Anti Bribery And
Anti Corruption Policy

ANTI-BRIBERY AND ANTI-CORRUPTION POLICY

1. PURPOSE AND SCOPE

The Anti-Bribery and Corruption Policy aims to establish the principles and prevention policy for combating bribery and corruption at TURK Elektronik Para A.Þ., ensuring the integrity and reputation of TURK Elektronik Para A.Þ. at a level encompassing its personnel and officers. This policy applies not only to employees but also to all members of the board of directors, consultants, and external service providers such as support service providers

MADDE 2 - DEFINITIONS

Institution:TURK Elektronik Para A.Þ,

Bribery:Activities such as a person influencing the workflow by performing, not performing, expediting, or slowing down a task directly or through intermediaries, and obtaining benefits by agreeing with a third party, as well as other benefits included in the following activities.

Corruption: The abuse of authority, directly or indirectly, based on one's position, within or outside the organization, to obtain or maintain any kind of tangible or intangible financial or non-financial gain by demanding, offering, promising, giving, or accepting a bribe or any other form of illegal benefit, whether in cash, gifts, or any measurable or immeasurable form.

.Cash payments,

. Donations to political parties and charities,

. Commissions received,

.Social benefits granted in an unequal manner and in violation of internal regulations,

.Gifts

Board of Directors: Board of Directors of TURK Elektronik Para A.Þ.

3. KEY ISSUES FOR THE PREVENTION OF CORRUPTION

Since bribery and corruption is an illegal act in addition to business ethics, compliance with anti-corruption regulations and all internal regulations, especially the corporate governance principles of our organization, is essential.

The basic principles that may provide grounds for bribery and corruption have been identified and defined.

4.1. Public Relations

It is prohibited to make, promise, offer, or allow direct or indirect payments to officials, including managers and employees of public enterprises or enterprises managed by the public, or civilians with official status, such as those working on behalf of any public institution, with the intention of influencing the public official to perform their official duties to obtain or retain any business or to secure any business advantage

Due to legal regulations, gifts and hospitality given directly or indirectly to officials of authorities with whom our Organization communicates are limited to symbolic and low-value items as specified in our Organization's Human Resources Directive (Directive). The procedures and principles related to the receipt and presentation of gifts, as well as the representation and hospitality processes, shall be implemented as stated in the Directive prepared by the Human Resources Department.

4.2. Acceptance/Presentation of Gifts

Our Organization has established internal processes related to all expenses, gifts, and tangible or intangible benefits, and has ensured the progression of these processes through specific approval mechanisms. Within this scope, in addition to cash payments:

- Gifts that go beyond ordinary business expenses,

- Promotional activities that may not be considered reasonable,

- Offering employment to a public official or their family members with the intention of securing a business benefit,

- In-kind and cash donations to political parties and candidates constitute a violation of the policy.

4.3. Representation and Hospitality Activities This includes invitations, entertainment, meals, and corporate communication events carried out for representation and hospitality purposes among individuals with or potentially having a business relationship. The procedures and principles related to representation and hospitality processes are specified in the Human Resources Directive.

4.4. Facilitation Payments These are unofficial, improper payments made to any official to secure or expedite the performance of a routine or necessary action to which the persons and entities covered by the policy are legally entitled. The offering of such improper payments is not permitted.

4.5. Political Contributions These can be categorized as political contributions and charitable donations. Any kind of political contribution or activity on behalf of the Organization is prohibited. Processes related to donation payments are investigated and monitored along with the opinions requested by the relevant business unit.

4.6. Sponsorship Relations Sponsorship relations may occur in various fields such as technology, finance, sports, arts, culture, education, entrepreneurship, or in the form of supporting an activity or organization. Our Organization conducts research on sponsorship processes in accordance with the opinions requested by the relevant business unit.

4. MONITORING AND SUPERVISION

In addition to establishing the basic principles for preventing bribery and corruption, it is essential to ensure compliance with the established principles and to establish effective internal control systems. Prevention of off-the-book transactions and accounting-related internal controls, including the approval of all transactions and the verification of the compliance of financial statements with principles, provide reasonable assurance in this regard. It is prohibited for members of the board of directors, managers, employees, and third parties to tamper with records by either concealing transactions or showing them differently with the intention of concealment or for any other purpose, or to omit such transactions from the Company's books or records. In the event of suspicion of a violation of this policy, an investigation is initiated within the scope of internal procedures and regulations of the Organization. If an investigation confirms a violation of this policy regarding institutions receiving external services and partnerships, the Compliance Unit is notified, and if it is determined that a third party has violated this Policy as a result of the investigations, such violation may result in the suspension or termination of the relevant contract and/or reporting the matter to the competent public authority.

5. TRAINING

This Policy is constantly and accessible to all employees at all times. Training sessions are organized to enhance awareness of anti-bribery and anti-corruption measures among employees, and these training sessions encompass all staff. Training programs include comprehensive information about anti-bribery and anti-corruption policies, relevant legal regulations, internal company procedures, and the responsibilities of employees in these matters.

6. NOTIFICATION OF POLICY BREACHES

The Organization encourages the confidential reporting of violations of the anti-bribery and anti-corruption policy to senior management, considering that reporting instances of non-compliance or suspicion thereof inherently serve the interests of the Organization. Employees and other relevant parties may report any suspected or observed violations through designated communication channels. These reports may also be made anonymously. The reporting individual may conceal their identity for security measures or similar reasons. No employee shall be subjected to adverse treatment for refusing to participate in any bribery or corruption incident or for reporting, in good faith, any bribery or corruption incident based on reasonable suspicion.

7. EFFECTIVE AND UPDATE

This policy shall enter into force upon approval by the Board of Directors. The Compliance Unit is responsible for all updates to the policy document. In case of any doubts regarding these regulations, communication can be made with the Compliance Unit.