Legal Information and Policies

FlavourTech is committed to conducting business with the highest standards of legal compliance and ethical behavior across all our operations. This commitment extends to our activities in Turkey, Tunisia, United Arab Emirates, the European Union, and all other markets we serve.

Regulatory Compliance

We adhere to all applicable laws, regulations, and industry standards in the jurisdictions where we operate, including but not limited to:

• Food safety and quality regulations
• Environmental protection laws
• Labor and employment laws
• Trade regulations and export controls
• Anti-corruption and anti-bribery laws
• Competition and antitrust laws
• Intellectual property rights

Ethical Business Practices

Our commitment to ethical business practices includes:

• Maintaining transparency in all business dealings
• Avoiding conflicts of interest
• Respecting human rights throughout our operations and supply chain
• Promoting fair labor practices and safe working conditions
• Implementing sustainable and environmentally responsible practices
• Engaging in fair competition and ethical marketing
• Protecting confidential information and intellectual property

Corporate Governance

Our corporate governance framework ensures accountability, fairness, and transparency in our operations. Key elements include:

• A clear organizational structure with defined roles and responsibilities
• Regular internal audits and compliance monitoring
• Comprehensive risk management processes
• Ongoing training and awareness programs for employees
• Whistleblower protection and reporting mechanisms

Stakeholder Engagement

We engage with our stakeholders—including customers, suppliers, employees, communities, and regulatory authorities—in an open, honest, and respectful manner. We value their input and consider their interests in our decision-making processes.

Commitment to Continuous Improvement

We continuously review and enhance our legal and ethical practices to ensure they remain effective and aligned with evolving standards and expectations. This includes regular assessments of our policies, procedures, and performance.

These Terms of Use govern your access to and use of the FlavourTech website (https://flavour.tech ) and related services. By accessing or using our website, you agree to be bound by these terms.

Acceptance of Terms

By accessing or using our website, you acknowledge that you have read, understood, and agree to be bound by these Terms of Use, as well as our Privacy Policy and any other applicable policies referenced herein.

Intended Use and Users

Our website and services are intended for business-to-business (B2B) purposes and are directed at business entities and professionals in the food industry. By using our website, you represent and warrant that you are accessing it in your capacity as a business professional or on behalf of a business entity.

Intellectual Property Rights

All content on our website—including but not limited to text, graphics, logos, images, audio clips, digital downloads, data compilations, software, and the compilation of all content—is the property of FlavourTech or our content suppliers and is protected by international copyright, trademark, and other intellectual property laws.

You may not reproduce, distribute, modify, create derivative works from, publicly display, publicly perform, republish, download, store, or transmit any material from our website without our prior written consent, except for:

• Temporarily storing copies of materials in RAM incidental to your accessing and viewing those materials
• Storing files that are automatically cached by your web browser for display enhancement purposes
• Printing or downloading one copy of a reasonable number of pages of the website for your own personal, non-commercial use and not for further reproduction, publication, or distribution

Prohibited Uses

You agree not to use our website:

• In any way that violates applicable laws or regulations
• To transmit or procure the sending of any advertising or promotional material without our prior consent
• To impersonate or attempt to impersonate FlavourTech, a FlavourTech employee, or any other person or entity
• To engage in any conduct that restricts or inhibits anyone’s use or enjoyment of the website
• To attempt to gain unauthorized access to, interfere with, damage, or disrupt any parts of the website, the server on which the website is stored, or any server, computer, or database connected to the website
• To attack the website via a denial-of-service attack or a distributed denial-of-service attack
• To use any robot, spider, or other automatic device, process, or means to access the website for any purpose

User Contributions

Any content you submit to our website (including through contact forms, feedback mechanisms, or other interactive features) must comply with these Terms of Use and applicable laws. You retain ownership of your contributions but grant us a perpetual, worldwide, non-exclusive, royalty-free license to use, reproduce, modify, publish, and distribute such content in connection with our business operations.

Links to Third-Party Websites

Our website may contain links to third-party websites that are not owned or controlled by FlavourTech. We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third-party websites. We strongly advise you to read the terms and privacy policy of any website you visit.

Disclaimer of Warranties

Our website and its content are provided on an “as is” and “as available” basis, without any warranties of any kind, either express or implied. We disclaim all warranties, including but not limited to implied warranties of merchantability, fitness for a particular purpose, and non-infringement.

Limitation of Liability

To the fullest extent permitted by law, FlavourTech shall not be liable for any direct, indirect, incidental, special, consequential, or punitive damages arising out of or in connection with your use of, or inability to use, our website or any content obtained from our website.

Indemnification

You agree to indemnify, defend, and hold harmless FlavourTech and its officers, directors, employees, agents, and affiliates from and against any claims, liabilities, damages, judgments, awards, losses, costs, expenses, or fees (including reasonable attorneys’ fees) arising out of or relating to your violation of these Terms of Use or your use of the website.

Governing Law and Jurisdiction

These Terms of Use shall be governed by and construed in accordance with the laws of Turkey, without regard to its conflict of law provisions. Any legal action or proceeding arising out of or related to these terms or the website shall be instituted exclusively in the courts of Turkey, although we retain the right to bring any suit, action, or proceeding against you for breach of these Terms of Use in your country of residence or any other relevant country.

Changes to Terms of Use

We may revise these Terms of Use at any time by updating this page. Your continued use of the website following the posting of revised Terms of Use means that you accept and agree to the changes.

These Delivery and Payment Terms apply to all business-to-business (B2B) transactions between FlavourTech and its customers. By placing an order with us, you agree to these terms.

Order Process

Orders may be placed through the following channels:

• Direct communication with our sales representatives
• Email to [email protected]
• Through our B2B ordering portal (where available)
• Written purchase orders submitted via established channels

All orders are subject to acceptance by FlavourTech. We reserve the right to refuse any order for any reason, including but not limited to product availability, errors in pricing or product information, or concerns about fraudulent activity.

Pricing and Quotations

Prices for our products and services are as follows:

• All prices are quoted exclusive of applicable taxes, duties, and shipping costs unless explicitly stated otherwise
• Quotations are valid for 30 days from the date of issue unless otherwise specified
• For long-term contracts, we may apply price adjustment mechanisms based on raw material costs, inflation, or other relevant factors
• Volume discounts may be available based on order quantity and frequency

Payment Terms

Our standard payment terms are as follows:

• New customers: Payment in advance for initial orders
• Established customers: Net 30 days from the date of invoice, subject to credit approval
• Accepted payment methods include bank transfer, letter of credit, and other approved methods
• All payments must be made in the currency specified on the invoice
• Late payments may incur interest charges at the rate of 2% per month or the maximum rate permitted by applicable law

Delivery Terms

Our delivery terms are as follows:

• Standard delivery terms are Ex Works (EXW) or Free Carrier (FCA) from our manufacturing facilities, as specified in the order confirmation
• Other Incoterms may be available upon request and agreement
• Delivery timeframes are estimates only and may vary based on product availability, production schedules, and shipping conditions
• Risk of loss or damage passes to the customer according to the agreed Incoterms
• Partial deliveries may be made and invoiced separately

International Shipping

For international shipments:

• The customer is responsible for obtaining all necessary import licenses and permits
• The customer is responsible for paying all import duties, taxes, and customs clearance fees
• FlavourTech will provide standard export documentation as required
• Additional documentation may be provided upon request, subject to additional fees

Inspection and Acceptance

Customers must inspect all products upon delivery and notify FlavourTech of any visible defects, shortages, or non-conformities within 5 business days of receipt. Products not rejected within this timeframe will be deemed accepted.

Returns and Refunds

Our return and refund policy for B2B transactions is as follows:

• Returns must be authorized in advance by FlavourTech
• Products must be returned in their original condition and packaging
• Custom or specially manufactured products are not eligible for return unless defective
• Approved returns may be subject to a restocking fee of up to 20%
• Refunds will be issued using the original payment method, where possible

Force Majeure

FlavourTech shall not be liable for any delay or failure to perform due to circumstances beyond our reasonable control, including but not limited to natural disasters, pandemics, strikes, transportation disruptions, raw material shortages, or government actions.

Governing Law

These Delivery and Payment Terms shall be governed by the laws of Turkey, without regard to its conflict of law provisions. The United Nations Convention on Contracts for the International Sale of Goods shall not apply to transactions between FlavourTech and its customers.

Quality Commitment

At FlavourTech, quality is the foundation of everything we do. Our commitment to quality encompasses:

• Strict adherence to international food safety and quality standards
• Comprehensive quality management systems certified to ISO 9001
• Rigorous testing and quality control throughout our production processes
• Continuous improvement of our products, processes, and systems
• Regular training and development of our team members
• Careful selection and monitoring of suppliers and raw materials

We maintain certifications to key industry standards, including BRC Global Standard for Food Safety and International Featured Standards (IFS), demonstrating our commitment to the highest levels of food safety and quality.

Sustainability Practices

We recognize our responsibility to operate in an environmentally sustainable manner. Our sustainability initiatives include:

• Reducing our carbon footprint through energy efficiency measures
• Minimizing waste generation and maximizing recycling and reuse
• Conserving water resources through efficient usage and treatment
• Sourcing raw materials responsibly with consideration for environmental impact
• Developing eco-friendly packaging solutions
• Complying with all applicable environmental regulations
• Setting measurable sustainability targets and monitoring progress

We are committed to transparent reporting of our environmental performance and continuously improving our sustainability practices.

Ethical Business Conduct

We conduct our business with the highest ethical standards, including:

• Fair and honest dealings with customers, suppliers, and competitors
• Zero tolerance for corruption, bribery, or other unethical practices
• Respect for human rights throughout our operations and supply chain
• Fair labor practices and safe working conditions for all employees
• Promotion of diversity, equity, and inclusion in our workforce
• Responsible marketing and transparent communication
• Protection of confidential information and intellectual property

Supply Chain Responsibility

We extend our quality, sustainability, and ethical standards throughout our supply chain by:

• Carefully selecting suppliers based on quality, sustainability, and ethical criteria
• Conducting regular supplier audits and assessments
• Collaborating with suppliers on continuous improvement initiatives
• Promoting transparency and traceability throughout the supply chain
• Addressing social and environmental risks in our sourcing practices

Stakeholder Engagement

We engage with our stakeholders to understand their expectations and concerns regarding quality, sustainability, and ethics. This engagement informs our policies, practices, and improvement initiatives.

Governance and Implementation

This policy is implemented through:

• Clear roles and responsibilities at all levels of the organization
• Documented procedures and work instructions
• Regular training and awareness programs
• Internal and external audits and assessments
• Management review and continuous improvement processes

Our executive leadership team is ultimately responsible for ensuring adherence to this policy, with oversight from our Board of Directors.

Corporate Governance

FlavourTech maintains a robust corporate governance framework that ensures accountability, transparency, and ethical conduct throughout our organization. Our governance structure includes:

• A Board of Directors with diverse expertise and perspectives
• Clear delegation of authority and decision-making processes
• Comprehensive risk management and internal control systems
• Regular reporting and disclosure practices
• Compliance with applicable corporate governance regulations in all jurisdictions where we operate

Health and Safety Policy

The health and safety of our employees, contractors, visitors, and communities is a top priority. Our commitment to health and safety includes:

• Compliance with all applicable health and safety laws and regulations
• Implementation of comprehensive health and safety management systems
• Regular risk assessments and hazard identification
• Provision of necessary training, equipment, and resources
• Promotion of a safety-first culture throughout the organization
• Regular monitoring, reporting, and continuous improvement of safety performance

Environmental Policy

We are committed to minimizing the environmental impact of our operations. Our environmental policy includes:

• Compliance with all applicable environmental laws and regulations
• Prevention of pollution and conservation of natural resources
• Reduction of waste, emissions, and energy consumption
• Environmentally responsible product design and development
• Regular environmental performance monitoring and reporting
• Engagement with stakeholders on environmental issues

Human Resources Policy

Our human resources policy is designed to attract, develop, and retain talented individuals while fostering a positive and inclusive work environment. Key elements include:

• Fair and transparent recruitment and selection processes
• Competitive compensation and benefits packages
• Ongoing training and professional development opportunities
• Regular performance feedback and career planning
• Promotion of diversity, equity, and inclusion
• Work-life balance initiatives and employee wellbeing programs
• Open communication and employee engagement

Information Security Policy

We are committed to protecting the confidentiality, integrity, and availability of our information assets. Our information security policy includes:

• Comprehensive information security management systems
• Protection of sensitive business and personal data
• Secure IT infrastructure and applications
• Employee awareness and training on information security
• Incident response and business continuity planning
• Regular security assessments and audits
• Compliance with relevant data protection and privacy regulations

Communication Policy

Our communication policy ensures consistent, accurate, and appropriate communication with all stakeholders. Key principles include:

• Transparent and timely disclosure of material information
• Clear designation of authorized spokespersons
• Responsible use of social media and digital platforms
• Protection of confidential and proprietary information
• Respectful and professional communication at all times
• Compliance with applicable marketing and advertising regulations

Intellectual Property Policy

We value and protect our intellectual property assets, which are crucial to our competitive advantage. Our intellectual property policy includes:

• Protection of patents, trademarks, copyrights, and trade secrets
• Clear ownership and assignment provisions for employee-created IP
• Respect for the intellectual property rights of others
• Appropriate confidentiality and non-disclosure agreements
• Regular IP portfolio review and management

Policy Implementation and Compliance

All FlavourTech policies are implemented through:

• Clear communication to all employees and relevant stakeholders
• Integration into business processes and decision-making
• Regular training and awareness programs
• Monitoring and auditing for compliance
• Periodic review and updating to ensure continued relevance and effectiveness

Employees are expected to comply with all company policies. Violations may result in disciplinary action, up to and including termination of employment.

Introduction

This statement is made pursuant to applicable modern slavery legislation, including but not limited to the UK Modern Slavery Act 2015, and sets out FlavourTech’s commitment to preventing slavery, servitude, forced or compulsory labor, and human trafficking in our business operations and supply chains.

Our Commitment

FlavourTech has a zero-tolerance approach to all forms of modern slavery and human trafficking. We are committed to acting ethically and with integrity in all our business dealings and relationships, and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

Our Business and Supply Chains

FlavourTech operates in the food technology sector with operations in Turkey, Tunisia, United Arab Emirates, and the European Union. Our supply chains include the sourcing of raw materials, packaging, equipment, and various services to support our business operations.

Risk Assessment and Due Diligence

We have conducted a risk assessment of our business operations and supply chains to identify areas with higher potential exposure to modern slavery risks. Based on this assessment, we have implemented a due diligence process that includes:

• Supplier pre-qualification and risk assessment
• Contractual provisions requiring compliance with anti-slavery laws
• Regular supplier audits and assessments
• Supply chain mapping for high-risk categories
• Collaboration with industry initiatives addressing modern slavery risks

Policies and Procedures

We have implemented the following policies and procedures to support our anti-slavery commitment:

• Supplier Code of Conduct, which explicitly prohibits the use of forced, bonded, or involuntary labor
• Whistleblowing Policy, which encourages reporting of concerns and protects whistleblowers
• Recruitment Policy, which includes verification of eligibility to work and voluntary acceptance of employment terms
• Procurement Policy, which incorporates modern slavery considerations into purchasing decisions

Training and Awareness

We provide training to key staff on modern slavery risks and our policies and procedures for preventing modern slavery in our business and supply chains. This training includes:

• Awareness of different forms of modern slavery
• Identification of red flags and risk indicators
• Reporting procedures for suspected cases
• Due diligence requirements for suppliers

Performance Indicators

We monitor the effectiveness of our anti-slavery measures through various performance indicators, including:

• Number of staff trained on modern slavery risks
• Number of suppliers assessed for modern slavery risks
• Number of reported concerns and remedial actions taken
• Completion of supply chain mapping for high-risk categories

Continuous Improvement

We recognize that addressing modern slavery risks requires ongoing vigilance and improvement. We are committed to:

• Regularly reviewing and updating our policies and procedures
• Enhancing our due diligence processes
• Expanding training and awareness programs
• Collaborating with industry partners and stakeholders
• Increasing transparency in our supply chains

Reporting Concerns

We encourage anyone with concerns about modern slavery in our business or supply chains to report them through our whistleblowing channels or by contacting our compliance team at [email protected].

Board Approval

This statement has been approved by the Board of Directors of FlavourTech, who will review and update it annually.

Our Commitment to Food Safety Standards

FlavourTech is committed to maintaining the highest standards of food safety and quality. We have achieved and maintain certification to both the British Retail Consortium (BRC) Global Standard for Food Safety and the International Featured Standards (IFS) Food, which are internationally recognized benchmarks for best practices in food safety, quality, and operational criteria.

BRC Global Standard for Food Safety

Our compliance with the BRC Global Standard demonstrates our commitment to:

• Senior management commitment and continuous improvement
• Comprehensive food safety plans based on HACCP principles
• Robust food safety and quality management systems
• High standards for factory environment, product control, process control, and personnel
• Effective management of food defense and food fraud vulnerabilities

Our facilities have achieved BRC certification at Grade A level, reflecting our dedication to maintaining exceptional standards in food safety management.

International Featured Standards (IFS) Food

Our compliance with IFS Food demonstrates our commitment to:

• Senior management responsibility for food safety and quality
• Quality and food safety management systems
• Resource management and staff training
• Planning and production processes
• Measurements, analyses, and improvements
• Food defense and external inspections

Our facilities have achieved IFS certification at Higher Level, reflecting our dedication to exceeding the fundamental requirements of the standard.

Implementation and Maintenance

To maintain our BRC and IFS certifications, we have implemented:

• Comprehensive documented food safety and quality management systems
• Hazard Analysis and Critical Control Points (HACCP) plans for all products
• Rigorous prerequisite programs covering all aspects of food safety
• Extensive training programs for all staff
• Regular internal audits and management reviews
• Annual third-party certification audits
• Continuous improvement processes

Key Food Safety Controls

Our food safety controls include:

• Supplier approval and monitoring program
• Raw material specifications and controls
• Allergen management procedures
• Foreign body detection and prevention systems
• Cleaning and sanitation programs
• Environmental monitoring
• Product testing and analysis
• Traceability systems and recall procedures
• Food defense and food fraud mitigation measures

Benefits to Our Customers

Our BRC and IFS certifications provide our customers with assurance of:

• Consistent production of safe, legal products of the specified quality
• Compliance with regulatory requirements
• Commitment to transparency and continuous improvement
• Reduced need for customer audits and inspections
• Confidence in our food safety and quality management capabilities

Verification and Transparency

Our current BRC and IFS certificates are available upon request. We are committed to transparency regarding our food safety performance and welcome customer inquiries about our certification status and food safety programs.

Our Commitment to Ethical Trade

FlavourTech is a member of Sedex (Supplier Ethical Data Exchange), a global membership organization dedicated to driving improvements in ethical and responsible business practices in global supply chains. Our Sedex membership demonstrates our commitment to transparency and continuous improvement in our labor practices, health and safety, environmental management, and business ethics.

Sedex Members Ethical Trade Audit (SMETA)

Our facilities undergo regular SMETA audits, which assess our compliance with the Ethical Trading Initiative (ETI) Base Code and local laws. These audits cover four key pillars:

1. Labor Standards

We are committed to upholding the highest labor standards, including:

• Freedom of association and the right to collective bargaining
• No forced or bonded labor
• Safe and hygienic working conditions
• No child labor
• Payment of living wages
• Reasonable working hours
• No discrimination
• Regular employment provided
• No harsh or inhumane treatment

2. Health and Safety

We maintain comprehensive health and safety programs that include:

• Risk assessment and hazard management
• Safe working environments, systems, and equipment
• Emergency preparedness and response
• Occupational health services and monitoring
• Employee training and awareness
• Adequate welfare facilities

3. Environmental Management

Our environmental management practices include:

• Compliance with environmental regulations
• Resource conservation and waste reduction
• Energy efficiency and emissions reduction
• Water management
• Responsible chemical management
• Environmental impact assessment and mitigation

4. Business Ethics

We conduct our business with the highest ethical standards, including:

• Anti-bribery and anti-corruption measures
• Transparent business practices
• Protection of intellectual property rights
• Responsible information management
• Fair competition
• Whistleblower protection

Implementation and Continuous Improvement

To maintain our Sedex compliance, we have implemented:

• Comprehensive policies and procedures covering all four SMETA pillars
• Regular internal assessments and audits
• Corrective action processes for addressing non-conformities
• Training programs for management and employees
• Engagement with workers and their representatives
• Performance monitoring and reporting

Supply Chain Management

We extend our ethical trade commitments to our supply chain by:

• Encouraging our suppliers to join Sedex
• Including ethical trade requirements in supplier contracts
• Conducting risk assessments of our supply chain
• Collaborating with suppliers on improvement initiatives
• Monitoring supplier performance on ethical trade issues

Benefits to Our Stakeholders

Our Sedex membership and SMETA compliance provide our stakeholders with:

• Assurance of ethical business practices
• Transparency regarding our social and environmental performance
• Reduced supply chain risks
• Evidence of our commitment to responsible business conduct
• Alignment with international ethical trade standards

Verification and Transparency

Our Sedex membership and SMETA audit reports are available to Sedex members through the Sedex platform. We are committed to transparency regarding our ethical trade performance and welcome stakeholder inquiries about our Sedex compliance.

Our Commitment to Supply Chain Security

FlavourTech is committed to maintaining the highest standards of supply chain security. We have achieved and maintain Global Security Verification (GSV) certification, which demonstrates our compliance with international supply chain security standards and best practices.

Global Security Verification Program

The GSV program assesses our security practices across multiple categories, including:

• Business partner security
• Manufacturing facility security
• Personnel security
• Information technology security
• Transportation security
• Storage and distribution security
• Shipment information security
• Raw material and packaging security

Our facilities have achieved GSV certification, reflecting our dedication to maintaining robust supply chain security measures.

Key Security Measures

To maintain our GSV certification, we have implemented comprehensive security measures, including:

Physical Security

• Perimeter security with appropriate fencing, gates, and barriers
• Access control systems for employees, visitors, and vehicles
• CCTV surveillance of critical areas
• Adequate lighting of facilities, parking areas, and shipping/receiving areas
• Alarm systems and security monitoring

Personnel Security

• Pre-employment screening and background checks
• Security awareness training for all employees
• Secure employee identification systems
• Procedures for removing access for terminated employees
• Visitor management procedures

Procedural Security

• Documented security procedures and policies
• Cargo handling and storage procedures
• Shipping and receiving procedures
• Seal control procedures
• Documentation processing procedures
• Anomaly reporting and investigation procedures

Information Technology Security

• Password policies and access controls
• Data backup and recovery procedures
• Network security measures
• Protection against malware and unauthorized access
• Information security training for employees

Business Partner Security

• Supplier security assessment and verification
• Security requirements in supplier contracts
• Monitoring of supplier security compliance
• Collaboration with logistics providers on security measures

Implementation and Maintenance

To maintain our GSV certification, we have implemented:

• Comprehensive security management system
• Regular security risk assessments
• Internal security audits and inspections
• Security incident reporting and investigation procedures
• Continuous improvement processes
• Regular training and awareness programs
• Annual third-party certification audits

Benefits to Our Customers

Our GSV certification provides our customers with:

• Assurance of secure supply chain practices
• Reduced risk of cargo theft, tampering, or contamination
• Compliance with international security standards
• Potential for expedited customs processing
• Confidence in our commitment to supply chain security

Verification and Transparency

Our current GSV certificate is available upon request. We are committed to transparency regarding our security practices and welcome customer inquiries about our certification status and security programs.

Our Commitment to Resilience

FlavourTech is committed to maintaining robust Business Continuity Management (BCM) systems to ensure the resilience of our operations and our ability to continue serving our customers during and after disruptive incidents. Our BCM program is designed to identify potential threats to our organization and the impacts those threats might have on business operations, and to provide a framework for building organizational resilience with the capability for an effective response.

BCM Framework

Our BCM framework is aligned with international standards, including ISO 22301 (Business Continuity Management Systems), and encompasses:

• Business Continuity Policy and governance structure
• Business Impact Analysis (BIA) and Risk Assessment
• Business Continuity Strategy
• Business Continuity Plans
• Incident Response Procedures
• Testing and Exercises
• Review and Continuous Improvement

Key BCM Elements

Business Impact Analysis

We conduct regular Business Impact Analyses to:

• Identify critical business functions and processes
• Determine recovery time objectives (RTOs) and recovery point objectives (RPOs)
• Assess the potential impacts of disruptions
• Identify resource requirements for business continuity

Risk Assessment

Our risk assessment process identifies:

• Potential threats and hazards to our operations
• Vulnerabilities in our processes, systems, and infrastructure
• Likelihood and potential impact of various scenarios
• Risk mitigation measures

Business Continuity Strategy

Our business continuity strategy includes:

• Alternative production arrangements
• Supply chain resilience measures
• IT disaster recovery capabilities
• Workforce continuity planning
• Crisis management and communication procedures

Business Continuity Plans

We maintain detailed business continuity plans for:

• Production and manufacturing operations
• Supply chain and logistics
• Information technology systems
• Facilities and infrastructure
• Key business functions

Testing and Exercises

We regularly test our business continuity capabilities through:

• Desktop exercises and simulations
• Technical recovery tests
• Full-scale business continuity exercises
• Post-exercise reviews and improvement actions

Implementation and Governance

Our BCM program is implemented and governed through:

• Executive leadership commitment and oversight
• Dedicated BCM team with clear roles and responsibilities
• Integration with other management systems
• Regular review and updating of BCM documentation
• Employee awareness and training programs
• Performance measurement and continuous improvement

Benefits to Our Customers

Our robust BCM program provides our customers with:

• Assurance of our ability to maintain supply during disruptions
• Reduced risk of service interruptions
• Transparent communication during incidents
• Confidence in our organizational resilience
• Compliance with customer business continuity requirements

Continuous Improvement

We are committed to continuously improving our BCM capabilities through:

• Regular reviews of our BCM program
• Learning from incidents and exercises
• Benchmarking against industry best practices
• Adapting to changing business needs and risk landscapes
• Incorporating feedback from stakeholders

Our Commitment

FlavourTech is committed to conducting business ethically and in compliance with all applicable anti-bribery and anti-corruption laws, including but not limited to the UK Bribery Act, the U.S. Foreign Corrupt Practices Act, and local anti-corruption laws in Turkey, Tunisia, United Arab Emirates, and the European Union. We have a zero-tolerance approach to bribery and corruption in any form.

Policy Scope

This policy applies to:

• All employees, officers, and directors of FlavourTech
• Third parties acting on behalf of FlavourTech, including agents, consultants, distributors, and other representatives
• All business activities conducted by or on behalf of FlavourTech worldwide

Prohibited Conduct

The following conduct is strictly prohibited:

• Offering, promising, giving, or authorizing the giving of anything of value to any person, directly or indirectly, to improperly influence actions or decisions
• Requesting, agreeing to receive, or accepting anything of value that may improperly influence your actions or decisions
• Making facilitation payments (small payments to government officials to expedite routine actions)
• Using third parties to circumvent this policy
• Creating inaccurate or false books and records to conceal improper payments
• Retaliating against anyone who refuses to engage in bribery or who reports suspected violations

Key Risk Areas

Gifts, Hospitality, and Entertainment

Gifts, hospitality, and entertainment must:

• Be reasonable, proportionate, and appropriate to the circumstances
• Have a legitimate business purpose
• Not be intended to improperly influence business decisions
• Comply with applicable laws and the recipient’s organization’s policies
• Be accurately recorded in our books and records
• Be approved in accordance with our internal procedures

Dealing with Government Officials

Interactions with government officials require special care. Additional restrictions and approval requirements apply to:

• Gifts, hospitality, and entertainment provided to government officials
• Charitable or political contributions involving government officials
• Hiring or engaging relatives of government officials
• Sponsorships involving government entities or officials

Third Party Due Diligence

Before engaging third parties who may interact with others on our behalf, we conduct risk-based due diligence to assess their reputation, qualifications, and connections to government officials. Third parties are required to comply with this policy and may be subject to ongoing monitoring.

Implementation and Compliance

To ensure compliance with this policy, we have implemented:

• Clear procedures for gifts, hospitality, and entertainment
• Risk-based due diligence for third parties
• Regular training and awareness programs
• Internal controls and financial record-keeping procedures
• Regular audits and compliance monitoring
• Confidential reporting mechanisms for suspected violations
• Investigation procedures for reported concerns

Reporting Concerns

We encourage anyone with concerns about potential violations of this policy to report them through our confidential reporting channels:

• Direct reporting to the Compliance Officer
• Email to [email protected]
• Our confidential whistleblowing hotline

We prohibit retaliation against anyone who reports concerns in good faith or assists in an investigation.

Consequences of Violations

Violations of this policy may result in:

• Disciplinary action, up to and including termination of employment
• Termination of business relationships with third parties
• Criminal penalties, including fines and imprisonment for individuals involved
• Significant financial penalties for the company
• Reputational damage

Responsibility and Oversight

The Board of Directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations. The Compliance Officer is responsible for implementing the policy, monitoring its effectiveness, and reporting to the Board on compliance matters.