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CODE OF CONDUCT & ETHICS FOR EFOR’S BUSINESS PARTNERS 

EFOR AKARYAKIT DAGITIM SANAYI VE TICARET ANONIM SIRKETI’s Code of Conduct & Ethics establishes the standards for how those working with and for EFOR interact with customers, colleagues, investors, business partners and regulators. We adopt internationally recognized standards to comply 
with both the letter and the spirit of the law. We expect our business partners to uphold similar levels of 
best business practices. 

• ANTI-BRIBERY & CORRUPTION We expect our business partners to comply with all local and international laws against any form of corruption, bribery, facilitation payments and extortion. While we acknowledge local customs and traditions may differ, we do not condone engaging in corrupt practices. 
Our business partners must ensure that they have appropriate Anti-Bribery & Corruption policies and procedures in place to ensure that relevant laws are complied with at all times. 

• GIFTS & ENTERTAINMENT Corporate entertainment in connection with legitimate business activities can serve to develop commercial relationships. However, we insist that any gifts and entertainment given or received by EFOR employees must be appropriate. We expect our partners to maintain the 
same high standards. Gifts and entertainment should never be used to obtain preferential treatment. 

• ANTI-MONEY LAUNDERING We do not support, facilitate or permit money laundering, terrorist financing or any other fraudulent activities. Our business partners should be similarly vigilant against schemes that attempt to conceal the proceeds of a crime within their financial transactions. 

• SANCTIONS We conduct our business in line with applicable international economic sanctions programmes. All EFOR business partners must ensure that all their operations are in compliance with applicable sanctions regulations. 

• MARKET CONDUCT All trading activities must be performed for genuine economic reasons and not to mislead or manipulate the market. We expect our business partners to abide by the rules and regulations applicable to our markets. We do not condone collusive or abusive strategies, or trading 
whilst in possession of inside information. We remind our business partners that anti-competition and market abuse regulations exist in many of the markets that we operate in and must be adhered to at all 
times. 

• CONFLICTS OF INTEREST We appreciate that conflicts of interest can arise through personal and commercial activities. EFOR employees and our business partners must proactively identify and manage potential, perceived and actual conflicts, and notify the relevant personnel within EFOR of these 
conflicts, if in relation to EFOR business. 

• HEALTH, SAFETY, ENVIRONMENT, HUMAN RIGHTS & COMMUNITIES (HSEC) We assign the highest priority to preserving the health, rights and safety of our employees, and respecting the environment and communities where we do business. Our aim is to work in harmony with our surroundings, to prevent pollution, and to provide benefit to our stakeholders. EFOR has Group HSEC expectations which define the standards that we apply. We require that our business partners adopt similar standards in accordance with local and international laws. 

• DIGNITY AND RESPECT Promoting fairness, dignity, trust and respect amongst all employees is our key commitment, as is striving towards a workplace that is free of discrimination and harassment. EFOR believes in equal opportunity and fair reward for individual contributions. We request that our business 
partners comport themselves respectably and treat all individuals, including EFOR employees, professionally. 
Any concerns related to the conduct of EFOR employees should be reported immediately to the 
Compliance Department [email protected] . EFOR maintains a strict no-retaliation policy for 
reports made in good faith.