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A. PURPOSE

Being one of the leading institutions in sustainable banking in Turkey, Türkiye Sınai Kalkınma Bankası A.Ş. (TSKB) aims to ensure contribution to the country's sustainable development and growth by defining the concept of sustainability in economic, environmental, social and governance terms. The Sustainability Policy designed to this end sets forth the fundamental principles guiding the activities of TSKB.

B. SCOPE

The policy covers all TSKB operations at the Head Office and branches.

The following policies include the complementary principles of this Sustainability Policy.

-TSKB Environmental and Social Impact Management Policy

- Annex: List of activities that are not to be financed

-TSKB Climate Change Mitigation and Adaptation Policy

-TSKB Occupational Health & Safety Policy

-TSKB Equal Opportunities and Inclusion Policy

-TSKB Human Rights Policy

-TSKB Gender Equality Policy

-TSKB Anti-Bribery and Anti-Corruption Policy

-TSKB Gifts and Hospitality Policy

-TSKB Sustainable Procurements Management Policy

-TSKB Responsible Communication Policy

C.  PRINCIPLES AND PRACTICES

TSKB Sustainability Policy includes the following main principles and practices.

The Bank:

1. Determines all positive and negative environmental and social impacts of its activities, and manages such impact in line with the national and international standards;

2. By recognizing the far-reaching impact that climate change has on economic and social welfare and economic growth, seeks to play an active role in the transition to a low-carbon economy and to make use of existing and new forms of credit in order to respond to social demands.

3. Takes into consideration the impact of climate change and the risks related thereto, and ensures contribution to the fight against climate change within the scope of its sustainable and responsible banking activities;

4. Does not finance the activities included in the List of Activities That Are Not To Be Financed in any manner whatsoever;

5. Provides its employees with a sound working environment that is physically and mentally balanced in line with the Occupational Health & Safety requirements and legal regulations, provides training and information, and takes necessary measures;

6. Rejects all forms of discrimination that, contrary to the principle of equal opportunities and inclusion, distinguish among, exclude, or single out individuals on the basis of their gender, sexual orientation, physical appearance, intellectual or physical disability, religion, religious beliefs, race, cultural or social background; recognizes workforce diversity as an essential component of the Bank’s intellectual capital;

7. Supports the increased participation of women in the workforce and in economic activity as a means of maintaining sustainable growth, raising educational levels, and reducing poverty. The Bank’s customers and suppliers are also expected to be mindful of gender equality;

8. Collaborates, and exchanges practical knowledge, with various stakeholders including, but not limited to, non-governmental organizations, universities, and public agencies through national and international initiatives which are related to the Bank’s fields of activity and that support sustainability;

9. Takes part in, and supports, social responsibility projects that support sustainable development in areas such as education, environmental issues, and culture & art;

10. Shares the values created and accumulated with shareholders, customers, employees and other stakeholders under equal terms, accurately, completely, clearly and in an accountable manner;

11. Adopts the principle of sharing all information related to the products and services offered as part of marketing and sales activities with the customers completely, clearly and in an easily-understandable manner in line with the responsible banking approach. Full compliance is ensured with fair competition principles in terms of marketing and sales activities;

12. Considers a sustainable and responsible banking approach in its brand and marketing communication activities. The principles related to the bank's internal and external communication strategies are defined in TSKB Responsible Communication Policy;

13. Creates a workplace environment in which human rights are respected, and social justice and employee rights are constantly improved. The collective consciousness is created to make sure that this approach is adopted by all stakeholders, and awareness is raised to that end. Training is provided to qualified human resources in all managerial and specialist positions at different levels taking into account the principle of equal opportunities and supporting the achievement of TSKB’s goal of being a globally competitive bank. Training is organized with a view to raising awareness on the adoption and management of sustainability policies;

14. Supports a fair compensation and rewarding approach embracing a culture of collaborative effort taking into consideration ethical values, strategic objectives, and employees’ contribution to success in line with the TSKB Remuneration Policy;

15. Assesses the performance of all employees taking part in the Sustainable Management organization in consideration of their tasks and responsibilities in the committees and working groups. These assessments are used for the remuneration and rewarding processes within the scope of TSKB Remuneration Policy;

16. Respects its employees' right of association and right to bargain collectively, which are constitutional rights. Bribery and corruption shall not be tolerated under any circumstances. In applicable cases, actions shall be taken in line with the TSKB Anti-Bribery and Anti-Corruption Policy;

17. Does not allow its employees to solicit or accept gifts from its customers or any other stakeholder directly or indirectly in violation of the Bank's Gifts and Hospitality Policy, or to commit actions resulting therein;

18. Works in close cooperation with its suppliers in order to manage the occupational health and safety risks, and environmental and social impact of its supply chain operations. Provides its suppliers with support in increasing their occupational health and safety, as well as environmental and social sustainability performance. Such matters shall be dealt with as provided in TSKB’s Sustainable Procurements Management Policy;

19. Formulates medium- and long-term strategies in a manner to observe the rights and interests of all stakeholders and the public good;

20. Constantly revises and improves sustainability practices, and declares related operating performance and targets to the stakeholders and the public via sustainability reports issued in line with the principles of transparency.

D. ROLES AND RESPONSIBILITIES

The sustainability activities of the Bank are carried out by the Sustainability Management structure consisting of the Bank's senior management and employees experienced in sustainability. The Sustainability Committee has been founded with the aim of ensuring that the Bank's business plans are created in line with the Bank's sustainability strategy, vision and targets are adopted and managed at the Board of Directors level. The Committee consists of at least three Members of the Board of Directors selected by the Board of Directors, the General Manager and two Executive Vice Presidents. The activities of the Sustainability Committee are supported by the Sustainability Management Committee and working groups, to whom representatives of different departments of TSKB are a member. Convening regularly throughout the year, the Committee follows up on the activities of Sustainability Management Committee and working groups. A "Sustainability Coordinator" is assigned in order to ensure the coordination of Sustainability Management organization, and perform the secretariat works of the Sustainability Committee.

E. REVISION

TSKB Sustainability Policy is revised by the Sustainability Committee at least once a year together with the supplementary policies in line with the requirements and the changes in operating conditions. The updates and changes deemed necessary are implemented upon being proposed by the Sustainability Committee and approved by the Board of Directors. These policies are made available for access by all stakeholders through the corporate website and by the employees through the Bank's corporate intranet.

F. EFFECTIVE DATE

This version of the TSKB Sustainability Policy that has taken effect in 2012 for the first time goes into effect as of the date on which it is approved by the Board of Directors.