FCR Real Estate Investment Partnership Inc.

Purpose and Scope

FCR GYO undertakes to fulfill its responsibilities towards its stakeholders by adhering to ethical principles and business ethics in all areas in which it operates. This ethical rules and business ethics directive is a guide for company employees, board members, business partners and all stakeholders. The directive specifies in detail the rules to be followed in decision-making and implementation processes in business processes.

1. Honesty and Transparency

• FCR GYO is committed to the principle of honesty and transparency in all business relations.

• Clear and understandable information sharing is ensured in relations with customers, employees, shareholders, suppliers and the public.

• All kinds of misleading information, documents and behaviors are avoided.

2. Compliance with Laws and Regulations

• The Company fully complies with national and international legal regulations, the Capital Markets Legislation, the Turkish Commercial Code and all other relevant legislation.

• Tax, environment, occupational safety, consumer rights and competition rules are fully complied with.

• An ethical, transparent and law-abiding attitude is displayed in relations with public institutions.

3. Prevention of Conflict of Interest

• Employees and managers avoid activities that will conflict with company interests and their personal interests.

• When any situation that may cause a conflict of interest is detected, the relevant person immediately reports it to the upper management.

• Persons acting on behalf of the company perform their duties impartially.

4. Confidentiality and Information Security

• Confidential information of the company, customers and business partners is protected; this information is shared only with authorized persons.

• Persons authorized to access internal information cannot use this information without being disclosed to the public, share it with third parties or use it for their own benefit.

• The company's digital security measures are regularly audited and improved to ensure information security.

5. Business Ethics and Professionalism

• All employees and managers perform their duties in a fair, impartial and professional manner.

• Fair competition principles are followed in supplier selection and business processes.

• Contractual commitments are fulfilled on time and completely.

6. Social Responsibility and Environmental Awareness

• The company supports social responsibility projects and carries out activities that will contribute to society.

• Technologies that do not harm the environment and sustainable business models are adopted.

• Efficient use of natural resources is ensured by acting with environmental protection awareness.

7. Human Rights and Employee Rights

• A zero tolerance policy is adopted against race, language, religion, gender, age and other types of discrimination.

• Equal opportunities are provided to employees; evaluations are made based on talent and performance.

• A safe, healthy and productive working environment is provided.

8. Combating Corruption and Bribery

• The company implements a zero tolerance policy against bribery, corruption, money laundering and all kinds of unethical behavior.

• Employees and managers act in accordance with legal and ethical values ​​in business processes.

• Audit mechanisms are implemented in accordance with relevant legislation and international standards.

9. Communication and Stakeholder Relations

• The company maintains open, respectful and constructive communication with all its stakeholders.

• Customer satisfaction is a priority and customer complaints are resolved quickly.

• Fair competition conditions are ensured in relations with suppliers.

10. Public Disclosure and Transparency

• The company provides accurate, understandable and timely information about its financial performance and activities.

• The Capital Markets Legislation and CMB regulations are complied with in public disclosures.

• General Assembly meetings are held within the framework of the principle of transparency.

11. Monitoring Compliance with Ethical Rules

• Regular internal audit mechanisms are established to ensure the implementation of ethical rules and to detect violations.

• Employees and managers are obliged to act in accordance with these rules.

• In the event of a violation of ethical rules, necessary sanctions are applied in line with company policies and legal regulations.

12. Complaint and Notification Mechanism

• Employees, managers and stakeholders have a secure mechanism through which they can report ethical violations.

• Notifications made are evaluated and resolved within the framework of the principle of confidentiality.

13. Ethics Committee

• The Company establishes an Ethics Committee to evaluate violations of ethical rules and produce solutions.

• The Ethics Committee examines complaints and violations, makes recommendations and makes decisions.

14. Enforcement and Update

• This Ethics Guideline shall enter into force on the date it is approved by the Board of Directors.

• It may be updated by the Board of Directors in line with evolving needs and legislative regulations.

FCR GYO aims to add value to all its stakeholders by conducting its activities in accordance with ethical rules. This guideline is a guide to ensure that our employees and business partners comply with ethical principles.