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TAV Airports Holding defines Code of Ethics as the rules and principles that all executives and employees are obligated to comply with in order to contribute financial value to its stakeholders and to enhance its corporate value. With this Code of Ethics hereby, it is aimed to ensure that TAV executives and employees display high standards of conduct, that they are aware of the impact of their conduct and attitudes on the Company, that the stakeholders employ the best methods and display highly qualified behaviours. Code of Ethics is announced at the TAV Corporate Intranet, and the internal media; and furthermore it is disclosed during employee focused programs. The Board of Directors, executives and all employees are expected to comply with the below described TAV Airports Holding Code of Ethics.

Conflict of interests

Conflict of interests is created when the private interests of the employee and interests of the company are in conflict, or in case there is a potential for such conflict. While undertaking their corporate responsibilities, TAV Airports Holding employees are expected to hold the corporate interests above their own interests and the interests of their families and acquaintances, and thus carry out their liabilities. The employees are to avoid any attempts which may be construed as pursuing the interests of their own or acquaintances.

Situations of conflicts of interests

While carrying out their duties, employees are responsible for protecting interests of the company. Circumstances given below are considered as conflict of interests:

• Commercial relationship between family members or up to third degree relatives of the employees and the company,

• Property or interest relationship between family members, up to third degree relatives of the employees or the competitors,

• Business relationship with the companies that family members and up to third degree relatives work in,

• Borrowing from the companies with which there are business relations or entering in commercial relationships.

Preventing conflict of interests

The possible cases of conflict of interests as well as the cases defined by the company management are shared with the employees and the company management takes the necessary precautions. Managers and employees are obliged to inform the management about the observed conflicts of interests. After the identification of such an incident, the Corporate Governance Committee evaluates the matter and takes the necessary actions.

Responsibility to take care in the performance of duties

Employees are obliged to meticulously carry out the duties they have undertaken through employment contracts. They are also obliged to take action to acquire/develop the qualifications and the knowledge required by their duties. They are responsible for the damages inflicted on the company intentionally, due to negligence and carelessness. The employees are responsible for delegating the works assigned to them to their subordinates, and to ensure timely completion, and to carry out the instructions issued by their executives. All employees must be aware of the fact that they represent the company, and they are obliged to protect the reputation of the company towards third parties. They are obliged to abstain from behaviours and actions which may lead to difficulties for the company. All employees are obliged to manage their relations with other employees, shareholders and stakeholders in compliance with the business ethics and code of ethics. No employee may gain interests from third parties or authorities in relation with his/her job, establish private business relations, nor request or make payments.

Responsibility to comply with the company principles and rules

Employees are obliged to comply with the rules, regulations and procedures stipulated by the company regarding the management, compliance, discipline, safety and health issues.

Responsibility to be careful in conduct and relationships

Employees are obliged to work in harmony with their colleagues and managers; to have good and proper relationships with private or official persons or institutions associated with the workplace and to carry out their duties in a rapid and honest manner. Employees are obliged to notify the Management of those who violate the code of ethics, with relevant documentation.

Confidentiality and responsibility to keep secrets

All employees, regardless of whether it is related to their duties or not, are obliged to keep the information and secrets they have acquired regarding the Company. They may not give or disclose the secrets, information they have acquired or the relevant documents, to unauthorized parties or authorities. This liability continues even after the termination of their relationship with the Company.

Responsibility to protect the company Interests

Employees are responsible for protecting the interests of the Company and the work place and must abstain from all conduct that may damage these. The employees may not utilize company means for their personal interests.

Prohibition of working in another job

Employees are not allowed to work in or accept any formal/private, permanent/temporary, and paid/no charge job or to carry on a business without the permission of the company.

Responsibility to declare personal information and revisions

Employees are obliged to declare all revisions concerning the family, civil status and addresses, as well as the information about the personal details, family or acquaintance details taken as the basis for the rights and liabilities governed by the contracts and/or regulations; and the documentation which is the basis for such information, to the Personnel Directorate in a timely manner.


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