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NUROL HOLDING INC. CODE OF GOVERNANCEDocument Code : NH-YS-YK-02Publication No : 03Publication Date : 03.03.2025Page No : 4/18Article 1 %u2013 Aim and Scope: (1) Ethics, in the simplest term, examines the standards of judgments which are widely and universally accepted in human relations. On the other hand, business ethics is the unity of principles that are developed for the purpose of guidance to behaviors in business world. Compliance is defined as the process of ensuring that companies and their employees comply with all laws, regulations, standards and ethical practices applicable to their organizations and the sectors in which they operate. Corporate compliance encompasses internal policies and procedures, as well as local and international laws, regulations and treaties. Compliance enforcement helps companies to detect/determine and prevent violations of these, thusprotect themselves against fines and litigations.(2) This Code of Governance hereby prepared for Nurol Holding Inc. and itsGroup Companies (hereinafter collectively referred to as %u201cNUROL%u201d) is composed of our ideas and behaviors which are the basis of all of our business relations and processesas well as our standards which are settled in this regard. These codes/rules also describe policies which determine risk management, working principles, ethic rules for behaviors and internal controls which are to be obeyed in all areas of operation. This document, together with the Policies and Codes of Practice, constitutes the Code of Governance and is of high importance in terms of determining working procedures of everyone. (3) This Code of Governance, which covers all employees of Nurol Holding Inc.and its Group Companies, as well as third parties acting on their behalf, and forms our joint working procedures and principles, constitutes the %u201cNurol Codes of Ethics and Compliance%u201d; it is a guide for employees in all our activities, business and transactions.Article 2 %u2013 General Principles: Code of Governance is composed of two sections:a) Codes of Ethics (Codes of ethics and working principles are composed of 5 fundamentals of ethics).b) Policies and Codes of Practice (policies which determine working principles).Article 3%u2013 Codes of Ethics: (1) These rules determine working principles and procedures which are required to be obeyed by each employee regardless of their titles and positions. (2) These rules are valid for everyone who works in NUROL. All the employees, regardless of their positions, are required to obey codes of ethics in their relations with other employees, customers, suppliers, contractors, shareholders and competitors.(3) Acting in accordance with the code of ethics is a very important element of working in NUROL and is of great and special importance in protecting NUROL's reputation and success.(4) We adopt our codes of ethics as a guide in all our activities and exhibit them at a level that can set a positive example for our society. We carefully avoid behaviors which may negatively affect this understanding and our identity. Ethics and behaviors