Pegasus Savunma A.Ş. is committed to conducting business transparently, honestly and with integrity.Therefore, Pegasus, takes a zero-tolerance approach to bribery, corruption and ethics violations. All employees and officers of Pegasus are responsible for conducting themselves in compliance with our Code of Business Ethics and Conduct, applicable company policies and laws and regulations.

Pegasus is a TRACE certified company.TRACE has successfully completed a TRACE certification due diligence review of Pegasus Savunma A.Ş.TRACE has issued Pegasus a certificate signifying that the company has completed internationally accepted due diligence procedures and has been forthcoming and cooperative during the review process. TRACE certification underscores Pegasus Savunma A.Ş.’s commitment to transparency in international commercial transactions.

Anti-Bribery and Anti-Corruption Policy

This policy covers all employees of Pegasus Savunma A.Ş and the individuals and corporations that act in the name of or provide services to Pegasus including outsourcing companies, suppliers, consultants, external auditors and representatives. This Policy aims to enable the compliance of the aforementioned parties with the effective antibribery and anti-corruption regulations, as well as ethical and professional principles within this context.

Corruption refers to demanding, offering, giving or receiving any kind of unjust gain or unlawful benefit by any stakeholder that obstructs the fulfillment of his responsibilities in compliance with the law. Bribery refers to obtaining of benefits by a person either directly or through intermediaries in order to do or not to do an act in relation to the performance of his duties.

1. Within the framework of international practices,Pegasus defines major risk areas where bribery and corruption can occur as follows:

• Gifts and hospitality activities
• Donations and sponsorships
• Facilitation payments
• Outsourcing companies and business partnerships
• Abuse of title and duty

2. No payments shall be made, no gifts shall be provided and no personal payment, aid or grant shall be given to any state officer or any other person in order to influence a decision that is related to the continuation of the Pegasus’ activities or that may be beneficial for the institution.

3. It is prohibited for the Pegasus to make political donations and/or to use the opportunities and facilities it owns in order to support a political candidate or institution.

4. The gifts given by the Pegasus shall not aim at influencing the parties related to a procurement or agreement, to which the Pegasus is a party.

5. Pegasus does not tolerate offering of any facilitation payments by its employees in their relations with the third parties.

6. The donations and sponsorships of Pegasus must be in compliance with the effective legislation and internal regulations of Pegasus.

7. The employees of Pegasus shall not demand or accept any gifts from third parties in violation of the provisions of Pegasus’ Gifts and Hospitality Policy and may not engage in any behaviors that might be interpreted as such. In case a Pegasus employee believes that his life or liberty is in danger due to an unlawful payment demand, he/she must receive or make such payment and immediately report this situation to his/her supervisor.

8. The employees of the Pegasus shall not use their duties and authorities, under any circumstances, for the benefit of themselves, their families or third parties in order to obtain personal or private gains.

9. The employees, who receive or are promised to receive any kind of benefit under any name or title either directly or via an intermediary for themselves, their families or third parties by consciously or intentionally misusing their title or duties through mutual agreement, inducement or compulsion, shall be subject to disciplinary action and the judicial bodies shall be notified if required by law.

10. The employees, who refuse to pay bribe or that denounce activities/attempts against the provisions of this policy in good faith and according to honesty and transparency principles, shall not become subject to any punishment and/or maltreatment depending on their behaviour.

11. For the behaviors which are identified as violation of the principles of this policy, required disciplinary sanctions, including termination of the contract of employment, are imposed within the frame of the related provisions and procedures of the Personnel Regulation and Collective Bargaining Agreement. The judicial bodies shall be notified if required by law.

12. Pegasus carries out research and due diligence, regarding bribery and corruption issues, before building business relationships with the parties stated in the “I. Object and Scope” section of this policy.Pegasus does not build any relationship with persons or institutions that have been realized to be engaged in bribery or corruption. In case a relationship of this kind has been built, this business relationship shall be immediately terminated if the engagement in bribery or corruption is proven with a judicial decision.

13. The individuals and corporations that act in the name of or provide services to Pegasus including outsourcing companies, suppliers, consultants, external auditors and representatives must comply with the legislation and all the effective anti-corruption laws.

14. Pegasus regularly provides trainings for its employees on the Anti-Bribery and Anti-Corruption Policy. The employees shall sign a document declaring that they would comply with the provisions of the Anti-Bribery and Anti-Corruption Policy and accept the results of any violating actions.

This policy, which acts as an integral part of the Sustainability Policy of Pegasus, has been approved by the Chairman of the Board and gone into effect on the date of 01 January 2019.

This policy is executed by the related Head Office division under the supervision of the Corporate Governance Committee. At least once in a year, this policy is reviewed in accordance with the requirements and changing operating conditions. Required revisions and amendments, which are submitted to the Chairman of the Board by the Corporate Governance Committee, go into effect with the approval of the Board.