CODE OF ETHICS

The 'Code of Ethics' of Sinpaş Gayrimenkul Yatırım Ortaklığı A.Ş., which all executives and employees are obligated to observe, has been defined with the purpose of enhancing the Company's institutional value and creating financial value for its shareholders.

The Board of Directors, executives, and all employees are expected to comply with these rules. The objective of these rules is to ensure that our employees are aware of the institutional impact of their behaviors and conduct, and to create a transparent, honest, and reliable communication environment in all decision-making and business management processes related to the Company, in pursuit of the ultimate goals set, and in managing relationships with shareholders as a publicly listed company.

SHAREHOLDERS

• - The fundamental purpose of Sinpaş GYO is to manage and enhance shareholders' investments in the most effective manner by generating added value.
• - Every shareholder is treated with equal respect, regardless of the number of shares held.
• - Shareholders are guided and informed in compliance with the relevant legislation published by the Capital Markets Board.
• - An environment that enables shareholders to communicate easily through various communication channels is maintained.

OPERATIONAL STANDARDS

• - It is essential that Company operations are conducted within the framework of the principles of transparency, honesty, and accuracy.
• - It is essential to comply with all legal rules and restrictions related to Company operations.
• - The rights and freedoms of individuals, institutions, and organizations with which the Company interacts through its employees and operations are respected.

EMPLOYEES

• - Employees must act in compliance with laws, regulations, and internal company rules.
• - Employees' legal rights are protected in full. All employment rights of every employee are provided accurately and in a timely manner. A safe and healthy working environment is ensured.
• - Employees are treated fairly; equal opportunities are offered under equal conditions.
• - No employee shall be subjected to discrimination, exclusion, intimidation, or any form of psychological harassment, nor shall they subject others to such conduct.
• - No employee shall engage in or be subjected to sexual, social, or physical harassment.
• - Employees are expected to embrace and uphold the name and reputation of Sinpaş GYO.
• - Employees are required to work harmoniously with colleagues and managers, maintain good and humane relationships with private and official persons and organizations related to the workplace, and carry out their duties honestly and promptly. Should an employee identify any breach of business ethics principles, this must be reported to management with supporting documentation.
• - Employees are obligated to protect the interests of the Company's operations and workplace and to refrain from any conduct that could harm such interests. In this regard, employees may not use Company resources for personal gain, may not engage in any unlawful conduct, and are obligated to report to management any offers from which they would personally benefit.
• - Employees may not accept official or private, permanent or temporary, paid or unpaid positions, or engage in trade without prior authorization from the Company.
• - Employees are required to keep confidential any information and trade secrets relating to the Company's operations and the organization, regardless of whether such information is directly related to their role. Confidential information, documents, or secrets may not be disclosed to unauthorized individuals or authorities. This obligation continues even after the employee's relationship with the Company ends.
• - Employees are obligated to promptly notify and submit to the Human Resources Department any changes in family, marital, or address status, as well as personal, family, or related party information and supporting documents relevant to rights and obligations set out in contracts and regulations.
• - The personal data of employees and job applicants is kept confidential and protected.
• - Every employee's suggestions for the development of the organization and processes are regarded as an opportunity and forwarded to the relevant unit manager.

GIFTS

• - Gifts that could exceed the intended purpose of gift-giving (those that could cast doubt on the recipient's impartiality or that have high monetary value) and that could place the parties in a difficult position may not be given to companies/employees with whom the Company has dealings, and such gifts may not be accepted by employees.

CUSTOMERS – COMPETITORS – SUPPLIERS

• - It is essential that relationships with customers and suppliers are conducted on a professional basis that is long-term, trust-based, and yielding outcomes in the Company's favor.
• - Care is taken to develop cooperation with partners who embrace Sinpaş GYO's ethical values.
• - No goods or services that would harm or mislead customers shall be offered.
• - No contact or agreement shall be made with competing firms for the purpose of boycotting customers or suppliers.
• - The Company considers it its duty to operate in accordance with fair competition principles within its field of activity, and expects other companies operating in the sector to demonstrate the same sensitivity.
• - No negative statements naming competitors or their executives shall be made in the press.
• - No contact or agreement shall be made with competing firms on matters such as blocking new competitors, fixing prices, or sharing territories, markets, or customers.
• - Unethical or unlawful methods shall not be used to access information about other companies; employees are prevented from resorting to such methods. However, there is no objection to the use of information that has entered the public domain (websites, price lists, advertisements, published articles, etc.).
• - The information (commercial, personal, etc.) of suppliers and customers is kept confidential and protected.

PUBLIC DISCLOSURE

• - No employee, other than those assigned to the relevant departments, may make verbal or written statements on behalf of the Company.
• - The disclosure tools specified in the Company's Disclosure Policy are used in a manner that ensures shareholders and stakeholders can benefit from them to the maximum extent and most easily.
• - On matters the Company is obligated to disclose to the public, and in providing information required by shareholders and stakeholders, access to such information shall be ensured in an accessible and equal manner, and it shall be kept up to date.

BOARD OF DIRECTORS

• - Board Members shall not yield to pressure that could have adverse consequences for shareholders, shall not accept material benefits, and shall not conceal any irregularity.
• - Board Members shall not disclose to the public any confidential or commercially sensitive information relating to the Company.

SOCIAL RESPONSIBILITY

• - Sinpaş GYO acts with social responsibility awareness while operating in its sector.
• - Sinpaş GYO supports its employees to voluntarily participate in social and community activities in order to foster social responsibility consciousness.
• - Sinpaş GYO takes utmost care to protect the environment both in its own operations and in the work of its business partners.
• - Sinpaş GYO uses natural and energy resources efficiently and prevents their waste.

COMPLIANCE WITH THE RULES

• Without exception, all Sinpaş GYO employees shall endeavor to fully implement these principles. In addition, employees are obligated to immediately notify management if any element contrary to the Code of Ethics is identified. Any loss of business resulting from compliance with these rules shall not be regarded as a negative outcome.


• The Code of Ethics is defined, updated, and amended by the Corporate Governance Committee, and is submitted to the General Assembly for information following Board of Directors approval, and is published on the Company's website and in the annual activity report.

Contact:

Phone: +90 212 310 54 84
E-mail: etikhatti@sinpasgyo.com.tr