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Sustainability

Code Of Ethics

To ensure that Ethics Principles are understood and embraced by all employees, we trained 31% of our employees with one hour of training per person, which totaled 3,216 hours.

The Enerjisa Code of Conduct (Enetik) sets a common framework in all business processes. All Enerjisa employees pledge to follow this framework, which defines the foundation of our business practices. The Enerjisa Code of Conduct covers various essential ethical principles concerning but not limited to respect for human rights and environmental protection, creating sustainable relationships including anti-bribery and anti-corruption as well as fair competition, protection of personal data and privacy; protection of corporate information and assets, the principles concerning written and visual media and social media, conflicts of interest, political activities, association memberships, the acceptance and payment of money, gifts and donations, external duties, dress code, working with relative and Occupational Health and Safety. To ensure that Ethics Principles are understood and embraced by all employees, we trained 31% of our employees with one hour of training per person, which totaled 3,216 hours.

The Ethics Committee and Compliance Management Unit are responsible for the implementation of Enerjisa Code of Conduct. Compliance Officers guide employees proactively in this respect. In addition to ensuring that Enerjisa Code of Conduct is universally embraced, Compliance Management Unit monitors and informs employees about issues that may cause violation of the Enerjisa Code of Conduct. It also supports the Internal Audit with respect to violations therof.

All employees and stakeholders of Enerjisa can report cases of non-compliance with or violations of the Code of Conduct to Enerjisa Enetik via various channels. Email: ENETİK@enerjisa.com, ethics notification form at www.enetik.enerjisa.com, by phone: +90 (216) 579 09 14, by fax: +90 (312) 573 55 55, or by mail: P.K. 2 06510 Emek/Ankara. You can also notify us via the Sabancı Holding ethics line. The head of the Internal Audit Department is the only person authorized to access notifications and is responsible for the security, confidentiality and management of all notification channels. Thoroughly examined notifications are reported to the executive management and the Disciplinary Board when deemed necessary. The Audit Committee is informed about notifications reported to the Disciplinary Board. In 2019, we received 102 notifications and resolved all of them.

Risks related to the violation of ethics are obtained from relevant units in qualitative risk assessment, performed twice a year and reported to the Early Risk Detection Committee or the Enerjisa Risk Management Committee. At the beginning of each year, we assess the risks that might arise from the violation of ethics with the Backtesting study, during which we assess the performance of the previous year’s risk reports. We examine the reported expectations and their probability and effects.

You can access the Enerjisa Enerji Ethics Policy here.

We manage anti-bribery and anti-corruption cases considered under the Enerjisa Code of Conduct with the Policy binding upon all employees and stakeholders. The Ethics Committee and the Compliance Management Unit have specific duties to prevent and end all types of bribery and corruption. All sanctions imposed for a violation of ethics also apply for bribery and corruption. The online ethics training for our employees includes anti-bribery and anti-corruption training.

In 2019, we received 56 notifications regarding bribery and corruption via our ethics channels. We resolved all these notifications. After evaluations, 52 employees were faced with disciplinary action. There is also one ongoing public prosecution concerning corruption.

You can access Enerjisa Anti-Bribery and Anti-Corruption Policy here.

INTERNAL AUDIT

The Internal Audit Department conducts all audit actions to ensure that Enetik, our corporate standards and our business applications are followed in all business processes. The Internal Audit Department reports directly to the Audit Committee, which is composed of independent members of the Board of Directors. The internal audit plan that defines the framework of audits is updated annually upon the approval of the Audit Committee and the Board of Directors.

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