Page 20 - Code Of Governance

v. Social Responsibility and Volunteering

1. Improvement and efforts of the employees are of high importance for the development
of NUROL and its greater achievements.
2. NUROL’s employees voluntarily participate in the activities for the development of
NUROL. One of their primary duties is to improve and renew themselves without
confining to the execution of their tasks.

3. NUROL acts to consider social benefits and interests in all its activities. It never forces
its employees for specific charity works and participation in social groups.

w. Compliance with Sanctions and Embargoes

1. All commercial activities made by Nurol shall be in compliance with the laws and
regulations of the Republic of Turkey and also sanctions and embargoes regarding the
financing of terrorism, money laundering, and anti-corruption imposed by international
organizations in which the Republic of Turkey is a party such as North Atlantic Treaty
Organization – NATO, United Nations – UN, European Union – EU, Council of Europe –
COE, Basel Committee, Financial Action Task Force – FATF and Wolfsberg Group. Nurol
shall also act in compliance with the rules of regulations of the above stated organisations
in its commercial activities.

2. Moreover, Nurol shall do its best effort in order to comply with the sanctions and
embargoes imposed by the countries who are the allies of and the countries with which
Turkey is of the friendly relations.

3. All Group companies shall be in close cooperation and coordination with the legal
departments of Nurol when and while applying this policy requirements, in particular
during selection of overseas suppliers and customers.

x. Charitable Donations

1. Corporate donations may lead to the risk of bribery. Charity donations may also appear
in various forms like bribery (monetary gifts, donations, scholars, tips etc.). Charity
donations may be misused by corrupted public servants. The most common bribery