The Koç Group Code of Ethics, which was updated as part of the Compliance Program, is intended to provide guidance and direction to all Koç Group companies, their employees, those who act on behalf of and business partners. While compliance with the Koç Group Code of Ethics is the duty of all Koç Group employees, senior executives of the Koç Group companies are expected to lead the way in this respect.      The Compliance Program is the set of rules, policies and procedures intended to determine and manage compliance matters of the Koç Group with a riskbased approach. The Compliance Program brings together the corporate compliance culture supported by the senior management and monitored by the Legal and Compliance Department with the standards documented across the Koç Group with the involvement of all employees.   The main components of the Koç Group Compliance Program are as follows: prevention, detection and response. The image below shows the components of the Compliance Program and the composition of these components.

The Koç Group Code of Ethics provides a comprehensive framework for the Koç Group employees and stakeholders on various matters, mainly human rights, anti-bribery and anti-corruption, prevention of conflicts of interest, economic sanctions, protection of privacy and inside information, and occupational health and safety.      Under the Compliance Program, numerous policies related to compliance have been developed, and approved by the Koç Holding Board of Directors. These policies include, among others, Sanctions and Export Controls, AntiBribery and Corruption, Supply Chain, Human Rights, Personal Data Protection, Donations and Sponsorships. The Koç Group Code of Ethics, Compliance Policy covering the details of the compliance structure, and the supporting policies can be found below.