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Kulular Teknoloji, Kulular Bilişim Teknolojileri Limited Şirketi
TR

← Corporate Policies

This English page explains a policy that binds the company under Turkish law. The Turkish text is the legally operative version.

Equal Opportunity and Gender Equality Plan

In force from
3 Eylül 2026
Review
Yılda bir kez, ölçüm sonuçlarıyla birlikte

1. Purpose and scope

This Plan sets out the commitments Kulular Bilişim Teknolojileri Limited Şirketi (the Company) undertakes to secure equal opportunity in working life, and how those commitments are measured.

The Plan concerns the employment relationship. It aims to ensure that no one is treated differently because of their sex in recruitment, assignment, pay, promotion, training or working arrangements. The Plan does not aim to redefine social roles or to state a position on family structure.

The Plan covers all employees, interns and third parties working on the Company's behalf. Candidates taking part in recruitment processes are also within scope.

2. Legal basis

The Plan rests on, and is read together with, the following provisions of Turkish and applicable international law.

  • Article 10 of the Constitution of the Republic of Türkiye: equality before the law.
  • Article 41 of the Constitution: protection of the family and children's rights.
  • Article 50 of the Constitution: special protection of women, minors and those with physical or mental disability in respect of working conditions.
  • Article 5 of Labour Law No. 4857: the principle of equal treatment, and the rule that a lower wage may not be agreed on grounds of sex for the same work or work of equal value.
  • Law No. 6701 on the Human Rights and Equality Institution of Türkiye: prohibition of discrimination.
  • Law No. 6284 on the Protection of the Family and the Prevention of Violence Against Women.
  • Article 105 of the Turkish Criminal Code No. 5237: the offence of sexual harassment.
  • The European Union's equal treatment in employment provisions, and the public gender equality plan requirement of the Horizon Europe programme.

3. Current position

The Company was registered on 1 September 2026 and is newly established. Three of the five founding partners are women and two are men. The managing director, who has sole authority to represent the Company, is a woman.

Because the team is small, proportions change materially with the arrival of a single person. For this reason, measurement results are stated together with the underlying headcount, not as a percentage alone.

The Company recognises that its current composition is a starting point, not an achievement. This Plan aims to preserve equal opportunity as the team grows.

4. Commitments in recruitment and promotion

  • Recruitment notices do not ask about sex, marital status, age or whether a candidate has children.
  • Interviews do not ask about a candidate's private life, or their marriage or childbearing plans. Such questions breach both Article 5 of Law No. 4857 and personal rights.
  • No pay difference based on sex is applied for the same work or work of equal value. Pay ranges are defined in writing by role.
  • Promotion and role-change decisions are based on written criteria, and the reasoning for a decision is recorded.
  • Access to training and development opportunities is not differentiated.
  • Equal opportunity is observed in intern recruitment; internships are not left unpaid.

5. Family and working arrangements

The Company recognises the family as the foundation of society, and that an employee's family responsibilities should not become an obstacle to their professional development. The arrangements in this section are not a privilege; they are the condition that lets an employee attend to both work and family.

  • Maternity, adoption, nursing and care leave are applied at no less than the statutory minimum.
  • An employee returning from leave keeps their role, title and pay. Time on leave is not counted against them in a promotion assessment.
  • Paternity leave is granted in full, and its use is encouraged.
  • Flexible and remote working is given priority consideration for employees with caring responsibilities, offered without distinction between mothers and fathers.
  • Meetings are, as a rule, scheduled within working hours and so as not to clash with school hours.
  • Leave requests from employees caring for an elderly or unwell relative are assessed with the same approach.

6. Preventing violence, harassment and discrimination

Sexual harassment, psychological harassment and discrimination based on sex are not tolerated at the Company in any form. These acts are also criminal offences and grounds for justified termination.

A report may be made directly to the managing director. Where the managing director is a party to the matter, the report is made to any of the founding partners.

The identity of the person reporting is not shared beyond what the investigation requires. A person who reports in good faith may not be subjected to any adverse treatment as a result.

Every report is recorded in writing and concluded within thirty days. The outcome is communicated to the person who reported in writing. Where an act constitutes a criminal offence, the right to apply to the judicial authorities is preserved, and the Company supports its employee in making that application.

7. Measurement and indicators

The Company measures the following indicators once a year and shares the results with the founding partners. Once headcount reaches a level at which anonymity is preserved, results are also published on this page.

  • The distribution of sex within the team, together with headcount.
  • The distribution within management and decision-making positions.
  • The distribution of applicants, those invited to interview and those recruited.
  • A comparison of average pay at the same grade.
  • Leave take-up and return-to-work rates after leave.
  • The number of reported harassment and discrimination cases and their time to resolution.
  • Participation in awareness training.

8. Responsibility and resources

The managing director is responsible for implementing the Plan, for measurement and for reporting.

The Company commits to holding awareness training on the relevant law and this Plan once a year, and to allocating budget for external expert support where needed.

9. Entry into force and review

This Plan takes effect on the date of its publication and carries the approval of the board of founding partners. It is reviewed at least once a year, together with the measurement results.

The Plan is amended by decision of the board of founding partners. The current version is always published on this page.