POLICY FOR WORKING PRINCIPLES AND ETHICAL VALUES

Daax Construction aims to guarantee customer satisfaction by providing products and services produced with the most efficient use of natural resources in top quality and standards and making a contribution to the development of economic life. In that line of action, it aims to become a model of reliability, respectfulness and continuity for its customers, partners, employees and suppliers supporting sustainable growth on local and global basis.

We expect all our stakeholders and employees to comply with the rules of business ethics and application principles supporting these rules and to protect and develop the respectfulness and corporate structure of Daax Construction. All of our employees including temporary staff are obliged to comply with the Policy for Working Principles and Ethical Values. Thus, it is considered as an essential duty and responsibility of our employees in managerial positions to use their best efforts and provide leadership in communicating these working principles and ethical rules to all employees so that they can give utmost importance to and comply with them.

Our Responsibilities

Towards our customers

Daax Construction is focused on creating value for the customers, meeting their demands and requirements to the maximum extent, following sustainable policies, creating a long-term environment based on mutual trust in the relations with the customers and avoiding from providing any misleading or deficient information to them. Daax Construction treats all customers equally and fairly without making any discrimination based on race, religion, language, nationality and sex and uses its best efforts to preserve the confidentiality of all information about the customers since they are considered as trade secret.

Towards our subcontractors and suppliers

Daax Construction is respectful to and tries to protect the rights of the subcontractors and suppliers arising from the applicable laws and regulations. In those conditions that are not regulated by the applicable legislation, common benefits we have with our suppliers will be protected in line with the rules of good faith and to the extent possible with the resources of Daax Construction. Daax Construction treats all subcontractors and suppliers equally and fairly without making any discrimination based on race, religion, language, nationality and sex and uses its best efforts to preserve the confidentiality of all information about the subcontractors and suppliers since they are considered as trade secret.

Towards our competitors

We will fairly and lawfully compete with our competitors based on our commitment on our working principles and without permitting development of unfair competition in our activities. In all of its areas of activity, Daax Construction will compete with its customers honestly, lawfully and in accordance with the current market requirements.

Towards our employees

Daax Construction will not make any discrimination based on race, religion, language, nationality or sex in the course of its relationship with its employees. It will be proud of the differences and cultural variability amongst the employees and try to use this variability as an instrument of development. We will use our best efforts to protect the confidentiality of personal information relating to our employees. Personal information of our employees, suppliers and business partners will never be used for the benefit of Daax Construction or of third persons without their prior written consent provided that such use is permitted by law. Safe and peaceful working environment will be provided to our employees with special focus on the protection of their health. We will respect and protect the rights of our employees arising from the applicable laws and regulations.

Towards the state and public in general

Daax Construction Daax Construction complies with the basic principles of law and with the applicable statues in all countries where it carries out its operations. Daax Construction will never neglect the public benefits in its commercial operations and activities and aims to carry out its operations in harmony with all sections of the society with which it works together.

Our Corporate Culture and Principles

Fundamental principles adopted by Daax Construction are given below:

Responsible Commercial Approach

• Avoiding from seeing commercial operations only as a source of material profit, and
• Carrying out all current and future commercial operations in line with the requirements of corporate culture and stakeholders, after taking into account environmental factors, applicable legislation and rules of sustainability.

Competition

• Avoiding from concluding agreements and performing acts in collusion with the competitors or other persons and entities, which aim to prevent, inhibit or restrict competition or which may potentially have this effect other than those agreements permitted under the applicable legislation,
• Not abusing its dominant position in a certain market even if it is in this dominant position all alone,
• Not entering into negotiations and exchange of information with the competitors in order to jointly determine the market and/or competition conditions and avoiding from any and all communications and processes that may cause or result in above mentioned acts in the private or professional meetings to be held with the representatives of the associations, committees, chambers, professional societies etc. with which we have relations.

Compliance with Laws and Lawful Activities

• Acting in compliance with the law of the country of operations, and with the policies and working principles of Daax Construction in all areas of activity
• Fully managing, recording and reporting all operational activities and accounting system in line with the applicable laws and regulations,
• Ensuring that contracts concluded with other persons and entities are expressed clearly in an easily understandable manner in compliance with the laws and ethical rules,
• Preventing all employees of Daax Construction from performing a transaction that would put Daax Construction under liability other than those transactions performed by the authorized signatories empowered in line with the principles and limits set forth in the signature specimen or other special certificate of authorization.

Activities performed in loyalty to the occupational health and safety and environmental rules, supporting sustainability

• Adopting the principle that it is the common responsibility of all employees to support the activities needed to improve the occupational health and safety measures based on a proactive work safety approach in all activities, with special focus on meeting all legal requirements and other obligations applicable in the matters of occupational health and safety,
• Designing the business processes with special commitment to the use of appropriate natural resources, and taking into account environmental impacts and all measures needed to enhance sustainable nature,
• Ensuring compliance with the occupational health and safety rules and instructions by the employees and encouraging them to take proper occupational health and safety measures at our worksites,
• Not allowing possession of any item or substance that is considered as dangerous or illegal at the worksite and/or for the workers,
• Not possessing or using any narcotic, addictive or other drug that may restrict or inhibit mental and physical abilities except for those drugs used on the basis of a valid medical report and not working at the worksite or at other places while under the influence of these drugs,
• Protecting the nature and environment in deep commitment to environmental rules and supporting all efforts taken to raise social consciousness about sustainability in nature,
• Training the employees and business partners in order to support environmental protection approach and minimize the need for natural resources and reducing energy losses and wastes,
• Developing measures to prevent pollution at its source based on the perception of all kinds of waste disposal as loss of natural resources,
• Designing business processes after taking into the account the need to meet all legal requirements and fulfill all obligations in the area of environmental protection.

Efficient communication and corporate informing, information flow and confidentiality

All activities in Daax Construction are carried out on the basis strict privacy.
Thus, our employees are obliged to comply with the following confidentiality rules and obligations:

• Through legal representatives, making those explanations or announcements needed for the clarification of people as required under the applicable laws,
• Complying with the obligation of not disclosing Company’s information to third persons and not making any trade with this information,
• Keeping confidential all information of Daax Construction, personal data of the employees and information about the customers and business partners,
• Not disclosing or not using for his/her own benefit or for the benefit of others any confidential and non-publicly available information of Daax Construction,
• Acting in line with the limitations arising from the copyrights, trademarks, trade secrets and patents,
• Protecting the nature and environment in deep commitment to environmental rules and supporting all efforts taken to raise social consciousness about sustainability in nature,
• Pursuant to the Personal Data Protection Law, treating customer data as confidential and not providing any of the customer data to the third persons except when officially required by the competent authorities

Private trade secrets and financial information belonging to Daax Construction, including all kinds of customer and employee information, information acquired in the course of business, materials, programs, documents, computer and telecommunication systems, hardware-software and all other arrangements and applications, along with all works, agreements made and products developed by the employees while serving to the Company shall be considered as confidential and shall be exclusively owned by Daax Construction. Any information acquired in the course of works about the third persons shall be also considered confidential. Documents containing confidential information may not be used for personal or private benefits or for the benefit of third persons, entities and organizations either during or after employment with the Company.

In principle, Daax Construction employees may not use the Company’s equipment, systems or e-mail system in order to prepare, store or send personal data and private information. If these systems are used, relevant employees shall be deemed to have waived the confidentiality of their personal data and the personnel in charge of auditing and security of the Company will be entitled to examine this information.

Conflict of interests

Conflict of interests means that an employee is providing any kind of benefit to himself/herself, his/her relatives, friends and related persons and entities or owns a material or other personal benefit, which affects or might potentially affect the performance of his/her duties in an unbiased manner. Daax Construction employees have accepted the principles listed below about the potential conflicts of interest and their efficient management:

The employees must inform our Company at the time of first employment if they own shares in another company or if they participate into their investments in such manner that it would be seen as a conflict of interest. Such type of ownership will be specifically inquired in the job interviews to be made with the candidates. The employees are obliged to inform their superiors about changes that might occur in these circumstances and similar issues that may be perceived as conflict of interest. Measures to be taken after this notification shall be determined at the discretion of Daax Construction.

Representation and participation into organizations and invitations

Prior consent of the relevant department head in Daax Construction is required for participation into those invitations and events organized by the persons or entities with which we have actual or potential business relationship if these invitations or events might make an affect on the decision-making process. Any supportive activities executed by Daax Construction are always managed by corporate means.

Giving and taking gifts

It is forbidden to accept or offer any gifts that causes a suspicion of or is perceived as an irregularity or that creates a relationship of dependency other than the promotional materials provided in the course of our relations with the private or official persons and entities that are willing to establish or continue a business relationship with Daax Construction and no discount or other benefit should be requested from the suppliers, dealers, authorized service stations, customers, group companies or third persons or offered to the third persons if it may potentially be perceived as improper.

Ex-employees making business with Daax Construction

Starting a business or making business in the capacity of vendor, contractor, consultant, commissioner, representative, dealer or similar capacity after leaving his/her position in Daax Construction is a very sensitive issue that must be dealt with carefully since it may be perceived negatively. Therefore, relevant person must act in line with the benefits of Daax Construction before and after that process; must be respectful to ethical rules and not allow any conflict of interest in that process. If business conditions are inappropriate, no commercial relationship must be established with the relevant person or entity. In such cases, course of action to be taken shall be determined by the management of Daax Construction.

Insider Trading

Attempting to gain unfair commercial benefits by using or giving to third persons all kinds of confidential information belonging to Daax Construction including performing directly or indirectly any transaction involving acquisition/transfer of shares on the basis of that information is defined as insider trading and must be avoided at all costs.

Global Responsibility

Daax Construction is aware of the importance of making contributions to the society as a requirement of contemporary and effective commercial business, which is held as much important as making contributions to the economy.

HASSAN GOZAL
Chairman of Board