Our Business Ethics Principles

1. SCOPE

The Business Ethics Principles adopted by Profelis Bilişim ve Danışmanlık Ticaret ve Sanayi Limited Şirketi (hereinafter referred to as “Profelis”) and approved by its General Assembly on January 25, 2011, together with the establishment of the Quality Management System, constitute the rules that all Profelis employees, as well as third parties involved in the Company’s decision-making processes or providing external consultancy services, are required to comply with within the scope of their respective responsibilities.These principles serve as the primary guidelines and management principles governing employees’ relationships with third parties and with one another within the Company. The General Assembly, the Quality Management Representative, and/or an employee appointed by management are responsible for the preparation, development, and updating of these principles, while the General Assembly and the Board of Managers are responsible for their implementation.The Profelis Business Ethics Principles are an integral part of the Quality Management System.

2. OUR PRINCIPLES

A. Honesty

Integrity and honesty are among our core values in all business processes and relationships. We act with integrity and honesty in our interactions with employees and all stakeholders.

B. Privacy

Confidential and private information includes information belonging to Profelis that could create a competitive disadvantage, trade secrets, financial and other information not yet disclosed to the public, personal data including information relating to the personal rights of employees and customers, and information covered by “Confidentiality Agreements” entered into with third parties.Everyone who starts working at Profelis signs a Confidentiality Agreement that defines and acknowledges the confidentiality rights of Profelis, the individual, and all institutions, organizations, and persons with whom they interact during the course of their work. Due care is taken to protect the confidentiality and private information of our customers, employees, and other relevant persons and organizations with whom we work.Confidential information relating to the Company’s activities is protected and is shared only with relevant persons within the scope of the authorizations previously determined by the General Assembly and/or the managers authorized by it. It is strictly unacceptable to obtain any commercial benefit through the unauthorized disclosure or internal leakage of any confidential information or personal data belonging to Profelis.When leaving the Company, confidential information and documents, projects, regulations, and similar materials obtained or accessed as a result of our duties may not be removed from the Company. In the event of such a situation, the provisions of the Confidentiality Agreement shall apply.

C. Conflict of Interest

Profelis employees avoid conflicts of interest. Employees may not use their current position or title to obtain personal benefits, either directly or through family members or close associates, from individuals, institutions, or organizations with which the Company has business relationships.In the event of a potential conflict of interest, it is ensured that the interests of the relevant parties are securely protected through legal and ethical means.

D. Our Responsibilities

In addition to our legal obligations, we take care to fulfill the responsibilities listed below toward our customers, employees, suppliers and business partners, competitors, society, and humanity.

1. Our Legal Responsibilities

We conduct all our activities in accordance with the laws of the Republic of Türkiye and international law, and provide accurate, complete, clear, and timely information to legal and regulatory authorities and institutions.In carrying out our activities, we maintain an equal distance from all public institutions and organizations, administrative bodies, and political parties, without any expectation of benefit, and fulfill our obligations with this sense of responsibility.

2. Our Responsibilities to Society and Humanity

The protection of democracy, human rights, and the environment, as well as support for education and charitable activities and the elimination of crime and corruption, are of great importance to us. With a strong sense of responsible citizenship, we act sensitively and proactively on social issues and provide both financial and non-financial support to non-governmental organizations, public-interest services, and activities aligned with these principles.We oppose child labor that negatively affects the mental, psychological, and social development of children and do not tolerate the exploitation of child labor.Bribes and/or commissions are neither accepted nor offered. Gifts, products, or services of excessive value are not offered, given, or accepted. No gift that is directly, indirectly, implicitly, or explicitly tied to any form of consideration or benefit is accepted.

3. Our Responsibilities to Our Customers

With a customer satisfaction-oriented approach, we aim to respond to our customers’ needs as quickly and accurately as possible. To achieve this, the necessary quality standards are established and monitored to ensure customer satisfaction.Our services are delivered on time and under the conditions we have committed to, and our customers are treated fairly, respectfully, and courteously.

4. Our Responsibilities Toward Our Colleagues

Employees are provided with full and proper access to their employment-related rights and benefits. We are committed to providing employees with an honest, fair, non-discriminatory, safe, and healthy working environment. The necessary effort and support are provided for employees’ individual development. Employees are encouraged to volunteer in social activities in which they wish to participate with a sense of social responsibility. A balance between professional and personal life is taken into consideration.No employee shall be granted preferential treatment on the basis of gender, religion, or race, nor shall any employee expect preferential treatment on such grounds. Differences such as gender, religion, or race shall not be used as a means to seek or grant concessions.No tolerance shall be shown toward preferential treatment based on gender, religion, or race, or toward conduct such as harassment, humiliation, discriminatory or defamatory remarks, or violations of any employee’s physical or emotional integrity. In such cases, the General Assembly shall review, investigate, and evaluate the matter. Such conduct may result in termination of employment for just cause.

5. Our Responsibilities Regarding Profelis

Priority is given to the continuity and sustainability of Profelis, and unnecessary or unmanageable risks are avoided in line with our goal of creating value for our stakeholders. We act within the principles of financial discipline and accountability.While performing their duties within the scope of their authority and responsibilities, employees manage Profelis resources efficiently and with due consideration for cost savings.

6. Our Responsibilities to Our Suppliers/Business Partners

Employees treat our suppliers and business partners fairly and respectfully, as expected of them. Due care is taken to ensure that obligations within this scope are fulfilled in a timely manner. The confidential information of the individuals and organizations we do business with, as well as our business partners, is carefully protected.

7. Our Responsibilities Towards Our Competitors

Competition is regarded as a means of achieving sustainable development, provided that it is conducted within boundaries that serve the interests of society. We compete only in legal and ethical areas. We avoid unfair competition and do not disparage our competitors, either explicitly or implicitly.

8. Responsibilities of Managers

Profelis managers have additional responsibilities beyond those defined for employees. Accordingly, managers at Profelis:

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

– Setting an example through their conduct in implementing ethical principles and educating employees about these principles,

– Supporting employees in raising questions, complaints, and reports regarding ethical principles,

– Providing guidance when consulted and considering all reports received objectively and without prejudice,

– Primarily responsible for ensuring that the business processes under their responsibility are structured in a way that minimizes risks related to ethical issues.

3. INFORMATION

Profelis is responsible for ensuring that the Business Ethics Principles are included as part of the orientation program provided to every new employee and are presented in a manner that can be read and understood by all third parties involved in the decision-making process or providing external consultancy services.Profelis managers and/or the Quality Management System Representative and/or employees appointed by management are responsible for informing the relevant parties. In the event of any changes to these principles, Profelis managers and/or the Quality Management System Representative and/or employees appointed by management are also responsible for using the communication methods specified by the Quality Management Standards to announce such changes and ensure that the relevant parties are informed.This document was updated on October 2, 2019.