ANTI-CORRUPTION

Vestel Elektronik Sanayi ve Ticaret AŞ (“Vestel Elektronik”) and Vestel Beyaz Eşya Sanayi ve Ticaret AŞ (“Vestel Beyaz Eşya”) effectively execute the processes for the implementation of the 10th Article of the Global Compact, to which they put their signature through Zorlu Holding. The Article stipulates companies to fight against all kinds of corruption including defalcation and bribery. Following instruments are utilized for fighting against corruption:

1. Zorlu Holding internal audit mechanism: Senior management is responsible for informing the Internal Audit Department immediately in case of any suspected or revealed corruption, a situation or any irregularity/violation that may put the Company under legal and financial obligation. Thus, the Internal Audit Department functions as an independent audit mechanism which supervises the financial, administrative and technical activities of all companies under the Group on behalf of the Board of Directors. It also performs routine audits.

2. Audits by independent auditors: As Vestel Elektronik and Vestel Beyaz Eşya are publicly listed companies; they are subject to independent auditing. Currently, the Companies’ financial statements and accounts are audited by PwC Serbest Bağımsız Denetim ve Muhasebeci Mali Müşavirlik AŞ. Tax Audit (Full Confirmation) of the Companies is conducted by Arılar Bağımsız Denetim ve Yeminli Mali Müşavirlik AŞ, which is a Chartered Accountant Company.

3. Information Security Management System: Vestel Elektronik and Vestel Beyaz Eşya established the ISO 27001 Information Security Management System in 2013. With the help of this system, the Companies aim to ensure information security, improve physical security, prevent access of unauthorized people to unauthorized areas/subjects and prevent violations of information security.

4. Anti-bribery and corruption: Our most important resources in our fight against bribery and corruption are ‘Vestel Code of Ethics’, which was prepared for our employees and suppliers and shared with all our employees and suppliers and the Global Compact Progress Reports, which are open to our stakeholders over the internet. Additionally, these subjects are discussed on a regular basis in the Zorlu and VS magazines that are published periodically.

5. Vestel takes as a principle not to be included in any political initiative and not to provide any material or moral support to political parties or figures. Vestel does not have any other relations with public authorities of countries where it operates, apart from the commercial and social responsibility projects.