Code of Business Ethics

1. PURPOSE AND SCOPE

Teknosa İç ve Dış Ticaret A.Ş. (Teknosa) Code of Business Ethics is created to serve as a guiding framework for Teknosa employees, suppliers, and all other stakeholders.

At Teknosa, we are dedicated to conducting all our activities in accordance with the Teknosa Code of Business Ethics, and we expect the same level of commitment from all our suppliers.

2. CODE OF BUSINESS ETHICS

2.1. Integrity

At Teknosa, we prioritize integrity in our business relationships. We build our relationships with our suppliers, customers, business partners, and all other stakeholders on the principles of trust, integrity, and transparency.

2.2. Privacy

At Teknosa, we safeguard the confidential and private information of our customers, employees, business partners, and other relevant individuals and organizations. We acknowledge that all financial and commercial information relevant to Teknosa, which has not been disclosed to the public, as well as information regarding store operations, strategies, any form of data, projects, software, reports, procedures, regulations, and any other information that could potentially conflict with the company's interests upon disclosure, are considered proprietary and confidential. We do not disclose these externally nor share them with third parties. We adhere to the Law on the Protection of Personal Data concerning information security and confidentiality.

2.3. Conflict of Interest

As Teknosa employees, we adhere to the principle of avoiding conflicts of interest. We refrain from seeking personal gains from individuals or organizations with whom we, our families, or close acquaintances engage in business relationships, leveraging our current positions for such advantages. We avoid using Teknosa's name and reputation for personal gain.

When we identify a potential conflict of interest, we pursue legal and ethical avenues to protect the rights of the parties involved when we believe we can do so. When faced with any doubts or uncertainties, we endeavor to resolve issues by reaching out to our managers, the Human Resources and Sustainability Department, the Ethics Advisor, or the Teknosa Ethics Violation Hotline.

2.4. Our Responsibilities

2.4.1. Our Legal Responsibilities

We fully comply with the laws and provide accurate and comprehensible information to regulatory bodies and institutions promptly.

In all our activities and processes, we maintain an impartial stance towards public institutions, administrative bodies, non-governmental organizations, and political parties, without seeking any preferential treatment. With this strong sense of responsibility, we diligently fulfill our obligations.

2.4.2. Our Responsibilities Towards Our Customers

We consider our customer-centric approach as one of our top priorities. We improve our operations in line with industry developments and the demands and expectations of our customers to gain a competitive advantage. Our aim is to be there for our customers, anytime and anywhere, focusing on delivering a 'Unique Customer Experience,' and facilitating their access to technology.

We operate with a customer satisfaction-oriented, proactive approach that swiftly and accurately addresses the needs and demands of our customers. Our services are delivered in a timely manner and under the conditions promised. We approach our customers with respect, dignity, fairness, equality, and courtesy.

2.4.3. Our Responsibilities Towards Our Employees

At Teknosa, ensuring that our employees fully and accurately exercise their labor rights is among our priorities. We provide our employees with an honest and fair approach. We are committed to fostering a non-discriminatory, safe, and healthy work environment. We respect the personal rights of our employees. We provide the necessary support for individual development while also promoting a sense of social responsibility. We encourage their voluntary participation in suitable social and community activities. Moreover, we prioritize the balance between work and personal life and assist our employees in maintaining this balance.

2.4.4. Our Responsibilities Towards Our Shareholders

Teknosa fulfills its responsibility to shareholders by maintaining financial transparency and upholding ethical corporate governance principles. Shareholders are regularly and transparently informed about the company's financial status, business performance, and future prospects. Company reports and meetings ensure that shareholders have access to accurate and current information.

Teknosa remains committed to ethical corporate governance principles. Upholding the independence of the board members and ensuring accountability strengthens the aim of safeguarding shareholders' interests. To protect shareholders' investments and create sustainable value, we effectively implement risk management processes. We avoid unmanageable risks and aim for sustainable profitability and success.

2.4.5. Our Responsibilities Towards Our Suppliers/Business Partners

At Teknosa, we embrace an ethos of integrity, fairness, and respect towards our suppliers and business partners. We aim to foster robust relationships based on integrity, transparency, and ethical values.

We respect and actively support the competitive independence of our suppliers and business partners. We believe in the importance of responsible collaboration and expect our suppliers and business partners to comply with national and international laws and regulations.

In this context, we expect our suppliers to commit to promoting and implementing our Code of Business Ethics in their practices and business environments. We aim to create a more sustainable, fair, and successful business environment through collaboration.

We meticulously safeguard the confidential information of individuals and organizations with whom we collaborate, ensuring the highest level of security for their confidential data. Placing their satisfaction at the forefront, we exert the necessary effort to fulfill our commitments promptly and diligently.

2.4.6. Our Responsibilities Towards Our Competitors

We support fair and independent competition in all our processes and adhere to the law on competition. We avoid unfair competition practices and strive to contribute to maintaining the desired competitive structure within society. We provide Compliance Training on Competition Rules regularly to all our employees.

2.4.7. Our Responsibilities Towards the Environment and Society

At Teknosa, we merge our passion for technology with our environmental responsibilities. We carry out all our activities with a commitment to conserving the environment.

We are committed to reducing energy consumption and carbon emissions, ensuring effective waste management, preventing environmental pollution, and sustaining awareness initiatives across all our processes and operations. Moreover, we support environmental sustainability by increasing the use of renewable energy sources and the efficient utilization of water resources.

We are making our customers a part of sustainable action by offering them high-energy class, energy-efficient, and recyclable products.

Beyond environmental awareness, we also fulfill our social responsibilities and actively participate in social projects. It is among our priorities to understand the needs of our society and generate solutions that align with these needs. Therefore, we support initiatives aimed at meeting the needs of the community by participating in activities in education, healthcare, environmental protection, and other relevant domains. We strive to contribute to civil society organizations and actively participate in suitable activities that meet the needs of the community.

2.4.8. Our Responsibilities Towards the Names “Teknosa” and “Sabancı”

At Teknosa, we rely on our professional competence and integrity to earn the trust of our business partners, customers, and other stakeholders. We are committed to maintaining our reputation at the highest level.

We offer our services in compliance with legal regulations, company policies, commitments, and ethical standards. We make every effort to fulfill our obligations promptly and diligently. This constitutes an integral part of our commitment to our customers and business partners, forming the cornerstone of our way of conducting business.

We emphasize our belief in possessing professional competence and our commitment to continuous improvement in this field. We aim to collaborate with suppliers, business partners, and employees who perform with integrity and legitimacy. We do not engage in business with those who pose a threat to human rights, the environment, or public health.

In public and while representing the company, we articulate the views of the company rather than our personal opinions. In our interactions with the press and on social media platforms, when expressing opinions related to our duties and/or personal preferences, we act with the awareness that these opinions could be associated with our company.

2.5. POLICIES SUPPORTING THE CODE OF BUSINESS ETHICS

2.5.1. Human Rights Policy

At Teknosa, we consider our employees as our most valuable asset and aim to provide them with a fair, equal, safe, and inclusive working environment, supporting their freedom of expression. We do not tolerate negative behaviors such as mistreatment, abuse, violence, or harassment towards our employees.

2.5.2. Anti-Bribery and Anti-Corruption Policy

We uphold integrity and ethical standards in all our activities, relationships, and business dealings, maintaining a zero-tolerance policy against bribery and corruption. Under no circumstances do we accept or offer bribes, regardless of the objective. We refuse to maintain business relationships with third parties who seek collaboration through bribery and corruption.

2.5.3. Policy on Accepting and Giving Gifts

It is fundamental for Teknosa and its employees not to accept gifts or benefits that could influence their impartiality, decisions, or behavior. Similarly, they should refrain from attempting to provide gifts or benefits to third parties that could create such influences.

We have developed a Policy on Accepting and Giving Gifts to regulate the exchange of gifts between our employees and third parties with whom they engage in business relationships.

2.5.4. Conflict of Interest Policy

At Teknosa, we prioritize business ethics and transparency, emphasizing that our employees should avoid situations that could create conflicts of interest. We do not use Teknosa's name, identity, or influence for personal gain. Avoiding situations that could negatively affect the name and reputation of Teknosa is a paramount responsibility for all our employees.

A Conflict of Interest Policy has been established to define situations of potential conflicts arising from our employees' business relationships and the principles to be applied in such circumstances.

2.5.5. Protecting Confidential Information Policy

At Teknosa, we uphold our commitment to safeguarding the confidential and private information of our customers, employees, business partners, and other relevant parties at the highest level. We take necessary measures to preserve the integrity, ensure accessibility, and guarantee the security of information, while performing requisite activities to ensure its continuity. Information security is an integral part of our business processes.

2.5.6. Human Resources Policy

At Teknosa, we highly prioritize establishing a fair work environment and do not discriminate among our employees based on language, race, color, gender, political ideology, beliefs, religion, sect, age, physical disability, or similar factors. We respect the personal lives and spaces of our employees.

We support harmonious collaboration among employees with diverse beliefs, thoughts, and opinions within the company, striving to foster a positive work environment.

2.5.7. Occupational Health and Safety Policy

At Teknosa, we uphold a sense of responsibility regarding occupational health and safety throughout all our processes. We commit to providing safe and healthy working conditions to our employees and ensuring the prevention of harm to any other individuals who may be affected by our operations.

We ensure full compliance with occupational health and safety regulations. We regularly inform and provide training for our employees. We ensure effective occupational health and safety communication.

2.5.8. Sustainable Supply Chain Policy

We recognize the significance of our suppliers within our value chain and endeavor to create sustainable value by fostering strong collaborations with all stakeholders.

In line with our responsible supply chain approach, we have formulated our Sustainable Supply Chain Policy. This policy aims to disseminate our sustainability approach to all our suppliers, striving to collectively create value, while sharing our commitments and goals in this regard.

You can access all of our policies, the main messages of which we have shared above, through this link.

2.6. EMPLOYEES’ RESPONSIBILITIES

SA-ETHICS, Teknosa's Code of Business Ethics, and relevant policies and procedures establish detailed ethical guidelines regarding how we should conduct ourselves and perform our jobs. It is the primary responsibility of all employees to abide by these codes. In this regard, all Teknosa employees have the responsibility to:

Act in accordance with laws and regulations under all circumstances,
Read the Sabancı and Teknosa Code of Business Ethics, learn, understand, internalize, and act in accordance with the codes, principles, and values therein;
Learn the general and business policies and procedures valid for Sabancı Holding/Teknosa;
Consult managers or Human Resources about potential violations concerning oneself or others;
Promptly report potential violations, whether by oneself or by others, to managers, human resources, and/or the Teknosa Ethics Violation Hotline, using written or verbal communication. Ensure reliance on reliable sources, information, and documentation whenever available, either with identification or anonymously.
Follow the “Procedures and Methods to Follow for Ethical Decision-Making” which is defined to guide behaviors and actions as to the codes and problem solving;
Collaborate with the parties conducting ethical investigations, maintaining confidentiality of information related to the investigation.

A. Procedures and Methods to Follow for Ethical Decision-Making

Our employees should follow the steps below as a guiding framework when deciding on a course of action and ask themselves the following questions:

Identifying the Issue, Decision, or Problem

Have you been asked to do something that you think might be wrong?
Are you aware of a situation within Teknosa, your suppliers, or business partners that potentially violates laws or fails to comply with business ethics?
Are you attempting to make a decision and have doubts about how to act in accordance with business ethics?

2. Think Before You Decide

Try to clearly identify and summarize your problem or issue.
Ask yourself why there is a dilemma.
Consider the options, their consequences, and who might be affected.
If in doubt, consult with others.

3. Decide on a Plan of Action

Identify your responsibilities.
Review all relevant facts and information.
Consult Teknosa policies, procedures, and professional standards.
Assess the risks and think about ways to mitigate them.
Try to create the best plan of action.
If in doubt, consult with others.

4. Test Your Decision

Review the ethical questions that need to be asked.
Review your decisions within the framework of Teknosa's core values.
Ensure that you take into account Teknosa's policies, laws, and regulations.
Consult with others and factor their opinions into your planned course of action.

5. Proceed with Resolution

Share your decision and its reasons with relevant people.
Share your learnings and success stories with others.

B. 4 Key Questions to Consider

1. Is this activity/behavior in compliance with laws, regulations, and traditions?

Is it in compliance with the law?
Does it align with professional standards?

2. Is this activity/behavior balanced and fair? Would we be uncomfortable if another competitor (someone else) did the same? (Sense of justice)

Do you think it is right?

3. Would Teknosa or our stakeholders be uncomfortable if all the details of this activity were made public? (Feelings and ethical values)

If others were aware of this behavior, would you find yourself in a difficult or embarrassing position?
Could this have negative consequences for you or Sabancı Holding/Teknosa?
Who else might be affected by this? (Other employees within Sabancı Holding/Teknosa, you, shareholders, etc.)

4. To what extent does the "perceived truth" align with the "objective truth"?

How would it reflect in the media?
What would any reasonable person think under the same circumstances?

2.7. MANAGERS’ RESPONSIBILITIES

Teknosa managers have additional responsibilities beyond those defined for employees within the SA-ETHICS and Teknosa Code of Business Ethics. Accordingly, it is the managers’ responsibility to:

Establish and maintain a company culture and work environment that supports ethical principles,
Lead by example in adhering to ethical rules through their behavior and educate their employees on ethical standards.
Support employees in communicating their questions, complaints, and reports related to ethical principles,
Provide guidance when consulted, consider all received reports, and promptly forward them to Teknosa Ethics Violation Hotline when deemed necessary,
Ensure that the business processes within their responsibility are structured to minimize ethical risks and implement necessary methods and approaches to ensure compliance with ethical rules.

2.8. RESPONSIBILITIES OF THE ETHICS ADVISOR

The responsibilities of an Ethics Advisor include:

Providing guidance and consultancy on ethical matters raised by employees within the company,
Contributing to the resolution of internal ethical non-compliance brought to their attention and redirecting unresolved non-compliance within the company to the Teknosa Ethics Violation Hotline,
Acting as the point of contact for the company in investigations concerning ethical violations and offering necessary support during investigations,
Monitoring and overseeing the effectiveness of SA-ETHICS practices conducted within the company, and providing support in their implementation.

2.9. OTHER RESPONSIBILITIES

The senior management of Sabancı Holding/Teknosa is responsible for:

Ensuring the effective implementation of SA-ETHICS or Teknosa Code of Business Ethics and fostering a supportive culture around this implementation,
Guaranteeing the confidentiality of complaints and reports made within the framework of the Code of Business Ethics and safeguarding individuals following their reports,
Ensuring the job safety of employees making reports,
Ensuring that complaints and reports are investigated promptly, fairly, consistently, and sensitively, and decisively taking necessary actions in the event of violations.

Teknosa Human Resources is responsible for:

Conducting periodic training sessions to inform employees about the Code of Business Ethics ensuring the clarity of policies and rules, and maintaining continuous communication with employees on this matter,
Ensuring that new hires read and are informed about ethical principles,
Ensuring that at the beginning of each year, all employees renew their notifications by signing the Sabancı Holding Business Ethics Compliance Form.

2.10. NOTIFICATION AND RESOLUTION OF NON-COMPLIANCE WITH THE CODE OF ETHICS

Should employees become aware of violations of Teknosa's Code of Business Ethics or the legal regulations applicable to the company, they are required to report such incidents directly to their immediate supervisors. If the matter involves the immediate supervisor, it should be escalated to the Company’s Ethics Advisor, the Company Ethics Hotline, and/or the company's CEO/General Manager. In the event that no action is taken or if a satisfactory resolution is not achieved concerning the incident, it is mandatory to report it to the Sabancı Holding Ethics Committee. If the violation involves the senior management of the company, the matter must be reported directly to the Sabancı Holding Ethics Committee.

Notifications made to the company are concluded and resolved in accordance with the internal processes and procedures of the company. The company informs and seeks the opinion of the Sabancı Holding Ethics Committee on significant matters and as deemed necessary. If deemed necessary, the Sabancı Holding Ethics Committee can directly oversee the investigation process. Individuals who violate Teknosa's Code of Business Ethics or Sabancı Holding/Teknosa policies and procedures may be subject to various disciplinary measures, which in some cases could lead to termination of employment.

Those who endorse, direct, or have knowledge of inappropriate behavior or actions that violate the rules but do not appropriately report such incidents will also be subject to disciplinary actions. Similarly, there will be no tolerance for individuals who exhibit negative attitudes or behaviors towards those who file complaints, make reports, or assist during investigations.

Intentional false or defamatory reports are considered violations of ethical principles. Sabancı Holding/Teknosa or the affected employee who has been subject to falsehoods or defamation may, within the scope of the Turkish Penal Code, Labor Law, and other relevant legislation within the Turkish legal framework, pursue separate legal avenues against those who made such reports.

A. Teknosa Ethics Violation Hotline

E-mail : etik@teknosa.com

Phone : 0216 468 3602

Address : Senior Directorate of Internal Audit, Carrefoursa Plaza, Cevizli Mahallesi. Tugay Yolu Caddesi No:67/B 34846 Maltepe/İstanbul

B. Sabancı Holding Ethics Violation Hotline

E-mail : etik@sabanci.com

Phone : 0212 385 8585

Address : H.Ö. Sabancı Holding A.Ş. Ethics Board, Sabancı Center, 4.Levent 34330 İstanbul

The Code of Business Ethics is prepared by the Sustainability and Occupational Safety Directorate and is published with the approval of the General Manager. It is periodically reviewed and updated, as necessary.

CORPORATE GOVERNANCE