İHLAS GAZETECİLİK A.Ş.

INFORMATION POLICY

Purpose

The main purpose of our Company’s information policy is to inform the public in a timely, complete, accurate, and sufficient manner about developments that may affect the value of all capital market instruments offered by our Company, and to ensure that no discrimination is made among Capital Market Participants (shareholders, investors, capital market experts, brokerage firms, etc.) in the exercise of the right to access and inspect information.

The information disclosed by the Company is made available in an understandable, interpretable, easily accessible, and equitable manner at a low cost to assist individuals and organizations in making informed decisions.

 

Regarding public disclosure, the regulations of the Capital Markets Board (SPK) and Borsa Istanbul A.Ş. (BİST A.Ş.) are complied with, and utmost care is taken to implement the principles contained in the SPK Corporate Governance Principles.

In addition to the requirements stipulated in legal regulations, the effective use of the website, email communications, press releases, media outlets, and compliance with all rules published or to be published by the Capital Markets Board (SPK) are essential when providing information.

Responsibility

The Board of Directors is responsible for monitoring, reviewing, and improving the Information Policy. The Corporate Governance Committee provides information and makes recommendations to the Board of Directors, the Audit Committee, and the Deputy General Manager responsible for Financial Affairs on matters related to the “Information Policy”. The Deputy General Manager responsible for Financial Affairs is responsible for the implementation of the Information Policy.

Public Disclosure Methods and Tools

The main public disclosure methods used by our Company are:

– Due to the obligation arising from the provisions of Capital Market Legislation and the Turkish Commercial Code (TTK); making the necessary special situation announcement to the Public Disclosure Platform in accordance with the Capital Markets Board’s (II-15.1) Special Situations Communiqué, using the forms in the Communiqué, and publishing the announcement on our corporate website at:

https://www.ihlasgazetecilik.com.tr.

– Publication of independent audit reports, declarations, and activity reports of financial statements and footnotes on the Public Disclosure Platform and our website.

– Publication of documents or information required by legislation during capital increases on the corporate website and, if required by legislation, in the Turkish Trade Registry Gazette and daily newspapers or other media.

– Publication of announcements and notices such as general assembly calls and dividend payments on our corporate website, as well as in the Turkish Trade Registry Gazette and daily newspapers or other media if required by legislation.

These are the main public disclosure methods used by our Company.

The above-mentioned disclosures, which our Company provides to capital market participants and which arise from legislation, are disseminated by:

– Being featured in written and visual media, on data distribution organizations such as Reuters, Foreks, etc.,

– Being explained in face-to-face or teleconference information meetings and discussions with capital market participants.

Public Disclosure of Financial Statements

Our company’s financial statements and footnotes are prepared on a non-consolidated basis in accordance with the Turkish Commercial Code, Capital Markets Law, Tax Laws, and relevant legislation, and are independently audited in accordance with the independent audit standards regulations published by the Capital Markets Board. They are submitted to the Board of Directors for approval with the favorable opinion of the Audit Committee. After the declaration of accuracy is signed by the responsible Board Members, they are publicly disclosed. Following the approval of the Board of Directors, the financial statements and footnotes, along with the independent audit report and accompanying documents, are submitted to the Public Disclosure Platform for publication in accordance with the regulations of the Capital Markets Board (SPK) and Borsa Istanbul A.Ş. (BİST A.Ş.). The financial reports are available retrospectively on the company’s website.

Public Disclosure of the Activity Report

The Activity Report is prepared in accordance with the Turkish Commercial Code and the Capital Markets Law Communiqués and Principles, submitted to the Board of Directors for approval, and publicly disclosed on our corporate website.

Capital market participants who wish to do so can obtain a printed version of the Activity Report in Turkish and/or English from our Company’s Investor Relations Management. Activity Reports are also available retrospectively on the company’s website.

Public Disclosure of Special Circumstances

The Company’s special circumstance disclosures are prepared under the supervision of the Deputy General Manager responsible for Financial Affairs and signed by the responsible Board Members before being submitted to the Public Disclosure Platform.

Maintaining Confidentiality Until Public Disclosure of Special Circumstances

Employees of İhlas Gazetecilik A.Ş. who possess inside information, and other parties in contact with them, are informed that they are obligated to maintain the confidentiality of this information during the process of the special circumstance occurring and until its disclosure to Borsa İstanbul A.Ş. (BİST A.Ş.). As a principle, İhlas Gazetecilik A.Ş. and its employees will not share any information of a special circumstance nature that has not yet been publicly disclosed with third parties under any circumstances. If it is determined that this information has been unintentionally disclosed to third parties, and if it is concluded that the confidentiality of the information cannot be ensured under Capital Market regulations, a special situation announcement will be made immediately.

Our Company primarily discloses inside information to the public on the date the disclosure obligation arises.

Postponement of Public Disclosure of Inside Information

In order to protect the legitimate interests, legal rights and benefits of our Company, the public disclosure of inside information may be postponed when necessary, provided that the confidentiality of the information is ensured, in accordance with Article 6 of the Special Situations Announcement. For the postponement of the disclosure, a board of directors decision will be taken regarding the impact of the postponement on the protection of our Company’s legal rights, the fact that it does not create a risk of misleading investors, and what measures have been taken to protect the confidentiality of this information during the postponement period.

As soon as the reasons for delaying the public disclosure of inside information cease to exist, our Company will immediately send a statement regarding the said inside information to the Public Disclosure Platform.

To ensure compliance with the rules regarding the use of inside information, a “List of Those with Access to Inside Information” has been prepared, and statements have been obtained from employees on the list confirming their awareness of their obligations to protect this information and not to misuse it. Care will also be taken to obtain statements from newly added employees to the list.

Until special circumstances are publicly disclosed, in order to maintain the confidentiality of this information, no information other than that already publicly disclosed will be revealed in individual or group meetings/discussions with capital market participants/third parties.

Subsequent changes and developments regarding the Company’s public disclosures will be announced to the public through special circumstances announcements.

Persons Authorized to Make Public Statements

Apart from the notifications mentioned above, written and oral information requests from capital market participants, excluding confidential and trade secret information, are answered by the Deputy General Manager in charge of Financial Affairs or the Investor Relations Management, depending on the content of the request.

Press releases to written and visual media and data distribution channels such as Reuters, Foreks, etc., can only be made by the Chairman of the Board of Directors, the General Manager, or the Deputy General Manager in charge of Financial Affairs. Apart from this, unless specifically assigned, Company employees cannot answer questions from capital market participants.

Incoming information requests are directed to the Deputy General Manager in charge of Financial Affairs or the Investor Relations Management.

Criteria Used in Determining Persons with Administrative Responsibility

The criteria used to determine persons with administrative responsibility in the Company are those stipulated in the regulations issued by the Capital Markets Board. These criteria are:

Persons with administrative responsibility:

1) Members of the Issuer’s Board of Directors,

2) Persons who, although not members of the Board of Directors, have regular direct or indirect access to the issuer’s inside information and are authorized to make administrative decisions that affect the issuer’s future development and commercial objectives,

Persons closely related to the person with administrative responsibility:

1) The spouse, children, and persons residing in the same household as the person with administrative responsibility at the time the transaction is carried out,

2) Legal entities, institutions, or partnerships whose administrative responsibilities are undertaken by the persons with administrative responsibility or the persons specified in subparagraph (1), or which are directly or indirectly controlled by or established for the benefit of these persons, or whose economic interests are essentially the same as the economic interests of these persons,

3) The subsidiaries of the issuer whose capital market instrument is traded on an exchange, whose total assets in the latest annual financial statement prepared in accordance with the Board’s regulations constitute 10% or more of the total assets; the persons specified in subparagraph (f) and its first and second subparagraphs,

Communication with Capital Market Participants

Our Company does not provide guidance regarding expectations for interim and annual operating results. Instead, it prefers to communicate to capital market participants critical issues affecting operating results, its strategic approaches, and important elements that provide a better understanding of the sector and the environment in which it operates. Unless otherwise stated in the disclosure policy, only persons authorized to make public statements on behalf of our Company may communicate with capital market participants. In non-public interviews with capital market participants, no information that has not yet been publicly disclosed and is important/confidential will be revealed.

Face-to-Face Meetings or Telephone Calls

In-person or group telephone interviews with capital market participants are an important part of investor relations development programs. In these types of environments, our Company will not provide new information; it will not update previously publicly disclosed information and will not disclose important and confidential information that has not been previously publicly disclosed.

Apart from this, investor information meetings will be held when it is necessary to comprehensively share the Company’s activities with investors and/or when the Board of Directors deems it necessary. In meetings between the Board of Directors or executives and the press, appointment requests from the press will be evaluated by the Investor Relations Department and arranged with the approval of the Corporate Governance Committee. The use of the internet will be encouraged for answering questions from potential investors, shareholders, stakeholders, the press, and financial institutions representing investors, primarily through written submissions; however, all questions will be answered by the Investor Relations Department within the framework of the information policy.

Statements, presentations, and reports made at investor information meetings or press conferences will be published on the company’s website.

Informing Small Investors

To ensure interactive information sharing and prevent speculative information, no new information will be provided in presentations and reports at introductory meetings, information meetings, or press conferences held with a specific group of investors; previously publicly disclosed information will not be updated, and no private information that has not been previously publicly disclosed will be revealed.

All such disclosures will be available on the corporate website. In addition to the methods stipulated in legal regulations, the corporate website, email communications, press releases, effective use of media outlets, and compliance with all rules published or to be published by the Capital Markets Board (SPK) are essential when providing information.

News and Rumors in the Press or on Websites

News and rumors about the company in the press or on websites are monitored on a current basis by Investor Relations Management.

If news or rumors about the company, published in the press or other communication channels, originate from sources not authorized to represent the company and contain information different from that previously disclosed to the public through special situation announcements, prospectuses, circulars, announcements approved by the Board, financial reports, and other public disclosure documents, and which are of significant importance and may affect the investment decisions of investors or the value of capital market instruments, the company shall issue a statement regarding the accuracy or sufficiency of such news or rumors in accordance with Article 9 of the Special Situations Communiqué titled “Verification of News and Rumors”.

If the news or rumors relate to information whose public disclosure has been postponed, it shall be deemed that the reasons for the postponement have ceased to exist, and the company shall make a public disclosure.

However, if the information contained in the news or rumors consists of information previously disclosed to the public through special situation announcements, prospectuses, circulars, announcements approved by the Board, and financial reports, and does not contain any additional information, no special situation announcement shall be issued.

Public Disclosure of Forward-Looking Assessments

The company may disclose forward-looking assessments from time to time in accordance with its disclosure policy.

Compliance with the provisions determined by legislation is essential in the public disclosure of forward-looking assessments.

Forward-looking assessments may be disclosed to the public only if approved by a decision of the board of directors or, if authorized by the board of directors, with the written approval of the authorized person.

This disclosure may be made in the form of a special situation announcement, or through activity reports published within the framework of the Board’s regulations on financial statements, or through presentations to inform investors, provided that they are disclosed on the Public Disclosure Platform (KAP). Forward-looking assessments are disclosed to the public by management a maximum of four times a year.

When a significant change occurs in the forward-looking assessments disclosed to the public, a disclosure will be made in accordance with the provisions of the legislation, without being subject to the numerical limitation in this paragraph.

Website (https://www.ihlasgazetecilik.com.tr)

In informing the public, the corporate website (https://www.ihlasgazetecilik.com.tr) is actively used as recommended by the Capital Markets Board’s Corporate Governance Principles. The statements on the company’s corporate website do not replace the notifications and special situation disclosures required under the Capital Markets Legislation. All public disclosures are accessible through the website.

On the company’s corporate website; trade registry information, information on partnership and management structure, information on preferred shares, the latest version of the articles of association along with the date and number of the Turkish Trade Registry Gazette in which amendments were published, special situation disclosures, annual and interim activity reports, periodic financial statements and reports, prospectuses and circulars, agendas of general assembly meetings and attendance lists, meeting minutes, proxy voting form, dividend distribution policy, information policy, corporate governance principles compliance report, ethical rules established by the company, frequently asked questions, subsidiaries, contact information, and Investor Relations contact information for investors seeking information are all included.

The website is structured and segmented in accordance with the Corporate Governance Principles and similar legal provisions. All necessary security measures are taken for the website. The website is available in Turkish and English, in the content and format prescribed by the Capital Markets Board’s Corporate Governance Principles. In particular, announcements regarding upcoming general assembly meetings, agenda items, information documents related to the agenda items, other information, documents and reports related to the agenda items, and information about methods of participation in the general assembly are prominently displayed on the website. Work on continuously improving the website continues.