Policies

1. INTRODUCTION

Our Company’s Law No. 5549 of the “Corporate Policy Document”, regulation on measures to prevent the laundering of criminal revenues and financing of terrorism, and the Regulation on compliance with obligations related to the prevention of the laundering of criminal revenues and the financing of terrorism, the recommendations, principles, standards and guidelines brought by national and international organizations, provided that they do not violate the relevant legislation and such legislation. has created a written Corporate Policy document.

2. PURPOSE

In this weaving, in order to ensure the necessary compliance as our institution and to fulfill the obligations in this regard, the provisions determined in the relevant regulations and other sub-regulations prepared on the basis of the “Law no. 5549 on the Prevention of The Laundering of Criminal Revenues” and this Law;

Ensuring that company policies, procedures and control methods comply with the regulations made by the institutions authorized by law and law,

Preventing the use of the company’s commercial activities for the purpose of laundering criminal proceeds and financing terrorism,

Evaluation of customers, transactions and services with a risk-based approach to eliminate the risks that the Company may face in this regard,

Informing the employees of the company about the fight against criminal revenues and their legal and administrative obligations,

Determination of internal audit and training activities,

is intended.

3. DESCRIPTIONS

Assets: Money, any legal documents or means that entrust any property or rights, material or non-material, and any legal documents or instruments that are represented by money,

Proceeds of Crime: The value of assets resulting from all kinds of crimes,

Laundering: To take criminal proceeds abroad or to subject them to various transactions in order to conceal their illegitimate source and to induce conviction that they are obtained in a legitimate way,

Criminal Income Laundering Offense: The crime of laundering assets resulting from a crime that carries a lower limit of one year or more in prison; the value of assets arising from the crimes of taking them abroad, concealing their illegitimate source, or subjecting them to various transactions in order to induce convictions that they were obtained by a legitimate means,

Financing of terrorism: to provide or collect any goods, rights, receivables, income and interests that may be represented by money or value, knowing and willfully being used in the processing of terrorist crimes , and the interest and value of converting them into each other,

Risk: The possibility of financial or reputational damages that bank or bank employees may suffer due to the laundering of criminal proceeds or the use of the services provided for the purpose of financing terrorism, or the failure to fully comply with legal obligations,

4.POWERS AND RESPONSIBILITIES

Our company and its employees may not take actions or actions that will in any way be considered as laundering of criminal revenue or facilitate these activities. For this purpose, employees must take the necessary care and care in case of criminal income laundering in their relations with the customer. Otherwise, they may face legal sanctions starting from the fine to the prison sentence as required by the relevant law.

5.RISK MANAGEMENT POLICY

The risk management policy covers the measures and rules of operation for the implementation of the Company’s customer acceptance policy.

5.1. Principles for customer recognition:

– Identification of the actual identity and address and confirmation using reliable, valid documents, data or information,

– Consistency of documents and information in itself,

– Customer’s professional activity/ subject, financial situation,

– To determine whether someone else has acted on their account and who owns the property in legal entities and partnerships and who is in control of them,

– Process profile and capacity,

– To buyers and sellers,

– Instead of workplace or activity,

reasonable research is carried out and the necessary information and documents are obtained. Customer relationship is not entered into with individuals and institutions that refuse to provide information and documents, providing misleading, unconfirmed information.

5.2 Identification Method:

Identification in Real Persons:

a-The relevant persons in the identification of real persons;

-First Name, Surname

-Place and date of birth,

-Mother and father name for Turkish citizens,

-Nationality,

-T.C. identification number for Turkish citizens,

-Type and number of the identity document,

-Address and signature example,

-Phone number, fax number, e-mail address, if any,

-Information about his work and profession

is taken. For other non-Turkish nationals,

-Passport,

-Residence motion,

-Identity document approved by the Ministry,

is confirmed through .

Identification of Legal Entities:

a.) Title of the legal entity,

b.) Trade registration number,

c.) Tax identification number,

d.) Subject of activity,

e.) Open address,

f.) Telephone number

g.) Fax number and e-mail address, if any,

h.) Interest in the name, surname, place and date of birth, nationality, type and number of the identity document and signature example of the person authorized to represent the legal entity

Overseas Resident Legal Entities:

For legal entities based abroad;

a-Title of legal entity,

b-Trade registration number (equivalent in the relevant country),

c-Tax identification number,

d-Activity subject,

e-Open address,

f-Phone number,

g-Fax number and e-mail address, if any,

h-Information on the name, surname, place and date of birth, nationality, signature sample, type and number of the identity document of the person authorized to represent the legal entity.

Associations and Foundations:

In the identification of the associations,

a.) Name

b.) Purpose

c.) Log number,

d.) Open address,

e.) Telephone number

f.) Information about the fax number and e-mail address, if any,

g.) In addition to the name, surname, place and date of birth, mother and father name, nationality, type and number of the identity document, signature sample and in addition to these documents, the name of the mother and father and the T.C. identification number of the person authorized to represent the Association are taken.

In the identification of foundations;

a-Name,

b-Purpose,

c-Central registration number,

d-Phone number,

e-Fax number and e-mail address, if any,

f-Information regarding the name, surname, place and date of birth, nationality, signature sample, type and number of the identity document and the name of the mother, father and T.C. identification number are taken in addition to this information for Turkish citizens.

Unions and Confederations:

In the identification of unions and confederations, the union or confederation;

a.) Name

b.) Purpose

c.) Registration number,

d.) Open address,

e.) Telephone number

f.) Fax number and e-mail address, if any,

g.) Information regarding the name, surname, place and date of birth, nationality, type and number of the identity document of the persons authorized to represent the union or confederation, the signature sample and the mother and father name and T.C. identification number are taken for Turkish citizens.

Political Parties:

Identification of the political party organization; the relevant unit of the political party

a.) Name

b.) Open address,

c.) Phone number,

d.) Fax number and e-mail address, if any,

e.) The name and surname of the person authorized to represent, the place and date of birth, nationality, signature sample and type and number of the identity document, as well as the mother, father’s name and T.C. identification number are taken for Turkish citizens.

Entities Without Legal Entities (Including Partnerships):

a.) Name

b.) Open address,

c.) Phone number, fax number and e-mail address, if any,

d.) Information regarding the name and surname, place and date of birth, nationality, signature sample, type and number of the identity document of the person authorized to represent the organization, as well as the mother, father’s name and T.C. identification number are obtained for Turkish citizens.

5.3 Declaration of Transaction on Someone Else’s Account and Recognition of The True Beneficiary

Article 15 of the Law no. 5549 on the Prevention of The Laundering of Criminal Proceeds; “In transactions requiring identification before or through the responsible persons, the person acting on his or her behalf and on behalf of someone else will be punished with a prison sentence of six months to one year or a criminal fine of up to five thousand days if he does not inform the obligators in writing whose account he is acting on before performing these transactions.”

provision.

Again, section 17 of the Regulation on Measures to Prevent the Laundering of Criminal Proceeds and Financing of Terrorism. According to the article, the obligators take the necessary measures to determine whether someone else has acted on their account and the identity of the real beneficiary of the transaction, to hang the necessary announcements in all the workplaces where they serve in order to remind those who act on their behalf and on behalf of someone else, and to receive the written declaration of the customer regarding whether someone else has been moved in the continuous business relationship facility. Must.

5.4 Trust third party:

Our company may establish or trade business relations by relying on the measures taken by another financial institution in relation to the customer in determining the identity of the customer, the person acting on behalf of the customer and the actual beneficiary and obtaining information about the purpose of the business relationship or transaction. In this case, the final responsibility within the scope of the regulations related to the Law and the Law shall belong to our Company,

-Since the financial institution has taken measures to meet the requirements of the identification, storage of records and customer recognition rule,

-Since it is subject to effective regulations and audits in the fight against laundering and financing of terrorism,

-Since the documents related to identification will be obtained immediately from the other side when requested,

must be assured.

In this context, the company cannot engage in business relationship with real or legal persons with financial institutions that it is not sure about.

6. RISK MANAGEMENT

In Article 11 of the Regulation on Compliance with Obligations related to the Laundering of Criminal Revenues and The Prevention of Financing of Terrorism, the Risk Management policy is defined and it is stated that “Within the scope of the risk management policy, the responsible persons create a risk management policy taking into account their business size, business volumes and the nature of the transactions they carry out.” The purpose of the risk management policy is defined as identifying, grading, monitoring, evaluating and reducing the risks that the liability may be exposed to and covered internal measures regarding the principles for the recognition of the customer at a minimum level.

In order to prevent criminal revenue launderers and those who wish to finance terrorism from trading through our company and to report suspicious transactions in such a case, the principles and rules specified in the legislation established by the Financial Crimes Investigation Board should be strictly observed. If not complied, the company and its employees may face the following risks:

Legal Risk: Brokerages face serious legal risks for failing to meet obligations to fight laundering, and if liability violations occur, they are even allowed to cancel their operating permits.

Reputation Risk: Since brokerages operate on a trust basis, public opinion on the integrity of an organization and the trust of customers is one of the most valuable assets that the organization will have

7. MONITORING AND CONTROL OBLIGATION

The Company carries out monitoring and control activities taking into account the nature of the transactions carried out by the customers.

The purpose of monitoring and control; protection of the company from risks and continuous monitoring and control of whether its activities are carried out in accordance with the regulations and communiqués issued in accordance with the Law and The Law and in accordance with the corporate policies and procedures.

In this context, the monitoring and control activities to be carried out within the framework of the aforementioned legislation,

7.1 Monitoring and controlling customers and transactions in the high risk group,

7.2 Monitoring and controlling transactions with risky countries,

7.3 Monitoring and controlling complex and unusual transactions,

7.4 When handled together, monitoring and controlling linked transactions exceeding the amount required for identification by sampling method,

7.5 Control and completion of deficiencies by sampling of information and documents that should be kept electronically or in writing about customers and information that must be included in electronic transfer messages,

7.6 Continuous monitoring of the customer’s compliance with information about their business, risk profile and funding sources throughout the business relationship

8. DETECTION AND NOTICE OF SUSPICIOUS TRANSACTIONS:

Section 4 of the Law No. 5549 on the prevention of the laundering of proceeds of crime. In accordance with Article 27 of the Regulation on Substances and Measures; If there is any information, doubt or doubt that the assets subject to the transactions made or attempted to be made before our Company are obtained illegally, these transactions shall be notified to the Compliance Officer by issuing a suspicious transaction notification form within the period specified in the legislation mentioned in the legislation. The Compliance Officer makes the necessary research regarding the suspicious transaction notification and informs the Chairman of the Financial Crimes Investigation Board of the Ministry of Finance.C in accordance with the legislation mentioned again.