PUBLIC INTERNAL AUDITORS' CODE OF ETHICS

I. INTRODUCTION

Pursuant to Article 67 (k) of Law No. 5018 on Public Financial Management and Control, it is stipulated that the ethical rules to be followed by internal auditors will be determined by the Internal Audit Coordination Board (the Board). Additionally, Article 9 of the Regulation on the Working Procedures and Principles of Internal Auditors states that internal auditors are obliged to adhere to the audit standards and ethical rules set by the Board, and these standards and rules will be determined, taking into consideration internationally recognized standards and rules.

Within this framework, the code of ethics has been created to develop the culture of professional ethics in public internal audit practices, based on the International Standards for the Professional Practice of Internal Auditing (IIA) and utilizing texts from other international professional organizations.

Internal auditing is an independent, objective assurance and consulting activity designed to add value and improve an organization's operations. It helps an organization accomplish its objectives by bringing a systematic, disciplined approach to evaluate and improve the effectiveness of risk management, control, and governance processes.

The code of ethics consists of 'Principles' related to the internal audit profession and practice and 'Code of Conduct' that defines the expected behavior of internal auditors.

This code of ethics is read and signed by the internal auditor upon entering the profession and presented to the internal audit unit and senior management.

II. PRINCIPLES

Internal auditors are expected to adhere to the following principles:

1. Integrity

Internal auditors' integrity inspires trust and thereby creates a foundation for reliance on their findings and evaluations.

2. Independence, Objectivity, and Impartiality

When collecting, evaluating, and reporting information related to their audits, internal auditors demonstrate the highest level of professional impartiality. They assess all relevant factors impartially and without bias, ensuring that neither they nor others' interests are compromised.

3. Confidentiality

Internal auditors respect the confidentiality of information obtained during audits, and unless required by legal or professional obligations, they do not disclose or reveal this information.

4. Competence

Internal auditors demonstrate the knowledge, skills, and experience required to carry out internal audit services.

III. CODE OF CONDUCT

1. Integrity

When conducting their activities, internal auditors:

1.1 Act with truthfulness and a sense of responsibility.

1.2 Comply with the law, provide the necessary disclosures required by law and the profession.

1.3 Do not engage in or knowingly participate in illegal activities or activities that would discredit the internal audit profession or the organization.

1.4 Respect and contribute to the legitimate and ethical objectives of the organization.

1.5 Consider the public interest in their decisions.

2. Independence, Objectivity, and Impartiality

Internal auditors:

2.1 Are independent and impartial in addressing issues and topics in their area of responsibility.

2.2 Safeguard their independence from any form of political influence.

2.3 Stand firm against individual or institutional internal or external interests and pressures.

2.4 Gather information and opinions presented by the audited entity and other parties but make their decisions with free will.

2.5 Prepare audit reports accurately and objectively (findings should be based solely on obtained evidence and comply with audit standards).

2.6 Do not engage in activities or relationships that may compromise their impartiality. This is also valid for activities or relationships that may conflict with the interests of the organization.

2.7 Refuse any benefit that could impair the auditor's professional judgment.

2.8 Disclose all significant findings that could jeopardize the validity of a report regarding the audited activity, even if not disclosed.

3. Confidentiality

Internal auditors:

3.1 Exercise caution in preserving and using information obtained during their duties. However, they report to the competent authorities any illegal or unethical activities as required by legislation.

3.2 Do not use the information they possess for personal interests or in a way that is unlawful or harmful to the legitimate and ethical objectives of the organization.

4. Competence

Internal auditors:

4.1 Only undertake tasks for which they possess the knowledge, skills, and experience required.

4.2 Perform internal audit services in accordance with public internal audit standards.

4.3 Continuously improve their competence and the quality of their services.

IV. APPLICABILITY AND ENFORCEMENT

The code of ethics is binding for the internal audit unit and internal auditors providing internal audit services. Violation of these rules will be evaluated and concluded according to the Board's regulations and administrative arrangements for those who hold a public internal auditor certificate or are internal auditor candidates. The absence of a specific prohibition in the code of ethics does not imply that a particular behavior is acceptable or correct.

Internal auditors should guide their behavior in a way that promotes collaboration and good relationships with their colleagues. They should:

1. Contribute to the development of the internal audit profession by collaborating with other internal auditors.
2. Establish reasonable and balanced relationships with other internal auditors.

V. CONFLICT OF INTEREST

If internal auditors provide consulting or other services to the audited entity, outside the scope of auditing, they should ensure that these services do not create a conflict of interest.

Internal auditors:

1. Should make sure that such services do not interfere with the management's exclusive authority and responsibility and should leave such matters to the audited entity's management.
2. Refuse any interests that might impact their independence and impartiality.
3. Avoid relationships and activities that threaten, or may threaten, their independence and impartiality with the audited entity's management, staff, and other relevant parties. This includes activities and relationships that conflict with the interests of the organization.
4. Do not use their official positions for personal purposes and should avoid relationships and activities that involve a risk of corruption or cause doubts about the auditor's independence and impartiality regarding conflicts.