CARGAS DE ESTRIBOR

Objectivity

Since the provision of media services constitutes its main field of activity, DYH is bound by its public duty and maintains an objective stance concerning public order and policy. This approach is also expressed in the code of ethics.

DYH respects the privacy of individuals within the scope of its media activities. DYH and its employees safeguard personal information gathered concerning the people and companies with whom they are associated, in accordance with the relevant laws and legislation. The management and employees of the Company cannot offer any material benefits to people they are associated with due to their or the Company’s interest. Institutions under the helm of DYH will not permit, contribute, or tolerate any commercial dealing that is in breach of this policy. DYH employees know their business clients and do not enter into commercial dealings with people involved in criminal acts, or into relations on money laundering activities with these persons. DYH operates in several countries beyond Turkey’s borders. The operations in all these countries are fully compliant with the international trade regulations governing issues such as licensing, shipping bills, import documents and storage of reports and records. DYH makes the utmost effort to make sure that transparency and credibility prevails in capital markets. Trade secrets, trademark, copyright and other information governed by intellectual property rights are among the most valuable assets of DYH. It is one of DYH’s main policies to establish, protect, maintain and defend all its commercially significant intellectual property rights and to use those rights in legally responsible ways. All employees should take necessary precautions to safeguard these assets. Just as it protects its own intellectual

A) DYH’s Core Values

1. Compliance with the law and social, democratic values

DYH does not violate the law. It does not offend social values or behave in a way that may have a negative impact on its reputation. DYH respects the democratic structure and associated rules. It believes in and supports modernization.

2. Focus on customers

The sole reason for DYH’s existence is its customers, who purchase its books, advertise through its channels and use goods and services that it provides. It is DYH’s responsibility to understand and meet customer expectations and, in the end, earn their respect.

3. Our actions earn us pride and respect

Every activity at DYH is evaluated on the basis of pride and respect, the most important of DYH’s core values. Our reputation is our most valuable asset. Our relationships with each other should also earn the Group pride and respect.

4. Our operations create value for our shareholders

DYH operations are built upon economic realities and prudent management principles. The Group does not engage in operations that do not create economic value because we believe that uneconomic activities harm our country, our society and our other core values in the long- term.

B) Practices Regarding Codes of Conduct

1. Responsibilities of the employees

All personnel at DYH and the Group companies working under an employment contract for a definite or indefinite period are subject to the DYH Code of Conduct. Subsidiaries of DYH and other Group affiliates commit to adopting and implementing similar rules.

2. Responsibilities of executives and leaders

Executives shall lead the efforts to regularly monitor matters related to direct reporting and compliance with the rules. They should set an example for all employees with their leadership and conduct. They are required to ensure that the employees understand that performance is never more important than complying with the corporate rules. The executives shall encourage employees to share their doubts about honesty and to ask any questions they may have.

3. Reporting

One of the most important responsibilities of DYH employees is to report to the relevant office whenever they suspect a violation of DYH’s Code of Conduct or the law.

C) Relationships with Customers and Suppliers

1. Inappropriate payments

DYH employees cannot offer, or allow to be offered, a valuable article (such as money, goods or services), directly or indirectly, to obtain an unfair advantage in the sale of goods and services, in financial transactions or during the representation of the Company interests to official bodies. DYH Group companies cannot consent to, participate in or tolerate any commercial practice that violates this policy.

corporate governance

2. International trade and business relations

In all countries where it conducts business, DYH complies with international trade regulations on matters such as licensing, delivery documents, import documents, notifications and maintenance of records.

3. Identification of customers

People engaged in criminal activities (e.g., illegal drug trafficking, bribery, forgery) may try to launder money to conceal or legitimize the proceeds from such criminal activity. DYH fully complies with the anti-money laundering laws worldwide.

4. Protection of private and confidential information

In accordance with all applicable rules and regulations, DYH and its employees commit themselves to protecting private information about individuals and corporations they conduct business with against any improper or unauthorized use and disclosure.

5. Relations with suppliers

DYH believes that relations with its suppliers usually impact its dealings with the customers, as well as the quality of its own goods and services. Therefore, DYH is committed to carrying out relationships with suppliers in an efficient, fair and legal manner.

D) Relations with Official Bodies

DYH commits itself to comply with all applicable laws and regulations in its business dealings with official bodies and observe the highest standards of business ethics.

E) Relations with Competitors

DYH commits itself to complying with competition laws, regulations and agreements in all of its activities.

F) Environment and Health

DYH targets perfection on environmental and health issues. The management and all personnel are aware of their responsibilities in this matter and commit themselves to complying with all environmental laws.

G) Relations with Employees

DYH provides fair and equal opportunities for all of its employees to work in a safe environment and achieve personal development. With a view toward enabling the development of society and individuals, the Group complies with all applicable labor laws and regulations.

H) Protection of DYH Assets

1. Conflicts of interest

DYH requires of all of its employees with activities outside their job to comply with the laws and avoid conflicts of interest with their professional roles as DYH employees. Employees cannot abuse DYH resources or damage its image or reputation.

2. Audit and control

DYH commits itself to establishing appropriate control mechanisms in accordance with the laws, regulations and Company policies.

3. Rules regarding the Stock Exchange and the Company stock

DYH commits itself to making every effort to facilitate transparency and confidence in capital markets.

4. Intellectual property rights

Intellectual properties - trade secrets, brands, copyrights and other proprietary information - are among DYH’s most valuable assets. One of the main policies of DYH is to establish, protect, maintain, defend and prudently utilize all commercially important intellectual properties of DYH. All employees are required to take the necessary measures to protect these assets. DYH not only protects its own intellectual property rights, but also respects the intellectual property rights of others.