Anti-Bribery and Corruption Policy

1. Purpose

To state that bribery, corruption, favouritism and fraud have no place in any part of hangel's work, and to describe what we do today to prevent them.

2. Scope

Board and Supervisory Board members, employees, the Association's own volunteers, super-admins, consultants and suppliers of the International Social Benefit Association (operator of the hangel platform). All relationships with organisations on the platform (NGOs, clubs, brands), affiliate networks, sponsors and public bodies are in scope.

3. Principles

1. Zero tolerance. Giving, offering, requesting or accepting money, gifts, services, jobs or any other advantage, directly or through an intermediary, is prohibited. A small amount does not change this.
2. No facilitation payments. No unofficial payment is made to speed up a process.
3. Platform decisions cannot be bought. Approval of an organisation's application, review of transparency documents, a complaint decision, featuring, ranking or a certificate is never granted or changed in return for payment or any advantage.
4. Records and documents. Every payment is backed by a document, made through a bank and recorded. No cash payments are made.
5. Dealing with public officials. Cooperation with public bodies is conducted openly and in writing; gifts and hospitality to public officials are subject to the Gifts and Hospitality Policy.
6. Reference framework. We are guided by the bribery and fraud provisions of the Turkish Criminal Code and by the anti-corruption principle (Principle 10) of the UN Global Compact.

4. Roles and responsibilities

• Board of Directors: approves this policy, investigates or arranges investigation of suspicious cases and reports to the competent authorities where required.
• Supervisory Board: audits the Association's accounts and transactions under the law on associations.
• Super-admins: use payment, rate and approval permissions only within the defined process.
• Everyone: refuses any bribe and reports it.

5. How it works at hangel today

• Transfers to NGOs: Amounts arising from shopping commissions and due to the NGOs chosen by users are calculated with a single calculation rule on the platform. The month-end transfer is made manually by bank transfer; a super-admin records it, a payout record with reference and amount is created and the NGO's administrator is notified.
• Reconciliation: Every day, conversions reported by the affiliate network for the last 35 days are compared with platform records and the differences are recorded.
• Rates: Tax and hangel-share rates can only be changed by a super-admin; the sponsorship service-fee rate is written into the agreement at the moment of acceptance and cannot be changed retroactively.
• Approvals: Organisation applications and transparency documents are approved or rejected after review by a super-admin or a lawyer; if a transparency document is rejected, the organisation is notified.
• Audit log: Administrative actions such as payouts, approvals and rate changes are written to the audit log.

6. Not yet in place and our goals

• A "four-eyes" rule (one person prepares, another approves) is not enforced in software for payouts; we aim to add it to the payout screen.
• We have not commissioned an independent financial audit.
• Corruption risk assessment and training are not yet carried out regularly; we aim to start them under the Risk Management Policy.

7. How to raise a concern

Bribe offers, suspicious payments or misconduct: kvkk@hangel.org (subject "Whistleblowing — Confidential"). If the matter concerns members of the Board of Directors, the report can also be sent in writing to the Association's Supervisory Board at the Association's registered address. No one who reports in good faith will face retaliation.

8. Review

At least once a year and after every confirmed breach.

9. Related documents

Code of Ethics · Gifts and Hospitality Policy · Conflict of Interest Policy · Whistleblowing Policy · Anti-Money Laundering and Counter-Terrorist Financing Policy · Existing "Anti-Fraud and Anti-Corruption Policy" (contracts: dolandiricilik-ve-yolsuzlukla-mucadele-politikasi)