Anti-Bribery and Anti-Corruption PoIicy

1.1 Purpose
The purpose of Anti-Bribery and Anti-Corruption Policy (the Policy) is to disclose Anti-Bribery and Anti-Corruption policies contained in the Code of Business Ethics of Runitas Bilisim Teknoloji A.Ş. ("Runitas Bilisim").

1.2 Scope
Anti-bribery and anti-corruption policy covers:
• All Runitas Bilisim employees including the Board of Directors,
• Companies from which we outsource good and services and their employees, people and agencies working on behalf of Runitas Bilisim including consultants, lawyers, external
This Policy is an integral part of:
• Corporate Governance Principles approved by the Board of Directors and disclosed to the public and Code of Business Ethics of Runitas Bilisim,
• Principles which we have undertaken to comply with by joining the United Nations' Global Compact,
• Human Resources Codes of Practice

1.3 Definitions
Corruption is the misuse of the authority held due to the position for the purpose of gaining advantage directly or indirectly.
Bribery is a person's gaining advantage or providing advantages to others within the framework of an agreement reached with a third person so that such person acts in breach of the requirements of his/her duty by doing or not doing a work, speeding up or slowing down thereof, etc.
Bribery and corruption may occur in various different ways, among these:
• Cash payments,
• Political or other donations,
• Commission,
• Social benefits,
• Gift, hosting,
• Other benefits
can be mentioned.

1.4 Duties and Responsibilities
Implementation and updating of the Anti-Bribery and Anti-Corruption Policy are in the responsibility and duties of the Board of Directors. In this context, the followings are required:
• The Corporate Governance Committee is required to advice the Board of Directors for establishing an ethical, reliable, legal and controlled working environment,
• Senior management is required to evaluate risks and establish the necessary control mechanisms in compliance with the principles of Board of Directors,
• Internal Audit Department, Financial Regulations, Accounting and Legal Department and the Ethics Board are required to evaluate whether operations are carried out safely and in compliance with legal regulations within the scope of their duties,
• In case policies, rules and regulations are not complied with, report, review and sanction mechanisms must be determined and operated.
Moreover, all Runitas Bilisim employees are responsible for;
• Ensuring compliance with established policies of the Board of Directors.
• Effectively managing the risks associated with their business operations.
• Working in a manner consistent with the relevant legal regulations and the applications of Runitas Bilisim.
• Informing the Ethics Board if they encounter with a conduct, activity or application which are in breach of the Policy

1.5 The Companies from/to Which Good and Services are Bought and Sold and Business Partners
The companies from which goods and services are bought and to whom goods and services are sold and Business Partners must comply with the Policy principles and other relevant regulations. Relations with persons and institutions failing to comply these conditions shall be terminated.

1.5.1 Selection of Companies and Business Partners
In addition to criteria such as experience, financial performance and technical sufficiency, Senior Management takes into account morality and a positive background in this field during the selection of the companies from which goods and services are bought and to whom goods and services are sold and the Business Partners. The companies and the Business Partners which have a negative information with regard to bribery or corruption are not collaborated even if they meet other requirements. Responsibility for making necessary research and evaluation within this scope primarily belongs to senior management. Internal Audit Department evaluates in its controls whether such issues are complied with.

1.5.2 Selection of Companies and Business Partners
In contracts and agreements to be made with companies and business partners who have positive information and meet other criteria, the following conditions are included:
• Ensuring full compliance with the principles indicated in the policy and other relevant regulations,
• Employees' internalizing these principles and acting accordingly,
• Ensuring its employees to receive trainings about the Policy in certain periods,
• Reminding its employees regularly about notification obligations and the Ethics Line and encouraging them to notify in case they encounter such situations.
Provisions stating that relations will be terminated, in case these criteria are not complied with or in case a situation against the Policy occurs, need to be added in the contracts.

1.6 Our Policies and Procedures
1.6.1 Bribery and Corruption
Runitas Bilisim is against all kinds of bribery and corruption. Accepting bribes or bribing can never be accepted under any purpose.
Business relationships with 3rd persons wishing to get business from Runitas Bilisim through bribery or corruption have to be terminated.

1.6.2 Gift
A gift is a product generally given by customers or persons with which a business relationship is established as a means of thanking or commercial courtesy and which does not require a financial payment.
All kinds of gifts offered or given to third persons by Runitas Bilisim must be offered in public, with good faith and unconditionally. Principles regarding gifts which can be given within this scope and recording thereof have been made written in the Runitas Bilisim’s Code of Business Ethics under the Policy of "Giving and Accepting Gifts”.
The same principles apply for accepting a gift and no gift must be certainly accepted apart from the symbolic gifts included in these principles, with low financial value. In addition, even within this scope, gift acceptance must not become frequent and the Human Resource Department and Senior Management have to be informed about the gift by the employee who accept gift through his/her supervisor.

1.6.3 Facilitation Payments
The persons and institutions within the scope of this Policy must not offer facilitation payments to guarantee or speed up a routine transaction or process (obtaining authorization and license, obtaininga document, etc.) with government agencies.

1.7 Correct Recording
Issues which Runitas Bilisim must comply with in relation to accounting and recording system are regulated with legal regulations. Accordingly;
• All kinds of accounts, invoices and documents belonging to relations with third parties (customers, suppliers, etc.) must be recorded and kept in a complete, accurate and reliable manner.
• Falsificationanddistortion must not be made on accounting or similar commercial records related to any transaction.

1.8 Training and Communication
Our Anti-Bribery and Anti-Corruption Policy has been announced to employees of Runitas Bilisim and it can be continuously and easily accessed via "RUNPORTAL" portal.
Trainings are important instruments for increasing awareness of employees. Within this scope, Human Resource Group Presidency designs training programs together with Internal Audit Department and Financial Regulations, Accounting and Legal Department which are compulsory for all employees.

1.9 Antitrust and Competition
Runitas Bilisim compete effectively, only in areas that are legal and ethical, and avoid unfair competition.
Runitas Bilisim support all efforts to construct a competitive structure targeted within the society.

1.10 Dealing with Government
We execute all our domestic and international activities and procedures within the framework of the laws of the Republic of Turkey and international laws; and we submit all required information to regulatory authorities and institutions in a correct, complete, clear and timely manner.
In executing all activities and procedures, we do not expect any benefit from, and keep an equal distance to all public institutions and organizations, administrative bodies, non-governmental organizations, and political parties; and we fulfil our liabilities with a sense of responsibility.

1.11 Lobbying of Government Officials
Lobbying is generally any activity that attempts to influence laws, regulations, policies, and rules. In certain jurisdictions, however, the legal definition of “lobbying” can also cover procurement and business development activity. Runitas Employees are responsible for understanding when your activities may legally be considered lobbying in a particular jurisdiction and for complying with all applicable laws.
Nobody may not lobby government on behalf of Runitas Bilisim.

1.12 Trade Compliance Laws and Regulations
Runitas Bilisim requires that you comply fully with all applicable the Republic of Turkey and global trade laws and regulations. Failure to comply could result in the loss or restriction of your or Runitas Bilisim’s trade privileges. Violation of these laws and regulations may also result in fines and imprisonment. Runitas Employee are responsible for understanding how the global trade laws and regulations apply and for conforming to these laws to ensure no technology, data, information, program, and/or materials resulting from services (or direct product thereof)
will be imported or exported, directly or indirectly, in violation of these laws, or will be used for any purpose prohibited by these laws and regulations.

1.13 Notification of Policy Breaches
If opinion or suspicion exists that an employee or a person acting on behalf of Runitas Bilisim is acting in breach of this Policy, the issue must be submitted to the Ethics Board. Codes of Business Ethics of Runitas Bilisim are reminded to employees of Runitas Bilisim in certain periods.
Runitas Bilisim encourages an honest and transparent approach; supports any employee or person acting on behalf of Runitas Bilisim who expresses his/her sincere concerns with good faith, and keeps notifications secret. None of the employee shall be subject to pressure or punishment for the notification of the Ethics Board about a violation of the Code of Ethics, the scope of the duties or place of job shall not be changed for this reason without written consent of the Ethics Board.
In case the notifying person is subject to such treatment, he/she is expected to notify this to the Ethics Board.
The companies and Business Partners from which goods and services are outsourced are also expected to remind their employees about the Ethics Line on a regular basis and encourage them to notify in case they encounter such situations. This issue is also guaranteed with the contracts made.

1.14 Policy Breaches
In cases which are or could be in breach of the Policy, the matter is reviewed by the Ethics Board and necessary sanctions are implemented if inappropriate acts are detected.
In contracts made with the companies from which goods and services are bought and to whom goods and services are sold and with persons and institutions carrying out duties on behalf of Runitas Bilisim, the provisions stating that if conducts, attitudes or activities in breach of Policy are detected, business will be terminated,need to be included and in case of breach of policy business shall be terminated.