Get to Know Memorial

Recognized at both the national and international levels as a renowned healthcare organization, we are committed to delivering high-quality, consistent healthcare services that prioritize quality, patient care, and employee satisfaction. To this end, we prioritize continuous improvement and maintaining high service, patient and employee satisfaction standards. We present the commitments set out in our “Quality Policy”, developed based on an understanding of these priorities:

• We comply with relevant national and international regulations and standards applicable to our activities.

• We develop our business processes and healthcare services as part of our commitment to continuous improvement.

• Our goal is to integrate high-quality standards into all our processes.

• We ensure that treatment processes are carried out in a safe and effective manner by providing accurate information to patients and their families at every stage of the healthcare process.

• We closely monitor innovations and technological developments in the healthcare sector, assessing the potential adoption of these innovations.

• We take a service-oriented approach based on the expectations and satisfaction of our patients and employees.

• We prioritize feedback from all our stakeholders, particularly patients and their families, and our employees and value feedback as an opportunity to uphold our high standards.

• We offer training programs to support the professional development of our employees and improve the quality of our services.

• We implement initiatives to encourage high-quality service delivery among employees throughout the organization, raising awareness and sharing this commitment with all our stakeholders.

• To ensure business continuity, we implement preventive measures and establish processes to facilitate uninterrupted workflow in the event of unexpected contingencies.

• We openly share our quality policy on our corporate website where it is accessible to all our stakeholders.

• We encourage all our employees to engage actively in the effective implementation and development of our policy. Our Quality Department assumes primary responsibility in this context.

• We review our quality policy and related management system at least once a year, and update them as necessary.

At Memorial Healthcare Group, our goal is to advance our sustainable business model and deliver positive environmental, social, governance and economic outcomes by maintaining high standards in our patient- and employee-focused services. To this end, we have developed a Sustainability Policy that sets out our core values and principles. We are committed to achieving our sustainability goals as outlined below:

• Our goal is to contribute to sustainable development by adopting and effectively implementing a sustainable business model.

• We identify our sustainability risks and opportunities, and use a strategic management approach to plan the implementation of our short-, medium- and longterm goals.

• We promote sustainability awareness within our organization and extend outreach to our entire value chain.

• We support and contribute to the United Nations Sustainable Development Goals (SDGs).

• To prevent climate change and reduce our carbon footprint, we regularly calculate our greenhouse gas inventory. We raise awareness of climate change among our stakeholders.

• We comply with all applicable legislation, standards and obligations.

• We prioritize our ethical principles.

• We prioritize corporate governance principles.

• We support and promote the principles of a circular economy, striving to use natural resources — especially energy and water — as efficiently and sparsely as possible.

• We conduct effective and proper waste management.

• We embrace equality and adopt an inclusive, non-discriminatory approach.

• We carry out activities to maintain high levels of satisfaction among our employees, patients and families.

• We prioritize innovation and continuous improvement, and we value the development of our stakeholders, particularly our employees.

• We conduct risk analyses and take proactive measures to ensure business and information security, as well as business continuity.

• Our Sustainability Policy is publicly available on our website to inform and raise awareness among all our stakeholders.

• While all our employees play a significant role in the effective implementation of our Sustainability Policy, ultimate responsibility lies with the Sustainability Committee.

• We review our Sustainability Policy at least once a year and update it when necessary.

At Memorial Healthcare Group, we conduct our operations by upholding our vision, mission and values. We recognize that protecting the environment is a social responsibility. Guided by this perspective, we have developed our “Environmental Policy” and are committed to accomplishing its objectives:

• We adhere to relevant national and international environmental regulations and meet the requirements of our national and international standards.

• We prioritize the minimization, prevention and protection of natural resources.

• As the world’s first fully equipped hospital to receive LEED Platinum certification, energy conservation is one of our key priorities. We explore opportunities to utilize renewable energy resources.

• We use water-saving systems and devices to optimize water consumption.

• Through these efforts, we strive to minimize our negative environmental impact and maximize our positive impact.

• The eco-friendly and sustainable nature of our products influences our purchasing decisions.

• We explore alternatives that reduce the use of single-use plastics with no

compromise on hygiene.

• We prioritize reducing waste at source through proper separation, storage, transportation, and delivery to authorized disposal companies, and divert waste to recycling when permitted.

• We promote environmental awareness and responsibility throughout our organisation by raising awareness and engaging all our employees in training.

• We provide information to raise environmental awareness among our patients, caregivers, suppliers, visitors and other stakeholders.

• We manage our environmental impact with a focus on continuous improvement, conducting regular monitoring and reporting to achieve our goals.

• We conduct activities that contribute to the prevention of climate change and we aim to reduce our carbon footprint by calculating and managing our greenhouse gas emissions.

• Our Environmental Policy is made available to the public on our website to inform and raise awareness among all our stakeholders.

• While all our employees play a significant role in the effective implementation of our Environmental Policy, our Quality Department oversees implementation and takes the lead on this responsibility.

• Our Environmental Policy is reviewed at least once a year and updated as necessary.

At Memorial Healthcare Group, we implement Occupational Health and Safety practices in line with national

and international standards, with the aim of protecting the health, safety and well-being of our stakeholders in

our areas of operation. Our Occupational Health and Safety Policy outlines our approach in this domain and is

committed to achieving the following:

• We comply with all applicable legal regulations, obligations and standards relating to occupational health and safety.

• Our aim is to provide a safe and healthy work environment for our employees, interns, patients, patient families, suppliers and visitors, and we do this by taking proactive measures against potential risks.

• We promote safe and healthy behaviours within our organizational culture.

• We implement and develop effective management systems to identify, minimize and manage workplace health and safety risks.

• We take the necessary measures to reduce or eliminate workplace accidents and injuries.

• We periodically review the hazards and risks associated with our activities.

• We embrace the principles of “zero occupational accidents” and “zero occupational diseases” as our fundamental approach.

• We regularly provide Occupational Health and Safety training and information to raise awareness of health and safety concerns in our line of work, and to prevent potential adverse events.

• Our commitment to continuous improvement enables us to further enhance occupational health and safety.

• We make plans for potential emergencies, take precautions and conduct drills.

• We consider occupational health and safety when purchasing goods and services.

• Our Occupational Health and Safety Policy is publicly available on our website, where it informs and raises awareness among all our stakeholders.

• While all our employees play a crucial role in the effective implementation of our policy, the responsibility ultimately lies with the Occupational Health and Safety Committee.

• We review our policy at least once a year and update it as necessary.

As part of our commitment to upholding our vision, mission and values, at Memorial Healthcare Group we have introduced an Energy Management System Policy to enhance our energy efficiency and protect natural resources

by minimizing our energy consumption. Compatible with national and international standards, this policy is implemented in our diagnosis and treatment services centred on patient and employee satisfaction. We adopt a strategic approach to energy management, focusing our efforts on environmental sustainability and energy efficiency to ensure the comfort of our patients, guests, employees and subcontractors.

• We adhere to the national and international regulations and standards to which we are bound, ensuring compliance with the certifications we hold.

• We uphold the applicable laws and obligations relating to the services we receive.

• The provision of resources to promote and supply energy-efficient products, equipment and technologies for uninterrupted patient care is a key priority for us.

• Our goal is to increase our energy efficiency, minimize our resource consumption and reduce our negative environmental impact while maximizing our positive impact.

• We closely monitor technological developments that could enhance our energy performance and support related design activities.

• We embrace sustainability-focused energy optimization.

• Opportunities for integrating renewable energy resources are monitored and efforts are made to leverage them.

• We review our energy performance and our Energy Management System, focusing on continuous improvement, and we engage in training, information and awareness programs to improve performance.

• Our Energy Management System Policy is available on our website to inform and raise awareness among all our stakeholders.

• While all our employees and suppliers contribute to the effective implementation of our Energy Management System Policy, responsibility for overseeing the process lies with the Central Energy Management Team

• We review our Energy Management System Policy on an annual basis and update when revisions are required.

At Memorial Healthcare Group, we are committed to achieving the following with our Human and Employee Rights

Policy. This policy sets out the fundamental values that we place on our employees, who are the primary source of

our service quality. It is based on our vision, mission and values, as well as national and international standards. The policy applies to our diagnosis and treatment services, which are focused on patient and employee satisfaction.

• We act within the framework of the United Nations Universal Declaration of Human Rights and the United Nations’ Guiding Principles on Business and Human Rights. We uphold these principles in our relationships with

our employees.

• We make no compromises on ethical issues such as child labor, modern slavery, and forced labor, regarding

which we have zero tolerance, and we take these issues into consideration when selecting our suppliers.

• We conduct our operations in compliance with the law regarding wages, working hours, overtime and employee and fringe benefits.

• We do not discriminate against our employees on the basis of age, gender, sexual orientation, race, colour,

language, religion, philosophical or political beliefs, ethnicity, economic status, health, disability, appearance,

dress or lifestyle. We never tolerate discriminatory behaviour, actions or retaliation of any kind. We embrace this

perspective in our relationships with our stakeholders.

• We prioritize inclusion and diversity.

• We respect the protection of personal data and the privacy of our employees and patients.

• We provide a physically and psychologically safe working environment, treating all employees with respect in a

manner that does not undermine human dignity.

• We give our employees freedom of expression and recognise their right to join legal associations.

• We fulfil our obligations under the legislation and standards to which we are subject.

• Our Human and Employee Rights Policy is publicly available on our website, where it informs and raises awareness among all our stakeholders.

• While all employees play a crucial role in the effective implementation of our Human and Employee Rights Policy, responsibility for this lies with the Human Resources department.

• We review our Human and Employee Rights Policy at least once a year and update it as necessary.

At Memorial Healthcare Group, in line with our people-centered Memorial+ (Memorial Plus) vision, we believe that sustaining excellence in healthcare is made possible through our employees. Guided by a trust-based corporate culture, we are committed to developing sustainable human resources practices that address not only today’s needs but also those of the future. On this journey toward sustainability, we are continuously evolving our human resources policy with this perspective. Our objective is to foster a fair, inclusive, and trustworthy working environment that creates meaningful impact across environmental, social, and governance (ESG) dimensions.

To this end;

1. Respect and Confidence In People:

▶ By enhancing employee well-being, happiness, and satisfaction, we foster a healthier, more engaged, and more productive work environment.

▶ We prioritize fostering a corporate culture rooted in open communication and collaboration, where every employee’s voice is heard, their ideas are valued, and they can work with confidence and trust.

▶ We are developing training and development programs, performance and reward systems, and a supportive leadership culture that enhance the knowledge, skills, and competencies of our employees.

▶ For us, the notion of “Trust” is built around 3 key stakeholder groups—primarily our employees, along with patients and external stakeholders.

▶ Employee Perspective: It enables employees to work in a supportive and collaborative environment, both individually and as teams, while enhancing performance and commitment. It fosters a culture of open, transparent, and sincere communication among management, physicians, and all other employees.

▶ Patient Perspective: Our patients perceive Memorial not only as a healthcare provider, but as a trusted partner accompanying them throughout their entire healthcare journey.

▶ Stakeholder Perspective: It reinforces Memorial’s position as a preferred and reputable brand within the sector, while cultivating longterm, trust-based, and sustainable relationships with all stakeholders.

2. Inclusion and Diversity:

By embracing the principle of equal opportunity, we regard inclusion and diversity as a source of strength and ensure that fairness is embedded in all recruitment, development, and career management processes.

3. Employee Well-Being:

We adopt holistic approaches to safeguard and support the physical, mental, and social well-being of our employees.

4. Development and Learning:

We establish an organizational structure that supports continuous learning and provide development opportunities that unlock the potential of our employees.

5. Responsible Digitalization and Environmental Awareness:

We digitalize our human resources processes while promoting environmentally responsible practices and implementing sustainable office operations.

6. Social Contribution and Volunteering:

We encourage our employees to actively engage in projects that create social value and uphold social responsibility as a core corporate value.

7. Transparency and Participation:

We foster employee participation in decision-making processes and continuously strengthen trust through transparent and open communication.

8. Employee Retention:

We place strong emphasis on employee engagement, which we measure periodically through structured assessments and employee feedback mechanisms. Based on the insights gathered, we implement targeted actions to continuously enhance employee satisfaction and experience.

9. Compensation and Benefits

Our compensation policy is grounded in fairness and equal opportunity, without discrimination based on race, gender, religion, or age. We determine salaries based on the value of the role, merit, title, level of responsibility, and local economic conditions, while ensuring full compliance with applicable legal regulations.

As the Memorial Healthcare Group, we are committed to achieving the following within the scope of our Patient and Family Satisfaction Policy. This policy outlines our responsibilities and approaches regarding the processes

at our hospital for our patients and their families, and is aligned with our vision, mission, and values:

Our approach to patient rights complies with every applicable national and international regulation and standard, particularly the “Patient Rights Regulation” of the Ministry of Health of the Republic of Türkiye.

• We conduct examinations and treatments for our patients promptly and accurately, in line with their needs and expectations. We do this in accordance with healthcare requirements and ethical values, while maintaining confidentiality.

• We treat all patients with respect, regardless of race, language, religion, skin colour, gender, sexual orientation, disability, political affiliation, philosophical beliefs, economic status or social background.

• We regularly provide our staff with training on how to communicate properly with patients and their families, raising awareness and encouraging them to provide patients with the utmost care. We ensure that our staff are qualified and competent to provide our patients with accurate and sufficient information. Adherence to our ethical principles is a priority for us.

• We establish quality standards for processes within our hospitals and ensure that all our employees adopt these standards.

• We closely monitor current scientific and technological advancements to ensure that the healthcare services we provide are of the highest quality and up to date.

• We provide clear, transparent and detailed information to our patients and their relatives about how they can benefit from healthcare services, treatment processes and medical information, and we respond attentively

to their queries.

• We uphold the rights and requests of our patients and their families, even after discharge.

• We conduct regular assessments to ensure that our patients can evaluate our staff, particularly our doctors and nurses, and provide us with feedback.

• We operate with a “person-centred care” approach, where physicians and patients work together.

• We provide communication support to our patients by employing multilingual staff in our hospitals and providing interpreters when necessary.

• Our Patient and Family Satisfaction Policy is publicly available on our website, raising awareness among all our stakeholders.

• While all our employees play a crucial role in effectively implementing our Patient and Family Satisfaction Policy, the responsibility ultimately lies with the Patient Rights, Complaints and Suggestions Evaluation Committee.

• We review our Patient and Family Satisfaction Policy at least annually and update it as necessary.

Access to accurate information at the right time and in a controlled manner is essential for Memorial due to its projects, the healthcare sector in which it operates and the range of geographical locations in which Memorial operates. It is imperative that the systems and environments housing such information are appropriately protected.

The purpose of the Information Security Policy is to ensure the confidentiality, integrity and availability of valuable information held by Memorial, while taking into account legal regulations and ethical principles and avoiding excessive disruption. Disclosures are provided to ensure transparency and inform individuals about Memorial’s personal data processing activities, which are conducted under the Personal Data Protection Law and the adopted principles for the protection of personal data. To this end, risks are assessed and appropriate measures are taken.

This policy applies to all Memorial employees using the Memorial Information Systems infrastructure, all third-party service, software and hardware providers, and any guests who access our Information Technologies and Digitalization Directorate, regardless of their geographic location or business unit.

Memorial Senior Management is committed to the implementation, periodic review and continuous improvement of this policy, and agrees to provide all necessary resources.

At Memorial, our primary information security objectives are:

• Protecting our reputation and brand value as perceived by our employees, patients/families, suppliers and the public,

• Managing information-related risks,

• Ensuring that information security requirements are met in services provided to patients and families,

• Ensuring that all business processes are integrated, compatible and balanced,

• Complying with all relevant information security legislation and agreements with third parties (business partners, patients and suppliers),

• Preventing interruptions to critical business processes and, should they occur, restoring them within the targeted recovery time,

• Minimizing potential losses from information security by effectively managing information security,

• Ensuring the development of the professional competencies necessary for the effective maintenance of the Information Security Management System,

• Reducing the likelihood of an information security breach and enabling coordinated responses should one occur

• Ensuring the confidentiality, integrity and accessibility of our patients’ information assets within the scope of the Information Security Management System,

• Constantly improving the Information Security Management System.

1. Purpose and Scope:

Code of Ethics and Working Principles of Memorial Health Group (MSG) have been prepared as a guide for MSG employees, managers, suppliers and stakeholders. This guide not only defines our standards of conduct, but also embraces the common goals of developing team spirit, protecting and improving our corporate identity, ensuring that our employees work in a respectable working environment, setting standards for the protection of information and data, and guiding us on the model of conduct we will adopt in our external relations. In line with the core values of Memorial Health Group, the purpose of these Ethical Rules and Working Principles is to ensure that all MSG employees, managers, suppliers, and stakeholders act in accordance with the principles of honesty, fairness, respect, and responsibility in their work processes. This policy applies to all group companies and affiliated business partners within MSG; while ensuring compliance with local legislation, it also references universal ethical standards and aims to establish a corporate culture based on fundamental values such as transparency, integrity, human rights, safety, and compliance with laws. It is essential that all individuals act in accordance with these principles to protect corporate reputation and stakeholder trust and support long-term success. Within the organization, our leaders are responsible for setting an example for employees and making business decisions aligned with the Memorial Health Group’s Code of Ethics and Working Principles.

All our employees are obliged to comply with the Memorial Health Group Code of Ethics and Working Principles. All our stakeholders (suppliers, patients and patient relatives) are expected to comply with the rules of business ethics and all other policies, principles and practices that support these rules. Group companies within MSG may implement stricter intra-company rules as long as they comply with these principles.

2. MSG Employee Relations and Basic Principles

MSG values its employees and respects employee rights. MSG aims to be the ideal institution that everyone is proud to be a part of, consisting of the most successful and competent professionals who create added value that will ensure sustainable growth.

The "Our people are our most valuable asset" approach is one of the basic principles adopted by MSG. In this direction, our corporate vision has been determined as "To become a world-renowned brand as a perfection-oriented and reliable healthy living partner". In this context, the basic principles guiding MSG employee relations are stated in the Human and Employee Rights Policy and Human Resources Policy.

3. Government Relations

3.1. To comply with all relevant laws, rules and regulations in the countries in which it operates and may operate,

3.2. To fully and appropriately manage, record and report all business activities and accounting system in accordance with the law,

3.3. To comply with all MSG policies in relations with public institutions and other government organizations.

4. Social Responsibility

 MSG believes that organizations can grow with the community they serve. In this context, it shows sensitivity to issues that concern the society and supports the positive development of the society; supports studies that will contribute to economic and social development.

5. Patient and Patient Relative Relations

In the light of our vision, mission and values, our responsibilities and approaches regarding the processes of our patients and their relatives in our hospital are specified in the Patient and Relative Satisfaction Policy.

6. Relations with Suppliers

6.1. Creating mutual value in business relations with suppliers,

6.2. To mutually comply with all legislation (laws, regulations, directives, etc.) related to the protection of competition and the decisions of the competent authorities,

6.3. Deciding on supplier company selections with absolute objective criteria. Not engaging in business with relatives, acquaintances, or affiliated parties that could create a conflict of interest.

6.4. To comply with reasonable confidentiality and occupational safety rules requested by the supplier during supplier audits and visits

7. Competitor and Competition Relations

7.1 Not to engage in any agreements or concerted practices, in any form, with competitors or other persons or entities that, outside the limits permitted by law, aim to, or result in, or may result in, restricting, distorting, or preventing competition, directly or indirectly,

7.2. Not to abuse its dominant position in a particular market, either alone or in conjunction with other undertakings,

7.3. Not to negotiate and exchange information with competitors to determine the market and/or competition conditions together. To refrain from any meetings or transactions in associations, assemblies, chambers, professional unions, or similar organizations, as well as in other private or professional meetings and negotiations that may lead to, or be regarded as, the situations mentioned above.

8. Ethical Conduct Rules to Be Followed by Employees

The continuation and further development of the MSG name with professionalism, honesty and trust is the primary responsibility of all MSG employees. MSG aims to train all employees to understand the ethical dimensions of health care delivery and to ensure that employees are able to identify ethical issues and conflicts/dilemmas associated with their roles and responsibilities. In this context, what is expected from MSG employees is as follows:

8:1. Always complying with the law,

8.2. To fulfill their duties within the framework of fundamental moral and human values,

8.3. To obtain the patient’s consent for all studies to be conducted on the patient, on any of their tissues, or solely through the use of their medical information,

8.4. Not to gain unfair benefits from individuals or organizations for any reason, and not to give or receive bribes,

8.5. To act in accordance with the relevant business ethics rules and all policies, principles and practices that support these rules in ongoing duties,

8.6. Not to make any behavior, statement or correspondence that will leave the company under commitment unless expressly authorized,

8.7. Not to engage in behaviors that will disturb and/or harm other employees, not to disrupt the work harmony,

8.8. To treat the company's information documentation and all tangible and intangible assets with the same care as personal property, and to protect them against possible loss, damage, misuse, abuse, theft, and sabotage,

8.9. Not to use working time and company resources directly and indirectly for personal benefit and/or political activity and interest,

8.10 Ensure that legal proceedings are initiated and completed in a timely manner in order to secure intellectual property rights for newly developed products, processes, and software,

8.11. To avoid unauthorized use of patents, copyrights, trade secrets, brands, computer programs or other intellectual and industrial property rights of other companies,

8.12. To ensure that all legal and internal records are kept in a complete and accurate manner,

8.13. Not to respond to information requests from third parties that fall into the confidential category for the company without the approval of the senior management,

8.14. To ensure that the statements disclosed and the reports submitted by the company are accurate,

8.15. To carry out the necessary crisis planning related to the emergency crisis management to be established in the event of emergencies such as natural disasters, thereby ensuring business continuity with minimum loss in case of a crisis,

8.16. To take all kinds of measures to prevent theft or loss of company assets,

8.17. To act with the awareness that MSG's financial and commercial secrets, information that will weaken its competitiveness, employee rights and information, agreements with its stakeholders, and patient information are within the framework of "confidentiality", to ensure their protection and confidentiality,

8.18. Not to share information learned in the course of work or any documents in their possession with unauthorized internal or external persons or authorities for any purpose, and not to use them for speculative purposes, either directly or indirectly,

8.19. Not to use non-public information about MSG, patients and other persons and companies with whom MSG does business for any purpose other than the foreseen purpose, and not to share it with third parties without obtaining the necessary permissions,

8.20. Not to provide unfair benefits in favor of themselves, their relatives or third parties by benefiting from the title and authority,

8.21. To take care to avoid any conflict of interest with MSG in personal investments,

8.22. To take care that personal investments to be made or activities other than any business activity do not hinder their current duty at MSG in terms of giving time and attention and to avoid the occurrence of such situations that prevent focusing on the main tasks,

8.23 To inform the senior manager, in cases where the employee and a person holding a primary decision-making position in a customer or supplier company are first-degree relatives,

8.24. To inform the senior manager if it is learned that their relatives have shares or financial interests in another company in a commercial relationship,

8.25. Not to take action in favor of themselves or their relatives,

8.26 Not to attend invitations such as sporting events or domestic/international trips — other than conferences, receptions, promotional events, seminars, etc. that are open to the general public — organized by persons or institutions with whom there is, or may potentially be, a business relationship, if such events may influence decision-making or be perceived as such, without the approval of senior management,

8.27. Ensuring that ethical conflicts/dilemmas that arise are resolved effectively and in a timely manner

8.28. Not to use the information and document received from MSG by establishing a company in person or as a partner in a company and not to compete with MSG after leaving their position at MSG, 

8.29. To acknowledge that attempting to gain any commercial benefit by using or disclosing any confidential information belonging to MSG (insider trading) constitutes a legal offense, and to strictly refrain from such attempts,

8.30. To submit to the approval of the Human Resources and department manager if the personnel will work outside the duty they undertake in MSG with an employment contract, even outside working hours,

Representation or membership duties on behalf of the company in boards and non-governmental organizations established by law are subject to the approval of MSG Management.

8.31. All kinds of mistreatment, threats, insults, blackmail and humiliation that are systematically applied to employees in the workplace by their superiors, equal employees or subordinates are considered as mobbing. In order to claim that the behavior is mobbing, some elements must be present in the event:

• It should be aimed at intimidation, bullying and exclusion from work, 
• The mobbing must take place in the workplace, 
• It should be carried out in a planned way,
• It should be repeated at regular intervals, 
• It should be done knowingly and willfully. 

No manager or employee within MSG may engage in behavior that may cause mobbing. All kinds of above-mentioned behaviors, actions and discourses are evaluated by the Disciplinary Board.

9. Fight against Corruption

MSG has zero tolerance for bribery, abuse of authority, or corruption of any kind, directly or indirectly for the purpose of obtaining any kind of gain.

No MSG employee, manager, or third party acting on behalf of MSG may directly or indirectly promise, offer, or give any bribe or item of monetary value to a public official, a representative of a state-owned enterprise, or any employee of another legal entity to influence that person’s decisions or actions for the purpose of obtaining an unfair advantage for MSG.

Except for materials given in accordance with commercial traditions, customs, and practices, or materials of a commemorative/promotional nature, you may not accept or offer any gift that could create the impression of an irregularity, cause a dependent relationship, or be perceived as such.

Similarly, it is strictly forbidden for any MSG employee to solicit or receive bribes directly or indirectly from any party.

10. Prohibition of Political Activity

MSG does not make donations to political parties, politicians or political candidates. No protest, propaganda, or any similar activities that are intentional are allowed within the boundaries of workplaces. Company resources (such as vehicles, computers, e-mails) cannot be allocated to political activities.

11. Utilization of the resources

 MSG employees must use company resources responsibly and carefully. Care is taken to use all machinery, tools, materials and all resources carefully, not to use them for personal purposes, to use resources correctly and only as needed, taking into account the interests of the company.

12. Obligation to Report Violations

Employees are obligated to report to the MSG Ethics Line if they become aware of or suspect a violation of the Code of Ethics and Work Principles, any other MSG policy, or the laws and regulations applicable to MSG. All employees are obliged to report inappropriate or unlawful/unethical behavior.

The disclosure of the notification made by the person in a way that negatively affects the peace of the workplace or business relations will be strictly prevented.

It is significant that the reporting person is free from intentions such as gossiping about the reported person or trying to negatively affect their career. In this respect, confidentiality, objectivity and compliance with ethical rules are extremely critical issues in the reporting and investigation process. It is obligatory that both those who report and those who manage the process on the subject pay the utmost attention and attention to this issue. Intentional statements that are false and/or defamatory will be considered a violation of ethical rules.

 The Ethics Line is a communication and reporting tool that MSG employees can use to share issues they cannot or do not want to share with company managers, report unethical behavior, and make anonymous reports. If desired, a phone line, an email address, or both can be used for this purpose.

The MSG Ethics Committee receives and evaluates reports. The results of the research and examination are evaluated at the meeting held with the participation of the members of the Ethics Committee. The actions, measures and penalties to be taken are decided at this meeting and shall be carried out on a confidential basis.

The disciplinary process is applied to persons who act contrary to ethical rules according to the extent of the violation. This process can range from a warning to cancellation of labor contract.

13. Use of Social Media

Social media platforms are considered to be the personal space of MSG employees, and everyone's private and family lives are respected. In addition, MSG employees should note that all social media posts are made within the framework of corporate identity, confidentiality and ethical principles. Social media should be used in accordance with company principles and brand values. Information, photos and any kind of sharing that would violate the confidentiality rules of the companies within MSG should be avoided. Relevant units should be informed about important content concerning the organization.

14. We share our Ethical Rules and Working Principles on our website with the public in order to inform and raise awareness among all our stakeholders.

15. Although all our employees have an important role in the effective execution of the Code of Ethics and Working Principles; responsibility lies with the Ethics Committee.

16. We review the Code of Ethics and Working Principles at least once a year and update them when necessary.