1. Purpose

The purpose of the Anti-Bribery and Anti-Corruption Policy is to set out the anti-bribery and anti-corruption policies of Titiz Group, which are also included in the Titiz Group Ethical Principles and Code of Conduct.

2. Scope

The anti-bribery and anti-corruption policy covers the following persons and entities:

• All Titiz Group employees, including the Titiz Group Board of Directors,
• Companies and their employees from which we procure goods and services, and persons and entities acting on behalf of Titiz Group (business partners), including suppliers, consultants, lawyers, and external auditors

This Policy is an integral part of the Titiz Business Ethics Rules and Human Resources Practices approved by the Titiz Board of Directors.

3. Definitions

Corruption is the abuse of the authority held due to one's position, directly or indirectly, for the purpose of obtaining any kind of gain. Bribery is when a person, in order to perform, have performed, not perform, expedite, or slow down a task related to the performance of their duty, secures, offers, or promises a benefit directly or through intermediaries, and thereby, within the framework of an agreement reached with another person for acting contrary to the requirements of their duty, provides an advantage to themselves or the relevant party. Bribery and corruption can be carried out in many different ways, including:

• Cash payments,
• Political or other donations,
• Commissions,
• Social benefits,
• Gifts and hospitality,
• Hiring of a relative,
• Promotion,
• Other benefits

4. Duties and Responsibilities

The implementation and updating of the Anti-Bribery and Anti-Corruption Policy fall under the authority, duty, and responsibility of the Board of Directors. Within this framework:

• Senior management must assess risks in accordance with the principles set by the Board of Directors and establish the necessary control mechanisms,
• The Financial Affairs Coordination, Sales and Marketing Coordination, and Production Coordination must monitor whether Titiz activities within their areas of responsibility are being carried out safely and in compliance with legal regulations,
• Notification, investigation, and sanction mechanisms must be determined and operated in cases of non-compliance with policies, rules, and regulations

In addition, all Titiz employees are responsible for:

• Complying with the policies determined by the Board of Directors,
• Effectively managing the risks related to their own areas of activity,
• Working in compliance with the relevant legal regulations and Titiz practices,
• Reporting in the event of encountering any behavior, activity, or practice that is contrary to the Policy

5. Companies from Which Goods and Services Are Procured and Sold and Business Partners

It is mandatory for companies from which goods and services are procured and sold, and for business partners, to comply with the principles of the Policy and other relevant legal regulations; work with persons and entities that do not comply with these will be terminated.

5.1 Selection of Companies and Business Partners
When selecting companies from which goods and services are procured and sold, and business partners, senior management takes into account, along with criteria such as experience, financial performance, and technical competence, their ethical standards and having a positive track record in this field. Companies or business partners with adverse intelligence regarding bribery or corruption will not be worked with, even if they meet other criteria.

5.2 Reaching Agreement with Companies and Business Partners
The following conditions are included in agreements and contracts to be made with companies and business partners that have positive intelligence and meet other criteria:

• Full compliance with the principles set out in the Policy and other relevant regulations,
• Ensuring that their employees internalize these principles and act in accordance with them,
• Ensuring that their employees receive training on the Policy at certain intervals,
• Regularly reminding their employees of their reporting obligations and the Ethical Business Rules, and encouraging them to report when they encounter such situations

6. Our Policies and Procedures

6.1 Bribery and Corruption
Titiz is opposed to all forms of bribery and corruption. Regardless of the purpose, accepting or giving bribes is strictly unacceptable. Business relationships with third parties wishing to do business with Titiz Group through bribery or corruption must not be continued.

6.2 Gifts
A gift is a product that does not require a monetary payment and is usually given by persons or customers with whom there is a business relationship, as a gesture of thanks or commercial courtesy. Any gift offered or given by Titiz to third parties must be offered openly, in good faith, and unconditionally.

6.3 Facilitation Payments
Persons and entities within the scope of this Policy do not offer facilitation payments to secure or expedite a routine transaction or process with government bodies.

6.4 Donations
With an understanding of social responsibility, Titiz Group may provide aid and donations to individuals, non-governmental organizations, associations or foundations, universities, and public institutions and organizations that operate in the fields of education, culture, arts, environment, and sports.

7. Accurate Record Keeping

The issues that Titiz Group must comply with regarding its accounting and record-keeping system are determined by legal regulations. Accordingly:

• Any and all accounts, invoices, and documents relating to relationships with third parties must be recorded and preserved completely, accurately, and in a reliably verifiable manner,
• No falsification may be made and facts may not be distorted in accounting or similar commercial records relating to any transaction

8. Training and Communication

The Anti-Bribery and Anti-Corruption Policy has been communicated to Titiz Group employees and is continuously and easily accessible via the KYS. Trainings are an important instrument for increasing employee awareness. Within this scope, Human Resources designs training programs in which participation of all employees is mandatory.

9. Reporting Policy Violations

If there is a view or suspicion that an employee or a person acting on behalf of Titiz Group has acted in violation of this policy, it must be communicated to senior management. Titiz encourages an honest and transparent approach; it supports any employee who, in good faith, voices their sincere concerns, and keeps notifications confidential. No employee may be subjected to pressure or punishment for a report they make based on a belief that there has been a violation of the Ethical Rules.

10. Policy Violations

In cases that are contrary to or may potentially be contrary to the Policy, the matter is examined and, if non-compliant behavior is identified, the necessary sanctions are applied. In contracts concluded with companies from which goods and services are procured and sold, or with persons and entities acting on behalf of Titiz, provisions are applied stating that, in the event of detecting behavior contrary to the Policy, the work and current contracts will be unilaterally terminated by Titiz for just cause.