Anti-Bribery and Anti-Corruption Policy

Anti-Bribery and Anti-Corruption Policy:

1. Purpose and Commitment

Alıcıbul Bilgi Teknolojileri Pazarlama ve Ticaret A.Ş. ("Company") adopts the highest ethical standards in all business processes. We operate with a "zero tolerance" principle against bribery and corruption. This policy aims to comply with national and international regulations such as the Turkish Penal Code, OECD Anti-Bribery Convention, FCPA, and UK Bribery Act.

2. Scope

This policy covers Board of Directors members, all employees, suppliers, business partners, consultants, and all third parties acting on behalf of the Company.

3. Basic Rules

Bribery Prohibition: Cash, gifts, or any benefits cannot be offered, given, received, or accepted to public officials or private sector employees for the purpose of doing, not doing, expediting a job, or providing an unfair advantage.

Facilitation Payments: Small payments made to expedite official procedures (facilitation payments) are prohibited.

Political Donations: The Company does not make donations to political parties, candidates, or politically affiliated organizations.

4. Gifts and Hospitality

Gifts and hospitality given or received for the purpose of developing business relationships must be reasonable, proportionate, in good faith, and compliant with laws. Gifts that could influence decision-making processes or luxury gifts are not acceptable. All gift and hospitality expenses must be recorded transparently.

5. Relations with Third Parties

Our Company considers the anti-bribery and anti-corruption history of business partners and suppliers when selecting them (Due Diligence). Compliance of third parties acting on behalf of the Company with this policy is guaranteed through contracts.

6. Record Keeping

All financial transactions, expenses, and payments must be shown accurately, completely, and transparently in accounting records. Creating off-the-books accounts or funds is strictly prohibited.

7. Reporting and Sanctions

Employees are encouraged to report their suspicions of violations of this policy to the Ethics Line or Management without fear of retaliation. In case of violation, disciplinary penalties including termination of employment and legal processes are initiated.

8. Effectiveness

This policy is binding for all employees and came into effect on January 1, 2025.