experts in the field through a consultancy firm with which Migros has an agreement. As a result of domestic violence, the victim may chronically be absent, be late, and have poor work-related performance. Migros takes approaches to solve the problem, protects the rights of the victimized employee, protects their privacy, ensures that they are supported through the psychological support lines of the Consultancy Firm with which it has an agreement, and informs them about methods of application to official institutions and non-governmental organizations in order to ensure their safety.
Migros conducts a series of surveys (in the field and among headquarter staff, and management) to measure employee perception of violence and awareness of what to do in the event of violence and analyze the results to develop new action programs to prevent violence.
FORMULATING AND IMPLEMENTING TRAINING PROGRAMS
Migros determines needs of training following surveys, raises awareness on violence among all employees, and provides training to managers on how to approach employees who are subjected to violence and what procedures they should follow. In addition, in order to ensure that the concept of Gender Equality, which is an important step in preventing violence and raising awareness, is adopted by all employees, the Company provides the "Equality Is Worth It" training program to all current and new employees.
CONFIDENTIALITY AND PRIVACY OF PRIVATE LIFE
We recognize that it can be difficult for survivors of violence to prove the violence they were subjected to and take steps to address it. For this reason, we take the statement of the person who has been subjected to violence
or who testifies as a basis. However, when support is requested, we can request proof of our involvement with the judicial authorities. We keep the information that the employees who are subjected to abuse share with our
Company, confidential. This situation does not in any way hinder the victim's personal and professional development, performance, remuneration and career development at work. Sharing this situation with the psychological support
lines of the Counseling Firm will provide an opportunity to help the victim. Migros therefore advises these individuals not to remain silent about the violence they experience.
In this process, Migros attaches great importance to the protection of your personal data and for it not to be used by unauthorized persons, and we would also like to state that we take extremely sensitive measures for the security of the data we process, together with the technical and administrative measures determined in accordance with the Personal Data Protection Authority and the relevant legislation regarding your personal data. Migros Ticaret A.S. Click here for the Clarification Text on the Protection and Processing of Personal Data on Domestic and Abusive Workplace Violence Policy.
If the employee is abused, they can apply to the online consultancy line of the Consultancy Firm contracted by our Company at 0212 8009030.
In addition to the psychological counseling and guidance and legal information service that the employee who has been subjected to domestic violence may receive from the counseling company, the employee may submit requests such as; a change in salary account / granting an advance / administrative leave as specified in this policy, to the Committee established at Migros via e-mail. The Committee consists of (Regional Manager, Store Manager, Industrial Relations Officer, Store Human Resources Officer, Headquarter Staff Human Resources Officer, Legal Officer, Corporate Communications Officer. (The e-mail address of the Committee is: email@example.com.) If necessary and mandatory, the Committee may inform the relevant Regional Human Resources Officer, Regional Manager and/or Store Manager for whom the person is responsible. The relevant Human Resources officer in the committee will be in contact with the employee to ensure that further processes are carried out. Progress is made by obtaining the employee's consent for each process.
IF THE PERSON SUBJECTED TO DOMESTIC VIOLENCE IS NOT AN EMPLOYEE OF THE COMPANY
In the event that the person subjected to violence outside the company applies to the online counseling line, it is stated that this line is only for Migros employees within the scope of the service received from the counseling company. The process will not continue.
EMPLOYEE SUBJECTED TO DOMESTIC VIOLENCE
Migros provides support to its employees who declare that they have been subjected to domestic violence in the following areas
1. Within the scope of the service received from the Counseling Company "Avita", 24/7 psychological counseling and support is provided by Avita via Avita's phone number 0212 8009030.
2. Within the scope of the service received from the Consultancy Firm "Avita", 24/7 legal support is provided by Avita via Avita's phone number 0212 8009030.
3. Deposit their salary into a new salary account in their name.
4. Provided the person proves that a legal action has been taken, an advance of up to 1 gross monthly salary for unforeseen expenses that the employee may need in the current situation will be provided once a year and to be collected within 6 months.
5. Paid administrative leave up to a maximum of 10 days per year for the purpose of safety, protection, finding a new home, counseling and health services, provided the person proves that a legal action has been taken. This leave is valid for one calendar year, from January 1 to December 31. Leave can be taken on a single day or multiple days on an hourly basis.
However, it should be noted that in the event that there is conclusive evidence that the person applying for internal support mechanisms has deliberately lied or made false statements, an internal audit and disciplinary process may be initiated for assessment.
INSTITUTIONS YOU CAN APPLY TO WHEN YOU WITNESS VIOLENCE
- Police Help 155
- Gendarmerie 156
- Emergency 112
- Alo 183 Family, Women, Children and Disabled Social Service Hotline
- Alo Bar 4442618
Public and Non-Governmental Organizations for Support
- Turkish Federation of Women's Associations Domestic Violence Emergency Hotline: 0212 6569696 / 0549 6569696
- Mor Çatı Women's Shelter Foundation: 0212 2925231-32
- Civil Society Organizations
- Municipal Women's Solidarity Centers
Complaint and Notice
- Governorships / District Governorships
- Police Stations
- Gendarmerie Stations
- Judicial Authorities (Public Prosecutor's Office and Family Courts)
- Provincial Directorates of Family Labor and Social Services
- Violence Prevention and Monitoring Centers (ŞÖNİM)
- Health Organizations
*Migros reserves the right to change, replace or withdraw this policy at any time without prior notice.