Page 18 - Code Of Governance

q. Lobbying Activities, Political Support and Political Donation

1. Lobbying activity is a legal activity which aims at developing NUROL’s competitive
position in order to make decisions which commercially affect NUROL and help the
decision makers in this regard by making a political connection or making a connection
with another shareholder.

2. Political support is all kind of support and assistance which is given to a political
party, an affiliate of a political party or a representitive of a candidate for a government
organization in order to strengthen their positions.

3. Political donation is the payment (or procurement of good and service) which is made to
such kind of organizations or people for providing political support. NUROL is prohibited
from making such a policital donation in accordance with the legislation; so it shall not
provide political donation in Turkey.

4. Lobbying activities and political support carried out on behalf of NUROL must be
within the framework of honesty and accuracy. Interests represented by NUROL must be
declared transparently and must be consistent with the legislation in force and NUROL’s
codes of ethics.

5. NUROL can provide political support only if it is allowed by the legislation and provided
that Holding’s Board of Directors give a written consent.

6. This policy must jointly be evaluated with the policies of Advisors, Representation and
Entertainment and Anti-Corruption and Bribe.

7. These provisions of prohibition and consent are only related with the use of NUROL’s
funds. It doesn’t have the purpose of deterring the employees from making legal and
personal contributions to their political parties or candidates. However; employees are
not allowed to use NUROL’s funds for this kind of personal contributions or any other
expenditures.

r. Sponsorship

1. NUROL shall consistently apply financial or non-financial support provided to another
organization as goods and services with regard to sponsorship and make sure that it is
in compliance with business targets, codes of ethics and other corporate liabilities in
accordance with the relevant legislation.