ANTI-BRIBERY AND ANTI-CORRUPTION

At Akçansa, our Anti-Bribery and Anti-Corruption Policy covers all employees, including the Board of Directors, as well as the organizations and business partners with whom we maintain business relationships. Within the scope of this policy, corruption and bribery, defined as the abuse of authority for personal gain or any form of undue benefit, are considered criminal offenses and are strictly prohibited. The Board of Directors is responsible for the implementation and updating of our Anti-Bribery and Anti-Corruption Policy.

Various training programs are organized to inform our employees about bribery and corruption and to raise awareness on these issues. These topics are also addressed indirectly within the ethics training programs delivered under the Sabancı Group Code of Business Ethics. In 2025, 247 employees received training on anti-bribery and anti-corruption, with a total of 247 training hours recorded. Ethics training programs generally focus on core principles such as integrity, transparency and compliance with laws, while providing a broader ethical framework that also encompasses the prevention of bribery and corruption. Our employees are required to report any violations of our established policies or any suspicious situations they may observe. Employees are encouraged to report such concerns, and reports can be made through the Akçansa Ethics Committee, the Sabancı Holding Ethics Committee, and the Heidelberg Materials Ethics Line. All reports received are handled in accordance with the principle of confidentiality. Alleged violations are reviewed objectively while respecting employee privacy, and where necessary, appropriate disciplinary measures are applied.

In 2025, no disciplinary actions were taken due to corruption. In addition, Akçansa has not been involved in any activities that have been subject to human rights reviews or ethical assessments. Our Anti-Bribery and Anti-Corruption Policy also covers our suppliers. In line with our Sustainable Supply Chain Policy, all our business partners are expected to act in compliance with ethical standards and applicable laws. In 2025, no reports related to bribery or corruption were received, no investigations were initiated, and no contracts with business partners or suppliers were terminated due to corruption. Furthermore, there were no cases of bribery or corruption subject to public litigation.

As Akçansa, we adopt a zero-tolerance approach to bribery and corruption and conduct our operations in line with the principles of transparency, ethical values, and accountability. To ensure the maintenance of high ethical standards for all our employees and business partners, we continue to implement audit and awareness-raising activities. We will also continue to carry out initiatives aimed at increasing awareness of anti-bribery and anti-corruption practices in the coming periods.

You can access Akçansa’s Anti-Bribery and Anti-Corruption Policy here.