FCR Real Estate Investment Partnership Inc.

1. Purpose and Scope

As FCR GYO, we are committed to conducting all our activities in accordance with ethical rules, legal regulations and international standards. This policy sets forth our zero tolerance approach to bribery and corruption, and provides binding rules and application principles for our employees, managers, business partners and all stakeholders.

This policy covers company employees, board members, suppliers, contractors, consultants, business partners and other third parties.

2. Definitions

2.1. Bribery:

A person providing, offering, requesting or accepting a material or moral benefit in return for doing or not doing a job related to his/her duty. This benefit may be direct or indirect.

2.2. Corruption:

The abuse of authority, duty or responsibility for personal gain. This may include providing financial gain or gaining unfair advantage.

2.3. Facilitation Payments:

Small-scale payments made to speed up or secure official processes. As FCR GYO, we strictly prohibit such payments.

2.4. Gifts and Entertainment:

Includes any transfer of material or moral value intended to influence business relations or provide an advantage.

3. Policy Principles

3.1. Legal and Ethical Compliance:

• All our activities are carried out in accordance with the Turkish Penal Code, the Capital Markets Law and international anti-bribery and anti-corruption regulations.

• Ethical values ​​are prioritized in business relations and all kinds of bribery, corruption and conflicts of interest are prevented.

3.2. Zero Tolerance in Combating Bribery and Corruption:

• A zero tolerance approach has been adopted in combating bribery and corruption.

• Company employees, managers or business partners are prohibited from providing, offering or accepting any benefit, directly or indirectly.

3.3. Transparency and Accountability:

• Transparency is the basis for all business processes and recorded transactions are open to audit.

• Employees and managers are responsible for fully fulfilling their obligations regarding the fight against bribery and corruption.

4. Application Areas

4.1. Gifts and Entertainment:

• Before accepting any gift or entertainment offer offered by business partners or third parties, employees must evaluate the compliance with company policies.

• Corporate gifts of low value may be accepted, provided that they do not harm commercial relations. However, these gifts must never be of a nature that will influence business decisions.

4.2. Facilitation Payments:

• Any payment made to accelerate or facilitate official processes is prohibited.

• In the event of such a request, the situation must be reported immediately to the relevant unit and senior management.

4.3. Donations and Sponsorships:

• Donation and sponsorship activities are completely transparent and recorded.

• Donations are made only in education, health, culture and other areas that benefit society and have no political purpose.

5. Training and Awareness

5.1. Training Programs:

• Regular training is provided to all employees on combating bribery and corruption.

• Training ensures that employees recognize bribery and corruption risks and implement appropriate action plans.

5.2. Communication and Information:

• Employees and business partners are informed about this policy.

• Regular information is provided for the implementation of the policy and a communication channel is established for questions.

6. Complaint and Reporting Mechanism

6.1. Reporting Channels:

• Any bribery or corruption attempt must be reported anonymously or openly to the company's complaint and reporting channels.

6.2. Confidentiality and Protection:

• The identity of the persons making the notification is kept confidential.

• Persons making the notification are protected from any reprisal or discrimination.

6.3. Investigation Process:

• All notifications are reviewed promptly and impartially.

• Necessary disciplinary or legal actions are taken as a result of the investigation.

7. Management and Audit

7.1. Responsibilities:

• The Board of Directors is responsible for the effective implementation and periodic review of the policy.

• Inspections regarding the fight against bribery and corruption are carried out regularly.

7.2. Updating the Policy:

• The policy is updated at regular intervals in accordance with legal regulations and industry standards.

8. Conclusion

As FCR GYO, we are determined to fight against bribery and corruption. All our employees, business partners and stakeholders are expected to comply with this policy. This policy was created to strengthen our company's commitment to ethical values ​​and transparency.