Disclosure Policy

a- Existing Investors
b- Potential Investors
c- Beneficiaries
d- Regulatory Institutions
e- The public

Means to Information:
The information policy is implemented through the means below.

• Web sites
• Annual report
• Meetings with investors
• Special Situation Announcement Form (SSAF)
• Media and press announcements
• Trade Register Gazette, other newspapers
• News channels (Reuters, AP, Bloomberg, Foreks etc.)
• Communication means like electronic mail etc.
• Telephone, Fax etc.

Responsibility:
The following individual/individuals will be responsible for giving information are the following:

—The Board of Directors
—The Committee of Monitoring
—The Committee of Corporate Governance
—General Manager
—Director of Finance

Issues to be disclosed:
The following issues will be disclosed:

• Annual reports, financial charts and their footnotes, independent auditing report and profit distribution policy are communicated to investors, the public, beneficiaries and regulatory institutions through the internet site and other distribution channels
• Meetings, road shows and analysis meetings are organized for the creditors, analysts and shareholders in order to inform investors. The members of the Board of Directors, the general manager, the director of finance, the Investor Relations Unit and auditors attend these meetings. These meetings are organized at least once a year and following the disclosure of financial charts twice.
• Any information about the general meeting are made available to the public from the company headquarters’ branches and announced to the public through the internet no later than 3 weeks before the general meeting.
• Financial charts and the independent auditing report are announced to the public quarterly.
• In case of occurrence of special situations specified by SPK Serial:VIII, No:54 “Notice of Guidelines for the Disclosure of Special Situations to the Public”, disclosure of special conditions related to this are sent to the SSCF.
• Meetings of the members of the Board of Directors with the press are planned and organized by the Investor Relations Unit. In case of matters that might affect the share value of the Company, meetings with the press are organized provided that the members of the Board of Directors have agreed upon jointly and the Investor Relations Unit has been informed of them.
• Regarding the insiders, an “insider trading” policy is formed for the members of the Board of Directors, directors and employees.

The obligations for security and protection of trade secrets of the company in line with this policy are the following:

- Avoidance from disclosing information involving trade secrets to unauthorized people
- Avoidance from purchase and sale of goods or making recommendations to any people outside the company about purchase and sale while holding such information
- Avoidance from discussions involving such information by chatting on internet sites
- Avoidance from any behaviours that might benefit personally or any people outside the company in line with such information

After the “policy of insider trading” has been developed inside the company, changing conditions are monitored and reviewed periodically and are updated.

• In its statement about whether it implements the Corporate Governance Principles published by the Capital Markets Board, the company mentions what issues it has not been able to implement together with their rationale in its annual reports and internet site.
• The profit distribution policy developed by the Board of Directors of the Company is disclosed to the public. This policy is submitted to shareholders at the general meeting and mentioned in the annual report.
• Except for disclosing special situations, if there are any pending, finalized or continuing lawsuits and penalties against the company, it informs the public of to what extent, at what rate and by which authorized body/bodies such disclosure will be made.

People Authorized to Disclose Information:
The people authorized to disclose the information except for the above mentioned publicized information are replied in writing or orally by the Group Chairman, the Chairman and Members of the Board of Directors, the General Manager, the Director of Finance or the Shareholder Relations Unit according to the level of information request. Employees other than these people are not authorized to reply to requests for information.

In order to prevent inequality in disclosure any disclosure to the public are made exclusively and simultaneously.

Web Sites:
The Company uses the web site efficiently for enlightening the public. The information requested by Part 2, 1.11.5 of the Notice of Capital Markets Board Corporate Governance Principles to be on the company’s web site are given on the web site of the company and updated regularly.

Disclosure on the web site of the company does not substitute statements and disclosure of special situations requested by the Capital Markets Legislation.

The company discloses information to the public in Turkish and/or English through its web site.

Ban on Disclosure:
In order to prevent incorrect or unauthorized disclosure, the company avoids from disclosing information that has not been announced to the public until financial charts and footnotes are published quarterly as of the 15th of the month following the end of the accounting period. It is not allowed to give an opinion and discuss about non-disclosed financial information of the company and to reply to questions about this as required by the principle of confidentiality.