Our disclosure policy created by the Board of Directors pursuant to Article 17 of the Communiqué Series II-15.1 on Material Events is as follows.

1- General Framework of our Disclosure Policy:

Our disclosure policy has been created in accordance with the Capital Market Legislation, Borsa Istanbul regulations, the principles set forth in the Corporate Governance Communiqué and the code of ethics of our Company.

The main purpose of the disclosure policy is to share with the public, relevant authorities, shareholders and stakeholders the necessary information and explanations, past performance, future expectations, strategies and vision of our Company except its trade secrets.

Our disclosure policy is based on the principles of openness and transparency, and investors, shareholders and all other stakeholders are equally, fairly and appropriately informed.

2- Authority and Liability:

The authority and liability of creation, monitoring, surveillance and improvement of the disclosure policy of our Company shall rest with the Board of Directors. The Financial Affairs Presidency Office and Investor Relations Departments have been appointed for the implementation of the disclosure policy.

3- Manner of Public Disclosure of Information:

The public disclosure policy shall be implemented via the following means and methods in accordance with the Capital Market Legislation, Borsa Istanbul Legislation and the provisions of the Turkish Commercial Code.

a) Material Disclosures: Material disclosures are prepared within the framework of "Communiqué Series II - 15.1 on Material Events" of the Capital Markets Board, are signed by the managers having signature authority, and are disclosed to the public via Public Disclosure Platform (KAP). In addition, material events shall be published on the Company's website and be retained for 5 years.

b) Annual Reports: Annual reports are prepared in accordance with the Capital Market Legislation, Turkish Commercial Code and Corporate Governance Principles, and are subjected to the approval of the Board of Directors. Our Company's annual reports are published in both Turkish and English, and are submitted for the examination of investors at the company headquarters and on the company's website. They are served to those who cannot come to the Company headquarters either in electronic environment or by mail upon their request.

c) Interviews and Press Releases: The Group Executive President discloses to the public the annual information and expectations related to future periods via printed and visual media after the Company's annual ordinary general assembly meeting. In addition, all written and visual media releases and interviews related to the commercial activities of the group companies of the Company and current issues shall be made by the General Managers within the knowledge of the Group Executive President. Besides, releases to be made in the form of press releases shall be prepared by the Head of the Department of Investor Relations of our Company, and be distributed in accordance with the principles of disclosure policy.

d) Website: Clear and detailed information on our Company is provided on the existing website of our Company, www.alarko.com.tr. You can find information on our website via the links provided in Article 9 of the Section II of the "Report on Compliance with Corporate Governance Principles" available on page "Investor Relations" on the website.

e) Public Disclosure of Financial Statements: The financial statement of our Company and its footnotes are prepared in accordance with the provisions determined by the Capital Markets Board, and are subjected to independent audits. Financial statement, its footnotes and the independent audit report are submitted for the approval of the Board of Directors upon approval of the Committee in Charge of Audit. The financial statements, its footnotes, independent audit report and liability statement approved by the Board of Directors are communicated by the Department of Financial Affairs to the Capital Markets Board and BIST via the Public Disclosure Platform (KAP) in line with the CMB and BIST regulations after the authorized signatures are obtained. Financial statements and their footnotes are also published on our website.

f) Trade Registry Gazette and Other Gazettes: Pursuant to the Capital Market Legislation and the Turkish Commercial Code, announcements such as general assembly invitations, share capital increases, dividend payments, prospectuses, circulars, etc. shall be made via the Trade Registry Gazette and other gazettes.

g) Information of the Investors and Intermediary Institution Analysts: The explanations, presentations and reports made during the promotion meetings, information meetings or press meetings held with a particular group of investors or intermediary institution analysts are also published on the website and kept available for access by everyone.

h) Written and Verbal Requests: The Department of Investor Relations has been appointed for the observation of all kinds of issues and answering the questions asked to the Company for public disclosure. All written and verbal questions asked to the Company within the year are responded by this unit, and the Board of Directors is also informed on the questions asked and their answers.

i) News and Rumors Related to the Company: The Department of Public Relations of the Company follow-up daily coverage from the written and visual media. News related to the Company are reported to the senior management every morning, and the content of the news is checked.

If a decision is made for making a public disclosure related to the news and rumors reported by the media-press but which do not lead to the obligation to make material disclosures, material disclosure shall be made upon the approval of the Group Executive President.

4- Criteria Used for the Designation of People with Administrative Liability:

People who act in the name and on behalf of the Company and who are authorized to make management decisions that have an impact on the development and commercial operations of the company, people who have detailed information on the issue, and Members of the Board, Group Executive President, General Manager, Group Presidents, Assistant to General Managers, Directors, Manager of Department of Law, Chief Financial Officer, Investor Relations Department, Consolidation Manager and other managers and experts involved in financial reporting may access the Company's insider information, and are thus considered to be employees.

Managers and other employees who have information on some of the Company affairs because of their job and whose general information is limited shall not be considered to have access to insider information.

5- Ensuring the Confidentiality of Insider Information:

Such information shall be ensured to be kept confidential until the public disclosure of the material events in line with the code of ethics approved by the Company Board of Directors and the Audit, Advisory and Approval Board and set forth in the Philosophy of Alarko Group of Companies. Pursuant to the code of ethics that should be observed by all employees, employees shall be obliged to take all necessary measures for keeping insider information confidential. In this connection, no Alarko employees may engage in any activities to derive profits by the trading of shares on the basis of insider information.

The supervisors shall follow-up in an hierarchical organization whether the employees observe the code of ethics. If any conduct is determined which is in violation of the code of ethics, the employees shall be obliged to inform the management immediately. The Board of Directors shall examine the violations that are reported, known or suspected by the Committee in charge of Audit, Group Executive President and other relevant managers, or have the Audit Group examine the same when necessary, and ensure compliance with this code of ethics. If the violation is obvious, necessary disciplinary measures shall be taken.

6- Disclosure of Forward-Looking Evaluations:

The Board of Directors makes disclosures about the forward-looking evaluations in annual reports. In case of new developments within the year about the evaluations made, additional disclosures are made in the relevant annual report for the interim period. In case of important developments on the issue, material disclosures are made.