MANAGEMENT APPROACH

Business Ethics
Verusa Holding carries out its activities within the framework of Verusa Holding "Human Resources Policy and Code of Ethics" prepared by the Board of Directors and disclosed to the public.

The Code of Ethics is based on the principles of compliance with the laws, integrity and honesty on the basis of respect for human rights, created for regulating the relations of the company and all employees with customers, suppliers and other stakeholders.

The Code of Ethics in our Policy constitutes an integrity with company policies and corporate values and covers all Verusa Group employees, Board members, companies and employees from whom we purchase goods and services, suppliers, consultants, lawyers, external auditors, business partners and all third parties with whom we do business. We expect all our stakeholders mentioned to comply with the Code of Ethics.

Our employees may consult with their top managers or the relevant human resources manager about the Code of Ethics; when necessary, in case of any violation of the Code of Ethics and / or witnessing a behavior or practice against the rules, they may report it by e-mail to the Verusa Ethics Line (etikhat@verusa.com.tr) or by phone (+90 212 290 74 90).

Verusa Holding Code of Ethics and Human Recources Policy

Verusa Holding and its subsidiaries that form the Verusa Group undertake to carry out their business activities honestly and ethically and to act in accordance with laws and regulations wherever they operate. For this reason, it is our principle to comply with national laws and international anti-corruption regulations within the scope of our activities.

Verusa Holding's 'Anti-Bribery and Anti-Corruption Policy', prepared by Verusa Holding Board of Directors and disclosed to the public, covers all Verusa Holding employees, companies and employees from whom we purchase goods and services, suppliers, consultants, lawyers, external auditors, business partners and all third parties with whom we do business.

It prohibits making any corrupt payments, offering or undertaking payments to any public official, political party, party officials, candidates or third parties for commercial interests in violation of the anti-bribery and anti-corruption laws and regulations that we are subject to within the scope of the policy. Within the scope of this policy, Verusa Holding and its affiliated company employees are prohibited from making, offering, undertaking bribes, kickbacks or other illegal and corrupt payments, or brokering or accepting similar payments.

This Policy is an integral part of the Corporate Governance Principles disclosed to the public by Verusa Holding Board of Directors, Verusa Holding Code of Business Ethics and the principles we commit to comply with by participating in the United Nations Global Compact.

Necessary sanctions are applied in cases contrary to the policy and in case of detection of inappropriate behavior.

Verusa Holding Anti-Bribery and Anti-Corruption Policy

Risk Management
Verusa Holding has adopted the principle of acting in accordance with corporate risk management principles in order to carry forward sustainable growth and the value it creates for its stakeholders.

The Group performs effective risk management by proactively and accurately determining the possible financial, strategic and operational risks of operating in different sectors and geographies.

Risks are managed and reported in two groups as financial and non-financial risks through the Early Risk Detection Committee under the Board of Directors.

Financial risks are market risk (currency risk and interest risk), credit risk and liquidity risk, which are caused by the Group's activities and whose effects are seen in the periodic financial statements.

The financial risk management program generally focuses on minimizing the potential negative effects of uncertainty in financial markets on the financial performance of the Group.

Non-financial risks are categorized as risks arising from internal and external factors at both corporate and group operational levels.

Risks originating from external factors are defined as risks such as information technologies risk, legal compliance, ethics, corruption and bribery, reputational risks arising from new laws or regulations, regional risks that may arise as a result of natural disasters, environmental risks, risks that may arise from political and economic changes and risks related to suppliers.

Risks originating from internal factors are the risks that may arise as a result of the reduction of the activities or the number of employees, the risks caused by the disruption of the implementation of information systems and backups, the risks that may arise from the change of employees or management, the risks that may arise from the implementation of new programs or services.

By identifying all these risks and determining the actions to be taken, risks are managed proactively, reporting and information are shared transparently throughout the Group, making the risk management process a part of the decision-making mechanisms.