BVN ETHICAL PRINCIPLES PROCEDURE

INTRODUCTION

Ethical Principles; includes the principles that BVN employees must comply with while performing their duties and the regulations regarding the working order. The purpose of these principles is to prevent any disputes and conflicts of interest that may arise between employees, customers and the company.

Attitudes and behaviors that violate these rules will be evaluated in accordance with the disciplinary regulation, and our expectation from our employees is that they act according to common sense and good faith in situations and conditions not covered by these rules.

In line with the principles of business ethics, our employees;

·       Must act with dignity, honor and honesty in all business relations.

·       Must avoid any personal behavior and attitude that will damage the reputation of BVN while fulfilling their responsibilities.

·       Must know the relevant laws, regulations and regulations in detail and adhere to them in matters related to their duties.

·       Never disclose information that is not open to the outside world to third parties other than those who need to know it.

·      Follow, review and act in accordance with the orders, regulations, procedures and instructions to be issued regarding the regulation of working conditions and the maintenance of work discipline.

·      Report any known or suspected violations of rules to the attention of the manager or the Human Resources Department before taking any personal measures.

·      Always be appropriate for the work environment, plain and stylish, and absolutely avoid wearing sports or evening dresses that are incompatible with the seriousness of the company and clothes that express social views.

·      Not act contrary to general morality and the moral behaviors accepted in society at BVN.

·      Take care to protect the environment in the transactions it carries out, whether or not it is regulated by law.

·      Always prioritize product safety, regardless of cost; and the satisfaction of internal and external customers.

Department managers or unit managers are primarily responsible for employees’ compliance with the rules set forth in these principles.

PART I.

CONFLICTS OF INTEREST

MAIN PRINCIPLE

Our employees cannot use their duties and authorities at BVN in any way to provide personal and private benefits for themselves, their families or third parties.

1) PROHIBITION ON PAYMENT/ACCEPTANCE OF GIFTS

Our employees cannot request or accept any personal payments or gifts from third parties doing business with BVN and cannot engage in behaviors that would suggest such.

2) GIFTS TO BE GIVEN TO CUSTOMERS

Our employees cannot make any bribe, commission or similar payments to any person or organization that may be a customer, regardless of how much they may lose, and cannot work with intermediaries that they feel can make such payments.

It must be ensured that gifts to be given to customers will not create a conflict of interest between the parties. In this context, the following rules have been determined for gifts to be given.

·      Gifts can be given to customers in accordance with the principles determined by BVN at the end of the year or on special days.

·      No monetary payments can be made in any form or amount.

·      Gifts given must not have the purpose of influencing the other party regarding any business or agreement in which BVN is involved.

3)     CORPORATE PAYMENTS, PERSONAL DONATIONS AND RELATIONSHIPS WITH POLITICAL INSTITUTIONS

No corporate or personal payment, aid or donation, gift can be given to any government official or political party candidate in order to influence any decision regarding the continuation of BVN’s activities or that may be in BVN’s interest. Political meetings and demonstrations cannot be attended in a way that represents BVN.

4) ADDITIONAL WORK

Our employees must definitely obtain the written approval of the Human Resources Department when there is a training, consultancy or similar position that requires them to be paid.

However, our employees may engage in voluntary activities (such as legally established charities, associations or non-governmental organizations, etc.) that do not disrupt their duties and responsibilities in the company.

5) POWER OF ATTORNEY AGREEMENTS WITH CUSTOMERS

Employees cannot directly or indirectly accept inheritances or wills from customers (unless they are close relatives or family members). Except for portfolio management transactions, they cannot assume the duty of a legally authorized guardian to represent the customer and cannot act as proxy for the customer, and cannot assume a power of attorney that will give them authority over the customer’s accounts.

6) PERSONAL INVESTMENTS

While directing their personal investments, our employees cannot make personal investments with stocks or other investment instruments of companies that would create any possible conflict of interest with their duties and responsibilities at BVN. Furthermore, they cannot in any way attempt to gain immoral benefits from our sales or other commercial transactions, whether legal or not.

PART II.

THE RULE REGULATES THE FLOW OF INFORMATION