Last updated: 13 September 2026
1. Purpose and Scope
NANODRAG Teknoloji İç ve Dış Ticaret Sanayi Limited Şirketi is committed to conducting business lawfully, responsibly and with integrity. This Code of Ethics applies to our directors, managers and employees and guides decisions made in connection with DragSYS products, services and business activities in Turkey and international markets.
We also expect distributors, suppliers, service providers and other business partners to observe the principles relevant to their work with us. Where these principles are incorporated into an agreement or supplier requirement, they form part of that contractual relationship.
The Code does not replace applicable law, employment obligations, contracts or technical procedures. Where a stricter legal or contractual requirement applies, that requirement must be followed.
2. Integrity, Honesty and Accountability
We communicate honestly, keep accurate commitments and take responsibility for our decisions. We do not conceal errors, misrepresent facts or permit commercial pressure to override safety, quality, compliance or ethical judgment.
Employees are expected to raise concerns early, seek guidance where a situation is unclear, and cooperate truthfully with internal reviews. Managers must lead by example and must not instruct or encourage anyone to disregard this Code.
3. Product Safety, Quality and Conformity
Laboratory products can affect safety, reliability and the reproducibility of professional work. We therefore treat product responsibility as an ethical obligation as well as a technical and legal one.
We shall:
- provide descriptions, specifications and documentation for laboratory equipment, instruments, tools, supplies and consumables that are accurate, supportable and appropriate to the product and intended market
- apply defined controls to product selection, design, sourcing, manufacture, inspection, storage and release, according to our role and the applicable requirements
- not knowingly alter, conceal or misuse conformity documents, test reports, calibration information, labels, instructions or product records
- investigate credible safety, quality and non-conformity concerns and take appropriate corrective action
- communicate material product risks, intended-use limitations and handling requirements responsibly and without avoidable delay
4. Fair Dealing and Customer Responsibility
We treat customers, distributors, suppliers and competitors fairly. Recommendations should respond to the customer’s actual application and requirements. We do not obtain business through deception, material omissions, improper pressure or claims that cannot be supported.
Prices, quotations, order confirmations, invoices, delivery information and warranty statements must be prepared accurately and communicated clearly. Commercially sensitive information received from another party must not be misused to gain an unfair advantage.
5. Ethical Marketing and Technical Communication
Our advertising and technical communication must be truthful, clear and capable of substantiation. Product performance, intended use, origin, certification, conformity, availability and delivery claims must not be exaggerated or presented in a misleading way. Comparisons with competitors must be fair and based on reliable information.
Employees and representatives must distinguish verified facts from estimates, planned developments and professional opinions. Information known to be outdated or incorrect must be corrected through the appropriate channel.
6. Anti-Bribery, Gifts and Hospitality
We do not offer, promise, give, request or accept bribes, kickbacks, facilitation payments or any improper advantage. No employee or business partner may use a third party to do something that would be prohibited if done directly.
Reasonable and modest gifts or hospitality may be accepted or offered only when they:
- have a legitimate business purpose and are lawful and customary in the relevant setting
- are infrequent, proportionate and not in cash or a cash equivalent
- cannot reasonably be understood as influencing a purchasing, tender, regulatory or other business decision
- are recorded or approved where company procedures require it
Gifts or hospitality involving public officials, healthcare or laboratory institutions, universities or procurement personnel require particular care and must comply with applicable rules. If there is doubt, the item must be declined or approved in advance by management.
7. Conflicts of Interest
Business decisions must be made in the legitimate interests of the company and without undisclosed personal influence. Employees must promptly disclose any actual, potential or perceived conflict, including personal or financial interests in a customer, supplier, distributor or competitor; outside employment; or a close personal relationship affecting a decision.
Disclosure does not automatically mean misconduct. It allows the conflict to be assessed and managed through recusal, approval, changed responsibilities or another appropriate measure.
8. Fair Competition, Trade Controls and Sanctions
We compete fairly and comply with applicable competition and antitrust laws. We do not agree with competitors to fix prices, divide markets or customers, manipulate tenders or exchange competitively sensitive information without a lawful basis.
We comply with applicable export controls, customs requirements, economic sanctions and restrictions on end users and end uses. Employees involved in international business must provide accurate trade information and escalate unusual destinations, parties, payment routes or requested uses for review.
9. Accurate Records and Responsible Use of Company Assets
Business, financial, quality, service and regulatory records must be complete, accurate and retained as required. False entries, undisclosed payments, fabricated documents and intentional misclassification are prohibited.
Company funds, equipment, systems, accounts, confidential information and intellectual property must be used responsibly and protected against loss, misuse and unauthorised access. Expenses and approvals must reflect the actual transaction and business purpose.
10. Confidentiality, Data Privacy and Intellectual Property
We protect confidential and personal information belonging to customers, employees, partners and the company. Information is accessed, used and disclosed only for authorised purposes and in accordance with applicable data protection law and contractual obligations.
We respect patents, trademarks, copyrights, designs, software licences, trade secrets and other intellectual property rights. Confidential information or intellectual property belonging to a previous employer, competitor or business partner must not be used without proper authority.
11. Respect, Equal Opportunity and Professional Conduct
We treat people with dignity and professional respect. Discrimination, harassment, intimidation, bullying and retaliation are not tolerated. Employment and work-related decisions are based on legitimate qualifications, performance, conduct and business needs, without unlawful discrimination.
We value different backgrounds and perspectives and support a workplace in which people can contribute, question decisions constructively and raise concerns without fear of unfair treatment.
12. Health, Safety and Well-being
We provide and maintain a safe and healthy working environment in accordance with applicable requirements. Employees must follow safety instructions, use equipment responsibly, report hazards and incidents, and stop or escalate work where there is a credible risk of harm.
We support employee well-being through appropriate workplace practices and initiatives. No commercial objective justifies knowingly exposing employees, customers, partners or visitors to an avoidable safety risk.
13. Sustainability and Social Responsibility
We work to reduce environmental impact through responsible resource use, waste prevention, appropriate material and packaging choices, energy-conscious operations and continuous improvement. Environmental considerations are integrated into product and operational decisions where technically and commercially practicable without compromising safety, quality or compliance.
We support appropriate community initiatives, employee participation and responsible corporate citizenship. Public statements about environmental or social performance must be accurate and must not overstate the results achieved.
14. Responsible Supply Chain
We seek suppliers and partners that operate lawfully and responsibly and that respect human rights, safe working conditions, environmental obligations and fair business practices. Selection and review are based on relevant risk, capability, quality, documentation, performance and commercial requirements.
We may request information, evidence or corrective action where a significant concern arises. Serious or repeated misconduct may lead to suspension or termination of the relationship, subject to applicable agreements and law.
15. Raising a Concern
Employees, business partners and other stakeholders are encouraged to report suspected misconduct, legal violations, safety concerns, falsified records, bribery, conflicts of interest or other breaches of this Code as early as possible. Reports may be submitted confidentially to info@dragsys.com.
A report may be made without stating the reporter’s name. Email itself may reveal technical or account information; a person seeking anonymity should avoid using an identifiable company or personal account and should not include unnecessary identifying details.
A useful report should describe the concern, relevant dates, persons or transactions, and available supporting information. A reporter is not expected to prove the concern before raising it, but knowingly false or malicious allegations are prohibited.
16. Confidentiality, Non-Retaliation and Review
Reports are handled as confidentially as reasonably possible. Information is shared only with persons who need it to assess, investigate or respond to the concern, or where disclosure is required by law. Absolute confidentiality or anonymity cannot be guaranteed where fair investigation, legal rights or authority requirements make disclosure necessary.
Retaliation against a person who raises a concern honestly and in good faith, asks for guidance or participates in a review is prohibited. This protection does not prevent proportionate action concerning knowingly false reports or misconduct discovered independently during a review.
Concerns are assessed fairly and proportionately. Relevant persons are expected to preserve information and cooperate truthfully. Appropriate action may include guidance, process improvement, corrective action, training, contractual measures or disciplinary action, subject to applicable law and agreements.
17. Responsibility and Questions
Every employee is responsible for understanding and following the principles relevant to their work. Managers are responsible for promoting ethical conduct, responding to questions and escalating concerns appropriately. Business partners are expected to cooperate with reasonable enquiries relating to their work with us.
Questions about this Code or its application may be sent to info@dragsys.com. Where a decision is uncertain, employees should seek guidance before acting.
18. Review and Updates
NANODRAG Teknoloji İç ve Dış Ticaret Sanayi Limited Şirketi may review and update this Code to reflect changes in the business, risks, law and recognised good practice. The current public version and its update date will be made available on the DragSYS website.
