Ethical Conduct Rules and Principles

HATKO KAUÇUK A.Ş.

ETHICAL CONDUCT RULES AND PRINCIPLES

Hatko Kauçuk A.Ş. (hereafter “Hatko”) requires its employees, business partners, and any third parties with whom it cooperates to conduct themselves in line with the highest standards of ethical behavior and in compliance with all applicable laws.
If any supplier, employee, business partner, or third party engages in unethical or illegal practices while doing business connected to Hatko, the contract or business relationship may be terminated.
These Ethical Conduct Rules and Principles cover:

• Integrity and honesty
• Fairness in business practices
• Data privacy
• Professional behavior
• Professional skills and added value
• Social respect
• Environmental care and sustainability

These principles guide how we do business together.

Purpose

Our goal is to raise awareness of ethical values and ensure that all business practices are consistently ethical. Hatko requires all employees, business partners, and other parties who do business with us to uphold our ethical and organizational values, and to reflect these values in their own behavior and decision-making processes when working with Hatko.

1. Integrity and Honesty

1. Everyone acting on behalf of Hatko must be familiar with and fully comply with these Ethical Conduct Rules and any relevant laws and regulations. Our aim is not merely to avoid financial penalties or legal prosecution, but also to protect our reputation.
2. All employees are responsible for adhering to these principles and to the additional company policies and procedures made available through official communications.
3. Beyond compliance with the law, Hatko expects every employee and third party to uphold integrity, honesty, and loyalty in all business dealings. Integrity must remain the focal point of our business practices. Information provided to our stakeholders must always be accurate and never misleading.

2. Fairness in Business Practices

1. Corruption, bribery, money laundering, embezzlement, and other illegal or unethical methods of doing business are strictly prohibited.
2. It is never acceptable to give, offer, or provide anything of value (cash, cash equivalents, gifts, charitable contributions, grants, sponsorships, travel, accommodations, investments, hospitality, or anything tangible or intangible of value) to a government official or any private individual with the aim of:
   • Gaining or retaining business,
   • Securing a business advantage, or
   • Directing business to any person.
3. Any direct or indirect payments, gifts, or benefits provided to private individuals must be reasonable and customary, and must not be excessive.
4. If an employee suspects any questionable business practice, they must report it to their supervisor or the relevant department.
5. Employees must not misuse their authority to obtain personal benefits for themselves or their relatives at the expense of the company.
6. Employees must not derive personal gain—directly or indirectly—from the company’s purchasing, sales activities, or any contracts or transactions to which Hatko is a party.
7. Employees must not engage in conduct or behavior contrary to morality, law, or company discipline.
8. Falsified, incorrect, or misleading business or commercial documents (e.g., invoices, delivery notes, return invoices, purchase orders) are unacceptable under all circumstances. Invoices and other documents must accurately reflect the goods shipped or services provided.
9. All contracts with third parties must follow the relevant approval and authorization processes.
10. In the case of export or import activities, employees must comply with all international trade control laws and customs regulations, as well as Hatko’s internal procedures.

3. Data Privacy

1. All employees and business partners must safeguard Hatko’s intellectual property and confidential information(e.g., trade secrets, financial results, business plans, pricing, customer or supplier data, sales figures, strategic information, research, processes, software, or any proprietary information).
2. Unless legally required by authorities or legislation, this information must not be disclosed to third parties.
3. Confidential information must not be altered, copied, or destroyed in an unauthorized manner. Proper care, storage, and non-disclosure measures must be taken to protect it. Any changes must be recorded with version history.
4. Confidential files must not be taken off company premises without the explicit approval of the information owner or senior management.
5. Passwords, user IDs, and other access credentials must be kept secret and must not be shared with unauthorized persons.
6. Confidential company information must not be discussed in public places (e.g., cafeterias, elevators, company shuttles) or shared on social media or personal mobile applications. Only authorized personnel may post company information on official Hatko social media accounts, in line with management-approved guidelines.
7. If there is any doubt about the level of confidentiality, treat the information as highly confidential and consult the relevant manager.
8. Personal data of employees (e.g., salaries, benefits) is confidential and must not be disclosed except to authorized individuals. Employees must not reveal their personal data to others or pressure colleagues to do so.
9. Information should be disclosed only when there is a legitimate business need and after the confidentiality level has been evaluated. Extra caution must be exercised whenever personal data is involved.
10. If Hatko needs to provide certain confidential information to business partners (e.g., limited access to IT systems), the business partner must sign a Non-Disclosure Agreement (NDA).
11. Hatko also respects the confidential information of its business partners and expects employees to protect any non-public or proprietary data received.
12. These obligations remain in effect even if your business or commercial relationship with Hatko ends.
13. Hatko complies with personal data protection regulations (e.g., GDPR, KVKK, or similar laws) in all relevant jurisdictions.

4. Professional Behavior

1. We invest in long-term relationships with our customers and suppliers. We value these partnerships and strive to meet their expectations at the highest level, honoring all commitments.
2. We encourage employees to create added value for customers, suppliers, and the company itself. This includes taking initiative, forming strong relationships, continuously improving internal processes, and reporting any need for improvement to management.
3. Team spirit is essential: sharing ideas and resources helps us be more productive. Hatko encourages its employees to work collaboratively with our business partners to maximize the value delivered.
4. Fraud or any business-related criminal conduct is strictly prohibited.
5. No falsified or misleading information may be recorded in accounting or financial records. The company’s financial performance must not be misrepresented. Any suspicious entry or delay must be reported to the Finance department.
6. Company assets must be used solely for legitimate business purposes and to fulfill professional responsibilities. Employees must protect company property from loss, damage, misuse, or theft.
7. Suppliers are selected based on factors such as quality, price, reliability, continuity, service, and compliancewith laws and regulations. We also evaluate suppliers’ environmental and sustainability performance, ensuring they align with Hatko’s values and legal requirements.
8. Employees must not choose or continue working with suppliers who engage in questionable business activities or who violate laws.
9. Hatko invests in a safe and healthy work environment to reduce the risk of accidents. Employees are encouraged to care for their own health and safety and that of others who may be affected by their actions.

5. Professional Skills and Added Value

1. Delivering high-quality services and added value is our core commitment and responsibility.
2. Our brand and image matter. Every employee is expected to convey a positive message about the company.
3. Personal social media channels are not places to publish company-related confidential or sensitive information.
4. Each Hatko employee plays a key role in the company’s success. We recruit carefully to ensure every new hire possesses the skills needed for their role.
5. Employees are expected to use their professional expertise to enhance the company’s performance, foster innovation, and uphold Hatko’s reputation.

6. Social Respect

1. Hatko promotes a culture of respect in the workplace and throughout the employment process. We treat colleagues, business partners, and third parties with dignity and respect.
2. Discrimination based on race, color, religion, gender, sexual orientation, age, or any other characteristic protected by law is not tolerated in any employment decision.
3. Harassment, intimidation, or insulting behavior is strictly prohibited.
4. We believe in fostering a workplace where everyone can contribute freely and safely, free from intimidation or bias.

7. Environmental Care and Sustainability

1. Protecting the environment is both a legal obligation and a core company value. We are committed to sustainable practices that minimize environmental impact, conserve natural resources, and promote a healthier planet.
2. Hatko strives to continuously improve its environmental performance through measures such as:
   • Reducing energy consumption and improving energy efficiency,
   • Minimizing waste and promoting recycling and responsible waste management,
   • Conserving water resources,
   • Controlling and reducing greenhouse gas emissions,
   • Complying with all relevant environmental regulations and standards.
3. All employees share responsibility for maintaining a safe and healthy work environment, which includes environmental stewardship. We encourage everyone to be proactive in identifying and reporting potential environmental risks or improvement opportunities to management.
4. We also expect our suppliers and business partners to adhere to environmental best practices. This includes:
   • Complying with all local and international environmental laws and regulations,
   • Obtaining and maintaining environmental permits and certifications where required,
   • Reducing their ecological footprint by adopting sustainable production methods, using renewable resources where feasible, and managing waste responsibly.
5. Employees and partners are encouraged to raise awareness about environmental issues—both within and outside the company—and to support recycling, energy saving, and other sustainability initiatives.
6. These commitments ensure that Hatko’s operations and those of its suppliers, partners, and customers reflect respect for the environment, contributing to the long-term well-being of our planet and communities.

Final Provisions

• These Ethical Conduct Rules and Principles apply to all employees, contractors, business partners, suppliers, and third parties acting on Hatko’s behalf or in relation to Hatko’s business.
• Any violation may result in disciplinary action, up to and including termination of employment or business relationships, as well as possible legal consequences.
• If there is any doubt or concern about the interpretation of these principles, employees are encouraged to seek guidance from their manager or the relevant department.
• By complying with these rules, we ensure that Hatko Kauçuk A.Ş. maintains its reputation for integrity, respects its social and environmental responsibilities, and fosters a trustworthy, sustainable business environment.

Acknowledgment
I have read and understood the above Ethical Conduct Rules and Principles of Hatko Kauçuk A.Ş. I agree to abide by them and to uphold these standards in all my professional dealings and decisions related to the company.

Nejan Hatko  / CEO
1^st of January,2025