EAE Elektrik Aydınlatma A.Ş. values its employees and respects employee rights. In this context, our basic principles in terms of employee relations are as follows To make merit-based selection in recruitment, to provide equal opportunity without discrimination, To recruit qualified employees who will carry our company into the future, To make maximum use of the talents, power and creativity of employees, To provide equal opportunities for training, guidance and development of employees, To reward success with fair and competitive wage policies, effective and objective performance evaluation system, To increase loyalty to the company by providing equal opportunities in career opportunities and rewards, To ensure labor peace and continuity, To provide employees with clean, healthy and safe working conditions in which all kinds of occupational safety measures are taken, To create and maintain a transparent working environment that encourages mutual respect, where cooperation and solidarity are important elements, To not allow harassment and psychological harassment (mobbing) in the workplace, To evaluate and respond to the opinions and suggestions of employees and to take measures to increase motivation, Not to share private information about employees with third parties without the consent and knowledge of the employee, except for legal obligations, To respect human rights.

The basic principles guiding EAE Elektrik Aydınlatma A.Ş.’s relations with its stakeholders are as follows;

Communication with Stakeholders

To represent our company in the eyes of the society and to enhance its reputation, To keep communication channels open with stakeholders, to evaluate criticism and suggestions, to establish and maintain positive relationships, To refrain from expressing personal opinions in all kinds of criticism.

 Shareholder Relations

To represent our Company before the society and enhance its reputation, to ensure that our Company is managed within the framework of the principles of trust and honesty, to manage its resources, assets and working time with an awareness of efficiency by targeting sustainable growth and profitability.

State Relations

Manage, record and report all business activities and the accounting system fully and appropriately in accordance with the laws, comply with all laws, rules and regulations in the countries of operation and new investment.

Social Responsibility

To support activities that will contribute to economic and social development, to show sensitivity to issues of interest to the society / country and to support the positive development of society.

Customer Relations

Creating value for customers, meeting their demands and requirements at the highest level, Providing quality products and services, Creating an environment of long-term trust in relations with customers, Increasing customer satisfaction in the sales and after-sales process, Not providing misleading and incomplete information to customers.

Supplier and Dealer Relations

To create mutual value in business relations with suppliers and dealers, To communicate with suppliers and dealers in an open, direct and accurate manner, To make decisions with objective criteria in the selection of suppliers and dealers, To comply with the confidentiality and business security rules requested by the supplier / dealer during supplier and dealer audits and visits,

Competitor and Rivalry Relations

Except for the limits permitted by the legislation, not to enter into agreements and behaviors with competitors or other persons or organizations, directly or indirectly, that have the purpose of preventing, distorting or restricting competition or that have or may have the effect of preventing, distorting or restricting competition, in any way whatsoever; not to abuse this situation when it is dominant in a certain market alone or together with undertakings; not to conduct negotiations and exchange information with competitors to determine market and/or competition conditions together; to avoid any negotiations and transactions that may lead to the above-mentioned situations or that may be qualified as such in meetings such as associations, chambers, professional unions, etc. attended on behalf of the Company. Avoiding all kinds of meetings and transactions that may lead to or be characterized as such in the meetings of associations, chambers, professional unions, etc. and other private or professional meetings and negotiations attended on behalf of the Company.

 Global Responsibility

To develop environmental policies and ensure their effective implementation, to act in accordance with the principles set out in the United Nations Global Compact, and to set an example in this regard.

 Asset and Information Management

It is the primary responsibility of all employees to ensure that our Company continues to be recognized for its professionalism, honesty and trust, and to carry it to a higher level. Within this framework, employees are expected to

To always comply with the law, To fulfill its duties within the framework of basic moral and human values, To act in fairness, good faith and understanding in order to ensure mutual benefit in all relationships, Our method of collecting data and its legal reason Not to gain any unfair gain from individuals and organizations for any purpose whatsoever, not to take or give bribes, To act in accordance with the relevant business ethics rules and all application principles that support these rules in the duties carried out, Not to engage in any behavior, statement or correspondence that would put the company under commitment unless expressly authorized, Not to engage in behavior that would disturb and/or harm other employees, To take care of all tangible and intangible assets of the company, including information and information systems, as if they were personal property, to protect them against possible loss, damage, misuse, misuse, abuse, theft and sabotage, Not to use working time and company resources directly or indirectly for personal interest and/or political activity and benefit.

 Intellectual Property Rights

To ensure that legal proceedings are initiated in a timely manner in order to secure the intellectual property rights of newly developed products, processes and software, To avoid unauthorized use of patents, copyrights, trade secrets, trademarks, computer programs or other intellectual and industrial property rights of other companies.

Knowledge Management

To ensure that all legal records are kept accurately and completely, Not to respond to information requests from third parties that fall under the category of confidential for the company without the approval of senior management, To take due care to ensure that the statements and reports disclosed and presented by the company are truthful.

 Security and Crisis Management

To take necessary measures to protect company employees, information and information systems, factories and administrative facilities against possible terrorism, natural disasters and malicious attempts, To make the necessary planning for emergency crisis management to be established in case of terrorism, natural disasters, etc., to ensure business continuity with minimum loss in the event of a crisis, to take all kinds of measures to prevent theft or damage to company assets.

 Privacy

Acting with the awareness that the financial and trade secrets of the company, information that will weaken the competitiveness of the company, personnel rights and information, agreements with stakeholders are within the framework of “confidentiality”, ensuring their protection and confidentiality, Information learned due to work and the documents they possess, Not to share with unauthorized authorities inside and outside the company for any purpose whatsoever, not to use it directly or indirectly for speculative purposes, not to use non-public information about the companies they work for and their customers and other persons and companies they do business with in any way other than for the prescribed purpose, not to share it with third parties without obtaining the necessary permissions. Not to go beyond the rules and instructions of the company in accordance with the Law on the Protection of Personal Data.

Avoiding Conflicts of Interest

Not to be in situations that may cause conflict of interest.

Conflict of Interest: It refers to any kind of benefit provided to the employees, their relatives, friends or persons or organizations with whom they have relations, and any material or any personal interest related to them, which affects or may affect the impartial performance of their duties.

Failure to Transact in Favor of Self or Relatives

Employees are required to declare their shareholding or participation in investments in another company, if any, at the time of their first employment. This issue will be questioned during job interviews with candidates. Employees shall notify their senior supervisors of any changes that may arise in these situations over time and similar issues that may be perceived as a conflict of interest.

Not to gain unfair advantage in favor of oneself, one’s relatives or third parties by taking advantage of one’s title and authority, To take care not to fall into a conflict of interest situation with the current organization in personal investments to be made, To take care that personal investments to be made or any occupations outside of any business activity do not interfere with the performance of the current duty in terms of time and attention, and to avoid such situations that prevent focusing on the main duties, Informing the immediate supervisor in case the employee and the persons who are in the first degree decision-making position regarding the same business in the customer or supplier company are first degree relatives, Informing the immediate supervisor in case it is learned that his/her relatives have shares or material interests in another company with which he/she has a commercial relationship.

 Participation in Representation and Organization Invitations

Participation in invitations such as conferences, receptions, promotional events, seminars, etc. that are open to general participation organized by persons or institutions with whom the Company has or has the potential to have a business relationship, as well as sports activities, domestic/foreign trips, etc. that are or may be perceived as influential in decision-making are subject to the approval of the Board of Directors.

 Receiving and Giving Gifts

In the conduct of relations with private or public persons and organizations wishing to establish or maintain a business relationship with the Company;

Not to accept or offer any gift that creates the impression of the existence of an irregularity, that may cause or may be perceived as a dependency relationship, except for materials given in accordance with commercial traditions, customs and traditions or in the form of souvenirs / promotional materials, not to accept any benefits that may be perceived as inappropriate from suppliers, dealers, customers, group companies or third parties, and not to accept when offered.

 Business with the EAE Group by Leavers

Establishing a company or becoming a partner in a company after leaving EAE Group and doing business with EAE Group companies as a salesman, contractor, consultant, broker, representative, dealer or in similar ways is a very sensitive issue that may create negative perceptions. Before or after such a process, it is necessary to act within the framework of EAE Group’s interests, to comply with moral and ethical rules, and not to allow conflicts of interest before or after the process. For a supplier in this situation, the relevant manager is required to contact the EAE Group company where the supplier has previously worked, prepare a report that there is no inappropriate situation and inform his/her immediate supervisor. If there is an inappropriate situation, no commercial relationship should be established with the relevant person. Except in exceptional cases requiring the approval of the Board of Directors, such commercial relations should not be approved until 2 years after the employee has left EAE Group in order to prevent negative perceptions.

Insider Trading

Knowing that it is a legal offense to try to obtain any commercial benefit by using or giving any confidential information belonging to our Company and EAE Group to third parties and never attempting to do so.

Our company aims to ensure full occupational health and safety in the workplace and on the job. Employees act in accordance with the rules and instructions set for this purpose and take the necessary precautions.

Employees shall not keep any item or substance in the workplace that poses a danger to the workplace and/or employees or that is illegal, Employees shall not keep drugs, addictive substances, substances that restrict or eliminate mental or physical faculties in the workplace, except for those kept in accordance with a valid medical report, and shall not work in the workplace or within the scope of work while under the influence of such substances.

Our company does not make donations to political parties, politicians or political candidates. Demonstrations, propaganda and similar activities are not permitted within the boundaries of the workplace. Company resources (such as vehicles, computers, e-mails) are not allocated for political activities.

Since EAE Elektrik Aydınlatma also operates in international markets, company operations may be subject to the laws and regulations of different countries. When there are question marks regarding the ethics of doing business in different countries, the established regulations in the country where the work is carried out should be followed first. If monitoring the regulations in the country and/or countries where the work will be carried out is of a nature that may create unfavorable results in terms of the ethical values adopted by EAE Elektrik Aydınlatma A.Ş., which will operate on the international platform, then we try to find solutions within the ethical rules and procedures we have.

 Ways and Methods to be Followed While Making Ethical Decisions

You should follow the steps below and ask yourself these questions to guide you in deciding on a course of action on an ethical issue:

Is the relevant issue/event/behavior in line with laws, rules and customs?

Is the issue / event / behavior balanced and fair? Would we feel uncomfortable if a competitor / someone else did it?

Would our company and our stakeholders feel uncomfortable if all the details of this incident were made public?

Would you feel embarrassed or ashamed if others knew you had done this?

Could it have negative consequences for you or your Company?

Who else may be affected (Group companies / our company and other employees within the company, you, etc.)

 Responsibilities of Managers

EAE Elektrik A.Ş. managers have additional responsibilities beyond the responsibilities defined for employees within the framework of the “Code of Business Ethics”. Accordingly, managers;

Ensuring the creation and maintenance of a corporate culture and working environment that supports ethical rules,

Setting an example for the implementation of ethical rules with their behaviors and informing their employees about ethical rules,

Supporting employees in communicating their questions, complaints and notifications regarding ethical rules,

Providing guidance on what to do when consulted, taking into account all notifications received and forwarding them to the Ethics Committee as soon as possible when deemed necessary,

Ensuring that the business processes under his/her responsibility are structured in a way to minimize the risks related to ethical issues and applying the necessary methods and approaches to ensure compliance with ethical rules.

Notification and Resolution of Non-Compliance with the Code of Ethics

If employees learn that the Company’s Code of Business Ethics or the legal regulations to which the Company is subject are violated, they are obliged to report this to their direct managers or the Human Resources Department or the Ethics Committee.

Notifications made to the Company are finalized and resolved in line with the Company’s internal operations and procedures. Those who violate the Code of Business Ethics or Company policies and procedures are dealt with in accordance with the “Disciplinary Management Procedure”.

Disciplinary management sanctions will also be imposed on those who approve, direct or have knowledge of inappropriate behavior and rule-breaking acts and fail to report them appropriately. In addition, there is also no tolerance for those who behave in a negative manner towards those who make complaints and notifications or assist in the evaluation process.

 Ethics Committee

Non-compliance with the announced “Code of Business Ethics” is resolved within EAE Elektrik Aydınlatma A.Ş. “Ethics Committee”. The Ethics Committee was established to resolve conflicts of interest within the scope of EAE Elektrik Aydınlatma A.Ş. “Code of Business Ethics” and to evaluate the notifications communicated to it regarding violations of ethical rules. The Ethics Committee consists of the following persons:

Chairman – Board Member/General Manager

Member – Factory Manager

Member – Accounting Finance and HR Manager

Member – R&D Manager

Member – Project Manager

Member – Quality Team Leader

 Ethics Committee Working Principles

The Ethics Committee conducts its activities within the framework of the principles set out below:

Keeps the identity of notifications and complaints and the identity of those making the notification or complaint confidential.

Everyone who notifies the Ethics Committee is under the protection of the Ethics Committee due to these notifications and cannot be subjected to pressure, discrimination or mobbing.

The Ethics Committee conducts the evaluation as confidential as possible.

It is authorized to request the information, documents and evidence related to the review directly from the existing unit. It may examine all kinds of information and documents it obtains only limited to the subject of the evaluation / complaint.

The evaluation process is recorded in a written report from the beginning. Information, evidence and documents are attached to the minutes.

The minutes are signed by the chairperson and members.

The assessment is handled in an expeditious manner and the outcome is reached as quickly as possible.

The decisions taken by the Board shall be implemented immediately.

Relevant departments and authorities are informed about the outcome.

The chairman and members of the Board act independently and unaffected by the department managers and the hierarchy within the organization while performing their duties on this issue. They may not be pressured or advised on the matter.

The Board may seek expert opinion if it deems necessary and may benefit from experts by taking measures not to violate the principles of confidentiality during the evaluation.

The evaluation is carried out according to the “Discipline Management Procedure”.

Diversity, Inclusion and Equal Opportunity

Demonstrate an inclusive, diversity-oriented, fair, ethical and egalitarian attitude without discriminating between our employees in the work environment or in recruitment, placement, termination, training, career, promotion, assignment, discipline, wage management and benefit processes, without discriminating religion, language, race, nationality, ethnic origin, belief, sect, color, age, sexual orientation, gender, marital status, political opinion, disadvantage and any legally protected characteristic,

To be the most preferred employer for all candidates who are committed to their work and can add value, and to be an employer that protects the rights of its employees,

Never tolerate any form of discrimination in our own operations and throughout our value chain,

To be in constant dialog with our employees, to regularly share all issues that may concern our employees with them and to create fair, healthy and safe working environments where our employees can freely express their opinions with a participatory approach,

To evaluate our employees in positions where they can utilize their potential in a truly productive manner and create contribution and value in achieving the main goals of the company,

Prevention of Child Labor and Forced/Compulsory Labor

We strongly oppose child labor and all forms of forced and compulsory labor, including modern slavery, bonded labor and human trafficking, which cause physical and psychological harm to children and deprive them of their right to education at any stage of our activities,

Ensure that our stakeholders also develop procedures to avoid child labor and forced and compulsory labor practices,

Zero Tolerance for Harassment and Violence

To provide our employees with a safe working environment, free from any kind of abuse, misconduct, intimidation, maltreatment or physical, verbal, sexual/psychological harassment, bullying, threats and violence and to take all necessary measures and support them with procedures,

Set remuneration competitively according to the sectoral and local labor market and pay all wages, including benefits, in accordance with applicable laws and regulations,

Full and correct use of the personal rights of our employees,

Ensure that our stakeholders develop procedures to apply similar approaches to their employees,

Personal/Professional Development

To see human capital as a valuable resource, to maintain a long-term business relationship with our employees by continuously investing in their talents, potential and personal/professional development through internal and external trainings so that they can develop themselves in the best way and do their jobs better,

Occupational Health and Safety

In accordance with the Occupational Health and Safety Legislation, to provide a healthy and safe working environment for our employees and our Stakeholders who are in our work areas for any reason, to take the necessary safety measures and to implement regular training and information activities in line with our “zero accident” target,

Working Life and Data Privacy

To comply with national/international regulations and digital privacy, data confidentiality and security standards for the protection of personal data of our Employees and Stakeholders, as well as confidential information (commercial information, technical data, financial data, production data, customer information, personal information, product information, equipment and application information, technical formulas and drawings, system and program information, procurement information, engineering information, regulations, business plans and all information that the company does not disclose to the public, including but not limited to),

Respect for the Environment and Society

In line with our sustainable growth and green transformation goals, analyzing the environmental impacts of our investment projects in accordance with national/international legislation, with the awareness of our responsibility towards the environment and society,

Being aware of the possible effects of our use of land and natural resources on human rights throughout our value chain, addressing this issue with special policies and practices, reducing the damage to the environment and health through the efficient use of energy, water and raw materials and the preference of renewable resources throughout our value chain in parallel with our company policy,

To identify areas of activity and production with high water stress, including the supply chain, to carry out studies to reduce the amount of water use and the amount of wastewater discharged on a resource basis and to increase water use efficiency,

Recognize our business as part of society and respect the rights of the communities affected by our activities, resolve local issues at the local level in the most appropriate way, and engage with civil society representatives on human rights issues as necessary,

Grievance Mechanism

We are committed to make arrangements through contracts to monitor and protect that international legal requirements regarding human rights in supply chain practices are met by all our employees and stakeholders and to use our existing whistleblowing/complaint hotline-ayd. [email protected] e-mail address mechanisms within EAE Aydınlatma A.Ş. effectively.

Our Human Rights Policy was published on 27.04.2023 with the approval of EAE Lighting A.Ş. General Manager. The said policy is regularly reviewed by the “EAE Lighting Ethics Committee” at least once a year, focusing on current requirements and changes in our operating conditions. Updates/revisions deemed necessary are approved by the General Manager upon the recommendation of the “EAE Aydınlatma A.Ş. Ethics Committee” and enter into force. The General Manager is responsible at the highest level for ensuring compliance with this policy and ensuring regular follow-up of possible violations and suspicious situations within the scope of improvements.

Any employee who believes that there is a conflict between the language of the policy and our activities, who has questions about this policy, or who wishes to confidentially report a potential violation of this policy may submit these questions and concerns to the “EAE Aydınlatma A.Ş. Ethics Committee” (one of the members of the committee). The secretariat duty of “EAE Aydınlatma A.Ş. Ethics Committee” is carried out by the General Accounting & I&I Team Leader. The manager of the relevant unit may be invited to the Ethics Committee on a subject basis.

We use our existing whistleblowing/complaint mechanism effectively to ensure compliance with the Human Rights Policy and to ensure regular follow-up of possible violations and suspicious situations within the scope of improvements, and we strive to ensure that our stakeholders from whom we procure goods/services evaluate their business processes within the scope of their commitments to international organizations in terms of human rights. We continuously interact with our stakeholders and our value chain to agree on ways to prevent and/or mitigate risks and impacts on these human rights issues.

We set annual goals/objectives and monitor progress over time (through internal and external programs and audits) to prevent and/or mitigate human rights risks and impacts across our value chain.

Feedbacks regarding this Policy and possible Policy violations and non-compliances can be reported to “EAE Aydınlatma A.Ş. Ethics Committee” by sending a sealed envelope and its attachments or by e-mail ([email protected]).

In the event that violations and suspicious situations that are contrary to the principles and principles contained in this Policy are detected, various disciplinary sanctions may be imposed in accordance with the provisions of the relevant legislation, which, if necessary, may reach the level of being asked to leave the job. Disciplinary sanctions will also be applied to those who approve, direct or have knowledge of inappropriate behaviors and acts that lead to breaking the rules, but do not make the necessary notification appropriately.

Our Human Rights Policy is made publicly available to all our stakeholders via our corporate website and to all our employees via our corporate intranet site/QDMS.

In the event that violations and suspicious situations that are contrary to the principles and principles in this policy are detected, various disciplinary sanctions may be imposed in accordance with the provisions of the relevant legislation, which may, if necessary, reach the level of being asked to leave the job. Disciplinary sanctions will also be applied to those who approve, direct or have knowledge of inappropriate behaviors and acts that lead to breaking the rules and who do not make the necessary notification appropriately.

Our employees or stakeholders will not be subjected to any ill-treatment for reporting violations of the principles and guidelines set out in this policy, refusing to participate in a bribery or corruption incident, or raising concerns about possible future acts of bribery and corruption.

• We make arrangements through contracts and use the existing whistleblowing/complaint hotline mekanizmalarımızı[email protected] to monitor and protect that national/international legal requirements regarding anti-bribery and anti-corruption in supply chain practices are met by all our employees and stakeholders.

Our Anti-Bribery and Anti-Corruption Policy was published on 17.04.2023 with the approval of EAE Lighting A.Ş. General Manager. The said policy is regularly reviewed by the “EAE Lighting Ethics Committee” at least once a year, focusing on current requirements and changes in our operating conditions. Updates/revisions deemed necessary are approved by the General Manager upon the recommendation of the “EAE Aydınlatma A.Ş. Ethics Committee” and enter into force. The General Manager is responsible at the highest level for ensuring compliance with this policy and ensuring regular follow-up of possible violations and suspicious situations within the scope of improvements.

Any employee who believes that there is a conflict between the language of the policy and our activities, who has questions about this policy, or who wishes to confidentially report a potential violation of this policy may submit these questions and concerns to the “EAE Aydınlatma A.Ş. Ethics Committee” (one of the members of the committee). The secretariat of the “EAE Aydınlatma A.Ş. Ethics Committee” is carried out by the General Accounting and HR Team Leader. We use our existing whistleblowing/complaint mechanism effectively to ensure compliance with the policy and to ensure regular follow-up of possible violations and suspicious situations within the scope of improvements, and we strive to ensure that our stakeholders, from whom we provide goods/services, evaluate their business processes within the scope of their commitments to international organizations in terms of human rights.

Feedback on this policy and possible policy violations and non-compliances can be reported to the “EAE Aydınlatma A.Ş. Ethics Committee” by sending the ethics notification form and its annexes in a sealed envelope or via e-mail ([email protected]). There are effective internal control mechanisms to prevent potential bribery and corruption risks in our business processes.

Our Anti-Bribery and Anti-Corruption Policy is made publicly available to all our stakeholders via our corporate website and to all our employees via our corporate intranet site/QDMS.

Prevention of Child Labor and Forced / Compulsory Labor: Our suppliers must strongly oppose child labor and all forms of forced and compulsory labor, including modern slavery, bonded labor, and human trafficking, which cause physical and psychological harm to children in their operations and take away their right to education.

Working Hours and Compensation: We expect our suppliers to observe compliance with legal working hours, working conditions and overtime provisions set by laws and regulations applicable in the regions where they operate. They are required to set remuneration competitively according to the industry and local labor market and pay all wages, including benefits, in accordance with applicable laws and regulations.

Zero Tolerance for Harassment and Violence: Our suppliers must provide their employees with a safe and secure working environment free from any form of abuse, exploitation, intimidation, maltreatment or physical, verbal, sexual/psychological harassment, bullying, threats and violence and must take all necessary measures and support them with procedures.

Personal/Professional Development: Our suppliers should recognize human capital as a valuable resource and invest in their employees’ talents, potential and personal/professional development through internal and external trainings in order for them to develop themselves in the best way and do their jobs better.

Occupational Health and Safety: In accordance with the Occupational Health and Safety Legislation, our suppliers must provide a healthy and safe working environment for their employees and persons who are in their work areas for any reason, take the necessary safety measures and implement regular training and information activities in line with the “zero accident” target.

Working Life and Data Privacy: Our suppliers must respect the right to privacy and comply with national/international regulations and digital privacy, data privacy and security standards to protect the personal data of their employees and stakeholders, as well as confidential information (including, but not limited to, commercial information, technical data, financial data, production data, customer information, personal information, product information, equipment and application information, technical formulas and drawings, system and program information, procurement information, engineering information, regulations, business plans, and all information that the company does not make public).

Respect for the Environment and Society: In line with our sustainable growth and green transformation goals, and with the awareness of our responsibility towards the environment and society, we expect our suppliers to take into account the impacts of climate change on economic, environmental and social welfare and the associated risks and opportunities, and to contribute to the global struggle to transition to a low carbon economy. In line with our country’s 2053 net-zero emission target, green development vision and circular economy principles, our suppliers should show the necessary sensitivity in energy/resource efficiency, renewable energy, recycling and recovery, aim to continuously reduce/prevent waste, emissions and discharges arising from their activities, products and services, and not harm the environment and health due to their operational activities. They should also aim to provide added value to the society in which they operate by developing social responsibility projects that support sustainable development. They should procure the energy resources they use in a way that contributes to the environment as much as possible and ensure the use of renewable energy.

Trade Controls

Our suppliers must ensure that their operations comply with the terms of their export licenses and applicable regulations. Our suppliers who transport and/or handle products subject to export/import controls or sanctions are responsible for properly understanding and applying relevant trade laws and regulations and company rules. Our suppliers must keep up to date with and comply with frequently changing sanctions, export restrictions, economic sanctions, boycott and embargo laws.

Anti-Bribery and Anti-Corruption

We consider anti-bribery and anti-corruption among the most important of our ethical principles, and we do not tolerate any anti-competitive behavior or any actions related to money laundering, bribery and corruption throughout our own operations and value chain. We expect all our suppliers to act in accordance with EAE Lighting A.Ş. Anti-Bribery and Anti-Corruption Policy.

Media and Social Media

We expect our suppliers not to share any positive or negative comments, information and documents related to EAE Aydınlatma A.Ş. or attributable to EAE Aydınlatma A.Ş. on visual/written media channels and social media. Our suppliers should not share any confidential or strategic information, documents and visuals, including EAE Aydınlatma A.Ş.’s trade secrets, in their personal accounts on social media and networks, should refrain from words and attitudes that disparage EAE Aydınlatma A.Ş. services, customers, suppliers or competitors, and should not respond to media or other organizations’ questions about EAE Aydınlatma A.Ş. and should not make any comments on behalf of EAE Aydınlatma A.Ş. Our suppliers must consult with the Plant Manager and obtain written approval before making any statement regarding their work with EAE Lighting.

Supplier Audit and Evaluation Process

Our suppliers must provide accurate, transparent and open information on the issues we audit and question them about. They should especially focus on the issues we have asked within the scope of sustainability and integrated management systems and ensure their own development. Complete the Non-Compliance reports submitted after the audit within the time period given to them and submit them to EAE Lighting in an accurate, transparent and understandable manner. The supplier must not make any non-compliance in this process.

Our Supplier Code of Conduct was published with the approval of the General Manager on April 27, 2023. The said Code is regularly reviewed by the “Ethics Committee” at least once a year, focusing on current requirements and changes in our operating conditions. Updates/revisions deemed necessary are approved by the General Manager upon the recommendation of the “Ethics Committee” and enter into force. The General Manager is responsible at the highest level for ensuring compliance with the Rules in this document and ensuring regular follow-up of possible violations and suspicious situations within the scope of improvements.

Feedback regarding the Supplier Code of Conduct and possible violations of legal regulations or Rules and non-compliance must be reported to the “Ethics Committee” via e-mail ([email protected]). The secretariat duty of the “Ethics Committee” is carried out by the General Accounting & I&I Team Leader. The relevant manager may be invited to the Ethics Committee on a subject basis.

In order to confirm that our suppliers act in accordance with the content of our Supplier Code of Conduct, EAE Lighting A.Ş. may conduct on-site or remote, announced or unannounced audits to our suppliers, and periodically request information/documents from our suppliers. Our suppliers also accept that EAE Lighting A.Ş. has the right to request and audit such information/documents. Our suppliers are obliged to submit all relevant documents requested from them to EAE Lighting within 3 days at the latest.

In the event that a possible non-compliance is detected during the audits to be carried out on our suppliers;

EAE Aydınlatma A.Ş. reserves the right to unilaterally terminate our business relationship with our suppliers who violate the principles and principles in our Supplier Code of Conduct.

We may require our suppliers to implement an action plan to address the non-compliance and may conduct follow-up audits to ensure that the actions set out in the action plan are carried out.

EAE Aydınlatma A.Ş. Supplier Code of Conduct is made publicly available to all our stakeholders through our corporate website, as well as to all our employees through our corporate intranet site/QDMS.

Environment Day Event

Every year on June 5, Environment Day, a tree planting event is organized with company employees. In addition, materials that can be used to reduce the amount of waste are given to company employees for the awareness of Environment Day. The aim of this event is to contribute to nature and to create environmental awareness among company employees.

Our Corporate Social Responsibility Policy was published with the approval of the General Manager on April 27, 2023. This policy is regularly reviewed by our Sustainability Committee at least once a year, focusing on current requirements and changes in our operating conditions. Updates/revisions deemed necessary are approved by the General Manager upon the recommendation of the Sustainability Committee and enter into force.

EAE Aydınlatma A.Ş. Corporate Social Responsibility Policy is made available to all our stakeholders through our corporate website and to all our employees through our corporate intranet site/QDMS.