Page 21 - Code Of Governance

scenario among public servants is providing business opportunities in return for a grant.
Charity donations may also be fronted by terrorists and illegal organizations.

2. To avoid hidden bribery, the following points must be taken into consideration:

a. If there is a perception or an offer that NUROL will have derive benefit in return for a
donation, you must never donate.

b. Verify that the donation is not prohibited by local laws.

c. Organizations which receive corporate donations must be approved by Holding’s
Board of Directors in beforehand.

d. Donations must not be in cash or not be paid directly to the individuals or their bank
accounts.

e. Donations must be approved in written and recorded in NUROL’s accounts accurately.

f. Donations must publicly be declared on NUROL’s web site or annual report for
transparency.

g. Required follow-up precautions must be taken in order to make sure that donations
are used for its purpose. In this regard, NUROL may require right of auditing for the
contribution of charity donations. On – site checks can be conducted in some cases
where the donations are given for supporting a physical project.

y. Reporting Violations

1. All the employees are obliged to obey to the principles specified in this Code of
Governance. In case of a suspection of violation of these Policies or the relevant
legislation, all the employees are obliged to notify that violation to Committee of Ethics
and Discipline or Officer of Codes of Ethics and/or the relevant General Manager or the
e-mail address etik.bildirim@nurol.com.tr or NUROL’s coporate web site
(www.nurol.com.tr). Notifications can be reported anonymously.

2. NUROL has created the required mechanisms for avoiding the violation of Code
of Governance. These mechanisms are defined in the rules of procedures of Nurol’s
Committee of Ethics and Discipline.

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