Statutory Regulations Under the Labor Law: (LABOR LAW NO. 4857)

Procedure in Termination

Article 19 – The employer must issue the notice of termination in writing and state the reason for termination clearly and precisely.

The employment contract of an employee employed under a permanent contract (indefinite term) cannot be terminated for reasons related to the employee’s conduct or performance without first obtaining their defense against the allegations. However, the employer's right to terminate the contract in accordance with the provisions of Article 25, paragraph (II) remains reserved.

Objection to Notice of Termination and Procedure

Article 20 – (Amended first paragraph: 12/10/2017-7036/Art. 11) The employee whose employment contract has been terminated must, on the grounds that no reason was stated in the notice of termination or that the reason stated was not a valid reason, apply to a mediator in accordance with the provisions of the Labor Courts Law within one month from the date of notification of the termination notice, requesting reinstatement. If no settlement is reached at the end of the mediation proceedings, a lawsuit may be initiated before the labor court within two weeks from the date the final minutes of non-settlement are issued. If the parties agree, the dispute may also be referred to a private arbitrator instead of the labor court within the same period. If the lawsuit is rejected on procedural grounds due to direct initiation without prior application to a mediator, the ex-officio notification of the dismissal decision is served to the parties. An application to the mediator can still be filed within two weeks from the date this finalized procedural dismissal decision is served.

The burden of proving that the termination was based on a valid reason rests with the employer. If the employee claims that the termination was based on a different reason, the employee shall bear the burden of proving this claim.

(Amended third paragraph: 12/10/2017-7036/Art. 11) The lawsuit shall be concluded expeditiously. In the event that an appeal is lodged against the decision rendered by the court, the regional court of justice shall render its decision expeditiously and with finality.

(Fourth paragraph annulled by the Decree of the Constitutional Court dated 19/10/2005, Merits No: 2003/66, Decision No: 2005/72.)

Consequences of Termination Without a Valid Reason

Article 21 – Where it is determined by the court or by a private arbitrator that no valid reason was shown by the employer or that the reason shown was not valid, and the invalidity of the termination is decided, the employer is obliged to reinstate the employee within one month. If, upon the application of the employee, the employer fails to reinstate them within one month, the employer shall be liable to pay compensation to the employee in an amount not less than four months’ wages and not exceeding eight months’ wages.

When the court or the private arbitrator decides on the invalidity of the termination, it shall also determine the amount of compensation to be paid in the event that the employee is not reinstated.

The employee shall be paid their accrued wages and other entitlements for the period they were not employed until the finalization of the decision, up to a maximum of four months.

(Additional paragraph: 12/10/2017-7036/Art. 12) The court or the private arbitrator shall determine the compensation regulated in the second paragraph, and the wages and other entitlements regulated in the third paragraph, in monetary terms based on the wage applicable on the date the lawsuit was filed.

If the employee is reinstated, the severance pay and the wages corresponding to the notice period paid in advance shall be deducted from the payment to be made pursuant to the provisions of the paragraph above. If the employee who is not reinstated was not granted a notice period or the wage for the notice period was not paid in advance, the amount of wages corresponding to these periods shall be paid additionally.

The employee must apply to the employer to resume work within ten business days from the notification of the finalized decision of the court or the private arbitrator. If the employee fails to apply within this period, the termination executed by the employer shall be deemed valid, and the employer shall only be liable for the legal consequences thereof.

(Additional paragraph: 12/10/2017-7036/Art. 12) If the parties agree on the reinstatement of the employee at the conclusion of the mediation process; they are mandatorily required to determine:

a) The date of reinstatement,

b) The monetary amount of the wages and other entitlements regulated in the third paragraph,

c) The monetary amount of the compensation regulated in the second paragraph in the event that the employee is not reinstated.

Otherwise, a mutual agreement shall be deemed not achieved, and the final minutes shall be issued accordingly. If the employee does not commence work on the agreed date, the termination becomes valid, and the employer shall only be liable for its legal consequences.

The provisions of the first, second, and third paragraphs of this article cannot be altered by employment contracts under any circumstances; any contractual provisions to the contrary shall be null and void.

Alteration of Working Conditions and Termination of the Employment Contract

Article 22 – The employer may make a fundamental alteration in working conditions established through an employment contract, by personnel regulations annexed to the contract, similar sources, or workplace practices, only by notifying the employee of the situation in writing. Alterations not executed in compliance with this form and not accepted by the employee in writing within six business days shall not bind the employee. If the employee does not accept the alteration proposal within this period, the employer may terminate the employment contract by explaining the valid reason for the alteration or the existence of another valid reason for termination in writing and by complying with the notice period. In this case, the employee may initiate a lawsuit in accordance with the provisions of Articles 17 to 21.

The parties may alter working conditions at any time by mutual agreement. Alterations in working conditions cannot be applied retroactively.

Liability of the New Employer

Article 23 – If an employee engaged in a continuous employment contract, whether for a definite or indefinite term, leaves their job before the expiration of the contract term or without complying with the notice period and enters the employment of another employer, the new employer shall be jointly and severally liable along with the employee for the termination of the contract under the following circumstances:

a) If the new employer caused or incited this conduct of the employee.

b) If the new employer hired the employee knowing about this conduct.

c) If the new employer continued to employ the employee even after learning about this conduct.

Right of the Employee to Immediate Termination for Just Cause

Article 24 – Whether the contract is for a definite or indefinite term, the employee may terminate the employment contract before the expiration of its term or without waiting for the notice period under the following circumstances:

I. Health Reasons:

a) If the performance of the work covered by the employment contract becomes dangerous to the employee’s health or life due to a reason arising from the nature of the work.

b) If the employer or another employee with whom the employee is in constant, close, and direct contact contracts an infectious disease or an illness incompatible with the employee's work.

II. Situations Incompatible with Moral Principles and Good Faith, and Similar Instances:

a) If the employer misleads the employee by showing false qualifications or conditions or by providing inaccurate information or making false statements regarding one of the essential points of the contract at the time it is concluded.

b) If the employer speaks words or engages in conduct that assaults the honor and reputation of the employee or a member of their family, or sexually harasses the employee.

c) If the employer assaults or intimidates the employee or a member of their family, or incites, provokes, or drags the employee or a member of their family into unlawful conduct, or commits an offense requiring imprisonment against the employee or a member of their family, or levels unfounded, severe, and defamatory allegations or accusations against the employee.

d) If the employee is subjected to sexual harassment in the workplace by another employee or third parties, and no necessary measures are taken despite notifying the employer of this situation.

e) If the employee’s wage is not calculated or paid by the employer in accordance with the provisions of the law or the terms of the contract.

f) In cases where payment of wages on a piece-work basis or per task amount is agreed upon, and the employer allocates less work to the employee than they can perform, if the wage deficit is not compensated on a time-basis or if the agreed working conditions are not applied.

III. Force Majeure:

If force majeure events emerge at the workplace where the employee is employed, requiring the suspension of work for more than one week.

Right of the Employer to Immediate Termination for Just Cause

Article 25 – Whether the contract is for a definite or indefinite term, the employer may terminate the employment contract before the expiration of its term or without waiting for the notice period under the following circumstances:

I- Health Reasons:

a) In the event that the employee contracts a disease or becomes disabled due to their own deliberate intent, disorganized lifestyle, or addiction to alcohol, and the resulting absenteeism exceeds three consecutive business days or more than five business days in a month.

b) In the event that it is determined by the Medical Board that the disease contracted by the employee is incurable and that it is hazardous for them to work at the workplace.

Except for the reasons listed in sub-clause (a), the employer’s right to terminate the employment contract without notice due to reasons such as illness, accident, childbirth, and pregnancy arises after these situations exceed the notice periods specified under Article 17 by six weeks, relative to the employee’s length of service at the workplace. In cases of childbirth and pregnancy, this period commences at the end of the period specified in Article 74. However, no wages shall accrue for the periods during which the employee cannot report to work due to the suspension of the employment contract.

II- Situations Incompatible with Moral Principles and Good Faith, and Similar Instances:

a) If the employee misleads the employer by asserting that they possess the necessary qualifications or conditions for one of the essential points of the contract at the time it is concluded, despite not possessing them, or by providing inaccurate information or making false statements.

b) If the employee utters words or engages in conduct that assaults the honor and reputation of the employer or a member of their family, or levels unfounded and defamatory reports or allegations against the employer.

c) If the employee sexually harasses another employee of the employer.

d) If the employee assaults the employer, a member of their family, or another employee, or reports to work intoxicated or under the influence of narcotics, or uses these substances within the workplace.

e) If the employee engages in conduct incompatible with integrity and loyalty, such as abusing the employer’s trust, committing theft, or disclosing the employer’s professional and commercial secrets.

f) If the employee commits an offense within the workplace that is punishable by imprisonment for more than seven days without suspension of sentence.

g) If the employee, without obtaining permission from the employer or without relying on a just cause, fails to report to work for two consecutive business days, or twice within a month on the business day following any holiday, or for three business days in a month.

h) If the employee insists on not performing the duties they are obligated to carry out, despite being reminded to do so.

ı) If the employee endangers workplace safety through their own wilful act or negligence, or causes damage or loss to machinery, installations, or other goods and materials owned by the workplace or under their custody, to an extent that cannot be covered by the equivalent of their thirty-day wage.

III- Force Majeure:

The emergence of a force majeure event that prevents the employee from working at the workplace for more than one week.

IV- In the event that the employee is taken into custody or arrested, and the period of absenteeism exceeds the notice period set forth under Article 17.

The employee may apply for judicial remedies within the framework of Articles 18, 20, and 21, asserting that the termination does not comply with the reasons set forth in the clauses above.

Time Limit for Exercising the Right of Immediate Termination

Article 26 – The authority to terminate the contract granted to the employee or employer based on the situations incompatible with moral principles and good faith shown in Articles 24 and 25 cannot be exercised after six business days from the day one of the parties learns of such conduct by the other party, and in any event, after one year from the occurrence of the act. However, the one-year limitation shall not apply if the employee has obtained a material financial benefit from the incident.

The rights of those who terminate the employment contract within the periods prescribed in the paragraph above to claim compensation from the other party due to these circumstances are reserved.

Analysis of the Termination of Employment Contracts and Its Legal Consequences in Employee-Employer Disputes in Light of the Labor Law, Doctrine, and High Court Jurisprudence

When the aforementioned statutory regulations of the Labor Law are examined, the termination of employment contracts by the parties in employee-employer disputes is strictly regulated. Under Article 19, paragraph 1 of the Labor Law, titled "Procedure in termination," it is stipulated that: "The employer must issue the notice of termination in writing and state the reason for termination clearly and precisely." The second paragraph states: "The employment contract of an employee employed under a permanent contract cannot be terminated for reasons related to the employee’s conduct or performance without first obtaining their defense against the allegations. However, the employer's right to terminate the contract in accordance with the provisions of Article 25, paragraph (II) remains reserved." This sets out the formal procedures and principles regarding the employer's termination process.

Furthermore, Article 20 of the Labor Law, titled "Objection to notice of termination and procedure," dictates that if the employment contract is terminated by the employer without stating a reason or if the stated reason is invalid, the employee must apply to a mediator within one month from the notification of termination, seeking reinstatement pursuant to Article 5/A of the Labor Courts Law. If mediation fails, the employee can file a lawsuit before the Labor Court within two weeks from the date the final non-settlement minutes are drafted.

Article 21, paragraph 1 of the Labor Law, titled "Consequences of termination without a valid reason," establishes that if the court or arbitrator rules that the termination is invalid, the employer must reinstate the employee within one month. If the employer fails to do so upon application, they are liable to pay compensation equal to a minimum of four months' and a maximum of eight months' wages. The court or arbitrator determines this compensation amount in the event of non-reinstatement (Art. 21/2). The employee is also entitled to up to four months of back-wages and other entitlements for the period they were kept away from work until the decision finalized (Art. 21/3). These amounts are calculated in monetary terms based on the wage rate applicable at the date the lawsuit was filed (Art. 21/4).

The employee must apply to the employer to resume work within ten business days from the notification of the finalized court or arbitrator decision; otherwise, the termination executed by the employer shall be deemed legally valid, and the employer will only be liable for its standard legal consequences (Art. 21/6). On the other hand, Article 22, paragraph 1, addressing "Alteration of working conditions," states that any fundamental alteration to working conditions arising from the employment contract or workplace practices can only be executed by written notification to the employee. Alterations not accepted in writing by the employee within six business days shall not bind them.

Statutory Forfeiture Period: The 6-Business-Day Rule

Pursuant to Article 26 of the Labor Law, titled "Time limit for exercising the right of immediate termination," the right to terminate based on behavior contrary to moral principles and good faith (Articles 24 and 25) must be exercised within six business days from the date the incident is discovered, and in any event, within one year from its occurrence (unless a material financial benefit was obtained by the employee). This timeframe is a statutory forfeiture period (hak düşürücü süre). Because it concerns public policy, the judge is obligated to consider this period ex-officio (resen), even if the parties fail to raise it during the proceedings.

Any party that exercises the right of immediate termination after these periods have expired will be deemed to have terminated the contract wrongfully (haksız fesih). Consequently, that party will be held liable for labor receivables, including notice pay (ihbar tazminatı) and severance pay (kıdem tazminatı).

In workplaces where the authority to terminate contracts rests with a disciplinary board, if an employee’s contract is to be terminated due to a violation of moral principles and good faith, the incident must be referred to the disciplinary board within 6 business days of its discovery. The Disiplinary Board must prepare an investigation file and obtain the written defense of the employee, allowing them reasonable time to respond. Since a disciplinary investigation inherently requires time, the statutory forfeiture period is suspended during this investigation process. Once the investigation and the defense procedures are finalized, the disciplinary board must complete the termination process within six business days. Failure to do so invalides the termination.

The six-business-day period starts from the day the employee or employer learns of the incident that grounds the termination. The day of discovery is excluded from the calculation; the period expires at the end of the sixth subsequent business day. If the workplace is open on Saturdays, Sundays, or public holidays as part of its ordinary, habitual operations, these days are counted as business days. However, if the workplace is technically open on holidays solely for security services or auxiliary tasks outside its main line of business, those days are not deemed business days.

When a party (employee or employer) terminates the employment contract for just cause, they must state the specific grounds and reasons for the summary termination within the notice of termination. The party asserting termination for just cause bears the burden of proof. Pursuant to Article 6 of the Turkish Civil Code (TMK No. 4721), "everyone is obligated to prove their own claims." Similarly, Article 190 of the Civil Procedure Code (HMK No. 6100) states: "Unless there is a specific statutory regulation in law, the burden of proof rests with the party that derives a legal benefit in their favor from the legal consequences attached to the alleged fact." Therefore, the party claiming a termination for just cause must prove that their actions strictly conformed to the mandatory formatting and timing requirements set forth in Article 26 of the Labor Law.

Fundamental Alteration of Working Conditions by the Employer

Article 22 of the Labor Law No. 4857 stipulates: “The employer may make a fundamental alteration in working conditions to the detriment of the employee—contrary to the employment contract, its annexes, personnel regulations, or established workplace practices—only by notifying the employee of the situation in writing and obtaining their express consent. Alterations not executed in compliance with these formal legal requirements and not accepted by the employee in writing within six business days shall not bind the employee. If the employee rejects the alteration proposal, the employer must explain in writing that the alteration is based on a valid reason or that another valid reason for termination exists. In this case, the employer may terminate the employment contract, provided that they comply with the notice period.”

PRECEDENTS OF THE COURT OF CASSATION AND REGIONAL COURTS OF JUSTICE

COURT OF CASSATION 9th CIVIL CHAMBER

Merits No: 2011/54865, Decision No: 2014/4290 (Date: 12.02.2014)

• THE REQUIREMENT TO EXERCISE THE RIGHT OF TERMINATION FOR JUST CAUSE WITHIN THE SIX-BUSINESS-DAY STATUTORY FORFEITURE PERIOD

• THE SIX-BUSINESS-DAY RULE SHALL NOT APPLY IF THE EMPLOYEE OBTAINS A MATERIAL FINANCIAL BENEFIT

• THE SIX-BUSINESS-DAY STATUTORY FORFEITURE PERIOD COMMENCES WHEN THE COMPETENT TERMINATION AUTHORITY LEARNS OF THE INCIDENT

• THE ONE-YEAR PERIOD IS DETERMINED IN ANY EVENT BASED ON THE DATE THE INCIDENT OCCURRED

• THE SIX-BUSINESS-DAY PERIOD IS NOT REQUIRED IN CASES OF VALID TERMINATION (GEÇERLİ FESİH)

SUMMARY: When just causes for termination arise for either the employee or the employer, the period for exercising the right to terminate the employment contract for just cause is not limitless. In this regard, Article 26 of the Labor Law No. 4857 provides two distinct time limits, taking the date of discovery of the cause and the date of the occurrence of the incident as benchmarks. If a party fails to execute termination within these periods, the termination will not yield the legal outcomes of a termination for just cause. This period is specified as six business days from the date the incident is learned by the other party, and in any event, one year from the date the act was committed.

The six-business-day period starts running from the day the employee or employer learns of the incident justifying termination. Excluding the day of discovery, the right of just termination expires at the end of the sixth subsequent business day. If the cause for just termination is continuous, the statutory forfeiture period does not run (Court of Cassation 9th Civil Chamber, 15.2.2010, Merits No: 2008/16869, Decision No: 2010/3345). For instance, an employee whose wages are unpaid can terminate the employment contract for just cause at any time as long as the non-payment continues.

The six-business-day and one-year periods provided under Article 26 of Law No. 4857 are separate and independent statutory forfeiture periods. In other words, the right to terminate must be exercised within six business days from discovery and within one year from the occurrence of the event. The expiration of even one of these periods strips the party of the opportunity to terminate for just cause. Due to the legal nature of statutory forfeiture periods, the judge is required to take them into consideration ex-officio, even if the parties do not raise them.

T.C. SAKARYA REGIONAL COURT OF JUSTICE 9th CIVIL CHAMBER

Merits No: 2025/898, Decision No: 2025/1471 (Date: 01/07/2025)

• INVALID TERMINATION

• TERMINATION EXECUTED UNDER THE CLAIM OF JUST CAUSE DEEMED UNJUST DUE TO THE EXPIRATION OF THE 6-BUSINESS-DAY TIME LIMIT FOR EXERCISING THE RIGHT OF JUST TERMINATION

• FAILURE TO PROVE VALID REASONS FOR TERMINATION

• THE FACT OF WHETHER THE EMPLOYEE WORKED AT ANOTHER WORKPLACE AFTER TERMINATION IS IRRELEVANT TO THE CALCULATION OF BACK-WAGES FOR THE FOUR-MONTH IDLE PERIOD

SUMMARY: The defendant employer terminated the plaintiff’s employment contract based on just causes stipulated under Article 25/II of the Labor Law. It is understood that the final act of the plaintiff cited in the notice of termination occurred on 22.07.2022, and the plaintiff's defense regarding this incident was taken on 27.07.2022. Since the employer executed the termination after the expiration of the 6-business-day period specified in Article 26 of the Labor Law, it is legally impossible to deem this termination as based on just cause. Regarding termination for valid reasons (geçerli neden), although the law does not prescribe a specific deadline for exercising this right, an evaluation of whether the alleged actions constitute a valid reason reveals that the employer failed to prove that the plaintiff’s conduct caused workplace inefficiencies, disrupted workflows, or rendered the continuation of the employment relationship intolerable. Thus, the termination cannot be deemed valid.

T.C. İZMİR REGIONAL COURT OF JUSTICE 7th CIVIL CHAMBER

Merits No: 2025/245, Decision No: 2025/1305 (Date: 14/07/2025)

• INVALID TERMINATION

• ABSENCE OF A WRITTEN NOTICE OF TERMINATION SERVED TO THE EMPLOYEE

• FAILURE TO PROVE THE CLAIM OF TERMINATION FOR JUST CAUSE

• THE EMPLOYER'S FAILURE TO OBJECT TO THE CBA (COLLECTIVE BARGAINING AGREEMENT) COMPETENCE

• FAILURE TO PROVE TERMINATION BASED ON TRADE UNION REASONS

SUMMARY: Based on the scope of the file, the burden of proving that the termination was based on a just or valid reason rests with the defendant employer. Despite the exit code being reported as 'Code 4' in the social security (SGK) declaration, the defendant employer failed to concretely prove—in accordance with the principles of case law—that the plaintiff's contract was terminated for just or valid causes, particularly since no written notice of termination was ever served to the employee. Consequently, no inconsistency with the facts of the file or the law was found in the local court's judgment regarding the reinstatement of the employee, and the objections raised by the defendant's counsel were dismissed as groundless.

Court of Cassation 9th Civil Chamber, Date: 22/11/2017, Merits No: 2016/30461, Decision No: 2017/18864:

The employer must apply a sanction that is proportional to the misconduct of the employee who violates the employment contract. A sanction that is disproportionate or excessive relative to the committed act cannot be condoned. Ultimately, termination is a severe punishment. Under the principle of proportionality, the measure applied must be capable of achieving the desired objective (suitability), must be necessary for that objective, and the intervention resulting from the measure must not be excessively disproportionate to the intended goal. Under this principle, when deciding whether a termination is valid, the judge will weigh the gravity of the employee's behavior and determine, based on the specific circumstances of each case, whether there is a disproportion (excessiveness) between the employee's conduct and the type of termination chosen by the employer.

REFERENCES:

• Labor Law - Legislation

• Decisions of the Court of Cassation - Court of Cassation

SAMPLE DEMAND AND TERMINATION NOTICE

NOTARIAL NOTICE OF TERMINATION OF EMPLOYMENT CONTRACT FOR JUST CAUSE

Sender / Notifying Party: ................. (TR ID No: .............)

Attorneys at Law: Atty. Mustafa MALGIR - Atty. Mehmet Serhat MALGIR

Mustafa Kemal Mahallesi 2144 Sokak No. 14/6 Beren Plaza, Söğütözü / Çankaya / ANKARA

Addressee / Respondent: ..........................

........................... Çankaya / ANKARA

Counsel for Addressee: .................................

.................................

Subject: Our demand for the notification that our client .............. has terminated their "Employment Contract" pursuant to Article 24, paragraph II / sub-clause (e) of the Labor Law No. 4857, titled "Right of the Employee to Immediate Termination for Just Cause."

Grounds for Notice:

1. From the date our client ................. began working at your company on ............ until the moment they were forcibly removed from the workplace through coercion, duress, and mobbing by the officials of your Regional Directorate, our client has never engaged in any conduct or attitude that violates the "Duty of Care and Loyalty" toward the workplace and the employer. On the contrary, they have fully executed all duties of loyalty.

2. While our client ................. had been serving as an Assistant Manager at your workplace for over a year, they were transferred—without any stated justification—to another business unit located 70 km away from their residence as a "M...... S.....", despite being married. This constitutes a fundamental alteration of working conditions that complicated and aggravated the conditions against the employee. Our client was forced to commute a total of 140 km daily on a motorcycle under hazardous conditions. Although their assignment appears as "M....... S........" in your workplace records, they were underpaid for two months under the status of an Assistant Manager with a deficit of ........ TL, thereby causing severe financial distress. This underpayment constitutes an abuse of right under Article 2 of the Turkish Civil Code (TMK). The employer's core obligation to pay wages in return for labor has been flagrantly violated.

3. On ../../2025, while our client ....../..... was on duty at the workplace, the workplace inspectors audited the premises down to the smallest detail. This audit revealed no inventory shortages, no monetary discrepancies, and no errors or actions attributable to our client that violated the duty of care and loyalty, including returns. This fact is firmly established by financial, bank, and store records.

4. Despite the audit proving that our client performed their duties in accordance with the principles of good faith, they were falsely accused of "theft" under the pretext of a cash deficit. Through insults, mobbing, and severe psychological pressure, they were pressured to sign a forced resignation letter. Furthermore, they were coerced via intimidation, insults, and blackmail into signing a promissory note for an advance payment of ..... TL. When our client resisted and refused to sign, they were forcibly removed from the workplace through duress, effectively forcing them to abandon the premises under threat. During the audit, the store's camera cables were severed to conceal the duress, mobbing, insults, and forced signature attempt perpetrated against our client. This material fact is supported by evidence. We demand that your company’s Board of Inspectors investigate this matter to uncover the material truth.

5. Pursuant to Article 24, paragraph II / sub-clause (e) of the Labor Law No. 4857, forcing our client to work in a distant adjacent zone away from their residence unilaterally altered and complicated the working conditions to their detriment. This falls squarely under the statutory definition of a "Fundamental Alteration of Working Conditions." Our client was forced to commute 140 km daily by motorcycle under high-risk conditions. Despite holding the rank of "M...... S......", they were placed in an unsuitable "Assistant" cadre and underpaid by ........... TL each month. Our client was subjected to systematic pressure and degrading, humiliating remarks by superiors within your company, and was publicly humiliated in front of their colleagues before being wrongfully expelled from the store. For the reasons explained above, we hereby NOTIFY you that our client has terminated their Employment Contract for just cause pursuant to Art. 24/II-e of the Labor Law No. 4857.

6. Due to the wrongful acts and misconduct of your company's personnel, a fundamental alteration was made to our client's working conditions, their wages were underpaid relative to their rank, and they were subjected to systemic mobbing and humiliating treatment. We hereby DEMAND and NOTIFY that the employment exit code of our client ........ be reported to the Social Security Institution (SGK) under the specific code designated for Article 24/II-e of the Labor Law. Your company shall be held fully liable for any damages our client may incur due to any non-compliant declaration.

7. We hereby legally DEMAND and NOTIFY on behalf of our client .................. that all outstanding labor rights and receivables—including unpaid salary balance, unused annual leave pay, overtime wages, severance pay, National Holiday and General Holiday (UBGT) pay, Minimum Living Allowance (AGI) differentials, notice pay, bad-faith compensation due to mobbing, and the salary differences resulting from cadre discrepancies—be paid to us as their attorneys. Otherwise, legal proceedings will be initiated against your company, and all litigation expenses, court fees, and statutory attorney fees will be charged to your party. Dated: ...../...../2025

Notifying Party / Sender Demanding Termination:

.............

Attorneys for the Sender: Atty. Mustafa MALGIR - Atty. Mehmet Serhat MALGIR

Secure E-Signature

ANNEX: Power of Attorney

To the Attention of the Public Notary:

We respectfully request that one copy of this notice, which consists of two pages and three original copies prepared by us outside your notary office, be served upon the addressee, that a copy bearing the certification of service be delivered to us, and that a certified copy be preserved in your notary archives.