1.PURPOSE

The purpose of this Anti-Bribery and Anti-Corruption Policy, which has been developed as an integral part of DEYAP’s ethical principles and sustainability goals, is to set forth DEYAP’s commitments to prevent bribery and corruption in all its activities in accordance with the relevant legal regulations and national and international ethical values, to provide the necessary information, to determine the responsibilities and rules in this regard and to share them with all stakeholders.

2.SCOPE

This Policy covers all DEYAP employees, including Board Members and senior executives, shareholders, subcontractor/supplier companies providing services to DEYAP, companies providing consultancy and audit services to DEYAP, and all other stakeholders with whom DEYAP has commercial and social relations, including but not limited to.

3.DEFINITIONS AND ABBREVIATIONS

DEYAP: Deniz Yapı Sanayi ve Ticaret Anonim Şirketi,

Gifts: A product that does not require a monetary payment and is usually given as a thank you or business courtesy by business contacts or customers,

Policy DEYAP Anti-Bribery and Anti-Corruption Policy,

Bribery: Cash or non-cash benefits illegally provided to a person or third parties with access/influence over that person in order to influence decisions and practices related to that person’s job, to get that person to do, not do, speed up, slow down or perform similar actions contrary to the requirements of his/her job,

Representation and hospitality: Activities carried out by DEYAP within the scope of social events, accommodation, dinner invitations, training, audits and similar activities

Corruption: The misuse of one’s authority by a person to gain unfair advantage for oneself or another person.

4.BASIC PRINCIPLES

DEYAP complies with the legal regulations and principles regarding bribery and corruption in all countries where it operates and is represented, as well as the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions, which Turkey signed on 17/12/1997.

Within the scope of this basic principle, DEYAP acts with a “zero tolerance” approach against bribery and corruption and is committed to carrying out its activities in a fair, honest, legal and ethical manner.

4.1. Gifts and Providing Benefits

All employees of DEYAP, including the members of the Board of Directors and senior executives, and their first-degree relatives (mother, father, sibling, child, spouse), customers, suppliers or other third parties cannot directly or indirectly request and accept gifts, money, checks, real estate or movable value, discounts and advantages, personal service or support, even for charitable purposes, in the form of commission or gratuity, which may affect DEYAP’s preferences and decisions. Personal gifts to be presented by the authorities that cannot be refused shall be recorded and kept in DEYAP inventory.

DEYAP may give modest promotional materials to third parties as gifts that may contribute to the promotion of DEYAP. Any gift given is offered in good faith, openly and unconditionally.

4.2. Donations and Aids

– Institutions, organizations, foundations and associations engaged in scientific research and development activities,

– Institutions and similar organizations established for social solidarity,

– For the construction of facilities of public interest such as schools, health facilities, etc. or for equipment that can be used within these facilities; and

– Cash donations and grants may be made to other causes that may be deemed beneficial by DEYAP.

Every year at the General Assembly meetings, all shareholders are informed about the donations made in the previous fiscal year. The upper limit of donations that can be made within a year is determined at the General Assembly meetings. A resolution of the Board of Directors is required for any donation to be made.

4.3. Political Activities

DEYAP, as a corporation, does not transfer liquidity directly or indirectly to the election campaigns of political candidates or other political campaigns under any circumstances. DEYAP does not make political aids and donations directly or indirectly under any circumstances.

DEYAP Board Members and all employees, including senior executives, may not carry out demonstrations, propaganda and similar activities within the boundaries of DEYAP workplaces, may not be candidates in local and general elections without resigning, may not use DEYAP’s resources (such as vehicles, computers, e-mails) and their positions in DEYAP for political activities.

All employees of DEYAP, including the members of the Board of Directors and senior executives, shareholders, subcontractor/supplier companies providing services to DEYAP, companies providing consultancy and audit services to DEYAP, and all other stakeholders and partners with whom DEYAP has commercial and social relations, including but not limited to these, may not use DEYAP’s resources directly or indirectly for political purposes and campaigns in any way.

4.4. Keeping Records

The issues that DEYAP must comply with regarding the accounting system of joint ventures and partnerships are determined as follows within the framework of the relevant legislation and regulations:

– Keeping and maintaining all kinds of accounts, invoices and documents related to relations with third parties (customers, suppliers, other service providers, etc.) in a complete, transparent, accurate, fair and reliable manner,

– Establishment of control systems to prevent unrecorded transactions,

– No alteration of accounting or similar commercial records relating to any transaction and no distortion of the facts.

In this context, it is necessary to act in accordance with the principle of due care and attention during the keeping of records.

4.5. Representation and Hospitality

DEYAP may carry out representation and hospitality activities to improve its commercial relations and to establish a commercial network. DEYAP takes care to ensure that these activities are reasonable.

DUTIES AND RESPONSIBILITIES

5.1. Board of Directors

The Board of Directors is responsible for DEYAP’s anti-bribery and anti-corruption activities at the highest level. The Board of Directors adopts the principles within the scope of this policy and provides the necessary environment for their implementation.

The Board of Directors ensures that audits are conducted and corrective measures are taken in order to ensure compliance with legal regulations and directives, processes and policies.

DEYAP Anti-Bribery and Anti-Corruption Policy has been approved by the Board of Directors.

The Board of Directors is responsible for creating, implementing and updating the Policy when necessary.

5.2. Managers and Employees

All employees, including DEYAP Board Members and senior executives, may not offer or accept bribes to any real/legal person or public institution or engage in corruption while performing their duties.

All employees are obliged to act in accordance with the rules regarding the fight against bribery and corruption and DEYAP Code of Ethics.

Senior executives ensure that the principles in this Policy are understood, implemented and upheld by the employees under their supervision; they assess potential risks and their reputational and financial impacts and take necessary measures to establish and implement control mechanisms for the management of identified risks.

It is essential that senior executives emphasize in their messages that anti-bribery and anti-corruption, transparency and integrity are part of DEYAP’s shared values.

Trainings are provided to DEYAP employees and managers to raise awareness on anti-bribery and anti-corruption.

5.3. DEYAP Anti-Bribery and Anti-Corruption Team

DEYAP Anti-Bribery and Anti-Corruption Team is a team whose objectivity and independence are trusted in order to integrate and develop DEYAP’s ethical principles with practices; it is a team formed to meet the needs of guidance, consultation, advice and to provide common knowledge.

The team consists of the Plant Manager, Accounting Officer, Customer Representative, Purchasing Officer and Quality Officer.

The team is responsible for preparing an anti-corruption program and measuring compliance with the program. The Ethics Committee convenes at least once every four months, depending on the frequency of applications and notifications. Employees can report acts of bribery and corruption within the scope of DEYAP Code of Ethics;

Our employees can communicate directly with team members within DEYAP.

The team informs the Management upon request about the issues consulted and the general operation

5.4. Supply Chain

DEYAP does not work with individuals and organizations that have negative intelligence on bribery or corruption before evaluating the organizations, dealers, business partners and suppliers with whom it will make agreements. For this purpose, DEYAP evaluates and selects the organizations, dealers, business partners and suppliers with which it will enter into agreements in a way to provide the best service to its customers, prioritizing DEYAP’s interests and in accordance with the principles of transparency and equality.

Companies that are found to be involved in bid rigging through fraud, promises, threats, use of influence, obtaining benefits, agreements, extortion, bribery or other means are included in the list of banned companies.

Members of the Board of Directors, senior executives and employees may not make personal agreements with companies with which DEYAP may enter into agreements, enter into activities that may weaken the possible advantages of DEYAP in the bargaining process, or carry out financial transactions.

POLICY VIOLATIONS AND SANCTIONS

In the event that there is an opinion or suspicion that one of DEYAP’s employees, including members of the Board of Directors and senior executives, shareholders, subcontractor/supplier companies providing services to DEYAP, companies providing consultancy and audit services to DEYAP, and all other stakeholders with whom DEYAP has commercial and social relations, including but not limited to these, act in violation of the Policy principles, the situation in question shall be communicated to the General Manager by the relevant persons. The General Manager forwards the matters communicated to him/her to DEYAP Disciplinary Board or DEYAP Anti-Bribery and Anti-Corruption Team for examination and decision.

The employee or complainant may conceal their identity for security and similar reasons.

No employee may be subjected to ill-treatment (disciplinary action, dismissal, threats, mobbing, etc.) for refusing to participate in a bribery or corruption incident or for reporting in good faith an actual or potential future bribery or corruption incident.

ANNOUNCEMENT AND EFFECT

The policy document is prepared in Turkish and is available for public access on DEYAP’s website (www.deyap.com.tr). The Policy is reviewed at regular intervals, necessary updates are made and announced on DEYAP’s website.