Human Rights Policy

PURPOSE

In line with Aklease's understanding of sustainability, creating a modern and respectful business environment for human rights, conveying our approach and principles in the field of human rights, providing and promoting being sensitive to human rights in our relations with our employees, customers, suppliers, business partners and all other stakeholders we are associated with, within the framework of these principles.

SCOPE and CONTENT

All Aklease employees are obliged to act in accordance with the rules and principles indicated in this policy. In addition, all our business partners and stakeholders are expected to act in accordance with this policy for applicable principles and the necessary mechanisms are established to monitor in this regard.

RESPONSIBILITIES

Prepared by : Department of People and Culture
Opinion issued by : Compliance Unit
Approved by : Board of Directors
Published by : Department of People and Culture

APPLICATION GUIDELINES and REFERENCES

Aklease's Human Rights policy has been prepared in accordance with relevant policies and principles, legal regulations and application guidelines and references published by international institutions.

Aklease policy and implementation principles

• Aklease Sustainability Strategy
• Ethic Principles
• Diversity and Inclusion Policy
• Human and Culture Implementation Principles
• Environmental and Social Risk Management Policy
• Occupational Health and Safety Procedures
• Remuneration Principles
• Zero Tolerance to Violence Policy

Principles and policies of international institutions

• United Nations Universal Declaration of Human Rights
• United Nations Global Compact
• United Nations Human Rights Council Guiding Principles on Business and Human Rights
• United Nations Women's Empowerment Principles
• Fundamental Conventions of the International Labor Organization
• International Labor Organization Declaration of Fundamental Principles and Rights at Work
• OECD Directory of Multinational Companies

Relevant legal regulations.

MAIN PRINCIPLES

Aklease focuses on and pays attention to fulfilling the requirements of international conventions to which our country is a party, particularly the United Nations Universal Declaration of Human Rights and the basic principles of labor rights, human rights and social justice of the International Labor Organization.

We transparently share our human rights policy and basic principles with our employees, customers, suppliers and all

other stakeholders, and we work wholeheartedly for the implementation and development of these principles.

Diversity and Equal Opportunity

We support the different cultures, knowledges, ways of thinking and experiences of our employees and we adopt as a basic principle that there is no discrimination based on individual characteristics such as race, gender, belief, religion, language, ethnic origin, nationality, political opinion, age, disability, marital status, sexual orientation.

In the recruitment, performance evaluation, career and remuneration processes, the expertise and competencies of our candidates and employees and their individual performances are accepted as the basic measurement and evaluation criteria.

In order to hear the voices of all employees equally, the participation of employees from different teams with different individual characteristics is considered in internal processes and studies. At Aklease, all employees are encouraged to express their opinions freely and everyone's opinions are treated with respect.

Our basic principles and practices in ensuring equal opportunities, diversity and inclusion are included in the “Diversity and Inclusion Policy”.

Preventing Forced Labor and Child Labor

Aklease strongly opposes child labour, which causes physical and psychological harm to children and deprives them of their right to education and a have a good life. It is against all forms of forced labour, defined as involuntary and threatened work.

In accordance with the contract and recommendation principles of the International Labour Organization, the Universal Declaration of Human Rights and the UN Global Compact, a zero-tolerance policy against slavery and human trafficking is implemented, and our employees, customers, suppliers and all business partners are expected to act accordingly.

Healthy, Safe and Environmentally Friendly Workplace

In order to ensure the occupational health and safety of our employees, we take the necessary measures in accordance with the legal regulations. In this context, we periodically evaluate the possible risks and measures taken and planned for them and our practices. At the same time, we aim to continuously increase the consciousness and awareness level of our employees through regular trainings.

We adopt environmentally sensitive approaches such as creating a sustainability-based working environment and minimizing the environmental impact of our operations by making use of the opportunities provided by technology.

Our policies, principles and practices regarding occupational safety and health are indicated in the "Occupational Health and Safety Procedures".

Zero Tolerance for Harassment and Violence

We believe that it is very important for our employees to feel safe and secure both at home and at work, and in this regard, we have zero tolerance for any kind of violence and abuse that threatens or damages safety. We also undertake to apply appropriate sanctions in case of behaviour and situations that cause harm in a safe and supportive work environment.

Our policies, principles and practices of safety at home and at the workplace are included in the “Zero Tolerance to Violence Policy”.

Working Conditions and Work-Private Life Balance

Working hours are determined in accordance with the legislation, practices such as using breaks during the day, limited overtime, and regular use of leaves are applied. The right of our employees to join a union and make collective agreements is respected. We aim to support our employees in achieving a work-life balance and contribute to their physical, emotional and mental well-being.

Remuneration

At Aklease, the remuneration policy is determined competitively within the framework of internal and external factors, and it is paid in accordance with legal regulations, including side benefits.

Our remuneration policies, principles and practices are indicated in the “Aklease Remuneration Policy”.

Providing Development Opportunities

We provide opportunities and possibilities for our employees to develop themselves personally and professionally. With the principle of continuous development, we design personalized development journeys tailored to the needs of our employees in accordance with the requirements of present and the future and support the development of our employees with innovative training methodologies and sharing of experience.

Protection of Personal Data

We take the necessary measures in accordance with the relevant legal regulations in order to protect the personal information and data of our employees, customers and business partners in accordance with the principle of privacy and the protection of the fundamental rights and freedoms of individuals, and to ensure that this information is not shared with unauthorized persons, and we undertake to implement high-level standards in this field.

Our employees are expected to comply with the measures and regulations regarding the protection of personal data during their daily work, and within this scope, our employees are supported with continuous training activities.

Relationship and Work with our Clients

We aim to produce innovative and value-added financial solutions for our customers. We take environmental and social risks into account, in addition to financial evaluations, in the presentation of our products and services, in financing our customers, and in determining investment decisions.

In accordance with our Environmental and Social Risk Management Policies, customers who carry out prohibited and restricted activities within the framework of legal regulations, contracts we are a party to and the principles we undertake to follow, or who are determined to engage in acts and activities contrary to the principles of child labour, forced labour and human rights are not financed.

In addition, we subject the projects to the environmental and social impact assessment system in financings above the limits in Aklease Environmental and Social Risk Management Policy, and we expect our customers to take the necessary measures in case a risk is detected as a result of this evaluation.

We apply a sustainability-based “know your customer” principle in order to establish commercial relations that respect human rights. We take the utmost care in establishing business relationships in line with our environmental and social values, and we ensure that our customers are performing transactions in line with our social values ​​through our monitoring and control systems.

Relationship and Work with our Suppliers

One of our main goals is to establish value-added, transparent, sustainable, reliable and quality business relationships with our suppliers.

In this regard;

• We attach importance to the implementation of all the issues in the United Nations Global Compact by our suppliers,
• We give priority to suppliers working with systems that are more sensitive to society and the environment in the supply of products and services,
• We strive to evaluate the working conditions of third-party employees, within the scope of their commitments to international organizations,
• We aim to provide equal opportunities for our employees and stakeholders, to support disadvantaged groups, to raise awareness for a comprehensive culture and to determine policies that support its survival, within the scope of our sustainability vision and strategies.

Relationship and Work with our Other Business Partners

In our work and relations with our other business partners, we also observe compliance with the basic principles, and we encourage them to follow an approach in this direction and to comply with the basic principles.

IMPLEMENTATION and MONITORING

Our employees are responsible for fully complying with the rules and principles in this policy approved by the Board of Directors, establishing and operating the control and monitoring mechanisms necessary for the implementation of the policy.

In case of non-compliance with the policy, it is expected to be reported by sending an e-mail to etik@akbank.com / etik@aklease.com or by calling 212 385 77 77.

EFFECTIVENESS and REVISION

This document and the amendments to be made in the document enters into force on the date approved by the Board of Directors.