Compliance & Sustainability

About These Statements

TDM Otomotiv supplies metal parts to selected customers in the global automotive and agricultural machinery industries. This page consolidates our policies in line with the responsible-supply-chain standards expected in those industries.

The statements below are provided to support our customers' supplier qualification processes. Each statement is approved by TDM Otomotiv management; detailed documentation is available on request. Specific customer references and supplier-tier wording (e.g. "Tier-1") are used subject to the relevant contractual and customer approvals.

1. Conflict Minerals Statement

TDM Otomotiv supports the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. The "3TG minerals" (tin, tantalum, tungsten, and gold) targeted by US Dodd-Frank Act Section 1502 and EU Conflict Minerals Regulation (2017/821) are not directly used in our manufacturing processes.

Where production inputs contain components with these minerals, we request the CMRT (Conflict Minerals Reporting Template) from our suppliers and, where appropriate, verify the smelter chain. Suppliers sourcing minerals from conflict zones around the Democratic Republic of Congo are not used.

CMRT reports are available on customer request via web@tdmtr.com, updated annually.

2. REACH and RoHS Compliance

Based on supplier declarations and our internal quality processes, we work to ensure that the metal parts we ship meet the applicable requirements of the EU REACH Regulation (1907/2006/EC) and the RoHS Directive (2011/65/EU as amended).

• REACH SVHC: our supplier qualification and quality processes are aimed at avoiding substances on the REACH Substances of Very High Concern list above threshold values. Substance-level SVHC declarations are provided on request to the extent available through our supply chain.
• RoHS: hazardous substances including lead, mercury, cadmium, hexavalent chromium, PBB, and PBDE are controlled within RoHS limits via supplier declarations and process specifications. Our currently specified galvanizing processes are designed not to use hexavalent chromium.
• IMDS (International Material Data System): IMDS notifications are provided to OEM customers on request.

Substance-level compliance declarations and technical documentation are maintained as part of our ISO 9001:2015 certified quality management system (IQR International, cert no. QMS-014904), supported by processes aligned with IATF 16949 principles, and provided on request; details of current certification scope are shared on request. Under our predecessor entity (TDM Otomotiv Ltd. Şti.), TDM previously held an IATF 16949 certificate issued by Bureau Veritas, valid 2018–2021; our current processes build on that experience.

3. Modern Slavery and Forced Labour Statement

TDM Otomotiv categorically opposes all forms of modern slavery, human trafficking, forced labour, and child labour. While TDM Otomotiv may not be directly subject to all of the following regimes, we align our internal practices with the responsible-sourcing expectations of customers who may be subject to them — including the UK Modern Slavery Act 2015, the German Lieferkettensorgfaltspflichtengesetz (LkSG / Supply Chain Act), and the fundamental International Labour Organization (ILO) conventions.

Internal practices:

• Full compliance with Turkish Labour Law No. 4857; written employment contracts and regular salary payments
• Prohibition of employment below the minimum age (18)
• Employees retain their own identity documents; freedom of movement on site
• No recruitment fees, deposits, or similar financial obligations imposed on employees
• Accessible grievance reporting mechanism

In our supply chain: we aim to request that our primary raw-material suppliers attest compliance with the ILO fundamental conventions, and we work to establish audit rights where appropriate.

4. Anti-Bribery and Anti-Corruption

TDM Otomotiv applies a zero-tolerance policy against bribery and corruption in all forms. This policy aligns with Turkish Criminal Code (TCK) articles 252–255, Law No. 3628 on Declaration of Wealth, and international standards including the UK Bribery Act 2010 and the US FCPA (Foreign Corrupt Practices Act).

The following conduct is prohibited for employees and business partners:

• Providing direct or indirect benefits to public officials or private sector representatives
• Making facilitation payments
• Accepting unreasonably valued gifts, entertainment, or travel from customers/suppliers
• Failing to report conflict-of-interest relationships

We are developing internal reporting mechanisms for suspected violations on the principle that reporting employees should be protected against retaliation.

5. Supplier Code of Conduct Adherence

TDM Otomotiv commits to the requirements of our customers' Supplier Code of Conduct documents, including:

• Ford Otosan Supplier Sustainability Requirements
• CNH Industrial Supplier Code of Conduct
• AGCO Code of Business Conduct
• AIAG (Automotive Industry Action Group) guidelines

We commit to following the requirements covered by these documents — human rights, occupational safety, environment, ethical business conduct, and data security — as integrated parts of our quality management processes. Details of current certification scope are shared on request.

6. ESG and Sustainability

Environmental commitments:

• Rooftop solar (GES): our facility is equipped with a rooftop solar power system that contributes significantly to our annual electricity consumption.
• We work to align our environmental management processes with ISO 14001 principles; details of current certification scope are shared on request.
• Scrap-metal recovery and waste-management processes
• Continuous-improvement objectives for water and chemical consumption
• We are developing our greenhouse gas (CO₂-eq) measurement and reporting capability

Social commitments:

• We work to align our occupational health and safety processes with ISO 45001 principles
• Diversity and equal opportunity; zero tolerance for discrimination by gender, ethnicity, religion, or political view
• Internship and training programmes for employee development
• Local community employment (Bursa Hasanağa OSB region)

Governance commitments:

• Independently auditable accounting (TFRS / Turkish Commercial Code)
• Internal control and risk management processes
• KVKK- and GDPR-compliant processing of customer data (see our Privacy Policy)

Our sustainability reporting is being developed with reference to the GRI (Global Reporting Initiative) standards.

Contact

For supplier qualification documents, compliance documentation, or ESG reports:

• Email: web@tdmtr.com
• Phone: +90 224 484 25 73
• Post: Hasanağa OSB Mah., 15. Cad., No: 11, Nilüfer / Bursa, Türkiye

The statements on this page are published as management commitments of TDM Otomotiv Sanayi ve Ticaret A.Ş. Customer-specific self-assessment forms or audit certificates are provided on request.