Dear Colleagues,

The success, reputation and image of our companies under “arsaVev” brand stem from your commitment, energy and efforts.

Building a corporate image and reputation requires a solid commitment to ethical principles and values. For this reason, the Executive Committee has taken a proactive approach to ensure compliance with the rules of good conduct set out in this Code of Ethics.

We are so much more than one of Turkey’s top real estate project development companies and a nationwide leader in real estate industry. With all the men and women working all together who are passionate about their profession from different backgrounds and walks of life, we are proud of this success.

Day in and day out, our standards drive us at all levels. It guides our projects, informs our decisions and energizes all of employees in their work. This Code of Ethics and Corporate Social Responsibility (CSR) is a natural extension of our concern for the highest standards and formalizes our commitment to placing ethics and sustainable development at the heart of our strategy, management methods and business practices.

Our principles of ethics and CSR consist of four simple messages:

– act in accordance with laws and regulations
– cultivate a culture of integrity
– demonstrate loyalty and honesty
– respect one another

These messages are aligned with our group’s values of trust, sharing, diversity and daring. Our Code is part of our ambitious value system, and it supports our long-term vision for harmonious development. We rely on each and every one of our employees to share these principles in their day-to-day activities so that arsaVev goes beyond simple economic performance by remaining a company with which our employees, customers and partners are happy to work. This is how we can ensure sustainable growth and development.

We ask all our employees, regardless of their role in the Company, to carefully read and abide by the provisions in this Code. Any questions you might have about these principles should be directed to your manager and/or the Human Resources Department.

The Executive Committee and I would like to thank you for your vigilance and personal involvement in ensuring that our Group’s integrity and reputation remain beyond reproach. You have achieved this by applying company-wide ethical principles daily.

Sincerely,

CONTENTS

1. Principles and Ethics
1.1. Our Values
1.2. Privacy Policy and Ensurance of Privacy
1.3. Integrity and Ethics
1.4. Relationships with Stakeholders
1.5 Dealings with Suppliers and Customers
1.6. Prevention of and fight against Corruption
1.7. Financial Documents
1.8. Intellectual Property Protection
1.9. Protection of the Company’s Image
1.10. Protection of the Confidential Information
1.11. Gifts and Hospitality

2. Employer
2.1. Equal Treatment among Employees
2.2. Diversity
2.3. Psychological (moral) and Sexual Harassment
2.4. Workplace Health and Safety

3. Environmental Commitments
3.1. The Environment
3.1.1. Reducing Environmental Impacts
3.1.2. Waste and Energy
3.2. Community
3.2.1. Involvement in Associations
3.2.2. Education and Training

Principles and Ethics

1. Our Values
arsaVev has forged a strong corporate culture built around four key values shared by all employees.

· Trust
We place our trust in our employees, in exchange for rigour and professionalism. We are committed to doing our best to be worthy of the confidence that our customers put in us and to offering them the best possible service that characterizes our brand image.
· Sharing
Mutual assistance and solidarity values are supported by a constructive and unifying team spirit that shapes our identity as a group. We promote knowledge management and experience sharing among employees, to continuously enrich our expertise.
· Daring
We encourage our employees to dare to take initiatives, acknowledging the right to make mistakes. Curiosity and critical thinking guide all our projects, as we believe that it is crucial to be able to continuously reinvent ourselves.
· Diversity
We attach particular importance to diversity, as our talents come from around the world, with a wide variety of backgrounds. We believe that diversity drives creativity, and we facilitate internal mobility to offer each individual a career path that suits their ambition and help them fulfil their potential.

2. Privacy Policy and Ensurance of Privacy
Independently of an obligation of respect and courtesy to all persons during operations, privacy policy includes not disclosing to others any information and documents related to the operations, customers, and suppliers of arsaVev.

Everyone is responsible for learning the company’s rules, particularly regarding the proper use of social media and information and communication technology. Employees must be treated with dignity and total respect for their privacy.

arsaVev undertakes to ensure the confidentiality and processing of its employees’ personal data in accordance with its internal policies and with regulations in force relating to the Data Protection Laws.

3. Integrity and Ethics
arsaVev strives to conduct its business in accordance with the principles of loyalty, integrity, equality, and fairness. It prohibits its employees and stakeholders from engaging in acts of corruption, profiting from corruption, engaging in anti-competitive behavior, or participating in money laundering operations.

4. Dealings with Suppliers and Customers
To maintain long-term supplier relationships built on trust, arsaVev is committed to treating them equally and fairly and, in return, expects reciprocity in terms of transparency.
arsaVev requires that its suppliers and intermediaries adopt ethical, environmental and societal standards, if not already the case, and comply with practices in line with its values.
arsaVev employees should serve customers with diligence, loyalty, neutrality and discretion. Customers are entitled to equal service. They should be given the best possible guidance and directed towards the most appropriate solution. Employees are committed to not proposing any options that they feel are not in the customer’s interest. Employees are responsible for performing the duties defined together with the customer with complete independence and transparency in compliance with rules specific to their business activity and refrain from putting their personal interests before those of their customer.

5. Prevention of and fight against Corruption
Corruption distorts the fair, orderly and efficient functioning of markets.
Whatever the prevailing circumstances and interests, the prevention and detection of corruption are essential for preserving arsaVev’s long-term interests. We all have a stake in this as we not only have a collective responsibility to not participate in corrupt acts but also a professional duty to do everything we can, to the extent of our ability, to prevent corruption or put an end to it if it is brought to our attention.

arsaVev strongly condemns corruption in its relations with all its stakeholders. The company prohibits its employees from accepting or paying money and from accepting or providing any benefit to its stakeholders.
arsaVev expects its employees to comply with this principle and ensures that all transactions are correctly recorded.
The involvement of an employee in a corrupt act constitutes professional misconduct that may trigger disciplinary measures, without prejudice to any legal action or administrative, civil or criminal sanctions.

6. Financial Documents
arsaVev agrees to provide accurate, honest, and clear financial information. Transactions and other accounting events are reported by arsaVev in the financial statements of each company in a true and fair manner in accordance with current regulations and internal policies.
Any transfer of funds (incoming and outgoing) requires special vigilance, particularly as regards the identity of the counterparty and the reason for the transfer.

7. Intellectual Property Protection
For arsaVev, intellectual property is an intangible asset that is essential to its innovative work. The group protects its scientific knowledge, patents, trademark, and products and conducts its research and development activities with complete confidentiality. It respects the intellectual property of its stakeholders by condemning any practices that could cause any harm.
Its employees do not use software or other computer tools whose user licenses were not obtained by the company.

8. Protection of the Company’s image
arsaVev shall protect its interests and reputation by asking its employees not to disclose any information on behalf of the company without having expressly obtained authorization.
The company stresses that its image greatly depends on the behavior of its employees and expects that its employees will not engage in any actions that denigrate another employee, a product, or the company through social media or other telecommunication means.

9. Protection of the Confidential Information
arsaVev attaches great importance to the protection of its sensitive data: we should all consider any information not made public as confidential.
Except where contractually permitted, no one is allowed to disclose such information to any person or entity (individual, company, corporation, association or other entity) for whatever reason both during the time they are employed by arsaVev and after their departure. Special attention should be paid to information that employees share on social media.

10. Gifts and Hospitality
Gifts exchanged between business partners are courtesies intended to establish and maintain positive working relationships.
Acceptance of corporate gifts and invitations to events or meals should fall within the scope of a business courtesy, remain within very reasonable limits, solely reflect a concern to improve relations with customers and suppliers without being such as to tarnish the image and reputation of arsaVev, its employees or senior management, whether inside or outside the Company.

2. Employer

1. Equal Treatment among Employees
arsaVev guarantees equal opportunity and treats each one of its employees fairly and respectfully. Gender equality is a key part of the equal opportunity policy. arsaVev is against any form of discrimination in this regard. Founded on human success, the company is committed to supporting the development of its employees.

2. Diversity
arsaVev considers the diversity of its talented employees to be a strength. The company supports diversity in Human Resources so that all employees can express their talents and thrive within the company. The company agrees not to discriminate regarding:
· sex and age
· health situation and disability
· family status, ethnic, social, cultural, or national origin
· sexual preferences and religious beliefs
· political or philosophical opinions

This non-discrimination applies both internally (during hiring and during decisions involving training and promotions) and externally (in our relations with stakeholders, including suppliers, customers, and business partners).

3. Psychological (moral) and Sexual Harassment
Harassment, whether it be sexual or moral, may violate the law and expose the offending employee and possibly arsaVev to legal, financial and reputational consequences.
Each one of us is entitled to respect and dignity. arsaVev has zero tolerance for any form of harassment and prohibits all forms of harassment including psychological and sexual harassment. We insist on respect and loyalty. Any behavior in violation of this principle that violates an individual’s dignity is unacceptable and any employee who has knowledge of or is the victim of such behaviors is asked to notify his/her manager.

4. Workplace Health and Safety
arsaVev, in its role as an employer, is committed to providing a work environment. We ensure that employees work in pleasant and respectful environments that complies with health and safety conditions and environmental laws and regulations. The company also ensures that its actions do not cause any risk to its employees or any other stakeholder.

1. Environmental Commitments

1.1. The Environment
1.1.1. Reducing Environmental Impacts
arsaVev is committed to preserving the environment and aims to comply with applicable standards and legislation. arsaVev seeks to reduce its environmental impact on a daily basis. This includes a zero-paper policy and recycling (paper, coffee grounds, etc.).
The company encourages travel by means of public transportation by reimbursing its employees for 100% of their transport pass expenses and is in a very easily accessible office location via public transportation.

1.1.2. Waste
On a daily basis, together with “office and computer equipment waste”, arsaVev produces waste nearly as much as a household. To implement a reduced impact policy, employees are instructed on sorting their waste.

1.2. Community and Involvement in associations
arsaVev is committed to the community. We support the empowerment of women

We are proud to be a signatory of the United Nations Women’s Empowerment Principles (WEPs), which promote gender equality and the empowerment of women in the business world and society, and to support the United Nations Global Solidarity Movement for Gender Equality, “HeForShe”, and through our sponsorships with sports clubs; Fenerbahce S.K. and Sheffield United Women Teams, we contribute each year to support women in basketball, volleyball and football.

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