1. Purpose

Esenyel & Partners Lawyers & Consultants ("Esenyel Partners") has established this Compliance Policy (the "Policy") as the cornerstone of its compliance programme (the "Programme"). The Policy sets out the minimum standards and guidelines through which Esenyel Partners identifies, mitigates and manages the legal, regulatory and reputational risks arising from bribery and corruption, breaches of economic and financial sanctions, and money laundering and the financing of terrorism, as well as the risks associated with entering into professional engagements with sanctioned, high-risk or otherwise prohibited persons and entities.

As a fundamental principle, Esenyel Partners is committed to conducting its practice in accordance with this Programme and to ensuring compliance with the Attorneys Act No. 1136, the professional and ethical rules of the Union of Turkish Bar Associations and the Istanbul Bar Association, the Law on Prevention of Laundering Proceeds of Crime No. 5549 and the secondary legislation of the Financial Crimes Investigation Board ("MASAK"), and the economic, financial and export-control regimes administered by the Republic of Türkiye, the United Nations ("UN"), the European Union ("EU"), the United States Department of the Treasury's Office of Foreign Assets Control ("OFAC"), the United Kingdom ("UK Sanctions"), and other relevant authorities.

This Policy is designed to safeguard compliance with national and international law, protect the reputation and independence of Esenyel Partners and its attorneys, manage counterparty risk, and enable a swift and effective response in the event of a potential or actual breach.