Code of Ethics and Working Principles

1. Purpose and Scope

CTN Group’s code of ethics and working principles have been prepared to ensure that our company acts with honesty, transparency, and responsibility towards the laws and society in all fields of activity. These rules apply to our employees, managers, suppliers, and all third parties acting on behalf of CTN. The aim is to determine the core values of the company, define our expectations, and prevent unethical behaviors.

2. Basic Principles

• Honesty and Reliability: Integrity, honesty, and transparency are our primary values in all our business relationships. Our employees are obliged to protect the reputation and reliability of our company.

• Compliance with Laws: Complying with all local and international laws, regulations, and standards is our basic principle. We act in accordance with the regulations issued by energy market regulators and other professional organizations.

• Avoiding Conflicts of Interest: Employees will not prioritize their personal interests over the company's interests and will perform their duties with impartiality. Situations that may lead to conflicts of interest are reported to managers.

• Confidentiality and Information Security: Our employees are responsible for keeping all information they learn as a requirement of their job confidential. Sharing private information belonging to customers, suppliers, or employees with unauthorized persons is prohibited.

• Honest Competition: We comply with the principles of fair and honest competition in all our relationships and avoid practices that will create unfair competition.

• Protection of Company Resources: Employees must use company assets and resources efficiently and respectfully; they must consider profit and efficiency principles while performing their duties.

3. Responsibilities of Employees

Every CTN Group employee;

1. Acts in accordance with basic moral and human values and company strategies while performing their duties.

2. Reads, understands, and complies with all principles regarding the institution's Code of Ethics.

3. Meets internal and external customer needs at the highest professional standards.

4. Acts in accordance with all legislation of legal regulators and professional organizations.

5. Reports unethical behaviors and suspicious situations to their managers or the Ethics Committee. Notifications can be made in confidence by using communication channels such as e-mail and telephone for reporting ethical violations.

4. Responsibilities of Managers

Managers set an example for the implementation of ethical rules with their behaviors, guide their employees, and ensure that the rules are understood. They are obliged to conduct necessary audits to prevent and correct ethical violations.

5. Implementation and Sanctions

Violation of ethical rules may lead to sanctions ranging from the implementation of disciplinary processes to the termination of the employment contract. Behaviors that damage the reputation of the institution are never tolerated.

6. Consulting and Notification Channels

Employees who have questions about ethical rules and working principles can contact Human Resources or the Ethics Committee. E-mail and telephone lines providing confidential reporting have been created to facilitate the reporting of ethical violations.