I. OUR CODE OF ETHICS AND CONDUCT

A. Integrity
Integrity and honesty represent our core values in all business processes and relationships. We uphold these principles in our interactions with employees and all stakeholders.

B. Confidentiality
Confidential and proprietary information includes information that could create a competitive disadvantage for H. Ö. Sabancı Holding A.Ş. and the Sabancı Group Companies, as well as trade secrets, financial and other information that has not yet been disclosed to the public, personnel records, and information covered under 'confidentiality agreements' with third parties. As Sabancı Group employees, we protect the confidentiality of our customers, employees, and other relevant individuals and organizations. We protect confidential information related to Group Companies, use it only for Sabancı Group's purposes, and share it only with authorized persons within the defined parameters. It is unacceptable for us to obtain any commercial benefit by disclosing confidential information related to H.Ö. Sabancı Holding A.Ş. and Sabancı Group Companies (insider trading). Upon departure, employees must ensure that no confidential documents, projects, or other sensitive materials acquired during their tenure are compromised or removed from company premises.

C. Conflicts of Interest
As Sabancı Group employees, we aim to avoid conflicts of interest. We do not seek personal benefits from individuals and organizations we have business relationships with through our current positions. We do not engage in any additional financial interest-based business activity outside H.Ö. Sabancı Holding A.Ş. and the Group Companies. We avoid using the Sabancı name and its influence or the fact that we work at Sabancı for personal gain. When we encounter potential conflicts of interest, we apply methods that we believe can safely protect the interests of the relevant parties through legal and ethical means. In case of doubt, we consult with our managers, the Human Resources Department, or the Ethics Committee.

D. Responsibilities
In addition to our legal obligations, we are committed to successfully fulfilling our responsibilities to our customers, employees, shareholders, suppliers, business partners, competitors, society, humanity, and the Sabancı name, as detailed below.

1. Legal Responsibilities
We conduct all our domestic and international activities and operations within the framework of Turkish international laws, providing regulatory institutions and organizations with accurate, comprehensive, and understandable information in a timely manner. While carrying out all our activities and operations, we maintain an equal distance from all public institutions and organizations, administrative bodies, non-governmental organizations, and political parties without expecting any benefit; we fulfill our obligations with this sense of responsibility.

2. Responsibilities to Customers
We take a proactive approach to achieving optimal customer satisfaction. We respond to our customers' needs and requests in the shortest time possible and in the most precise way. We provide our services promptly and under the promised conditions, treating our customers with respect, honor, fairness, equality, and courtesy.

3. Responsibilities to Employees
We ensure that employees fully and precisely exercise their personal rights. We treat employees honestly and fairly, committing to a non-discriminatory, safe, and healthy working environment. We strive for our employees' individual development, support their voluntary participation in appropriate social and community activities with a sense of social responsibility, and help them maintain a balance between their work and private lives.

4. Responsibilities to Shareholders
Prioritizing the continuity of the Sabancı Group and creating value for our shareholders, we avoid taking unnecessary or unmanageable risks and strive to achieve sustainable profitability. We operate within a financial discipline and accountability framework, managing our company's resources, assets, and working time with a sense of efficiency and savings. We strive to enhance our competitive strength and invest in areas with growth potential that will provide the highest returns on allocated resources. Our public disclosures and communications with shareholders provide timely, accurate, complete, and clear information concerning our financial status, strategies, investments, and risk profile.

5. Responsibilities to Suppliers and Business Partners
We act fairly and respectfully, taking the necessary care to fulfill our obligations on time. We carefully protect the confidential information of the individuals and organizations we work with.

6. Responsibilities to Competitors
We engage in competition solely within legal and ethical boundaries, steering clear of unfair practices. We also support initiatives aimed at fostering a fair, competitive environment in society.

7. Responsibilities to Society and Humanity
We are committed to protecting democracy, human rights, and the environment, as well as supporting education and charitable activities. Additionally, we prioritize the elimination of crime and corruption. Guided by our commitment to being responsible citizens, we actively engage in and lead social initiatives. We strive to participate in non-governmental organizations, public benefit services, and other suitable activities. We are respectful of the traditions and cultures of Türkiye and the countries where we conduct international projects. Furthermore, we adhere to strict ethical standards, neither giving nor accepting bribes, gifts, products, or services that exceed a reasonable value.

8. Responsibilities to the ‘Sabancı' Name
Our business partners, customers, and other stakeholders trust us due to our professional competence and honesty. We are committed to upholding this reputation at the highest level. We provide our services within the framework of the Holding Company/Group Companies policies, professional standards, commitments, and ethical rules, and we show the necessary dedication to fulfilling our obligations. We are careful to offer services in areas where we are professionally competent and confident in our ability to deliver. We aim to work with customers, business partners, and employees who meet the criteria of accuracy and legitimacy. We do not work with those who undermine public morals or harm the environment and public health. In public and in situations where the audience perceives us as representing our Holding Company/Group Companies, we express only the views of our company, not our personal opinions. When faced with complex situations that could put H. Ö. Sabancı Holding A.Ş. and/or the Group Companies at risk, we first consult with the appropriate personnel, following suitable technical and administrative consultation procedures.

II. POLICIES SUPPORTING CODE OF ETHICS AND CONDUCT

A. Conflict of Interest Policy
It is essential for employees of H. Ö. Sabancı Holding and the Group Companies to avoid situations that may create conflicts of interest. One of the most important responsibilities of all our employees is to avoid using the resources, name, identity, and influence of the Holding Company/Group Companies for personal gain and to avoid situations that could negatively affect the institution's name and image. The following code of practice outlines potential conflict of interest situations that the Holding Company/Group Companies' employees might encounter in their private lives or through business relationships while performing their duties, along with the principles that should be applied in such cases.

Code of Practice

1. Activities that May Create Conflicts of Interest  
All Holding Company/Group Companies' employees must fully comply with the principles listed below, which outline activities that may create conflicts of interest. The Holding Company and Group Companies conduct necessary studies to encourage employees to comply with these principles.

i. Engaging in Activities that May Create Conflicts of Interest  
Employees shall not engage in any business relationship that provides mutual or unilateral benefits to family members, friends, or other third parties with whom they have a relationship. For example, an employee with purchasing authority should avoid conducting business with a supplier where a family member is employed. Exceptional cases are subject to the knowledge and approval of the Chair of the Holding Company/Group Companies' Board of Directors. Similarly, the Holding Company/Group Companies' employees must be cautious of potential conflicts of interest arising from close family members working for competitors of the Holding Company/Group Companies. Employees of H. Ö. Sabancı Holding and the Group Companies are strictly prohibited from using any inside information belonging to the Holding Company/Group Companies for commercial gain, including trading stocks or enabling others to profit similarly. Furthermore, it is crucial that employees do not engage in activities that would classify them as 'merchants' or 'tradespeople,' either directly or indirectly, nor should they work for any other person and/or institution for a fee or similar benefit under any name during or outside working hours. However, exceptions are permitted for employees who wish to work for another person (family member, friend, other third parties) and/or institution for a fee or similar benefit outside of working hours, provided that:
- It does not create a conflict of interest between their duties at the company and the practices of other Sabancı Group companies.
- It does not create an inconsistency with other business ethics rules and the policies supporting these rules.
- It does not negatively affect their ability to perform their duties at the company.
- They have written approval from management.
Approval for external engagements is structured as follows: For the Group President, General Manager, and all positions reporting to the General Manager, the Sabancı Holding CEO grants authorization based on the Ethics Committee's opinions and after consideration of the immediate supervisor's advice. For other employees, approval is provided by the company's General Manager, following the recommendations of the company's Ethics Rule Advisor and the Human Resources Manager.
Employees of H. Ö. Sabancı Holding and the Group Companies cannot serve as board members or auditors in companies outside the Group Companies without the approval of the Holding Company/Group Companies' Board of Directors. They cannot work with competitor companies or companies that have business relations with the Holding Company/Group Companies. Employees may serve in social responsibility and charity positions in non-profit organizations and universities with written approval from management, provided these activities do not interfere with their duties within the Holding Company/Group Companies.
Managers in a position to make hiring decisions cannot employ their spouses, close relatives, or the relatives of these individuals.
Employees may give speeches or author professional articles on topics unrelated to the company and its policies, provided they obtain approval from the CEO/General Manager if they wish to use the names of the Holding Company/Group Companies.
Employees of H. Ö. Sabancı Holding and the Group Companies can engage in political activities individually and voluntarily. Managers cannot request their employees to perform political tasks or join a political party. Employees may participate in political activities under the following conditions and with written approval from management:

• Employees engaging in any political activity must ensure that it does not create a conflict of interest with their duties at the Holding company and the practices and approaches of other Sabancı Group companies.
• Employees are prohibited from engaging in any political activities during working hours and must not use their colleagues' time for such activities.
• Employees must not use the company's name, their position within the company, their title, or company resources during their political activities.

Approval for employees to engage in political activities is granted by the Sabancı Holding CEO when it comes to Group Presidents, General Managers, and positions reporting to the General Manager based on recommendations from the Ethics Committee. For other employees, approval is granted by the company Ethics Rules Advisor, the company Human Resources Manager, and the Company General Manager.
Employees can provide financial or moral assistance and/or donations to third parties on a personal basis and can serve in charitable organizations.

ii. Misuse of Authority
It is unacceptable for employees to use their authority to benefit themselves or their close relations and cause harm to the Holding Company/Group Companies by acting outside the expected diligence. Employees are prohibited from deriving personal profit, either directly or indirectly, from the company’s purchasing and sales activities or any transactions and contracts involving the company. Additionally, employees must not engage in actions or behavior that contravene morals, laws, or the disciplinary codes of the Holding Company/Group Companies.

iii. Use of Resources
Company resources must always be used in the interest of the Holding Company/Group Companies. Assets, facilities, and personnel of the Holding Company/Group Companies must not be used for external purposes unrelated to the interests of the Holding Company/Group Companies, regardless of the circumstances or beneficiaries involved. All personnel are required to adhere to the principle of 'savings in every matter' to ensure efficient and responsible use of resources. Properly using resources in the interest of the Holding Company/Group Companies also requires the appropriate use of time. Holding Company/Group Company employees must use their time efficiently during working hours and refrain from allocating time to personal matters. Managers cannot assign employees to personal tasks. Employees must not accept personal visitors during working hours. For necessary visitors, employees should complete meetings related to the established topic of the visit within a reasonable time and without disrupting workflow.

iv. Relations with Other Persons and/or Organizations with Which the Holding Company/Group Companies Have Commercial Relations
Employees must not engage in private business relationships with Holding Company/Group Companies' customers, subcontractors, suppliers, or other individuals and/or organizations with which the Holding Company/Group Companies have commercial relations. They cannot borrow money and/or receive goods/services for personal purposes from these parties, nor can they lend money and/or provide goods/services to said parties. Regarding customer interactions, the following points are considered company policy: no transaction can be conducted without the customer's knowledge, even if it is in the customer's favor. The company cannot gain an advantage by exploiting customer vulnerabilities, and profit cannot be sought by providing incomplete or incorrect information to the customer. Holding Company/Group Companies' personnel cannot request or hint at gifts from individuals and/or organizations with whom the Holding Company/Group Companies have commercial relations; they cannot accept any gifts, money, checks, property, free vacations, exclusive discounts, etc., that would obligate the Holding Company/Group Companies. Personal assistance or donations cannot be accepted from any person or organization with a business relationship with the Holding Company/Group Companies. The Gift Acceptance and Giving Policy applies to this matter.

v. Relations with the Media
Relations with the media are conducted within the framework of the Holding Company/Group Companies' Communication Protocol. Providing statements to any publication, conducting interviews, or participating as a speaker at seminars or conferences is subject to the approval of the company's executive management. No personal profit can be gained from these types of activities.

vi. Representing the Company
When representing the Holding Company/Group Companies in any association, employer union, or similar civil society organization, fees accrued from such duties are donated to the relevant institution or channels designated by that institution. Payments received by Holding Company/Group Companies' employees from third parties for seminar speaking or similar services must also be donated in the same manner. However, individuals may accept awards, plaques, or similar items given as mementos of the occasion, which hold purely symbolic value.

B. Gift Acceptance and Giving Policy
Employees of H.Ö. Sabancı Holding and the Group Companies must not accept gifts or benefits that could affect their impartiality, decision-making, and behavior, nor offer such gifts and benefits to third parties and organizations. The following principles define the guidelines for receiving and giving gifts and the principles to be applied in such cases:

Code of Practice

1. Holding Company/Group Companies' employees are prohibited from accepting any benefits or gifts, whether they have economic value or not, that affect or have the potential to impact their impartiality, performance, or decision-making while performing their duties.
2. Holding Company/Group Company employees may accept and/or give gifts or accept special treatment as outlined in item
3, provided that:
- They align with the institution's business objectives,
- They comply with applicable regulations,

• Accepting the gift would not place the Holding Company/ Group Companies in a difficult position if it were to become known to the public.

3. Provided that they meet the conditions specified in the second item:

• Holding Company/Group Companies' employees may give and receive entertainment, hospitality, and meals at standards acceptable in the business world, in accordance with the principles outlined in the Authorization Table.
• While representing the Holding Company/Group Companies at seminars and similar events, employees may accept symbolic gifts like awards and plaques, which serve as mementos of the occasion, but they must refrain from accepting monetary gifts.

4. Apart from the situations mentioned above, approval is not required for other gifts, benefits, vacations, discounts, etc., excluding money, if the total value of the gifts received from each person/institution in each calendar year is less than 250 TRY, provided they meet the conditions listed in item 2.
5. Accepting gifts or benefits tied to an implicit or explicit return is forbidden.
6. Bribery and/or commission giving, receiving, or offering under any circumstances is unacceptable.
7. Holding Company/Group Companies' employees are prohibited from accepting money, either as a gift or a loan, from subcontractors, suppliers, consultants, competitors, or customers and from having their travel expenses, event costs, or similar payments covered by these parties.
8. Gifts and promotional materials that may be given to customers, dealers, and other third parties with whom the Holding Company/Group Companies have business relationships must be approved by the Holding Company/Group Companies' executive management. Once approved, no additional permission is required for the distribution of these gifts and promotional materials.
9. Provided they comply with the conditions listed in item 2, the Holding Company/Group Companies may accept suitable products and services as gifts. With the knowledge and approval of the Holding Company/Group Companies' executive management, products or services that align with the recipient's culture and ethical values may be received as gifts.
10. In exceptional situations where local cultural values require gift exchanges exceeding the values set in company policies, these gifts may only be accepted on behalf of the company and with the approval of the company's executive management. Gift exchanges must always comply with local cultural practices.

C. Confidential Information Protection Policy
Information is one of the most critical assets that H. Ö. Sabancı Holding and Group Companies utilize to realize their vision. In this regard, it is the collective responsibility of all our companies and employees to effectively use, accurately share, and ensure the confidentiality, integrity, and accessibility of information. The management systems and processes established for the management and confidentiality of information in our Holding Company/Group Companies must be harmonized to ensure the highest benefit level for the Group. Details of practices related to this topic are provided in the Sabancı Information Security Policy and related documents. The following code of practice defines confidential information for the Holding Company/Group Companies and regulates the principles employees must adhere to regarding the handling of confidential information.

Code of Practice
Confidential information includes but is not limited to, the intellectual rights of the Holding Company/Group Companies, such as trademarks and all kinds of innovations, including any data, printed communication materials, processes, advertisements, product packaging and labels, as well as plans (marketing, product, technical) written, created, developed, produced, or implemented by personnel. It also encompasses information regarding business strategies, strategic partnerships and partners, financial information, personnel information, customer lists, product designs, knowledge, specifications, the identity of potential and actual customers, and information on suppliers. This includes all forms of information, whether written, graphic, or machine-readable.

The principles that must be adhered to regarding confidential information are listed below:
1. Confidential information cannot be disclosed to third parties unless required by law or official authorities.
2. Confidential information cannot be altered, copied, or destroyed. Necessary precautions are taken to ensure that information is kept securely and not disclosed. Changes to the information are recorded with a history.
3. Confidential files cannot be removed from the institution without permission. When confidential information must be removed, approval must be obtained from the information owner or executive management.
4. Passwords, user codes, and similar identifying information used to access company information are kept confidential and are never disclosed to unauthorized individuals.
5. Company confidential information is not discussed in public places such as dining halls, cafeterias, elevators, and shuttle buses.
6. Confidential information is classified according to the degree of confidentiality, which is clearly indicated in the content. Employees must understand the confidentiality levels of the information they handle and act accordingly. If there is any doubt regarding the level of confidentiality, a higher confidentiality level must be applied, and the relevant manager's opinion is sought if necessary.
7. If information is shared with third parties and/or organizations for the benefit of the Holding Company/Group Companies, a non-disclosure agreement must be signed, or a written confidentiality commitment must be obtained from the other party to ensure that these individuals and organizations understand their responsibilities regarding the security and protection of the shared information.
8. Unfounded statements and/or rumors about individuals or institutions are prohibited.
9. Personnel information such as wages, fringe benefits, and other personal rights reflecting company policy is confidential and cannot be disclosed to anyone other than authorized persons. Such information is sent to personnel individually. Employees are prohibited from disclosing this information or pressuring others to disclose it.

D. Creating and Maintaining a Fair Working Environment Policy
H.Ö. Sabancı Holding and the Group Companies consider creating and maintaining a fair working environment for employees as one of their top priorities. The aim is to enhance employee success, development, and commitment by establishing a fair, respectful, healthy, and safe working environment in compliance with all relevant laws and regulations. Following the code of practice defines the fundamental principles for creating and maintaining a fair working environment within the Holding Company/Group Companies.

Code of Practice
1. Holding Company/Group Companies' practices comply with all applicable laws and regulations related to employment and working life. Employees must also fulfill all legal requirements within the scope of their activities and act in accordance with legal regulations.
2. Sabancı Group's human resources policies and practices ensure fairness in all employment practices such as recruitment, promotion, transfers, rotation, remuneration, rewarding, and social rights.
3. Discrimination among employees based on language, race, color, gender, political opinion, belief, religion, sect, age, physical disability, or any similar grounds is not tolerated.
4. A positive and harmonious working environment that supports cooperation and prevents conflicts ensures that people with different beliefs, thoughts, and opinions can work together harmoniously.
5. Employees' private lives and personal spaces are respected.
- Unrelated parties must not violate communications between individuals.
- Even if legally recorded, unlawfully disclosing, disseminating, or obtaining personal data is prohibited.
- Personnel records and personal information, which may be necessary due to the nature of the employment relationship, are not used for purposes other than intended and are not shared with third parties without the individual’s consent.

• All employees' private and family lives are respected.

6. The inviolability of employees, including their physical, sexual, and emotional integrity, is respected.

• Violating employees' immunity in any way through physical, sexual, and/or emotional harassment at the workplace or any place where they are present due to work is against the law, contravenes our ethical rules, and is not tolerated by the Holding Company/Group Companies.This policy aims to ensure that employees work in an environment where their physical, sexual, and emotional immunity is fully protected.
• Violation of a person's bodily inviolability through sexual behavior and/or harassment of a person for sexual purposes without physical contact is defined as sexual harassment. Accordingly, any behavior that falls within this definition is strictly prohibited.
• Additionally, no tolerance is shown towards those who exhibit negative attitudes and behaviors against individuals who file complaints, report harassment, or assist in investigations.

7. No employee may demand privileged treatment, show privilege to anyone, or be subjected to special treatment due to differences in gender, religion, language, or race. It is unacceptable to give or receive concessions by exploiting differences such as gender, religion, language, or race.
8. We ensure that the physical working environment and conditions at the workplace are healthy and safe for all our employees. 

E. Sabancı Group Companies' Share Trading Policy
It is essential that H. Ö. Sabancı Holding and Group Companies' employees comply with the relevant legal regulations and avoid situations that may create conflicts of interest when trading shares of Sabancı Group Companies. The following principles outline the guidelines employees must follow regarding purchasing and selling Sabancı Group Companies' shares.

Code of Practice
1. Individuals with access to undisclosed information are forbidden from using said information for personal benefit and/or to benefit third parties (insider trading).
2. Individuals who may engage in insider trading include the chair of the board, members of the board of directors, executives (managers and higher), and auditors of the publicly traded company. This category also extends to professionals and others who, through their duties, have access to published information, as well as those who may indirectly acquire published information through interactions with these individuals.
3. These people can buy and sell shares of Sabancı Group Companies using disclosed information for investment purposes (holding shares for more than three months is categorized as investment).
4. Other Sabancı Group employees can freely trade Sabancı Group Company shares using disclosed information without any time restrictions.
5. The above practices also apply to employees' spouses and children; any transactions conducted by spouses and children of employees will be treated as if the employee made them directly.

III. APPLICABLE LEGISLATION
Since Sabancı Group Companies operate in international markets, company operations may be subject to the laws and regulations of different countries. When questions arise regarding business ethics in other countries, the regulations of the country where the business is conducted should be followed first. However, if these regulations are incompatible with the ethical values adopted by Sabancı Group Companies, solutions should be sought within the framework of our ethical rules and procedures.

IV. EMPLOYEES’ RESPONSIBILITIES
The SA-ETİK and related policies and procedures define in detail the Code of Ethics and Conduct that guide our behavior and work. Compliance with these rules is the primary responsibility of all employees. In this context, all Sabancı Group employees are responsible for:

• Acting in accordance with laws and regulations in all circumstances.
• Reading, understanding, internalizing, and adhering to the Sabancı Code of Ethics and Conduct, including the principles and values they contain.
• Learning the general policies and procedures applicable to the Holding Company/Group Companies, as well as the specific policies and procedures related to their work,
• Consulting with their manager and Human Resources Department regarding potential violations involving themselves or others.
• Promptly reporting any potential violations involving themselves or others; such reports may be made to their manager, Human Resources Department, and/or Ethics Committee, either named or anonymously, in writing or verbally.
• Following the 'Methods and Processes to be Followed in Ethical Decision-Making' to assist in adhering to the rules and resolving issues.
• Cooperating with the Ethics Committee during ethical investigations and keeping investigation-related information confidential.

A. Methods and Processes to be Followed in Ethical Decision-Making
To guide you in making a decision, follow the steps below and ask yourself the following questions:

1. Identify the Issue, Decision, or Problem
- Are you being asked to do something you think might be wrong?
- Are you aware of a situation in your workplace or related to your business partners that might be illegal or unethical?
- Are you trying to make a decision but need help with how to proceed ethically?
2. Think Before You Decide
- Clearly define and summarize the problem or issue.
- Ask yourself why there is a dilemma.
- Consider the options and their consequences.
- Think about who might be affected.
- Consult with others.
3. Make a Decision on a Course of Action
- Determine your responsibilities.
- Review all relevant facts and information.
- Refer to applicable company policies, procedures, and professional standards.
- Assess the risks and consider how to mitigate them.
- Try to formulate the best course of action.
- Consult with others.
4. Test Your Decision
- Review the questions that need to be asked from an ethical perspective.
-  Check your decisions within the framework of the company's core values.
- Ensure you have considered company policies, laws, and professional standards.
- Seek input and consider the opinions of others before deciding your planned course of action.
5. Proceed with Determination
- Share your decision and reasoning with relevant parties.
- Share what you have learned.
- Share your success story with others.
B. Four Key Questions to Consider
1. Does this activity/behavior comply with the laws, rules, and customs? (Standards)
   - Is it in line with professional standards?
   - Is it lawful?
2. Is this activity/behavior balanced and fair? Would you be uncomfortable if a competitor (or another party) behaved in this way? (Sense of Fairness)
   - Does it seem right to you?
3. Would our company and stakeholders be uncomfortable if the details of this activity were made public? (Feelings and Ethical Values)
   - Would you feel uneasy or embarrassed if others knew about this behavior?
   - Could it have negative consequences for you or the Holding Company/Group Companies?
   - Who else might be affected (other employees within the Holding Company/Group Companies, you, shareholders, etc.)?
4. How does the 'perceived reality' align with the 'objective reality'?
   - How would it be reported in the newspapers?
   - What would a reasonable person think under the same circumstances?

V. MANAGERS' RESPONSIBILITIES
Sabancı Group managers have additional responsibilities beyond those defined for employees under SA-ETİK. Accordingly, managers are responsible for:

• Creating and maintaining a company culture and working environment that supports ethical rules.
• Leading by example in applying ethical rules and educating their employees about these rules.
• Supporting their employees in asking questions, making complaints, and reporting issues related to ethical rules.
• Providing guidance when consulted on what should be done, considering all reported issues, and promptly referring them to the Ethics Committee if necessary.
• Structuring the business processes under their responsibility to minimize risks related to ethical issues and implementing the necessary methods and approaches to ensure compliance with ethical rules.

VI. ETHICS ADVISORS’ RESPONSIBILITIES
Ethics Advisors are responsible for:

• Providing guidance and consultancy on questions and issues related to ethics raised by employees within the company.
• Referring unresolved or investigation-requiring ethics violations within the company to the Ethics Committee.
• Contributing to the resolution of internal ethics violations in accordance with the Ethics Committee's directives.
• Regularly reporting or providing reports upon request on ethics-related questions and violations, along with their outcomes, to the Ethics Committee.
• Serving as the company's contact people during investigations conducted by the Ethics Committee and providing the necessary support for these investigations.
• Monitoring and tracking the effectiveness of the SA-ETİK practices implemented within the company and providing support in these practices. 

VII. OTHER RESPONSIBILITIES

• The executive management of the Holding Company/Group Companies is responsible for the effective implementation of SA-ETİK or company-specific Code of Ethics and Conduct created within this framework and for fostering a supportive culture
• Code of Ethics and Conduct and related policies are reviewed, revised, and documented by the Human Resources Group Presidency based on the Ethics Committee's recommendations and communicated to the Holding Company/Group Companies with the approval of the Chair of the Holding Board of Directors.

Holding Company/Group Companies’ Human Resources are responsible for:

• Informing employees about the Ethics Rules, providing periodic training to ensure the clarity of the policies and rules, and maintaining continuous communication regarding this topic with employees.
• Ensuring new hires read the ethics rules, are informed about them, and sign the Employee Declaration (See Annex-1 Employee Declaration).
• Ensuring all employees renew their declarations by signing the Code of Ethics and Conduct Form at the beginning of each year (See Annex-2 Code of Ethics and Conduct Compliance Form).

Holding Company/Group Companies’ Management, in cooperation with the Ethics Committee, are responsible for the following:

• Guaranteeing the confidentiality of complaints and notifications made within the framework of the Ethics Rules and protecting individuals following their notifications.
• Ensuring the job security of employees who make notifications.
• Guaranteeing that complaints and notifications are investigated in a timely, fair, consistent, and sensitive manner and taking necessary actions decisively in case of violations.

VIII. RESOLUTION OF ETHICAL RULE VIOLATIONS
Individuals who violate the Code of Ethics and Conduct or Holding Company/Group Companies' policies and procedures will be subject to various disciplinary actions, including possible termination. Disciplinary actions will also apply to those who approve, direct, or fail to report the actions leading to inappropriate behavior and rule violations.

A. Ethics Committee
The Ethics Committee is responsible for investigating and resolving complaints and notifications regarding violations of the Sabancı Group Code of Ethics and Conduct (SA-ETİK). The Ethics Committee operates under the Chair of the Board of Directors of H.Ö. Sabancı Holding A.Ş. and is comprised of the following positions:

• Chair – Head of the Audit Department
• Member – Head of the Legal Department of H.Ö. Sabancı Holding
• Member – Head of the Labor Relations Department of H.Ö. Sabancı Holding

B. Ethics Committee Operating Principles
The Ethics Committee conducts its work with the following principles:

• Keeps the identity of those making notifications and complaints confidential.
• Conducts investigations as confidentially as possible.
• Has the authority to request information, documents, and evidence directly from the relevant unit. Reviews all obtained information and documents limited to the subject of each investigation.
• Documents the process of each investigation in writing from the beginning. Information, evidence, and documents are attached to the records.
• The committee chair and members sign the records.
• Investigations are handled urgently and concluded as quickly as possible.
• Decisions taken by the committee are implemented without delay.
• Relevant departments and authorities are informed about the results.
• The committee chair and members perform their duties independently and without influence from the department managers and hierarchy within the organization. They cannot be pressured or influenced regarding the investigations.
• The committee may seek expert opinions if necessary and may take measures to use experts during the investigations while maintaining confidentiality principles.

For questions and notifications, you can use the following email and postal addresses or directly contact the Ethics Committee members.