CODE OF ETHICS POLICY

AE Arma-Elektropanç members of Ethics and Reputation Society of Turkey hereby represent and warrant to:

- Conduct our business in compliance with any and all applicable local laws, including, primarily, the Constitution of the Republic of Turkey, and any and all international treaties, conventions, agreements and regulations, to which the Republic of Turkey is signatory.

- Conduct our business in compliance with any and all applicable local laws, including, primarily, the Constitution of the Republic of Turkey, and any and all international treaties, conventions, agreements and regulations, to which the Republic of Turkey is signatory.

- Build our business on ethical principles.

- Endeavour to earn a reputation for integrity, competence and excellence.

- Introduce a transparent disclosure policy for the company's operations.

- Protect and encourage fair competition.

- Have due regard for labour law including health and safety and support the fair employment of young, women and physically challenged individuals.

- Prevent any form of corruption.

- Consider integrity as our core values in all our business processes and business relations.

- Put our efforts towards making business ethics constitute the very fundamental of our corporate culture.

- Provide our employees with the awareness, rules and practices to ensure avoidance of conflicts of interests.

- Maintain equal distance to any and all public offices and authorities, administrative entities and political parties without any expectations of interest through the course of our operations and actions.

- Support endeavors contributing to economic and social development.

- Prohibit our employees from accepting and giving away presents which may influence their or counter party's impartial decision making and conduct.

- Develop practices to disseminate above principles, concepts and practices to all parties within our sphere of influence, including our business partners, contractors and suppliers.

- We further declare our support to the 10 principles constituting the essence of the United Nations Global Compact and represent our commitment to take such principles into consideration in the organization of our managerial structure and the development and implementation of our corporate policies.