Anti-Bribery and Anti-Corruption Policy

Purpose

The purpose of the Anti-Bribery and Anti-Corruption Policy (the "Policy") is to set out the anti-bribery and anti-corruption policies of FORTE Kent Teknolojileri A.Ş. ("FORTE").

Scope

The anti-bribery and anti-corruption policy covers:

• All FORTE employees, including the FORTE Board of Directors,
• The companies from which we procure goods and services and their employees; and the persons and organizations acting on behalf of FORTE (business partners), including suppliers, consultants, lawyers and external auditors.

This Policy is an integral part of:

• The Corporate Governance Principles approved by the FORTE Board of Directors and disclosed to the public,
• The principles we have committed to uphold by joining the United Nations Global Compact,
• Human resources practices.

Definitions

Corruption is the abuse of the authority held by virtue of one's position, directly or indirectly, for the purpose of obtaining any kind of gain.

Bribery is the provision, offering or promising of a benefit — directly or through intermediaries — or its solicitation, acceptance or facilitation, so that a person performs, procures, refrains from, accelerates or delays an act related to the performance of their duty, generating profit for themselves, the requesting party, or a third party in the context of an agreement reached with another person to act contrary to the requirements of their duty.

Bribery and corruption can take many different forms, including cash payments, political or other donations, commissions, social benefits, gifts and hospitality, and other benefits.

Duties and Responsibilities

The implementation and updating of the Anti-Bribery and Anti-Corruption Policy is within the authority, duty and responsibility of the Board of Directors. Within this framework:

• The Corporate Governance Committee advises the Board of Directors on establishing an ethical, reliable, lawful and controlled working environment.
• Senior management assesses risks in line with the principles set by the Board of Directors and establishes the necessary control mechanisms.
• Financial Affairs, Legal and Accounting, together with senior management, monitor within their own areas of duty whether FORTE Kent activities are conducted safely and in compliance with legal regulations.
• Notification, investigation and sanction mechanisms are defined and operated in cases of non-compliance with policies, rules and regulations.

In addition, all FORTE employees are responsible for:

• Complying with the policies set by the Board of Directors,
• Effectively managing the risks related to their own areas of activity,
• Working in compliance with the relevant legal regulations and FORTE practices,
• Reporting to senior management any behaviour, activity or practice contrary to the Policy.

Companies Bought From/Sold To and Business Partners

Companies from which goods and services are procured or to which they are sold, and business partners, are required to comply with the principles of the Policy and other relevant legal regulations; engagements with persons and organizations that fail to comply are terminated.

In selecting companies and business partners, their ethical standing and positive track record in this area are considered alongside criteria such as experience, financial performance and technical competence. Companies or business partners with adverse intelligence regarding bribery or corruption are not engaged, even if they meet the other criteria. The responsibility for conducting the necessary research and assessments before entering into a business relationship rests primarily with senior management; the Quality Department evaluates compliance with these matters in its audits.

Agreements and contracts with companies and business partners that have a positive record and meet the criteria include terms on full compliance with the principles of the Policy, internalization of these principles by their employees, periodic Policy training, and notification obligations. Provisions are added stating that, in case of non-compliance or a situation contrary to the Policy, the engagement and the contracts in force will be terminated with just cause.

Our Policies and Procedures

Bribery and corruption: FORTE stands against all forms of bribery and corruption. Receiving or giving bribes, whatever the purpose, is absolutely unacceptable; business relationships are not maintained with third parties seeking to do business with FORTE through bribery or corruption.

Gifts: Any gift offered or given by FORTE to third parties must be offered openly, in good faith and unconditionally. Permissible gifts and record-keeping principles are set out in the Gift Acceptance and Giving Policy within the FORTE Code of Business Ethics. Gifts other than symbolic ones of low material value must not be accepted; accepted gifts must be reported through the immediate supervisor to HR and senior management.

Facilitation payments: Persons and organizations within the scope of the Policy do not offer facilitation payments to secure or expedite a routine transaction or process with government institutions (permits, licences, obtaining documents, etc.).

Donations: The legislation to which FORTE is subject imposes certain legal limitations on donations and aid. The Donations and Aid Policy has been published on the website and approved by the General Assembly. Employees supporting charities with amounts they raise independently of their work falls outside this policy; however, the principles in the FORTE Code of Business Ethics also apply in this respect.

Accurate record keeping: All accounts, invoices and documents relating to relationships with third parties are recorded and retained completely, precisely and reliably. No falsification is made on accounting or similar commercial records, and facts are not distorted.

Training and communication: The Anti-Bribery and Anti-Corruption Policy has been announced to FORTE employees and is also continuously and easily accessible via Google Drive and the website. Training is an important instrument for raising employee awareness. In this context, the Human Resources Department, together with the Quality Department and the Financial Affairs, Legal, Accounting and Investor Relations Department, designs training programmes in which the participation of all employees is mandatory.

Reporting Policy Violations

Any opinion or suspicion that an employee or a person acting on behalf of FORTE has acted contrary to this Policy must be reported to the Ethics Committee. Matters relating to the FORTE Code of Business Ethics are periodically brought to employees' attention.

FORTE encourages an honest and transparent approach; it supports any employee or person acting on its behalf who raises concerns in good faith, and keeps reports confidential. No employee may be subjected to pressure or punishment because of a report made to the Ethics Committee; no change may be made to their scope of duty or workplace for this reason without the written consent of the Ethics Committee. Anyone subjected to such treatment must report it to the Ethics Committee.

Companies from which goods and services are procured and business partners must also regularly remind their employees about the Ethics Line and encourage them to report when they encounter such situations; this is also secured through contracts.

Policy Violations

Situations that are, or may be, contrary to the Policy are examined by the Ethics Committee; where improper conduct is identified, the necessary sanctions are applied. Contracts include provisions stating that, where conduct contrary to the Policy is identified, engagements/contracts will be unilaterally terminated by FORTE with just cause, and these provisions are applied without exception in case of violation.