The purpose of the Anti-Bribery and Corruption Policy is to outline and clearly communicate the principles and practices of EAE Aydınlatma A.S. in combating bribery and corruption. Through this policy, we aim to identify, mitigate, and manage bribery and corruption risks in alignment with legal regulations, ethical and professional principles, and the guidance of the ‘United Nations Global Compact (UNGC) (2000)’ universal legal framework.

This Policy is also integrated with EAE Aydınlatma A.S. Code of Business Ethics, our company policy and our Corporate Values and is applied throughout our own operations and our entire value chain. Our internal practices refer to this Anti-Bribery & Anti-Corruption Policy and our Code of Business Ethics.

Wherever we operate, our employees and managers are obliged to act in accordance with our policies about ethics, to apply and support the relevant procedures and controls of EAE Lighting, as required by our policies. We expect all our stakeholders, with whom we do business for supply of goods or services, and our entire value chain, to act in compliance with the principles required by our policies, to the extent applicable to the relevant party and activity, and we take the necessary actions accordingly.

Conflict of Interest:

Any material or immaterial benefit that prevents employees from performing their duties impartially or creates a perception of such an impediment.

Ethics Committee:

The Ethics Committee is the committee that reports to the General Manager and decides on the actions to be taken in the event of complaints and notifications of violations of ethical rules within the scope of the Code of Business Ethics.

Gift:

Any items or benefits, whether of economic value or not, that are directly or indirectly accepted and may influence or appear to influence an employee’s impartiality, performance, decision-making, or fulfilment of duties.

Stakeholders:

Governance components engaged in economic, social, and environmental interaction throughout the value chain.

Bribery:

It refers to the act of a person obtaining material or immaterial benefits, either directly or indirectly, for themselves, the requesting party, or another individual they designate, within the framework of a verbal or written agreement, in order to perform, refrain from performing, cause not to be performed, expedite, or delay an action that is contrary to the requirements of their duties or outside the normal course of operations, whether directly or through intermediaries.

Corruption:

It is the misuse of duties and powers, deviating from their lawful execution, to obtain material or immaterial gain directly or indirectly.

As EAE Aydınlatma A.S., we are committed to conducting our operations in alignment with our ethical values. Our Code of Business Ethics document regulates the fundamental ethical behaviour rules of our company and has been developed to ensure EAE Aydınlatma A.S.’s compliance with national and international laws and ethical standards. In accordance with our ethical principles, EAE Lighting Inc. aims to fully comply with the principles and provisions outlined in this policy; under no circumstances is any form of bribery or corruption tolerated. This EAE Aydınlatma A.S. Anti-Corruption and Anti-Bribery Policy has also been actualized as a requirement of the importance given to this subject.

We regard combating bribery and corruption as one of the most important aspects of our ethical principles and expect all our stakeholders to act in accordance with these principles and the EAE Aydınlatma A.S. Anti-Corruption Policy. In all our agreements with stakeholders, we ensure that the issue of combating bribery and corruption is safeguarded. We include provisions that require full compliance with the principles and fundamentals outlined in this policy, encourage our stakeholders’ employees to internalise these principles and fundamentals, and act accordingly.

To increase awareness and competence among our employees and stakeholders regarding the fight against bribery and corruption, and to ensure the internalisation of the principles and fundamentals outlined in this Policy, e-learning programmes are developed with the support of the Quality Unit of EAE Aydınlatma A.S. and are implemented regularly each year.

All our employees and stakeholders are required to act in accordance with the principles and provisions set out in this Policy, the relevant national / international legal regulations, and all applicable anti-bribery and anti-corruption laws in force. Our employees are required to sign a document declaring their acceptance of compliance with these policy provisions and the consequences of non-compliance.

In the event of violations or suspicious situations contrary to the principles and provisions of this policy, various disciplinary measures may be applied, up to and including termination of employment, in compliance with applicable regulations. Disciplinary sanctions shall also be applied to those who approve or lead inappropriate behaviours and actions that result in violation, or who do not take necessary actions to report despite the fact that they have information about it.

It is not permissible for our employees or stakeholders to face any mistreatment due to reporting violations of the principles and rules stated in this policy, refusing to participate in a bribery or corruption incident, or raising concerns about potential future bribery and corruption actions.

• We make arrangements through contracts to monitor and protect compliance with national/international legal requirements regarding the fight against bribery and corruption in our supply chain practices, and we effectively utilise our existing whistleblowing/complaint hotline mechanism at [email protected].

Our Anti-Bribery and Corruption Policy was published on 17th April 2023 with the approval of the General Manager of EAE Aydınlatma A.S. This policy is reviewed regularly by the ‘EAE Aydınlatma A.S. Ethics Committee’ at least once a year, focusing on current requirements and changes in our operational conditions. Updates/revisions deemed necessary are approved by the General Manager upon the recommendation of ‘EAE Aydınlatma A.S. Ethics Committee’ and subsequently put into effect. The General Manager holds the highest level of responsibility for ensuring compliance with this policy, overseeing improvements, and regularly monitoring any potential violations or suspicious situations.

Any employee who believes there is a conflict between the language of this policy and our activities, has questions about the policy, or wishes to confidentially report a potential violation, can share their concerns with the ‘EAE Aydınlatma A.S. Ethics Committee’ (or any member of the committee). ‘EAE Aydınlatma A.S. Ethics Committee’ secretary position is executed by the General Accounting & HR Team Leader. The General Manager or the relevant manager may be invited to the Ethics Committee on a subject-based basis. We effectively utilise our existing reporting/complaint mechanisms to ensure compliance with the Human Rights Policy and improve monitoring of potential violations and suspicious activities. Furthermore, we make every effort to evaluate the business processes of our stakeholders, from whom we procure goods and services, within the framework of their commitments to international organisations regarding human rights.

Feedback, as well as potential violations and non-compliance with this policy, can be reported to the ‘EAE Aydınlatma A.S. Ethics Committee’ by submitting a sealed envelope with attachments or via email at (ayd.[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 publicly accessible to all our stakeholders through our corporate website and available to all employees via our corporate intranet / QDMS system.