Code of Ethics and Working Principles

Article 1: Purpose and Scope

Company Code of Ethics and Working Principles, Çates Elektrik Üretim A.Ş. ("Company" or "Company") and the rules that all third parties and employees acting on behalf of the Company must comply with, employee rights, as well as company ethical evaluation and basic principles.
Ethics, in its simplest sense, examines value judgments that are generally valid and universally accepted in human relations. Business ethics covers the set of principles developed to guide behavior in the business world.
The Company's core values ​​and principles guide our business ethics rules and form our expectations, standards and ethical practices that form the basis of all our business relationships and transactions.

Article 2: Responsibilities of Employees

Honesty and integrity of employees are necessary to maintain the reputation, reliability and success achieved under the role modeling of the company management. Unethical behavior or behavior that does not comply with business principles is never accepted or tolerated. It is the duty of every employee to protect the reputation and success of the Company.
Each employee must work at the highest professional level in order to meet internal and external customer needs within the scope of the work under his or her responsibility. In addition, employees work efficiently; He/she must contribute to his/her own goals, the goals of the department and the company he/she is affiliated with, and to meet customer needs.
Especially every employee;
(i) While performing their duties, they must act within the framework of basic moral and human values ​​and in line with institutional strategies,
(ii) Act with integrity and reliability; establish and maintain equal interpersonal relationships; Must cooperate with other employees towards common goals and use company assets and resources effectively, efficiently and respectfully,
(iii) Must exhibit behavior and business ethics in accordance with the “Ethical Rules and Working Principles” announced throughout the institution, read and understand all the principles of the institution and comply with these principles,
(iv) While performing the assigned duties, must comply with all laws, principles and applicable statutes and regulations issued by the relevant regulators (Energy Market Regulatory Board, Capital Markets Board, etc.) and professional institutions and organizations of which the Company is a member,
(v) Avoid unfair competition in all transactions and relations with other financial institutions within the framework of fair competition principles,
(vi) We must not forget that being open, complete and accurate to all stakeholders is part of our identity and reliability, and must always act in a way that enhances the reputation of the Company. Every employee must show the necessary common sense and effort while performing his/her duties, take into account the principles of profitability and efficiency, and avoid any action or transaction that may cause harm to the institution. It should not be forgotten that behavior that violates or exceeds the limits of the "Code of Ethics and Working Principles", which are seen as the guarantee of the reputation of the institution, may lead to ethical review or disciplinary investigation. The institution expects managers and all employees to make judgments in accordance with our "Code of Ethics and Working Principles" while carrying out their work. It is important for managers and all employees to frequently refer to these rules, to frequently confirm that they are proceeding in accordance with what is written in the "Ethical Rules and Working Principles" guide and the purposes for which it was written, and to fulfill their duties in the most effective and correct way in line with the corporate objectives.
As an institution, the rules expressed in this guide do not provide complete answers to every question and every situation. In such cases or with any questions or thoughts you may have regarding the "Ethical Rules and Working Principles", you can contact the Ethics Committee Representative and Human Resources Management.
The communication channel established for your questions regarding the "Code of Ethics and Working Principles" and to report those who violate the "Rules of Ethics and Working Principles" or suspicious situations that will reduce our reputation is as follows:
Email: etik@cates.com.tr
Phone: 0850 575 0 575
Mail: To the "Ethics Committee Presidency" with the address Muğla on our company's website

Article 3: Confidentiality

Article 3.1: Ensuring Confidentiality Within the Institution
Our employees;
(i) Each employee is obliged to comply with the details specified in the Aydem Information Security Procedure and relevant legislation regarding information security.
(ii) Except for the disclosure of information and documents requested by authorized persons or institutions specified in the law and other legal regulations, it is strictly prohibited to use the personal and financial information of customers, suppliers, an employee for purposes other than unauthorized / business purposes.
(iii) They cannot share the information they have learned and the documents they have as part of their work with unauthorized persons and authorities within or outside the institution for any purpose, and they cannot use them directly or through a third party for speculative purposes.
(iv) The projects, technical infrastructure, regulations, etc. that they have developed due to their duties. knows that the works are the property of the Company; They cannot, under any circumstances, take these or similar studies out of the institution without obtaining the written approval of the relevant Company's senior executive.
(v) They do not share their personal rights, which should only be known to them, with other people inside or outside the institution.
(vi) They avoid criticism regarding the Company's general policies that would damage the company's reputation.
(vii) They cannot discuss matters related to their duties outside of their duties, and they cannot cause any speculation or situation that may lead to negative evaluation.
(viii) In case the employee leaves his/her position in the company for any reason, the responsibility to protect personal and financial information of customers continues. It is prohibited to take confidential information out of the institution, share it with third parties, or use such information for personal purposes outside the institution.

Article 3.2: Protection of Customers' Personal Information
It is very important for the reliability and reputation of the Company that our employees comply with professional conduct standards that ensure the confidentiality of relations and information between the institution and its customers. Discussing or discussing confidential information about customers or transactions outside of normal business activities and in public areas where third parties may hear may result in a violation of this confidentiality.
Personal information accessed by our employees for work purposes must be used in accordance with the Personal Data Protection Law (“KVKK”) and the legislation supporting this law, company policies and procedures. The use of information arising from their duties or internal authorities is limited to situations strictly necessary for the Company's legitimate and appropriate business objectives.
Consumption, address and identity information of eligible consumers should never be shared for the benefit of other retail / wholesale electricity sales companies.
Additionally, information about how our day-to-day business operates (such as our strategic plans and products) and non-public information about customers should be used with caution and care. Even the slightest hint on this subject may cause misunderstandings.
The Company's obligation to maintain the confidentiality of information continues even in the event of resignation for any reason.

Article 3.3: Information on Company Ownership
Non-public information, transactions, computer software, technical information, materials, records, files, documents, programs, reports, reviews, data, customer lists, trade secrets and all other information regarding the Company's customers and other third parties are the property of the Company and are not disclosed outside of business. cannot be used. Our employees cannot disclose this information to any third party. Under no circumstances can this information be made known or disclosed to any competitor or any third party during or after the service.
Equipment and items provided by the company to its employees as part of their duties are not considered personal belongings. In addition, the company reserves the right to monitor employees' user accounts and the electronic means of communication assigned to them for work, such as e-mail, telephone, computer systems and other electronic records, based on existing laws.

Article 3.4: Storing Information
It is our employees' responsibility to be aware of all policies regarding the secure handling, distribution, transportation, storage or disposal of information. All our employees are obliged to act in accordance with the provisions of the "Information Security Policy" published / to be published by the institution, except for the matters stated below.
As a Company employee, we are expected to comply with these basic policies:
Restricting Access to Confidential Information
(i) All computer access must be limited to information necessary to perform daily tasks. If there is a need to share information with people outside the company, this issue should be questioned in detail and, if necessary, the situation should be discussed with the Information Security Management and the relevant Ethics Committee Representative.
(ii) When sharing information with authorized persons, the required information must be provided at the required level.
(iii) Confidential information must be stored in locations visible and accessible only to authorized persons. When not in active use, documents containing confidential information should be stored securely in a drawer or cabinet and should not be left in fax machines, printers or other unsafe places.
(iv) When distributing such information within the organization, envelopes marked “Personalized” should be used. Protecting Information on Computer Hardware
(i) Laptops and other portable devices are highly susceptible to theft. Such portable devices (computer, tablet, radio, mobile phone, etc.) should not be left in unsafe places. In case the device belonging to the employee is lost or stolen, Information Security Management and Human Resources Management should be notified as soon as possible.
(ii) Our employees must lock their computers or log out of the system before leaving their computers unattended.
(iii) User IDs or passwords are personal and should not be shared with anyone. Our employee may be held responsible for any use of the user ID or password, including any unauthorized use, and for any corporate damages that may be caused by any abuse that may occur. In cases where user ID or password is suspected to be compromised, passwords should be changed and Information Security Management should be contacted.
(iv) The configuration of the anti-virus program of the computer provided by the Company cannot be changed. It is our employee's responsibility to protect the computer allocated by the Company from computer viruses sent to the employee from outside the organization and that may reveal company information.

Article 4: Internal and External Relations of the Company

Article 4.1: Relations with the State and Public Institutions
Within the scope of this article, the principles set out in Article 5.2 of the Bribery and Corruption Policy apply.

Article 4.2: Relations with Customers, Suppliers and Other External Organizations
Our employees act within the framework of the principle of integrity in their relationships with customers, shareholders, affiliates and other companies, representing the company.
As a company, our main goal is to meet customers' needs. Customer satisfaction determines the success or failure of our organization and therefore; Our customers are the most important part of our business. Since ensuring customer satisfaction is the best advertising tool we can achieve, customer relationship management in the Company; It is based on the principles of professionalism, courtesy and, more importantly, seriousness and reliability. Honesty, equality and compliance with the law should be kept at the highest level in customer relations. Employees must provide customers with full and clear information about company products and services. Employees do not have the right to provide false information in order to make higher profits. Our customers are clearly informed about their rights and obligations in their transactions with the Company and the benefits and risks of the products and services offered to them. Therefore, our employees have a responsibility to be well-equipped regarding both the Company and the services and products provided by the Company and its subsidiaries.
Sales or communication techniques that are incompatible with professional ethical rules, provide incorrect or incomplete information to the customer about the product or service, or attempt to force the customer in the decision process cannot be used. In addition to the interests of the institution in the activities carried out within the free market economy, employees; In general, they avoid behaviors that create unfair competition within the framework of the principles of maintaining trust in the energy sector, making efforts for the development of the sector, and observing common interests. Employees also do not express positive or negative opinions or make comments regarding competing organizations and their products and services during their duties.
The company avoids practices that create unfair competition, such as abuse of dominant position in the industry, price determination by creating a cartel, price discrimination and price fixing, barrier to market entry, violation of market transparency and industrial espionage.
Relations with suppliers are also based on the rules mentioned above.
Confidentiality conditions in relations with individuals or organizations from which consultancy services are received should be clearly guaranteed with a contract. However, the ability of personnel whose employment in the company has expired to work temporarily as a consultant is subject to the proposal of the relevant business unit manager, the evaluation of the Human Resources Director and the approval of the General Manager.
Any Company employee cannot make any real or apparent commitment on behalf of the Company, formally or informally, without authorization in accordance with approved procedures, and cannot work with those who harm public morals or harm the environment and public health.
All company employees must avoid any activity, practice or action that would violate competition law, especially abuse of dominant position.

Article 4.3: Media Relations
In the Company's relations with the press, our employees must avoid situations that may lead to any speculation, negative evaluation regarding the institution, and practices and behaviors that may harm the trust, reputation and stability of our institution or the sector or create unfair competition. In public and in areas where listeners think we are speaking on behalf of our company, we express only the views of our company, not our own.
Press relations regarding the entire company are carried out by the Corporate Communications Department. All external relations are carried out within the procedures determined by the company. All requests, interview requests and all questions from written and verbal media must be immediately transferred to the Corporate Communications Directorate in the Company. Prior approval must be obtained from the Corporate Communications Directorate regarding all contact information to be provided to third parties. Only authorized individuals may communicate about the company and its policies, practices and procedures.
In our posts on social networking sites, blogs, dictionaries, forums, and e-mail groups, we avoid expressions that would give the impression that third parties are sharing on behalf of the Company.
In addition, the "Aydem Digital and Social Media Management Procedure" published to represent the corporate structure through social media is essential.

Article 4.4: Conflicts of Interest
The company does not prevent its employees from engaging in external activities that will not cause them to neglect their in-house responsibilities, will not restrict them from acting in accordance with the interests of the institution, and will be in compliance with the declared "Code of Ethics and Working Principles". However, our employees participating in such activities must avoid possible or actual situations that conflict between the interests of the company and their own interests.
“Conflict of Interest” occurs when an employee's personal interest and the company's interest interfere with each other. For example, an employee's responsibilities or obligations in a situation that is in his own interest outside the organization or in his private life may make it difficult for him to fulfill his responsibilities and duties related to his position in the company objectively / impartially and effectively. Conflicts of interest may also arise when a family member of an employee receives a personal benefit through his or her position at the company. Any transaction or relationship that may create a conflict of interest must be reported to the affiliated Ethics Committee Representative.
In order to prevent possible conflicts of interest, our employees;
(i) They avoid causing situations that would create a conflict of interest or the impression in favor of themselves or their relatives, and they do not take part in the decision-making process on matters that concern their or their relatives' interests. (ii) They do not enter into any personal financial relationships with customers and suppliers, nor do they obtain personal benefits by using business relationships.
(iii) They do not allow gifts or offers of interest that may affect their decisions and consent or create a conflict of interest.
(iv) They use the Company's assets and resources efficiently and solely for the benefit and benefit of the institution. (v) They use their time and effort for the institution, do not undertake any other responsibilities that would create a conflict of interest, and do not work for another natural or legal person outside the company.
(vi) In their relations with public institutions and organizations, they act in line with the principles of honesty and transparency and maintain distance and impartial relations.
(vii) They protect corporate and customer secrets and do not take out corporate-specific information that provides competitive advantage.
(viii) They do not use the information they have obtained as part of their duties in a way that would lead to unfair gain.

Article 4.5: Institutional Opportunities
Our employees at all levels must show the necessary common sense and effort while performing their duties, take into account the principles of profitability and efficiency, and avoid all actions and transactions that may cause damage to the company. Our employees are obliged to use these legal business opportunities when any opportunity arises in favor of the institution.
Employees cannot make decisions or engage in activities that are contrary to the interests of the company or incompatible with the responsibilities of the employee. If a potential conflict arises, the employee must immediately report the situation to the Ethics Committee Representative.
Our employees; They must refrain from not taking advantage of any opportunity that may be beneficial to the Company, obtained by using the Company's property or information, or obtained as a result of their position in the Company, because it is contrary to their own interests, or to prevent other employees from doing so.

Article 4.6: Borrowing Prohibition
Our employees must not, under any circumstances, borrow money from customers or third parties, provide benefits, or enter into a suretyship relationship during or in connection with the performance of their duties.
Our employees should manage their private and financial affairs responsibly and should not be burdened with debts that they cannot pay. Our employees must display a balanced and harmonious attitude both in their professional lives and their personal financial situations.
Between company employees in subordinate and superior relationships and among company employees; They are prohibited from entering into debt-credit relationships with customers, suppliers and contractors.

Article 4.7: Bribery
Within the scope of this article, the principles set out in Article 5.1 of the Bribery and Corruption Policy apply.

Article 4.8: Political Activities
Within the scope of this article, the principles set out in Article 5.2 of the Bribery and Corruption Policy apply.

Article 4.9: Political Donations
Within the scope of this article, the principles set out in Article 5.5 of the Bribery and Corruption Policy apply.

Article 4.10: Acceptance of Gifts
Within the scope of this article, the principles set out in Article 5.4 of the Bribery and Corruption Policy apply.

Article 5: Transactions

Article 5.1: Accuracy of Records
Within the scope of this article, the principles set out in Article 5.8 of the Bribery and Corruption Policy apply.

Article 5.2: Employees' Stock Transactions – Insider Trading (Information Abuse)
It is natural that our company has certain expectations from its employees within the framework of the duty of loyalty and the principles of protecting the company's interests. In the context of these expectations;
It is possible for employees to carry out investment transactions with the Company's shares on the stock exchange, under the conditions specified in the Capital Markets Board regulations. However, employees are aware that trying to obtain any benefit, including directly or indirectly buying and selling shares on stock exchanges, by using any confidential information belonging to the Company or giving it to third parties, will constitute insider trading and that these behaviors are criminalized by law. They know they are accepted. Internal procedures established to implement the Capital Markets Board regulations are implemented with precision. Employees included in the list of "persons with inside information" are expected to be in full compliance with the relevant legislation, company policies and procedures.
Except for the persons specified in the above-mentioned circular, employees of the Company can participate in public offering transactions made by both companies within the Company and other intermediary institutions.

Article 6: Company Resources

Article 6.1: Use of Company Assets and Resources
Any goods, assets, equipment, vehicles, computers, computer programs and the like owned by the Company and provided to employees to carry out daily business may not be used by any employee for personal benefit or the personal benefit of anyone else.
The Company's telephones, personal computers, photocopier and fax machines, supplies, postal service, e-mail, bulletin boards and meeting rooms are primarily for company use. Using the specified resources or other company resources for personal purposes may disrupt the flow of very important information.
Company phone and company address, e-mail, internal communication and messaging systems should not be used for personal correspondence and meetings. Private phone calls should be kept short.
We take into account the interests of the institution in the use of resources on behalf of the company and its subsidiaries, and we show sensitivity in protecting company assets. We avoid loss, damage, misuse and waste of assets of the Company and its subsidiaries. We do not use company assets and facilities outside of company business, under any name and for anyone's benefit, without the benefit of the company. In cases of public interest or obligation, the approval of the General Manager of the relevant business unit is required.

Article 6.2: Use of Technology
The Company Internet and Intranet system is for business transactions, communications and research. It cannot be used for purposes other than these (watching TV series / movies, etc.) and/or for obscene, pornographic or terrorist purposes. Additionally, employees should not install and use unlicensed software on company computers. In no way, via mobile devices belonging to the Company; Messages that are abusive, threatening or that will damage the reputation of the institution cannot be sent.

Article 6.3: Taking Assignment Outside the Institution
Employees cannot, directly or indirectly, engage in work that requires them to be considered merchants or tradesmen ("commercial enterprise" or "tradesman enterprise"), they cannot serve as board members or auditors in companies other than the Company and its subsidiaries without the written approval of the top manager, and they cannot act as a member of the board of directors or auditors of real and legal persons. They cannot work in any commercial business, paid or unpaid, without obtaining written approval.
Employees may receive offers to participate in external events as paid or unpaid speakers or consultants, based on the experiences they have gained throughout their business life. Such opportunities should be evaluated by the senior executive of the relevant business unit and the Director of Corporate Communications to determine whether any conflicts between personal and corporate interests exist.

Article 6.4: Business-Related Communications and Records
All communication, whether written or verbal, must be conducted in a professional manner and in accordance with our code of ethics. What we say, write and do must clearly reflect the Company's ethical values ​​and expectations and indicate the existence of sound personal judgment. Exaggeration, misdirection, pompous language, overly shorthand expressions, legal speculation, and disparaging remarks and attitudes towards people, companies and their products and services should always be avoided.
Everything employees say, write and do should aim to protect and reflect the integrity and reputation of the Company. This policy applies to all forms of communication, including voicemails, emails, official memos and reports.

Article 6.5: Email
Email is an important method of internal and external communication. E-mails are records that can only be disclosed if required by legal processes, otherwise they must be kept strictly confidential. No e-mail that does not comply with our ethical standards should be written or sent in any way.
All e-mails should be written in a professional manner and be considered legal records. The transmission of any message must occur in compliance with all policies and must be protected against unauthorized access.
Below are the basic rules to use when using e-mail:
(i) E-mail is used when business requires.
(ii) When preparing an e-mail, it should be taken into account that it is a document that can be viewed as a written record, therefore respectful, clear, honest and precise expressions should be used. Exaggerated, frivolous language or slang expressions or derogatory words should not be used in the e-mail content.
(iii) Reply messages must contain sufficient information to avoid misunderstanding. Communication via email must comply with our ethical standards and policies, its nature and purpose, and each message must be carefully reviewed before being sent.
(iv) Our standards for information protection and security also apply to email communications. Because e-mail messages are sent outside the company over public networks such as the internet, they may be intercepted or misdirected. Therefore, great care must be taken to ensure that it does not contain information that could be used to harm the company, its customers, employees or any of its shareholders.
(v) If confidential information must be transmitted via the internet, it must be sent using a secure (encrypted) email facility. Work-related “Top Secret Information” should not be sent outside the organization by e-mail.
(vi) To reduce the risk of disclosing customer information, if a customer sends an email that contains personal information, that information should be deleted from the email response.
Email facilities should not be used for:
(i) Transmitting or storing messages that may be perceived as offensive, derogatory or hostile,
(ii) Transmitting or storing virus warnings or joke messages (Information Security Management should be informed about these warnings),
(iii) Engaging in communication or activity that may harm the Company or any of its customers or shareholders,
(iv) Transferring chain messages containing expressions of protest, aid or exploiting human emotions to others (those who send such messages should warn and the Ethics Committee Representative should be notified that there is such a chain message in the system),
(v) Transmitting messages that will negatively affect the system capacity, including attached files containing games, sounds and images that are not business-related, for entertainment purposes,
(vi) Chatting via messaging programs during business hours; e-mail and messaging reach the level of neglect of work.

Article 6.6: Monitoring Employee's Use of Email and Other Systems
The Company reserves the right to monitor whether the e-mail, computer files or systems allocated to its employees are used for their intended purpose.
The Company has the right to monitor all communications made via e-mail and to intervene and read them when necessary. All kinds of document, contract theft, unauthorized photography, questions asked to employees for the purpose of leaking information are considered as security violations. The employee accepts this practice in advance. If the data / information security breach occurred by a company employee; Disciplinary provisions are applied to the relevant person and the responsible person who was negligent in the incident. If it is committed by a person or institution outside the company; Legal action is taken when deemed necessary.
Within the scope of ethical review and disciplinary investigation activities; If deemed necessary, the Internal Audit Unit is the only unit authorized to review the device and software records (notebook, external data storage device, mobile phone, tablet, e-mail, Skype, SMS, etc.) provided to the relevant personnel by the Company for use. Relevant records may be subject to review by the Internal Audit Unit upon written request from the Information Technologies Directorate. This authority cannot be transferred to another unit and the data cannot be shared with third parties within or outside the company.

Article 7: Respect at Work and Business Life

Article 7.1: Acting Respectfully and Considerately in Our Relationships with Others
As a company, our main goal is to approach our employees with respect, consideration and understanding and to create an environment that will contribute to full communication at all levels. We encourage open discussion of business problems and finding solutions to these problems.
To develop team spirit within the company; Protecting and improving the corporate company identity should be adopted as a common goal. All our employees are responsible for creating and maintaining an atmosphere in the workplace that is compatible with all the values ​​stated in this guide.

The company is based on race, religion, nationality, gender, sexual orientation, marital status, age, seniority, family, etc. It provides employment opportunities to people who are diverse in different aspects. Our employees are required to value this diversity and conduct their relationships with each other in line with the principles of mutual respect, justice, courtesy, honesty and equality. Company personnel should not disturb each other in common areas reserved for employees (including the use of service vehicles). In these areas, posters, handwritten notes and notes should not be hung, except for those permitted by the management, and goods and services should not be sold.
An employee may be contacted by another employee, either directly or by phone, e-mail, etc. Harassment through indirect means such as this is also unacceptable. Harassment includes, but is not limited to, the behaviors listed below.
(i) Describing members of a particular group in derogatory terms,
(ii) Negative classifications, derogatory jokes, offensive statements,
(iii) Pictures or caricatures that are derogatory or mocking of a particular group or person,
(iv) Any derogatory remarks or physical attacks that affect the relationship between employees by creating an uneasy and hostile work environment,
(v) Physical or verbal behaviors other than the distance relationship required by the work environment, promotion at work due to the sexual choice of the employee, performance evaluation, cooperation with colleagues, etc. establishing or threatening ties between
(vi) Any unwelcome sexual advances, sexually explicit overtures or other remarks, or similar gestures. No accusatory and/or vindictive behavior can be taken against employees who report harassment or inappropriate behavior in the work environment to the relevant management and/or the Ethics Committee Representative. Additionally, our managers are required to manage such situations confidentially.
In case of harassment or aggressive, accusatory attitude and behavior of the type mentioned above, a problem occurs within the institution that causes a decrease in workforce and performance, or if any of our employees thinks that they have been exposed to similar behavior by their colleague, manager or customer, the Ethics Committee Representative and Human Resources Resources Management should be informed.

Article 7.2: Our Principles on Harassment and Mobbing
Any violation of immunity through physical, sexual and/or emotional harassment against our employees or our stakeholders with whom we have a business relationship by our employees, at the workplace or anywhere they are for business purposes, will not be tolerated. Possible negative attitudes and behaviors towards people who report such violations or assist during the investigation are considered a violation of our ethical rules.
Systematic and planned behaviors that aim to alienate the targeted person from work, reduce his performance, or cause him to resign, which can be considered within the scope of psychological mobbing, are not tolerated.

Article 7.3: Attitude / Behavior and Appearance
Company employees must dress in a clean, attentive and professional manner in their working environment; Must be friendly, caring and respectful towards everyone.
Employees must represent the Company, an institution of trust, in the best possible way with their behavior and appearance. This principle is extremely important in terms of improving customer relations and increasing the reputation of the institution and must be fulfilled meticulously.
Creating team spirit within the company, protecting and improving the company image is the common goal that plays an important role in the workplace and in the private life of each employee. A balanced and harmonious attitude must be displayed professionally and financially in order to prevent negative reflections on the work done and/or the image of the company.
External relationships must also demonstrate equal respect for customers, potential customers, shareholders and the communities served. This requires providing courteous service, ethical business conduct and compliance with all laws and regulations. As a customer-focused institution, Company employees have a responsibility to act in a way that creates positive impressions about the Company.
Employees must adhere to high standards of integrity in the conduct of their daily work and strive to perform their job to the best of their ability to ensure that company goals and objectives are achieved. He/she must use the time correctly during his/her working hours and ensure that his/her personal work is short-term so as not to disrupt customer transactions.

Article 7.4: Ensuring Intra-Company Hierarchy
The development of employees has a great contribution to the company's achievement of its goals. Managers should manage employees based on professional criteria and provide equal development and reward opportunities to all employees in connection with their contribution to the company's success. Managers who coordinate specific jobs or departments must exercise the powers designed for their job with balance, impartiality and taking into account the personal dignity of staff. Our managers must refrain from abusing their positions and responsibilities for any purpose and from doing or having others do anything beyond their authority. Our managers must continually support employees' professional development.
Within the framework of honest and prudent management principles, managers are responsible for proposing and implementing management styles that will increase the company's values, provide maximum profit to the Company and protect the rights of employees in the long term.
Employees should work to ensure maximum cooperation with their managers, avoiding behavior that is incompatible with working principles.
As a general principle, our employees are responsible for carrying out the instructions of their superiors. However, it is not obliged to carry out instructions that may harm the profitability, efficiency and reputation of the Company or that are not in accordance with the company's principles and legislative provisions on the subject. An employee who believes that the instructions are contrary to legal and/or internal regulations or harmful to the company reports this opinion to the senior manager who gave the instruction and to the Ethics Committee Representative. If the employee who fulfills the instruction believes that the action he/she has taken pursuant to the instruction constitutes a crime clearly stated in the relevant laws and regulations and/or will cause damage to the company, he/she must report the situation to the Internal Audit Unit without delay.
Relationships between different job levels should be regulated within the rules of mutual loyalty and respect created by the hierarchy - within the company and in a manner that respects the company's values ​​and goals.

Article 7.5: Work of Kinship Relatives
Colleagues who are related to the following degree cannot be assigned to report directly to the same manager in any department of the company.
(i) Spouse, mother, father and children, siblings, uncles, aunts and their spouses and children,
(ii) Your spouse, mother, father, sibling, uncle, aunt, and their spouses and children.
All transactions involving family members and relatives of employees are carried out by other employees who are not involved in the transactions in question.
At the same time, in order to ensure maximum transparency in all affairs, our employees must inform the Human Resources Management if one of their family members (in case of blood relation) has or has a connection with the company.

Article 7.6: Attendance Obligation
Our employees are obliged to take care to comply with the working hours determined for the workplace they work in and to use the personnel attendance control system (card reading, fingerprint reading, etc.) at entrance and exit. It is essential that the employee is on-site during working hours.
An employee who leaves his/her place of duty for any reason must inform his/her manager or his/her closest colleague about the place of visit.
An employee who must be outside the organization due to his/her duty must inform his/her manager about the destination and the hours he/she will spend outside.

Article 7.7: Sharing Information with Colleagues – Obligation to Transfer/Deliver
An employee who leaves his job permanently or temporarily cannot leave his job unless he hands over the money and monetary values, documents, tools and equipment that he has to keep and use. This principle also applies to those who are temporarily assigned to another position.
If the company suffers any damage due to failure to fulfill the duty of transfer and delivery, those who caused it will be held responsible.

Article 7.8: Equal Opportunity / Providing Equal Opportunities in Employment
The company aims to create a working environment that values ​​each individual's talents and experiences, respects differences, and gives each employee a voice in their ideas and opinions.
Respecting differences is not only the right way to do our job, it is essential to the success of our business.
The company does not allow discrimination among its employees. It ensures that all personnel practices are carried out based on individual ability and merit, regardless of race, religion, color, age, gender, national origin or ancestry, sexual preference, physical disability, seniority status or other factors determined and protected by law. These practices include, but are not limited to, recruitment, selection, performance management, training, placement, transfer, promotion, disciplinary action and termination of employment.

Article 8: Workplace Safety and Health

Article 8.1: Occupational Health and Safety (OHS) and Environmental Protection
The company is obliged to provide maximum OHS conditions to all its employees, provide training and deliver its equipment. Likewise, employees are obliged to fully participate in relevant training and take all precautions regarding the issue. All employees must notify their managers in writing/verbally and/or by filling out “Near Miss” forms about possible hazards they see in their workplace. It is the responsibility of process owners related to OHS and human resources management to share the lessons to be learned regarding work accidents in the field. Employees are obliged to comply with the Company's Occupational Health and Safety and Environmental Policies and the details specified in the relevant legislation.
OHS incidents are reported to the relevant authorities in a transparent manner and in accordance with the legislation and company policies / principles.

Article 8.2: Carrying / Possession of Weapons
Employees, customers and visitors are prohibited from carrying weapons in work areas, except for those who have to carry weapons due to their duties (Security Guards, etc.).
During checks at building entrances, our colleagues must carry out the necessary checks, regardless of title.
Carrying weapons for special reasons and armed entry of visitors is only possible with the permission of the Human Resources Management.

Article 8.3: Substance Use
The use of any substance (alcohol, drugs, etc.) that will affect our employees' work performance or endanger workplace safety is strictly prohibited. This prohibition also includes being under the influence of these substances that will adversely affect the employee's job performance upon entering the Company premises.

Article 8.4: Betting and Gambling
Employees cannot engage in activities such as betting or gambling that are defective and that may damage the reputation of the Company in the public eye.
Organizing or participating in any type of gambling activity, such as providing gambling equipment, organizing any type of raffles or games with prizes for goods or money, or buying and selling tickets for such games, is prohibited for all employees.

Article 9: Scope and Rules of Application
Company Code of Ethics and Working Principles have been published by the Board of Directors and are reviewed once a year in line with needs, changing conditions and current practices.

Article 9.1: Violation of the Code of Ethics and Business Principles and its Consequences
Our Code of Ethics and Business Principles are the main factors of our reputation and continuous success in the sector. Violation of these rules and principles may negatively impact our reputation and success in the industry. Therefore, behaving unethically, contrary to our principle of honesty, or going against business principles falls within the scope of ethical review or disciplinary investigation. All our employees must act in accordance with these rules. Our employees must carry out their responsibilities in accordance with the applicable written laws, regulations, legislation and general trends. Our employees cannot engage in any illegal activity or inform anyone in this way while carrying out their responsibilities in the company or doing their daily work.
Any violation of the law, corporate policies, or ethical rules, such as failure to cooperate with an investigation, may be subject to ethical review or disciplinary investigation.

Article 9.2: Duties and Responsibilities of the Ethics Committee Representative
Ethics Committee Representative;
(i) To provide guidance and consultancy on questions and issues submitted by employees regarding ethics within the company,
(ii) Referring ethical nonconformities that cannot be resolved within the company or whose resolution requires ethical review or disciplinary investigation to the Ethics Committee,
(iii) To contribute to the resolution of internal ethical non-compliances received by the Ethics Committee, in line with the request of the Ethics Committee,
(iv) Reporting ethics-related questions and nonconformities that come to it, together with their consequences, to the Ethics Committee regularly or when requested,
(v) Being the contact person from the company in ethical reviews and investigations requested by the Ethics Board and providing the necessary support to the reviews and investigations carried out by the Internal Audit Unit,
(vi) Responsible for monitoring and monitoring the effectiveness of the ethical practices carried out in the Company and supporting the practices.

Article 9.3: Duties and Responsibilities of Managers
Company managers have additional responsibilities beyond those defined for employees within the framework of the Code of Ethics and Working Principles. Accordingly, managers;
(i) Ensuring that a company culture and working environment that supports ethical rules is established and maintained,
(ii) Setting an example with their behavior in the implementation of ethical rules and training their employees on ethical rules,
(iii) Supporting its employees in communicating their questions, complaints and notifications regarding the rules of ethics,
(iv) To provide guidance on what needs to be done when consulted, to take into account all notifications made and to forward them to the Ethics Committee as soon as possible when deemed necessary,
(v) He/she is responsible for ensuring that the business processes under his/her responsibility are structured to minimize risks related to ethical issues and for applying the necessary methods and approaches to ensure compliance with ethical rules.

Article 10: Resolution of Incompatibilities

Article 10.1: Ethics Committee Organization
Incompatibilities on ethical issues are resolved within the Company Ethics Board.
The Ethics Committee structure is specified in the Ethics Committee and Disciplinary Committee Structure and Working Order Procedure.

Article 10.2: Notification of Violations and Ethics Committee Working Principles
The Ethics Committee carries out its work within the framework of the principles set out below:
(i) Keeps notifications and complaints confidential, as well as the identity of those making notifications or complaints. It adopts a policy to prevent possible retaliatory attitudes and behaviors towards employees or individuals who report ethical violations.
(ii) Conducts investigations and investigations within the rules of confidentiality.
(iii) It has the authority to request information, documents and evidence related to the examination and investigation directly from the existing unit.
(iv) It may examine any information and documents it obtains, limited only to the subject of the investigation.
(v) The review and investigation process is linked to a written report from the beginning. Information, evidence and documents are added to the report.
(vi) Notifications subject to review and investigation are handled promptly and the result is reached as quickly as possible.
(vii) The decisions taken by the Board are put into practice immediately.
(viii) The relevant departments and authorities are informed about the result.
(ix) The chairman and members of the board act independently and without being influenced by the department managers to whom they are affiliated and the hierarchy within the organization, while performing their duties on this matter. They cannot be pressured or suggested on the subject.
(x) The Board may seek expert opinion if deemed necessary and may benefit from experts by taking measures that will not violate confidentiality principles during the review or investigation.