Disclosure Policy

HEKTAŞ TİCARET TÜRK ANONİM ŞİRKETİ
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 non-confidential information, the company's past performance, and
future expectations in a complete, fair, accurate, timely, understandable, and easily accessible manner with all
stakeholders, such as local/foreign shareholders, potential investors, employees, customers, and relevant
authorities, in an equal manner in accordance with the provisions of the Capital Markets Legislation, Corporate
Governance Principles, and the Company’s Articles of Association.
The Company's information policy is carried out in accordance with the provisions of the Capital Markets
Legislation, decisions of the Capital Markets Board, and other relevant regulations. In this framework, the
matters to be disclosed are announced to the public in a timely, complete, and accurate manner.
The Information Policy covers all employees operating within Hektaş.
II- Authority and Responsibility
In accordance with the Corporate Governance Principles of the CMB, the Company’s Disclosure Policy is created
and implemented under the authority of the Board of Directors. The Board of Directors reserves the right to
make changes to this policy from time to time, as required by the relevant regulations. The disclosure policy and
any amendments to the policy are disclosed to the public on the Public Disclosure Platform (KAP) and the
Company's corporate website (www.hektas.com) following the approval of the Board of Directors.
The responsibility for overseeing and monitoring this Information Policy lies with Company Investor Relations
Department.
All written and visual press releases to be made under this policy are announced to the public by the Company
officials, consisting of the Board of Directors, the General Manager, Directors and the Manager of the Investor
Relations Department.
The provision of the Capital Markets Board (CMB) Communiqué II-15.1 on Material Events, Article 10/a:
"Forward-looking statements may be disclosed to the public, provided that they are subject to the written
approval of the Board of Directors or, if authorized, the person authorized by the Board of Directors," is reserved.
III- Information Methods and Tools
The methods and tools used by Company for disclosure under this Disclosure Policy are outlined below.
Financial statements, independent auditor reports, and statements periodically submitted to the Public
Disclosure Platform (KAP)
-Annual Activity Reports
– Investor Presentation Files
-Company Website
-Material event disclosure forms
-Announcements and notices made through the Trade Registry Gazette and daily newspapers
-Communication methods via telephone, email, fax, and other communication tools
IV- Principles Regarding Presentations and Reports Disclosed at Information or Press Meetings
Unless otherwise stated in the Disclosure Policy, only individuals authorized to make public statements on behalf
of HEKTAŞ Ticaret Türk A.Ş. may communicate with capital market participants.
Requests for information from analysts are answered by the Investor Relations Unit, in accordance with publicly
disclosed information, ensuring accuracy, completeness, and adherence to the principle of equality, through
written or verbal responses or information meetings.
For matters subject to special situations, including forward-looking evaluations, press and media outlets, press
conferences and/or press releases, or other communication channels may also be utilized to disclose information
to the public.
Company officials may occasionally participate in conferences or meetings at the national and international levels
to share information with investment institutions and analysts. The presentations used in these events are also
published on the Company’s website in both Turkish and English.
V- Principles Regarding the Monitoring of News and Rumors About the Company in Media Outlets or Websites
and the Disclosure of Related Statements
The Company follows news and rumors appearing in national or international media outlets or other
communication channels through a media monitoring company. In the presence of news or rumors that differ
from the information first disclosed to the public or previously disclosed information, the Company evaluates the
potential impact on the value, price of the shares, or investors’ investment decisions within the framework of its
internal regulations. If deemed necessary, the Company will make a public disclosure in accordance with the
principles set out in capital markets legislation, even if a postponement decision has been made, to assess
whether the information is accurate or sufficient.
The Company may choose to make a statement regarding news and rumors published in media outlets that do
not trigger an obligation for a material event disclosure. These statements may be communicated to the public
through written or verbal communication with the press, or they may be announced via the Company's website
(www.hektas.com.tr).
The Company is not obligated to make a public disclosure regarding the adequacy and accuracy of comments,
analyses, assessments, and forecasts made based on publicly disclosed information through media outlets and
other communication channels.
VI- Measures Taken to Ensure Confidentiality Until the Public Disclosure of Material Events
Company executives, their spouses, children, or individuals living in the same household, are prohibited from
trading in the Company's shares or capital market instruments based on these shares, from the day following the
end of the financial period for which the financial statements and independent audit reports are prepared, until
the public disclosure of these statements and reports in accordance with the regulations. Individuals who hold
shares in the Company and its subsidiaries or controlling affiliates, due to their positions as managers in the
Company or its subsidiaries and controlling affiliates, and who have access to inside information or ongoing
information, are also subject to this prohibition.
The Company may delay the public disclosure of insider information, provided that it can ensure that the release
of such information does not mislead investors and that the information remains confidential, in order to protect
its legitimate interests. In such cases, the Company takes all necessary measures to ensure the confidentiality of
insider information, in accordance with capital markets legislation.
The Company informs its executives and employees, through in-house training programs, about the obligations
outlined in the laws and relevant regulations regarding insider information, as well as the sanctions related to
the misuse or dissemination of such information. The Company takes the necessary measures, such as obtaining
confidentiality agreements from employees not listed as having access to insider information and third-party
service providers, to prevent unauthorized access to such information.
Individuals with access to insider information are informed in writing, against signature, about the obligations
outlined in the laws and relevant regulations regarding such information, as well as the sanctions related to the
misuse or dissemination of these details.
VII- Principles Used in the Identification of Individuals with Administrative Responsibility
Within the framework of the Capital Markets Legislation, "Individuals with Administrative Responsibility" are
defined as the members of the Company's Board of Directors, as well as individuals who, although not Board
members, regularly have direct or indirect access to the issuer's insider information and have the authority to
make administrative decisions that affect the issuer's future development and commercial objectives.
The people with administrative responsibilities are the Board of Directors, the General Manager, and the
Directors.
VIII- Principles Regarding the Disclosure of Forward-Looking Statements
Forward-looking statements containing internal information, including plans and forecasts, or assessments that
provide investors with insights into the issuer's future activities, financial condition, and performance, may be
disclosed to the public within the framework of the principles set forth in the Capital Markets Legislation. The
disclosure of forward-looking statements to the public is not mandatory but is discretionary.
Forward-looking statements are based on reasonable assumptions and forecasts. In the event of deviations due
to unforeseen risks and developments, and if there is a significant difference between previously disclosed
information and actual outcomes, an explanation is provided to the public, including the reasons for these
discrepancies.
The Chairman of the Board of Directors and the CEO are authorized by the Company's Board of Directors to
disclose the Company's forward-looking assessments.
Forward-looking statements, within the framework of the principles set forth in the Capital Markets Legislation,
may be disclosed through material event disclosures, as well as through media outlets, press conferences, press
releases, conferences or meetings at national and international levels, and other communication channels.
All questions regarding the implementation principles and procedures of this policy should be directed to the
Investor Relations Unit.