Competition Law Compliance Policy

Competition Law Compliance Policy:

1. Purpose

This policy commits Alıcıbul Bilgi Teknolojileri Pazarlama ve Ticaret A.Ş. ("Company") to full compliance with Law No. 4054 on the Protection of Competition and international competition regulations in all its activities. Our aim is to maintain a free and fair competitive environment and to avoid any behavior that violates competition.

2. Prohibited Behaviors

Company employees and managers are strictly prohibited from making agreements or engaging in coordinated actions with competitors, directly or indirectly, on the following matters:

Price Fixing: Determining service prices, discount rates, or profit margins with competitors.

Market/Customer Sharing: Sharing specific regions or customer groups with competitors (e.g., "Region X is yours, Region Y is mine").

Supply Restriction: Attempting to influence prices by artificially restricting service supply.

Information Exchange: Sharing sensitive information with competitors regarding future prices, strategies, or trade secrets.

3. Relations with Competitors

When meeting with competitors in environments such as industry association meetings or trade fairs, topics that could violate competition (price, cost, customer information, etc.) should not be discussed. If such a topic is raised, the employee must immediately leave the environment and report the situation to the Legal Department.

4. Abuse of Dominant Position

Even if our Company holds a dominant position in the market where it operates (or may become dominant in the future), it does not use this power to prevent competitors from entering the market or to push them out of the market. Actions such as predatory pricing, discrimination, or refusal to supply are prohibited.

5. Reporting Violations and Sanctions

Violation of competition law rules may result in severe administrative fines and loss of reputation for the Company; and termination of employment and criminal liability for employees. Any suspicious situation or violation must be immediately reported to Company Management or the Compliance Officer.

6. Effectiveness

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