1.0 PURPOSE It is to determine the ethical rules of conduct and working principles that all managers and personnel working at Ekovar A.Ş. must comply with during the term of the service contract. 2.0 SCOPE It covers all managers and personnel employed in Ekovar A.Ş. on a permanent, temporary or part-time basis with a service contract. DEFINITIONS Ethics: It is defined as the science of morals, the science of ethics, moral, related to morality. Ethics, in its simplest definition, is moral philosophy. Morality: The concept of morality, on the other hand, is a discipline that regulates the relations of people in social life. Morality is a set of unwritten rules that determine the behavior of a society that is accepted as good or bad. •Ethics is the theory of right and wrong behavior. Morality is its practice. • The concept of ethics is used when it comes to principles, while the concept of morality is used when it comes to behavior. • Ethics is the values ​​that a person wants to express in a particular situation, while morality is the way they put them into practice. Culture: It includes the way of life, language, tastes, literature, folklore, artistic activities and creative power of a society. Values: The importance that an individual places on different factors in his life. Value can also be defined as any mindset, object or activity that is important to the individual. Values ​​are accepted as criteria that direct all behaviors of individuals such as thoughts, attitudes and feelings. Norms: It is a set of criteria that ensures order, it is formed by considering and applying values ​​in relation to certain roles. Norm; guides the individual in determining mutual rights, duties and responsibilities. The individual’s attitudes and behaviors are evaluated according to the norm. OUR VALUES We work with the awareness of providing added value to the society, the environment, our business partners, our subcontractors and suppliers, and our customers. We take care of our values ​​that make up our corporate culture, and we give place to people who are compatible with our values ​​in our working life. Accuracy; It is a concept that points to truthfulness and reliability. Ethical behavior requires honesty and sincerity in dealing with others. Those who do not act sincerely and honestly damage relations and the atmosphere of trust disappears. Legality: To abide by the law in the provision of all kinds of services in business life and in solving problems related to employees. Competence: There are constant developments in business life every day. To follow these developments, to renew oneself, to adapt it to business life. Impartiality: Impartiality or objectivity is the ability to see individuals or objects as they are and to distinguish this image from the image created by the individual’s own desires and fears. Respect: People are valuable because they are human beings first of all. The value and dignity of human beings are important in human relations. Respect means seeing a person as they are, recognizing their personality and uniqueness. Openness: Requires mutual communication. In interpersonal communication, the participants must be face to face, there must be mutual communication between the participants, and the messages in question must be verbal or nonverbal. In order for managers to be open, they must be open to criticism. OUR ETHICAL CONDUCT RULES AND POLICY At Ekovar, the basis of ethical behavior rules is not only the generally accepted ethical values, but also the corporate values ​​that make up the corporate culture. Respect • It is considered that communications with customers, business partners or suppliers reflect Ekovar, and a meticulous and respectful language is used.

• Ekovar employees respect the privacy, private life, personal preferences, cultural and religious differences of their colleagues.
and they cannot discriminate for the purpose of misusing or favoring this information.

• Managers cannot assign non-work assignments to employees.

• Individuals’ ideas or beliefs on matters related to religion and private life are tolerated.

• The national and religious values of our employees who are citizens of other countries are respected.

• The records of the employees are kept confidential by the relevant units.

• The confidentiality of employees’ activities outside of work is respected.

• No conversations or correspondence can be made between Ekovar employees and/or their customers outside the boundaries of morality.

• Verbal, physical and/or psychological pressure and harassment cannot be made for the purpose of psychological violence (mobbing). Compliance with Laws and Regulations

• Ekovar is obliged to ensure that all employees of the company always act in accordance with the law, by displaying legal, professional and ethical behavior while conducting its business activities, by valuing transparency and reliability in administrative and management practices.

• Ekovar employees are obliged to act in accordance with laws, regulations and regulations while carrying out their work.

• While fulfilling their duties and responsibilities, Ekovar employees are obliged to comply with the company’s working principles and/or all regulations and announcements published in writing on the intranet and/or announced by e-mail.

Information Privacy

As an Ekovar employee, you have the broadest access to information about Ekovar and its partners, based in part on your location. This information, including fees and compensation policies applied at Ekovar, is hereinafter referred to as “Company Information”. You should handle Company Information very carefully in all your professional and private internal and external contacts. Your obligation here is to keep Company Information confidential. Our actions and omissions may harm the interests and reputation of Ekovar and its customers. It is very important that we are aware of this and act with integrity both in the work environment and outside.

Ekovar employees are responsible for keeping company information confidential and ensuring that the said information is not distributed without permission. Ekovar has a clean desk policy, therefore company information that has not yet been disclosed to the public should not be easily accessible by persons other than Ekovar employee(s) and/or Ekovar partner(s) who are aware of them due to their location.

• Files, documents, USB, CD-ROM and all other data carrier devices containing confidential and private company information should be kept locked after use and in any case, especially after working hours.

• Passwords used in systems should not be written on places that can be seen by everyone, such as desktops or screens. You are expected to set your computer to require a password login automatically after a period of inactivity. Documents containing confidential information should not be shared over the public network, and waste documents containing confidential information should be destroyed. Ekovar employees are obliged to ensure the security of all kinds of documents containing confidential information on their computers, portable memory, external disk and similar data storage environments. If confidential/important data needs to be placed on a USB or external disk, it should be encrypted and stored.

• Company records or documents cannot be taken, changed or destroyed without authorization. Accurate Information Sharing & Accurate Reporting • False, misleading or false information cannot be shared for the company or its employee in internal or external communication.

• All kinds of changes in personal, family, marital and address status, personal, family or relatives based on the rights and obligations set forth in contracts and/or regulations, and the documents on which they are based, are reported and delivered to Human Resources.

• Timely, complete and accurate record keeping, reporting and presentation are very important for Ekovar to be a reliable organization. For this reason, false, incomplete and/or misleading record keeping, accounting, statements, documents, (tax) returns and reporting are strictly prohibited. It is your responsibility to apply this rule in your daily activities.

Information Sharing with the Press & Social Media • Press communication is an important tool of corporate reputation management. If you receive a communication request from members of the press regarding Ekovar and its activities, you should direct this request to the spokespersons of the business unit you work for and the Corporate Communications Department without using any right to speak.

• Making a statement to any broadcasting organization, interviewing, seminars / conferences, etc. Participating as a speaker in the workshops is subject to the approval of the company’s senior management. No profit can be made from these activities.

• Ekovar employees, on their personal accounts in social media or in their Ekovar accounts, political, religious, etc. on sensitive issues, which may be associated with the institution, perceived as the opinion of the institution, and which may disclose the private company information of Ekovar or the institutions we cooperate with, employers should avoid. Use of Ekovar Resources • Ekovar assets, facilities and personnel cannot be used outside of Ekovar’s interests.

• It should be treated sparingly when using resources.

• Employees use their time well, do not spare time for their private work during business hours.

• Managers cannot assign employees for their personal work.

• It is essential that no special visitors are accepted during working hours. Employees must complete the negotiations for mandatory visitors in a reasonable time in connection with the subject of the visit and in a way that does not hinder the workflow.

• Business meetings should be held in appropriate meeting rooms.

• Time and effort are used for the institution; no other responsibility is assumed and no other natural or legal person can be employed.

• Employees can work in foundations voluntarily. For foundations, work is expected to be outside of business hours.

• Accessing inappropriate websites from company computers, sending abusive texts, images and e-mails via company-provided mobile phones also constitutes inappropriate use of company facilities; must be avoided.

• Company assets, belongings of other employees or visitors at the workplace cannot be abused or damaged.

Avoiding Conflicts of Interest • It is not appropriate for Ekovar employees to request personal benefits such as gifts, money, checks, property, holidays, special discounts or accept such gifts from other persons and organizations with whom they have commercial relations. In addition, promotional, giveaway (agenda, pen, etc.) gifts with corporate logos of institutions and organizations with which we have a business relationship can be accepted as they will not create a negative perception.

• The fact that the employee has a relationship with Ekovar up to a third degree, or the employee or a person with a third degree relationship with Ekovar’s competitor companies, suppliers or business partners may cause a conflict of interest.

• Situations such as establishing commercial relations between employees, teammates, managers and other employees, entering into any debt-debt relationship and thus establishing a relationship of interest will be considered as conflict of interest. Therefore, such relations and behaviors among employees are not considered appropriate by Ekovar.

• A personal financial relationship cannot be entered into with the customer, business partner or supplier, personal benefit cannot be obtained by using business relations.

• A distant and impartial relationship should be maintained in line with the principles of honesty and transparency in relations with customers, business partners and suppliers.

• All employees are obliged to report any conflict of interest they observe to the senior management.

Bribery and Corruption

• Ekovar prohibits dealing with bribery while conducting its business. You are requested to strictly comply with anti-corruption laws and regulations. It is forbidden to make financial and/or in-kind contributions to political parties or politicians, as well as to pay for any facilitating action regarding the company, valid for all areas in which Ekovar operates.

Our Company Management supports the implementation of these ethical rules against bribery.

• If you receive a bribe offer from anyone, you should report it to your manager immediately.

• Ekovar allows giving corporate business gifts prepared by senior management. You can get information from your manager and senior management on this subject, and if there is no gift already produced, you can produce a special gift solution together.

• These anti-bribery and anti-corruption rules are also valid and binding on our Company’s agents, consultants, distributors, suppliers and Joint Venture Partners (“Business Partners”) working on behalf of the company anywhere in the world.

Fairness and Credibility

• The professional and meticulous service approach offered from the beginning to the end in all business processes provides the perception and confidence of “correct and reliable”. The principle of trust and justice is the basis of relations with employees and all stakeholders.

• During the recruitment process, not only the key qualifications required for certain functions are taken into account; At the same time, attention is paid to competencies such as creativity, reliability, sensitivity, integrity and working in a team. It is important that the best possible candidates have the opportunity to apply for open positions, regardless of their age, gender, sexual orientation, marital status, disability, skin colour, racial or ethnic origin, and nationality. In addition, positive discrimination is applied to women in the recruitment process at Anel.

• Managers do not discriminate between subordinates and other colleagues. All employees are given the same opportunity to improve themselves.

• Even if it is in favor of the customer, a transaction cannot be made without the knowledge of the customer, and even if it is in favor of the company, the customer’s weaknesses are not exploited, and no profit motive can be sought by giving incomplete or incorrect information to the customer.

• The same principle of fairness and reliability should be observed in the selection of business partners and in the conduct of the business relationship. When serving customers, due care must be taken so that activities are acceptable in terms of human rights compliance. This also applies to third parties hired by Anel. If there is any doubt as to whether the activities of this 3rd person are legally acceptable or according to the Ekovariş Ethics Principles, the relevant unit manager should be consulted to evaluate this business relationship. If the client is an existing client, it may also be chosen to terminate the business relationship with management’s approval.

Private Transactions with Customers and Family • Ekovar employees should work free from their private business and personal interests with their customers and/or family members/acquaintances, and should act objectively without any prejudice.

Occupational Health and Safety • Ekovar invests in a safe and healthy working environment for employees in order to reduce the risk of accidents. Employees are encouraged to take care of the health and safety of themselves and others who may be affected by their actions.