OUR ETHICAL VALUES AND BUSINESS ETHICS RULES

I. OUR BUSINESS ETHICS RULES

A. Honesty

Truthfulness and honesty are our fundamental values in all our business processes and relationships. We act with honesty and integrity in our relationships with our employees and all our stakeholders.

B. Confidentiality

Confidential information includes information that could harm the company's competition, trade secrets, undisclosed financial and other information, the information of our employees and patients, the personal data of our stakeholders, and information for which we are responsible under confidentiality agreements with third parties.

As company employees, we keep the information of our patients, employees, and other relevant individuals and organizations with whom we cooperate confidential and commit to protecting this information. We protect the confidential information related to the activities of BHT CLINIC Health Inc., use this information only for the purposes of BHT CLINIC, and share it with relevant persons only within the scope of designated authorities by the senior management.

C. Conflict of Interest

BHT CLINIC employees diligently avoid actions that would result in a conflict of interest. They take care to protect the interests of BHT CLINIC during their duties and refrain from any actions and behaviors that could mean providing benefits to themselves and their relatives. Under no circumstances is it permitted for personal interests to conflict with BHT CLINIC's interests or for employees to obtain inappropriate personal benefits due to their position or to provide benefits to their relatives or third parties.

In cases of uncertainty, we consult our Manager or the Human Resources Department.

D. Our Responsibilities

In addition to our legal responsibilities, we take care to fulfill our responsibilities towards our patients and their relatives, our colleagues, shareholders and partners, suppliers and business partners, the environment, our competitors, society, humanity, and on behalf of BHT CLINIC as listed below.

1. Regarding Laws

BHT CLINIC is committed to high standards of ethical conduct. It conducts all its activities in full compliance with national and, where necessary, international laws and regulations. While fulfilling our legal obligations in all our activities, we approach all institutions and organizations without any expectation of benefit and maintain an impartial and equal distance from non-governmental organizations and political parties. We ensure that all reports, financial statements, or records prepared by BHT CLINIC are kept in accordance with national and international accounting principles determined by the current legal legislation.

2. Regarding Patients and Their Relatives

We work with a proactive approach that centers on patient satisfaction and meets the needs and requirements of our patients in the shortest time and most accurate way. We provide our services in a timely and most effective manner. We approach our patients with respect and kindness and treat them equally without discrimination.

3. Regarding Employees

We form the BHT CLINIC workforce without discrimination, especially in terms of race, color, religion, age, gender, political opinion, national origin, or social origin. We respect the private lives of our employees.

We ensure that personal rights are fully exercised. We ensure that employees work in safe, healthy, and suitable working conditions, and at the same time, we provide the necessary effort and opportunities for individual development, and we act fairly and offer equal opportunities in matters such as training, career, and promotion.

4. Regarding Our Partners

Giving priority to the continuity of BHT CLINIC Health Inc. and in line with the goal of creating value for our partners; we avoid taking unnecessary or unmanageable risks and aim for sustainable profitability. We act within the framework of financial discipline and accountability, and we manage our company's resources and assets and our working time with an awareness of efficiency and savings. We take care to increase our competitiveness and to invest in areas that have growth potential and will provide the highest return on the invested capital. In our public disclosures and to our shareholders, we provide timely, accurate, complete, and understandable information about our financial statements, strategies, investments, and risk profile.

5. Regarding Our Suppliers/Business Partners

BHT CLINIC is committed to being in fair, balanced, impartial, and mutually respectful relationships with all suppliers, institutions, insurance companies, etc., starting from the negotiation stage. Just as BHT CLINIC protects its own image and information confidentiality, it also protects the images and confidential data of its business partners.

6. Regarding Our Competitors

BHT CLINIC competes with rival hospital businesses actively and within a framework of mutual respect, only on legal and ethical grounds, and avoids violations of competition law. It does not support initiatives aimed at restricting or limiting competition.

7. Regarding Society and the Environment

BHT CLINIC acts with an awareness of its responsibilities towards society and the environment. While producing products in compliance with international standards, it will always remain loyal to the principles of continuously improving human health, operational safety, and environmental protection standards. All official statements are made through individuals and units designated by BHT CLINIC. Apart from this, no employee can make verbal or written statements to media organizations. We try to engage in appropriate activities on issues that are for the benefit of society and the public. We strive to reduce our natural resource consumption by ensuring the efficient use of energy, water, and recyclable materials. We conduct environmental awareness activities for our employees and subcontractors to act in an environmentally sensitive manner in their activities. We commit to complying with all environmental laws, statutes, and regulations we are obliged to follow.

II. POLICIES SUPPORTING THE BUSINESS ETHICS RULES

A. Conflict of Interest Policy

It is essential for BHT CLINIC Health Inc. employees to avoid situations that would result in a conflict of interest. It is one of the most important responsibilities of all employees to avoid situations such as using the BHT CLINIC name, assets, and resources for personal interests.

Implementation Principles

1. Activities That May Create a Conflict of Interest

All company employees are required to fully comply with the principles stated below. Companies will take the necessary steps to encourage their employees to comply with these principles.

i. Engaging in Activities That May Create a Conflict of Interest

Company employees do not enter into business relationships that provide mutual or non-reciprocal benefits for any activity that would mean providing benefits to themselves and their relatives. For example, a person working as a purchasing manager in the hospital should avoid doing business with a supplier where one of their family members works. Exceptional cases are presented to the knowledge and approval of the Chairman of the Board of Directors. Similarly, Company employees should also be careful about conflicts of interest that may arise from their close family members working in rival hospitals.

Employees cannot obtain any commercial benefit, including buying and selling shares on the stock exchange by leaking any company information from the inside, nor can they enable others to obtain benefits.

ii. Abuse of Authority

They do not use, and prevent the use of, BHT CLINIC assets and resources for their personal interests. They cannot obtain personal gain in any way by using company resources.

It is unacceptable for employees to harm the company by using their authority for their own or their relatives' benefit and beyond the expected diligence. They cannot act contrary to the company's policies and procedures or business discipline.

iii. Use of Resources

In the use of resources on behalf of the company, the company's interests are taken into account. Without the company's interest, under any name and for whomever's benefit, company assets, facilities, and personnel cannot be used outside the company. The principle of "savings in every matter" is applied by all personnel.

iv. Relationships with Other Persons and/or Organizations with which the Company has a Commercial Relationship

No special business relationship can be entered into with hospital patients, subcontractors, or suppliers and other persons and/or organizations with which there is a commercial relationship; no personal loans of money and/or goods/services can be taken, and no loans of money and/or goods/services can be given to other persons and/or organizations with which there is a commercial relationship.

v. Media Relations

Giving statements to any publication, giving interviews, participating as a speaker in seminars, conferences, etc., is subject to the approval of the company's senior management. No personal gain can be obtained from these activities in any way.

vi. Representing the Company

Any fees obtained from duties performed on behalf of the company in all kinds of associations, employer unions, and similar non-governmental organizations are donated to the relevant institution or to channels indicated by the relevant institution.

B. Gift Acceptance and Giving Policy

It is essential that BHT CLINIC Health Inc. and its employees do not engage in attempts to benefit from gifts, products, and services aimed at providing privileges or benefits that are not in line with the course of business and that could affect their impartiality, decisions, and activities.

Implementation Principles:

1. Company employees do not accept gifts, whether of material value or not, that would affect their decisions and activities or are aimed at providing privileges or benefits not in line with the course of business.
2. Company employees may accept symbolic awards, etc., of memorable value from the organizations they attend on behalf of the company, excluding money.
3. No gifts can be accepted with any consideration of benefit.
4. Accepting/giving bribes is unacceptable under any circumstances.
5. Company employees cannot ask for loans from suppliers, subcontractors, colleagues, and subordinates.
6. Company employees can give promotional products approved by the senior management to people and customers they have a business relationship with.

C. Protection of Confidential Information Policy

Information is one of the most important assets that BHT CLINIC Health Inc. will use on its way to achieving its vision. In this regard, the effective use of information, its correct sharing, and ensuring the confidentiality, integrity, and accessibility of information in this process is the common responsibility of all our companies and employees.

Implementation Principles

Confidential information includes, but is not limited to, information belonging to BHT CLINIC Health Inc. that could create a competitive disadvantage, trade secrets, financial and other information not yet disclosed to the public, information on personnel's personal rights, personal data of our employees, patients, and stakeholders, and information we are obliged to protect within the framework of "confidentiality agreements" made with third parties.

The principles to be followed regarding confidential information:

1. This information cannot be disclosed to third parties unless its disclosure is required by Official Authorities and Legislation.
2. This information cannot be altered, copied, or destroyed. Necessary measures are taken to keep the information carefully, store it, and prevent its disclosure.
3. Confidential files cannot be taken outside the institution. For confidential information that needs to be taken outside the institution, the approval of the information's owner or senior management must be obtained.
4. Passwords, user codes, and similar identifiers used to access company information are kept confidential.
5. Confidential company information is not discussed in public places such as dining halls, cafeterias, elevators, service vehicles, etc.
6. Confidential information is classified according to its degree of confidentiality, and this is clearly stated in the content of the information.
7. If information needs to be shared with third parties and/or organizations for the benefit of the Company, a confidentiality agreement is signed first.
8. Personal information such as wages, fringe benefits, and similar employee rights are confidential and cannot be disclosed to anyone other than authorized persons.
9. Actions are taken in accordance with the legislation on the Protection of Personal Data.
10. Ethical obligations regarding confidentiality continue for employees who have left their job.

D. Policy on Creating and Maintaining a Fair Working Environment

BHT CLINIC HEALTH INC. considers the creation and maintenance of a fair working environment for its employees as one of its most important priorities.

Implementation Principles

1. Company practices are compliant with all relevant laws and regulations in force regarding employment and working life.
2. Human resources policies and practices ensure that all other applications such as recruitment, promotion-transfer-rotation, remuneration, rewarding, social rights, etc., are fair.
3. Discrimination among employees within the institution based on language, race, color, gender, political opinion, belief, religion, sect, age, physical disability, and similar reasons is unacceptable.
4. A supportive, positive, and harmonious working environment is created in the company, and conflict situations are prevented, ensuring that people with different beliefs, thoughts, and opinions can work together in harmony.
5. The private lives and personal spaces of employees are respected.
6. In addition to all kinds of immunities of employees, their physical, sexual, and emotional immunities are also protected.
7. It is ensured that the physical working environment and conditions of the workplace are healthy and safe for all employees.
8. BHT CLINIC HEALTH INC. acts as a pioneer and in a sensitive manner regarding its responsibilities towards society and humanity to ensure that its main activities do not have negative impacts on the environment.

IV. RESPONSIBILITIES OF EMPLOYEES

The relevant policies and procedures have detailed the ethical rules on how we should behave and how we should do our job. Compliance with these rules is the primary responsibility of all employees. In this regard, all employees;

• To act in accordance with laws and regulations under all circumstances,
• To read the Business Ethics Rules, to know, understand, internalize, and act in accordance with the rules, principles, and values contained therein,
• To learn the general and job-related policies and procedures applicable to the company,
• To consult their manager and human resources on potential violations concerning themselves or others,
• To promptly report their own or others' possible violations,
• Have the responsibility to cooperate with the Disciplinary Board in investigations and to keep information related to the investigation confidential.

V. RESPONSIBILITIES OF MANAGERS

BHT CLINIC managers have additional responsibilities beyond those defined for employees within the framework of business ethics. Accordingly, managers;

• Are responsible for creating and maintaining a company culture and working environment that supports ethical rules,
• For setting an example with their behavior in the implementation of ethical rules and for training their employees on ethical rules,
• For supporting employees in communicating their questions, complaints, and notifications regarding ethical rules,
• For providing guidance on what to do when consulted, considering all notifications received, and forwarding them to the Disciplinary Board as soon as possible when deemed necessary,
• Are responsible for structuring the business processes under their responsibility in a way that minimizes risks related to ethical issues and for implementing the necessary methods and approaches to ensure compliance with ethical rules.

VIII. REPORTING AND RESOLUTION OF NON-COMPLIANCE WITH ETHICAL RULES

If employees learn that the Company's Business Ethics Rules or the legal regulations to which the Company is subject have been violated, they are obliged to report this first to their direct manager. If the situation is related to the direct manager, they should report it to the company's General Manager, and if no action is taken and no result is obtained, they are obliged to report it to the Disciplinary Board.

A. Disciplinary Board

The Disciplinary Board reports to the Chairman of the Board of Directors of BHT CLINIC HEALTH INC. The Disciplinary Board consists of the General Manager, Deputy General Managers, Chief Physician, Human Resources Manager, Patient Care Services Manager, and Financial Affairs Officer.

The Disciplinary Board was established to resolve conflicts of interest, to evaluate notifications of violations of the ethical rules determined by the board, and to decide on the path, method, and practices to be followed in cases of ethical rule violations.

B. Working Principles of the Disciplinary Board

• The Disciplinary Board conducts its work within the framework of the principles set out below.
• It keeps notifications and complaints, as well as the identity of those who make them, confidential.
• Everyone who makes a notification to the Disciplinary Board is under the protection of the Disciplinary Board due to their notification, and they cannot be subjected to behaviors such as pressure, discrimination, or mobbing.
• The Disciplinary Board conducts the investigation with as much confidentiality as possible.
• It has the authority to request information, documents, and evidence directly from the relevant unit.
• The investigation process is recorded in written minutes from the beginning.
• The minutes are signed by the members of the Disciplinary Board.
• The investigation is handled urgently and a conclusion is reached as quickly as possible.
• The decisions of the board are implemented immediately.
• The relevant departments and authorities are informed about the result.
• While fulfilling their duties on this matter, the board members act independently of and without being influenced by the managers of the departments they are affiliated with and the hierarchy within the organization.
• The board may consult an expert opinion if it deems necessary and may benefit from experts during the investigation by taking measures that will not violate the principles of confidentiality.