I. OUR CODE OF BUSINESS ETHICS
A. Integrity
Integrity and honesty are our core values in all our business processes and interactions. We act in integrity and honesty in all our relations with the employees and stakeholders.
B. Confidentiality
Private and confidential information includes information that might lead to a competitive disadvantage of KIRANKAYA Engineering Co. trade secrets, financial and other information that has not been publicly disclosed, employee personal information, and information within the framework of "confidentiality agreements" enacted with third parties.
As employees of the KIRANKAYA Engineering Co., we give utmost importance to protecting the privacy of our customers, employees and other associated individuals and companies and the confidentiality of their information. We protect confidential information regarding the activities of the Companies, use this information only for the purposes of the KIRANKAYA Engineering Co., and share this information only with relevant authorized parties.
C. Conflict of Interest
As KIRANKAYA Engineering Co. employees, we take responsibility to avoid situations and relationships that involve conflict of interest. We do not use our present position to obtain any benefits personally or through our families and relatives, from people and companies with whom we have business relations. We do not engage ourselves in any business activity aimed to gain personal financial benefit outside KIRANKAYA Engineering Co. We refrain from using the name and power of KIRANKAYA Engineering Co. to gain personal benefit.
In cases of potential conflicts of interest, when we believe that interests of the relevant parties may be safely protected by legal and ethical methods, we adopt these methods. When in doubt, we consult our manager, the Human Resources Department, or the Ethics Board.
D. Our Responsibilities
In addition to our legal responsibilities, we give utmost importance to fulfil the following responsibilities vis-a-vis our customers, employees, stakeholders, suppliers and business partners, competitors, the community, humanity, and to the name of KIRANKAYA Engineering Co..
1. Our Legal Responsibilities
We execute all our domestic and international activities and procedures within the framework of the laws of the Republic of Turkey and international laws; and we submit all required information to regulatory authorities and institutions in a correct, complete, clear and timely manner.
In executing all activities and procedures, we do not expect any benefit from, and keep an equal distance to all public institutions and organizations, administrative bodies, non-governmental organizations, and political parties; and we fulfil our liabilities with a sense of responsibility.
2. Our Responsibilities Towards Our Customers
We adopt an approach which is focused on customer satisfaction and proactive in responding to customers' needs and demands in an appropriate and timely manner. We deliver our services on time and under the promised conditions; we approach our customers with respect, honour, fairness, equality, and courtesy.
3. Our Responsibilities Towards Our Employees
We enable our employees to use their personal rights fully and correctly. We approach employees with honesty and fairness; and ensure a non-discriminatory, safe, and healthy working environment. We undertake the necessary efforts to enable personal development of our employees; with a social awareness support them in volunteering for appropriate social and community activities; and respect and assure the balance between their private and professional lives. 

4. Our Responsibilities Towards Our Partners
Dedicating prime importance to the continuity of the KIRANKAYA Engineering Co., and in line with our goal to create value for our partners, we avoid taking on unnecessary or unmanageable risks, and strive for sustainable profitability. We act with financial discipline and accountability, and manage our company's resources, assets and our professional work time with a sense of efficiency and economy. We work to enhance our competitive power, and to invest in areas with growth potential and which offer the highest return on allocated resources. We give timely, correct, complete, and clear information on our financial statements, strategies, investments and risk profile to the public and to our shareholders.
5. Our Responsibilities Towards Our Suppliers/Business Partners
We act respectfully and fairly as expected from a good customer, and ensure to fulfil our liabilities on time. We carefully protect the confidential information pertaining to the persons, organizations and our business partners.
6. Our Responsibilities Towards Our Competitors
We compete effectively, only in areas that are legal and ethical, and avoid unfair competition.
We support all efforts to construct a competitive structure targeted within the society.
7. Our Responsibilities Towards the Community, Society and Humanity
Preservation of democracy, human rights, and conservation of the environment; education and charity activities, eradication of crimes and corruption is of utmost importance to us. We pioneer in social affairs with an awareness of good citizenship and responsiveness; we try to play a role in non-governmental organizations, in services and activities for the benefit of the society and public. We act in a responsive and sensitive manner in Turkey and towards the customs and culture of those countries where we undertake international projects. We do not offer and accept bribes or gifts in forms of products or services, etc. beyond commonly accepted reasonable limits.

8. Our Responsibilities Concerning the Name " KIRANKAYA Engineering Co."
Our business partners, customers, and other stakeholders trust us due to our professional competence and integrity. We strive to keep our reputation at the highest level.
We offer our services within the framework of company policies, professional standards, our commitments, and ethical codes; and we ensure to fulfil our liabilities.
We offer services in areas where we believe we are or will be professionally competent; and we seek to work with customers, business partners, and employees demonstrate integrity and legitimacy. We do not collaborate with those impairing social ethics, and damaging the environment or public health. 
We do not express our personal opinions, and only communicate our company's view in public, and in areas where we are perceived as representing our company.
II. POLICIES SUPPORTING CODE OF BUSINESS ETHICS
A. Conflict of Interest Policy
Employees of KIRANKAYA Engineering Co. are required to avoid situations and relationships that involve actual or possible conflict of interest. Employees are required to assume the primary responsibility for avoiding the use of Company resources, name, identity and power for personal benefit and keeping away from situations that might have a negative affect on the organization's reputation and image. The following rules of practice define situations and/or relationships involving conflict of interest that Company employees might experience while fulfilling their duties or in their private lives due to certain business relationships, and establish the principles to be followed by employees in such situations.
Rules of Practice
1. Activities That Might Create Conflict of Interest
All employees are required to fully comply with the situations which are defined below as activities that might create conflict of interest, and the below established principles. The Company undertakes the necessary efforts to encourage employees to abide by these principles.
i. Engaging in Activities That Might Create Conflict of Interest
Employees shall in no way enter a business relationship with their family members, friends, or third parties that offers them reciprocal or non-reciprocal benefit. For example, an employee with purchasing authority should avoid doing business with a supplier where a family member is employed. Exceptional circumstances require the knowledge and approval of the Company Chairperson. In the same respect, Company employees should also be careful against possible conflict of interest that may arise due to family members working for the competitor.
It is fundamental that Employees of KIRANKAYA Engineering Co. shall not conduct activities directly or indirectly, that may require them to be classified as "merchant" or "tradesman", and shall not under whatever name work for an individual and/or organization during or outside working hours for a fee or a similar benefit. However, employees may only work for third party (family member, friend, other third persons) and/or an organization in return for a payment or a similar benefit outside business hours with the condition that this activity;

• does not create any conflict of interest with their current role in their company and the practices of other KIRANKAYA Engineering Co. companies,
• complies with the other business ethic codes and with the policies supporting these codes,
• does not have a negative impact on their performance at the company;
  
  and written approval from management is obtained.

The approval shall be granted by KIRANKAYA Engineering Co. CEO based on the direct manager’s advice followed by Ethics Board's advice  for Group President, General Manager and all positions reporting to the General Manager; and by the Company General Manager based on the Company  Ethics Compliance Officers’s and Company Human Resources Manager's advice for  all other employees.
Employees of KIRANKAYA Engineering Co.  may not act as a member of the board or auditor in organizations other then the Group Companies without the approval of the Company Board of Directors; and shall not accept positions with a competitor or companies with whom the Group has business relations. They may work at universities and non-governmental organization for social responsibility and charity purposes upon written approval of the management, as long as it does not hinder employee's responsibilities at the Holding/Company.
Managers making employment decisions shall not employ their spouses, close relatives, and relatives of these people.
Employees may give speeches and write professional articles in topics that are not related to the company or its operations, and that are not in conflict with the companies policies. Approval of the CEO/General Manager is needed to use Company name in these activities. 
Company employees may actively be involved in a political party, individually and voluntarily.  Managers shall not request any employee to get involved in any political activity or to become a member to any political party. Meeting the following conditions and obtaining written approval of the management are required for employees to serve in any political party;

• The employees' involvement in any political activity shall not cause any conflict of interest with their current role in the company nor the practice and perspectives of KIRANKAYA Engineering Co..
• Employees may not be involved in any political activity during business hours nor occupy their colleagues' time for these activities.
• Employees may not use the company name, their position and title in the company nor company resources for their political activities.

The approval shall be granted by KIRANKAYA Engineering Co. CEO based on the Ethics Board's advice for Group President, General Manager and all positions reporting to the General Manager; and by the Company General Manager based on the Company  Ethic Compliance Officer's and Company Human Resources Manager's advice for  all other employees.
Employees may personally offer financial or non-financial charity to third persons outside the Company, and may be active in charity organizations.ii. Professional Misconduct
Any employee action that results in harm to the Companies through the use of ones authority with neglect and for ones own and/or relatives' interest shall not be tolerated.
Employees shall not obtain direct or indirect personal benefit from purchasing and sales activities and contracts that the Company is a party to.
Employees may not engage in actions or conduct that is immoral, illegal, or that is in conflict with the Company discipline.
iii. Utilization of Resources
In utilizing resources in the name of the Company, the interests of the Company shall be considered. Company assets, resources, and personnel shall not be used outside the Company under whatever name, or for the name or benefit of whoever unless Company's interests are ensured. All personnel shall abide by the principle of "economy on all resources".
Correct utilization of resources in the interests of the Company also requires proper utilization of time. During working hours, Company employees utilize their time effectively, and do not spend their time for personal business. Managers shall not assign personal tasks to employees.
In principle, guests and personal appointments are not welcomed during working hours. Employees should conduct meetings and interviews with essential visitors in accordance with the subject of the visit, and within a reasonable time not disrupting the business flow.
iv. Relation With Other Individuals and/or Organizations With Whom The Holding/Company Has Commercial Relations
Private business relations cannot be established with, and personal debts and/or goods/services may not be received from Company customers, contractors, or suppliers and other persons and/or organizations with whom the Company has commercial relations. Personal debts in the form of cash and/or goods/services cannot be given to other people and/or organizations with whom the Company has commercial relations.
The following factors should be considered in relationships with customers; even when the customer's benefit is concerned, no transaction may be conducted without the customer's knowledge and approval; and even when company's benefit is concerned, customer's vulnerabilities shall not be exploited and profit shall not be assumed through providing  incomplete or incorrect information to the customer.
Company personnel shall not request or imply for gifts from any person and/or organization with which there is a business relationship, shall not accept any gifts, money, checks, properties, free holidays, special discounts, etc. that may put the Company under any obligation. Personal aid or donations cannot be accepted from any person or organization having business relations with the Company. Under these circumstances, the Policy on Giving and Accepting Gifts shall be followed.
v. Relations With The Media
In relationships with the media, all actions should be in accordance with the Company Communication Protocol.
Giving statements or interviews to any media organization, participating in seminars, conferences, etc. as a speaker requires approval from company's top management. No personal gains shall be received from such activities.
vi. Representing The Company
Any fees that are due because of work done in representation of the Company in any association, in employers' unions and similar NGOs shall be donated to relevant institution or other channels as directed by the institution.
Payments made by third parties to a Company employee for making a speech at seminars or similar services are also donated to the organization, or to channels as directed by the organization. These persons may receive awards, plaques, etc. with symbolic value given as commemoration of the day.
B. Giving and Accepting Gifts Policy
Employees of KIRANKAYA Engineering Co. shall refrian from accepting gifts or benefits that might influence their impartiality, decisions, and conduct; and from offering such gifts and benefits to third party persons and organizations. The rules of practice defined below, define the framework around exchanging of gifts between Company employees and third party individuals and organizations with whom a business relationship exist, and establish relevant principles to be followed by employees in such situations.
Rules of Practice
1. Company employees are prohibited to receive any kind of benefits or gifts, with or without an economic value, that influence or might influence their impartiality, performance, and decision-making while carrying out their duties.
2. Company employees might receive and/or give gifts as outlined in Article 3, or might accept to undergo a special practice on the condition that these:

• are in compliance with the business targets of the organization,
• are in compliance with current legislation, and
• shall not cause an embarrassment for the Company in case of public disclosure of the gift.

3. With the condition that the terms of Article 2 are met;

• Company employees may offer and accept ‘reasonable' entertainment, gifts, and meals in accordance with standards acceptable in the business environment, and on the condition of abiding by the principles in the Company Authorisation Table.
• Awards, plaques, etc. with symbolic, non-monetary value may be accepted as commemoration of having participated in seminars and similar organizations to represent the Company.

4. Cases mentioned above and other gifts, benefits, holidays, discounts, etc. aside from any currency, do not require approval if these are in accordance with the terms of Article 2, and if the total value of the gifts received in each calendar year from each individual/company does not exceed TL 250/or equivalent.
5.  It is forbidden to receive gifts or benefits that are openly or implicitly requiring reciprocation.
6. Receiving, giving, or suggesting bribes and/or commissions is not acceptable under any circumstance.
7. It is forbidden for the Company employees to accept unrequited money or to borrow money from sub-employers, suppliers, consultants, competitors or customers; or to request or accept these people and/or organizations to pay their travel expenses, activity expenses, or similar expenditures.
8. Gifts and promotional material supplied by the Company for customers, dealers, or other third parties in business relationships should be approved by Company top management. Distribution of this approved gifts and promotional material does not require an additional approval.
9. With the condition that the terms stated in Article 2 are met, Company may accept appropriate products and services as gifts; and products and services viewed appropriate for the culture of the recipient and ethical values may be given as gifts with the knowledge and approval of the Company top management.
10. In exceptional cases where local culture requires exchange of gifts that are above the values established by company policy, these gifts may only be accepted in the name of the Company, and upon the approval of the Holding/Company top management. In all cases, exchange of gifts should be done in accordance with local culture.

C. Protecting Confidential Information Policy
Information is among the most important assets that KIRANKAYA Engineering Co. will use in realizing its vision. Therefore, effective use of information, sharing it appropriately, and preserving its confidentiality, integrity, and accessibility are the joint responsibility of all our companies and employees. The compatibility of the management systems established and processes implemented to manage information and its confidentially is very important in maximizing the benefit that the Group shall receive. Details of practices regarding this issue are defined in the KIRANKAYA Information Security Policy and associated documents. The following rules of practice define confidential information for Companies, and establish the principles that the employees must embrace concerning confidential information.

Rules of Practice
Confidential information includes, but is not limited to; brands, and other intellectual rights belonging to the Companies, databases coded, discovered, developed, or deployed by the personnel, including all kinds of innovations, processes, advertisements, product packaging and labels, plans (marketing, product, technical), business strategies, strategic partnerships and information on partnerships, financial information, personnel information, customer lists, product designs, know-how, specifications, identity of potential or actual customers, information on suppliers, and all such information either written, graphical, or readable on a machine.
Principles concerning confidential information are stated below:

• These information may not be disclosed to third parties unless so required by the Official Authorities or Regulations.
• These information may not be altered, copied, or destroyed. Necessary measures are taken to preserve, store, and protect them. Modifications the information are recorded with dates.
• Confidential files may not be taken out from the Organization. For those confidential documents that have to be taken away from office, approval of the person responsible or of the top management should be obtained.
• Passwords, user codes, and similar identifying data used for access to company information are kept confidential and not disclosed to anyone other than authorized users.
• Confidential information belonging to the company is not discussed in food halls, cafeterias, lifts, transport service vehicles or similar public places.
• Confidential information are classified in accordance with the degree of confidentiality, and this is clearly mentioned in the content of the information. Company personnel know the degree of confidentiality of the information received in line with their duties, and act accordingly. In case where there is hesitation concerning the degree of confidentiality, higher level of confidentiality is adopted and the relevant manager is consulted as seen necessary.
• If for the interests of the Company, sharing of company information with third party individuals and/or organizations is in question, a confidentiality agreement concerning information sharing is signed or a written pledge of confidentiality is received from the other party before the confidential information is disclosed, in order to ensure that these parties are aware of their responsibility in terms of the security and protection of those assets.
• There shall be no unfounded statements and/or gossip made concerning individuals or organizations.
• Wages/salaries, side benefits, and similar personnel information reflecting the company policy and that is private to individuals is confidential and may not be disclosed to anyone other than authorised people. Information concerning personnel are delivered in a way as to be private to the individual. It is strictly forbidden for the personnel to disclose these to others, or to apply pressure on other employees to have this information disclosed.

D.   Establishing and Preserving a Fair Working Environment Policy
KIRANKAYA Engineering Co. consider the establishment and preservation of a fair working environment for the employees as an important priority. Through establishing a fair, healthy, and safe work environment in which employees are respected and all relevant laws and regulations are complied with, the intent is to improve and increase employee performance, development, and commitment. The following rules of practice define the basic principles in establishing and preserving a fair working environment at the Companies.
Rules of Practice
1.    Company practices are in accordance with all current laws and regulations concerning employment and working conditions. Company employees fulfill all legal requirements within the context of their activities, and act in accordance with legislation.
2.   The KIRANKAYA Engineering Co. human resources policies and practices ensure that all employment practices including recruitment, promotion-transfer-rotation, compensation, remuneration, social benefits, etc. are fair.
3.    Any discrimination among employees within the organization based on language, race, color, gender, political opinion, creed, religion, sect, age, physical challenge and similar causes are not tolerated. 
4.    A positive and harmonious work environment is established within the Company to promote cooperation, and people with different creeds, beliefs, and opinions are enabled to work in harmony.
5.   Private lives and personal spaces of employees are respected.

• Communications between individuals may not be violated by third persons.
• Even if recorded legally, it is forbidden to give/distribute/obtain personal data illegally.
• Personal information concerning personnel which are basis to and continuity of the employment relation may not be used outside their purpose and context or shared with third persons without the individual's consent.
• Private and family lives of all employees are respected.

6.    In addition to all privacies of employees, physical, sexual, and emotional privacies are also protected.

• Violation of employees' privacies through physical, sexual, and/or emotional harassment in the workplace or in any other environment gathered for work purposes is against the laws and ethical codes; and Holding/Company will in no way tolerate this offense. The goal here is to enable employees to work in an environment where their physical, sexual, and emotional privacies are protected.
• Violating an individual's physical integrity by sexual advancements and/or sexually harassing an individual without physical contact is defined as sexual harassment. Accordingly; it is forbidden to display any behavior that can be defined within this context.
• Furthermore, persons who display a negative attitude or behavior towards those that file a harassment complaint/notifications or towards those who cooperate in such an investigation shall similarly not be tolerated.

7.    No employee may demand any privilege based on a different gender, religion, language, or race; no one shall be privileged and be subject to special treatment. Giving or obtaining concessions because of differences in gender, religion, language, race, etc. is not accepted.
8.   A  healthy and safe physical working environment and conditions shall be established for all employees.

III. REGULATIONS TO BE ENFORCED
KIRANKAYA Engineering Co. conduct business in international markets and therefore, company operations might be subject to laws and regulations of different countries. When faced with uncertainty and hesitation concerning ethics of doing business in different countries, initially the established regulations in the country of operation should be complied with. If complying with the regulations in the country and/or countries of operation shall have adverse consequences concerning the ethical values adopted by the KIRANKAYA Engineering Co., then we should seek solutions within our existing code of ethics and procedures.

IV. EMPLOYEES' RESPONSIBILITIES
KIRANKAYA Engineering Co-ETHICS and its relevant policies and procedures establish the ethical codes on how we should act and how we should do our jobs in detail. It is the primary responsibility of all employees to abide by these codes. Hence, all employees of the KIRANKAYA Engineering Co. have the responsibility to;

• Act in accordance with laws and regulations under all circumstances;
• Read the KIRANKAYA Code of Business Ethics, learn, understand, internalize, and act in accordance with the codes, principles, and values therein;
• Learn the general and business-specific policies and procedures valid for Company;
• Consult their manager or Human Resources about potential violations concerning self or others;
• Urgently report potential violations by self or others; notify manager, Human Resources and/or the Ethics Board verbally or in writing either by disclosing ones identity or keeping it confidental;
• Follow the "Procedures and Methods to be Followed While Making an Ethical Decision" which is defined to guide behaviors and actions as to the codes and problem solving;
• Cooperate with the Ethics Board during ethical investigations, keep information spesific to the investigation confidential.

A. Procedures and Methods to be Followed While Making an Ethical Decision
You should follow the steps defined below and ask yourselves the following questions as a guideline for deciding on an action plan:


1.   Determining the Issue, Decision or Problem

• Have you been asked to do something that you think may be wrong?
• Are you aware of a situation in the Companies or concerning your business associates that may potentially be illegal or not in compliance with business ethics?
• Are you trying to make a decision but have doubts as to how you should behave in compliance with the business ethics?

2. Think Before You Decide

• Try to define and summarize the problem or your question clearly
• Ask yourself why there is a dilemma
• Think about the options and outcomes
• Think who may be affected
• Consult others

3.  Decide Upon an Action Plan

• Define your responsibilities
• Review all relevant facts and information
• Consult relevant company policies, procedures, and professional standards
• Assess the risks, and think about how you can reduce them
• Try to define the best action plan
• Consult others

4.  Test Your Decision

• Review questions that should be asked ethically
• Review your decisions within the context of company core values
• Make sure you have considered company policies, laws, and professional standards
• Consult others and consider their opinions within the formulated action plan

5.   Proceed with Resolution

• Share your decision and its reasons with relevant people
• Share what you have learned
• Share your success story with others

B. 4 Basic Questions to be Considered 
1. Is this activity/behavior in line with laws, rules and tradition? (Standards)

• Is it in conflict with professional standards?
• Is it legal?

2. Is this activity/behaviour balanced and fair? Would we be upset/displeased if a competitor (or someone else) acted as such? (Sense of justice)

• Do you think it is right?

3. Would it be embarrassing for our company and/or stakeholders if this activity/behavior is disclosed in detail in public? (Feelings and ethical values)

• Would you be in a difficult position or embarrassed if others knew of your action?
  Could it lead to negative outcomes for you or your Holding/Company?
• Who may be affected by it (other employees in the Holding/Company, you, shareholders, etc.)?

4. How much does the "perceived fact" and "objective fact" overlap?

• How would it reflect in the newspapers?
• What would any reasonable person think under similar circumstances?

V. MANAGERS' RESPONSIBILITIES
KIRANKAYA Engineering Co. managers have additional responsibilities, further to those defined for employees within the framework of KIRANKAYA Engineering Co-ETHICS. Accordingly, it is the managers' responsibility to;

• Create and preserve a company culture and working environment that promotes the ethics codes,
• Be a role model in practicing the ethics codes; educate their personnel on the ethics codes,
• Support their employees in expressing their questions and in filing their complaints/notifications concerning the ethics codes,
• Offer guidance regarding what should be done when consulted, diligently consider all ethical concerns raised, and forward them to the Ethics Board at the shortest possible time when deemed necessary,
• Structure all work processes under his/her responsibility in a way as to minimize ethical risks and implement necessary methods and approaches to ensure compliance with the ethics codes.


VI. ETHICS COMPLIANCE OFFICERS' RESPONSIBILITIES

• Providing guidance and consulting to employees regarding questions and issues related to ethics within the company.
• Directing those ethical violations which cannot be resolved within the company and need further investigation to the Ethics Board.
• Participating and contributing to the resolution of ethical violations within the company that are directed to him/her through the Ethics Board.
• Reporting the questions and notifications regarding ethical issues, including their resolutions to the Ethics Board regularly or when requested.
• Acting as the point of contact within the company for the investigations conducted by the Ethics Board and supporting the investigations where necessary.
• Monitoring the effectiveness of the KIRANKAYA Engineering Co-ETHICS program within the company and providing support in its practice.


VI. OTHER RESPONSIBILITIES

• The Company top management is responsible for effective enforcement of the KIRANKAYA Engineering Co-ETHICS or the company-specific Code of Business Ethics created within this context, and a culture to promote these codes.
• The Ethics Codes and all policies concerning the Code of Business Ethics are reviewed, revised and documented by the Human Resources Group Management upon the recommendations of the Ethics Board, and the revisions are announced to the Companies upon the approval of the Chairperson of KIRANKAYA Engineering Co..
• Company Human Resources has the responsibility to;
•   - Inform employees about the Code of Ethics, offer periodical ethics training to enable clarity regarding policies and codes, and establish continuous communication on this subject with the employees;
•   - Ensure the newly employed personnel read the Code of Ethics, inform them in this subject, and ensure that they sign the Employee Declaration
•   - At the beginning of each year, ensure employees sign the Business Ethics Compliance Form and update their declarations.
• Company managements, in cooperation with the Ethics Board, have the responsibility to;
•   - Ensure confidentiality of complaints/notifications made within the framework of the Code of Ethics, and protect individuals after filing such complaints,
•   - Provide job security for the employee who filed complaints/notifications.
•   - Ensure that complaints and notifications are investigated timely and in a fair, consistent and sensitive manner; and resolutely take necessary actions against violations.

VII.  NON-COMPLIANCE WITH CODE OF ETHICS
Those who violate the Code of Business Ethics and/or company policies and procedures shall be subject to disciplinary action up to and including termination of employment. Disciplinary action shall also be applied to those approving or directing inappropriate conduct and actions violating the ethics code, as well as to those who fail to raise a concern or report a possible violation that they are aware of.
A. Ethics Board
The Ethics Board has the responsibility to investigate and resolve all complaints and notifications concerning violation of the Code of Ethics of KIRANKAYA Engineering Co. and related policies. The Ethics Board reports directly to the Chairperson of the Holding Company and is composed of the following position holders:
Chairman : Head of Internal Audit
Member   : Division Head, Responsible for Legal Affairs
Member   : Division Head, Responsible for Labor and Industrial Relations
B. Working Principles of the Ethics Board
The Ethics Board conducts its activities within the framework of the principles stated below:

• Keeps the complaints/notifications and the identity of the complainant confidential.
• Conducts the investigation with confidentiality as much as possible.
• Has the authority to request information, documents, and evidence concerning the investigation directly from the related department. May analyze all information and documents only within the subject limits of the investigation.
• The investigation process is recorded in writing. Information, evidence, and documents are added to the record.
• The record is signed by the chairman and members of the Ethics Board.
• The investigation is handled in urgency, and resolved as rapidly as possible.
• Resolutions of the Ethics Board are executed immediately.
• Relevant departments and authorities are informed of the outcome.
• While discharging their duties, the chairman and members of the Ethics Board act independently of, and without being influenced by their department superiors and the organizational hierarchy. They may not be subjected to any pressure or suggestions on the subject.
• If deemed necessary by the Ethics Board, "expert opinion" may be sought, and experts may be consulted ensuring that the necessary measures taken so as not to violate the confidentiality principles during investigation.