Policies

• Employee performance evaluations are conducted under the “Target-Based Performance Evaluation System.” This model aligns the Bank’s strategic objectives with individual goals to foster a shared high-performance culture.
• The “Target-Based Performance Evaluation System” is objective, as it relies on concrete and measurable targets. At the beginning of the year, managers and employees collaboratively set personal goals aligned with their responsibilities that contribute to the Bank’s strategic goals. Throughout the evaluation year, development processes are closely monitored through effective feedback, and development strategies are planned on an employee basis.
• Performance Evaluation results inform actions for high-performing employees and identify necessary support to improve low performance. The system ensures recognition for employees who achieve notable results, facilitates identification of individual training needs, and serves as the foundation for creating employees' career and talent plans, as well as for identifying critical roles.

• The primary goal is to plan essential career steps to ensure that high-potential employees who embrace the Bank’s vision, mission, and core values are prepared for managerial roles within the Bank. In this context, employees are encouraged to actively participate in their career planning, managing this process in collaboration with their reporting managers based on their performance evaluation results.
• The Bank develops its managers from within, giving priority to internal candidates for any lateral and upward career opportunities that may arise.
• To optimize the use of qualified human resources, the Bank’s promotion process is structured to allow employees with strong performance and competencies to advance to higher roles.

• The core objective of the Bank’s remuneration policy is to establish a fair compensation strategy aligned with the Bank's strategic goals, designed to attract new talent, retain existing employees, and enhance performance.
• The remuneration structure is designed objectively and rationally, taking into account both internal factors related to the nature and requirements of each role and external benchmarks, including data on wages within the Banking Sector.
• It is essential that all remuneration practices are fair, transparent, and confidential, based on objective performance goals, support sustainable success, and are aligned with the Bank’s risk management principles.

In line with its strategic goals, our Bank:;

• aims to support both the personal and professional growth of our employees with suitable training programs to maximize the effective and efficient use of human resources.
• creates an environment and opportunities for employees to realize their potential.
• strategically plans employee training and development to build a qualified and successful talent pool..

In order to achieve effective and robust compliance risk management, our Bank has adopted strong and effective customer due diligence principles, which are the most effective way to combat money laundering and terrorist financing.

Ongoing and continuous review practices are essential for customer due diligence within specified periods.

Our strong and robust CDD implementation principles/key elements include:

• Identification and confirmation of the cutomer's identity and beneficial owners, and verification of the source of funds and/or assets,
• Checking customers and beneficial owners against international sanction lists,
• Scanning negative media news,
• Gathering detailed information about the purpose and content of the business relationship,
• Obtaining information on expected/forecast transaction volumes and types,
• Conducting systematic identification and customer risk rating according to customer types in compliance with legal regulations,
• Establishing detailed know your customer, acceptance rules, and warning mechanisms, including senior executive approval for high-risk individuals and institutions,
• Performing customer and transaction monitoring activities with a risk-based approach,
• Examining and investigating unusual customers and transactions,
• Keeping customer information and documents up to date, documenting/storing information and identified situations,

Establishing and maintaining business relationships with customers based on transparency and mutual trust.

The asset freezing decision and the decision on lifting this decision take legal effect upon publication in the Official Gazette, and it is immediately checked whether there is an asset record with our Bank regarding the persons, institutions, or organizations for which there is an asset freezing decision. If there is an asset record with our Bank, necessary actions are taken and the information regarding the frozen assets is notified to the Board in accordance with the periods specified in the relevant legislation from the notification date.

As a result of customer due diligence within the scope of the above-mentioned principles, the following is essential:

• Identification of the customer's risk,
• Detailed assessment of customers classified as high-risk,
• Taking actions to establish, reject, and/or terminate the business relationship with the customer.

The risk-based approach established within the scope of local and international legislation forbids entering into business relationships, providing products and services to the following persons and institutions:

• Persons and institutions requesting account opening with anonymous/fake names and aliases,
• Shell Banks and Companies,
• Persons and organizations engaged in casinos, illegal, and/or illicit betting activities,
• Non-Profit Organizations (Foundations, Associations, etc.) registered in a country other than Turkey,
• Individuals and institutions unwilling to provide necessary information and documents or cooperate, making customer due diligence impossible (e.g., unverifiable identity information or dubious reliability of shared information),
• Individuals and institutions that are suspected or have reasonable grounds for suspicion that their assets or source of funds are related to laundering and terrorism financing offenses,
• Individuals and organizations on international sanctions lists,
• Individuals and institutions seeking services, products, or transactions for tax evasion,
• Individuals and institutions transferring or trading funds/assets on behalf of their clients or third parties,
• Individuals and institutions requesting acceptance of funds and assets without customer identification and confirmation, or without identifying the beneficial owner and obtaining information on the nature and purpose of the business relationship.

When identification cannot be made at our Bank or sufficient information cannot be obtained about the purpose of the business relationship, the business relationship cannot be established, and our personnel do not perform the transactions requested by customers.

The business relationship is terminated if the required identification and confirmation cannot be made due to doubts about the adequacy and accuracy of the customer identity information previously obtained.

Our Bank identifies tools that define potential risk assessment criteria using a risk-based approach and performs customer and product services risk ratings by evaluating customer, product, and geographical risks within the established framework. Our Bank's risk rating is (i) Low, (ii) Medium, and (iii) High.

For customers classified as low risk, relatively basic and/or low controls are applied compared to other risk classes within customer due diligence, account review, and assessment.

For customers classified as medium risk, additional controls are applied when necessary, beyond the relatively basic controls applied to low-risk classes, within customer due diligence, account review, and assessment.

For customers classified as high-risk, the Bank's principles can be summarized as enhanced due diligence and close monitoring and review of transactions and customer behavior.

A suspicious transaction is any information, suspicion, or doubt that the assets involved in a transaction, whether made or attempted by or through the Liable Parties, have been obtained illegally, used for illegal purposes, including terrorist acts, or used by terrorist organizations, terrorists, or terrorist financiers, or related or connected to them.

It is a legal obligation to notify MASAK in cases of suspicion or any matter requiring suspicion.

The customer and transaction monitoring process begins with confirming the asset/fund source and analyzing the nature and purpose of the transaction. Transactions should align with the customer's risk profile and financial profile. A reasonable assessment should be made based on the following factors:

• Customer's risk level
• Nature and history of the employment relationship
• Transaction risk level determined according to the Bank's risk category and rating criteria

New and existing employees receive training in line with national and international regulations on the anti-money laundering and combating the financing of terrorism, as well as the Bank's internal policies. The Bank conducts training activities under the supervision and coordination of the Compliance Officer, within the framework of the applicable legislation and the annual training program approved by the Board of Directors. These activities are tailored to the size of the business, transaction volumes, and evolving conditions to prevent laundering proceeds of crime and the financing of terrorism. The training program is prepared by the Compliance Officer with the participation of relevant units. Training sessions may be conducted face-to-face through seminars, panels, or conferences, or online via electronic platforms such as internet or intranet-based systems. The Compliance Officer monitors the effective implementation of the training program. Training activities are carried out in accordance with a structured training plan and program that includes the following topics:

• Concepts of laundering proceeds of crime and financing of terrorism,
• Concepts of financing the proliferation of weapons of mass destruction,
• Stages and methods of laundering proceeds of crime, including case studies,
• Legislation on the prevention of laundering proceeds of crime and the financing of terrorism,
• International regulations on anti-money laundering and combating the financing of terrorism,
• Risk areas,
• Principles of Customer Due Diligence.r

The purpose of training activities is to ensure compliance with obligations under the applicable legislation, foster a corporate culture, and update employees' knowledge by enhancing their awareness of responsibilities related to this Policy, the Bank's internal policies, and its risk-oriented approach.