Sanctions and Export Controls Policy

Sanctions and Export Controls Policy:

1. Purpose

This policy aims to ensure Alıcıbul Bilgi Teknolojileri Pazarlama ve Ticaret A.Ş.'s ("Company") compliance with economic sanctions and export controls imposed by the United Nations (UN), United States (OFAC), European Union (EU), and the Republic of Turkey in its international trade activities.

2. Prohibited Countries and Persons

Our Company does not enter into direct or indirect commercial relations with countries and regions subject to comprehensive sanctions (e.g., Iran, North Korea, Syria, Cuba, Crimea Region, etc.). Additionally, doing business with persons, institutions, or organizations listed on "Prohibited Persons Lists" (SDN List, Consolidated List, etc.) is strictly prohibited.

3. Screening and Control Processes

Customer Screening: Before starting to work with a new customer or supplier, it is checked whether the relevant party and its partners are on sanctions lists.

Transaction Screening: Before cross-border payments and service deliveries, it is examined whether the transaction is connected to a country or person under sanctions.

End-User Control: Necessary commitments are obtained that our software services (SaaS) will not be used for military purposes or in the development of weapons of mass destruction.

4. Export Controls and Technology Transfer

If the software or technologies developed by our Company are subject to export control regimes (e.g., dual-use materials), their transfer abroad or making them accessible without obtaining the relevant export licenses is prohibited.

5. Contractual Protection

Contracts made with our customers and business partners include clauses committing to compliance with sanctions rules and allowing immediate termination of the contract if a party is placed on a sanctions list.

6. Violations

Violation of sanctions rules may result in the Company's access to the international financial system being cut off, heavy fines, and suspension of its commercial activities. In case of any suspicion, the transaction should be stopped and the Compliance Department should be consulted.

7. Effectiveness

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