Code of Ethics and Compliance Policies

Within the scope of the "Compliance Project" carried out under the leadership of Koç Holding between 2018 and 2020, a "Compliance Program" has been implemented within the Koç Group, with the approval of the Koç Holding Board of Directors, in light of the risk assessments made regarding the group companies and good practices on a global scale.

In line with the Koç Group Ethical Principles and policies, which have been updated in this context, guiding and guiding all employees, those acting on behalf of the group and business partners, a “Compliance Program” has been implemented within our Company with the approval of our Board of Directors, and our Ethical Principles, Sanctions and Export Controls, Bribery and Export Controls Compliance policies developed on many issues including Anti-Corruption, Supply Chain, Human Rights, Protection of Personal Data, Donation and Sponsorship have been put into effect.

The reporting mechanism (Ethics Hotline) for the detection of violations of the applicable legislation, Ethical Principles and compliance policies is made available to all Koç Group employees, Koç Group business partners and all Koç Group stakeholders from all over the world.

KoçSistem Ethical Principles draw a comprehensive framework for KoçSistem employees and stakeholders, particularly on issues such as human rights, fight against bribery and corruption, prevention of conflict of interest, economic sanctions, protection of confidentiality and inside information, occupational health and safety. Compliance with the Ethical Principles and policies is the duty of all KoçSistem employees under the leadership of KoçSistem senior management.

KoçSistem's obligations under the Compliance Program are not only limited to complying with mandatory regulations or contractual obligations, but also include voluntary compliance commitments or organizational standards undertaken by KoçSistem such as contracts, policies and procedures with third parties.

In this context, as KoçSistem

We base ourselves on the goals and principles of Vehbi Koç, the founder of the Koç Group, and carry out our duties in the light of these principles.

Our decisions and actions are guided by honesty, honesty, responsibility, trust and respect; We exhibit attitudes and behaviors that will ensure cultural integrity within the framework of these values.

We act in accordance with KoçSistem and Koç Group Ethical Principles and compliance policies, as well as the legal regulations of the countries with which our company has a business or business relationship.

We do not remain silent when the Ethical Principles and compliance policies and/or applicable legislation are violated or compelled to violate.

We act in accordance with the spirit of our Ethical Principles and in line with the basic ethical values in cases that are not expressly included in the Koç Group and KoçSistem Code of Ethics or Compliance Policies.