Measures to Ensure Confidentiality of Inside Information Until It Is Disclosed to the Public
As a general principle, those working on behalf of the Company cannot share any information that has not yet been disclosed to the public and that may be considered as a special situation with third parties under any circumstances. If it is determined that inside information has been disclosed to third parties without their consent, and if it is concluded that the confidentiality of the information cannot be ensured within the scope of capital market regulations, a special situation disclosure is made immediately. If the disclosure of the information is postponed, a list of the persons who have the information in question is drawn up at the time of the postponement decision and the “List of Persons with Access to Insider Information” is updated within this scope. Necessary efforts are made to inform both these persons and the parties who have information other than these persons, and reasonable measures are taken. The persons included in the list of those who have access to the said insider information are informed by the investor relations department that they are on the list in order to protect the insider information and ensure that they comply with the confidentiality rules until the public disclosure of the special situations, financial and operational results. The Company signs confidentiality agreements with institutions that need inside information while performing their duties or use this information on behalf of the Company, or from which it receives services such as consultancy and translation services, and obliges these institutions to keep the information in question confidential. The Company takes all necessary measures to ensure the confidentiality of inside information in accordance with the relevant legislation.