Common use of Bilgi Akışının Önlenmesi ve Yönetilmesi Clause in Contracts

Bilgi Akışının Önlenmesi ve Yönetilmesi. Kuruluş içinde veya şirketler topluluğunun üyeleri arasında bilgi akışının önlenmesi veya yönetilmesi amacıyla, işlemler sadece bu konuda yetkilendirilmiş personel tarafından gerçekleştirilir. Bilgi güvenliği konusunda genel güvenlik kavramlarının yanı sıra, bilgilerin gizliliğinin, bütünlüğünün ve erişebilirliğinin sağlanması amacıyla “Bilgi Güvenliği Yönetmeliği” ve “Bilgi Güvenliği Uygulama Esasları” hazırlanmıştır. Kuruluşumuz, müşterilerine ait kimlik bilgilerini ve faaliyetleri dolayısıyla öğrendiği her türlü bilgiyi, bu konuda kanunen açıkça yetkili kılınan mercilerden başkasına açıklamaz, elde ettiği bilgileri kendisi veya üçüncü bir tarafın menfaati doğrultusunda kullanmaz. Kuruluşumuzun yetkili olduğu diğer tüm hizmet ve faaliyetler ile yan hizmetlerden dolayı müşterilerimizin çıkarlarına aykırı olabilecek olası durumları Our Institution has built an organization structure adequate for preventing the probable conflicts of interests between on one hand itself and its shareholders, employees and directors and other persons having direct or indirect relations with them and on the other hand its customers or between a customer and another customer in the course of its relations with its customers. All conditions needed for professional and personal development of our employees are satisfied and met. If a conflict of interests cannot be prevented due to reasonable causes arising out of modus operandi of markets, the customers are informed in writing prior to the relevant activity or service about the contents, nature and causes of conflicts of interests that may arise between our Institution and our customers, and a statement duly signed by the Customer and verifying such information is received. Our Institution may not engage in transactions which may be in favor of one or more of our customers and in disfavor of other customers, in violation of the objective good faith rules and principles. No priority can be granted to any person or entity in execution of orders of the Customer. Time priority rule is applied in accordance with the relevant laws and regulations of the Capital Markets Board. In the course of performance of capital market transactions in the name of our Customers, for prevention of a conflict of interests, our Institution acts together with all other financial institutions having a capital partnership with our Institution. In addition, our Institution has built its systems and applications with a view to preventing situations where: • Our Institution gains financial profit or avoids financial loss in disfavor of the Customer; or • our Institution reaps interests out of services and activities provided to the Customer though the Customer does not have an interest therein; or • our Institution reaps interests as a result of preference of a customer or a customer group to another customer or customer group; or • our Institution makes financial profit, other than fees and commissions, from a person other than the Customer, due to the activities and services provided to the Customer. As a result of portfolio brokerage activities wherein our Institution executes as the counterparty the purchase or sale orders of the customers with regard to capital market instruments, the customer may suffer a loss, and our Institution as the counterparty may make a profit, as a requirement of the nature of the services or products offered hereunder. The authorized institution is under obligation to disclose to the customer all its relations and conditions which may probably affect the objectivity of comments and advices provided in the course of investment consultancy activities, and particularly, its material financial interests relating to the capital market instrument being the subject of such comments and advices, or its material conflicts of interests with the issuer thereof. Said liability is valid for all natural persons or legal entities who participate in the preparation of investment advices and who work within the frame of a contract creating employment relations with the Institution or without any contract in connection therewith. All information relating to shares equal to or more than 1% held by the issuer and the Institution mutually in each other’s paid capital or voting rights, and management privileges they hold in each other, and material financial relationships between them, such as credit agreement and rent contracts, are required to be disclosed to the customer. a) Prevention and Management of Information Flow:

Bilgi Akışının Önlenmesi ve Yönetilmesi. Kuruluş içinde veya şirketler topluluğunun üyeleri arasında bilgi akışının önlenmesi veya yönetilmesi amacıyla, işlemler sadece bu konuda yetkilendirilmiş personel tarafından gerçekleştirilir. Bilgi güvenliği konusunda genel güvenlik kavramlarının yanı sıra, bilgilerin gizliliğinin, bütünlüğünün ve erişebilirliğinin sağlanması amacıyla “Bilgi Güvenliği Yönetmeliği” ve “Bilgi Güvenliği Uygulama Esasları” hazırlanmıştır. Kuruluşumuz, müşterilerine ait kimlik bilgilerini ve faaliyetleri dolayısıyla öğrendiği her türlü bilgiyi, bu konuda kanunen açıkça yetkili kılınan mercilerden başkasına açıklamaz, elde ettiği bilgileri kendisi veya üçüncü bir tarafın menfaati doğrultusunda kullanmaz. Kuruluşumuzun yetkili olduğu diğer tüm hizmet ve faaliyetler ile yan hizmetlerden dolayı müşterilerimizin çıkarlarına aykırı olabilecek olası durumları engellemek amacıyla; hizmet verilen müşteri bilgileri Portföy Saklama Şubesi’nde ayrı bir sistem üzerinde tutulmaktadır. Saklama hizmeti verilen müşteri bilgilerine Portföy Saklama Şubesi bünyesinde çalışan personel haricinde erişim imkânı bulunmamaktadır. Buna ek olarak denetim, raporlama ve bilgi işlem amaçlı olarak sınırlı sayıda yetkiliye görüntüleme amaçlı erişim yetkisi verilmektedir. offering investment services and activities and ancillary services. Our Institution employees are obliged to pat necessary care and attention in any transaction related to capital markets. This policy and foreseen principles regarding conflict of interest shall not be used in such a manner that will arise the conclusion of making works and transactions against legislation. Our corporation has built become an organization structure adequate for preventing the probable that will prevent conflicts of interests interest in relations with its customers that may occur between on one hand itself itself, its partners, employees, managers and its shareholders, employees and directors and other persons having direct directly or indirect relations indirectly associated with them and on the other hand its customers or as well as between a customer and another customer in the course of its relations with its customerscustomer. All Environment and conditions needed required for professional occupational and personal development are provided to our employees. In the event of our employees are satisfied and met. If a failure to prevent conflict of interests cannot be prevented interest due to reasonable causes arising out reasons caused by the operation of modus operandi of marketsthe market, the customers are informed in writing prior to written about the relevant content and reasons of conflicts of interest that may occur between our Corporation and our customers before offering the related activity or service about the contents, nature and causes takes signature of conflicts of interests customer regarding that may arise between our Institution and our customers, and a statement duly signed by the Customer and verifying such information is receivedhas been made. Our Institution may Corporation shall not engage in make transactions which may be in favor of one or more of our customers and in disfavor of other customers, in violation of against the others against the objective good faith rules and principlesrules. No priority can be granted is given to any person or entity corporation in execution fulfillment of orders of the Customercustomer orders. Time priority rule is applied in accordance with the relevant laws and regulations of the Capital Markets Boardpursuant to related SPK legislation. In the course of performance of offering capital market transactions in to the name of our Customers, for prevention of a conflict of interestscustomer, our Institution Corporate acts together with all other financial institutions having a corporations with capital partnership with binding in preventing conflict of interest. Also our Institution. In addition, our Institution Corporation has built established its systems and applications with a view in order to preventing situations prevent cases where: ; • Our Institution gains It will obtain financial profit gain against customer or avoids it will get rid of financial loss in disfavor of the Customer; loss, • It will obtain interest from service or activity offered to customer although customer has no interest, • our Institution reaps interests out of services and activities provided to the Customer though the Customer does not have an It will obtain interest therein; or • our Institution reaps interests as a result of preference of a preferring one customer or a customer group to another other customer or customer group; or , • our Institution makes It will obtain financial profit, gain other than fees standard fee and commissions, commission from a another person other than the Customer, out of customer due to the activities service and services provided activity offered to the Customercustomer. As a result Within the scope of portfolio brokerage activities wherein our Institution executes as which is the counterparty the purchase activity of Corporation’s fulfilling purchasing or sale sales orders of the customers with regard related to capital market instruments, the customer may suffer a loss, and our Institution instruments as the counterparty may make a profitcounter party, as a requirement it is possible that customer’s making loss and the counter party Corporation’s making profit due to quality of the nature of the services offered service or products offered hereunderproduct. The authorized institution Authorized corporation is under obligation to disclose liable for disclosing to the customer important conflicts of interest with the issuer and important financial conflicts regarding capital market instrument that especially the comment and suggestion is related, all its relations and conditions which may probably that are likely to affect the objectivity of comments and advices provided in suggestions offered during the course of investment consultancy activities, and particularly, its material financial interests relating to the capital market instrument being the subject of such comments and advices, or its material conflicts of interests with the issuer thereofactivity. Said The said liability is also valid for all natural persons real or legal entities who participate persons participating in the preparation of investment advices the suggestion and who work within the frame of a contract creating employment relations with the Institution or employees without any contract in connection therewithor within a frame of contract that will arise employment relation with the Corporation. All It is obligatory to disclose information relating to regarding other important financial relations such as shares equal to that they have at the ratio of 1% or more than 1% held by the in their capitals paid mutually or voting rights of issuer and the Institution mutually in each other’s paid capital or voting rightsCorporation being subject to offered comments and suggestions, and management privileges privilege that they hold in each otherhave, and material financial relationships credit agreement between them, such as credit agreement and rent rental contracts, are required to be disclosed to the customer. a) Prevention Preventing and Management of Managing Information Flow:

Bilgi Akışının Önlenmesi ve Yönetilmesi. Kuruluş içinde veya şirketler topluluğunun üyeleri arasında bilgi akışının önlenmesi veya yönetilmesi amacıyla, işlemler sadece bu konuda yetkilendirilmiş personel tarafından gerçekleştirilir. Bilgi güvenliği konusunda genel güvenlik kavramlarının yanı sıra, bilgilerin gizliliğinin, bütünlüğünün ve erişebilirliğinin sağlanması amacıyla “Bilgi Güvenliği Yönetmeliği” ve “Bilgi Güvenliği Uygulama Esasları” hazırlanmıştır. Kuruluşumuz, müşterilerine ait kimlik bilgilerini ve faaliyetleri dolayısıyla öğrendiği her türlü bilgiyi, bu konuda kanunen açıkça yetkili kılınan mercilerden başkasına açıklamaz, elde ettiği bilgileri kendisi veya üçüncü bir tarafın menfaati doğrultusunda kullanmaz. Kuruluşumuzun yetkili olduğu diğer tüm hizmet ve faaliyetler ile yan hizmetlerden dolayı müşterilerimizin çıkarlarına aykırı olabilecek olası durumları be used in such manner to pave the way for unlawful acts, affairs and transactions. Our Institution has built an organization structure adequate for preventing the probable conflicts of interests between on one hand itself and its shareholders, employees and directors and other persons having direct or indirect relations with them and on the other hand its customers or between a customer and another customer in the course of its relations with its customers. All conditions needed for professional and personal development of our employees are satisfied and met. If a conflict of interests cannot be prevented due to reasonable causes arising out of modus operandi of markets, the customers are informed in writing prior to the relevant activity or service about the contents, nature and causes of conflicts of interests that may arise between our Institution and our customers, and a statement duly signed by the Customer and verifying such information is received. Our Institution may not engage in transactions which may be in favor of one or more of our customers and in disfavor of other customers, in violation of the objective good faith rules and principles. No priority can be granted to any person or entity in execution of orders of the Customer. Time priority rule is applied in accordance with the relevant laws and regulations of the Capital Markets Board. In the course of performance of capital market transactions in the name of our Customers, for prevention of a conflict of interests, our Institution acts together with all other financial institutions having a capital partnership with our Institution. In addition, our Institution has built its systems and applications with a view to preventing situations where: • Our Institution gains financial profit or avoids financial loss in disfavor of the Customer; or • our Institution reaps interests out of services and activities provided to the Customer though the Customer does not have an interest therein; or • our Institution reaps interests as a result of preference of a customer or a customer group to another customer or customer group; or • our Institution makes financial profit, other than fees and commissions, from a person other than the Customer, due to the activities and services provided to the Customer. As a result of portfolio brokerage activities wherein our Institution executes as the counterparty the purchase or sale orders of the customers with regard to capital market instruments, the customer may suffer a loss, and our Institution as the counterparty may make a profit, as a requirement of the nature of the services or products offered hereunder. The authorized institution is under obligation to disclose to the customer all its relations and conditions which may probably affect the objectivity of comments and advices provided in the course of investment consultancy activities, and particularly, its material financial interests relating to the capital market instrument being the subject of such comments and advices, or its material conflicts of interests with the issuer thereof. Said liability is valid for all natural persons or legal entities who participate in the preparation of investment advices and who work within the frame of a contract creating employment relations with the Institution or without any contract in connection therewith. All information relating to shares equal to or more than 1% held by the issuer and the Institution mutually in each other’s paid capital or voting rights, and management privileges they hold in each other, and material financial relationships between them, such as credit agreement and rent contracts, are required to be disclosed to the customer. a) Prevention and Management of Information Flow:

Bilgi Akışının Önlenmesi ve Yönetilmesi. Kuruluş içinde veya şirketler topluluğunun üyeleri arasında bilgi akışının önlenmesi veya yönetilmesi amacıyla, işlemler sadece bu konuda yetkilendirilmiş personel tarafından gerçekleştirilir. Bilgi güvenliği konusunda genel güvenlik kavramlarının yanı sıra, bilgilerin gizliliğinin, bütünlüğünün ve erişebilirliğinin sağlanması amacıyla “Bilgi Güvenliği Yönetmeliği” ve “Bilgi Güvenliği Uygulama Esasları” hazırlanmıştır. Kuruluşumuz, müşterilerine ait kimlik bilgilerini ve faaliyetleri dolayısıyla öğrendiği her türlü bilgiyi, bu konuda kanunen açıkça yetkili kılınan mercilerden başkasına açıklamaz, elde ettiği bilgileri kendisi veya üçüncü bir tarafın menfaati doğrultusunda kullanmaz. Kuruluşumuzun yetkili olduğu diğer tüm hizmet ve faaliyetler ile yan hizmetlerden dolayı müşterilerimizin çıkarlarına aykırı olabilecek olası durumları Our Institution has built an organization structure adequate for preventing the probable conflicts of interests between on one hand itself and its shareholders, engellemek amacıyla; hizmet verilen müşteri bilgileri Portföy Saklama Şubesi’nde ayrı bir sistem üzerinde tutulmaktadır. employees and directors and other persons having direct or indirect relations with them and on the other hand its customers or between a customer and another customer in the course of its relations with its customers. All conditions needed for professional and personal development of our employees are satisfied and met. If a conflict of interests cannot be prevented due to reasonable causes arising out of modus operandi of markets, the customers are informed in writing prior to the relevant activity or service about the contents, nature and causes of conflicts of interests that may arise between our Institution and our customers, and a statement duly signed by the Customer and verifying such information is received. Our Institution may not engage in transactions which may be in favor of one or more of our customers and in disfavor of other customers, in violation of the objective good faith rules and principles. No priority can be granted to any person or entity in execution of orders of the Customer. Time priority rule is applied in accordance with the relevant laws and regulations of the Capital Markets Board. In the course of performance of capital market transactions in the name of our Customers, for prevention of a conflict of interests, our Institution acts together with all other financial institutions having a capital partnership with our Institution. In addition, our Institution has built its systems and applications with a view to preventing situations where: • Our Institution gains financial profit or avoids financial loss in disfavor of the Customer; or • our Institution reaps interests out of services and activities provided to the Customer though the Customer does not have an interest therein; or • our Institution reaps interests as a result of preference of a customer or a customer group to another customer or customer group; or • our Institution makes financial profit, other than fees and commissions, from a person other than the Customer, due to the activities and services provided to the Customer. As a result of portfolio brokerage activities wherein our Institution executes as the counterparty the purchase or sale orders of the customers with regard to capital market instruments, the customer may suffer a loss, and our Institution as the counterparty may make a profit, as a requirement of the nature of the services or products offered hereunder. The authorized institution is under obligation to disclose to the customer all its relations and conditions which may probably affect the objectivity of comments and advices provided in the course of investment consultancy activities, and particularly, its material financial interests relating to the capital market instrument being the subject of such comments and advices, or its material conflicts of interests with the issuer thereof. Said liability is valid for all natural persons or legal entities who participate in the preparation of investment advices and who work within the frame of a contract creating employment relations with the Institution or without any contract in connection therewith. All information relating to shares equal to or more than 1% held by the issuer and the Institution mutually in each other’s paid capital or voting rights, and management privileges they hold in each other, and material financial relationships between them, such as credit agreement and rent contracts, are required to be disclosed to the customer. a) Prevention and Management of Information Flow: