Setur Ethical Principles

1. Our Core Values

As Setur, we take the goals and principles of our Founder Vehbi Koç as a basis and fulfill our duties in the light of these principles. In addition to the Setur Code of Ethics, we adopt the Koç Group Code of Ethics.
Integrity, honesty, responsibility, trust and respect are our core values that guide us in our decisions and actions. As Setur employees and management, we exhibit attitudes and behaviors that will ensure cultural integrity within the framework of these values.

2. Our Ethical Principles - Why and For Whom?

Setur Code of Ethics has been created to guide Setur managers, employees and our Business Partners (suppliers, agents, dealers, contractors, consultants, all kinds of representatives acting on behalf and account of the company, etc.). All Setur employees are required to comply with the Setur Code of Ethics and the Koç Group Code of Ethics, which is the source of these principles, as well as the legal regulations of the countries in which we operate or have a business relationship. Setur also takes necessary measures to ensure that its Business Partners comply with the Setur Code of Ethics and related policies to the extent relevant.
While compliance with the Setur Code of Ethics is the duty of all Setur employees, Setur senior management is the leader of this issue.
Our Code of Ethics is based on the following three operational pillars of the Compliance Program:

• Prevention - We aim to embed and promote a culture of honest work at all levels in all countries where we have operations.
• Identify - We encourage our people to report non-conformities and be a voice for our values.
• Response - We report violations, investigate them in a proper and fair manner, impose relevant sanctions when necessary, and work to continuously develop and improve our own system.

In cases that are not explicitly included in the Setur Code of Ethics or policies, Koç Group Code of Ethics or policies, we act in accordance with the spirit of our Code of Ethics and in compliance with fundamental ethical values. When in doubt about anything, we consult Setur Legal and Compliance Consultancy.

3. Our Principles and Policies

3.1 Respect for Human Rights

As Setur, we aim to be the ideal organization that will ensure sustainable growth, create added value, consist of the most successful and competent professionals, and that everyone is proud to be a part of.
We embrace the United Nations Declaration of Human Rights and aim to ensure that our Code of Ethics and related policies are in line with these principles.
We take great care to treat all our employees equally and fairly, and we expect the same attitude from all our stakeholders.

• In our communication with all our stakeholders, we use a style that is compatible with our values and befits our corporate identity.
• In recruitment, we look for qualifications that are suitable for the job as the sole criterion, regardless of gender, language, religion, race, color, age, nationality, difference of opinion and assets.
• We reward success through fair and competitive wage policies, effective and objective performance evaluation systems and practices.
• We aim to increase the loyalty of our employees to the company by providing equal opportunities in appointments, promotions, rotations and rewards.
• We provide equal opportunities for the training, guidance and development of our employees.
• We create a transparent and mutually respectful working environment where cooperation and solidarity are paramount.
• We do not tolerate any form of discrimination.
• We provide our employees with clean, healthy and safe working conditions.
• We respect the unionization and collective bargaining rights of our employees.
• We do not tolerate any form of violence and harassment.
• We do not tolerate child labor, slavery, human trafficking and forced labor.
• We use company resources responsibly.

3.2 Compliance with the Law in All Circumstances

In every country where we do business, we act in accordance with the law and, where the law is unclear, we act in accordance with our Code of Ethics and, where necessary, in consultation with the competent authorities.
As Setur, we consider intellectual and industrial property rights as an important tool to achieve sustainable competitive advantage and the best business results. In this context, our basic principles in this area are to protect our distinctive innovations and strong brands in the markets where we do business, to create value from our portfolio, to be open to collaborations in this context and to respect the intellectual and industrial property rights of third parties.
We act in accordance with legal regulations in the processing of personal data and take necessary measures. In this context, as Setur, we act in accordance with the local and international legislation to which we are subject and the principles determined in the processing of personal data under all circumstances.
We record all our commercial activities and records in a complete and clear manner in accordance with the applicable legislation, and ensure that agreements with third parties are clear and understandable in accordance with the legislation, our Code of Ethics and policies.
We provide our employees with the necessary training, but we expect them to know in which cases they should seek support from their managers or the Legal and Compliance Consultancy.
We know that failure to act in accordance with the law will affect not only the relevant employee, department or Setur, but the entire Koç Group. We know that in addition to local legislation, Setur may be required to comply with international regulations within the scope of its contractual obligations. We act with the awareness that our non-compliant actions may have many sanctions, including administrative fines, and that individuals may be held personally liable.

3.3 Combating Bribery and Corruption

As Setur, we conduct every business and every decision we make in accordance with the highest ethical standards. In accordance with the United Nations Global Compact signed by Koç Holding A.Ş., we resolutely take the necessary measures to combat corruption and bribery.
In line with our Code of Ethics and related policies, it is strictly prohibited to provide an interest to domestic or foreign government officials and other third parties, regardless of whether they are public officials or not, in order to obtain an illegitimate benefit. This prohibition also includes providing, offering, promising or accepting anything of value to or from any third party directly or indirectly related to Setur's business activities in order to influence their decisions.
All of our employees are obliged to comply with local and relevant international anti-bribery and anti-corruption legislation and relevant Setur policies, and we expect all our Business Partners to act in accordance with the relevant regulations.

Gifts and Hospitality

• Our gift and hospitality practices within Setur must comply with the following rules:
• It must comply with the legislation.
• It must be done with courtesy.
• It should be within the limits set out in policies and procedures, within reasonable amounts and should be a rare practice.
• Must not be in cash or similar (e.g. coupons).
• Our books and records must be open and transparent.
• It must be done in accordance with accepted commercial practices.
• It should not affect the decision-making process in any of our business relationships.
• It must be of a nature that will not harm the reputation of Setur and the Group if it becomes publicly known.

3.4 Preventing Conflicts of Interest

As Setur employees, in the decisions we make according to our roles and responsibilities, we take care not to be in any situation that may prevent us from being impartial, that may benefit ourselves or our relatives, or that may give the impression of such a conflict, or that may conflict or give the impression of a conflict between our personal interests and our individual business interests and the interests of Setur or Setur's Business Partner and our responsibilities towards Setur.
In the event that we are in a situation that may be considered a conflict of interest, we share the matter with our managers and/or Setur Legal and Compliance Consultancy without delay to avoid any damage that this situation may cause to us and our company.
To avoid conflict of interest situations:

• We refrain from abusing our titles or authorities to obtain benefits for ourselves or our relatives.
• We take due care to ensure that our personal investments outside of work do not prevent us from devoting the time and attention necessary to fulfill our current duties at Setur and do not create a conflict of interest.
• Even outside of working hours, we do not work and/or enter into a partnership relationship that may be contrary to our loyalty obligation to Setur and/or that may negatively affect our individual performance.
• In the event that our Business Partners have a kinship or other relationship with the persons in the primary decision-making position in their commercial activities related to Setur, we inform our manager and the Legal and Compliance Consultancy about the matter.

3.5 Prevention of Money Laundering, Terrorism and Financing of Weapons of Mass Destruction

The process of integrating the proceeds of illegitimate means into the financial system in order to make it appear as if they were earned through legitimate means is called laundering of proceeds of crime.
As Setur, in compliance with local and international legislation, we avoid all kinds of commercial transactions that may be seen as laundering proceeds of crime, financing terrorism or proliferation of weapons of mass destruction, and therefore, we conduct Due Diligence to get to know the relevant party before entering into a business relationship with third parties. As Setur, we do not enter into business relations with third parties about whom we do not have sufficient information or about whom there is negative intelligence, or who pose a risk or create suspicion for these and similar reasons.

3.6 Compliance with Economic Sanctions and Export Controls

As a globally operating Group, we take effective and necessary measures to comply with regulations on economic sanctions and export controls.
In this context, we do not establish commercial relations with persons on embargo and sanctions lists, and if it is necessary to establish direct or indirect contact, we always obtain approval from the Legal and Compliance Consultancy before contact is established.

3.7 Confidentiality and Protection of Information

We know that it is prohibited to use or share personal, commercial, financial, technical, legal and/or similar confidential information belonging to our Company, Koç Group, our employees or our Business Partners for the benefit of ourselves or third parties, and we take the necessary measures to protect confidential information that we are aware of due to our roles and responsibilities.
We use the information we obtain only for the work we are obliged to do as per our job description. We act in accordance with the relevant legislation and our contractual obligations in sharing trade secrets and other confidential information.
We protect the confidential information we obtain even if we leave Setur and do not share it with third parties.

3.8 Donations, Sponsorship and Community Investments

We make donations to support social development in the geographies where we operate and sponsor events that are in line with our principles. We carry out donation and sponsorship processes in a transparent manner and take care to ensure that these activities do not conflict with the values or commercial interests of Setur and Koç Group.
We do not donate or sponsor any activity that violates human and animal rights, promotes tobacco, alcohol and drugs, or harms nature. We do not donate to or sponsor activities of organizations that discriminate on the basis of gender, language, religion, race, color, age, nationality and difference of opinion.

Social Investments

We invest in environmental and social issues by developing long-term collaborations in line with the needs of the geography in which we operate. We care that our social investments are in line with our business priorities and are realized in cooperation with institutions or individuals who are experts in the field.

Political Activity

We do not donate to political parties, politicians or political candidates. On the other hand, we respect and do not limit our employees' voluntary participation in legal political activities. Setur resources (vehicles, computers, e-mails, etc.) cannot be used for political activities or personal donations for this purpose. Demonstrations, propaganda and similar activities for political purposes are not allowed within Setur work areas.

3.9 Compliance with Competition Law

As Setur, we act within the framework of legal regulations and our company policies in all countries where we operate, in a manner befitting our reputation. We do not take part in any practice that would be contrary to the rules of competition law.
Our basic principles under competition law are as follows:

• To be compliant with the regulations related to competition law.
• Except for the limits permitted by the legislation, not to engage in agreements and behaviors with competitors or other persons or organizations, directly or indirectly, that have the purpose of preventing, distorting or restricting competition or that have or may have this effect.
• Obtaining information on competitors only through methods stipulated by legislation and case law and using it in all relevant documents by citing the source.
• Avoiding behaviors that may be considered as abuse if we are in a dominant position in the markets in which we operate.
• Avoiding all kinds of meetings and communications that may lead to or be characterized as such in the meetings of associations, assemblies, chambers, professional unions and other private or professional meetings and meetings that bring competitors together, such as conferences and fairs, in which Setur is represented.
• Dealing with issues that may violate competition law within Setur with the same care and diligence.

3.10. Creating a Healthy and Safe Work Environment

As Setur, one of our biggest goals is to create a healthy and safe work environment for our employees and to ensure that our Business Partners such as our agencies and dealers also create such a work environment. To this end, we take every precaution and try to raise awareness in this area by providing trainings on occupational health and safety.
We carry out our activities in a healthy and safe manner without putting our employees, contractors, dealers and society at risk. To realize this, we use facilities with safe design, work with competent people and prioritize safety in our processes.
At Setur, human life is a priority and no job is too important to be performed without taking safety and health precautions. Our employees comply with all legal regulations and Setur policies regarding Occupational Health and Safety and immediately report any unsafe working conditions to our communication channels. All Setur employees immediately report any accident, injury or unhealthy situation. Identify emergency scenarios and make appropriate preparations; know what to do in case of an emergency. Do not come to work under the influence of drugs and alcohol.

3.11 Use of Social Media Accounts

As Setur, we continue to take part in social media, which has a strong growth trend in the world and in our country in recent years, in accordance with our Setur and Koç Group principles and brand values. We know that personal social media accounts are everyone's private spaces and we respect their sharing preferences.
On the other hand, we are aware of the benefits that can be derived from the proper use of social media, as well as the significant reputational risks it may bring to Setur and Koç Group. Therefore, when posting on social media, we refrain from sharing content that may lead to disagreements and uncertainties on corporate issues, as well as information and photos that may violate the privacy rules of companies. In our social media posts, we always ensure that we act in accordance with legal regulations and Koç Group and Setur Code of Ethics and related policies.

3.12 Acting Honestly and Fairly in Relations with Our Stakeholders

Stakeholders refer to all parties that are affected by Setur's activities and whose activities affect Setur, and our basic principles in our relations with our stakeholders are set out below:

• We make decisions based on objective criteria in our supplier and agency selections, and we pay attention to be in business relations with parties that attach importance to human rights, take into account the principles of anti-bribery and anti-corruption, and fulfill their legal obligations.
• We keep our communication channels with our stakeholders open and always take their complaints and suggestions into consideration.
• We always comply with confidentiality rules in our visits and audits to our stakeholders.
• We expect all our stakeholders to comply with the relevant laws and regulations at all times.
• We refrain from expressing personal opinions to the public, and when it is necessary to provide information to the public, we only make statements on behalf of Setur by authorized employees.
• We always provide honest and reliable information to the public and media. We do not make statements in press releases that contradict the ethical values of Setur and Koç Group.
• We protect the rights and interests of shareholders as determined by law.
• We make every effort to create value in return for the resources they provide, and we distribute the resulting profit to shareholders or invest it in accordance with the laws and regulations.
• We ensure that Setur is managed within the framework of the principles of trust and integrity that have been in place since the foundation of Koç Group, and we manage the resources, assets and working time of our companies with an awareness of efficiency, aiming for sustainable growth and profitability.

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