ETHICAL UNDERSTANDING PROCEDURE

SolarAPEX aims to create a culture of fairness and respect among employees and to reflect this approach at every level of management in interactions between employees and/or in areas affected by our actions. Within SolarAPEX, we work with a sense of family, embracing the Company’s vision and mission and working towards defined goals. Respect for people, respect for the environment, and respect for the work performed are indispensable principles for employees at every level. Under no circumstances are compromises made on the virtues of accuracy, honesty, transparency, and equality. All employees aim for the highest quality in their work and act in accordance with the Company’s interests. They never forget that every step they take in their professional lives represents the Company and avoid actions and statements that could damage the Company’s reputation.
1. Use of Company Resources
The protection of Company resources against theft, wasteful use, or use for personal gain and personal purposes is ensured through the interactive work of Company employees, units specifically established within the Company for this purpose, and security units.
To ensure the efficient use of Company resources, each employee must do the following (without limitation):
• Do everything in their power to prevent the wasteful use, theft, and personal use of company resources,
• Use communication and contact facilities (telephone, internet connection, e-mail, etc.) only for Company business purposes,
• Protect all electronic programs, data, communication information, and written documents from access by third parties in accordance with the laws of the Republic of Turkey and within the framework of the commercial secrecy regulations in force within the Company,
• Use Company resources, employees, and assets in accordance with the law.
• The Company does not disregard the possibility that employees may, in certain circumstances, be required to use electronic communication facilities, office equipment, and official vehicles for purposes other than Company business.

SolarAPEX has the right to claim compensation from the employee for any damages incurred by the Company as a result of conduct contrary to the above, in accordance with the laws of the Republic of Turkey.
2. Representation Expenses
Representation expenses are used for customers and business meetings. Representation expenses are used only in the relevant areas and cannot be transferred between expenditure areas.
No invoice shall be obtained from another source for expenses for which no invoice has been received. Where necessary, an expense report shall be prepared in accordance with the law, and expenses shall not be concealed by obtaining different invoices.
Managers may purchase gifts for their employees, take them to restaurants, theaters, concerts, and similar venues to foster team spirit, reward them, boost motivation, and for similar reasons. No distinction is made among employees in carrying out these activities.
3. Time Management
Time is one of SolarAPEX’s most important resources. It is essential that company employees use their working hours efficiently and do not devote time to personal matters during working hours. Managers cannot assign employees to perform personal tasks. Ensuring the effectiveness of the time allocated for meetings is the responsibility of the person organizing the meeting, and it is essential that all participants come to the meeting prepared. All participants adhere to the start and end times allocated for the meeting.
As a rule, private visitors are not to be received during working hours. In special and exceptional cases, meetings between employees and visitors from outside the company should not exceed 10-15 minutes.
4. Relationships
4.1 Relationships with Suppliers
The following points are taken into consideration in relations with suppliers. SolarAPEX employees conduct their activities in an ethical and honest manner in all circumstances and conditions, comply with human rights principles that aim to support and protect human rights, protect the environment, and contribute to the community in which they operate. All our employees act in accordance with the Supplier Ethics Principles and Rules that govern our relations with Company suppliers.
4.2 Customer Relations
SolarAPEX implements customer-focused practices based on customer satisfaction. We prioritize customer needs and requests and work with an understanding of responding to customer complaints and requests as quickly and accurately as possible. Even if it is in the Company’s interest, we cannot take advantage of customer weaknesses and cannot pursue profit by providing incomplete or incorrect information to customers.

Customer complaints are immediately recorded and forwarded to the Purchasing Engineer. The reporting of customer complaints to senior management is carried out meticulously by the relevant departments in accordance with the principles of transparency.
Employees cannot enter into private business relationships with Company customers, borrow money, or lend money to customers.
Purchasing goods or services from a customer at a price significantly below their value or without any payment is considered a conflict of interest and warrants disciplinary action, up to and including termination of the employment contract.
4.3 Relations with the Media
Giving statements to any media organization, conducting interviews, participating as a speaker at seminars, conferences, and similar events, and determining whether or not to receive payment for such activities is subject to the approval of our General Manager. Under no circumstances may personal gain be derived from these activities.
4.4 Relations with Public Authorities
Relations with public authorities are conducted within the framework of laws and company policies/procedures. Written records are created for information requested by official authorities, and the General Manager is informed. Information is provided to the relevant parties accurately and in a timely manner.
5. Obligations to the Company
5.1 Acceptance of Gifts, Invitations, Assistance, and Donations
5.1.1 Acceptance of Gifts
Gifts cannot be requested from customers, suppliers, or consultants, and no suggestion to that effect can be made. No gifts, money, checks, property, free vacations, special discounts, or other benefits that would place the company or the field under obligation can be accepted.
5.1.2 Acceptance of Invitations
Invitations to meals, business meetings, and social activities organized by third parties may be accepted, provided they do not influence the decisions of participating employees, do not conflict with company policies and interests, and are approved by the General Manager.

5.1.3 Acceptance of Assistance and Donations
No assistance or donations may be accepted from any person or organization that has any kind of financial relationship with the company. Any offers of donations or assistance must be shared with the General Manager in all cases.

6. Avoiding Activities That Create Conflicts of Interest
A conflict of interest is an adverse relationship between the interests of the Company and personal interests or the interests of customers. Personal interests cannot be placed above the interests of the Company. One’s position within the Company, Company property, or service information cannot be used for personal gain.
When a conflict of interest arises, or when there is any doubt as to whether a conflict of interest exists, the situation is shared with the General Manager.
It is inappropriate for our employees to purchase services and materials from our suppliers at better prices and terms than those offered by the Company for their own personal needs, or to exceed their own needs and reach commercial proportions.
In bids submitted by Companies in which former Company employees are direct/indirect partners or employees, and in any business conducted with these Companies, this situation is clearly stated and the approval of the General Manager is obtained.
Family members working for supplier companies and customers are not permitted to create a conflict of interest if they are close relatives. In such cases, the approval of the General Manager is obtained before establishing a commercial relationship.
Employees with purchasing decision-making authority shall not make purchasing decisions regarding offers made by companies in which their family members, close relatives, or friends are direct or indirect partners. Purchasing decisions may be made provided that this situation is clearly stated in the evaluations, it is in the Company’s best interest, and the General Manager is informed and gives their approval.
Except for employees who communicate with customers and suppliers as part of their job, it is not appropriate for other employees to have close relationships with these individuals.

SolarAPEX employees

• cannot derive any special benefit from customers, nor can they transfer benefits by establishing intermediary relationships between customers.
• When there is a conflict of interest between customers, they treat all customers equally and fairly.
• They strive to perform their duties impartially.
To prevent conflicts of interest, personnel are required to comply with the following rules.
• Not to act as a guarantor for customers or accept their guarantees,
• Not entering into relationships with clients that are incompatible with professional practices, such as debt-credit relationships,
• Not participating in invitations or domestic/international trips where the expenses are fully or partially paid by customers, except in cases where a Founding Partner is informed and gives permission,
• Not accepting gifts of a nature and value that could create obligations for themselves from customers,
• Not to give excessively expensive gifts to current or potential clients and not to use one’s position to provide clients with advantages (e.g., special discounted shopping opportunities) that exceed their purpose and are outside normal practices.
7. Other Rules
All our employees,

• Protect the brand,
• Comply with the principle of professional confidentiality,
• Protecting personal data belonging to employees, customers, suppliers, and other business partners as required by their job,
• Performing their duties honestly,
• Ensuring the careful protection of company assets,
• Compliance with legal regulations and all policies and regulations published by the Company
Comply
is required.
Employees are obligated to carry out instructions given by their superiors. However, if any employee believes that an instruction received violates legal regulations and/or all policies and regulations published by the Company, ethical rules, or the manner in which these rules are applied, they must report this situation to the General Manager and/or the Sales and Purchasing Deputy General Manager responsible for ethical principles via email. Such action shall not place the reporting employee in a position of liability for any reason.

7.1 Protection of the Brand
The SolarAPEX brand is our most important asset, driving all our activities. Our primary goal is to consistently protect and enhance our brand’s strong reputation in line with our marketing and communication principles. Our employees are responsible for performing their duties in accordance with the principles of protecting and enhancing our brand.
We recognize that personal social media accounts are private spaces and respect sharing preferences. However, we expect employees to use personal email addresses for social media accounts, not company email addresses; to avoid sharing content on social media that could cause disputes or uncertainty or represent the Company; and to refrain from sharing information or photos that violate privacy rules.
7.2 Professional Confidentiality
Our employees are obligated not to disclose any information related to the Company’s activities and transactions to anyone other than the legal authorities explicitly listed in the laws and authorized Company employees.
In the course of their duties within the Company, employees who become aware of confidential and/or first-hand Company information that has not been made public may not disclose such confidential information to anyone other than those who need to know it.
“Confidential information” includes any and all Company information that our employees learn in writing, verbally, or electronically in the course of their duties, whether old, current, or future.
Employees may only disclose confidential information they have learned in the course of their duties to other Company employees who are required to know such confidential information within the framework of Company policies and regulations; they may not disclose it to third parties. Disclosure of Company secrets to anyone other than authorities expressly authorized by law to receive such information is considered a violation of our ethical principles.
Analyses and plans prepared for the Company and all types of information obtained by the Company, whether publicly disclosed or not, as well as the Company’s financial data, services it produces, capacity reports, computer software, expenses, business plans, customer and supplier names, working and marketing methods, announcements, and internal regulatory documents and information in the form of regulations and instructions are the property of the Company. This information cannot be disclosed to unrelated persons.

7.3 Protection of Confidential Information
The necessary measures are taken to ensure the confidentiality, storage, and non-disclosure of the Company’s information.
Every evening, desks are cleared, and any confidential documents are locked away, with keys stored in a secure location.
Passwords and user codes are kept confidential and are not disclosed to anyone.
No information is copied to floppy disks or similar media except for work and legal obligation notifications.
Persons who are not company employees are not permitted to access the company’s information network or perform operations on company computers.
7.4 Enforcement of Employees’ Legal Rights
The Company recognizes labor rights arising from laws as an integral part of human rights. The Company conducts its activities in accordance with all legal rights of employees and their rights to recognition upon achieving successful results, opposes discrimination, forced labor, and mobbing, and supports employee participation in decisions made for the development of the Company.
The Company implements personnel development programs that include training and professional development, social packages, motivation methods, and working and rest conditions for employees.
SolarAPEX supports practices that strengthen employee loyalty, increase discipline and productivity, and uphold teamwork traditions.
7.5 Internal Corporate Culture
7.5.1 Internal Personal Relationships
All employees have the right to work in an environment of respect and understanding. Relationships between company employees should be based on mutual respect, obedience, and loyalty in the context of superior-subordinate relationships. Dialogue between employees should be conducted in a manner that does not violate the honor and dignity of the other person.
7.5.2 Relationships with Companies with Which the Company Has Business Relations
Company employees must maintain maximum objectivity and impartiality in their relationships with other companies and must make every effort to conduct these relationships within the framework of justice, mutual respect, ethical behavior rules, and the principles of the legislation of the Republic of Turkey.

Company employees may not withhold, alter, or misuse any information for personal gain through the Company or through other companies with which the Company has a relationship.
8. Compliance with Legal and Company Policies and Regulations
The first priority of SolarAPEX employees is to comply with legal regulations and Company policies and regulations and to avoid events that may pose a risk. Our employees never abuse their position or allow it to be abused. Abuse of position is when a person uses their authority and responsibility for their own benefit, thereby harming the Company and our business partners.
Company employees may not directly or indirectly participate in shameful crimes such as theft, fraud, or pickpocketing, nor may they turn a blind eye to others doing so.
All Company employees must report any behavior that violates our ethical rules to their immediate supervisor and/or the Vice President of Sales and Purchasing via email.
9. Enforcement of Ethical Rules
Those who violate SolarAPEX’s ethical conduct rules and implementation principles may face disciplinary sanctions, up to and including termination of their employment contract.
All employees must embrace the ethical conduct rules and refrain from any actions that violate these rules. All activities carried out and decisions made must be examined for compliance with SolarAPEX’s ethical conduct rules. In case of any doubts regarding compliance with the ethical conduct rules, the communication channels listed below should be contacted. Confidentiality is paramount in all communications.