Compliance Program
"What should a corporate compliance program include in Turkey?"
Quick Answer
In Turkey, an effective compliance program starts with a risk assessment and management ownership, then translates into written policies (e.g., anti-corruption, competition law, KVKK/data protection), training, and documented approval controls—especially for third parties and high-risk transactions. It should also include a reporting/investigation mechanism, monitoring/audit, and proportionate disciplinary and remediation steps supported by clear records.
Commercial Law Framework
A corporate compliance program in Turkey is not regulated by a single statute; it is a governance and risk-management framework designed to ensure adherence to applicable Turkish laws and sector-specific regulations. Depending on the business model, the relevant risk areas commonly include anti-corruption and fraud controls, competition law (Law No. 4054), personal data protection (KVKK Law No. 6698), workplace compliance, and—where applicable—AML and international trade/sanctions screening.
Key Points to Remember
- Board/management tone at the top and a documented compliance governance structure (roles, authority, reporting lines).
- Risk assessment and a written policy set (Code of Conduct + topic policies: anti-corruption, competition, KVKK, gifts/entertainment, third parties).
- Reporting channel (whistleblowing) and a documented investigation/response workflow with corrective actions.
- Training, monitoring/audits, and proportionate disciplinary measures; keep evidence (logs, approvals, training records).
Business Implementation
Implementation should be proportionate to the company’s size and risk profile, but certain building blocks are universal: a clear approval matrix, third-party onboarding and due diligence, and documentation that proves the program is actually working (training logs, approvals, audit findings, remediation).
For many B2B businesses in Turkey, the highest exposure points are (i) competitor communications and distribution practices (competition law), (ii) personal data processing in HR/CRM/vendor tools (KVKK), and (iii) payments/benefits offered through intermediaries. A practical program therefore includes contract clauses, workflow controls, and an incident-response plan rather than relying only on policies “on paper.”
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