Electrip Global Ltd - Code of Conduct PDF

ELECTRIP GLOBAL LTD – CODE OF CONDUCT CODE OF CONDUCT I  ELECTRIP GLOBAL LTD – CODE OF CONDUCT Integrity is doing the right thing, even when no one is watching”...

ELECTRIP GLOBAL LTD – CODE OF CONDUCT CODE OF CONDUCT I  ELECTRIP GLOBAL LTD – CODE OF CONDUCT Integrity is doing the right thing, even when no one is watching” C.S.Lewis Dear Colleagues; We are a team of people united for common purposes, but with different cultures, backgrounds, opportunities and challenges: I am convinced that each of us brings valuable insights to our business. As we expand in a dynamic landscape, our common values and principles navigate us on our path. We are happy to share with you our “Code of Conduct” which is designed as a guide for our behaviours, decisions, interaction with our colleagues and external stakeholders. As Electrip Global, we conduct our activities by researching sustainable and smart energy solutions, which we are convinced are relevant components of the future of the territories in which we Nicola De Sanctis operate. Our business areas offer many opportunities for innovation Chairman and growth. We strive to offer innovative and sustainable solutions Electrip Global Ltd to our customers and to build a better world with them. Sharing common values makes us more united, and our customers become natural partners in our daily business. With this in mind, our Code of Conduct is based on transparency, respect and accountability, which are basic components in our relationships with our partners, internal and external, and in the management of all our business processes. In line with our principles embedded in our corporate sustainability vision, it is essential that all Electrip Global employees internalize the values and principles contained in this document. Our vision and mission require that we all refrain from behaviors that are not in line with our values. As a company, we embrace responsibility and accountability, which naturally bring along, open communication, avoidance of misconduct, unethical behavior and compliance to rules and laws. Last but not the least, I would like to remind you that as family members, we must take care of our colleagues and be scrupolous against any kind of corruption and bribery that could endanger our reputation. As we take our company into the future, we will grow the seeds we have sown together. Being a member of an ethical and well-recognized community requires the protection and support of core values. For a better future, we expect you, our valued colleagues, to adopt this Code of Conduct and act within the framework of these principles. II  ELECTRIP GLOBAL LTD – CODE OF CONDUCT (CONVENIENCE TRANSLATION into ENGLISH – ORIGINALLY ISSUED in TURKISH) "For Electrip Global Ltd to thrive and achieve success, it relies on the confidence of various stakeholders, such as employees, customers, business partners as well as the communities and societies it engages with. The foundation of this confidence is integrity – an unwavering dedication to upholding the highest standards of ethical business practices and professional behavior." Dear Colleagues, I am delighted to introduce the Electrip Global Ltd's Code of Conduct, reflecting the dynamic environment in which we operate and aligned with our sustainability goals. One of these goals is to instill a culture of integrity and transparency across our entire value chain. Electrip Global Ltd's growth and success hinge on the trust of our stakeholders, encompassing employees, customers, business İnanç Salman partners, shareholders, and the communities we serve. This trust is CEO fundamentally rooted in integrity—an unwavering commitment to Electrip Global LTD upholding the highest standards of ethical business conduct and professional behavior. In an era where technological advancements are rapidly accelerating, and speed is a crucial competitive advantage, our Code signifies our collective and individual dedication to integrity. It offers practical guidance on global business conduct, aiding us in making sound decisions amid ambiguous or complex situations. The Code embodies our company values—courage, care, curiosity, and collaboration—translated into concrete integrity practices, such as empowerment and accountability, respect and governance, awareness and continuous improvement, and transparency. Above all, the Code demands fairness, honesty, and respect in our interactions, compliance with all applicable laws and regulations, and the prompt reporting of Code violations. Additionally, we commit to maintaining safe and healthy work practices, adopting sustainable and environmentally responsible business approaches, and upholding human rights. The Code is applicable to all of us, and we pledge to hold each other accountable for our actions. To foster an environment where employees and other stakeholders feel comfortable reporting potential violations, the Code includes a commitment against retaliation. Let's collaboratively uphold the Code of Conduct as a reflection of our aspirations as a company, propelling Electrip Global Ltd's forward as both a technology leader and a trusted corporate citizen. 03  ELECTRIP GLOBAL LTD – CODE OF CONDUCT (CONVENIENCE TRANSLATION into ENGLISH – ORIGINALLY ISSUED in TURKISH) “At Zes Solar and Electrip Global , our success is not just about innovation and growth, it’s about earning the trust of those we serve. Whether it's our employees, customers, business partners, or the communities we impact, trust is the foundation of our relationships. We achieve this trust by maintaining an uncompromising commitment to ethical behavior, transparency, and respect in all actions we pursue.” Dear Colleagues, I am honored to share my perspective on our Code of Conduct, designed to guide us through the landscape of our business and foster a culture of integrity, transparency, and responsibility across all areas of our work. We believe trust is the key component in building our relationships at each level from employees to customers, investors, communities and Evren Evcit partners. We are determined to pursue our commitment to ethical CEO business practices and with this ambition we conduct ourselves, in Zes Solar both our professional and personal lives, to have a positive impact on the reputation and credibility of Electrip Global. In a fast- evolving industry; the importance of keeping the same distance with all parties we encounter and maintaining our loyalty to our values while adapting to new challenges is vital. This guide we declare hereby serves as a tool we should refer to while making sound decisions, especially when faced with complex or uncertain situations. Our values focusing on innovation, accountability, sustainability, and respect are the leverages to align our actions reflecting our Company’s vision and mission. At Electrip Global, we are keeping pace with the energy industry, which is on a green energy transition period, and we are committed to more than just developing cutting-edge solar technologies; we strive to lead by example, ensuring that our operations, products, and services are environmentally responsible and contribute to the global shift toward renewable energy. As we care for all the communities we are serving for; we ensure that our environmental impact, workplace practices, and business decisions align with sustainability targets. The Code emphasizes the importance of compliance with the laws and regulations and being fair, honest, and respectful in our daily interactions as a sign of our human-oriented approach. We encourage all these values and assure that any violation defined under this scope will not be underestimated or ignored. We expect our colleagues’ cooperation in our commitment to ethics, dignity, trust, accountability, health, safety, and human rights in all areas of operation, both internally and externally. As a big family, we are all responsible for upholding the values outlined in this Code. By working together and holding ourselves accountable, we contribute not only to the growth of our Company but also to the sustainable future we are collectively striving to build. As the ambassadors Zes Solar and Electrip Global, let’s ensure that every step we take reflects our high ethical standards. 03  ELECTRIP GLOBAL LTD – CODE OF CONDUCT (CONVENIENCE TRANSLATION into ENGLISH – ORIGINALLY ISSUED in TURKISH) 1. Purpose and Scope Electrip Global (Electrip Global Ltd) conducts its activities within the framework of the Electrip Global Code of Conduct, which has been approved by the Board of Directors and disclosed to the public through the company website. The Code of Conduct is a set of fundamental rules, essentially based on principles of “integrity and “fairness”, designed to govern the intra-company relations and relations between the Company and all employees with customers, suppliers, and other stakeholders, to increase the service quality and to increase the efficiency in protecting assets and resources. The ultimate purpose of the Code of Conduct is, as a responsible institution towards society, to build an ethical corporate culture that is based on written sets of rules to increase the awareness of our employees and stakeholders. In this respect, it is intended to act as a guide to company employees and those acting on behalf of the organization to be compliant with the law and business ethics in the decision to be made in performing their duties and the behaviors the way they act. Electrip Global Code of Conduct is applicable on a global scale, encompassing all individuals associated with Electrip Global, including employees, managers, officers, directors, consultants, self-employed contractors, casual workers, agency workers, and volunteers. This code extends its reach to wholly owned affiliates, subsidiaries, and employees of any joint venture or entity where Electrip Global holds a majority ownership interest or exercises effective control. We anticipate our business partners adhere to ethical standards aligned with our Code of Conduct. 03  ELECTRIP GLOBAL LTD – CODE OF CONDUCT (CONVENIENCE TRANSLATION into ENGLISH – ORIGINALLY ISSUED in TURKISH) 2. Relationships with Employees As Electrip Global, we respect human rights and the reputation of all employees. We treat our employees within the principles of equality and integrity. To create a safe and healthy working environment, we comply with all applicable laws and regulations and aim to create best practices. 2.1 Protection of Human Dignity As Electrip Global, we believe in the power of our employees in shaping the future. We acknowledge our employees as our most valuable asset, also respect and protect their rights. We provide a working environment for our employees, that is respectful, fair, and assuring human dignity. Electrip Global Ltd fosters an organizational culture that upholds human rights and strives to avoid involvement in human rights violations. We endorse the principles outlined in the International Declaration of Human Rights, the United Nations Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises, the International Labor Organization (ILO) Core Conventions on Labour Standards, and other relevant laws and principles. We mandate our suppliers, contractors, and other business partners to adhere to similar standards in areas where human rights issues may arise, including working hours and conditions, discrimination and equality, child labor, fair wages, compulsory or forced labor, and modern slavery. Please refer to Zorlu Holding Human Rights Policy for core principles. We adopt a fair, trustful, constructive communication approach; demonstrate ethical behavior as to affection and respect and avoid acts of humiliation and beneath one’s dignity. We value the input of our employees, and we encourage them by providing a working environment with free speech. In Electrip Global, we do not tolerate engaging in any behaviors that is, physical, sexual, and psychological harassment or violence and in any form of disturbing acts of mobbing, intimidation. We are sensitive about protecting the personal rights of our employees. We do not allow any kind of act of mobbing, harassment that violates personal values, and lead to psychological exhaustion. When such a situation is encountered, we carefully and diligently investigate the case subject to complaints and we ensure that the process is concluded fairly and quickly. We respect rights associated with freedom of association, collective representation, equitable compensation, impartial treatment, and secure and healthy workplaces. 2.2 Respect to Diversity and Equality As Electrip Global, we follow the global developments in human resources management and continuously improve the working environment to increase the loyalty of our employees, with a dynamic approach appropriate to the different needs of our sectors and functions. We do not make any distinction based on religion, language, race, ethnic origin, gender, and sexual orientation in all human resources processes covering from recruitment to wage management. We must treat others with dignity and respect and under no circumstances shall demonstrate or tolerate discrimination or harassment based on age, race, color, national origin, citizen status, political opinions, religion, marital status, gender, sexual orientation, gender identity, disability and any other status not otherwise mentioned. We shall not tolerate or exercise any form of harassment or bulling behaviour. We are a global organization with a workforce comprising individuals from diverse countries, backgrounds, and cultures. Our employees represent various genders, ethnicities, religions, generations, and abilities. We view our diversity as an asset that contributes to our strength and competitive edge. In fostering an environment where our employees are engaged, motivated, and empowered to fulfill their potential, we actively promote a culture centered on mutual respect, tolerance, and collaboration. At Electrip Global Ltd, our employment-related decisions, including hiring, retention, training opportunities, and promotions, are guided by factors such as competence, performance, and potential. We align with the 04  ELECTRIP GLOBAL LTD – CODE OF CONDUCT (CONVENIENCE TRANSLATION into ENGLISH – ORIGINALLY ISSUED in TURKISH) principles outlined in the International Labor Organization (ILO) Core Conventions on Labor Standards and adhere to relevant employment and labor laws in all the regions where we operate. This encompasses regulations related to wages, hours, immigration, collective bargaining, anti-discrimination, anti-harassment, bullying and other employment standards. Issues related to anti-harassment and bullying can be reported to Head of HR or the ethics hotline. Please refer to section 13.2 for reporting methods. 2.3 Child Labor As Electrip Global, we always take into consideration the importance of the young population and their contributions to our future as a society, and we care about this both in our foundation and in our working conditions. In this respect, while performing our operations, we act in accordance with the provisions prescribed by the Constitution Law, Labor Law, and relevant legislation, inclusive of minimum age clauses, and do not tolerate child labor in our companies and suppliers. 04  ELECTRIP GLOBAL LTD – CODE OF CONDUCT (CONVENIENCE TRANSLATION into ENGLISH – ORIGINALLY ISSUED in TURKISH) 2.4 Effective and Efficient Use of Working Hours Our working hours are shared source for Electrip Global and are used to carry us towards our common goals. As Electrip Global, our working hours are set by considering the balance of work and private life. It is essential that our employees spend their working hours in an efficient and effective manner with full awareness of their duties and responsibilities. We, at Electrip Global do not engage in activities that are not related to our duties and responsibilities during working hours. We behave professionally, refrain from speaking outside Electrip Global on any subject relating to Electrip Global and related entities unless authorized to do otherwise, contribute to implementing Electrip Global best practices, particularly in the areas of risk management, prevention of fraud, and internal control in general, and seek to preserve and enhance Electrip Global’s reputation. Under any circumstances and with no exception (except medicines prescribed by medical doctors), it is 2.5 Abuse of Alcohol, Drugs and Substances prohibited for Electrip Global employees to use of and/or to be under the influence of alcohol, abusing illegal drugs and substances, consuming alcohol whilst working hours, conducting company business operations, driving designated vehicles, or operating designated equipment. We do not work with individuals who cannot end their harmful habits (alcoholism, dependency on abusing drugs and substances etc.) despite warnings. We expect our employees to uphold Electrip Global reputation by behaving responsibly during events that they represent us. Gambling, betting, and games of chance are strictly forbidden at work and during working hours. We do not 2.6 Gambling and Betting employ any individuals with addiction to gambling, betting and such habits even though outside of working hours. Just like we, as Electrip Global, are committed to treat our employees equally and fairly, we, as well, expect 2.7 Obligation to Declare our employees in this regard to provide the correct declarations and update the information requested from them by the Company’s Human Resources Department as necessary, in order to distribute the benefits fairly and to ensure that they and their colleagues can take full advantage of those benefits and that the legal obligations of the Company can be realized properly. We also expect our employees to report on investigations initiated by the Public Prosecutor's Office and/or any criminal proceedings against them due to their duties in the company and subsidiaries or for reasons other than their duties, to their managers and the Company’s Human Resources Manager. 05  ELECTRIP GLOBAL LTD – CODE OF CONDUCT (CONVENIENCE TRANSLATION into ENGLISH – ORIGINALLY ISSUED in TURKISH) 3. Corporate and Personal Conflicts of Interest Conflict of interest refers to cases where employees have personal interests that may affect or lead to a perception that may affect them in performing their duties in an unbiased and objective manner. It covers all kinds of benefits provided to them, their relatives and to the people or organizations with whom they are involved, and any other financial or non-financial liabilities related to them. Financial conflict of interest involves a real or potential monetary gain. However, it is not obligatory for this gain to be in hard cash. Gains such as gifts and amenities also fall within this scope. Although there is no monetary gain in non-financial conflicts of interest, personal interest still will be in question. Trade of influence, reputation and use of liaison can also be considered in this context. While the likelihood of affecting employees’ behavior is sufficient condition for a conflict of interest, the feeling of a third party from an external perspective that objectivity is impaired is also considered as other criteria for determining a conflict of interest. In case of identification and proof of any conflict of interest, that may affect the main business operations and financial statements of Electrip Global Companies, cause the violation of related laws, impair the corporate reputation and/or may provide benefit to the employee due to his/her position and duties within Electrip Global, we shall exercise our legal right to them to full extent. As Electrip Global employees, we shall act with conscious that it is essential for us not to ask for any discount or benefits that can be perceived inappropriate, not to offer to third parties, and not to accept any when offered from Electrip Global Companies or real or legal parties that we have business relationships. We also do not enter any personal debt-credit relationship with third parties (suppliers and business partners, dealers, authorized dealers, authorized services etc.) that are directly or indirectly related to our duties. As Electrip Global employees, we acknowledge that we are obliged to act fairly and honestly, to take the necessary steps to avoid any conflict of interest, and to notify our superiors as soon as we notice a potential conflict of interest incident. To protect the reputation of Electrip Global, we execute our duties in line with the principles of accountability and transparency principles, we act with the consciousness that we should consult with our managers and/or when we are not sure. If working in a position associated with an actual, potential, or perceived conflict of interest, the relationship must be promptly reported through the ethical hotline. 06  ELECTRIP GLOBAL LTD – CODE OF CONDUCT (CONVENIENCE TRANSLATION into ENGLISH – ORIGINALLY ISSUED in TURKISH) 3.1 Accepting and Giving Gifts, Representation and Entertainment As Electrip Global employees, while conducting our relationships during and after the business with public institutions and organizations, suppliers, partners, customers, consumers, dealers, authorized dealers, and authorized services, we act transparently, also we do not accept gifts that will adversely affect our ability to make objective decision-making; that is, we act in a way that will not give the impression of any conflict of interest. While the gifts, as well as, memorabilia and promotional materials given to the stakeholders on the basis set by Electrip Global administrations at year-ends and on special occasions are not in this scope, we still take into consideration the criteria such as “fair-mindedness” and “not negatively affecting the Company’s reputation, in the presence of our stakeholders or third parties” when accepting gifts, giving gifts or hosting and representing them. We never offer or accept any gift as cash, gift vouchers or cash equivalents. In case, the candidate to be hired has an affinity by blood or marriage1, including the 2nd degree, with an 3.2 Relationships with Relatives employee working at the workplace, it is not acceptable to have them work in the same department or to have a superior - subordinate relationship. However, should there be an exemption for the greater good of the Company, such as, where the employer’s interests require them to work in the same department or in a superior - subordinate relationship, those are subject to the approval of Head of HR Department at Electrip Global Ltd. This provision is not applicable to relatives who are currently working in the same departments or who are working in a superior-subordinate relationship. Our managers, who are in the hiring position are excluded from all related decision-making process with an affinity to them by blood or marriage, including the 2nd degree. In case the candidate to be hired or already hired personnel has an affinity by blood or marriage, including the 2nd degree, with personnel working currently or later with an employee working at company and subsidiaries, then two considerations are considered. Their first managers cannot be the same person. They cannot be within a superior - subordinate relationship. As Electrip Global employees, we consciously are obliged to notify in written to the Company Human Resources Manager and our immediate manager in case we are aware of that. 1 Affinity by Blood or Mariage Relative by Blood Relative by Mariage First Degree -Kids, -Mother, -Father Parents-in-law Second Degree -Siblings -Grandchildren, -Partner’s Siblings, -Grandparents -Grandparents-in-law 07  ELECTRIP GLOBAL LTD – CODE OF CONDUCT (CONVENIENCE TRANSLATION into ENGLISH – ORIGINALLY ISSUED in TURKISH) Affinity with a person by blood or marriage, including the 2nd degree, currently working or about start to work, People with whom we have affinity by blood or marriage, including the 2nd degree with a person, have managerial and audit rights or financial interests. within the Electrip Global and/or in the companies with whom we have business relations and/or in competition; in the decision-making position concerning the same duty. We knowledge that the same obligation also applies to our relatives. 3.3 Doing Business with Former Employees Doing business with Electrip Global after the termination of the employment contract covers the following in fully, the acts to perform commercial activities with Electrip Global such as establishing a personal company or on behalf of persons with an affinity by blood or marriage, including the 2nd degree, to have shares in such a company, to undertake a contract, to act as a consultant, to obtain representation rights, to open a dealership, or status and similar commercial activities to have as a supplier, contractor, broker etc. For being in a commercial relationship with an entity in which the former Electrip Global employee has a managerial or shareholding position, following the first year of the termination of employment contract, besides, the execution process of the supplier selection process in an objective and fairly manner, the approval of the Company General Manager/CEO is also required. In such cases, we expect our current employees to act within the framework of Electrip Global's interests, while respecting moral and ethical rules and not impairing objective decision-making. We, under no circumstances, engage in any commercial relationships with a former employee dismissed for unethical conduct, or the company he/she represents in any capacity. Should a former employee of Electrip Global start working for a company that is currently in a business relationship and/or a competitor, we expect him/her to fulfil his/her duty of confidentiality regarding the information and documents considered as confidential business information that is acquired during his/her employment with Electrip Global. 3.4 Participations to Events as Guests Formal representatives at associations and non-governmental organizations (NGOs) in which the Company has a corporate membership are expected to inform their immediate superiors to attend at a public event (conference, reception, promotion activities, seminars, etc.) organized by said associations and non- governmental organizations. No written permission is required for those. Except for the organizations which are open to general participation as (conferences, receptions, promotion activities, seminars etc.) and such organized by parties that Electrip Global is in business relationship presently or potentially, accepting the invitations (sporting events, domestic/international trips etc.) which may significantly impair or significantly perceive the objectivity of the employees, are subject to the approval of the General Manager for the subsidiaries and the approval of the CEO/General Manager/Director for the company units. 08  ELECTRIP GLOBAL LTD – CODE OF CONDUCT (CONVENIENCE TRANSLATION into ENGLISH – ORIGINALLY ISSUED in TURKISH) 3.5 Participation of Employees to Events as Speakers or Trainers Electrip Global employees can attend events, activities such as meetings, panels and conferences as speakers or trainers, without interrupting the flow of business and violating the confidentiality principle, only by the written approval of the Company's General Manager and the Human Resources Executive. As Electrip Global employees, while participating in events as speakers or trainers as to contribute to the society by sharing our knowledge and experience, we also inform the General Management of Corporate Communications of our activities, donate the income gained from those activities to the entity or to the institutions to be directed by the entity. However, we are entitled to keep symbolic gifts such as prizes, plates etc. 3.6 Full Time Employment Principle As Electrip Global employees, even if it is out of working hours, we cannot work or consult in any paid or unpaid engagement, for any other employer and/or within another legal entity, without any written consent of the Employer. Moreover, we act consciously that we cannot establish direct or indirect companies, become partners, members of the board of directors or managers of any other entity. In the event such instances are approved by the Company’s Country Manager, we also acknowledge that we are required to make a written notification to the Head of Electrip Global Human Resources to identify and manage conflicts that could arise between our and Electrip Global and its subsidiaries or its stakeholders’ interest. Our close family member interests should also be reported whenever Electrip Global and subsidiaries have the power to influence the outcome of a business transaction and those family members could directly or indirectly benefit from it. The subject of external work will be assessed within the scope of the existing employment contract, provided that the Country Manager's approval is obtained, and written notification is submitted to HR. 3.7 Insider Trading / Data Breach At Electrip Global we take compliance with market abuse and insider dealing laws extremely seriously and non-compliance is likely to amount to gross misconduct leading to summary dismissal. Furthermore, market abuse, insider dealing, and related offences (described below) also constitutes a criminal offence in most if not all the jurisdictions where Electrip Global carries out business activity. These offences can result in significant terms of imprisonment and/or large fines and can be prosecuted based on recklessness as well as intention to make false or misleading statements, let alone reputational damage to Electrip Global. As Electrip Global employees, we comply with all legal regulations regarding market abuse and insider dealing and do not use insider information not yet disclosed to the public (all kinds of commercial, financial, technical and legal etc.) to afford advantage to ourselves or to third party beneficiaries. We do not provide unfair advantage in the capital market, which disrupts equality in opportunities among traders or dispose of any kind of damage. Electrip Global and subsidiaries are not currently publicly traded. Zorlu Energy is one of the shareholders of Electrip Global and is a publicly traded company. Consequently, stock movements related to Zorlu Energy may impact Electrip or share movements regarding Electrip may also affect Zorlu Enerji, one of Electrip Global's shareholders. As Electrip Global employees, we pay attention to the required precautions to comply with our confidentiality obligation, even if we leave the job. Since our confidentiality obligations include all Electrip Global Companies, we make all our official disclosures to stakeholders, investors, and the public, in compliance with the principle of equality, in a complete, accurate, timely and comprehensive manner, through authorized persons/units by Electrip Global. 12  ELECTRIP GLOBAL LTD – CODE OF CONDUCT (CONVENIENCE TRANSLATION into ENGLISH – ORIGINALLY ISSUED in TURKISH) 3.8 Trading Policy of Electrip Global’s Equity Shares If any member of staff is in any doubt as to whether market abuse or insider abuse laws apply, they should immediately contact the Electrip Legal Team for guidance. Electrip Global and subsidiaries are not currently publicly traded. Zorlu Energy is a shareholder of Electrip Global BV and is a publicly traded company. Consequently, stock movements related to Zorlu Energy may impact Electrip. Per the Capital Markets Law, the person who might be engaged in insider trading are defined as; a) Managers of issuers or those of their subsidiaries or their controlling corporations, b) People who possess this information by holding a share in issuers’ corporation or in their subsidiaries or their controlling corporations, c) People who possess this information due to the performance of their jobs, professions, and tasks, d) People who obtained this information by committing crimes, e) People who know that the information they possess is of the nature mentioned in this paragraph or that should know it in the case when demonstrated. Accordingly, these people, that is, employees of the publicly held Electrip Global Companies' employees who have access to corporate information can only buy and sell the shares of Electrip Global Companies by using publicly disclosed information and for investment purposes. This condition includes all commercial actions, including secondary stock and bond market transactions such as double-earning transactions and short-term or other futures. These obligations of the employees will continue even if they leave their jobs. Regardless of whether it is included in this article, as to insider trading, we pay utmost attention and comply fully with all regulations as prescribed by the Capital Market Law and the related legislation. 3.9 Financial Sanctions As Electrip Global and subsidiaries, we are strictly prohibited from engaging, supporting or facilitating business relationships and business activities with persons and entities that are subject to United Nations, European Union or United States sanctions as well as with countries that are subject to comprehensive sanctions. We must: Be alerted to spot financial sanctions related issues, involvement of sanctioned parties or countries when reviewing or analyzing business dealings, Pay particular attention to changes to sanctions requirements and the immediate impacts these have on business activities, Escalate concerns immediately as per the applied internal regulation. 4. Protection of Assets and Information Security 4.1 Security and Protection of Assets The proper use of all assets and resources belonging to Electrip Global and subsidiaries for their intended purpose and to avoid them being in use of personal and third parties benefit, is a general rule. We use the tangible and intangible assets and resources of the Company solely for the purpose of conducting the 13  ELECTRIP GLOBAL LTD – CODE OF CONDUCT (CONVENIENCE TRANSLATION into ENGLISH – ORIGINALLY ISSUED in TURKISH) business of the company or within the principles and procedures permitted by the management. In addition to the efficient use of the assets and resources of Electrip Global and subsidiaries, it is the responsibility of our employees and stakeholders to take all necessary measures to protect the Company's tangible assets (cash and cash equivalents, inventories, company vehicles, machinery and equipment, electronic devices, etc.) and intangible assets (information and information systems, brands, reputation, intellectual property rights, trade secrets, etc.). We expect them to avoid behaviors and actions that might impair this responsibility and to act in a conscious and responsible manner to conserve while carrying out their duties. We take all kinds of precautions to prevent theft or being damaged of the entire tangible and intangible assets of Electrip Global, and in this regard, we ensure that assets and resources are secured against potential loss, deficit, misuse, fraud, theft, and sabotage. Limited personal use of Electrip Global Ltd’s. IT assets are acceptable within the bounds of relevant policies, aligned with Electrip Global Ltd's interests, rules, guidance, and your job responsibilities. 4.2 Information & Data Security We acknowledge the importance of protecting personal data and affirm that data protection principles strengthen individual rights. As a company, we ensure full compliance with relevant laws regarding the collection, use, storage, processing, transfer, and disclosure of personal data, and we expect our suppliers and business partners to maintain similar standards. The company adheres to globally established guidelines for the protection of personal data, ensuring a high level of protection regardless of the location where the data is collected or processed. In accordance with relevant laws, the company collects, uses, stores, processes, transfers, and discloses personal data. In Electrip Global, the confidentiality of all commercial and personal information regarding our employees, suppliers and business partners, customers and consumers is essential. While processing these private and confidential information, as to accessing and using data, we comply with relevant laws, regulations and legislations and share them only with authorized people. We do not disclose to third parties unless disclosure is required by official authorities and legislation. We do not take any kind of data, information and document that might harm the activities and reputation of Electrip Global, put in a difficult position in terms of competition, violate the confidentiality of private information, out of the company via e-mail or by means of other communication ways. When using all kinds of information technology resources and electronic communication tools, we strictly respect data confidentiality and security, we act with the awareness that the user is responsible for passwords and user codes for accessing information, we do not share them with third parties or colleagues including our managers. Cyberattacks typically involve attempts to steal or manipulate data, rendering systems unusable. Such attacks can affect numerous parties, including customers and employees, causing significant disruptions to our IT and operational technology systems. If you detect any potential cyberattack or any malicious behavior within the systems or assets of Electrip Global Ltd, please immediately report it to the Service Desk and the IT team. We expect our employees to comply strictly with the policies and instructions published by Electrip Global Information Technology Directorate, which is also available for employees, regarding taking necessary measures to protect information security and trade secrets, as well as the use of internet, e-mail systems and other electronic communication tools together with information systems infrastructure and all the devices. While speaking and using mobile devices in public and social areas (restaurants, cafes, parks, dining halls, elevators, shuttles etc.), we pay attention not to mention any critical information regarding Electrip Global and subsidiaries. We are committed to transparency and will promptly inform affected parties and regulatory authorities in the event of a significant data breach, in accordance with legal requirements. Electrip Global Ltd is renowned for its leadership in technology, with innovation ingrained in our identity We are dedicated to continuously fostering and safeguarding Electrip Global Ltd's innovation, products, 14  ELECTRIP GLOBAL LTD – CODE OF CONDUCT (CONVENIENCE TRANSLATION into ENGLISH – ORIGINALLY ISSUED in TURKISH) technologies, and brand through a robust array of intellectual property rights, encompassing patents, copyrights, trademarks, service marks, trade secrets, design rights, domain names, and other proprietary rights. Our extensive know-how and confidential information provide us with a competitive advantage in the market. We actively defend our intellectual property and confidential information, adhering to internal policies governing their proper use, safekeeping, marking, and handling. Upholding a commitment to respect the intellectual property and confidential information of others, we anticipate reciprocal adherence from them. In particular: Staff should not do anything to jeopardize our valuable trade secrets and other confidential information and intellectual property using social media. Staff should avoid misappropriating or infringing the intellectual property of other companies and individuals, which can create liability for the organization, as well as the individual author. Do not use our logos, brand names, slogans or other trademarks, or post any of our confidential or proprietary information without prior written permission. To protect yourself and the organization against liability for copyright infringement, where appropriate, reference sources of information you post or upload and cite them accurately. If you have any questions about whether a particular post or upload might violate anyone's copyright or trademark, ask the Electrip Global Legal Team before making the communication. 5. Accuracy in Records and Financial Reporting As Electrip Global, we act in line with our principles of integrity and fairness for our company's reputation, reliability, and sustainability; we ensure the highest level of compliance with all national and international rules and internal regulations, particularly the relevant legislation. In all areas where we operate related to our services and operations, we are confident as to: Keeping and preparing all kinds of financial reports, financial statements and records in accordance with the national and international accounting standards, Recording, reporting and fair presentation of all commercial and financial documents, Not making any payments other than its intended purpose, Retaining records and documents, securely. We also act transparently to our third-party stakeholders (suppliers and business partners, customers and consumers, shareholders, investors, etc.) and regulatory authorities; we share all kinds of information other than trade secrets, in a complete, fair, accurate, timely and understandable manner when requested or deemed necessary in accordance with the regulations. 15  ELECTRIP GLOBAL LTD – CODE OF CONDUCT (CONVENIENCE TRANSLATION into ENGLISH – ORIGINALLY ISSUED in TURKISH) 6. Health, Safety & Environment We are dedicated to ensuring a safe and healthy workplace for our employees and contractors, fostered by a robust learning culture. We implement local legal requirements and monitor the best international health & safety workplace standards in the countries where we operate. Compliance with these standards is expected from our employees, contractors, suppliers, and other business partners. Safety is ingrained in our operational ethos, constituting a fundamental aspect of our organization, and playing a crucial role in the delivery of our products and services. In this regard, we raise awareness of our human resources by given practical and interactive training programs to ensure the continuity of a safe and health work environment. Electrip Global and subsidiaries are not currently publicly traded. Zorlu Energy is one of the shareholders of Electrip Global and is a publicly traded company. Consequently, stock movements related to Zorlu Energy 7. Relationship with Stakeholders 7.1 Shareholders may impact Electrip Global. As Electrip Global, we take our decisions based on economic data to maintain the confidence of our shareholders to our institution and ensure that our resources and assets are operated in the most efficient way with an understanding of financial discipline and accountability. Taking into consideration our investments and sustainable profitability, we focus on areas that will increase our competitive power and provide high returns for our shareholders. At the stages of investment and operations, while taking investments decisions, we consider the participation of our shareholders as well as the suggestions, opinions, and requests of all stakeholders, primarily residents. We use our resources effectively and efficiently; manage them in favor of our shareholders with savings consciousness, avoid unnecessary and unmanageable risks, and implement strategies that create growth- oriented value. Based on commercial and financial discipline, we develop and implement a fair, transparent, and sustainable reporting system that complies with legal regulations and rules. We regularly provide deemed necessary information to the relevant authorities, institutions, and agencies. In our statements to the public and shareholders, we provide necessary information related to the financial statements, strategies and investments in a timely, complete, accurate and understandable manner as required by the legislation. We comply with the legal regulations regarding the trading of shares of our publicly traded companies and we avoid situations where conflicts of interest may arise. 7.2 Third Parties As Electrip Global employees, we consider them to be accurate, consistent, and reliable in our business relations and our relations with our customers; we carry out product/services agreements in accordance with the relevant international and local legislation, and within the framework of policies and principles of Electrip Global. We take the opinion of Electrip Global Legal Team about the contracts and protocols to be made with those who are in commercial business relationship with Electrip Global. While establishing and performing business relations, we act based on objective, transparent, equal, and independent criteria and are compatible with our corporate values and criteria such as cost/benefit to the benefit of our stakeholders without being under the influence of an individual and/or conflict of interest. 7.2.1 Suppliers and Business Partners We act honestly, respectfully, and fairly in our relations with suppliers and business partners, which we believe have an important role in the quality of our products and services in accordance with the relevant international and local regulations. At Electrip Global, we consider the basis of objective criteria in the selection of our suppliers and business partners whom we prefer to work in cooperation within long term. 16  ELECTRIP GLOBAL LTD – CODE OF CONDUCT (CONVENIENCE TRANSLATION into ENGLISH – ORIGINALLY ISSUED in TURKISH) As Electrip Global employees, while maintain a relationship during and after the determination of our suppliers and business partners, we act transparent and do not accept any items (gifts, interests, etc.), that will negatively affect our objective decision-making competencies and not act in a way that will impose an impression of potential interest relationship. We expect our suppliers and business partners to continue performing their activities in accordance with laws, regulations, and Electrip Global Code of Conduct. In this regard, we follow their compliance with standards such as fulfilling their legal obligations, respecting human rights, protecting employees' rights and the environment etc. We realize detailed due diligence for our suppliers. We support them to act in accordance with the principles of business ethics and anti-corruption. Please refer to the Supply Principles where we outline the fundamental requirements that we expect suppliers to adhere to. 7.2.2 Customers and Consumers We approach our customers and end consumers with a satisfaction-oriented mindset, we act with care, honesty, and fairness in our relations. We approach all our customers and consumers on the same basis and without any distinction. We present quality products and services at the highest level and develop innovative products focusing on changing customer and market needs. We work with a proactive approach to create value for our customers and consumers, to meet their demands and requirements at the highest level. We continuously aim to improve customer and consumer health and safety related processes. We clearly inform our customers and consumers about the rights and obligations, benefits and risks related to the products and services we present, and we take the necessary measures and effort to fulfill our commitments. We protect the rights of our customers and consumers, consider their objections and complaints, and perform customer relations activities to make the necessary reviews and evaluations. In our relations with our customers and consumers, we act responsive to their problems, within the framework of courtesy rules, produce a fast and lasting solution and strive to create a trust-based relationship between us. In accordance with the Law on the Protection of Personal Data No. 6698 in Turkey, the EU General Data Protection Regulation, the UK Data Protection Act 2018, the UK General Data Protection Regulation and other applicable data protection legislation we take all necessary technical and administrative measures to ensure the appropriate security level is maintained to protect personal data and to prevent unlawful access and processing of personal data. We process, register, and protect personal data and privacy of our customers and consumers in accordance with the relevant legal regulations and confidentiality rules. We use the information obtained about customers and consumers for business processes, only for the fulfillment of the service provided or for future improvements. 7.2.3 Global Trade We function within a global context and adhere to relevant trade laws and regulations, encompassing import and export controls, trade sanctions, and customs procedures. We also require our business partners to uphold similar standards. Electrip Global Ltd has established comprehensive policies, organizations, and controls to minimize trade-related risks. This includes screening transactions involving embargoed or sanctioned countries, facilitating compliance with trade laws, and implementing systems and training to ensure precise declarations to trade authorities. Numerous countries impose restrictions on exporting or transferring specific items, software, technology, services, and funds to certain countries, individuals, entities, or governments for reasons related to national 17  ELECTRIP GLOBAL LTD – CODE OF CONDUCT (CONVENIENCE TRANSLATION into ENGLISH – ORIGINALLY ISSUED in TURKISH) security, foreign policy, or other concerns. Exports come in various forms and are not limited to physical items. They encompass scenarios such as carrying electronic devices with information across borders, transmitting information electronically, or placing it in a collaborative workspace accessible to others. Even when visiting foreign national views- controlled information at our site, it constitutes an export. Whether initiating occasional imports or exports of physical or intangible items, strict adherence to the laws of the countries involved and compliance with related country trade regulations are mandatory. Trade compliance laws cover even minor transactions, such as those involving low volume, low price range, or cost- free replacements and goods transported for service delivery. Import and export documents must be accurately completed, verified, and recorded in accordance with related country regulations. 7.2.4 Relationships with Competitors and Compliance with Competition Legislation Electrip Global act in accordance with all applicable legislation (laws, regulations, codes) related to the Law on Protection of Competition. We are meticulous about the freedom of competition and development of the sector, observing common interests and ensuring continuity of confidence in the sector. In our relations with competitors, we observe fair competition conditions. Violations of competition rules may result in individual and institutional high-level punishment with material fines and/or potential imprisonment. As Electrip Global employees, we act with the full awareness that we are responsible for ensuring compliance with all applicable laws, regulations, governmental decrees, and lawful orders regarding the protection of competition. 18  ELECTRIP GLOBAL LTD – CODE OF CONDUCT (CONVENIENCE TRANSLATION into ENGLISH – ORIGINALLY ISSUED in TURKISH) Avoiding Contravention of Competition Legislation As Electrip Global and subsidiaries, we strictly refrain from agreements, behaviors and concerted practices that are intended to prevent or limit competition, directly or indirectly, with competitors or other third parties. We do not abuse our dominant position when we are in a dominant position in a particular market, alone or together with other enterprises. As Electrip Global, we do not interfere in the resale price of the products/services we are the provider of, and the sales conditions where the exemption is not the issue. We act in the knowledge that Electrip Global Law Team should be consulted for the hesitations regarding the actions and activities, in cases where the provisions of the international or local legislation are not clearly understood. Gathering Information about Competitors As Electrip Global and subsidiaries, we do not exercise any illegal and unethical means of accessing information about our competitors. We only use publicly available information about competitors, we do not use any information regarding competitors through unknown sources. As a general practice, we should refrain from (directly or indirectly) seeking, acquiring, or exchanging commercially sensitive information that could impact decisions made by Electrip Global Ltd or a competitor regarding costs, margins, pricing data, future strategies, product plans, employee salaries, etc. 7.2.5 State Institutions and Organizations As Electrip Global, we act in line with the principle of equality in our relations with state institutions and organizations. While performing our operations, we keep arms’ length relationship with the state institutions and organizations, non-governmental organizations, and political parties. We comply with the requirements of laws and legislation; we do not engage in any material or immaterial interest relationship with public servants, political people, and their representatives. We pay attention to disclose accurate, consistent, and timely information publicly available when deemed necessary, also act responsibly for protecting the internal information that should not be shared with the public 19  ELECTRIP GLOBAL LTD – CODE OF CONDUCT (CONVENIENCE TRANSLATION into ENGLISH – ORIGINALLY ISSUED in TURKISH) 7.2.6 Media We treat media among our key stakeholders and establish regular, open, and transparent relationships with media. We perform all content details such as requests for opinion, disclosure, news, and interviews from media institutions within the knowledge of the General Management of Corporate Communications Team. We do not make any distinction among media institutions; we keep our arms’ length stand. We do not give any misleading information to the public in our announcements. Other than our corporate spokespersons, we as employees or managers do not make any disclosure to the public. We do not use discriminatory expressions, political, hatred and insulting discourses in any way that might impair the reputation of the entity. 7.2.7 Social Media Our corporate business partners use statements that are consistent with Electrip Global brand reputation and corporate culture when they disclose publicly about Electrip Global, subsidiaries and brands. We maintain social media channels in the same way as traditional communication channels, with a sensitivity towards the reputation of the names and brands of Electrip Global and our corporate culture and manage these channels with this understanding. Our employees are obliged to act in accordance with our Social Media Guide. Our employees do not share any kind of content praising crime and/or criminals in their social media accounts. We expect our employees to be aware of the sensitivities we have shown in traditional communication channels, especially in social media and in all digital channels regarding their sharing content about Electrip Global. We require them not to include any content that is not produced by our entity, that might impair the reputation of our entity and employees, which does not align with our corporate culture and that exceeds their authority. Apart from the official disclosures in social media, we know privacy should be protected, and we do not share any unconfirmed information about Electrip Global. In this respect, we expect our employees to act responsibly and attentively in accordance with the Code of Conduct. 7.2.8 Publicity and Promotion As Electrip Global, we do not make any kind of misleading and deceptive advertisements, and we do not make any statements that may damage the reputation of our competitors or the companies we are competing with. We do not prepare or publish any ads that promote discrimination and incitement to the public, ads that cause child abuse, that include sexual content, and which violate general moral codes. We also make sure that the advertising and/or sales materials are not printed and distributed without the approval of the required units and managers. 20  ELECTRIP GLOBAL LTD – CODE OF CONDUCT (CONVENIENCE TRANSLATION into ENGLISH – ORIGINALLY ISSUED in TURKISH) 8. Compliance with the Laws and Regulations The basis on which Electrip Global is established is the principles of compliance primarily with the national legislation and International Conventions and other internal regulations, which have become a part of our national law. We expect our employees to respect and adapt to the local culture and values where we operate. In our relations with legal regulatory institutions and organizations, we are sensitive about open, complete, accurate and timely communication, and we approach all domestic and foreign institutions and organizations without any distinction, while fulfilling our activities and legal obligations. 9. Prevention of Money Laundering, Fight Against Corruption and Bribery Money laundering is the process of transactions and activities of individuals aiming to hide, cover up or show differently the quality, source, location, status, movement and holder of cash or similar property in value obtained from illegal activities, to hide their crimes or legalize the criminal earnings. As Electrip Global, in accordance with the provisions of national and international legislation, we adopt the fight against money laundering, terrorism financing, corruption and similar crimes as an important principle. We hold our employees obliged to comply with all laws and regulations in force in the fight against money laundering and corruption. We explicitly forbid "grease" or "facilitation" payments, even in cases where local law or business customs may permit them. Such payments typically involve offering public official compensation for routine government services or benefits to which everyone is normally entitled. Such payments typically refer to those made to expedite, facilitate, or ensure the completion of business processes. However, such payments often lead to illegal or unethical practices. For instance, these payments may be made to encourage actions such as tax evasion, manipulation of permit acquisition processes, or bribery of public officials. Such practices may contravene legal regulations and ethical standards and are prohibited or subject to strict scrutiny in many countries. Besides, we treat any kind of corruption and bribery that impair the reputation of Electrip Global and its employees with great care and sensitivity. We do not allow our employees to: Ask for the use of special benefits and conditions granted by the Company for their personal interest, Ask for special privileges or discounts other than offered for everyone, Claim personal debt. 21  ELECTRIP GLOBAL LTD – CODE OF CONDUCT (CONVENIENCE TRANSLATION into ENGLISH – ORIGINALLY ISSUED in TURKISH) from our suppliers and business partners, customers, consumers, competitors, and other third-party stakeholders. It is essential that employees and all third parties acting on behalf of Electrip Global demonstrate due diligence; do not provide unjust benefits, offer, accept, or give bribes or commissions for any reason whatsoever to individuals and organizations; and counter such actions to the extent of their knowledge. When such an offer is encountered, or an observation or suspicion arises, the situation must be reported to the immediate manager/executive and/or to [email protected]. 10. Political Activities 10.1 Corporate Approach to Political Activities As Electrip Global, we do not make donations to political parties, politicians or political candidates, steer in political opinions and thoughts of employees and managers, neither demand them to disclose their opinions nor file them. 10.2 Personal Political Activities The discretion of our employees and managers to engage in and contribute to any political activity or social activity is personal and reflects only their personal views. However, we do not allow any activities intended to disseminate political ideas in the workplaces of Electrip Global, such as making political propaganda in political matters. We do not allocate company resources (tools, vehicles, computers, e-mail, etc.) to political activities. On behalf of the Company, we do not make any statements about any political party and/or political non-governmental organization for political purposes through our business and private lives, via social media accounts. 22  ELECTRIP GLOBAL LTD – CODE OF CONDUCT (CONVENIENCE TRANSLATION into ENGLISH – ORIGINALLY ISSUED in TURKISH) 11. Social Responsibility, Volunteering, Donations As Electrip Global, we act with the understanding of creating shared value in our social investments. Electrip Global aims to contribute to the developments of society and to create value in accordance with its social responsibility approach; we encourage our employees to be involved in volunteering and charity projects under the framework of our corporate volunteering program. As Electrip Global employees, we know that we can participate in activities within the framework of non-governmental organizations working outside the company to provide social benefit in our spare time and if within the working hours, with the approval of the Company General Manager and Human Resources Manager, without delaying our duties. We act sensitively to the problems of society and contribute to the solution to act with a sense of business ethics and social responsibility. We take part in projects that will contribute to the development of the life of society; we make donations; also enrich social life by supporting cultural, artistic, scientific and sportive activities. We pay attention not to make our corporate donations and social contributions to political activities and the persons and organizations related to these activities, private accounts and profit-oriented institutions and organizations that might impair the reputation of Electrip Global. We act with the awareness that the donation campaigns, volunteer programs and all kinds of financial and in-kind aid activities supported by Electrip Global must be carried out within the knowledge of the General Management of Corporate Communications in order them to be made to the people, institutions, and organizations legally reviewed and approved by Electrip Global. 23  ELECTRIP GLOBAL LTD – CODE OF CONDUCT (CONVENIENCE TRANSLATION into ENGLISH – ORIGINALLY ISSUED in TURKISH) 12. Climate Change, Environment and Sustainability We adhere to the environmental laws and regulations applicable in the regions where we operate. Furthermore, we actively endorse sustainable development and endeavor to realize of Electrip Global Ltd's sustainability objectives by contributing to economic advancement, environmental conservation, and social development. Our company ensures full compliance with environmental legislation and regulations in the regions where it operates. Additionally, we actively support sustainable development, striving to contribute to social progress while preserving natural resources and aligning with the company's sustainability goals. Our commitment to continuous improvement encompasses all our products, services, and business processes. By implementing various projects, we aim to reduce our impact on biodiversity. We endeavor to minimize our water usage, carbon footprint, and waste generation while prioritizing the reduction of hazardous substances and energy efficiency in our operations, thereby playing a leading role in combating climate change. As Electrip Global, we perform all our activities and investments in environment-friendly and assess the environment in terms of sustainability of natural resources and minimization of adverse effects in the environment. As Electrip Global, we consider protection of nature in accordance with environmental legislation as part of our responsibility to future generations in the long term. We develop innovative solutions, inclusive of our value-chain2, to improve environmental performance continuously with knowing that limited resources should be used responsibly. We strive to increase the production and consumption of renewable energy, to use natural resources, especially soil and water, with common sense and productive manners, to reduce carbon emissions and waste to the minimum, and to increase recycling. We prioritize the development of environmentally friendly technologies that will increase energy efficiency and water savings of our products to reduce energy and water consumption of consumers. As Electrip Global, we rapidly adapt to the changes taking place on a global and local scale; we continue to work with the vision of a smart future that can offer environmental and nature friendly products and services. With this understanding, we accomplish the sustainability approach shaped by commitment to society, environment, legislation, and Code of Conduct. In the meantime, while carrying out activities that will benefit the present society, we adopt an understanding that takes care of the needs of future generations. 2 Value-chain is a chain of activities carried out by an institution to present products and services that will provide value to the market. Core value- creating activities include customer-oriented processes such as design, production, marketing, shipment, after sales services and the relationship model among them. 24  ELECTRIP GLOBAL LTD – CODE OF CONDUCT (CONVENIENCE TRANSLATION into ENGLISH – ORIGINALLY ISSUED in TURKISH) 13. Practice of the Code of Conduct, Compliance and Violations 1 3. 1 Establishment of Ethical Culture Electrip Global Code of Conduct covers all subsidiaries operating in Turkey and abroad. Electrip Global Companies employees are obliged to comply with the Code of Conduct in carrying out their duties. Adaptation to the principles and rules set out in the Code of Conduct is a dynamic process and we expect our employees to make conscious decisions based on a certain source and compliance with the standards and culture of Electrip Global. Non-compliance with the provisions of this Code of Conduct also leads to internal sanctions, other than the administrative and penal sanctions prescribed by the relevant legislation. We also assess the status and performance of our employees in terms of compliance with the Code of Conduct. Establishment of Ethical Culture and Ethics Committee It is the responsibility of the Ethics Committee to create, update, publish and provide application practices to coordinate training programs for employees assigned to that task or to cooperate with expert institutions in these matters; to do all kinds of activities that are deemed necessary with the aim of ethical culture’s incorporation, development, and sustainment. Head of Electrip Global Human Resources, Head of Electrip Global Legal and CAO (Chief of Audit Officer), if appointed are the full members of the Ethics Committee established by the Board of Directors of Electrip Global under the chairman. Non-full members are the top management of the company (CEO/Country Managers) with respect to the agenda items of the Ethics Committee and the authorities who can be invited by the full members as subject to the issues. Employee Notification and Training We inform our employees at all levels at Electrip Global about the Code of Conduct and their responsibilities regarding these principles as an employment related condition. We communicate our Code of Conduct to each of our newly hired employees through our orientation program and take a commitment confirming the understanding of our staff that confirms the understanding of the rules is an integral part of the employment contract which is kept in the employee’s personal file. Electrip Global Human Resources Team is responsible for documentation certifying that the Code of Conduct is read, understood, and committed by the current employees. 25  ELECTRIP GLOBAL LTD – CODE OF CONDUCT (CONVENIENCE TRANSLATION into ENGLISH – ORIGINALLY ISSUED in TURKISH) The Code of Conduct and related applications can also be accessed through our corporate communication portal. In addition, we provide basic ethical training to each employee with the most applicable method (online and/or classroom training) according to the job description and place, and we continue our ethical training periodically. The responsibility for registration and tracking of the training is at the responsibility of Electrip Global HR Department. 1 3. 2 Practice Principles of the Code of Conduct Paths and Methods to be Followed for Ethics (Ethical Decision Tree) The Code of Conduct also serves the purpose of defining the processes to be followed in the event of attitudes and behaviors that contradicts or violate the rules required for a harmonious and productive working environment within Electrip Global and determine the sanctions to be applied at the end of the process. However, it is not possible to define both the behaviors that are contrary to business ethics and legislation, and illegal business processes under the Code of Conduct. We expect our employees to act with an understanding of compliance with the obligations arising from laws and regulations, Electrip Global Code of Conduct, other Company procedures, policies, and regulations as well as with personal conscience and common sense. Obligation to Report of Violations and Code of Conduct Notification Line (Hot-Line) Electrip Global employees are obliged to adopt Code of Conduct and act within the framework of these principles while performing their day-to-day business. We expect our employees to consult with their senior management or the relevant human resources managers on the Code of Conduct when needed. In the meantime, all employees who need to communicate or consult in the event of any doubt of the contents of the Code of Conduct and/or in case of witnessing an improper action or an execution contrary to the rules, can reach by; E-mail to the Code of Conduct Hotline ([email protected]) Such hotlines are intended only for notification of issues considered not proper to comply with the Code of Conduct and requests like customer or consumer complaints, suggestions or objections are not considered within the scope of the Code of Conduct Hotline activities. Such notifications are expected to be communicated by the relevant Group Company through other communication channels (customer service, etc.). 26  ELECTRIP GLOBAL LTD – CODE OF CONDUCT (CONVENIENCE TRANSLATION into ENGLISH – ORIGINALLY ISSUED in TURKISH) It is essential that the identity of the employee(s)/person reporting the violation is kept confidential within the legal and administrative requirements. Although anonymous notifications are considered during the notification of violations, if additional information is needed to conduct an effective review, and, to provide feedback on the outcome of the review process, we prefer that contact information is shared. Retaliation, in a corporate context, refers to any adverse action taken by an employer against an employee in response to the employee's participation in a protected activity, such as reporting discrimination, harassment, or other illegal or unethical behavior in the workplace. This adverse action can include but is not limited to termination, demotion, reassignment, denial of benefits, or other forms of mistreatment. Retaliation is prohibited by various employment laws and corporate policies aimed at promoting a safe and fair work environment where employees feel empowered to speak up without fear of reprisal. Electrip Global is committed to the protection of the rights of employees/persons reporting violations. Retaliation is prohibited for our employees due to their notifications. We will take the necessary action on those attempting retaliation. We also monitor that our employees are always acting properly in their responsibilities and attitudes in accordance with business ethics, complying with the substance and purpose of the Code of Conduct. Accordingly, we expect that no false declarations will be made to ensure that our resources are used effectively and efficiently, and that Electrip Global or our employees' reputation is not unnecessarily impaired. We remove the notices that are considered as intended to be deceived out of the review process, and we enforce sanctions on the employees who do so consciously within the framework of the Disciplinary Regulation. We also apply these disciplinary actions to all employees and managers who approve, direct or act on violating the Code of Conduct and disruption of the Code of Conduct, or who knowingly do not make the necessary notifications and stretch the rules and tolerate them. Review, Research and Reporting Authority for Violation Notices The Ethics Committee established by the Board of Directors is authorized and responsible for the evaluation and resolution of complaints, whistleblowing (explained more in detail in the Whistleblowing Policy under Annex I) and claims reported to the Code of Conduct Hot Line. In this context, the reporting regarding the violation of the Code of Conduct is evaluated by the Audit Department. The investigations regarding the complaints, claims and whistleblowing are investigated by the Internal Audit Review Department where possible, under the CAO (Chief of Audit Officer), if appointed. It is prohibited to perform such inspections by unauthorized units other than the Board of Directors except for the Internal Audit Review Department. The Internal Audit Review Department is authorized to carry out the necessary investigations and research into the practices and conduct against the Code of Conduct and based on request made or to be made. When using this authority, information and documents are requested from the relevant units as necessary, based on the investigations and research to be conducted on the practices and conduct against the Code of Conduct. To ensure that the execution of the review is performed effectively and efficiently, the interviews and information requested directed to employees should be absolutely replied to within 2 working days at the latest. In the event of detecting a transaction or action violating the Code of Conduct, a report on the case or a review report in case no violation to the Code of Conduct is determined is issued by the Internal Audit Review Department to the Board Members, CEO with the Manager of the related entity, and members of the Ethics Committee. In addition, all the complaints, whistleblowing, and claims reported to the Code of Conduct Hot Line are prioritized by the Internal Audit Review Department, fully listed, and reported to the Ethics Committee on a quarterly basis. 27  ELECTRIP GLOBAL LTD – CODE OF CONDUCT (CONVENIENCE TRANSLATION into ENGLISH – ORIGINALLY ISSUED in TURKISH) Disciplinary Practice For those who violate the Code of Conduct, we apply the provisions of the Disciplinary Regulation. Failure to comply with laws and regulations, the Code of Conduct and other Electrip Global policies, procedures and regulations may result in penal consequences including the termination of the employment contract. We act within the framework of legal requirements and corporate arrangements in case of detection and proving of any irregularities that might affect the main activities and financial statements of Electrip Global, violation of the relevant laws, impair the corporate image and/or provide benefits to the employee due to his/her position and duty in Electrip Global. Declaration of Compliance the Code of Conduct I, hereby, declare and undertake that I have read, understood, and agreed to comply with all the provisions of the Code of Conduct. Name-Surname : Company : Title : Date : Signature : 28