Codes of Conduct

Integrity:
• At Ulkar Holding, being truthful and acting with full integrity in all our processes and our relations (employees, customers, suppliers, shareholders, etc.) are our primary values. We act with truthfulness and integrity in all our relations, without any expectation of interest.
• The values that we believe and internalize at the corporate level are guidelines and a road map for all our behaviors both for the company and for employees.
• We stick to and believe what is true and speak truthfully. We value the consistency between the promises and actions. We keep our promises. We expect everyone to behave so.
• Lying, slander, harassment, defamation, plagiarism, concealment of the truth, misinforming doctors and pharmacies regarding products, mobbing, not keeping promises or commitments are major ethical problems.
Privacy:
• Confidential and private information may be about other corporations and institutions, it may also cover the information that may create a disadvantage for Ulkar Holding.
• We never use confidential and private information of our company and our customers/partners for our interest and purposes. We abide by the relevant laws and obligations to not to disclose private information. Furthermore, we believe in the importance of being keeping secrets and discretion.
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• At Ulkar Holding, we respect the private lives and personal traits of our employees. We respect the rights of privacy of our employees regarding their use of computers, e-mail, and the internet, and we observe the legal obligations regarding this matter.
Deriving personal benefit:
• We expect everyone to avoid any kind of unethical relation, favoritism, and suspicious circumstances that might create a conflict of interest both in and out of the company and to refrain from such relations at all times.

• We expect everyone to avoid establishing relations to derive benefits for themselves or third parties using our corporate identity, confidential information, and corporate information, capabilities, manufacturing technologies, know-how, and the company’s equipment.
Relations with state actors and our legal obligations:
• We conduct our health- and pharmaceutical-related activities in Turkey and abroad in line with the laws and legislation of Turkey or the corresponding country(ies) where we operate and the international law. We provide the information requested by the relevant institution and entities in a timely, correct, and comprehensible manner.
• At the Holding, we treat every public institution and entity, administrative entity, non-governmental organization, and political party the same with no expectation of benefit and fulfill our responsibilities in line with the principles of equality and impartiality.
• We observe our legal obligations to the letter in the business relations we establish with our customers and partners, and in our business agreements.
Our responsibilities and satisfaction of our customers/shareholders/business partners
Our responsibilities towards our employees at Ulkar Holding:

• We provide personal benefits to employees correctly and fully. We provide an honest, fair, and healthy working environment to the employees. We plan the required training for the personal and technical development of our employees.
• We provide leadership, coaching, and skill improvement, etc. training to our employees and make sure that they remain open to learning opportunities.
• We accept our differences and believe in the synergy created by differences. We are respectful and trusting towards one another.
Our responsibilities towards our customers at Ulkar Holding:
• We work with a quality and customer-oriented mindset. We provide our services timely and just as we promised; we approach our customers with respect, fairness, good service understanding, and politeness.
Our responsibilities towards our suppliers/business partners at Ulkar Holding:
• We act with fairness and respect as would be expected from a good customer and take special care in fulfilling our obligations in time.
Our responsibilities towards our competitors at Ulkar Holding:
• We compete in line with the laws and codes of conduct and avoid unfair competition.
Our responsibilities towards the public and humanity:
• As a corporation that operates for the health and well-being of society on an international scale, it is our basic global principle to value global economic development and improvement, global relations, win-win and sharing principle, reconciliation, and cultural differences.
• We observe the laws of our country as well as other countries where we operate as a pharmaceutical and health sector company and act in line with the rightful interest/earning and expectations designated with laws.
• We respect the traditions, customs, festivities, and other values, as well as cultural events, holidays, and vacation plans of the countries where we operate as a corporation and fulfill our corresponding obligations.

Our responsibility towards the environment:
• We expect our employees to believe in the virtue of being environmentally-friendly and aware citizens and expect them to act accordingly.
• At Ulkar Holding, we promote preserving the environment and ensuring a healthy ecological environment both in Turkey and other countries where we operate and observe all laws and regulations within this scope.
• At the corporate level, we adopt the principles to preserve the natural resources of our plant, keeping the waters and air clean, using them proportionately and reducing wastes, and take special care to make our use of resources sustainable.

Our responsibilities towards Ulkar Holding:
To become a reputable company both domestically and internationally, To lead and be vision-oriented, To believe in the importance of quality, To create open and transparent working spaces, To observe official obligations and laws to the letter.
Responsibilities of our employees:
• The responsibilities of and expectations from the employees working in our companies based in Turkey and abroad are quite clear. To comply with our codes of conduct, corporate policies and obligations is the primary duty of all holding employees. The responsibilities of our employees:
• The responsibilities of and expectations from the employees working in our companies based in Turkey and abroad are quite clear. To comply with our codes of conduct, corporate policies and obligations is the primary duty of all holding employees.
• We expect our employees to carefully read and adopt the Ulkar Holding business ethics rules, our responsibilities, obligations, and policies and act in line with the laws and regulations. In the case of any breach of these, we make the necessary investigations at the corporate level and act in accordance with the Ethics Committee decisions.
Our responsibilities towards our employees:
Responsibilities of directors:
• We ensure that corporate culture and working space that support the codes of conduct are created.
• We comply with the codes of conduct and set an example with our behavior.
• We train our employees for the codes of conduct.
• We implement various methods and approaches to ensure that the business processes under our responsibility are structured in a manner to minimize the risks regarding ethical matters.
Responsibilities of the human resources:

• We ensure that all procedures regarding the business codes of conduct are evaluated and documented, and announced to the employees after these rules are approved by the Ulkar Holding Board of Directors.
• We inform the holding employees regarding the codes of conduct, provide training to ensure the policies and rules are understood, and keep in touch with the employees regarding these matters.
• We are responsible for ensuring the holding’s new employees read and are informed about the codes of conduct booklet.
Financial solidity, financial records, and obligations:
• Reputability attracts investors to the business, and customers to the business’ products and services, and qualified employers to the company. Therefore, we believe that a robust corporate reputation prolongs the company’s period of activity in the market.
• We keep the reports, ledgers, records, and accounts in line with the accounting principles and the laws of our country as well as other countries where we operate.
• At Ulkar Holding, we run internal audits.
• We fulfill our promises and warrants to all our partners with whom we are in financial relations (banks, supply chains, etc.) in a timely manner and take special care to preserve our corporate reputation.
• We fulfill our tax and similar corporate obligations in a timely and legally compliant manner.
Our policy of operation:
• We regard creating and sustaining a fair business setting for our employees as an important priority. It is our priority targets to create a harmonious, respectful, healthy, and safe working environment that is compliant with laws and regulations and to increase the success, improvement, and commitment of employees.
• We implement physical arrangements regarding the working environment by collaborating with the relevant occupational health and safety entities, procure the required equipment and devices, and provide training and information to our employees.
• We take measures at the corporate level against occupational accidents and hazards that might cause occupational diseases and observe hygiene rules to protect public health.
• Ulkar Holding is an employer that offers fair and equal opportunities during recruitment and working. We do not discriminate in terms of age, race, beliefs, sex, language, nationality, marital status, sexual orientation, seniority, and political beliefs. We respect universal rules of working and observe international laws and regulations.
• We conduct the processes for recruitment and assignment, promotion, termination of employment contract, annual leaves, salaries, and training sessions in a fair manner and observe the laws.
• Any kind of harassment that might occur in a working environment is not tolerated by the company. If such behavior is detected, we start an investigation immediately.
Our product and service policy:
• We believe in high quality standards in the products we manufacture and services we provide and act in accordance with this understanding.
• We act in accordance with the guidelines, specifications, procedure, and quality (cGMP-cGLP, etc.) standards designated for the quality of products and services.
• We listen to our customers, partners, and shareholder, take their opinions and recommendations, and adopt an approach that is open to improvements.
• At the holding, we evaluate our customers’ quality demand in 3 different aspects:
1- Customer demands in terms of product quality and efficiency.
2- Customer demands in terms of service quality.
3- Quality demands in terms of after-sale service points.
• Ulkar Holding’s fundamental principles in this topic are efficiency, reliability, being economical, solution-oriented, proactive to meet customers’ demands quickly, politely, and respectfully