Ethics Code and Compliance Mechanisms

Galata Wind regards ethical values as one of the fundamental components of its way of doing business. Business ethics management not only guides employee behavior but also directly influences the quality of decision-making processes, investor confidence, and the sustainability of stakeholder relations. Ethics management runs in an integrated manner with the corporate governance system. Oversight of the Company’s internal control structure is carried out by the Audit Committee, and as in all processes, transparent reporting principle is also observed for ethics related matters.

As of 2024, Galata Wind’s key indicators regarding ethics management have been reported as follows:

• Rate of notifications submitted to the management regarding breach of anti-bribery policies: 0%
• Number of ethics-related reports, suggestions, or complaints submitted to the Board of Directors: 0

Corporate ethical conduct rules are defined through internal policies. Communicated to all employees at the time of recruitment, these rules cover a broad framework ranging from conflict of interest to information security.

To improve its ethics management at the corporate level, Galata Wind determined several development targets, and plans to implement them in 2025:

• Delivering training programs on ethics awareness
• Preparing ethics procedures specific to at-risk functions
• Preparing an Ethical Business Conduct Policy
• Integrating provisions on compliance with ethics code into supplier contracts

Improving Company’s performance in anticorruption and compliance with ethics code is considered one of the fundamental components of the sustainability strategy. In 2024, under the coordination of the Holding Ethics Committee, Galata Wind continued its efforts to disseminate corporate policies aimed at improving ethics processes and to ensure full alignment with the Doğan Holding Compliance Procedure. In 2025, developing training programs on ethics to be given to all employees, initiating the work on Ethics Code, and integrating compliance with ethics code criteria into the performance system are among the planned objectives.

Galata Wind, a subsidiary of Doğan Holding, makes its Ethics Code and Rules of Conduct documents available on the Company’s website for access by all stakeholders.

Ethics Hotline Website Application: https://www.speak-hub.com/doganetik

Ethics Hotline: [email protected]