ETHICAL PRINCIPLES AND ANTI-CORRUPTION

Vestel Elektronik Sanayi ve Ticaret AŞ (“Vestel Elektronik”) and Vestel Beyaz Eşya Sanayi ve Ticaret AŞ (“Vestel Beyaz Eşya”) stipulate that the Global Principles they have signed “must fight against all forms of corruption, including extortion and bribery”. They effectively operate their processes regarding the 10th article stating that The following tools are used to combat corruption:

1. Zorlu Holding’s Ethical Principles: Ethical Principles that is applicable to Zorlu Holding and all its Group Companies is in harmony with company policies, values and principles and includes all Zorlu Group employees, members of the Board of Directors, suppliers and business partners, intermediaries, contractors, proxy workers and all third parties with whom business is made.

Employees and all third parties acting on behalf of Zorlu Group should show due care and diligence; It is essential that they do not gain unfair advantage from individuals and organizations for any purpose, do not offer, receive or give bribes or commissions, and prevent such actions from being made to the extent of their knowledge. When such an offer is encountered, observations or doubts arise about it, the situation should be reported to the manager and/or to etik@zorlu.com.

All employees and stakeholders can send an e-mail to the Ethical Principles Hotline (etik@vestel.com.tr, etik@zorlu.com) or call 0 212 456 23 23 or 0 850 226 23 23 at any time of the day to report or consult on nonconformities they encounter on ethical issues.

The information regarding the violation of the Ethical Principles is evaluated by the Zorlu Holding General Directorate of Audit. Necessary studies, examinations or investigations regarding complaints, claims and notices reaching the Violation Notification Hotlines are carried out by the Internal Audit Investigation Department under Zorlu Holding General Directorate of Audit.

2. Zorlu Holding Internal Audit Mechanism: As is the case for all Zorlu Group Companies, the internal audit of the Vestel Group of Companies is carried out by the centralized Internal Audit Department operating within Zorlu Holding. Process audit activities are carried out in line with a board-approved, risk-based annual audit program to evaluate the effective and efficient use of resources, adherence to written rules (laws, regulations, internal policies and directives), and the accuracy, security and reliability of information.

3. Third-party Audits: Vestel Elektronik and Vestel Beyaz Eşya are subject to independent audits as they are publicly traded companies. Currently, the financial statements and accounts of the companies are audited by KPMG Free Independent Auditing and Accountant Mali Müşavirlik AŞ. The tax (Full Certification) audit of the companies is carried out by Arılar Independent Auditing and Yeminli Mali Müşavirlik AŞ.

4. Information Security Management System: Vestel Elektronik and Vestel Beyaz Eşya have established and operated the ISO 27001 Information Security Management System (“ISMS”) since 2013. With ISMS, it is aimed to ensure information security, increase physical security, prevent unauthorized persons from accessing unauthorized areas/subjects, and prevent information security violations.

5. Anti-bribery and corruption: Zorlu Holding Ethical Principles have been designed to include issues related to the fight against bribery and corruption and are open to all stakeholders on the website. Employees are also provided with in-house training. Our other important resource in the fight against bribery and corruption is the Global Compact Progress Reports, which are available to all our stakeholders online. In addition, these topics are covered periodically in Zorlu Magazine, which is published periodically.

6. 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.