Code of Ethics and Working Principles

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

Mail: etik@aydemenerji.com.tr

Phone: 0 (850) 575 0 575

Sending by mail: Adalet Mahallesi Hasan Saygın Bulvarı No: 15/1 Merkezefendi / Denizli (To the Ethics Committee Presidency)

Ethics examines, with the simplest methods, values ​​that have general validity and are universally accepted in humans. Business ethics covers a set of principles to guide behavior in the business world.

While Aydem Energy's core values ​​and principles guide our business ethics rules, they constitute our expectations, standards and ethical practices that form the basis of all our business relationships and transactions.

Aydem Energy Code of Ethics and Working Principles define the rules that "Aydem Energy Anonim Şirketi and all its subsidiaries" (Aydem Energy) and all third parties and employees who do not act on their behalf must comply with, employee rights, as well as company ethical evaluation and basic rules.

Honesty and integrity of our employees are necessary to maintain our reputation, reliability and successes gained through the role modeling of our leaders. Unethical behavior or behavior that does not comply with our business principles is never accepted or tolerated. It is the duty of every employee to protect the reputation and success of Aydem Energy.

Each employee must work at the highest professional level in order to meet internal and external customer needs within the scope of the work under his or her responsibility. In addition, employees work efficiently; He/she must contribute to his/her own goals, the goals of the department and the company he/she is affiliated with, and to meet customer needs.
Especially each of us;

• While performing our duties, we must act within the framework of basic moral and human values ​​and in line with corporate strategies,
• Must act within the framework of honesty and reliability; establish and maintain equal interpersonal relationships; Must cooperate with other employees towards common goals and use company assets and resources effectively, efficiently and respectfully,
• Must exhibit behavior and business ethics in accordance with our "Code of Ethics and Working Principles" announced throughout the institution, read and understand all the principles of our institution and comply with these principles,
• While performing the duties assigned to us, we must comply with all laws, principles and applicable statutes and regulations issued by the relevant regulators (Energy Market Regulatory Board, Capital Markets Board, etc.) and professional institutions and organizations of which Aydem Energy is a member,
• We must avoid unfair competition in all transactions and our relations with other financial institutions within the framework of fair competition principles,
• We must not forget that being open, complete and accurate to all our stakeholders is a part of our identity and reliability, and
• we must always act in a way that increases Aydem Energy's reputation.

As employees, each of us must show the necessary common sense and effort while performing our duties, take into account the principles of profitability and efficiency, and avoid any action or transaction that may cause harm to the institution. We should not forget that behavior that violates or exceeds the limits of our "Code of Ethics and Business Principles", which are seen as the guarantee of the reputation of our institution, may lead to ethical review or disciplinary investigation.

Our institution expects our managers and all our employees to make judgments in accordance with our "Code of Ethics and Working Principles" while carrying out their work. It is important for our managers and all our employees to frequently refer to these rules, to frequently confirm that they are proceeding in accordance with what is written in the "Code of Ethics and Working Principles" guide and the purposes for which it was written, and to fulfill their duties in the most effective and correct way in line with the corporate objectives.

As an institution, we are aware that the rules expressed in this guide are not a complete answer to every question and every situation. In such cases or regarding any questions or thoughts you have regarding the "Code of Ethics and Working Principles", you can contact the Code of Ethics Advisor and Human Resources Management.

The communication channel created for your questions regarding our "Code of Ethics and Working Principles" and to report those who violate our "Rules of Ethics and Working Principles" or suspicious situations that will reduce our reputation is as follows:

Phone: 0 (850) 575 0 575

Sending by mail: Adalet Mahallesi Hasan Saygın Bulvarı No: 15/1 Merkezefendi / Denizli (To the Ethics Committee Presidency)

Ensuring Confidentiality Within the Institution

Our employees;

• Each employee is obliged to comply with the details specified in Aydem Energy Information Security Policy and relevant legislation regarding information security.
• It is strictly prohibited to use personal and financial information of customers, suppliers or employees for any unauthorized/non-business purpose (except for the disclosure of information and documents requested by authorized persons or institutions specified in the law and other legal regulations).
• They cannot share the information they have learned and the documents they have as part of their work with unauthorized persons and authorities within or outside the institution for any purpose, and they cannot use them for speculative purposes (directly or through a third party).
• Projects, technical infrastructure, regulations, etc. that they have developed due to their duties. knows that the works are the property of Aydem Energy; They cannot, under any circumstances, take these or similar studies out of the institution without obtaining the written approval of the relevant Company's senior manager.
• They do not share their personal rights, which should only be known to them, with others inside or outside the institution.
• They avoid criticism regarding Aydem Energy's general policies that could damage the reputation of the Company.
• They cannot discuss issues related to their duties outside of their duties, and they cannot cause any speculation or situations that may lead to negative evaluations.
• Even if the employee leaves his/her position in the company for any reason, the responsibility to protect customers' personal and financial information continues. It is prohibited to take confidential information out of the institution, share it with third parties, or use such information for personal purposes outside the institution.

It is very important for the reliability and reputation of Aydem Energy that our employees comply with professional behavior standards that ensure the confidentiality of relations and information between the institution and its customers. Discussing or talking about confidential information about customers or transactions outside of normal business activities and in public areas where third parties may hear may result in a violation of this confidentiality.

Personal information accessed by our employees for work purposes must be used in accordance with the Personal Data Protection Law (KVKK) and the legislation supporting this law, company policies and procedures.

The use of information arising from duties or internal authorities is limited to situations that are strictly necessary for the legitimate and appropriate business objectives of Aydem Energy Group.

Consumption, address and identity information of eligible consumers should never be shared for the benefit of other retail / wholesale electricity sales companies.

Additionally, information about how our day-to-day business operates (such as our strategic plans and products) and non-public information about customers should be used with caution and care. Even the slightest hint on this subject may cause misunderstandings.

Aydem Energy's obligation to maintain the confidentiality of information continues in case of resignation from its position for any reason.

Non-public information, transactions, computer software, technical information, materials, records, files, documents, programs, reports, reviews, data, customer lists, trade secrets and all other information regarding the company's customers and other third parties are the property of Aydem Energy and Cannot be used outside of work.

Our employees cannot disclose this information to any third party. Under no circumstances can this information be made known or disclosed to any competitor or any third party, during or after the service.

Equipment and items provided by the company to its employees as part of their duties are not considered personal belongings. In addition, the Company reserves the right to monitor employees' user accounts and electronic communication means such as e-mail, telephone, computer systems and other electronic records assigned to them for work, based on existing laws.

It is our employees' responsibility to be aware of all policies regarding the secure handling, distribution, transportation, storage or disposal of information. All our employees are obliged to act in accordance with the provisions of the "Information Security Policy" published / to be published by the institution, except for the matters stated below.

As an Aydem Energy employee, we are expected to comply with the following basic policies:

• All computer access should be limited to information necessary to perform daily tasks. If there is a need to share information with people outside the company, this issue should be questioned in detail and, if necessary, the situation should be discussed
• with the Information Security Management and the relevant Code of Ethics Advisor.
• When sharing information with authorized persons, the required information must be provided at the required level.
• Confidential information should be stored in places where only authorized persons can see and access it. When not in active use, documents containing confidential information should be stored securely in a drawer or cabinet and should not be left in fax machines, printers or other unsafe places.
• When distributing such information within the institution, envelopes marked "Personalized" should be used.

• Laptops and other portable devices are highly susceptible to theft. Such portable devices (computer, tablet, radio, mobile phone, etc.) should not be left in unsafe places. In case the device belonging to the employee is lost or stolen, Information
• Security Management and Human Resources Management should be notified as soon as possible.
• Our employees must lock their computers or log out of the system before leaving their computers unattended.
• User IDs or passwords are personal and should not be shared with anyone. Our employee may be held responsible for any use of the user ID or password, including any unauthorized use, and any corporate damages that may be caused by any abuse that may occur. In cases where user ID or password is suspected to be compromised, passwords should be changed and Information Security Management should be contacted.
• The configuration of the company-supplied computer's antivirus program cannot be changed. It is our employee's responsibility to protect the computer allocated by the company from computer viruses sent to the employee from outside the organization and that may reveal company information.

Relations with Government and Public Institutions

The Company's relations with public administration, political organizations, unions and other organizations; It should be based on the principles of integrity, honesty, equality and independence at the highest level.

Relations with Customers, Suppliers and Other External Organizations

Our employees act within the framework of the principle of integrity in their relations with customers, shareholders, affiliates and other companies, representing the Company.

As Aydem Energy, our main goal is to meet the needs of our customers. Customer satisfaction determines the success or failure of our organization and therefore; Our customers are the most important part of our business. Since ensuring customer satisfaction is the best advertising tool we can achieve, customer relationship management in the Company; It is based on the principles of professionalism, courtesy and, more importantly, seriousness and reliability. Honesty, equality and compliance with the law should be kept at the highest level in customer relations.

Employees must provide customers with full and clear information about the Company's products and services. Employees do not have the right to provide false information in order to make higher profits. Our customers are clearly informed about their rights and obligations in their transactions with Aydem Energy and the benefits and risks of the products and services offered to them. Therefore, our employees have the responsibility of being equipped with both Aydem Energy and the services and products provided by the Group Companies.

Sales or communication techniques that are incompatible with professional ethical rules, provide incorrect or incomplete information to the customer about the product or service, or attempt to force the customer in the decision process cannot be used.

In addition to the interests of the institution in the activities carried out within the free market economy, employees; In general, they avoid behaviors that constitute unfair competition within the framework of the principles of maintaining trust in the energy sector, making efforts for the development of the sector, and observing common interests, and do not express positive or negative opinions or make comments regarding competing organizations and their products and services during their duties.

Relations with suppliers are also based on the rules mentioned above.

Confidentiality conditions in relations with individuals or organizations from which consultancy services are received should be clearly guaranteed with a contract. However, the ability of personnel whose employment in the company has expired to work temporarily as a consultant is subject to the proposal of the relevant business unit manager, the evaluation of the Human Resources Director and the approval of the CEO.

Any Aydem Energy employee cannot make a real or visible commitment on behalf of Aydem Energy, officially or unofficially, without authorization in accordance with approved procedures, and cannot work with those who harm public morals or harm the environment and public health.

All Company employees must avoid any activity, practice or action that would violate competition law, especially abuse of dominant position. The relevant rules are regulated in the Competition Law Guide.

In Aydem Energy's relations with the press, our employees must avoid situations that may lead to any speculation, negative evaluation regarding the institution, and practices and behaviors that may harm the trust, reputation and stability of our institution or the sector or create unfair competition.

In public and in areas where the audience thinks we are speaking on behalf of our Company, we express only the views of our Company, not our own.

Press relations regarding all of Aydem Energy are carried out by the Corporate Communications Directorate. All external relations are carried out within the procedures determined by the company. All requests, interview requests and all questions from written and verbal media should be immediately transferred to the Corporate Communications Management at Aydem Energy.

Prior approval must be obtained from the Corporate Communications Directorate regarding all contact information to be provided to third parties. Only authorized persons may communicate about the Company and its policies, practices and procedures.

We avoid expressions that would give the impression that third parties are sharing on behalf of Aydem Energy in their posts on social networking sites, blogs, dictionaries, forums, and e-mail groups.

In addition, the Aydem Energy Digital and Social Media Principles Document published to represent the corporate structure through social media is essential.

Aydem Energy does not prevent its employees from engaging in external activities that will not cause them to neglect their in-house responsibilities, will not restrict them from acting in accordance with the interests of the institution, and will be in compliance with the declared "Ethical Rules and Working Principles". However, our employees participating in such activities must avoid possible or actual situations that conflict between the interests of the Company and their own interests.

“Conflict of Interest” occurs when an employee's personal interest and the Company's interest interfere with each other. For example, an employee's responsibilities or obligations in a situation that is in his own interest outside the organization or in his private life may make it difficult for him to fulfill his responsibilities and duties related to his position in the Company objectively / impartially and effectively. Conflicts of interest may also arise when a family member of an employee receives a personal benefit through his/her position with the Company.

Any transaction or relationship that may create a conflict of interest must be reported to the Ethics Rules Advisor.

In order to prevent possible conflicts of interest, our employees;

• They avoid causing situations that would create a conflict of interest or the impression in favor of themselves or their relatives, and do not take part in the decision-making process on matters that concern their or their relatives' interests.
• They do not enter into any personal financial relationships with customers and suppliers, and they do not gain personal benefit by using business relationships.
• They do not allow gifts or offers of interest that could affect their decisions and consent or create a conflict of interest.
• They use the company's assets and resources efficiently and solely for the benefit and benefit of the organization.
• They use their time and effort for the institution, do not undertake any other responsibilities that would create a conflict of interest, and do not work for another real or legal person outside the company.
• In their relations with public institutions and organizations, they act in line with the principles of honesty and transparency and maintain distance and impartial relations.
• They protect corporate and customer secrets and do not take out corporate-specific information that provides competitive advantage.
• They do not use the information they have obtained as part of their duties in a way that would lead to unfair gain.

Our employees at all levels must show the necessary common sense and effort while performing their duties, take into account the principles of profitability and efficiency, and avoid all actions and transactions that will cause the company to suffer losses. Our employees are obliged to use these legal business opportunities when any opportunity arises in favor of the institution.

Employees cannot make decisions or engage in activities that are contrary to the interests of the Company or incompatible with the responsibilities of the employee. If a potential conflict arises, the employee must immediately report the situation to the Code of Ethics Advisor to whom he/she is affiliated.

If a potential conflict arises, the employee must immediately report the situation to the Code of Ethics Advisor to whom he/she is affiliated.

Our employees; They must refrain from taking advantage of any opportunity that may benefit Aydem Energy, or obtained by using Aydem Energy's property or information, or obtained as a result of their position in the company, because it is contrary to their own interests, or to prevent other employees from doing so.

Our employees must not, under any circumstances, borrow money from customers or third parties, provide benefits or enter into a suretyship relationship during or in connection with the performance of their duties.

Our employees should manage their private and financial affairs responsibly and should not be burdened with debts that they cannot pay. Our employees must display a balanced and harmonious attitude both in their professional lives and their personal financial situations.

Between company employees in subordinate and superior relationships and among company employees; They are prohibited from entering into debt-credit relationships with customers, suppliers and contractors.

Bribery means obtaining an illegal benefit; It is offering payments or benefits directly or indirectly to our employees in order to influence decisions and practices. Payment in cash or non-cash, giving valuable gifts, offering the employee an advantage that will provide personal benefit, etc. It can occur in many ways.

If our employees are offered a bribe by any person, company or institution, the employee to whom the offer is made must immediately report it to the relevant Code of Ethics Advisor.

Company employees should not become members of political organizations using the company name while performing their duties. However, in their personal memberships, they are obliged to avoid any activity that may harm the interests and image of the Company and negatively affect their working hours.

None of our employees may engage in political resource management activities or campaign activities at work or use the company for these activities.

Donations (in cash or any other form) cannot be made on behalf of Aydem Energy to political parties, political organizations, representatives of such groups and candidates, directly or indirectly, for the purpose of providing benefits to the company. Our employees must avoid situations that could mean material or moral support to political parties on behalf of Aydem Energy.

It is of great importance that the gifts sent to our employees due to their duties do not create doubt in the eyes of third parties about the impartiality of our corporate judgment and decisions. Preventing inappropriate relationships with third parties that could damage Aydem Energy's reputation is possible with the existence of a corporate approach and practice regarding gift acceptance. For this reason, our employees are required to act jointly in accordance with the rules stated below regarding the acceptance of gifts.

Our employees may not accept any item/service of any symbolic value (corresponding to 100 USD) or cash, check, etc., regardless of value, for any transaction or business. cannot demand or accept.

It does not matter whether the person does not directly benefit from this valuable item. Anything of value cannot be accepted on behalf of a third person or party.

Gifts, hospitality or other gifts that may or are intended to influence our company's preferences and decisions should not be accepted, and such requests should not be made.

Any gift that does not comply with the above-mentioned rules must be returned to the sending person or institution by the employee who sent it, by informing his/her manager. If a decision cannot be made regarding the suitability of the gift, written approval must be obtained from the relevant Code of Ethics Advisor.

In cases where it is decided that returning a gift worth more than 100 USD is not practical or may have undesirable consequences in terms of the business relationship, the acceptance and use of the gift in question may only be deemed appropriate with the written approval of the relevant Code of Ethics Advisor. In such cases, the gift must be accepted and reported to the Internal Audit and Control Directorate at the same time (for example, within 24 hours).

Every gift amounting to 100 USD or more must be recorded by the Management and the gift acceptance reports created must be kept by the Managers to be presented to the Code of Ethics Advisor when necessary.

Additionally, in order to prevent similar gifts from being sent again from the same institution in the future, our Company's principles and practices in this regard can be explained to the sending institution or person in a thank you letter.

All our employees are responsible for complying with the procedures mentioned above and reporting the issue to the relevant Code of Ethics Advisor and Human Resources Management in cases where they think or witness a violation of this procedure.

Gifts may be given on behalf of the company to customers, business partners or supplier representatives within the framework of maintaining the business relationship. Gifts, regardless of their value, must be honest in nature and of a nature that will not influence decisions to be made in business relations.

The process must comply with the principles and general practices determined by Aydem Energy management and must not damage the reputation of the institution. The principles applied to accepting gifts, invitations and donations also apply to their giving, and a limit of 100 USD will be applied to these transactions.

Acceptance of Events Sponsored or Expenses Undertaken by Third Parties

Our employees; entertainment, free education, seminars, accommodation, trips, meals, etc., with the aim of influencing their decisions in their work. should not accept the offer.

However, the Company acknowledges that, in certain cases, rejecting offers of the type mentioned above may damage customer relations. Therefore, free conferences, promotional meetings, training, etc. from third parties or our customers or potential customers. Purposeful participation offers can only be accepted with the written approval of the senior manager of the relevant function and the relevant Code of Ethics Advisor.

Accuracy of Records

Integrity, accuracy and reliability in all kinds of records, documents and financial statements issued on behalf of Aydem Energy are of great importance for the continued success and future of Aydem Energy. For this reason, our employees are responsible for ensuring the accuracy and legal compliance of records, documents and documentation in all transactions they carry out on behalf of Aydem Energy.

In addition to accounting and audit records, these documents include time records, loan documents, telephone records, transaction records and all other records that are part of our daily workflow. All records must reflect transactions accurately and on time, and in case of errors, errors must be corrected immediately.

If any deception, alteration and/or negligence is detected within the general activities of the company, the Code of Ethics Advisor and Human Resources Management or the relevant unit of the company must be immediately notified.

Employee Stock Transactions - Insider Trading

It is natural that our company has certain expectations from its employees within the framework of the principles of duty of loyalty and protecting the company's interests. In the context of these expectations;

It is possible for employees to carry out investment transactions with Aydem Energy shares on the stock exchange, under the conditions specified in the Capital Markets Board regulations. However, employees are aware that trying to obtain any benefit, including directly or indirectly buying and selling shares on stock exchanges, by using any confidential information belonging to Aydem Energy or giving it to third parties is insider trading and that these behaviors are prohibited by law. They know that it is considered a crime. Internal procedures established to implement the Capital Markets Board regulations are implemented with precision. Employees included in the "insider" list are expected to be in full compliance with the relevant legislation, company policies and procedures.

According to the Capital Markets Board's Series: VIII, No: 22 "Principles Regarding Sales Methods in Public Offerings of Capital Market Instruments" Additional Article: 1 "Prohibition of Transactions in Public Offerings": "In sales of capital market instruments through public offering; Chairman and members of the board of directors, legal auditors, executive directors, general managers and deputy general managers of issuers who issue and offer capital market instruments and intermediary institutions that mediate public offerings, and other personnel who may have information due to their duties, as well as their spouses and first-degree blood relatives Marriage relatives cannot directly or indirectly purchase the capital market instruments in question.”

Employees of Aydem Energy, other than the persons specified in the above-mentioned circular, can participate in public offering transactions made by both companies within Aydem Energy and other intermediary institutions.

Use of Company Assets and Resources

Any goods, assets, equipment, vehicles, computers, computer programs and the like owned by the company and provided to the employee to carry out daily work cannot be used by any employee for personal benefit or the personal benefit of anyone else.

Company-owned telephones, personal computers, copiers and fax machines, supplies, postal service, e-mail, bulletin boards and meeting rooms are primarily for company use. Using the specified resources or other company resources for personal purposes may disrupt the flow of very important information.

Company phone and company address, e-mail, internal communication and messaging systems should not be used for personal correspondence and meetings. Private phone calls should be kept short.

We take into account the interests of the institution in the use of resources on behalf of Aydem Energy companies, and we are sensitive in the protection of company assets. We avoid loss, damage, misuse and waste of group assets. We do not use company assets and facilities outside of company business, under any name and for anyone's benefit, without the benefit of the company. In cases of public interest or obligation, the approval of the General Manager of the relevant business unit is required.

Aydem Energy Internet and Intranet system is for business-related transactions, communications and research. It cannot be used for purposes other than these (watching TV series / movies, etc.) and/or for obscene, pornographic or terrorist purposes. Additionally, employees should not install and use unlicensed software on company computers. In no way via company-owned mobile devices; Messages that are abusive, threatening or that will damage the reputation of the institution cannot be sent.

Employees cannot engage in work that requires them to be directly or indirectly considered as merchants or tradesmen ("Commercial enterprise" or "Craftsman enterprise"), cannot serve as board members or auditors in companies other than Aydem Energy companies without the written approval of the top manager, and cannot engage in commercial activities of real and legal persons. They cannot work in any job, paid or unpaid, without obtaining written approval.

Employees may receive offers to participate in external events as paid or unpaid speakers or consultants, based on the experiences they have gained throughout their business life. Such opportunities should be evaluated by the senior executive of the relevant business unit and the Director of Corporate Communications to determine whether any conflicts between personal and corporate interests exist.

All communication, whether written or verbal, must be conducted in a professional manner and in accordance with our code of ethics. What we say, write and do must clearly reflect Aydem Energy's ethical values ​​and expectations and indicate the existence of a healthy personal judgment. Exaggeration, misdirection, pompous language, overly shorthand expressions, legal speculation, and disparaging remarks and attitudes towards people, companies and their products and services should always be avoided.

Everything that employees say, write and do should be aimed at protecting and reflecting the honesty and reputation of Aydem Energy. This policy applies to all types of communications, including voicemails, emails, memos and reports.

Email is an important method of internal and external communication. E-mails are records that can only be disclosed if required by legal processes, otherwise they must be kept strictly confidential. No e-mail that does not comply with our ethical standards should be written or sent in any way.

All e-mails should be written in a professional manner and be considered legal records. The transmission of any message must occur in compliance with all policies and must be protected against unauthorized access.

The basic rules to be used when using e-mail are as follows;

• E-mail is used when business requires it.
• When preparing an e-mail, it should be taken into account that it is a document that can be seen as a written record, therefore respectful, clear, honest and precise expressions should be used. Exaggerated, frivolous language or slang expressions or derogatory words should not be used in the e-mail content.
• Response messages must contain sufficient information to avoid misunderstanding. Communication via email must comply with our ethical standards and policies, its nature and purpose, and each message must be carefully reviewed before being sent.
• Our standards for information protection and security also apply to email communications. Because e-mail messages are sent outside the Company over public networks such as the Internet, they may be intercepted or misdirected. Therefore, great care must be taken to ensure that it does not contain information that could be used to harm the company, its customers, employees or any of its shareholders.
• If confidential information must be transmitted via the internet, it should be sent using secure (encrypted) e-mail facility.
• Work-related 'Top Secret Information' should not be sent outside the organization by e-mail.
• To reduce the risk of revealing customer information, if a customer sends an email that contains personal information, this information should be deleted from the email response.

Email facilities should not be used for;

• Transmitting or storing messages that may be perceived as offensive, derogatory or hostile,
• Transmitting or storing virus warnings or joke messages (Information Security Management should be informed about these warnings),
• Engaging in communication or activity that may harm Aydem Energy or any of its customers and shareholders,
• Transferring chain messages containing expressions of protest, aid or exploiting human emotions to others (those who send such messages should be warned and the Code of Ethics Advisor should be informed that there is such a chain message in the system),

• Transmitting messages that are not work-related, for entertainment purposes, containing attached files containing games, sounds and images that will negatively affect the system capacity,

• Chatting via messaging programs during working hours; e-mail and messaging reach the level of neglect of work.

Monitoring Employee's Usage of Email and Other Systems

Aydem Energy reserves the right to monitor whether the e-mail, computer files or systems allocated to its employees are used for their intended purpose.

The Company has the right to monitor all communications made via e-mail and to intervene and read them when necessary. All kinds of document, contract theft, unauthorized photography, questions asked to employees for the purpose of leaking information are considered as security violations. The staff accepts this practice in advance. If the data/information security breach occurs by a Company employee; Disciplinary provisions are applied to the relevant person and the responsible person who was negligent in the incident. If it is committed by a person or institution outside the company; Legal action is taken when deemed necessary.

Within the scope of ethical review and disciplinary investigation activities; If deemed necessary, the Internal Audit and Control Directorate is the only unit authorized to review the device and software records (notebook, external data storage device, mobile phone, tablet, e-mail, Skype, SMS, etc.) provided by the Company to the relevant personnel for use. Stop. Relevant records may be subject to review by the Internal Audit and Control Directorate upon written request from the Information Technologies Directorate. This authority cannot be transferred to another unit and the data cannot be shared with third parties within or outside the company. Internal Audit and Control Directorate has the said authority; It has sole ownership based on the precedent decisions of the Constitutional Court and the Supreme Court, KVKK and relevant legislation and the relevant articles of Aydem Energy Information Security Policy.

Acting Respectfully and Considerately in Our Relationships with Others

As Aydem Energy, our main goal is to approach our employees with respect, thoughtfulness and understanding and to create an environment that will contribute to full communication at all levels. We encourage open discussion of business problems and finding solutions to these problems.

To develop team spirit within the company; Protecting and improving the corporate company identity should be adopted as a common goal. All our employees are responsible for creating and maintaining an atmosphere in the workplace that is compatible with all the values ​​stated in this guide.

Aydem Energy race, religion, nation, gender, sexual preference, marital status, age, seniority, family, etc. It provides employment opportunities to people who are diverse in different aspects. Our employees are required to value this diversity and conduct their relationships with each other in line with the principles of mutual respect, justice, courtesy, honesty and equality.

Company personnel should not disturb each other in common areas reserved for employees (including the use of service vehicles). In these areas, posters, handwritten notes and notes should not be hung, except for those permitted by the management, and goods and services should not be sold.

An employee may be contacted by another employee, either directly or by phone, e-mail, etc. Harassment through indirect means such as this is also unacceptable. Harassment includes, but is not limited to, the behaviors listed below.

Describing members of a particular group in derogatory terms,

• Negative classifications, derogatory jokes, offensive expressions,

• Pictures or caricatures that humiliate or ridicule a particular group or person,

• Any derogatory remarks or physical attacks that affect the relationship between employees by creating an uneasy and hostile work environment,

• Physical or verbal behaviors other than the distance relationship required by the working environment, promotion at work due to the sexual choice of the employee, performance evaluation, cooperation with colleagues, etc. establishing or threatening ties between

• Any unwanted sexual advances, sexual overtures or other remarks or similar gestures.

No accusatory and/or vindictive behavior can be taken against employees who report harassment or inappropriate behavior in the work environment to the relevant management and/or the Code of Ethics Advisor. Additionally, our managers are required to manage such situations confidentially.

In case of harassment or aggressive, accusatory attitude and behavior of the type mentioned above, a problem occurs within the institution that causes a decrease in workforce and performance, or if any of our employees thinks that they have been subjected to similar behavior by their colleague, manager or customer, the Code of Ethics Advisor and Human Resources Advisor Resources Management should be informed.

Any violation of immunity through physical, sexual and/or emotional harassment against our employees or our stakeholders with whom we have a business relationship by our employees, at the workplace or anywhere they are for business purposes, will not be tolerated. Possible negative attitudes and behaviors towards people who report such violations or assist during the investigation are considered a violation of our ethical rules.

Systematic and planned behaviors that aim to alienate the targeted person from work, reduce his performance, or cause him to resign, which can be considered within the scope of psychological mobbing, are not tolerated.

As an Aydem Energy employee, you must dress in a clean, attentive and professional manner in your working environment; We must be friendly, caring and respectful towards everyone.

We must represent Aydem Energy, a trustworthy institution, in the best possible way with our behavior and appearance. This principle is extremely important in terms of improving customer relations and increasing the reputation of the institution and must be fulfilled meticulously.

Creating team spirit within the company, protecting and improving the company image is the common goal that plays an important role in the workplace and in the private life of each employee. We must display a balanced and harmonious attitude, professionally and financially, in order to avoid negative reflections on our work and/or the image of the company.

In our external relationships, we must show equal respect to our customers, potential customers, shareholders and the communities we serve. This requires providing courteous service, ethical business conduct and compliance with all laws and regulations. As employees of a customer-oriented organization, we have a responsibility to act in a way that creates positive impressions about Aydem Energy.

We must adhere to high standards of integrity in the conduct of our daily work and strive to perform our job to the best of our ability to ensure that we achieve the Company's goals and objectives. We must use the time correctly during the working period and make sure that our private works are short-term so as not to disrupt customer transactions.

The development of employees has a great contribution to Aydem Energy's achievement of its goals. Managers should manage employees based on professional criteria and provide equal development and reward opportunities to all employees in connection with their contribution to the company's success. Managers who coordinate specific jobs or departments must exercise the powers designed for their job with balance, impartiality and taking into account the personal dignity of staff. Our managers must avoid doing and/or having others do anything beyond their authority by abusing their positions and responsibilities for any purpose. Our managers must continually support employees' professional development.

Within the framework of honest and prudent management principles, managers are responsible for proposing and implementing management styles that will increase the company's values, provide maximum profit to the Company and protect the rights of employees in the long term.

Employees should work to ensure maximum cooperation with their managers, avoiding behavior that is incompatible with working principles.

As a general principle, our employees are responsible for carrying out the instructions of their superiors. However, it is not obliged to carry out instructions that may damage Aydem Energy's profitability, efficiency and reputation or that are not in accordance with the Company's principles and legislative provisions on the subject. An employee who believes that the instructions are contrary to legal and/or internal regulations or harmful to the Company reports this opinion to the senior manager who gave the instruction and to the Code of Ethics Advisor. If the employee who fulfills the instruction believes that the action he/she has taken pursuant to the instruction constitutes a crime clearly stated in the relevant laws and regulations and/or will cause damage to the Company, he/she must immediately report the situation to the Internal Audit and Control Directorate.

Relationships between different job levels must be regulated within the rules of mutual loyalty and respect created by the hierarchy - within the Company and in a manner that respects the Company's values ​​and objectives.

Colleagues who are related to the following degree cannot be assigned to report directly to the same manager in any department of the Company.

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

• Your spouse, mother, father, sibling, uncle, aunt, and their spouses and children.

All transactions involving family members and relatives of employees are carried out by other employees who are not involved in the transactions in question.

At the same time, in order to ensure maximum transparency in all affairs, our employees must inform the Human Resources Management if one of their family members (in case of blood relation) has or has a connection with the Company.

Our employees are obliged to take care to comply with the working hours determined for the workplace they work in and to use the personnel attendance control system (card reading, fingerprint reading, etc.) at entrance and exit. It is essential that the employee is on-site during working hours.

An employee who leaves his/her place of duty for any reason must inform his/her manager or his/her closest colleague about the place of visit.

An employee who must be outside the organization due to his/her duty must inform his/her manager about the destination and the hours he/she will spend outside.

An employee who leaves his job permanently or temporarily cannot leave his job unless he hands over the money and monetary values, documents, tools and equipment that he has to keep and use. This principle also applies to those who are temporarily assigned to another position.

If the company suffers any damage due to failure to fulfill the duty of transfer and delivery, those who caused it will be held responsible.

Equal Opportunity/Providing Equal Opportunities in Employment

Aydem Energy aims to create a working environment that values ​​the talents and experiences of each individual, respects differences and gives each employee the right to express their ideas and opinions.

Respecting differences is not only the right way to do our job, it is essential to the success of our business.

Aydem Energy does not allow discrimination among its employees. It ensures that all personnel practices are carried out based on individual ability and merit, regardless of race, religion, color, age, gender, national origin or ancestry, sexual preference, physical disability, seniority status or other factors determined and protected by law. These practices include, but are not limited to, recruitment, selection, performance management, training, placement, transfer, promotion, disciplinary action and termination of employment.

Occupational Health and Safety (OHS) and Environmental Protection

The company is obliged to provide maximum OHS conditions to all its employees, provide training and deliver its equipment. Likewise, employees are obliged to fully participate in relevant training and take all precautions regarding the issue. All employees must notify their managers in writing/verbally and/or by filling out “Near Miss” forms about possible hazards they see in their workplace. It is the responsibility of process owners related to OHS and Human Resources Management to share the lessons to be learned regarding work accidents in the field. Employees are obliged to comply with Aydem Energy Occupational Health and Safety and Environmental Policies and the details specified in the relevant legislation.

OHS incidents are reported to the relevant authorities in a transparent manner and in accordance with the legislation and Company policies/principles.

Employees, customers and visitors are prohibited from carrying weapons in work areas, except for those who have to carry weapons due to their duties (Security Guards, etc.).

During checks at building entrances, our colleagues must carry out the necessary checks, regardless of title.

Carrying weapons for special reasons and armed entry of visitors is only possible with the permission of the Human Resources Management.

The use of any substance (alcohol, drugs, etc.) that will affect our employees' work performance or endanger workplace safety is strictly prohibited. This prohibition also includes being under the influence of these substances that will negatively affect the employee's work performance when entering Aydem Energy buildings.

Employees cannot engage in activities such as betting or gambling that are defective and that may damage the reputation of Aydem Energy company in the public eye.

Organizing or participating in any type of gambling activity, such as providing gambling equipment, organizing any type of raffles or games with prizes for goods or money, or buying and selling tickets for such games, is prohibited for all employees.

Aydem Energy Code of Ethics and Working Principles have been published by the Board of Directors and are reviewed once a year in line with needs, changing conditions and current practices.

Our Code of Ethics and Business Principles are the main factors of our reputation and continuous success in the sector. Violation of these rules and principles may negatively impact our reputation and success in the industry. Therefore, behaving unethically, contrary to our principle of honesty, or going against business principles falls within the scope of ethical review or disciplinary investigation. All our employees must act in accordance with these rules.

Our employees must carry out their responsibilities in accordance with the applicable written laws, regulations, legislation and general trends. Our employees cannot engage in any illegal activity or inform anyone in this way while carrying out their responsibilities in the Company or doing their daily work.

Any violation of the law, agency policies, or ethical rules, such as failure to cooperate with an investigation, may be subject to ethics review or disciplinary investigation.

The top manager responsible for Human Resources management of each company within Aydem Energy is the Code of Ethics Advisor. Code of Ethics Consultants;

To provide guidance and consultancy on questions and issues submitted by employees regarding ethics within the company,
Referring ethical nonconformities that cannot be resolved within the company or that require ethical review or disciplinary investigation to the Ethics Committee.
To contribute to the resolution of internal ethical non-compliances received by the Ethics Committee, in line with the request of the Ethics Committee,
Reporting ethics-related questions and non-conformances, along with their consequences, to the Ethics Committee regularly or when requested,
Being the contact person from the company in ethical reviews and investigations requested by the Ethics Board and providing the necessary support to the reviews and investigations carried out by the Internal Audit and Control Directorate,
Responsible for monitoring and monitoring the effectiveness of ethical practices carried out in the company and supporting the practices.

Aydem Energy managers have additional responsibilities beyond the responsibilities defined for employees within the framework of the Code of Ethics and Working Principles. Accordingly, managers;

• To ensure the creation and maintenance of a company culture and working environment that supports ethical rules,
• To set an example with their behavior in the implementation of ethical rules and to train their employees on ethical rules,
• To support its employees in communicating their questions, complaints and notifications regarding ethical rules,
• To provide guidance on what needs to be done when consulted, to take into account all notifications made and to forward them to the Ethics Committee as soon as possible when deemed necessary,
• He is responsible for ensuring that the business processes under his responsibility are structured in a way that minimizes risks related to ethical issues and for applying the necessary methods and approaches to ensure compliance with ethical rules.

Resolving Incompatibilities

Ethics Committee Organization

Incompatibilities on ethical issues are resolved within the Aydem Energy Ethics Board.

Ethics Committee; It consists of the Chairman of the Board of Directors, Group Human Resources Senior Manager and Group Legal Executive. The Ethics Committee evaluates violation issues by taking into account the ethical review and disciplinary investigation reports prepared by the Internal Audit and Control Directorate. The functioning of the Ethics Committee, decision-making processes, relations with Disciplinary Committees in companies and reporting practices are described in detail in the Disciplinary Practices Procedure.

The Ethics Committee carries out its work within the framework of the principles set out below:

• Keeps notifications and complaints and the identities of those making notifications or complaints confidential. It adopts a policy to prevent possible retaliatory attitudes and behaviors towards employees or individuals who report ethical violations.
• Conducts investigations and investigations within confidentiality rules.
• It has the authority to request information, documents and evidence related to the examination and investigation directly from the existing unit. It can examine all kinds of information and documents it obtains only limited to the subject of the investigation.
• The review and investigation process is linked to a written report from the very beginning. Information, evidence and documents are added to the report.
• Notifications subject to review and investigation are handled promptly and results are reached as quickly as possible.
• The decisions taken by the Board are put into practice immediately.
• The relevant departments and authorities are informed about the result.
• The chairman and members of the board act independently and without being influenced by the department managers they are affiliated with and the hierarchy within the organization while performing their duties regarding this matter. They cannot be pressured or suggested on the subject.
• If the Board deems necessary, it may seek expert opinion and may benefit from experts by taking precautions that will not violate confidentiality principles during the examination or investigation.

For your questions and notifications, you can use the following communication channels or contact the Ethics Committee members directly.