Ethical Principles

1. OBJECTIVE

The objective of this procedure is to describe the ethical principles that must be adopted by the employees of Doğuş Construction.

2. METHOD

2.1. Basic Principles

To work like a family towards common objectives by adopting company vision and mission.

The principles of “respect for human”, “respect for the environment” and “respect for the work performed” are irreplaceable for each employee of the Company regardless of their level.

No concessions can be made from the merits of honesty, faithfulness, transparency and equality under any circumstances.

All activities ground on legal legislations, articles of incorporation, regulations and policies.

2.2. Business Ethics and Conducts

2.2.1. Protection of Corporate Reputation

Each employee aims the best quality performance and acts consistent with the interests of the Company. They keep in mind that each step they have taken in their professional lives represents the Company and avoid acts and speeches that may cause to corporate reputation damage.

2.2.2. Confidentiality

Preservation of Corporate Data

Employees can not share confidential and non-public data that belongs to the Company with unauthorized people for any reason. If the employee has a doubt about the confidentiality of the data, the opinion of the senior manager must be taken. It is significant not to leave confidential documents apparent on tables. Passwords have to be carefully kept confidential and confidential data should not be revelead in public areas such as elevators and refectories. Also, former employees can not disclose any confidential data to third parties which belongs to the Company, and they can not hold these against the Company.

Personal Data

Personal data of the employees are confidential and can not be revealed to anyone other than the authorized. Personal data of the employees are sent to themselves privately. Employees who receive documents containing private data of themselves read it and hide it to avoid other people to see it or never reveal it to other people. False charge and gossipping about people and institutions are not appreciated/allowed and disciplinary actions are taken against the employee who is engaged in these kind of activities.

2.2.3. Time Management and Sourcing

Employees are liable to perform business related works during office hours. Private matters can not be followed up during office hours. Company assets can not be used for personal purposes. Time and sources are used within the direction of corporate principles in consideration of the policy of “respect for the environment” in a cost conscious manner directed towards saving and in the most effective way.

2.2.4. Internet Access and Electronic Mail

Internet access and electronic mails that are allocated to employees can only be used for business purposes within the framework of data safety policy. Internet access can be limited by company resolution. Web sites that are illegal or make political propaganda or inconsistent with moral values or include games and entertainment content should not be accessed by employees.

2.2.5. Relations with Third Parties

Relations with Customers, Subcontractors and Other Third Parties

The Company assesses the firms, subcontractors and other third parties which it will establish business affairs and selects the ones in the direction of equality principle that will provide the best service consistent with the Company’s interests. No personal relations can be established with these firms and people as well personal interests may never be pursued.

Gifts and Discounts

Employees neither can directly or indirectly accept gifts nor can accept private discounts or loans from the firms and people whom the Company has business affairs with. Agendas, gift baskets or gifts like chocolates sent for the New Year are not considered within this scope. However, if aforementioned gifts are provided with a high cost, Ethical Committee is notified about this matter and they are assessed accordingly.

Relations with the Media

Before sharing any information with the media regarding to the Company and its projects, employees must receive the approval of Top Management. They should refrain from any kind of statements or acts that may cause negative assessments or speculations about the Company. It is subject to the approval of Top Management to make decisions on whether to make statements and interviews with broadcasting organizations, participate in seminars and conferences as a spokesman and decide whether to charge relative parties for those services.

2.2.6. Activities that May Cause Conflict of Interests

Company employees may only establish business relations with their spouses, relatives and friends within the knowledge of the Board of Directors. They could make speeches on the issues that are not against company policies and not related to the Company, and could write professional articles within the borders of aforementioned principles. The Company is not obliged to support these activities. Written approval of Top Management is required in order to be able to articulate the Company name for these matters. Company employees could provide financial and inner support to third parties in external institutions as well donate and participate in charities.

2.2.7. Political Activities

Company employees can not provide financial or inner support to any political act on behalf of the Company even if he has the financial means to give that support. Company employees can not actively participate in any political party during their term of office. Executives can not require from their employees to perform a political duty or become a member of a political party. Employees can not form their way of dressing or image in the direction of a political ideology.

2.2.8. Professional Misconduct

Professional misconduct is defined as the damage given to the Company by an employee through a behaviour outside the bounds of what is prescribed in the moral, ethical and professional code of conduct, as a result of satisfying his personal interests. It is strictly forbidden to obtain personal gain directly or indirectly from the activities (such as purchasing) of the Company or from other transactions and contracts in which the Company appear as a party.

2.2.9. Mobbing

Behaviours, manners and contacts that are against moral rules and legislation, sexual overtures by an employee by using his/her authority towards another employee without the will of the latter, discriminations on religion, language, race or gender and sexual harassment are assessed within the scope of mobbing.

3. LIABILITIES

Incidents, attitudes and behaviours that are inconsistent with Ethical Principles adopted by the Company are notified to the Ethical Committee (etik@dogusinsaat.com.tr) and these notifications are strictly kept confidential. Necessary actions are taken with the support of Top Management within the direction of the assessment by the Ethical Committee. Disciplinary actions are taken against disorderly conducts.