A. Integrity

Accuracy and honesty are our primary values in all our business processes and relationships. In our relations with our employees and all our stakeholders, we act with transparency and integrity.

B. Confidentiality

Confidential and private information includes information belonging to Titiz Grubu Şirketleri that may create a competitive disadvantage, trade secrets, financial and other information, information related to personnel employment rights, and information covered under "confidentiality agreements" concluded with third parties. As Titiz Grubu employees, we take care to protect the privacy and private information of our customers, employees, and other relevant individuals and institutions we work with. When leaving our company, we do not take outside any confidential information and documents, or projects, regulations, etc. that we possess due to our duties.

C. Conflict of Interest

As Titiz Grubu employees, we aim to avoid conflicts of interest. We do not derive personal benefits from persons and institutions with which we have business relations by taking advantage of our current positions personally, through our family, or our close relatives. We do not engage in any business activity based on additional financial gain outside Titiz Grup Şirketleri. We do not use the Titiz name and power for personal benefit.

D. Our Responsibilities

In addition to our legal responsibilities, we take care to fulfill the responsibilities listed below towards our customers, employees, shareholders, suppliers and business partners, competitors, society, humanity, and the name Titiz.

1. Our Legal Responsibilities

We carry out all our current activities and transactions domestically and abroad within the framework of T.R. laws and the legal norms of the regions in which we operate, and we provide accurate, complete, and understandable information to regulatory institutions and organizations in a timely manner. While conducting all our activities and transactions, we keep an equal distance to all public institutions and organizations, administrative bodies, non-governmental organizations, and political parties without any expectation of benefit.

2. Our Responsibilities Towards Our Customers

We work with a proactive approach focused on customer satisfaction, responding to the needs and demands of our customers as quickly and accurately as possible. We provide our services on time and under the conditions we have committed to; we approach our customers within the framework of rules of respect, dignity, fairness, equality, and courtesy.

3. Our Responsibilities Towards Employees

We ensure that employees fully and correctly exercise their employment rights. We approach employees honestly and fairly and commit to a non-discriminatory, safe, and healthy working environment. We make the necessary effort for the individual development of our employees and pay attention to the balance between work and private life.

4. Our Responsibilities Towards Our Shareholders

By primarily attaching importance to the continuity of Titiz Grubu and in line with our goal of creating value for our shareholders, we avoid taking unnecessary or unmanageable risks and aim for sustainable profitability. We act within the framework of financial discipline and accountability and manage our company's resources and assets, as well as our working time, with an awareness of efficiency and savings.

5. Our Responsibilities Towards Our Suppliers/Business Partners

We act fairly and respectfully as expected from a good customer and take the necessary care to fulfill our obligations on time. We diligently protect the confidential information of the individuals and institutions we do business with and our business partners.

6. Our Responsibilities Towards Our Competitors

We compete effectively only in areas that are legal and ethical and avoid unfair competition. We support efforts aimed at ensuring the competitive structure targeted within society.

7. Our Responsibilities Towards Society and Humanity

The protection of democracy, human rights, and the environment; education and charitable works, and the elimination of crime and corruption are very important to us. With the awareness of being a good citizen, we act sensitively and as a pioneer in social matters. We do not give or accept bribes or products and services such as gifts that exceed their intended purpose.

8. Our Responsibilities Towards the Name "Titiz"

Our business partners, customers, and other stakeholders trust us thanks to our professional competence and integrity. We strive to keep this reputation at the highest level. We provide our services within the framework of company policies, professional standards, our commitments, and ethical rules.

II. Policies Supporting the Code of Business Ethics

A. Conflict of Interest Policy

It is essential that Titiz Grup Şirketleri employees avoid situations that may create conflicts of interest. Not using company resources, its name, identity, and power for personal benefit, and avoiding situations that may adversely affect the institution's name and image are among the most important responsibilities of all employees.

i. Engaging in Activities That May Create a Conflict of Interest

Employees shall not, under any circumstances, enter into business relationships with family members, friends, or other third parties with whom they have relations that provide mutual or non-mutual benefits. It is essential that Titiz Grup Şirketleri employees do not engage, directly or indirectly, in activities that would require them to be considered a "merchant" or "tradesman". Titiz Grup Şirketleri employees cannot serve as members of the board of directors or auditors in companies outside the Group Companies without the approval of the Company's Board of Directors.

ii. Abuse of Position

It is unacceptable for employees to harm the companies by using their authority for their own and/or their relatives' benefit and beyond the due care expected of them. Employees cannot obtain personal gains, directly or indirectly, from the company's purchasing and sales activities and from all transactions and contracts in which it is a party.

iii. Use of Resources

In the use of resources on behalf of the company, the company's interests are taken into account. Regardless of the name under which it may occur, company assets, facilities, and personnel cannot be used outside the company without a company interest. The principle of "savings in every matter" is applied by all personnel.

iv. Relations with Persons and Institutions with Which the Company Has a Commercial Relationship

No private business relationship may be established with the company's customers, subcontractors, or suppliers, or with other persons and/or institutions with which the company has a commercial relationship. No transaction can be carried out without the customer's knowledge, even if it is in the customer's favor, and the customer's weaknesses cannot be exploited.

v. Relations with the Media

In relations with the media, action is taken in line with the Company Communication Procedure. Giving statements to any media outlet, conducting interviews, and participating as a speaker in seminars, conferences, etc. are subject to the approval of the company's top management.

vi. Representation of the Company

Any and all fees that may accrue due to duties performed in any association, employers' union, or similar non-governmental organization representing the company shall be donated to the relevant institution or to channels indicated by the relevant institution.

B. Policy on Accepting and Giving Gifts

It is essential that Titiz Grup Şirketleri and its employees do not accept any gifts or benefits that may affect their impartiality, decisions, and behaviors. The implementation principles defined below regulate possible exchanges of gifts between company employees and third parties and institutions with whom they are in a business relationship.

• It is prohibited for company employees to receive any benefits or gifts that affect or may potentially affect their impartiality, performance, or decision-making.
• Gifts that are compatible with the institution's business objectives, comply with applicable legislation, and are limited to conditions under which disclosure to the public would not put the company in a difficult position may be received and/or given.
• Entertainment, hospitality, and meals at acceptable standards in the business world may be offered and accepted.
• It is prohibited to accept gifts or benefits that are implicitly or explicitly contingent on a quid pro quo.
• Receiving, giving, or offering bribes and/or commissions is under no circumstances acceptable.
• It is prohibited to accept money, whether as a gift or in the nature of a loan, from subcontractors, suppliers, consultants, competitors, or customers.
• When a gift is intended to be given to any public official or employee, the current decision of the Prime Ministry Ethics Board must be followed.

C. Policy on Protection of Confidential Information

Information is one of the most important assets that Titiz Grup Şirketleri will use in realizing its vision. The effective use of information, its proper sharing, and ensuring the confidentiality, integrity, and accessibility of information throughout this process are the joint responsibility of all our companies and employees.

• Confidential information cannot be disclosed to third parties unless its disclosure is mandatory by official authorities and legislation.
• This information cannot be altered, copied, or destroyed. Necessary precautions are taken to ensure that information is kept carefully and is not disclosed.
• Confidential files cannot be taken outside the institution. For confidential information that must be taken outside the institution, approval must be obtained from the information owner or top management.
• Passwords and user codes used to access company information are kept confidential and are not disclosed to anyone other than authorized users.
• Company confidential information is not discussed in public places such as dining halls, cafeterias, elevators, and similar areas.
• If information is to be shared with third persons and/or institutions, a confidentiality agreement is first signed or a written confidentiality undertaking is obtained from the other party.
• Personnel salary, fringe benefits, and similar employment-related information are confidential and cannot be disclosed to anyone other than authorized persons.

III. Applicable Legislation

Since Titiz Grubu Şirketleri operate in international markets, company operations may be subject to the laws and regulations of different countries. When there are questions regarding business ethics in different countries, the local regulations of the country where the work is performed should be followed first.

IV. Responsibilities of Employees

The relevant policies and procedures have defined in detail the ethical rules regarding how we should behave and how we should perform our work. Compliance with these rules is the primary responsibility of all employees. In this regard, the responsibilities of all Titiz employees are to:

• Act in compliance with laws and regulations under all circumstances,
• Read the Titiz Code of Business Ethics, know, understand, internalize, and act in accordance with the rules, principles, and values it contains,
• Learn the general and job-specific policies and procedures that are valid for the company,
• Consult their manager and human resources regarding potential violations concerning themselves or others,
• Promptly report their own or others' possible violations,
• Cooperate in ethical investigations and keep information related to the investigation confidential

V. Responsibilities of Managers

In addition to the responsibilities defined for employees within the framework of the Code of Business Ethics, Titiz managers have additional responsibilities. Accordingly, managers are responsible for:

• Ensuring the creation and maintenance of a company culture and working environment that supports ethical rules,
• Setting an example through their behavior for the implementation of ethical rules, and training their employees on ethical rules,
• Supporting their employees in raising questions, complaints, and notifications regarding ethical rules,
• Ensuring that the business processes under their responsibility are structured in a way that minimizes risks related to ethical issues

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VII. Other Responsibilities

Company top management is responsible for the effective implementation of the Code of Business Ethics and for creating a culture that supports it. The Code of Business Ethics and all related policies are reviewed, revised, and documented by Human Resources and communicated to the companies with the approval of the Chairman of the Board.

• Company Human Resources is responsible for periodically providing training with the aim of informing employees about the Ethical Rules and ensuring the comprehensibility of the policies and rules.
• Company managements are responsible for guaranteeing the confidentiality of complaints and notifications made within the framework of ethical rules and for protecting individuals after their notifications.
• They are responsible for ensuring the job security of employees who make notifications and for guaranteeing that complaints and notifications are investigated in a timely, fair, consistent, and sensitive manner.

VIII. Resolution of Non-Compliance with Ethical Rules

Those who violate the Code of Business Ethics or company policies and procedures will be subject to various disciplinary sanctions, which may extend to termination of employment where necessary. Disciplinary sanctions will also be applied to those who approve or direct inappropriate behaviors, or who are aware of them and fail to make the necessary notification in an appropriate manner.