ANTI-CORRUPTION AND ANTI-BRIBERY PROCEDURE

This Procedure;
• The Corporate Governance Principles and Business Ethics Rules approved by Solar APEX senior management and disclosed to the public,
• Human Resources Practices,
• Disciplinary Regulations,
• Procurement of Support Services, Purchasing, and Outsourced Employees
It is an integral part of the regulations governing its management.
Solar APEX is against any form of bribery and corruption and is committed to complying with relevant laws, regulations, and principles. Accepting or offering bribes is absolutely unacceptable, regardless of the purpose.
Business relationships with third parties seeking to obtain work from our company or have work done through bribery must not be continued.

1. Gifts and Hospitality Rules
As a matter of policy, Solar APEX prohibits the acceptance of gifts or anything of value from our current or prospective customers and suppliers, except in the circumstances specified below. In particular, we cannot accept any gift that could be perceived as influencing our business decisions.
If a gift could be perceived by others as a potential bribe or create the impression of official or business favoritism, we should not give such a gift. Regardless of the amount, cash gifts should not be given to or received from customers, suppliers, or other business partners, as this could damage the company’s image and lead to misperceptions.
Accepting, giving, or offering bribes and/or kickbacks is unacceptable under any circumstances. Giving bribes to public officials is illegal and constitutes a crime.
The following situations are exceptions regarding gifts and hospitality:
• Company employees may give and receive entertainment, hospitality, and meals commensurate with their authority, in line with business practices and company policies and procedures.
• Symbolic gifts such as awards, etc., may be accepted as mementos of the day at seminars and similar events attended on behalf of the company, provided they are not monetary in nature.
• High-value gifts cannot be received or given on occasions such as New Year’s, holidays, etc.
• Except for promotional materials, no gifts or hospitality services should be given to government officials without the approval and opinion of senior management (even if permitted by relevant laws).

2. Record Keeping
Solar APEX’s accounting and record-keeping system is regulated in accordance with legal regulations, Ethical Principles, and legal legislation. Accordingly;
• All accounts, invoices, and documents related to relationships with third parties and all relevant parties (customers, suppliers, etc.) must be recorded and maintained in a complete, accurate, and reliable manner.
• No damage shall be done to accounting or similar commercial records related to any transaction, and the facts shall not be distorted.

3. Training
The bribery and corruption prevention procedure has been communicated to all employees. It is continuously and easily accessible on notice boards in our workplace.
Regular training sessions are held to ensure that employees embrace the principles outlined in the procedure and continue to work in accordance with these principles.

4. Reporting Violations of the Procedure
Company employees or persons acting on behalf of the Company are obliged to immediately report to senior management any individuals or institutions acting contrary to the rules of this policy and procedure in the transactions they encounter, or any situation that violates these rules. Reports are kept strictly confidential. During any subsequent investigation or inquiry, confidentiality rules are strictly adhered to, and actions are taken primarily to ensure that the reporting employee is not harmed.

Our anti-bribery and anti-corruption policy:
• All employees of our company,
• Supplier companies and their employees from whom we purchase goods and services, as well as individuals and organizations acting on behalf of Solar APEX (business partners), including suppliers, consultants, and external auditors.
• Our affiliated companies and subsidiaries and their employees,
are covered.

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