Code of Ethics and Working Principles

In the simplest terms, ethics analyze the generally accepted standards of judgment recognized all around the world in terms of human relations. Business ethics are, on the other hand, the set of principles developed to guide behaviors in the business world.

Aydem Enerji’s core values and principles guide our code of business ethics while at the same time constituting the expectations, standards and ethical practices that are the basis of all our business relationships and operations.

The Code of Ethics and Working Principles of Aydem Enerji define Aydem Enerji Anonim Şirketi and all its affiliates (Aydem Enerji) and all third parties acting on behalf of them, as well as the rules that the employees must follow, rights of employees, and ethical valuation and basic principles of the Company.

We need honesty and integrity from our employees in order to maintain the reputation, reliability and achievements that we have gained following the lead of our leaders. Behaviors that are unethical or in contradiction with our working principles can never be accepted or tolerated. It is the responsibility of each and every employee to protect the reputation and success of Aydem Enerji.

Each employee must do their best in professional terms to meet the needs of internal and external customers within the scope of their respective job. Employees must also work efficiently to contribute to their own objectives, as well as those of their departments and of the Company, and to meet customer needs.

Each and every one of us must especially:

• Act in compliance with the core ethical and human values and the corporation’s strategies when fulfilling our duties;
• Act within the framework of honesty and reliability, establish and maintain equal relationships with people, collaborate with other employees to reach common goals and use the Company’s assets and resources efficiently, effectively and respectably;
• Demonstrate behaviors and work ethics that comply with the “Code of Ethics and Working Principles” announced across the Company, read, understand and abide by all principles of our Company;
• Comply with all laws and principles, as well as all applicable legislations and regulations set out by the relevant regulatory authorities (Energy Market Regulatory Authority, Capital Markets Board, etc.) and the professional organizations where Aydem Enerji is a member, when fulfilling our duties;
• Act as per the fair competition principles and avoid unfair competition in all operations and in all relationships with other financial institutions;
• Never forget that being open, complete and honest with all our shareholders is part of our identity and reliability, and always act to improve the reputation of Aydem Enerji.

When doing our jobs as employees, each one of us must have the required common sense and make the necessary efforts, consider profitability and efficiency principles, and avoid all kinds of actions and operations that may cause loss to the Company. We must keep in mind that any behavior that violates or exceeds the limits set by our “Code of Ethics and Working Principles” may result in an ethics or disciplinary investigation as these code of ethics and working principles are considered the guarantee of our Company’s reputation.

Our Company expects its managers and all other employees to make judgements that comply with the “Code of Ethics and Working Principles” when fulfilling their duties. It is important for our managers and all other employees to frequently refer to these rules and to regularly check whether they are acting in compliance with the “Code of Ethics and Working Principles” and their purpose so that they can fulfill their duties in the most efficient and correct way possible in line with the Company’s goals.

As a company we are aware of the fact that the rules in this manual do not completely cover every question or every situation. In such cases, and for all your questions or opinions about the “Code of Ethics and Working Principles”, you can contact the Code of Ethics Consultant and the Human Resources Management.

Below is the contact channel provided for you to submit your questions regarding the “Code of Ethics and Working Principles” or to report those who violate the “Code of Ethics and Working Principles”, or the suspicious situations that may harm our reputation.

E-Mail : etik.aydemperakende@aydemenerji.com.tr

Tel : 0 (850) 575 0 575

Posta Adress :To the “Office of Ethics Committee” of Denizli given on the website of our Company

Ensuring Privacy in the Company

Our employees:

Are responsible for abiding by the details in Aydem Enerji Information Security Policy and the applicable legislation, with regard to information security.

Can under no circumstances use the personal or financial information of a customer, supplier or another employee without authorization/for non-business purposes (except for the disclosure of the information and documents requested by authorized persons or bodies as stated in the law and other legal regulations).

Cannot share the information or the documents they have as part of their jobs with internal or external unauthorized persons or organizations for any reason, or use them for speculative purposes (directly or through third parties).

Know that the work they produce within the scope of their jobs (such as projects, technical infrastructures, regulations, etc.) is the property of Aydem Enerji, and can never take the same or other similar efforts out of the Company without the prior written approval of the top executive of the Company.

Do not share any personal rights that must be known only by them with other internal or external parties.

Avoid criticizing the general policies of Aydem Enerji as such expressions may harm the company reputation.

Cannot discuss matters related to their duties while not on duty, and do not cause any circumstances that may lead to a speculation or a negative opinion.

Continue to be obliged to protect the personal and financial information of customers even if they leave their jobs at the Company for any reason. It is prohibited to take the confidential information out of the Company, share it with third parties or use it for personal matters outside the Company.

Protecting the Personal Data of Customers

It is of utmost importance for the credibility and reputation of Aydem Enerji that our employees follow the standards of professional behavior that ensure the relationship and information privacy between the Company and its customers. Discussing or talking about confidential information related to customers or transactions outside the regular business activities or in public areas including third parties could cause violation of such privacy.

Our employees must use any personal data they access as part of their jobs in compliance with the Personal Data Protection Law (KVKK) and the complementing legislations, company policies and procedures.

Use of the information obtained as part of the job or internal authority is limited to the situations where such use is absolutely necessary for the legitimate and appropriate business purposes of Aydem Enerji.

Consumption, address or identity details of eligible consumers must never be shared for the benefit of other retail/wholesale electricity companies.

In addition, information on how we handle our daily tasks (such as our strategic plans and products) and the non-public information related to customers must be used with due consideration. Even the slightest implication in this regard may cause misunderstanding.

If the employee leaves their job at Aydem Enerji for any reason, they continue to be obliged to protect the privacy of the information.

Company-Owned Information

Non-public information about the Company’s customers and other third parties, as well as any such transactions, computer software, know-how, materials, records, files, papers, programs, reports, reviews, data, client lists, trade secrets and all other information are the property of Aydem Enerji and cannot be used for non-business purposes.

Our employees are not authorized to disclose such information to any third party. Such information can under no circumstances be shared with or disclosed to a competitor or any third party during or after services.

Equipment and materials entrusted to the employees by the Company for their work are not considered personal belongings. Furthermore, the Company reserves the right to monitor, based on applicable laws, the employees’ user accounts and the electronic communication channels such as the email accounts, phones, computer systems and other electronic records entrusted to them for business purposes.

Storing Information

It is the responsibility of the employees to be familiar with all the policies on how to handle, distribute, transmit, store or dispose of the information in a safe manner. In addition to the following matters, all employees are obliged to abide by the provisions in the “Information Security Policy” published/to be published by the Company.

As Aydem Enerji employees, we are expected to follow these basic policies:

Restricting Access to Confidential Information

• All access to computers must be limited to the information required to handle daily tasks. Should there be a need to share information with parties outside the Company, this necessity must be examined in detail and if needed, it must be discussed with the Information Security Management and the relevant Code of Ethics Consultant.
• When sharing information with authorized persons, the information required must be shared at the required level only.
• Confidential information must be stored in places where it can be seen and accessed by authorized persons only. When not in use, documents containing confidential information must be stored securely in a drawer or cupboard, and not be left in fax machines, printers or other unsafe places.
• If distributed within the Company, confidential information must be put in an envelope with the word “Proprietary” written on it.

Protecting Information on Computer Hardware

• Laptops and other portable devices are quite vulnerable to theft. Such portable devices (computers, tablets, radio devices, mobile phones, etc.) must not be left in unsafe places. If a device entrusted to an employee gets lost or stolen, this must be reported to the Information Security Management and Human Resources Management in the shortest time possible.
• Before leaving their computers, the employees must make sure that they lock them or log off the system.
• User IDs and passwords are private information and must never be shared with anyone. The employee may be held responsible for the consequences of the use of the user ID or password, including unauthorized use, and of the damages to the company resulting from potential misuse. If you suspect that the user ID or the password is in danger, you must change the password and contact the Information Security Management.
• Configuration of the antivirus software installed on the computer provided by the Company cannot be changed. It is the employee’s responsibility to protect the computer entrusted to them by the Company against the viruses that are sent to the employee externally and that may expose company information.  

Relationships with Governmental and Public Bodies

The Company’s relationships with public administrations, political organizations, unions and other organizations must be based on the highest level of honesty, integrity, equality and independency.

Relationships with Customers, Suppliers and Other External Organizations

Our employees act in compliance with the principal of integrity in their relationships with customers, shareholders, affiliates and other firms on behalf of our Company.  

At Aydem Enerji, our main objective is to meet the needs of our customers. The level of customer satisfaction defines the success or failure of our Company, which is why our customers are the most important elements of our business. Ensuring customer satisfaction is the best advertisement we can possibly have. For this reason, customer relations management at the Company are based on the principles of professionalism, kindness, and above all, seriousness and reliability. Maximum level of honesty, equality and compliance with law must be maintained in customer relationships.  

Employees must provide customers with complete and clear information regarding the products and services offered by the Company. Employees are not authorized to give misinformation in order to gain higher profits. Our customers are clearly informed about their rights and liabilities in the activities they carry out with Aydem Enerji, and about the benefits and risks of the products and services offered to them. For this reason, our employees are obliged to be knowledgeable about both Aydem Enerji and the products and services offered by the Group Companies.  It is prohibited to use sales or communication techniques that are against the professional code of ethics, that give misinformation to the customer about the products and services, or that try to force the customer in the decision-making process.  

In addition to protecting the Company’s benefits from the activities carried out in the free market economy, employees avoid actions that may cause unfair competition based on the principles to ensure continuous trust in the energy sector, make efforts to improve the sector and work for joint interests. Employees, during the course of their duty, also do not express opinions or make comments -positive or negative- about competitors or their products and services.  

The above-stated rules also apply to the relationships with suppliers.  For relationships with persons or organizations from which we receive consultancy services, privacy conditions must be secured clearly with an agreement. On the other hand, an employee whose employment with the Company has been terminated can work at the Company for a temporary period as a consultant subject to a proposal by the manager of the relevant business unit followed by a review of the Human Resources Director and approval of the CEO.  

None of the Aydem Enerji employees can officially or unofficially make an actual or apparent commitment on behalf of Aydem Enerji without authorization according to the approved procedures, nor can they work with those who harm social ethics, the environment or public health.  

All Company employees must avoid all kinds of activities, practices and actions that are against the competition law, especially misuse of dominant position. Relevant rules are set out in the Competition Law Manual.  

Media Relations

In Aydem Enerji’s relationships with the press, our employees must avoid any act that may cause speculations or a negative opinion about our Company, and must refrain from practices and behaviors that may damage the reliability, reputation and consistency of our Company or the sector, or that may lead to unfair competition.  

Before the public and in areas where the audience thinks we are talking on behalf of the Company, we should not express our own opinions, but the Company’s opinions only.  Media relations for Aydem Enerji as a whole are handled by the Directorate of Corporate Communications. All external relations are maintained as per the procedures set out by the Company. All demands, interview requests and questions from print and verbal media must immediately be forwarded to the Corporate Communications Management Units at Aydem Enerji.  

For all contact details to be provided to third parties, prior approval must be obtained from the Directorate of Corporate Communications. Only authorized persons are allowed to engage in communications about the Company and the Company’s policies, practices and procedures.  

In posts shared on social media platforms, blogs, forums and emails, we avoid expressions that may cause third parties to assume that we are sharing the post on behalf of Aydem Enerji.  

The Aydem Enerji Digital and Social Media Principles Document is the basis for representing the corporate structure on social media.  

Conflicts of Interest

Aydem Enerji does not prevent their employees from engaging in external activities that will not cause them to neglect their internal responsibilities, that will not stop them from acting in line with the Company’s interests, and that are in compliance with our “Code of Ethics and Working Principles”. However, employees engaged in such activities must avoid possible or actual situations that cause conflicts between the Company’s interests and their own interests.

A “Conflict of Interest” arises when the personal interest of an employee and that of the Company affect/prevent each other. For example, an employee’s responsibilities or obligations that serve their own interests outside the Company or in their personal life may make it difficult for that employee to objectively/impartially and efficiently fulfill their responsibilities and tasks related to their job at the Company. A conflict of interest can also arise when one of the family members of an employee gains a personal benefit because of the employee’s position at the Company.

Any action or relation that may lead to a conflict of interest must be reported to the relevant Code of Ethics Consultant.

In order to prevent potential conflicts of interest, our employees:

• Avoid situations that would lead to an actual conflict of interest or the impression that there is a conflict of interest in favor of them or of the people related to them, and do not take part in the decision-making process for matters that are associated with their interests or that of the people related to them.
• Do not engage in any kind of personal financial relationship with the customers or suppliers, and do not use their business relations to gain personal benefits.
• Do not allow gift or benefit proposals that might affect their decisions or consent, or that might create a conflict of interest.
• Efficiently use the assets and resources of the Company only for the Company’s interests and benefits.
• Use their time and efforts for the Company, do not take on any other responsibility that would cause a conflict of interest, and do not work for another natural person or legal entity outside the Company.
• Comply with the principles of honesty and transparency, keep the required distance and maintain an unbiased attitude in their relationships with public bodies and institutes.
• Protect the secrets of the Company and the customers, and make sure that the Company’s proprietary information that would offer a competitive advantage is not taken out of the Company.  
• Do not use the information they have as per their jobs to get ill-gotten gains.  

Corporate Opportunities

When doing their jobs, employees from all levels must have the required common sense and make the necessary efforts, consider profitability and efficiency principles, and avoid all kinds of actions and operations that may cause loss to the Company. When there is an opportunity that will provide benefits for our Company, our employees are responsible for seizing such legal business opportunities.

Employees are not authorized to make decisions or carry out activities that are against the Company’s interests or not related to their responsibilities. In case of a potential conflict, the employee must immediately report the situation to the relevant Code of Ethics Consultant.

In case an opportunity arises for the benefit of Aydem Enerji as a result of the use of Aydem Enerji’s assets or information or through the relevant job position at the Company, the employee must avoid not using this opportunity because it is against their own interests, and avoid preventing other employees from using the opportunity.

Prohibition on Borrowing

Our employees can under no circumstances borrow money or gain benefits from or engage in a bailing relationship with customers or third parties during the course of or in relation to their duties.

Our employees must manage their personal and financial affairs in a responsible manner and must not go into debts that they cannot pay back. Our employees must have a balanced and consistent attitude with respect to their financial position both in their personal and professional lives.

While any debit/credit relationships are prohibited between the superiors-subordinates at the Company, employees also cannot be engaged in such a debit/credit relationship with the customers, suppliers and contractors.

Bribery

Bribery means directly or indirectly offering payments or interests to our employees to gain unlawful benefits or affect decisions and practices. Bribery can take many forms such as cash or non-cash payments, expensive gifts, offering the employee an advantage to serve their interests, etc.  When an employee is offered bribe by any person, company or organization, that employee must immediately report it to the relevant Code of Ethics Consultant.  

Political Activities

When fulfilling their duties, employees of the Company must not become members of political organizations using the Company’s name. In their personal memberships, on the other hand, they are obliged to avoid any activities that may harm the Company’s interests or reputation and adversely impact the working hours.  

None of our employees can engage in political resource management or campaign activities at the workplace or use the Company for such activities.  

Political Contributions

It is prohibited to make donations on behalf of Aydem Enerji (in cash or in any other way) to political parties, political organizations and the representatives and candidates of such groups, directly or indirectly, in order to gain advantages for the Company. Our employees must avoid situations that may imply monetary or moral support to political parties on behalf of Aydem Enerji.

Gift Acceptance

It is of great importance that the gifts sent to our employees due to their positions do not cause any suspicion in the eyes of third parties regarding the impartiality of our corporate judgements and decisions. Preventing inappropriate relationships with third parties that may harm the reputation of Aydem Enerji is only possible through a corporate approach and implementation with regards to gift acceptance. For this reason, our employees must follow the rules below when it comes to accepting gifts.

Our employees cannot request or accept an object/service that is above the nominal value (100 USD) for any transaction or business, or cannot request or accept cash, check, etc. of any value.

Same rules apply even if the person does not gain a direct advantage from this valuable object. Similarly, it is not allowed to accept something valuable on behalf of a third person or party.

Our employees must not accept or request gifts, entertainment or other offerings that may or aim to affect the preferences and decisions of our Company.

An employee who received a gift that is not in compliance with the rules above must inform their manager and return the gift to the person or organization who sent it. In cases where one cannot be sure if the gift is appropriate or not, a written approval must be obtained from the relevant Code of Ethics Consultant.

If it is determined that returning a gift with a value above 100 USD is not practical or may lead to a situation that is not desirable in terms of the business relationship in question, acceptance and use of the said gift is only possible upon written approval by the relevant Code of Ethics Consultant. In such cases, acceptance of the gift must at the same time (e.g. within 24 hours) be reported to the Directorate of Internal Audit and Control.

All gifts that have a value at or above 100 USD must be recorded by the Management, and the gift acceptance reports created must be stored by the Managers to be submitted to the Code of Ethics Consultant when necessary.

Furthermore, in order to prevent the relevant organization from sending similar gifts in the future, a thank you letter could be sent to them, explaining the principles and practices of our Company in this regard.

All employees are obliged to follow the procedures above and report any actual or suspected situation that is against these procedures to the relevant Code of Ethics Consultant and the Human Resources Management.

Offering Gifts and Donations

Gifts can be offered to customers, business partners or supplier representatives on behalf of the Company in order to maintain the business relationship. However, no matter what their value is, gifts must be of a nature that does not impact any decisions to be made within the scope of the principle of honesty and business relationships.  

The process must comply with the principles set out by the Aydem Enerji management and the general practices and must not damage the reputation of the Company. Principles regarding acceptance of gifts, invitations and donations are also valid in the process of offering them, and the 100 USD limit will apply.  

Acceptance of Activities Where Third Parties Are Sponsors or Cover the Expenses 

Our employees must not accept entertainment, free training, seminars, accommodation, trips, meals, etc. that are aimed at influencing their business decisions.  

However, the Company agrees that rejecting such offers in certain cases may harm the relationships with customers. For this reason, any free of charge offers that third parties or existing or potential customers make to our employees to attend a conference, promotional meeting, training, etc. can be accepted only upon written approval by the top executive of the relevant function and the relevant Code of Ethics Consultant.  

Accuracy of Records

It is vital for the continuity and future of Aydem Enerji’s success to ensure integrity, accuracy and reliability in all kinds of records, documents and financial statements issued for Aydem Enerji. For this reason, our employees are obliged to ensure that the records and documents are accurate and in compliance with the law in all transactions they carry out on behalf of Aydem Enerji.  

In addition to the accounting and auditing records, these documents also include time records, credit documents, phone records, transactional records and all the other records that are parts of our daily workflow. All records must accurately and timely reflect the transactions performed, and in case of a mistake, it must be remedied immediately.  

If any deception, modification and/or negligence is detected in the general activities of the Company, it must immediately be reported to the Code of Ethics Consultant and the Human Resources Management or the relevant unit of the Company.  

Stock Transactions of Employees - Insider Trading

Within the scope of the duty of loyalty, and the principles to protect the company interests, it is natural for our Company to have certain expectations from its employees. As part of these expectations:

It is possible for the employees to perform investment activities on the stock market with their shares at Aydem Enerji, on the condition that such activities comply with the regulations set out by the Capital Markets Board. However, employees acknowledge that using confidential information of Aydem Enerji or giving it to third parties with the aim of gaining benefits, including buying/selling shares on the stock market directly or indirectly, is considered insider trading and that such actions constitute a crime as per the law. Internal procedures that are created to implement the regulations of the Capital Markets Board are applied strictly. Employees listed in the document “with knowledge that may lead to insider trading” are expected to ensure full compliance with the relevant legislation and the company policies and procedures.

According to Additional Article 1: “Transaction Ban on Public Offerings” in the “Principles of Sales Methods for Public Offerings of Capital Market Instruments” No.22, Serial No. VIII of the Capital Markets Board: “When capital market instruments are being sold through public offering, issuers who issue and offer to public the capital market instruments, and the chair and board members, statutory auditors, deputy managers, general managers and deputy general managers, and other personnel that may have information as part of their jobs -as well as their spouses and any first degree relatives by blood or marriage- at the intermediary firms that mediate such public offering cannot directly or indirectly purchase the said capital market instruments.”

Aydem Enerji employees except for those stated in the above notice may participate in public offerings made by Aydem Enerji companies or other intermediary firms.

Using Company Assets and Resources

Any kind of property, asset, equipment, vehicle, computer, computer software, etc. that belongs to the Company and is provided to the employee to perform daily tasks cannot be used by the employee for personal benefits or for another person’s interests.  

Company phones, personal computers, copiers and fax machines, supplies, postal services, emails, notice boards and meeting rooms are principally for company use. Using these or other company resources for personal purposes may harm the information flow, which is critical.  

Company phone and the company address, email, internal communication and messaging system must not be used for personal correspondence or communications. Attention must be paid to keep personal phone conversations short.  

When using resources on behalf of Aydem Enerji companies, we consider the Company’s interests and pay attention to protect the company assets. We avoid losing, damaging, misusing and wasting the Group’s assets. If there is no benefit to the Company, we do not use the Company’s assets or facilities under any name whatsoever for purposes other than company business, regardless of whoever benefits from such use. If there is a public interest or obligation, approval must be obtained from the General Manager of the relevant business unit.  

Use of Technology

Aydem Enerji’s internet and intranet system is for business-related activities, communications and research. It cannot be used for other purposes (to watch movies/shows, etc.) and/or for obscene, pornographic or terrorism-related purposes. In addition, employees must not install or use unlicensed software on company computers. It is strictly forbidden to use company mobile devices to send messages that are harassing, threatening or that could damage the reputation of the Company.

External Assignments

Employees cannot engage in works that require them to be considered merchants or tradespeople (“Mercantile business” or “Tradesperson business”) directly or indirectly, cannot serve as a board member or auditor at companies other than Aydem Enerji companies without written approval from the relevant top executive, and cannot work for a fee or free of charge in any commercial business of natural persons or legal entities without prior written approval.

An employee may receive offers to participate in external activities as a paid or unpaid speaker or consultant due to the experience they have gained over the course of their business life. Such opportunities must be reviewed by the top executive of the relevant business unit and Corporate Communications Director in order to determine if there is a conflict between personal and corporate interests.

Business-Related Communications and Records

All kinds of communication, either written or verbal, must be professional and in compliance with our code of ethics. What we say, what we write and what we do must clearly reflect the ethics and expectations of Aydem Enerji, and must indicate the existence of a healthy, personal judgement. We must always avoid exaggeration, misguidance, lexiphanicism, extremely short statements, legal speculations, and words and behaviors that belittle persons, companies, or their products and services.

Everything that the employees say, write and do must be aimed at protecting and reflecting the honesty and reputation of Aydem Enerji. This policy applies to all types of communication including voice messages, emails, official notes and reports.

Email

An email is an important way of communicating internally and externally. Emails are records that can be disclosed only if it is legally obligatory to do so; otherwise, they must be kept confidential. An email that does not comply with our code of ethics can under no circumstances be written or sent.

All emails must be created considering the fact that they might be used as legal records, and must be written in a formal language. All kinds of messages must be sent according to all applicable policies and protected against unauthorized access.

Basic rules to be followed when handling emails are as follows:

• Emails are used when required by the job.
• When writing an email, it must be remembered that it can be considered a written record; therefore, it must be written using respectful, open, honest and precise statements. Hyperbolic statements, frivolous language, slang or derogatory remarks must be avoided when writing emails.  
• Replies must contain adequate information to avoid any misunderstanding. Email communications must comply with our code of ethics and policies, as well as the nature and purpose of such communications, and each message must be carefully reviewed before being sent.  
• Our standards for information protection and security also apply to email communications. Because email messages are sent to recipients outside the Company via public networks such as the internet, and they may stop or be misdirected in this process. For this reason, extreme care must be taken to ensure that the emails written do not contain any information that could be used to harm the Company, its customers, employees or shareholders.  
• If confidential information must be sent over the internet, secure (encrypted) emails must be used. ‘Highly Confidential Information’ related to the business must not be sent outside the Company via email.  
• In order to reduce the risk of customer information being exposed, if a customer sends an email that contains personal information, such information must be deleted from the reply message.  

Emails must not be used for:

• Sending or storing messages that might be considered offensive, derogatory or hostile;  
• Sending or storing messages that contain virus warnings or jokes (such warnings must be reported to the Information Security Management);  
• Engaging in communications or activities that might harm Aydem Enerji or any of its customers or shareholders;
• Forwarding chain messages that contain protests, donations or statements that exploit people’s emotions (those who send such messages must be warned, and the Code of Ethics Consultant must be informed of the presence of such chain messages in the system);  
• Sending messages that are not business-related and are aimed at entertainment; containing game, sound or image attachments that may affect the system capacity negatively;  
• Chatting on messenger programs during working hours; sending emails and messages to the extent that the work is neglected.  

Monitoring the Employee’s Use of Emails and Other Systems

Aydem Enerji reserves the right to monitor if the email, computer files or systems entrusted to employees are being used for the intended purpose.

The Company has the right to check and, when necessary, intervene and read all email communications. All kinds of document theft, contract theft, and unauthorized photo shootings, as well as any questions to employees with the aim of leaking information are considered security breaches. The personnel acknowledges this practice in advance. If the data/information security breach was made by an employee of the Company, disciplinary provisions shall apply for the relevant employee and the authorized person who committed negligence in that case. If it was made by an external person or organization, legal actions shall be taken if deemed necessary.

Within the scope of the ethical review and disciplinary proceedings, the Directorate of Internal Audit and Control is the only business unit that is authorized to review the device and software (notebook, external data storage device, mobile phone, tablet, email, Skype, SMS, etc.) entrusted to the employee by the Company. The Directorate of Internal Audit and Control may request the relevant records from the Directorate of Information Technologies in writing to review them. This authorization can never be transferred to another unit and the data cannot be shared with internal/external third parties. The Directorate of Internal Audit and Control is the sole holder of such authority as per the precedents by the Constitutional Court and the Supreme Court, as well as the Personal Data Protection Law (KVKK) and the related legislation, and the relevant articles of the Information Security Policy of Aydem Enerji.

Behaving Respectfully and Thoughtfully in Our Relationships with Others

At Aydem Enerji, our main purpose is to approach our employees respectfully, thoughtfully and sympathetically, and to create an environment that will contribute to a complete communication at all levels. We encourage our employees to openly discuss business-related issues and offer solutions to them.

The common goal must be to improve the team spirit within the Company, and to protect and enhance the corporate identity. At the workplace, all employees are responsible for creating and maintaining an environment that complies with all the values stated in this manual.

Aydem Enerji provides job opportunities for people who add to the corporate diversity in terms of race, religion, nationality, gender, sexual orientation, marital status, age, seniority, family, etc. Our employees must embrace such diversity and maintain relationships with each other in compliance with the principles of mutual respect, fairness, kindness, honesty and equality.

Employees must not disturb each other in common areas (including the shuttles) designated to them. It is prohibited to place posters, scripts or notes and to sell products or services in these places except for those areas allowed by the management.

It is not acceptable for an employee to harass another employee directly, or indirectly through phone, email, etc. Harassment includes but is not limited to the following:

• Using derogatory statements to define the members of a certain group;  
• Negative classifications, humiliating jokes, offensive statements;
• Mocking pictures or caricatures that humiliate a certain group or person;  
• Derogatory statements or physical attacks that affect the relationships between employees by creating an uneasy and hostile working environment;  
• Physical or verbal behaviors that do not keep the distance required by the working environment; associating an employee’s sexual orientation with their promotions, performance reviews, collaborations with colleagues, etc. or threatening them;  
• All kinds of unwanted sexual advances, sexual offers, speeches and similar behaviors.  

When an employee reports any harassment or inappropriate behavior at the workplace to the relevant management and/or the Code of Ethics Consultant, it is prohibited to blame and/or retaliate against them in any way. In addition, our managers must handle such cases with confidentiality.

In case of a harassment like above, or offensive, accusatory attitudes and behaviors, or a problem that negatively affects the labor force and performance within the Company, or in cases where an employee thinks that they are subjected to a similar behavior by their colleague, manager or a customer, the Code of Ethics Consultant and the Human Resources Management must be informed.

Our Principles on Harassment and Mobbing

We do not tolerate any kind of privacy violation through physical, sexual and/or emotional harassment towards our employees, or by our employees towards our shareholders we have a business relationship with, at the workplace or in any other place they visit for business purposes. Potential negative attitudes and behaviors against individuals who report such cases or help with the investigation of the same shall be considered violation of our code of ethics.  

We do not tolerate systematic or planned behaviors that are aimed at causing someone to become disinclined to work, deteriorating their performance or making them resign in a scheme that would be considered mobbing.  

Attitude/Behavior and Appearance

As Aydem Enerji employees, we must have a clean, nice and professional way of dressing in the working environment and be genial, attentive and respectful to everyone.  With our behaviors and appearance, we must represent Aydem Enerji, a corporation of trust, in the best way possible. This principle is vital to improve customer relations and increase the reputation of the Company and must be strictly followed.  

Creating team spirit in the Company, and protecting and improving the company image is a common goal that plays an important role at the workplace and in the personal life of each and every employee. We must have a balanced and consistent attitude in professional and financial terms in order to prevent potential negative effects on the work we do and/or the company image.  

Also in our relationships outside the Company, we must show an equal level of respect to our existing and potential customers, shareholders and the communities we serve.

This requires offering services in a kind manner and complying with code of business ethics, as well as all applicable laws and regulations. As employees of a customer-oriented company, it is our responsibility to act in a manner that will leave good impressions about Aydem Enerji.  

When performing our daily tasks, we must comply with the highest standards of integrity, and we must strive to do our work in the best way possible to reach the Company’s goals and objectives. We must use the time efficiently during working hours and make sure that our personal matters do not take too much time to avoid impeding the transactions of customers.  

Workplace Hierarchy

Improvement of employees greatly helps Aydem Enerji reach its goals. Managers must manage their employees based on professional criteria, and provide them with equal development and reward opportunities based on their contribution to the Company’s success. Managers coordinating certain tasks or departments must use their specific authorities in a balanced and impartial manner, considering the personal dignity of the personnel. Our managers must avoid exploiting their positions and responsibilities for doing something/getting something done outside the scope of their authorities, regardless of the purpose. Our managers must continuously support the professional development of their employees.  

Managers are responsible for offering and implementing management methods that will increase the value of the Company, provide maximum profit for the Company and protect employee rights in the long term, in compliance with the principles of honest and prudent management.  

Employees must avoid behaviors that are against the working principles and ensure maximum collaboration with their managers.  

As a general rule, our employees are responsible for following the orders given by their superiors. However, they are not obliged to follow the orders that may harm Aydem Enerji’s profitability, efficiency and reputation, or that are against the Company’s relevant principles and the legislation. If an employee believes that the orders are against the legal and/or internal regulations or harmful to the Company, they shall report such opinion to the manager of their superior who gave that order and the Code of Ethics Consultant. If an employee following an order believes that what they are doing as per the order is a crime explicitly stated in the relevant laws and regulations and/or that such order will cause loss to the Company, they must immediately report it to the Directorate of Internal Audit and Control.  

Relationships between different levels of task must be regulated in line with the rules of mutual loyalty and respect required by the hierarchy, within the Company in a manner that respects the Company’s values and goals.  

Kinship in Employment

Employees who have the following levels of kinship cannot be employed in such a way that they will directly report to the same manager in any department of the Company.

• Spouse, mother, father and children, siblings, uncles, aunts and their spouses and children  
• Spouse’s mother, father, siblings, uncles, aunts and their spouses and children

All actions that cover the family members and relatives of employees are carried out by other employees who are not associated with such actions.

Compulsory Attendance

Our employees are responsible for complying with the working hours determined for their respective workplaces and using the personnel attendance control system (card reader, fingerprint access, etc.) when entering and leaving the workplace. It is obligatory for employees to be present at the workplace during working hours.  

An employee who leaves their place of duty for any reason must report this to their immediate manager or to their nearest colleague so that they can report it to the said manager.  

An employee who must be outside the company as per their job must inform their manager about the place they are going to and the time they will spend outside.  

Sharing Information with Colleagues - Handover Obligation

An employee who is leaving their job temporarily or permanently cannot do so unless they hand over the money and other assets that can be used as money, as well as the documents, vehicles and tools they have had to keep and use. This principle also applies to those assigned to temporary duties.  

If failure to do the handover causes loss to the Company, those who caused it shall be held responsible.  

Equality of Opportunity/ Providing Equal Opportunities in Employment

Aydem Enerji aims to create a working environment where the talents and experiences of each individual are valued, diversity is respected, and each and every employee can express their thoughts and opinions.  

Respecting diversity is not only the correct way of doing business but is also vital for success.  

Aydem Enerji does not allow discrimination between employees. It ensures that all practices regarding the personnel are handled based on individual capabilities and qualities, regardless of race, religion, color, age, gender, national origin, sexual orientation, physical disabilities, seniority or other factors defined and protected under the law. These practices include but are not limited to recruitment, election, performance management, training, onboarding, transfers, promotions, disciplinary actions and termination of employment.  

The Code of Ethics and Working Principles of Aydem Enerji were released by the Board of Directors and are reviewed annually according to needs, changing conditions and current practices.

Violations of the Code of Ethics and Working Principles, and Possible Consequences

Our Code of Ethics and Working Principles are among the main contributors of our reputation and continued success in the sector. Violating these rules and principles may adversely affect our reputation and success in the sector. For this reason, unethical behaviors that are against our principle of honesty or acting outside the working principles requires ethical review or disciplinary investigation. All employees are obliged to comply with these rules.

Our employees have the obligation to fulfill their responsibilities according to the applicable written laws, regulations and legislations, as well as the general practices. When fulfilling their responsibilities or doing their daily tasks at the Company, employees can under no circumstances engage in an illegal activity or inform anyone this way.

Violating the laws, corporate principles or the code of ethics in any way such as refusing to collaborate in an investigation can be subject to ethical review or disciplinary investigation.

Roles and Responsibilities of Code of Ethics Consultants

A Code of Ethics Consultant is the top manager responsible for the human resources management at each company of Aydem Enerji. Code of Ethics Consultants are responsible for:

• Offering guidance and consultancy to company employees about their questions and concerns on ethics;  
• Escalating to the Ethics Committee any ethical non-compliances at the company that could not be resolved or require ethical reviews or disciplinary investigations;  
• Contributing, as per the Ethics Committee’s request, to the resolution of internal ethical non-compliances they have been informed of;  
• Reporting the ethics questions and non-compliances, together with their results, to the Ethics Committee regularly or upon request;  
• Acting as the contact person for the ethical reviews and investigations requested by the Ethics Committee and supporting the reviews and investigations made by the Directorate of Internal Audit and Control;  
• Tracking and monitoring the efficiency of the ethics practices applied at the Company, and providing support in implementation.  

Roles and Responsibilities of Managers

Managers at Aydem Enerji have additional responsibilities beyond those defined for employees in the Code of Ethics and Working Principles. Accordingly, managers are responsible for:

• Ensuring that a corporate culture and working environment that support the code of ethics are created and maintained;  
• Leading by example in the implementation of the code of ethics, and training their employees on the code of ethics;  
• Encouraging their employees to submit their questions, complaints and reports on the code of ethics;  
• Guiding those who consult them on what to do, taking into account all the reports submitted and, where required, sending such reports to the Ethics Committee in the shortest time possible;
• Ensuring that the business processes they supervise are structured in a manner that will minimize ethical risks, and adopting the methods and approaches required to ensure compliance with the code of ethics.  Uyumsuzlukların Çözümlenmesi

Resolving Non-Compliances

Ethical non-compliances are resolved by the Ethics Committee of Aydem Enerji.

The Ethics Committee is comprised of the Chair of the Board of Directors, Human Resources Top Executive of the Group, and Legal Top Executive of the Group. The Ethics Committee assesses the ethical review and disciplinary investigation reports drawn up by the Directorate of Internal Audit and Control in order to evaluate violations. Ethics Committee’s functioning, decision-making processes, relationships with the Disciplinary Committees at the companies and reporting practices are detailed in the Disciplinary Practices Procedure.

Reporting Violations, and Working Principles of the Ethics Committee

The Ethics Committee carries out their operations as per the following principles:

• It keeps confidential the reports and complaints, as well as the identity of those who have submitted those reports or complaints. It adopts a policy that prohibits retaliatory attitudes and behaviors against employees or persons who have reported an ethical violation.
• It conducts reviews and investigations according to the rules of confidentiality.
• It has the authority to directly ask the relevant unit for the information, documents and evidence associated with the review and investigation. It can review the information and the documents obtained only for the relevant investigation purpose.  
• The review and investigation process is written down in a report from the beginning. Information, evidence and documents are included in the report.
• Notifications related to the review and investigation are immediately handled and a consequence is reached in the shortest time possible.  
• Decisions made by the Committee are implemented with immediate effect.  
• Relevant departments and authorities are informed about the consequence.
• When fulfilling their duties during this process, the chair and members of the Committee act independently of and without being affected by the managers of the departments they work for and the organizational hierarchy. They cannot be forced or given suggestions on the subject matter.
• The Committee, if it deems necessary, can consult an expert’s opinion and work with experts during the review or investigation process on the condition that measures are taken to avoid violating the principles of confidentiality.  

For your questions and reports, you can use the contact channels below or directly contact the members of the Ethics Committee.

E-Mail : etik.aydemperakende@aydemenerji.com.tr

Tel : 0 (850) 575 0 575

Posta address: To the “Office of Ethics Committee” of Denizli given on the website of our Company