Sustainability Committee

İHLAS GAZETECİLİK A.Ş.

SUSTAINABILITY GOVERNANCE POLICIES AND PROCEDURES

(Compliant with TSRS)

1. INTRODUCTION AND APPROACH

İhlas Gazetecilik A.Ş. regards sustainability as an inseparable part of its business model, integrating environmental, social, and governance (ESG) risks and opportunities at a strategic level. In line with its vision of creating long-term value through newspaper sales, commercial printing, packaging production, and news agency operations via subsidiaries, the company has established a corporate sustainability governance structure.

This policy has been prepared within the framework of the Türkiye Sustainability Reporting Standards (TSRS) to define, at the corporate level, the oversight, control, and reporting processes related to the management of sustainability and climate-related risks.

2. THE OVERSIGHT ROLE OF THE BOARD OF DIRECTORS AND SENIOR MANAGEMENT

The Board of Directors is responsible for the ultimate oversight of İhlas Gazetecilik A.Ş.’s sustainability strategies. Risks and opportunities related to sustainability are regularly evaluated within the strategic governance agenda; large-scale investment decisions, risk management, and performance objectives are shaped accordingly.

The Deputy Chairman of the Board of Directors and the General Manager also serve as the Chair of the Sustainability Committee, ensuring holistic coordination of the company’s sustainability practices.

Within the corporate governance framework, roles and authorities related to sustainability are explicitly integrated into the job descriptions of senior executives.

3. THE SUSTAINABILITY COMMITTEE AND INFRASTRUCTURE

3.1 Purpose, Structure, and Responsibilities of the Committee

Purpose of the Committee:
The Sustainability Committee operates to monitor İhlas Gazetecilik A.Ş.’s risks and opportunities in the fields of environmental, social, and governance (ESG) at a strategic level, fulfill obligations under the TSRS, and ensure sustainability is embedded throughout the organization.

Structure of the Committee:

Member	Position	Sustainability Role
Deputy Chairman of the Board & GM	Senior Management / Executive	Committee Chair
Board Member Responsible for Financial Affairs	CFO	Member
Deputy GM Responsible for Printing and Packaging	Operational Governance	Member
Human Resources Manager	Employee Well-being, Equality	Member
Publishing Coordinator	Media & Content Oversight	Member

The Committee meets regularly every six months to discuss developments regarding sustainability and may hold interim meetings when necessary. At each meeting, members are informed about sustainability practices, risks, and opportunities, and the Committee reports to the Board of Directors at least twice a year. Secretarial activities of the Committee are carried out by the Human Resources Manager.

Responsibilities of the Committee:

3.1.1 Strategic Governance and Policy Development

Coordinates the preparation, updating, and approval of corporate sustainability policies in the ESG field.
Oversees the establishment, documentation, and implementation of governance processes defined within the TSRS.
Ensures sustainability is integrated into company strategy and aligned with core business objectives.

3.1.2 Sustainability Goals and Performance Monitoring

Coordinates the setting of short-, medium-, and long-term sustainability goals.
Ensures the identification and monitoring of related KPIs (e.g., emission intensity, waste ratio, female employee ratio).
Verifies whether performance targets are integrated into employee remuneration and bonus systems.

3.1.3 Information and Reporting

Monitors sustainability developments every six months and organizes Committee meetings.
Reports to the Board of Directors at least twice a year on sustainability strategy, progress, and challenges.
Oversees the coordination of sustainability reports prepared within the TSRS framework and monitors data flows from working groups.

3.1.4 Coordination and Oversight of Working Groups

Coordinates the activities of thematic working groups: Environment & Climate, Product & Innovation, Supply Chain & Business Ethics, People & Social Sustainability.
Approves annual targets and activity plans of each working group; monitors their implementation performance.
Ensures the establishment of sub-working groups when necessary.

3.1.5 Risk and Opportunity Management

Assesses ESG risks and opportunities (e.g., climate change, supply chain fragility, social inequalities) using the principle of financial/impact materiality.
Ensures integration of relevant risks into the corporate risk management system.
Requires impact assessments prior to major sustainability-related decisions (e.g., new investment, raw material procurement, energy infrastructure transformation).

3.1.6 Information, Training, and Competence Development

Plans regular training programs to ensure Committee members and all managers are sufficiently informed about sustainability and climate risks.
Supports trainings, external seminars, certification programs, and mentoring initiatives aimed at developing sustainability competencies.
Provides regular updates to all management on best practices and regulatory developments in sustainability.

3.1.7 Internal Control and Compliance

Ensures integration of sustainability processes with the internal audit unit.
Monitors the accuracy and integrity of control points related to TSRS-compliant reporting (e.g., data sources, calculation methodologies, approval chains).
Coordinates preparation processes for external audit and limited assurance engagements when necessary.

3.1.8 External Stakeholder Engagement and Transparency

Ensures the execution of processes such as feedback collection, impact assessment, and materiality analysis regarding stakeholder dialogue.
Oversees the publication of sustainability reports in a transparent, comparable, and auditable manner.
Coordinates notifications on sustainability performance to relevant institutions (e.g., KGK, SPK, Borsa İstanbul, CDP, GRI)

4. THEMATIC WORKING GROUPS AND PROCEDURES

To ensure the dissemination of sustainability practices across the organization, four thematic working groups have been established. These groups perform the following duties:

4.1 Environment and Climate Working Group

Duties:
The Environment and Climate Working Group is responsible for developing, implementing, and monitoring strategies and practices aimed at reducing İhlas Gazetecilik A.Ş.’s environmental impacts. Its key duties are as follows:

Greenhouse Gas Emissions Management:
Monitoring, reporting, and developing reduction projects for Scope 1, Scope 2, and Scope 3 greenhouse gas emissions. Ensuring that emission data is collected in accordance with relevant TSRS and GHG Protocol standards and disclosed in annual reports.
Energy Efficiency and Consumption Analysis:
Monitoring and analyzing energy consumption in printing facilities and packaging production areas, identifying opportunities for improvement, and developing recommendations to increase the use of renewable energy sources.
Waste Management:
Establishing procedures for the management of paper, plastic, metal, and hazardous waste; supervising source separation practices; implementing Zero Waste compliance processes; and ensuring certification in line with Ministry regulations.
Climate Risk and Opportunity Analysis:
Evaluating physical risks (e.g., water stress, extreme heat) and transition risks (e.g., carbon tax, regulatory risks). Identifying adaptation and mitigation measures to enhance the company’s climate resilience.
Performance Monitoring:
Determining and monitoring environmental performance metrics such as energy intensity, emission intensity, and waste recycling rate.
TSRS Compliance Process:
Compiling environmental and climate disclosures required under TSRS, contributing to the preparation of the relevant section of the annual sustainability report.

Chair: Commercial Printing Executive

Members: İhlas Packaging Deputy General Manager, Operations Manager

Secretariat: Operations Manager

Meeting / Reporting Frequency:
The working group convenes regularly every six months and reports its activities and outcomes to the Sustainability Committee.

Monitoring Metrics:

Metrics	Unit of Measure	Formula
Metric 1: Scope 1, Scope 2, and Scope 3 Emissions	(tCO₂e)
Metric 2: Carbon Intensity Ratio	(%)	(tCO₂e / Revenue)
Metric 3: Total Energy Consumed Gigajoule	(GJ)
Metric 4: Paper Recycling Ratio	(%)	[Recycled Paper (tons) / Total Paper Used (tons)]

4.2 Product and Innovation Working Group

Duties:
The Product and Innovation Working Group coordinates projects aimed at reducing the environmental and social impacts of İhlas Gazetecilik A.Ş.’s printed and packaging products, strengthening sustainability through innovation, and enhancing digitalization capacity. Its responsibilities are as follows:

Eco-Friendly Product Development:
Increasing the use of recycled and sustainably sourced raw materials in products such as offset-printed cardboard boxes, newspapers, and magazines; integrating compliance with environmental certifications (e.g., FSC, TSE HYB) into new product development processes.
Life Cycle Perspective:
Assessing the environmental impacts of products throughout their life cycle (raw material sourcing, production, distribution, use, and disposal) and identifying mitigation measures.
Digital Publishing and Transformation:
Transitioning Türkiye Newspaper and affiliated digital channels to platforms with a lower carbon footprint, developing user-friendly digital solutions, improving digital subscription infrastructure, and conducting environmental impact analyses of digital media tools.
Innovation Strategy Development:
Tracking and evaluating innovative, energy- and resource-efficient technologies in printing and packaging solutions.
Marketing and Product Positioning:
Differentiating sustainable products in the market, creating eco-labeling strategies, and developing customer awareness initiatives.
TSRS Compliance Support:
Contributing to the preparation of sustainability disclosures related to product innovation and digitalization within the TSRS framework.

Chair: İhlas Packaging Deputy General Manager

Members: Marketing Manager, Editorial Manager

Secretariat: Editorial Manager

Meeting / Reporting Frequency:
The working group convenes every six months and reports its activities to the Sustainability Committee.

Monitoring Metrics:

Metrics	Unit of Measure	Formula
Metric 1: Number of eco-friendly products	(Units)

4.3 Supply Chain and Business Ethics Working Group

Duties:
The Supply Chain and Business Ethics Working Group coordinates activities aimed at ensuring adherence to sustainability principles across İhlas Gazetecilik A.Ş.’s entire supply chain, institutionalizing ethical business practices, and monitoring human rights risks. Its responsibilities include:

Supply Chain Sustainability:
Assessing suppliers’ ESG performance, establishing and implementing sustainable supply principles, developing improvement strategies for high carbon footprint inputs, and promoting environmentally responsible suppliers.
Ethical Principles and Compliance Policies:
Developing, implementing, and monitoring business ethics rules, including anti-bribery, conflict of interest, transparency, integrity, and fair trade. Updating internal regulations accordingly and communicating them to employees.
ESG Criteria in Supplier Selection:
Establishing control mechanisms to ensure systematic evaluation of environmental performance, occupational safety practices, social responsibility, and respect for human rights in supplier selection processes.
Human Rights Assessments:
Evaluating risks such as child labor, forced labor, and discrimination among suppliers and subcontractors; developing policies aligned with international human rights frameworks.
Monitoring and Auditing:
Conducting periodic audits of critical suppliers against ESG criteria, identifying deficiencies, and developing action plans.
Reporting Support:
Providing necessary data and documents related to supply chain and ethics for TSRS sustainability disclosures to the Sustainability Committee.

Chair: İhlas Packaging Deputy General Manager

Members: Procurement Manager, Accounting Manager

Secretariat: Accounting Manager

Meeting / Reporting Frequency:
The working group convenes every six months and reports its activities to the Sustainability Committee.

Monitoring Metrics:

Metrics	Unit of Measure	Formula
Metric 1: Total purchased wood fiber-based raw material	(tons)
Metric 2: Percentage of certified wood fiber-based raw material	(%)	[Certified source wood fiber (tons) / Total purchased wood fiber (tons)]
Metric 3: Number of identified ethics violations (units)	(units)

4.4 People and Social Sustainability Working Group

Duties:
The People and Social Sustainability Working Group is responsible for defining, implementing, and monitoring İhlas Gazetecilik A.Ş.’s employee-focused sustainability strategies. The group aims to enhance employee satisfaction, improve occupational health and safety (OHS) culture, and integrate equality and inclusiveness into the corporate structure. Its main duties include:

Employee Satisfaction and Engagement:
Designing, conducting, and analyzing internal employee satisfaction surveys. Developing suggestion systems, internal communication channels, and feedback mechanisms to strengthen participatory management culture.
Occupational Health and Safety (OHS):
Ensuring full compliance with OHS legislation across all production and office areas, conducting risk analyses, carrying out periodic inspections, and organizing OHS training programs for employees.
Equality and Inclusiveness Policies:
Developing policies and practices on gender equality, equal opportunities, accessibility for persons with disabilities, and combating discrimination. Setting and monitoring targets to increase the proportion of female employees.
Social Responsibility Practices:
Developing social projects to strengthen community engagement, promoting volunteer programs, and measuring social impact.
Employee Development and Training:
Planning and expanding internal training programs in areas such as sustainability, climate awareness, ethical values, and digital competencies.
TSRS Reporting and Data Preparation:
Preparing and providing relevant data and documents for TSRS sustainability disclosures related to people and social dimensions to the Sustainability Committee.

Chair: Advertising Group Head

Members: OHS Specialist, HR Specialist

Secretariat: HR Specialist

Meeting / Reporting Frequency:
The working group convenes every six months and reports its activities to the Sustainability Committee.

Monitoring Metrics:

Metrics	Unit of Measure	Formula
Metric 1: Female employee ratio	(%)	[Number of female employees / Total number of employees]
Metric 2: Employee turnover rate	(%)	[Number of employees who left during the period / ((Employees at beginning + Employees at end) / 2)] × 100
Metric 3: Number of workplace accidents	(units)
Metric 4: Employee satisfaction score	Between 1–5	Based on internal surveys
Metric 5: Percentage of employees receiving OHS training	(%)	[Employees trained in OHS / Total employees]
Metric 6: Number of annual social responsibility projects	(units)
Metric 7: Number of training sessions held	(units)

5. MANAGEMENT’S ROLE AND CONTROL PROCEDURES

5.1 Organization of Management

All working groups operate under the Sustainability Committee. Annual goals of the working groups are determined, measured, and monitored by the Committee. Risks and opportunities are reviewed at least once a year.

5.2 Controls and Monitoring

KPIs are determined to monitor risks and opportunities (e.g., energy consumption, emission intensity, employee turnover rate).
Separate environmental and social targets are established for each business line (newspaper, printing, packaging).
Performance metrics are integrated into the employee evaluation system.
Indicators within the scope of TSRS are audited by the internal audit unit prior to the reporting period.

6. REPORTING PROCESS AND INTEGRATION

The Sustainability Committee is responsible for preparing a TSRS-compliant report each year.
Disclosures within the scope of TSRS are prepared in accordance with the principle of “financial materiality.”
In compliance with TSRS requirements, risks and opportunities are monitored in an integrated manner within governance processes.
For subsidiaries (İhlas News Agency), the equity method approach is applied, and the proportional sustainability data is reported.

7. POLICY UPDATE AND IMPLEMENTATION

This policy is reviewed once a year and updated when necessary.
All employees and managers are accountable under this policy.
The policy is taken as the basis in internal audit and independent assurance processes.