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The  booklet “Handbook  for Borusan  Employees:  Business  Principles,  Business
            Ethics and Human Resources Practices”, composed by Borusan Group Ethics
            Board, which defines in detail the business principles concerning topics such as

            human rights, environment and public activities, the outline for the implementation
            of ethical rules and the rules of conduct regarding stakeholder relations, which all
            employees are obliged to act accordingly, can be reached on our corporate web-

            Besides the responsibility of our employees to comply with the ethics rules, they
            are expected to guide relations amongst employees and stakeholders according

            to these principles. The responsibili-
            ties of investigating notices received    Our business ethics approach
            through the Borusan Group Ethical
                                                      based on honesty and
            Rules Consultation and Information
            Line,  where complaints  regarding  accountability creates the

            violations of ethical rules are also
                                                      basis for all stakeholder
            conveyed  and developing  solutions
                                                      relations of Borusan Group.
            in relation to these notices belong to
            the Ethics Board that works under         We lead the way in the

            Borusan Holding Inc. Chairman of
                                                      industries we operate
            the Board of Directors.
                                                      regarding ethics, fair

            The Ethics Board may be reached
                                                      competition and fight against
            24/7 by phone or e-mail. The pro-
            cesses of investigating the notices  corruption, and make

            received from group companies are         maximum effort to raise

            conducted by Borusan Holding  Au-
                                                      community awareness in
            dit Director and Borusan Holding Le-
            gal Director; notices conveyed to the     these issues.
            Ethics Board by Borusan Group em-
            ployees or third parties are undisclosed. The examination and investigation works
            are conducted by independent experts in secrecy.

            Every year, we provide trainings to all new white-collar employees working at group
            companies, about ethics and risks associated with corruption, which is an ethics

            subtopic. In 2017, 62% of 29 new employees completed online ethics training.

            Borusan Holding, Borusan Yatırım and Borusan Mannessman are among the found-
            ing members of the Ethics and Reputation Society (TEID), which was established
            with the aim of enhancing business ethics awareness in Turkey.

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