• The Company’s Board of Directors and the Audit Committee are responsible for the implementation of the Code of Ethics at the highest level.
• The members of the Board of Directors and the Audit Committee accept the Code of Ethics and comply with these principles therein.
• Batu International Logistics provides the appropriate environment within the Company for the implementation of the Code of Ethics.
• The Company ensures the provision of the necessary communication channels for reporting acts that violate the Code of Ethics.

• All managers accept the Code of Ethics, follow the principles therein and set a good example for employees with their conduct.
• Managers ensure that the Code of Ethics are understood and observed by employees working under them.
• Managers ensure that the Code of Ethics is adapted and maintained in units they are primarily responsible for.
• Under no circumstances and for no reason can managers force employees to act in violation of the Code of Ethics.
• Managers listen to the questions, complaints, suggestions and requests of employees related to the Code of Ethics and encourage them to provide feedback.
• Managers evaluate business processes under their responsibility within the framework of the Code of Ethics, identify any non-compliance, and take measures to ensure compliance with the Code of Ethics.

• All Batu International Logistics employees accept and comply with the Code of Ethics.
• Employees make their best effort to ensure that other employees comply with the Code of Ethics, and encourage them to this end.
• Employees inform managers of any conduct or action in violation of the Code of Ethics using the communication channels specified below.
• All employees know and fully implement the regulations, procedures and instructions related to their work and Batu International Logistics as a whole.

3.1 Use of Batu International Logistics Resources

• Batu International Logistics always pays strict attention to the fair, effective and efficient use of resources. The principle of saving is taken into account in all activities.
• Resources of Batu International Logistics are not used for personal interests or the interests of any person or organization other than Batu International Logistics.
• Measures are taken against theft, disruption and damage to assets of Batu International Logistics and assets of Batu International Logistics are protected to the extent possible.
• Employees should use working hours effectively and efficiently, and avoid attending to personal matters during working hours.
• The company’s vehicles, mobile communication vehicles, computers and other equipment allocated to employees are considered to be assets of Batu International Logistics and should be used in accordance with the principles set out above and internal directives of Batu International Logistics.
• When using the Internet and electronic mail over Batu International Logistics’s communication network, the rules required by internal directives Batu International Logistics should be followed in order to ensure information security and effective use of resources.

• All accounting and business records of Batu International Logistics are kept accurately, fully and in accordance with the relevant regulations, and each employee fulfills their responsibilities in this regard to the fullest extent.
• Batu International Logistics employees never use the information that they obtain due to their duty or position for their own personal benefit.
• It is strictly forbidden to make unfair profit in capital markets using non-public information of Batu International Logistics or by disclosing such information to third parties.
• Non-public information of Batu International Logistics (strategic plans, sales price information, production techniques, studies on new products and services, research and development activities, etc.) should not be disclosed to third parties.
• When it is necessary to disclose non-public information of the Group with third parties, measures such as non-disclosure agreements should be taken to prevent mishandling of such information.
• Non-public information of the Group should not be discussed in public places such as dining halls or shuttle services for employees.
• The regulations, procedures and instructions on the security of information of Batu International Logistics should be strictly observed. Necessary measures should be taken to ensure that such information is carefully stored, archived and not disclosed.

• Employees of Batu International Logistics should not engage in any activity that requires them to be considered “merchants”, “tradesmen” or “self-employed persons”, and should not work in any company and commercial enterprise or alongside merchants or tradesmen either on a paid or unpaid basis.
• Employees of Batu International Logistics may take part in non-profit organizations, non-governmental organizations and charitable organizations on a voluntary basis. Care should be taken to ensure that any such involvement does not disrupt the duties of employees at Batu International Logistics, does not create a conflict of interest, and does not constitute a clear violation of Batu International Logistics
• Employees of Batu International Logistics may become members of political parties; however, they may actively engage in politics only with the approval of the Chairperson of the Board of Directors and provided that it does not create a conflict of interest with Batu International Logistics policies and activities and does not disrupt their duties at Batu International Logistics.
• Employees of Batu International Logistics may write articles, give interviews, make presentations or speeches in the media regarding policies and decisions of the company or production, sales and similar operations of the company only with the approval of the Chairperson of the Board of Directors.
• Employees of Batu International Logistics may teach in professional organizations and educational and training institutions only with the approval of the Chairperson of the Board of Directors.
• Employees of Batu International Logistics may take part in institutions and organizations related to Batu International Logistics’s fields of activity (professional associations, chambers, boards, federations and other public organizations) only with the approval of the Chairperson of the Board of Directors.

• No gifts or benefits may be requested from customers and suppliers.
• No hospitality or business lunches may be requested from customers and suppliers. Business lunch offers from customers and suppliers may be accepted provided that they comply with local standards and are of reasonable magnitude.
• Non-cash offers such as free holidays, discount vouchers, gift vouchers from customers and suppliers are also considered as gifts and benefits and should not be accepted by principle. However, if such rejection of gift offers from customers and suppliers may be perceived as unkind and offend the gift giver, they may be accepted provided that they do not exceed TRY 500 or its foreign exchange equivalent in value.
• Such offers may be accepted only if all Batu International Logistics employees are provided with the same.
• Gifts with symbolic value such as plaques and plates given at meetings or seminars attended as a representative of Batu International Logistics may be accepted.

• Employees should not engage in business relations with family members, close relatives and friends when performing tasks for Batu International Logistics to provide mutual or unrequited benefits.
• In case of family members, close relatives and friends working in supplier and customer companies, such relationships are not allowed to prevent any conflict of interest.
• In case of family members, close relatives and close friends working within Batu International Logistics, such relationships should not be allowed to affect decisions to be made within the company. All employees of Batu International Logistics should maintain their impartiality in all cases and evaluate employees according to their performance, knowledge, and experience.
• Employees who have the authority to make a hiring decision should not engage in nepotism by giving priority to family members, close relatives, and friends. Family members, close relatives, and friends may be hired with the approval of a senior manager and on the condition that it is in the best interest of Batu International Logistics.
• Employees who have the authority to make purchasing decisions may not make a purchasing decision on offers made by companies of which their family members, close relatives, and friends are employees or partners, either directly or indirectly. Such decisions may be made by fully informing and obtaining the approval of a senior manager and on the condition that it is in the best interest of Batu International Logistics.
• In case of offers made by or business relations with companies in which former Batu International Logistics members are employees or partners, either directly or indirectly, this should be clearly stated.

• Batu International Logistics’s interests should always be considered at the highest level in relations with customers and suppliers.
• Employees should not establish personal relations with customers and suppliers based on mutual or unrequited benefits, such as taking personal loans, etc.
• Promises made to customers should be kept and promises that cannot be kept should not be made.
• No illegal and unethical act should be committed in order to obtain information about customers and suppliers.
• Information about customers and suppliers obtained illegally by third parties and disclosed to employees of Batu International Logistics should never be used or disclosed to others.
• Customers and suppliers should be treated based on the principles of respect, equality, courtesy, and fairness.
• Misleading and deceptive acts should not be committed against customers and consumers.
• Confidential information of customers and suppliers should not be disclosed to third parties.
• Contracts and protocols with customers and suppliers should be fulfilled as required.

• The competition rules and laws in the country of operation should be fully complied with, and the principle of righteousness and integrity should not be compromised in competition.
• Employees should act with caution if they consider that the rules of fair competition are violated during meetings, seminars or discussions, and remove themselves from such environments, if necessary.
• No illegal and unethical act should be committed in order to obtain information about competitors.
• Information about competitors obtained illegally by third parties and disclosed to employees of Batu International Logistics should never be used or disclosed to others.
• No unfounded and vague rumor should be spread about competitors, and employees should not get involved in such rumors.

• All kinds of information and documents requested by government agencies should be provided in an accurate, complete, and timely manner.
• Misleading and deceptive acts should not be committed in relations with government agencies. Batu International Logistics does not try to gain an advantage in its favor by deceiving government agencies. Batu International Logistics’s interests should be protected to the fullest extent in line with the laws and regulations.
• In case of any reservation regarding how a law or regulation applies, employees should consult with Batu International Logistics’s Legal Counsel and Financial Counsel.
• No benefits may be offered, either directly or indirectly, to public officials in exchange for preferential treatment. Employees should not make in cash or in kind payments to any person in violation of laws and regulations, even if such payment serves the interest of Batu International Logistics.
• It should be ensured that third parties acting on behalf of Batu International Logistics (such as representatives, consultants) refrain from such offers in their work on behalf of Batu International Logistics.

• The Code of Ethics of Batu International Logistics should be adopted and no act in violation of the Code should be committed.