Code of Ethics and Code of Conduct

Subject and Scope

Code of ethics consists of the principles that the employees of our company must comply with when fulfilling their duties, as well as the working order related principles. The objective of those principles is to establish a general framework of the basic rules that need to be complied with, and to prevent any disagreements and conflicts of interest which may arise between employees, business partners, customers, and our company.

Basic Principles

Managers and employees must comply with the basic principles set forth in this document hereby in all their affairs and businesses, and must do their best to maximize the reputation of the Doğan Group and its shareholders. Our employees must act as per the principle of care and loyalty in situations and under conditions not covered by this code.

The Code of Ethics has been presented under three main headings:

• Conflicts of Interest
• Relations with Stakeholders
• Flow of Information