OUR ANTI-BRIBERY AND ANTI-CORRUPTION POLICY

• Within the scope of the fight against bribery and corruption; it is our basic policy to comply with local laws in Turkey and all other applicable laws and regulations in all geographies where we operate or have business relations.

• Our company, its subsidiaries and foreign branches; take the necessary measures together with all its employees to act in accordance with the United Nations Global Compact (UNGC), the USA Foreign Corrupt Practices Act (FCPA), the United Kingdom Bribery Act (UKBA) and all applicable principles, sanctions laws and regulations published by the European Union.

• Our Company does not tolerate bribery and corruption in its relations with public/politically exposed persons and business partners during the execution of its activities.

• Our Company's senior anagement meticulously monitors and absolutely does not tolerate any activity by its employees that constitutes or encourages corruption and bribery.

• Our company evaluates its services and business partnerships with a risk-based approach and ensures that the necessary actions are taken to determine and reduce reputational, operational and legal risks. In these cases cooperation with institutions, organizations and individuals whose connections to bribery and corruption are detected is strictly prohibited.

• Our company does not engage in relationships with public/politically influential people and business partners in the form of direct or indirect payments, transfer of assets, gifts, entertainment, travel/hosting other than those defined in the contracts, making promises that provide benefits, etc. that encourage bribery and corruption.

• Our company complies with international trade sanctions laws, regulations and regimes on corruption and bribery issues and does not engage in any transactions that may result in sanctions.

This Policy will be published on the KOLİN İNŞAAT website to ensure that all our employees and business partners are informed.