Anti-Bribery and Anti-Corruption Policy

Introduction: KALE AIR HAVACILIK SAN. VE TIC. A.S. (hereinafter referred to as “Company”) is committed to conducting its business with integrity, transparency, and ethical values. Accordingly, we have established this policy to combat bribery and corruption, ensure compliance with legal and ethical obligations, and promote a culture of honesty and accountability.

Purpose of the Policy: The purpose of this policy is to define the responsibilities of the Company’s employees, partners, suppliers, and other stakeholders regarding the fight against bribery and corruption, and to take the necessary measures to prevent, detect, and report such activities.

Scope: This policy applies to all employees, managers, business partners, suppliers, and any other third parties acting on behalf of the Company.

Definitions:

• • Bribery: Offering, giving, receiving, or soliciting something of value for the purpose of influencing the actions of an official or other person in discharge of their duties.
  • Corruption: The abuse of entrusted power for private gain, which can occur in both public and private sectors.

Principles:

• • The Company does not tolerate any form of bribery or corruption.
  • Employees must conduct their business with honesty and transparency, complying with all legal and ethical standards related to anti-bribery and anti-corruption.
  • Suppliers and business partners are expected to adhere to the Company’s policies in this regard.

Responsibilities:

• • Board of Directors: Responsible for implementing the anti-bribery and anti-corruption policy and providing necessary resources.
  • Employees: Obligated to comply with the policy and promptly report any suspicious activities.
  • Internal Audit Department: Ensures the effective implementation of policies and conducts periodic reviews.

Reporting and Whistleblowing: Employees and other stakeholders must immediately report any suspicious activities related to bribery and corruption to the Company’s ethics hotline or internal audit department.

Training and Awareness: The Company will organize regular training and awareness programs on anti-bribery and anti-corruption for employees and relevant stakeholders.

Sanctions: Disciplinary actions will be taken against individuals who violate this policy, and necessary legal procedures will be followed.

Review of the Policy: This policy will be periodically reviewed and updated according to changes in legal regulations and Company needs.

Approval: This policy has been approved and enacted by the Executive Board Member & General Manager.