Code of Business Ethics

BUSINESS ETHICS RULES

I. OUR BUSINESS ETHICS PRINCIPLES

A. Integrity
Integrity and honesty are our primary values in all business processes and relationships.
We act with integrity and honesty in our relationships with employees and all stakeholders.

B. Confidentiality
Confidential information includes data belonging to Ekmob Inc. and its affiliated companies that could create a competitive disadvantage, trade secrets, financial and other information not yet disclosed to the public, employee personal rights, and personal data of employees, customers, and stakeholders. It also includes information we are obliged to protect under confidentiality agreements made with third parties.
As employees of Ekmob Inc., we take care to protect the confidentiality and private information of our customers, employees, and relevant individuals and organizations we work with. We safeguard confidential information related to Ekmob Inc.’s operations, use it only for its intended purposes, and share it solely within the bounds of designated authority.
Any commercial benefit gained through the leakage of confidential information belonging to Ekmob Inc. or its affiliates (insider trading) is strictly prohibited. Even when leaving the company, we refrain from taking outside any confidential information, documents, projects, regulations, etc., obtained through our roles.

C. Conflict of Interest
As employees of Ekmob Inc., we aim to avoid conflicts of interest. We do not use our current roles to gain personal benefits through family or close associates from individuals or organizations we have business relationships with. We refrain from engaging in financially motivated activities outside of Ekmob Inc. and its affiliated companies, both domestically and internationally. We avoid using Ekmob Inc.’s name and identity for personal gain.
In situations where a potential conflict of interest arises, we implement measures to ensure the interests of all parties are safeguarded through legal and ethical means. In cases of uncertainty, we consult our manager, Human Resources Department, Board of Directors, or Finance Department.

D. Responsibilities
In addition to our legal obligations, we diligently fulfill the following responsibilities toward our customers, colleagues, shareholders, suppliers and business partners, competitors, society, humanity, and Ekmob Inc. itself.

• Legal Responsibilities
  We conduct all domestic and international activities and operations within the framework of Turkish laws and international regulations. We provide accurate, complete, and understandable information to regulatory institutions and organizations promptly.
  While conducting our activities and operations, we maintain equal distance from all public institutions, administrative bodies, non-governmental organizations, and political parties without any expectation of benefit.
• Responsibilities to Our Customers
  We operate with a customer satisfaction-oriented approach, proactively responding to our customers’ needs and requests promptly and accurately. We deliver our services on time and under promised conditions, treating our customers with respect, honor, fairness, equality, and courtesy.
• Responsibilities to Employees
  We ensure employees fully and correctly utilize their personal rights. We approach employees with honesty and fairness, providing a non-discriminatory, safe, and healthy working environment. We support employees’ personal development and encourage their participation in appropriate social and community activities with a sense of social responsibility, while also maintaining a balance between work and private life.
• Responsibilities to Shareholders
  Prioritizing the continuity of Ekmob Inc., we avoid unnecessary or unmanageable risks while aiming for sustainable profitability. We act with financial discipline and accountability, managing the company’s resources, assets, and working time with efficiency and savings consciousness. We focus on enhancing competitiveness and investing in areas that promise high returns and align with connected resources.
• Responsibilities to Suppliers/Business Partners
  We act fairly and respectfully as a good customer would, ensuring our obligations are met on time. We take care to protect the confidential information of the individuals and organizations we do business with.
• Responsibilities to Competitors
  We compete effectively within the bounds of legality and ethics, avoiding unfair competition. We support efforts to create a competitive environment in society.
• Responsibilities to Society and Humanity
  Protecting democracy, human rights, the environment, education, and charitable activities, as well as eliminating crime and corruption, are of great importance to us. We act sensitively, taking a leading role in societal issues.
• Responsibilities on Behalf of Ekmob Inc.
  Our stakeholders trust us due to our professional competence and integrity. We strive to maintain this reputation at the highest level.

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II. POLICIES SUPPORTING BUSINESS ETHICS

A. Conflict of Interest Policy
Employees of Ekmob Inc. and its affiliates are expected to avoid situations that may create conflicts of interest. It is the responsibility of all employees to refrain from using company resources, its name, identity, or influence for personal benefit and to avoid actions that may negatively impact the company’s reputation or image.

• Activities Creating Conflicts of Interest
  Employees must not engage in mutual or unilateral benefit-driven relationships with family members, friends, or third parties involved in business relations. For example, an employee with purchasing authority must avoid working with a supplier employing a family member. Exceptions require the knowledge and approval of the Company’s Board of Directors.

II. POLICIES SUPPORTING THE CODE OF BUSINESS ETHICS

A. Conflict of Interest Policy
It is essential that employees of Ekmob A.Ş. and its subsidiaries avoid situations that may create a conflict of interest. It is the responsibility of all employees to avoid using the company’s resources, name, identity, and power for personal benefit, and to refrain from situations that may negatively impact the company’s image. The following principles determine the situations that employees may encounter, whether in their professional duties or personal life, that could create a conflict of interest and the principles to be applied in such cases.

Application Principles
Activities That May Create a Conflict of Interest
All employees of the company must strictly adhere to the following situations, which are identified as potential conflict of interest scenarios, and the principles outlined. The company will take the necessary actions to encourage its employees to comply with these principles.

i. Engaging in Activities That May Create a Conflict of Interest
Employees should never enter into business relationships that provide mutual or non-mutual benefits with family members, friends, or any other third parties. For example, an employee with purchasing authority should avoid working with a supplier where a family member is employed. Exceptional cases are subject to the knowledge and approval of the Chairman of the Board of the Company. Similarly, employees must be cautious about potential conflicts of interest arising from their close family members working for competing companies.

Employees cannot gain any commercial benefits by leaking any company information, including stock trading based on inside information, or cause others to benefit in this way.

Ekmob A.Ş. employees must not work for another person or institution, for any payment or similar benefits, during or outside of working hours, in activities that would classify them as a “merchant” or “trader.” However, employees may work for another person (family member, friend, or other third parties) or institution for payment or similar benefits outside of working hours, under the following conditions:

• It does not create a conflict of interest with their role at the company and its subsidiaries.
• It does not conflict with other ethical rules or policies supporting these rules.
• It does not negatively affect their role within the company.
• Written approval from the management is obtained.

Approval for positions reporting directly to the CEO/General Manager and positions reporting to the CEO/General Manager must be given after consulting with the CEO and Board of Directors. For other employees, approval must be obtained from the CFO and HR Manager, in consultation with the CEO.

ii. Work with Competitors
Employees must avoid any relationships or activities with companies that are considered direct competitors of Ekmob A.Ş. These relationships or activities include both formal partnerships or informal personal business activities that may present conflicts of interest.

iii. Business Relationships Involving Family or Friends
Employees must refrain from entering into any professional relationship or contract with family members, relatives, or friends, except for cases where full transparency and written approval from the company’s management are provided. In cases of direct family or friendship involvement in any business transaction, the relevant employee must inform their supervisor and seek the necessary approval before moving forward.

iv. Gifts, Entertainment, and Invitations
Employees should avoid accepting gifts or other forms of compensation from business partners, vendors, clients, or competitors. However, if an employee receives a gift in the course of their duties, the gift should be of nominal value and not intended to influence decisions in favor of a particular party. For any gift or invitation that is of significant value or could be perceived as an attempt to influence business decisions, employees must immediately report it to their supervisor and seek advice on whether it should be returned or disclosed.

B. Anti-Bribery and Anti-Corruption Policy
Ekmob A.Ş. is committed to conducting its business with the highest standards of integrity and transparency. The company strictly prohibits bribery, corruption, or any form of unethical behavior, whether involving public or private officials.

Application Principles

• No employee or representative of Ekmob A.Ş. may offer, give, or receive bribes in the form of money, gifts, or other benefits.
• Employees must never engage in any form of bribery, whether directly or indirectly, to secure business or other benefits for themselves or the company.
• All employees must report any instance or suspicion of bribery or corruption immediately through the designated reporting channels.
• Employees are encouraged to act in a manner that reflects the company’s commitment to legal compliance and ethical conduct.

C. Confidentiality and Data Protection Policy
Maintaining confidentiality and protecting the company’s sensitive data is critical to Ekmob A.Ş.’s business operations and the trust it has built with clients, partners, and employees. All employees must comply with the company’s confidentiality agreements and data protection policies.

Application Principles

• Employees are prohibited from disclosing confidential information, including trade secrets, financial data, and business strategies, to unauthorized individuals or third parties.
• The use of confidential information for personal gain is strictly prohibited.
• All company data should be handled with care and kept in secure environments to prevent unauthorized access.
• Employees must comply with all applicable data protection laws and regulations regarding personal and sensitive data.

D. Whistleblower Protection Policy
Ekmob A.Ş. encourages its employees to report any violations of the company’s ethical guidelines, policies, or legal obligations. To ensure that employees can report violations without fear of retaliation, the company has implemented a whistleblower protection policy.

Application Principles

• Employees are encouraged to report any unethical behavior or legal violations through anonymous or direct channels without fear of retaliation.
• The company commits to investigating all reported concerns promptly and thoroughly.
• Retaliation against individuals who report violations in good faith is strictly prohibited.

III. CONSEQUENCES OF POLICY VIOLATIONS

Employees who fail to adhere to the Code of Business Ethics or any associated company policies will face disciplinary action, which may include verbal or written warnings, suspension, or even termination of employment, depending on the severity of the violation. In cases where violations involve illegal activities, legal action may also be taken.

IV. CONCLUSION

Ekmob A.Ş. is committed to maintaining a culture of integrity, transparency, and respect in all aspects of its business operations. This Code of Business Ethics serves as a guide for employees to understand their responsibilities and the company’s expectations of their conduct. By adhering to these guidelines, employees contribute to the company’s success and its reputation as a trusted and ethical organization.

Application Principles
The company’s applications comply with all applicable laws and regulations regarding employment and working life. The company’s employees also fulfill all legal requirements within their activities and act in accordance with legal regulations.
Ekmob A.Ş. and its subsidiaries’ human resources policies and practices ensure fairness in recruitment, promotion, transfer-rotation, compensation, reward, social rights, and other related applications.
Discrimination based on language, race, color, gender, political thought, belief, religion, sect, age, physical disability, or any other reasons between employees is unacceptable.
A supportive, positive, and harmonious working environment is created within the company, where people with different beliefs, thoughts, and opinions can work together in harmony, preventing conflict.
The privacy and personal space of employees are respected.
The physical, sexual, and emotional inviolability of employees is safeguarded in addition to their personal inviolability.
Any violation of an individual’s inviolability through physical, sexual, and/or emotional harassment at the workplace or anywhere related to work is against the law and ethical rules, and the company does not tolerate such acts in any way. In this regard, all necessary measures are taken to ensure that employees work in an environment where their physical, sexual, and emotional inviolability is protected.
The violation of someone’s physical inviolability and/or sexual harassment without physical contact is defined as sexual assault/harassment. Therefore, any behavior that can be evaluated under this definition is unacceptable.
“Psychological Harassment at the Workplace” (Mobbing), a malicious, intentional, negative attitude, and behavior that is performed systematically over time by one or more persons against others, which harms the victim’s personality, professional status, social relationships, or health, is considered one of the types of harassment mentioned above.
The physical working environment and conditions at the workplace are ensured to be healthy and safe for all employees.
Ekmob A.Ş. and its subsidiaries act responsibly and sensitively to ensure that their fundamental activities do not have negative impacts on the environment, and take all measures required by regulations in relation to their social and human responsibilities.
The company works to raise employees’ awareness and sensitivity on this issue.

Principles of Application
It is prohibited for individuals who may have access to non-public information to use that information for personal or third-party gain, meaning insider trading.
Insider trading refers to using non-public information to trade shares or financial instruments of publicly traded companies and is illegal.
Individuals who may engage in insider trading include the chairman and members of the board of directors, managers (people in positions of director or higher), auditors, and anyone else who, through their profession or job, is in a position to access non-public information.
Employees of Ekmob A.Ş. and its subsidiaries, excluding those mentioned above, can freely buy and sell shares of the company using publicly available information without any time restrictions.
The above practices also apply to the spouses and children of employees. Transactions made by them are considered as if made by the employee themselves.

Applicable Legislation
Since Ekmob A.Ş. operates in international markets, the company may be subject to the laws and regulations of different countries. In cases where there are concerns about the ethical conduct of business in a foreign country, the regulations in place in the country where the business is being conducted should be followed. If the regulations of the country where the business will take place may lead to undesirable outcomes in terms of the ethical values adopted by Ekmob A.Ş., efforts should be made to find solutions within the ethical rules and procedures that we follow.

Employee Responsibilities
The relevant policies and procedures have detailed the ethical rules regarding how we should behave and how we should perform our jobs. Compliance with these rules is the primary responsibility of all employees. Accordingly, all employees of Ekmob A.Ş. and its subsidiaries must:

• Act in accordance with laws and regulations under all circumstances,
• Read the Ekmob A.Ş. Code of Ethics, understand, internalize, and act according to its rules, principles, and values,
• Learn the general policies and procedures related to their job and the company,
• Consult with their manager or human resources regarding potential violations concerning themselves or others,
• Immediately report potential violations related to themselves or others, providing reliable sources, information, and documents whenever possible, either anonymously or by identifying themselves, to their manager, human resources, or the Ethics Committee,
• Follow the “Ethical Decision-Making Procedures” established to assist in solving problems and making decisions based on ethical guidelines,
• Cooperate with the Ethics Committee during ethical investigations, keeping the investigation information confidential.

Ethical Decision-Making Procedures
To guide you in making a decision or action plan, you should follow the steps below and ask yourself these questions:

1. Identifying the Event, Decision, or Problem
   • Were you asked to do something you believe may be wrong?
   • Are you aware of a situation in your company or with your partners that may be illegal or unethical?
   • Are you trying to make a decision but are uncertain about how to act ethically?
2. Think Before Deciding
   • Try to clearly define and summarize the problem or question,
   • Ask yourself why this is a dilemma,
   • Consider the options, potential consequences, and who may be affected,
   • Consult with others.
3. Decide on a Plan of Action
   • Identify your responsibilities,
   • Review all relevant facts and information,
   • Refer to appropriate company policies, procedures, and professional standards,
   • Evaluate risks and consider ways to mitigate them,
   • Try to create the best plan of action,
   • Consult with others.
4. Test Your Decision
   • Review the ethical questions that should be asked,
   • Reassess your decision in the context of the company’s core values,
   • Ensure you have considered company policies, laws, and professional standards,
   • Consult with others and evaluate their feedback on your plan.
5. Move Forward with Confidence
   • Share your decision along with your rationale with the relevant individuals,
   • Share what you have learned and your success story with others.

Key Questions to Consider

• Is this activity/behavior in compliance with laws, rules, and traditions? (Standards)
• Is it aligned with professional standards?
• Is it in accordance with the law?
• Is this activity/behavior balanced and fair? Would we be uncomfortable if a competitor (someone else) did it? (Sense of fairness)
• Is this the right thing to do, according to you?
• Would our company and stakeholders be uncomfortable if all details of this activity were made public? (Emotions and ethical values)
• Would you feel uncomfortable or embarrassed if others knew you acted this way?
• Could this lead to negative consequences for you or your company?
• Who else might be affected (other employees, shareholders, etc.)?
• How does the “perceived reality” overlap with “objective reality”?
• How would this reflect in the media?
• What would a reasonable person think in these circumstances?

Managers’ Responsibilities
Managers at Ekmob A.Ş. and its subsidiaries have additional responsibilities beyond the duties defined for employees. Accordingly, managers must:

• Ensure the creation and maintenance of a company culture and working environment that supports ethical guidelines,
• Be role models in applying ethical rules, educate employees about them,
• Support employees in communicating questions, complaints, and reports about ethical rules,
• Provide guidance when asked about what should be done and ensure that all reports are considered and promptly communicated to the Ethics Committee if necessary,
• Ensure that the work processes they are responsible for are structured to minimize ethical risks and apply necessary approaches to ensure compliance with ethical rules.

Ethical Rule Consultants’ Responsibilities
Ethical Rule Consultants are responsible for:

• Guiding employees in ethical issues and providing advice,
• Contributing to resolving internal ethical issues and forwarding unresolved issues to the Ethics Committee,
• Reporting ethical issues and violations regularly or upon request to the Ethics Committee with their findings,
• Acting as the point of contact for the Ethics Committee during investigations and providing the necessary support,
• Monitoring and supporting the effectiveness of the application of the Ethics Code within the company.