AIM

This Guidelines contains the constitutive values, codes of conduct and work principles to be implemented at YAPIRAY.

SCOPE

YAPIRAY values, codes of conduct and work principles are in force of policies, which should be complied by all our Employees including directors at any level.

IMPLEMENTATION

1. OUR VALUES

YAPIRAY has been founded "to design, manufacture and construct contemporary structure projects, which shall serve humanity by creating an environment of happiness".

YAPIRAY ‘targets beauty, likes projects being open to innovation and creativity and works from which good outcomes to be derived' on basis of "Science and Esthetics in the Structure".

We believe that one work may reach to good results only through good implementation of productive ideas.

We know that a project may only be as fine as its design and as productive as its work plans.

Human dignity should be observed and reflected to work at any work we do.

No compromise on the quality is made at YAPIRAY.

Every effort of YAPIRAY is towards a higher civilisation and creating happiness in human life.

"We become happy by creating happiness." is our principal idea and motto.

2. OUR CODES OF CONDUCT (ETHICAL PRINCIPLES)

Our Company's management approach and policy to add value to our customers and society through principles of social responsibility, honesty and reliability.

Therefore, YAPIRAY agreed keeping its promises, deciding based on information and continous development as its codes of conduct.

YAPIRAY is a group of companies, endeavouring to complete each project on time, being open, transparent, innovative and pioneering at the sectors where it operates.

We are liable to ensure that the service we have been rendering and production we have been offering to be quality and in compliance with contract requirements.

We favour development of Turkey and world civilisation and customer satisfaction in all our works.

We act respectfully and sensitively to the history, traditions, customs and laws of the countries for which we render services.

We prepare a healthy and secure working environment for our employees and respect their personalities and rights and support their development.

We, as YAPIRAY, work by showing adherence to 10 fundemental principles presented below, which forms the very core of United Nations Global Compact Principles ("Global Compact"):

1. We ensure our companies not to violate human rights. We stipulate our corporate policy and procedures towards this aim.
2. We respect human rights protection in our area of effect. We support these rights and encourage others to support the same.
3. We embrace freedom of association, collective bargaining and collective bargaining agreement. We provide labour environment where such rights can be used.
4. We do not allow compulsory labour. We prevent forced labour.
5. We do not allow child labour and take measures to prevent the same.
6. We do not make discrimination during recruitment and job assignments. We make our decisions according to objective measures and assessments.
7. We effectively implement Versatile Sustainability policies in all our management, production and service processes. We support approaches being preventive and protective which do not harm the environment.
8. We share environmental responsibility. We encourage the formations and attempts to spread the same.
9. We join and support the development and diffusion of environmentally friendly technologies.
10. We stand against all unethical actions and corruption. We work without allowing the same.

3. OUR RULES OF WORK

YAPIRAY employees, including Directors at any level:

1. Perform all works within their areas of duty in compliance with the provisions of legislation in force and stipulations and principles provided in this Guidelines;
2. Comply all provisions of the legislation and rules being determined by the Company on environment, labour health and safety; work by taking any measures not to jeopardise environment, labour health and safety. Never keep and take alcohol, narcotic and stimulant drugs at our workplaces, offices and work sites; the persons who have taken alcohol, narcotic and stimulant drugs, may not enter these areas;
3. Never use the name of YAPIRAY, their current assignments in the Company and resources and facilities of the Company to provide personal interest. Always work by avoiding any action, relation and situation, which may be held as conflict of interest;
4. Never accept and give any gain and gifts being offered directly or indirectly holding high economic or intangible value, which may affect the neutrality, performance, decisions or work of persons or corporations;
5. Ensure protection of any financial and trade secrets of YAPIRAY, its clients, business partners and third parties, who are related with YAPIRAY by acting with the awareness that the aforementioned is under the frame of "Confidentiality". They never share those information and documents with unauthorised persons and parties within and out of the Company within and after their employment for any reason whatsoever. They pay diligence to the protection of Personal Data.
6. Establish positive and good relations with the employees, clients, business partners or third parties with which they associate in relation with their duties. Never perform actions against clients, business partners, suppliers and colleagues, superiors or inferiors, which are not kind and dignified, which are harassing, deterrent and humiliating and never use disrespectful expressions in communication and correspondences;
7. Never take part and perform actions including publicity activities in any political, religious and commercial organisation other than the Company except the associations, foundations and organisations to which our Company is a member of, by using the names and facilities of our Companies and YAPIRAY;
8. Our directors act just and without prejudice to their inferiors; pay attention that the recruited persons to hold the loyalty and ability appropriate for the requirement of business. Race, colour, gender, religion, political opinion and belief discrimination amongst our employees does not exist and is not allowed.

4. SUPERVISION OF OUR VALUES, CODES OF CONDUCT AND RULES OF WORK

All our Employees and Directors are liable to embrace, have had embraced, implement and supervise the implementation of YAPIRAY values, codes of conduct and rules of work.

To supervise and ensure duly implementation of our Codes of Conduct is the duty of all of our Directors. Disciplinary Board works as Ethics Committee while investigating violations of our Codes of Conduct.

It is obligatory for the Employees and Directors, who have information on the violation of our Codes of Conduct and Rules of Work immediately to inform their directors or Disciplinary Board members collectively or individually through letter of e-mail.

All notifications are transmitted to Disciplinary Board by the notified Director without delay. The Disciplinary Board performs necessary investigation within reasonable period and rapidly by asking additional information and documents when required.

Our Employees and Directors assist this investigation to be performed by the Disciplinary Board by giving any information and support to be asked by the Disciplinary Board, in an accurate manner.

Principal policy and approach of YAPIRAY regarding violation notifications is the fact that every Employee should be able to notify violations without fear of retaliation and reaction, except intentional unreal accusations.

The persons who are subject to investigation or disciplinary sanction are warned regarding not to retaliate and react against the persons who have reported or notified and supported investigation.

The Disciplinary Board shares the investigation conclusion report with the Board of Directors in a manner to include disciplinary implementation recommendation deemed necessary after completing the investigation on violation. The Board of Directors decides on disciplinary sanction for violation. The Human Resources Department executes the decision.

RESPONSIBILITIES

Management Responsibility

This Guidelines has come into force after being approved by the Board of Directors.

Corporate Governance Coordinator acts by assuming the role of "Ethics & Compliance Officer". Guidelines policy and content are reviewed in December each year by the Corporate Governance Department and submitted to the approval of Holding Company's Board of Directors if there are amendments.

Chairmen of Boards of Directors and General Managers of Group Companies are responsible from the execution of this policy at first degree and collectively.

Our Boards of Directors, General Managers and Directors act as role models for all our Employees to embrace and implement the values, principles and rules provided in this Guidelines; supervise our sub-contractors, suppliers and business partners to comply with our Codes of Conduct and spread codes of conduct in works we perform.

The Company General Managers and Directors are responsible against related company's Board of Directors from the compliance of both YAPIRAY activities and our Employees' attitudes and actions with the legislation, regulations and standards at all times; from the performance of risk assessments and audits, taking necessary preventive and corrective measures and actions regarding this matter.

Responsibility of Employees

The policies and principles provided in this Guidelines binds and are embraced by all Employees.

Human Resources

Our Human Resources Department and Directors ensure strengthening awareness and internalisation within the organisation in respect of our values, codes of conduct, rules of work, policies and regulations during and after orientation of new recruits with awareness trainings to be given and meetings to be held in circumstances and at times deemed necessary.

Audits

The auditing whether the regulations provided in this Guideline are complied with, are also included to Internal Audit activities.

Control Documents:

• Internal Auditing Findings, Reports
• Independent Auditor Reports
• Labour Dispute Lawsuit Files and Court or Arbitrator Orders
• Inspection, Audit Reports of Governmental Agencies
• Resolutions of the Board of Directors