Page 4 - Code Of Governance

Aim and Scope

1. Ethics, in the simplest term, examines the standards of judgments which are widely
and universally accepted in human relations. On the other hand, business ethics is
the unity of principles that are developed for the purpose of guidance to behaviors in
business world.

2. This Code of Governance hereby prepared for Nurol Holding Incorporated Company and
the Group Companies (hereinafter referred to as “NUROL”) is composed of our ideas and
behaviors which are the basis of all of our business relations and processes as well as our
standards which are settled in this regard. These codes/rules also describe policies which
determine risk management, working principles, ethic rules for behaviors and internal
controls which are to be obeyed in all areas of operation. This document is composed
of Code of Governance as well as Policies and Codes of Practice. Moreover; it is of high
importance in terms of determining working procedures of everyone.

3. Covering the whole Nurol Holding Inc. Co. and its Group Companies, third parties acting
on its behalf and its employees as well as constituting our joint working procedures and
principles, this Code of Governance hereby (“Nurol Codes of Ethics”) is a kind of instructive
for all the employees in all kinds of our activities and business processes.

General Principles

Code of Governance is composed of two sections:

a) Codes of Ethics (Codes of ethics and working principles are composed of 5
fundamentals of ethics).

b) Policies and Codes of Practice (policies which determine working principles).