AML/CFT Policy | Corporate Compliance

1. Anti-Money Laundering and Counter Financing of Terrorism (AML/CFT) Policy

1. Purpose

This policy has been established to prevent Alıcıbul Bilgi Teknolojileri Pazarlama ve Ticaret A.Ş. ("Company") from being used for money laundering and terrorist financing activities. Our Company fully complies with Law No. 5549, MASAK regulations, and international AML standards.

2. Know Your Customer (KYC) Principle

Our Company verifies the identity of its customers and business partners before establishing a business relationship.

Identity Verification: Trade registry records, signature circulars, and Ultimate Beneficial Owner (UBO) information are requested for corporate customers.

Risk Assessment: Customers are subject to risk assessment based on the sector they operate in, geographical location, and transaction volume. "Enhanced Due Diligence" is applied for high-risk customers (e.g., those from high-risk countries).

3. Monitoring and Reporting of Suspicious Transactions

The following situations may be considered suspicious transactions and are carefully examined:

• Transactions inconsistent with commercial activity, unusually large or complex transactions.

• Fund transfers of unclear origin or payments from third parties.

• Customers who avoid providing identity information or provide inconsistent information.

• Transactions related to persons or institutions on sanctions lists.

When a suspicious situation is detected, notification is made to MASAK or relevant local authorities within the framework of legal obligations.

4. Payment and Collection Rules

Our Company, in principle, does not accept cash payments. All payments are made through the banking system in a traceable and transparent manner. It is essential that the sender's name matches the invoiced customer's name.

5. Training and Awareness

Company employees are regularly trained on money laundering methods, legal obligations, and suspicious transaction detection.

6. Sanctions

Non-compliance with this policy may result in severe criminal and administrative sanctions for the Company and its employees, in addition to internal disciplinary penalties.

7. Effectiveness

This policy applies to all Company operations and business relationships. It came into effect on January 1, 2025.