Disclosure Policy

DISCLOSURE POLICY

I- Purpose and Scope

The purpose of the Disclosure Policy of Hektaş Ticaret T.A.Ş. (“Hektaş”) is to ensure continuous, effective and transparent communication by sharing all kinds of information that is not in the nature of trade secrets, as well as the Company’s past performance and future expectations equally with all stakeholders such as domestic/foreign shareholders, potential investors, employees, customers and related authorized institutions in a complete, fair, accurate, timely, comprehensible and easily accessible manner, within the framework of the provisions of the Capital Market Legislation, Corporate Governance Principles and the Articles of Association of the Company.

The Company’s disclosure policy is implemented in the light of the issues within the scope of the Capital Market Legislation, decisions of the Capital Market Board and other relevant legislation and the matters required to be disclosed within this framework are announced to the public on time, accurately and fully.

The Disclosure Policy covers all employees active within Hektaş.

 II- Authority and Liability

Our Company’s Disclosure Policy is established and implemented under the authority of the Board of Directors. The Board of Directors also reserves the authority to amend this policy from time to time as per relevant regulations. The disclosure policy and amendments to be made in the policy are published on the Company’s web site upon the approval of the Board of Directors.

The Investor Relations Department of our Company is responsible for adhering to and following this Disclosure Policy.

All written and visual press releases to be made within the scope of this Policy are announced to the public by the Company’s authorities including the Chairman of the Board of Directors, General Manager, Assistant General Managers and the Head of the Investor Relations Department. The provision of the article 10/a of the Special Cases Communiqué no. II-15.1 of the CMB which states that, “Prospective evaluations may be disclosed to the public provided that they are subject to a decision of the board of directors, or the written approval of the authorized person, if an authority is granted by the board of directors,” is reserved.

III- Disclosure Methods and Instruments

The disclosure methods and instruments used by our Company within the framework of this Disclosure Policy are as follows.

–Financial statements, independent auditor’s reports and declarations periodically entered in the Public Disclosure Platform (KAP)

– Annual Activity Reports

– Web Site of the Company

– Special case disclosure forms

– Declarations and announcements made in the Trade Registry Gazette and daily newspapers

– Communication methods by means of communication tools such as telephone, e-mail, fax

IV- Principles regarding presentations and reports announced at information meetings or press conferences

Demands for information communicated to the Company from shareholders, investors and analysts are replied to in writing, verbally or through disclosure meetings in line with the principle of equality and in an accurate and complete manner by the Investor Relations Department, within the framework of the publicly disclosed information.

Press and media organs, press conferences and/or press releases or other means of communication may also be used to publicly announce matters subject to special cases, including prospective evaluations. Before or simultaneously with these announcements, a statement is also made on the Public Disclosure Platform and is also posted on the Company’s website.

The Company’s authorities may occasionally attend national and international conferences or meetings to share information with investors and analysts. The presentations used in these events may also be posted on the Company’s web site.

V- Principles for the follow-up of news and comments about the Company in the press and media organs or on the Internet, as well as making statements relating to such news and comments

The Company follows the news and comments in the national or international press and media organs or other communication channels via a media monitoring company, and in the event of news or comments with content different than the information previously disclosed to the public or disclosed to the public for the first time, the Company evaluates their impact on the value and price of the Company’s shares or investors’ investment decisions within the framework of its internal regulations. In cases where deemed necessary, a public statement is made immediately within the framework of the principles determined under the capital market legislation regarding whether they are accurate or adequate, even if a decision of postponement had been made.

The Company may wish to make statements regarding news and comments that appear in the press and media organs, but that do not give rise to an obligation to make special case disclosures. These statements may be in the form of written or verbal communication via the press and may also be announced to the public via the Company’s web site (www.hektas.com.tr).

With respect to comments, analyses, evaluations and estimations made based on publicly disclosed information, via press and media organs and other means of communication, the Company is not obliged to make statements to the public regarding their accuracy and adequacy.

VI- Measures taken to ensure confidentiality until special cases are disclosed to the public,

The Company’s executives and their spouses, children or household members may not conduct transactions on the Company’s shares or capital market instruments based on these shares within the period starting from the day that follows the end of the fiscal period when the financial statements and reports drawn up by the Company and independent audit reports are prepared, until the public disclosure of these statements and reports in accordance with the legislation. Executives of the Company’s subsidiaries and controlling partnerships, as well as persons who have inside information or permanent information due to ownership of shares in the Company and its subsidiaries and controlling partnerships are also covered by this prohibition.

The Company may postpone the public disclosure of the inside information in order to prevent harm to its legitimate interests, provided that this does not result in the investors being misled and is capable of ensuring the confidentiality of the information. In these cases, the Company takes all kinds of measures to ensure the confidentiality of the inside information under the capital market legislation.

The Company informs its executives and employees about the liabilities stipulated in the law and the relevant legislation with respect to inside information as well as sanctions relating to the misuse or dissemination of such information, through in-service trainings. The Company takes the necessary measures by obtaining confidentiality commitments that prevent the access of employees other than those in the list of persons with access to inside information and third parties providing services and through similar methods.

Persons with access to inside information on the other hand are informed about the sanctions relating to the misuse or dissemination of such information, in writing and by obtaining their signatures, by ensuring the acknowledgment of their obligations in the law and the relevant legislation regarding inside information.

VII- Principles used in determining the persons with administrative liability

Under the Capital Market Legislation, “Persons with Administrative Liability” are described as the Company’s board of directors members and persons who are not members of the board of directors, but who regularly access the issuer’s inside information directly or indirectly and have the authority to take administrative decisions that affect the issuer’s future development and business goals.

The Persons with Administrative Liability in our Company are determined as Members of the Board of Directors, General Manager and Assistant General Managers, Accounting and Budget Manager, Finance Manager, Domestic Sales Manager, Purchasing Manager, Human Resources Manager, R&D and Quality Control Manager, Production Manager, Foreign Sales Manager , Plant Protection P&D Manager, Information Technologies Manager, Animal Health Licensing and P&D Manager, Project and Maintenance Manager, Logistics Manager, Product Manager, Commercial Marketing Manager, Human Resources and Quality Systems Coordinator.

VIII- Principles regarding the disclosure of prospective evaluations

Evaluations that include plans and estimations in the nature of prospective inside information or provide investors with insight about the issuer’s future activities and financial situation  and performance may be disclosed to the public within the framework of the principles specified in the capital market legislation.

Prospective evaluations are based on reasonable assumptions and estimations and in the event of deviations due to unpredictable risks and developments, a public statement is made by specifying the reasons for differences as well, if there are significant differences between the matters previously disclosed to the public and the actual situations.

The Chairman of the Board of Directors and the General Manager are authorized by the Company’s Board of Directors to disclose the Company’s prospective evaluations.

Prospective evaluations may be made through special case disclosures, media organs, press conferences, press releases, national and international conferences or meetings, and other means of communication, within the framework of the principles stipulated in the capital market legislation.

All questions regarding the application principles and procedures of this policy should be directed to the Investor Relations Department.