Our policies

OUR MISSION

To be an exemplary company that creates value for its stakeholders and the sector by providing high-quality, uninterrupted and sustainable services.

OUR VISION

To be a leader in all activities carried out within our service area, in line with our quality objectives.

CORPORATE CULTURE

We embrace an inclusive, people-oriented culture in which our core values are upheld and embedded throughout the organization.

OUR QUALITY POLICY

Our Quality Policy is to fulfill our responsibilities with a commitment to continuous stakeholder satisfaction.

In order to continuously enhance our service quality, we attach great importance to identifying exemplary best practices and rapidly making them available to our customers and users.

Our quality objectives are established across the organization at departmental level and are reviewed and updated annually.

The provision of electricity distribution services in accordance with our established Quality Policy is subject to the oversight, commitment and assurance of our Board of Directors.

OUR CORE VALUES

• Stakeholder Focus

• Team Spirit

• Occupational Health and Safety

• Transparency

• Sustainability (Human, Social and Environmental)

Our User Complaint Policy

We undertake that all requests, suggestions and complaints submitted to KCETAŞ will be handled effectively, efficiently, with a solution-oriented approach and free of charge, in accordance with the following principles:

• Customer Focus,

• Objectivity,

• Transparency,

• Impartiality,

• Confidentiality,

• Traceability and Accessibility,

• Accountability.

We undertake to make every necessary effort to ensure that all complaints are resolved,

To act in accordance with applicable legislation, Company policies and ethical principles in ensuring customer satisfaction and handling complaints,

To respect the confidentiality of personal information relating to complaints in accordance with consumer rights,

And to analyze every application received and implement preventive actions aimed at improving our services.

Our Call Center Policy

KCETAŞ regards every request, complaint, inquiry and suggestion received from its consumers as an opportunity to improve its products and services, organizational structure, infrastructure and management quality. It meets the needs and expectations of its consumers through its “Different Solutions for Different Expectations” approach.

For this purpose;

All requests are evaluated objectively and with due respect for customer privacy, in accordance with applicable laws, regulations, ethical principles and Company rules. Evaluations are carried out within the committed timeframes by competent personnel and with appropriate resources, and realistic, practical solutions are provided in line with defined objectives.

With its qualified personnel, continuously evolving process-oriented approach, innovative services and integrated technologies, KCETAŞ strives to provide a Call Center service approach that responds effectively to current requirements.

In addition to providing a call center service approach focused on satisfaction in every area, KCETAŞ acts with a responsible sense of social responsibility in order to contribute to and support the economic, environmental, cultural and social development of society.

Our Occupational Health and Safety Policy

OCCUPATIONAL HEALTH AND SAFETY POLICY

Since our establishment in 1928, as Kayseri ve Civarı Elektrik Türk A.Ş., one of Türkiye's longest-established electricity distribution companies, we have adopted the following principles in our electricity distribution activities:

We recognize that occupational accidents and occupational diseases are preventable. We work effectively to raise our employees' awareness of occupational health and safety through training, minimize existing workplace hazards and risks, monitor them through regular inspections, and provide a safe working environment.

Our employees at all levels embrace Occupational Health and Safety practices as an integral part of their professional responsibilities.

We take a proactive approach to Occupational Health and Safety and actively contribute to its implementation. We continuously enhance our awareness and strive to embed Occupational Health and Safety as an integral part of our corporate culture.

We identify, assess and monitor all Occupational Health and Safety-related risks and opportunities in accordance with our corporate risk management approach, based on their potential impact and likelihood, and take prompt action whenever necessary.

Within the framework of Management System standards, we carry out initiatives with the active participation of our employees to enhance Occupational Health and Safety awareness across the organization, and we continuously improve and develop our performance in this area.

We establish cooperation with neighboring facilities, competent authorities and local administrations on matters related to Emergency Management, Health, Safety and the Environment. We fulfill all applicable legal, social and other obligations.

We cooperate with our service providers, maintenance and investment contractors, suppliers and other stakeholders to ensure that their working practices are aligned with the principles set out in this policy.

In carrying out our Company's duties and professional activities, it is unacceptable for either our employees or any third party to suffer harm or be exposed to an accident that may result in bodily injury.

We implement Occupational Health and Safety processes, which are an integral part of our business, without compromise.

Our Environmental Policy

OUR ENVIRONMENTAL POLICY

Our Company has been carrying out electricity distribution activities in Kayseri and its surrounding areas under the license obtained from the Energy Market Regulatory Authority (EMRA) in 2009. In general, population growth in urban areas and the increasing use of energy-intensive technologies are making the need for environmental protection policies more important with each passing day. In addition to the measures that governments and individuals can take, the private sector also bears significant responsibility for ensuring environmental sustainability.

In particular, the electricity distribution activities carried out by our Company within our area of responsibility may be associated with environmental and social impacts. For this reason, we conduct our environmental management activities in accordance with the ISO 14001:2015 Environmental Management System. In 2023, audits were conducted by an authorized quality certification body within the scope of the ISO 14001:2015 Management System. As no nonconformities were identified during these audits, our certification was approved for a further three-year period.

At every stage of electricity distribution activities within our area of responsibility, our Company focuses on acting in an environmentally respectful and responsible manner, continuously improving its environmental performance, and reducing potentially harmful impacts on the environment. Accordingly, at the end of each year, our Environmental Policy for the following year is reviewed with the participation of our management team in line with our environmental sustainability objectives and is revised with particular consideration given to areas such as resource efficiency, air and water emissions, climate change mitigation, biodiversity, air and water emissions, and energy efficiency.

CLIMATE CHANGE

In recent years, extreme weather events observed both globally and in Türkiye, together with steadily rising average temperatures, have created direct risks for the energy distribution sector. At the same time, issues such as increasing energy diversity through the integration of renewable energy into the distribution network, improving the efficiency of energy distribution, and expanding smart grid and energy storage systems have significantly increased the responsibilities of our Company as a leading organization in the sector.

As KCETAŞ, we are aware of our role in combating climate change. We aim to reduce the direct and indirect environmental impacts and carbon emissions arising from the delivery of energy to consumers while increasing energy efficiency across all processes. We regularly monitor energy consumption and carbon emissions, support initiatives that improve efficiency, and work to reduce all forms of environmental impact.

We determine our annual energy consumption reduction targets by effectively monitoring electricity, water, and fuel consumption in our buildings, based on the region-specific ISO 14001 Environmental Management System. In addition, under Presidential Circular No. 30860 on “Energy Savings in Public Buildings,” published in 2019, our Company, as a public-sector company, has been recognized as a primary entity subject to the requirements of the Circular. Accordingly, after fulfilling all applicable obligations, our Company obtained ISO 50001 Energy Management System certification in 2024. Within the scope of this certification, a 20% reduction in energy consumption at our Company's headquarters compared with the previous year is targeted.

Direct greenhouse gas emissions arising from sources owned or controlled by the Company, including fuel consumption by Company vehicles and fugitive emissions, are monitored through the ISO 14001 Environmental Management System and ISO 50001 Energy Management System, and appropriate measures are taken accordingly. In this context, electric bicycles have been added to the Company fleet for use in meter-reading activities with the aim of reducing greenhouse gas emissions.

• Smart Grids: Through pilot projects, we examine grid systems established in alignment with renewable energy systems for future energy infrastructure and energy storage solutions. Electric public transportation and charging infrastructure are managed in an integrated manner. Through these pilot projects, we aim to achieve significant benefits in terms of energy efficiency and greenhouse gas emission reductions.

• Reuse of Faulty or Dismantled Grid Materials: Faulty materials used as part of electricity grid operations, such as transformers, are assessed through Material Quality Control processes. Investments have been made in material quality control and repair equipment that enables us to determine whether dismantled and faulty grid materials delivered to the Recycling Test Center can be reused. These investments have generated significant benefits in terms of both resource utilization and waste reduction.

• Recycling and Reuse of Materials: We attach importance to the reuse and recycling of materials such as cables, poles, panels, circuit breakers, fuses, meters, and all other types of grid equipment. Waste is managed comprehensively in accordance with waste types, waste codes, and the waste hierarchy stipulated under the Waste Management Regulation of the Ministry of Environment and Urbanization. Recycling/recovery and final disposal processes include:

- Recycling of transformer waste and waste transformer oils through licensed recycling companies.

- Recycling of waste engine oils from Company vehicles through licensed recycling companies.

- In addition, waste tires, waste cooking oils from the cafeteria, and recyclable waste collected separately at our Company buildings are regularly delivered to the relevant municipalities against official records.

• New Connection Digitalization Project: Through the “Project Approval System,” which our Company began using in 2020, we have transferred new connection application processes and project approval procedures to a digital environment, thereby preventing paper waste. In this way, the use of 7.5 million sheets of A4 paper annually has been avoided and the cutting of 750 trees per year has been prevented.

WASTE MANAGEMENT

With a strong sense of environmental responsibility, we manage waste in accordance with applicable legislation, international standards, Occupational Health and Safety requirements, and our Environmental Policies. Measures are implemented to prevent, reduce, and recover domestic, industrial, hazardous, and non-hazardous waste generated by our activities at source.

Our Waste Management Procedure has been prepared within the scope of the ISO 14001:2015 Environmental Management System and in accordance with relevant national legislation to define the methods to be applied for the reduction, collection, transportation, storage, recycling and/or final disposal of domestic, hazardous, and non-hazardous waste generated by the activities and operations of electricity distribution companies.

In addition, we ensure that the legally required Compulsory Financial Liability Insurance for Hazardous Substances and Hazardous Waste covering all areas where hazardous waste is temporarily stored is renewed annually before expiry. Two Hazardous Waste Temporary Storage Areas have been established at our Company's storage facility located in the Kayseri Organized Industrial Zone. Transformers and transformer oils are temporarily stored in one of these waste storage areas, while dismantled materials are temporarily stored in the other. Separate containment pits have also been constructed at both temporary storage areas to prevent potential leaks and spills from causing environmental harm.

Hazardous Waste Management: We aim to reduce the environmental impacts of our activities and, by applying a life-cycle approach, return waste to the circular economy without loss of value. Suitable dismantled grid materials processed through the Material Quality Control and Recycling Test Center are recycled and reused. All other grid waste generated by our operations is appropriately collected and recycled, significantly reducing the overall volume of waste. Hazardous waste is stored in accordance with applicable legislation and disposed of through licensed recycling companies and municipalities.

Non-Hazardous Waste Management: In line with our Zero Waste objective, collection bins have been installed, particularly at our headquarters building, to facilitate more accurate and convenient waste separation.

We send domestic and recyclable waste to the relevant municipalities and to companies authorized by municipalities and/or licensed waste management facilities. Waste vegetable oils generated in our Company cafeteria are sent to licensed companies for disposal in accordance with the Waste Oil Control Regulation. Awareness-raising activities are also carried out within the Company to prevent waste arising from single-use plastics, paper, and similar materials.

BIODIVERSITY CONSERVATION

We manage extensive electricity grid operations covering a wide geographical area. The electricity grid and its area of influence, including rights-of-way and grid repair and maintenance activities, inevitably extend into areas of high ecological importance in Türkiye, including designated Ramsar sites, national parks, and various nature conservation areas.

We emphasize the importance of protecting biodiversity while seeking to reduce the potential adverse impacts of our activities on wildlife and natural habitats. Where new investments involve wildlife development and conservation areas, Ecosystem Assessment Reports are prepared and measures are implemented in accordance with applicable legislation to reduce the environmental impacts of our investments.

Türkiye is located on two of the world's major bird migration routes, making the country an important feeding and breeding area for birds. As protected areas are located within our distribution region, the electricity grid we operate also intersects with bird flight routes. In this context, our Company undertakes the following activities:

• Trees located along power transmission lines may cause electricity losses and fires if they come into contact with the lines after installation has been completed. In accordance with applicable regulations, vegetation is cleared within a specified corridor along power transmission lines. Where necessary, trees are removed from the area through cutting or pruning. However, this process not only entails significant financial costs but also has an important ecological impact. Through the “Kaplama Alanı” Project, which we have been implementing since 2020, we aim to enhance line safety and prevent potential fires. In this way, tree-related failures and losses on electricity distribution lines will be reduced, prolonged power outages will be prevented, loss-related costs will be lowered, and the balance of nature and ecological conditions will be preserved. The project provides numerous direct and indirect benefits, including reducing the workload of maintenance teams, preventing potential accidents, decreasing fault-repair expenditures, and reducing energy losses.

• Avian fauna, particularly migratory birds, may face the risk of electrocution when landing or nesting on distribution grids or when coming into contact with two conductors. Potential accidents resulting from such interactions cause fatalities among a significant proportion of affected birds. As part of the High-Voltage Line Insulation Project, launched at the end of 2017, the installation of insulators on electricity lines is continuing.

• To minimize bird fatalities caused by electrocution, bird deterrent devices are installed on selected sections of overhead power lines.

Our Information Security Policy

INFORMATION SECURITY POLICY

1- DEFINITION;

Information security ensures the protection of information against a wide range of threats in order to maintain the continuity of our Company's operations and minimize potential disruptions to business activities.

Information security is fundamentally based on the following three principles:

Confidentiality: Ensuring that information is accessible only to authorized persons,

Integrity: Protecting information against unauthorized modification and ensuring that any such modification can be detected,

Availability/Accessibility: Ensuring that information is available to authorized users whenever required.

2- SCOPE;

This Policy applies to all information processed, stored and/or transmitted in relation to all products used in electricity distribution services at all existing locations of Kayseri ve Civarı Elektrik Türk A.Ş. (KCETAŞ), as well as to all KCETAŞ personnel. Within this scope, employees are required to adopt and comply with all relevant documentation in order to ensure the effective implementation of the ISO 27001 Information Security Management System (ISMS) and the ISO 27701 Privacy Information Management System (PIMS).

3- PURPOSE;

Company Management aims to ensure the security of all physical and electronic information assets used in the provision of the Company's information services in order to:

• Protect the Company's reliability and corporate reputation,

• Ensure compliance with requirements stipulated in agreements entered into with third parties,

• Ensure the continuity of the Company's core and supporting business activities with minimum disruption,

• Protect the confidentiality, integrity and availability of corporate information assets,

• Enhance organizational resilience against cybersecurity threats,

• Make information security awareness an integral part of the corporate culture.

Information is regarded as a strategic corporate asset of KCETAŞ, and the protection of this asset is the shared responsibility of all employees.

4- POLICY;

KCETAŞ has established its Information Security Policy with the commitment to fulfilling the requirements of the ISMS and PIMS, maintaining their effectiveness, continuing continuous improvement activities, and meeting information security requirements by taking into consideration applicable legal requirements, customer requirements, and existing or potential risks.

KCETAŞ Senior Management undertakes to:

• Provide the necessary resources to achieve information security objectives,

• Support the establishment and promotion of an information security culture throughout the organization,

• Ensure that information security performance is reviewed regularly,

• Encourage continuous improvement activities.

The risk management framework covers the identification, assessment, treatment and monitoring of information security risks. Information security risks are reviewed at regular intervals with the objective of maintaining them at acceptable levels.

Everyone who uses the information technology infrastructure or accesses information resources is required to:

• Protect the information assets under their responsibility in accordance with established classification and access control rules,

• Process only information for which they have been granted authorization,

• Report information security incidents without delay,

• Ensure that critical information is appropriately backed up,

• Comply with security measures established in accordance with applicable risk levels.

Necessary processes are implemented to minimize the impact of information security incidents, analyze their root causes, and prevent the recurrence of similar incidents.

Internal Company information resources, including announcements, documents and similar materials, may not be disclosed or transmitted to unauthorized third parties. Company information technology resources may not be used for activities that violate the laws of the Republic of Türkiye or other applicable legislation.

KCETAŞ supports the development, testing and regular updating of business continuity and disaster recovery plans in order to ensure the continuity of critical business processes.

Suppliers, contractors and other third parties that have a business relationship with KCETAŞ are required to comply with applicable information security requirements.

5- SANCTIONS/PENALTIES;

In the event of non-compliance with the policies, procedures and instructions of the ISO 27001 Information Security Management System and ISO 27701 Privacy Information Management System established within KCETAŞ, one or more of the sanctions specified under the Disciplinary Procedure (KE.PRO.032) may be applied.

6- RESPONSIBILITIES;

• The ISMS/PIMS Manager is responsible for providing the necessary coordination to ensure the continuity, implementation, monitoring and improvement of this Policy.

• All managers and directly responsible personnel are responsible for ensuring that information security objectives are implemented within their respective areas of responsibility and that employees comply with the requirements of this Policy.

• All employees are responsible for participating in information security awareness training, protecting information assets, and reporting any security incidents they encounter.

• All personnel, guest users and contracted service providers who use information systems or have direct access to corporate information acknowledge and accept their confidentiality and information security obligations.

• The ISMS Policy is evaluated at least once a year during Management Review Meetings. The suitability, adequacy and effectiveness of the Policy are reviewed regularly, and necessary improvements are planned accordingly.

Our Energy Policy

ENERGY POLICY

Within the scope of our services, we undertake to:

• Reduce energy costs by aligning existing energy systems with high-efficiency, low-operating-cost technologies or by upgrading such systems accordingly, in compliance with applicable legislation,

• Conduct our activities in accordance with all applicable laws and regulations, as well as the obligations arising from agreements to which we are a party,

• Ensure the efficient use of energy resources and protect the environment by separating recyclable waste at source, minimizing non-recoverable waste, and reducing environmental impacts,

• Establish objectives and targets to continuously improve the efficiency and performance of the Energy Management System, adapt our processes accordingly, and pursue continual improvement in order to achieve these targets,

• Provide the information and resources necessary to achieve our objectives and targets,

• Regularly review and continuously improve the effectiveness and performance of the Energy Management System in accordance with the requirements of national and international standards,

• Regularly monitor our energy performance, report it at defined intervals, and transparently communicate the results to relevant internal and external stakeholders,

• Provide our employees with training on energy conservation and energy efficiency and encourage habits that promote the efficient use of energy,

• Monitor technological developments and innovations, procure energy-efficient products and services, and contribute positively to sustainable operations and the environment through the efficient use of energy and materials,

• Provide our stakeholders with the necessary information and raise awareness to support the efficient use of energy in all their activities in line with our Energy Policy.

As the Management, we undertake to conduct our activities in compliance with applicable national and international laws and regulations, within the framework of an Energy Management System based on continual improvement, and by providing the necessary resources.

Our Sustainability Policy

SUSTAINABILITY POLICY

At KCETAŞ, we recognize sustainability as an integral part of all our activities and adopt a management approach that aims to create environmental, social and economic value while contributing to a more livable world for future generations. While conducting our activities in compliance with national legislation, international standards and ethical principles, we aim to create long-term value for all our stakeholders.

Our Policy

1. Environmental Sustainability

• Ensure the efficient use of energy resources.

• Support investments and technologies aimed at reducing electricity distribution network losses.

• Contribute to infrastructure initiatives that support renewable energy and the transition to clean energy.

• Promote waste reduction, increased recycling and the efficient use of natural resources.

• Strengthen business continuity by assessing risks arising from climate change.

2. Social Sustainability

• Provide a safe and healthy working environment that supports our goal of zero occupational accidents.

• Continuously support the training, development and competencies of our employees.

• Embrace the principles of equal opportunity, diversity and inclusion.

• Respect human rights and employee rights.

• Provide high-quality, reliable and uninterrupted services aimed at enhancing customer satisfaction.

• Contribute to social development through education, environmental and social responsibility projects.

3. Economic Sustainability and Corporate Governance

• Ensure sustainable financial performance through the effective and efficient use of resources.

• Invest in technologies that support digital transformation and innovation.

• Act in accordance with ethical principles, transparency, accountability and corporate governance principles.

• Encourage our suppliers to conduct their activities in accordance with sustainability principles.

• Continuously improve our risk management and internal control systems.

4. Energy Efficiency and Innovation

• Expand the implementation of smart grid technologies and applications.

• Improve operational efficiency through digital solutions.

• Support the adoption of new technologies that enhance energy efficiency.

• Contribute to the development of sustainable energy infrastructure through R&D and innovation activities.

5. Stakeholder Engagement

• Establish open, transparent and trust-based communication with our employees, customers, suppliers, public institutions and all other stakeholders.

• Continuously improve our sustainability performance by regularly assessing stakeholder expectations.

• Measure, monitor and regularly report our sustainability objectives and performance.

OUR COMMITMENT

At KCETAŞ, we view sustainability not only as an environmental responsibility but also as a fundamental element of economic growth, social development and strong corporate governance. We are committed to conducting all our activities with a continual improvement approach, aligning with national and international sustainability principles, and contributing to a more livable world for future generations.

Our Responsible Procurement Policy

RESPONSIBLE PROCUREMENT POLICY

At KCETAŞ, we conduct our procurement and tender processes in accordance with the principles of transparency, competition, equal treatment, reliability, confidentiality, efficient use of public resources and accountability. We aim to establish sustainable and regulatory-compliant business relationships with our suppliers and all stakeholders based on mutual trust.

Within the scope of our responsible procurement approach:

• Full compliance with applicable legislation, Company regulations and ethical principles is ensured throughout procurement and tender processes.

• Equal opportunities are provided to all suppliers, and practices that may restrict or undermine fair competition are not permitted.

• Procurement and tender processes are conducted in accordance with the principles of transparency, impartiality and objectivity.

• Supplier selection takes into consideration criteria including quality, cost, delivery time, occupational health and safety, environmental impacts, sustainability and technical competence.

• Effective market research is conducted to support supplier diversification and establish competitive procurement conditions.

• The development of the supplier base is encouraged by enabling new suppliers to participate in the procurement system.

• Procurement methods that ensure the economical, efficient and effective use of public resources are preferred.

• Cooperation with suppliers that demonstrate a responsible approach to occupational health and safety, environmental protection, quality management and social responsibility is encouraged.

• Sustainability and resource efficiency principles are taken into consideration throughout all processes, from the identification of procurement needs to contract management.

• We aim to establish long-term business relationships with our suppliers based on mutual trust, open communication and continual improvement.

• Practices that contribute to the organizational development of our suppliers are supported, and supplier performance is evaluated on a regular basis.

At KCETAŞ, we conduct our procurement and tender activities within the framework of compliance with applicable legislation, commitment to ethical values, promotion of competition, sustainability and corporate responsibility. We strive to establish a reliable and efficient supply chain that creates value for all our stakeholders.

Our Customer Satisfaction Policy

CUSTOMER SATISFACTION POLICY

As KCETAŞ Call Center; We operate with a service approach that focuses on customer satisfaction, adopts a quality service approach and adapts to developing technologies and changing processes. We continue our work by adhering to legal legislation, quality policies and ethical values in all the services we offer to our customers.

Our primary goal is to produce fast, effective and permanent solutions to the demands, complaints, suggestions and problems of our customers in our service area. Acting with the understanding of continuous improvement, we aim to increase our service quality and raise customer satisfaction to higher levels every day.

In this direction;

• To record our customers' requests, complaints and suggestions in a structure that is accessible 24 hours a day, 7 days a week, without paying any fee, and to ensure that they are informed about the processes in a timely manner,

• To provide the fastest and most effective solutions to our customers' problems by accurately analyzing their needs and expectations,

• With a fair, objective, impartial and respectful approach to all our customers; To provide services within the framework of ethical rules and human values,

• Ensuring the confidentiality and security of personal data and information,

• To respect and protect the rights of our customers within the scope of legal legislation,

• Continuously improve our systems and processes in order to increase service quality and sustainability,

• Improving the knowledge and competencies of our employees through regular training in order to provide the best customer experience,

• To provide services with the understanding of an accountable, transparent, impartial, quality-oriented institution that respects people and the environment,

We accept it as our basic principles and goals.

Because we know that; We are aware that our customers who are satisfied with the service quality contribute to the success of KCETAŞ, which leads the industry with its century-old history. Therefore, as a pioneering and exemplary organization, we see it as our fundamental responsibility to constantly improve our service quality and provide the best experience to our customers.

Our Anti-Bribery And Anti-Corruption Policy

ANTI-BRIBERY AND ANTI-CORRUPTION POLICY

1. Purpose

The purpose of this Anti-Bribery and Anti-Corruption Policy is to clearly establish the zero-tolerance approach to bribery and corruption within Kayseri ve Civarı Elektrik Türk A.Ş. (KCETAŞ), which also forms a fundamental basis of the Company's Business Ethics Principles, and to define the standards of corporate integrity and the principles of legal and regulatory compliance.

2. Scope

This Policy applies to:

• All Company executives and employees, including the members of the KCETAŞ Board of Directors,

• Suppliers of goods and services, contractors, subcontractors, consultants, lawyers, external auditors, and all individuals and organizations acting directly or indirectly on behalf of KCETAŞ.

This Policy constitutes an integral part of our Company's Corporate Governance Principles, Business Ethics Rules, Human Resources practices and EFQM Governance Model.

3. Definitions

• Corruption: The direct or indirect misuse of a position, duty or authority, in violation of applicable legislation, for the purpose of obtaining any form of personal or corporate benefit or gain.

• Bribery: The act of providing, offering or promising a benefit to oneself, one's company or another person, or requesting or accepting such a benefit, directly or through intermediaries, under an arrangement whereby a person acts contrary to the requirements of their duty in order to perform, cause the performance of, refrain from performing, accelerate or delay an act related to the performance of that duty.

• Donation: Any form of monetary or in-kind benefit or assistance provided without consideration, whether or not subject to a specific condition.

Acts of bribery and corruption may take the form of cash payments, gifts and hospitality exceeding reasonable standards of business courtesy, commissions, political or other improper donations, unjustified benefits or privileges, or any other similar form of advantage.

4. Duties and Responsibilities

The implementation, oversight and updating of this Policy fall under the authority and responsibility of the KCETAŞ Board of Directors. Within this framework:

• Senior Management: In accordance with the principles established by the Board of Directors, Senior Management is responsible for proactively assessing bribery and corruption risks within its respective functions and establishing the necessary internal control mechanisms.

• Internal Audit and Legal Counsel: Within their respective areas of responsibility, Internal Audit and Legal Counsel monitor and assess whether Company activities are conducted in compliance with applicable legislation and this Policy.

• Integrity Assurance: No KCETAŞ employee may suffer any loss of rights, disadvantage, retaliation or disciplinary sanction for refusing to tolerate, participate in or disregard bribery or corruption.

Responsibilities of All Employees:

• Fully comply with the rules set out in this Policy and all applicable legal requirements,

• Effectively manage operational risks within their respective areas of activity,

• Report any conduct, circumstance or transaction that is contrary to this Policy, suspicious or irregular through KCETAŞ Ethics/Whistleblowing Channels, subject to confidentiality requirements.

5. Business Partners and Supply Chain Management

All companies and business partners from which KCETAŞ purchases or to which it supplies goods and services are required to comply with the principles of this Policy and applicable legislation.

5.1. Selection of Companies and Business Partners

During the selection of business partners and suppliers, in addition to experience, technical competence and financial performance, their ethical standards, corporate reputation and positive track record in these areas are considered critical selection criteria. No business relationship shall be established with any company that has an adverse history or credible adverse information relating to bribery, corruption, tender irregularities or similar misconduct.

5.2. Contract Management and Termination for Just Cause

All agreements entered into with approved companies and business partners shall explicitly stipulate that:

• Full compliance with the principles of this Policy is required,

• Necessary training and information shall be provided to ensure that their employees comply with these rules,

• In the event of a violation of this Policy or the identification of unethical conduct, KCETAŞ has the right to unilaterally terminate the relevant agreements for just cause and without compensation.

6. Policy Implementation Principles

6.1. Zero-Tolerance Principle

Our Company is firmly opposed to all forms of bribery and corruption. Regardless of its purpose, amount or justification, offering, giving, requesting or accepting a bribe is strictly prohibited and unacceptable.

6.2. Gifts, Representation and Hospitality

Any gifts or hospitality accepted or offered by employees must remain within reasonable standards of business courtesy and must be reasonable, transparent, proportionate and unconditional, without creating any dependency or undue privilege. The offering or acceptance of cash, cash equivalents or high-value benefits that may influence decision-making processes or create the appearance of such influence is prohibited.

6.3. Facilitation Payments

No "facilitation payment" (unofficial payment or gratuity), under any name or form, may be offered or made to public officials or third parties for the purpose of securing, facilitating or accelerating routine administrative procedures carried out with public institutions and authorities.

6.4. Corporate Donations and Contributions

Corporate donations and contributions made by KCETAŞ shall be carried out in a fully transparent and traceable manner, in compliance with applicable legislation, the Company's Articles of Association and Board of Directors approval processes. Voluntary charitable contributions made by employees entirely at their own discretion and from their personal funds fall outside the scope of this Policy; however, the Company's name or resources may not be used in connection with such activities, and no pressure may be exerted on other employees.

6.5. Political Activities and Political Neutrality

It is strictly prohibited to make any monetary or in-kind donation, contribution or assistance on behalf of KCETAŞ to any political party, political candidate, trade union or similar political organization. Company resources, vehicles and premises may not be allocated or used for political activities.

7. Accurate and Transparent Record-Keeping

Full transparency and accuracy are fundamental principles in our Company's accounting, financial and operational record-keeping systems:

• All accounts, invoices, receipts and documents relating to transactions or relationships with third parties, including subscribers, suppliers and public authorities, must be recorded completely, accurately and truthfully and retained for the periods required by law.

• No commercial or financial transaction may be falsified or manipulated, no off-the-books account may be created, and the true nature of any transaction may not be misrepresented.

8. Training, Communication and Reporting of Violations

• Accessibility and Awareness: This Policy is communicated to all KCETAŞ employees and made continuously accessible through the Company's internal systems. Periodic and mandatory training programs are organized to increase awareness.

• Reporting and Investigation: In the event of an act contrary to this Policy or a suspected irregularity, the matter must be reported confidentially to KCETAŞ Internal Audit. Reports are carefully reviewed and investigated in accordance with the principles of impartiality and confidentiality.

• Sanctions: Where a violation of this Policy is identified, the necessary disciplinary measures and legal proceedings, including termination of employment where applicable, shall be implemented against the relevant employees in accordance with Company regulations and the Disciplinary Procedure. Business relationships with business partners shall be terminated immediately through termination of the relevant agreement for just cause.

Our Personal Data Protection And Processing Policy

PERSONAL DATA PROTECTION AND PROCESSING POLICY

1. Purpose and Scope

The protection and lawful processing of personal data are among the highest priorities of Kayseri ve Civarı Elektrik Türk A.Ş. (KCETAŞ). Pursuant to the Constitution of the Republic of Türkiye, everyone has the right to request the protection of personal data relating to them.

The purpose of this Policy is to ensure that personal data relating to natural persons, including primarily our subscribers, employees, job applicants, suppliers, business partners and third parties, are processed, protected and managed in full compliance with Personal Data Protection Law No. 6698 and the relevant secondary legislation in connection with the activities carried out by our Company. The details of the operational processes conducted within the framework of this Policy are implemented throughout the Company in accordance with the principles set out herein.

2. Our Commitments as Data Controller

In its capacity as Data Controller, KCETAŞ adopts and undertakes to implement the following fundamental principles in order to ensure the security of all personal data processed within the Company:

• Purpose Limitation and Accuracy: KCETAŞ determines the purposes, methods, legal grounds and retention periods for the processing of personal data in accordance with applicable legislation and processes such data solely for the specified purposes.

• Secure Data Recording Systems: KCETAŞ establishes and manages physical and system-based (digital) data recording structures in which processed data can be securely stored and implements the necessary administrative and technical measures to prevent unauthorized access.

• Obligation to Inform and Transparency: KCETAŞ informs data subjects about the relevant processing activities at the time their personal data are collected. Effective and legally compliant application channels are established to enable data subjects to exercise their rights under Article 11 of the Personal Data Protection Law.

• Protection of Special Categories of Personal Data: When processing special categories of personal data, such as health data, criminal conviction data and biometric data, KCETAŞ fully implements the additional security measures and administrative/technical safeguards determined by the Personal Data Protection Board.

• Data Transfers in Compliance with Legislation: KCETAŞ fully complies with the conditions and restrictions prescribed by law when transferring personal data, including special categories of personal data, to third parties, public authorities or business partners located within Türkiye or abroad.

• Risk Management and Audit Approach: KCETAŞ operates an effective and proactive risk management and internal audit mechanism in order to mitigate and eliminate risks of data leakage or breaches that may arise during personal data processing activities.

• Destruction and Anonymization: Where the legal and operational grounds requiring the processing of personal data cease to exist, KCETAŞ deletes, destroys or anonymizes such data in accordance with the applicable periodic destruction periods.

• Data Breach Notification Mechanism: In the event that processed personal data are unlawfully obtained by third parties, thereby resulting in a personal data breach, KCETAŞ notifies the relevant data subject and the Personal Data Protection Board as soon as possible.

3. Corporate Governance, Awareness and Data Processor Management

• Corporate Organization and Resource Management: In order to ensure continuous and full compliance with the Personal Data Protection Law, KCETAŞ maintains the necessary organizational structure within the Company, including the Personal Data Protection Compliance Committee, continuously improves relevant processes and allocates sufficient resources to these activities.

• Employee Awareness and Training: KCETAŞ organizes periodic training programs and issues internal corporate communications in order to increase employees' awareness of data protection and clearly define their roles and responsibilities.

• Information Security Integration: KCETAŞ promotes full compliance by all employees with the Company's Information Security Management System (ISMS) policies, procedures and cybersecurity controls.

• Third-Party (Data Processor) Management: In order to ensure that suppliers, contractors, consultants and all externally contracted service providers process personal data lawfully, KCETAŞ continuously implements contractual commitments, information security protocols and legal compliance review processes.

Our Ethics Board

ETHICS BOARD

1. Purpose and Scope

The purpose of this Policy is to define the fundamental values, ethical principles and legal compliance commitments that guide KCETAŞ in all of its operations, decisions and business practices. This Policy applies to all Company employees, members of the Board of Directors, suppliers, subcontractors and all business partners acting on behalf of the Company.

2. Core Values and Legal Compliance

Integrity and Respectability: Our Company regards integrity and respectability as indispensable cornerstones of its business culture. Transparency, trust and open communication are fundamental principles in all stakeholder relationships.

Full Compliance with Legislation: All our business activities, transactions and operations are conducted in full compliance with national and international laws, legal regulations and applicable industry standards.

3. Human Rights and Working Environment

Equal Opportunity and Diversity: Our working environment is guided by the principles of gender equality, equal opportunity, diversity and inclusion.

Zero-Tolerance Areas: Modern slavery, human trafficking, child labor, forced labor, mobbing (psychological harassment), discrimination of any kind and all forms of harassment are strictly unacceptable within KCETAŞ. Where such incidents are identified, the necessary legal and disciplinary procedures are initiated immediately.

Decent Working Environment: Employees' freedom of association and organization is respected, and a fair, safe and healthy working environment is supported.

4. Relationships with Stakeholders and Business Partners

Subscriber Focus and Fair Business Practices: Our subscribers are treated in a transparent, respectful and fair manner. Subscriber feedback is addressed promptly, and transparency is maintained in the promotion of products and services.

Shareholder Rights and Governance: Business models that enhance corporate capacity and support sustainable growth are developed for our shareholders, and international corporate governance standards are applied.

Expectations from Business Partners: Relationships with our suppliers and business partners are established on the basis of mutual trust. All business partners are expected to transparently comply with KCETAŞ's ethical values and principles.

5. Social and Environmental Responsibility and Sustainability

Sustainable Environment: By embracing the United Nations Sustainable Development Goals (UN SDGs), we conduct all our activities with a level of environmental responsibility that goes beyond mere compliance with applicable environmental legislation.

Contribution to Society: Social responsibility projects, charitable activities and initiatives supporting women's rights are institutionally encouraged with the aim of creating value for the communities and ecosystems in which we operate.

6. Operational and Commercial Ethics Principles

Fair Competition: Competition in the market is encouraged, and full compliance with competition law is maintained. No agreement or action that may result in monopolization or unfair competition is permitted.

Anti-Bribery and Anti-Corruption: No unlawful payment in the form of bribery, corruption, commissions or similar arrangements is permitted in our business processes. No employee, regardless of position, may offer or accept such conduct. All commercial records and books are maintained in a manner that fully and accurately reflects the true nature of transactions.

Conflicts of Interest, Gifts and Hospitality: Conflicts between employees' personal interests and the interests of the Company are not permitted. Offering or accepting hospitality or gifts that may influence decision-making processes, or may reasonably create the appearance of such influence, is prohibited.

Information Confidentiality and Personal Data Protection Compliance: The confidentiality of all commercial, financial and operational information belonging to the Company and its stakeholders is protected. Personal data are processed and retained in full compliance with applicable personal data protection legislation.

Intellectual and Industrial Property Rights: In accordance with national and international laws, the intellectual and industrial property rights of our Company and third parties, including patents, trademarks and copyrights, are fully respected and protected.

7. Reporting of Ethical Violations and Assurance

Management ensures that the ethics framework within KCETAŞ is operated effectively, transparently and without interruption.

Strict confidentiality is maintained to ensure that employees or external stakeholders who report any conduct, suspicion or violation contrary to ethical principles do not suffer harm, disadvantage or retaliation.

Whistleblowing processes and ethical reviews are conducted on a confidential basis by impartial committees.

Our Human Resources Policy

HUMAN RESOURCES POLICY

1. Purpose and Scope

The purpose of this Policy is to define the fundamental principles governing all Human Resources processes in line with KCETAŞ’s vision and values. This Policy applies to all employees, managers, interns and job applicants within KCETAŞ.

2. Core Principles and Corporate Approach

KCETAŞ believes that its people are at the heart of its success. With the objective of being an employer of choice within its sector, KCETAŞ provides a fair, transparent, safe and people-oriented working environment.

• Equal Opportunity and Inclusion: Merit is the fundamental principle in all processes, including recruitment and placement, training, promotion and remuneration. No discrimination is permitted on the basis of language, religion, race, gender, age, disability, political opinion or any similar characteristic.

• Zero Tolerance: KCETAŞ applies a zero-tolerance approach to psychological harassment (mobbing), discrimination and all forms of mistreatment in the workplace.

• Human Rights and Legal Compliance: Employee rights are protected. Child labor is prohibited, and forced or compulsory labor is not tolerated. Freedom of association and trade union rights are respected.

• Work-Life Balance: A working culture that supports employees’ physical and mental well-being and promotes a healthy balance between professional and personal life is adopted.

3. Process and Implementation Principles

• 3.1. Recruitment and Talent Acquisition: Merit and equal opportunity are fundamental principles in recruitment. Objective assessment tools are used to select the right person for the right position, while orientation programs support the effective integration of new employees into the organization.

• 3.2. Training and Continual Development: Technical, leadership and personal development training programs are planned in line with the principle of "continual development." Internal coaching and the sharing of knowledge and experience are encouraged.

• 3.3. Career Management and Succession Planning: Succession plans are developed for critical positions. Transparent career paths are provided for internal transfers and promotions, with priority given to developing and utilizing internal talent.

• 3.4. Performance and Recognition: A fair performance management system based on measurable objectives is implemented. Recognition and reward mechanisms are applied to acknowledge achievement, innovative ideas and outstanding contributions.

• 3.5. Compensation and Benefits: Compensation management is conducted in line with market conditions and the principle of "Equal Pay for Equal Work." Full compliance with applicable legislation is maintained with respect to working hours and leave processes.

• 3.6. Occupational Health and Safety (OHS): In line with the principle of "People and Occupational Safety First," KCETAŞ pursues a "Zero Accident" objective and provides a safe working environment through preventive measures.

• 3.7. Digital HR and Communication: Data-driven decision-making tools and digital solutions are utilized throughout HR processes. Transparent communication is maintained through employee suggestion systems, surveys and an open-door policy.

• 3.8. Data Security and Ethics: Employee and applicant data are protected in accordance with applicable personal data protection legislation. All employment-related rights and entitlements are fully safeguarded.

4. Effective Date and Monitoring

This Policy enters into force upon the approval of Senior Management and is published on the Company intranet. It is reviewed and updated at least once a year.

Our Artificial Intelligence Governance Policy

ARTIFICIAL INTELLIGENCE GOVERNANCE POLICY

1- DEFINITION;

Artificial Intelligence (AI) governance refers to the collective set of principles, responsibilities and processes established to ensure that AI systems currently used or planned to be developed within KCETAŞ are managed in a secure, ethical, transparent, accountable and legally compliant manner.

The following principles shall be observed in the use of AI applications:

• Human-centricity,

• Reliability,

• Transparency,

• Accountability,

• Fairness,

• Privacy,

• Information security,

• Legal and regulatory compliance.

2- SCOPE;

This Policy applies to:

• KCETAŞ employees,

• Contractors,

• Service providers,

• All parties that use or manage AI systems.

This Policy covers AI systems currently used or planned to be used within the Company, including:

• Generative AI applications,

• Decision-support systems,

• Forecasting and analytics systems,

• Automation solutions,

• AI-based software.

3- PURPOSE;

Company Management has issued this Policy in order to:

• Ensure the safe and efficient use of AI technologies,

• Manage risks arising from the use of AI,

• Protect information security and personal data,

• Establish a culture of AI use that is consistent with ethical principles,

• Ensure compliance with legal and regulatory requirements,

• Support corporate efficiency and innovation.

4- POLICY;

4.1 General Principles

All AI systems used within KCETAŞ shall:

• Be aligned with corporate objectives,

• Operate under appropriate human oversight,

• Comply with information security and personal data protection requirements,

• Be subject to corporate risk assessment.

4.2 Data Protection and Privacy

The following information shall not be uploaded to or processed by AI systems outside authorized processes:

• Confidential information,

• Trade secrets and commercially sensitive information,

• Personal data,

• Critical infrastructure information.

Data used in AI applications shall be managed in accordance with applicable legislation, personal data protection requirements and Company policies.

4.3 Human Oversight

Outputs generated by AI systems shall not be regarded as final decisions.

Human review and approval are required for critical decisions affecting operational, legal, financial or customer service processes.

The relevant business unit is responsible for verifying the accuracy of results generated by AI systems.

4.4 Risk Management

Before AI applications are put into use, they shall be assessed with regard to:

• Information security risks,

• Privacy risks,

• Operational risks,

• Legal risks,

• Reputational risks.

Additional controls shall be implemented for high-risk AI applications.

4.5 Ethical Use

AI systems shall not be used in a manner that:

• Results in discrimination,

• Violates human rights,

• Generates misleading information,

• Supports unlawful activities.

4.6 Transparency and Accountability

In AI-supported processes:

• Traceability of the systems used shall be maintained,

• Decision-making processes shall be kept explainable to the extent reasonably possible,

• Roles and responsibilities shall be clearly defined.

4.7 Third-Party Services

Before using cloud-based or third-party AI services, assessments shall be conducted with respect to:

• Information security,

• Personal data protection,

• Contractual obligations.

5- LEGAL AND REGULATORY COMPLIANCE;

KCETAŞ aims to conduct its activities in alignment with:

• Personal Data Protection Law No. 6698 (KVKK),

• Regulations applicable to the electricity sector,

• Information security obligations,

• ISO 27001,

• ISO 27701,

• ISO 42001 Artificial Intelligence Management System standards.

6- RESPONSIBILITIES;

Senior Management

• Provides the necessary resources for AI governance.

• Supports the implementation of this Policy.

Information Technology Department

• Implements technical controls.

• Monitors the security of AI systems.

ISMS/PIMS Manager

• Coordinates risk assessment activities.

• Monitors the effectiveness of this Policy.

All Employees

• Are responsible for using AI tools in accordance with this Policy.

• Shall refrain from unauthorized disclosure or sharing of data.

• Shall report identified risks, incidents or policy violations.

7- CONTINUAL IMPROVEMENT

The AI governance system shall be reviewed on a regular basis.

This Policy shall be updated in line with technological developments, changes in applicable legislation and regulations, security incidents and evolving business requirements.

This Policy shall be evaluated at least once a year as part of the Management Review process.

Our Communication Policy

COMMUNICATION POLICY

At KCETAŞ, we conduct our communication activities in accordance with the principles of transparency, accuracy, reliability, accessibility and stakeholder focus.

In our communications with employees, customers, public institutions and authorities, business partners, suppliers, the media and society, we are committed to ensuring that accurate information is communicated at the right time through appropriate communication channels.

Accordingly, we:

• Manage our internal and external communication processes in a planned and sustainable manner.

• Take into consideration the views, suggestions and expectations of our stakeholders.

• Ensure that our corporate identity is represented consistently across all communication channels.

• Use digital communication, social media, press and corporate communication channels effectively and responsibly.

• Strengthen internal communication to foster a sense of belonging, collaboration and team spirit.

• Act in compliance with personal data protection, information security, confidentiality requirements and ethical principles.

• Prioritize rapid, accurate and reliable communication during crises and emergency situations.

• Communicate our social responsibility and sustainability initiatives through an effective and responsible communication approach.

The KCETAŞ Communication Policy aims to strengthen our corporate reputation, establish sustainable relationships with our stakeholders based on trust, and effectively represent KCETAŞ’s corporate values across all communication activities.

Our policies

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