Statement of Continued Support

May 5th, 2022

To our stakeholders:

I am pleased to confirm that Işıklar Energy ve Yapı Holding (IEYHO) reaffirms its support of the Ten Principles of the United Nations Global Compact in the areas of Human Rights, Labour, Environment and Anti-Corruption. In our Mission Statement, we emphasize to show maximum efforts to support a sustainable environment. Our Vision is to grow our Packaging, Foundry and Brick core businesses with exports and investments in renewable energies to erase their carbon footprint. To reach sustainable high profitability with the support of our Real Estate and High Technology investments.

In this annual Communication on Progress, we describe our actions to improve continually the integration of the Global Compact and its principles into our business strategy, culture and daily operations. We also commit to share this information with our stakeholders using our primary channels of communication.

Sincerely yours,

Volkan GIRISKEN
Group CEO
Işıklar Holding AS

Işıklar Group’s Rules of Business Ethics Handbook, and values provide clear guidelines on human rights issues: Employees and shareholders of Işıklar Holding Group acts with the awareness of their responsibilities against the society, environment, customers and business partners and these responsibilities constitute the basic principles of business ethics of Işıklar Holding. Group culture does not allow Işıklar Employees to demean themselves or others; they are motivated to increase the well-being of society. Every new Işıklar Group employee has to adopt themselves with the Group Values through a variety of internal communication tools, they are obliged to sign under Işıklar Rules of Business Ethics Handbook as they step in the Group the first day. We emphasize that all our business partners including customers, shareholders and suppliers comply with these rules.
All employees and subcontractors receive an orientation program about the Group, its values and mission, they have to appreciate and respect these principles.
Harassment, Targeting, Sacrificing : We all have right to be respected and human dignity. It is not possible to accept an action which may violate this or especially sexual harassment.
We should avoid acting or speaking in a way that it would isolate the employee, targeting someone and wearing actions which may create psychological pressure. Systematic and planned actions directed at alienating the targeted employee from work, reducing his performance and causing him to resign may be given as example. (for example: criticizing the personal life of the employee, interrupting him in crowded environments, insulting him in front of other employees, ignoring his success etc.)
Işıklar Holding Group takes all measurements to prevent such actions and it expects from all employees to pay strict attention to this.
Women and Gender Equality
Women and gender equality is essential during our search and selection process and all employees are equally considerable for any new post in the organization and the main criteria is the ability to perform the job and the performance level.
Children's Rights
Işıklar Group has been committed to wellbeing of children in the society. No children workers are present in our plants and we ask the same from our suppliers and customers. We only accept official interns from Highs schools for their trainings.
However we have a foundation called Turgut Işık Foundation working on giving scholarships on education and aid for health if needed.

Since 1992, Turgut Işık Foundation has been giving scholarships to an average of 100 students every year. The income of the foundation consists of donations, earnings and interest. We distribute the revenues of our foundation as medium level financial aid as scholarships.
Meanwhile as Işıklar Group we are giving scholarships to Koç University Students through two of our subsidiaries Işıklar İnşaat Malzemeleri AŞ and Çemaş. The Project has been organized by Koç University and called Anatolian Scholarship Program and we have currently 4 scholars in the program. In Turkey, university placements and the distribution of scholarships for higher education are determined based on students’ performance on the national university exam, where only the top candidates who score within the top 1 percentile are provided financial aid. With limited financial means, university candidates from vulnerable populations are at a distinct disadvantage relative to other students in reflecting their true potential on the nationwide university entrance exam; hence they have less likelihood to be placed in the nations best schools/colleges.
On the other hand, charitable giving for students in need is a strong tradition among philanthropists. The combination of these two considerations triggered the idea of the Anatolian Scholarship Program for highly accomplished students from underprivileged backgrounds, who are not eligible for a full scholarship under the public national scholarship system but who are high achievers and exceptional individuals in all regards.
Designed to offer affordability and provide greater access to high quality education, the Program was launched in 2011 providing scholarships for 14 students with the support of 6 sponsor companies. As of 2021, the number of students benefitting from the program has reached 982 and the number of sponsor companies has exceeded 300. In addition, more than 1500 individual contributors (mostly alumni) support the Program.
Indigenous People
Our Rule of Business Ethics Handbook declares which is to comply with the laws of Republic of Turkey and all foreign countries we work with and to carry out our role in order to improve the society we live in. This is “Citizenship Consciousness”
Persons with Disabilities - Barrier-Free Development Academy
Barrier-Free Development Academy is a project created in awareness of social good and initiated by TİSK, Türk-İş (Confederation of Turkish Trade Unions) and Hak-İş (Trade Union Confederation) to empower people with disabilities (PwDs). TİSK handles the coordination and operation of the project implemented collaboratively by NGOs, Workers’ Confederations and İŞKUR and the Academy will be offering people with disabilities free access to personal development courses and vocational training modules created by experts from home. The educational content will include special content technologically formulated for the vision and hearing impaired. At the Training Design Laboratory to be set up within the premises of Türk Traktör, who is one of the collaborators of the project, all educational content will be prepared with media accessibility including sign language, detailed subtitling, and audio description. All training modules to design in line with the needs of PwDs and their places of employment. As Işıklar we are committing to make life easier either for our employees and our visitors.
Human Trafficking
Human trafficking involves the use of force, fraud, or coercion to obtain some type of labor or commercial sex act. Every year, millions of men, women, and children are trafficked worldwide – including right here in the United States. It can happen in any community and victims can be any age, race, gender, or nationality. Traffickers might use violence, manipulation, or false promises of well-paying jobs or romantic relationships to lure victims into trafficking situations.
Işıklar Groups bans all kinds of such activities and control and eliminates.
Health And Safety İssues
Işıklar has been committed to provide best possible environment in terms of Health and Safety İssues for all employees. In this regard, we are planning to implement a new Artificial Intelligence tool in our plants.

Işıklar Main Reference is of course the Universal Declaration of Human Rights or other International Standards, for example our subsidiary Işıklar Ambalaj has been member of Ecovadis and Avetta successfully for many years.

Written company policy on respecting Human Rights and preventing potential abuses is our main pillar to manage and track all these human rights issues(e.g. in code of conduct). Our Rules of Ethics Hanbooks is readily available and signed under by all employees
The Context and Basics of Our Rules of Ethics Book is as follows :
IŞIKLAR HOLDİNG GROUP is committed to the highest moral standards in all relationships both between our employees, customers and the society we live in and the companies that we buy products and services and with our shareholders. We are proud of our commitment to the truth, equality and social responsibility. Moral principles and values guide us in all the works we perform:
• Honesty: Abiding by the truth with all our employees, acting honestly and downrightly to each other, to our customers, societies, our supply resources and shareholders.
• Truth: Saying what we want to express, delivering the products we promised and defending what we believe is true.
• Respect: Behave each other in a respectful and equal manner, being conscious of the fact that the labor force of our company consists of different individuals and that each individual is unique and distinctive.
• Trust: To give confidence by establishing a clear and intimate communication through team work.
• Responsibility: In case of acts against our regulation and company principles, to notify these to the authorities clearly and without hesitation; trying to obtain explanatory and directive information in case of doubt.
• Citizenship Consciousness: To comply with the laws of Republic of Turkey and all foreign countries we work with and to carry out our role in order to improve the society we live in.
Rules Of Business Ethics Handbook
This study aims to explicitly introduce the business management principles which includes the responsibilities of our employees towards the company. “Rules of Business Ethics” includes all the managers and employees of the company and subsidiary companies, all these people shall be referred to as “employees” in the text. As employees, responsibility of each one of us is to protect the honesty and ethical business principles. We are obligated to be honest, reliable, and trustworthy in our relationships and to comply with ethical business rules at every stage our work.Objective of the business ethics; is to give us a mutual understanding about what issues are expected from us in our field of work besides the existing regulations and rules of our company. These studies stipulate the principles of business ethics which defines us as a company and helps us understand these principles and sets forth some practical and directive rules which will help you follow these principles. However, it is not possible to include each subject and detail in this study. These rules design to cover the most encountered subjects, and it is not a comprehensive book of rules. Please read these ethic rules of our company, make time to think about them and make an effort to work within these rules. We recommend you to apply to your manager or Human Resources Directorate for your questions about these rules and possible ethics violations in your company. Main principle of this study can be summarized as follows; “As a representative of the company, we need to behave honestly, fair and respectfully all the time and in every aspect.”
• Policy requiring business partners and suppliers to adhere to the Global Compact principles on Human Rights
• We have always been signing framework agreements coming from our multinational customers, and we are planning to prepare one and get it signed by our customers and suppliers.
• Assessment of Human Rights related risks and impact in industry sector and country(ies) of operation (see Risk Assessment Report at The Human Rights and Business Project)

1- Preparations and signing of a framework agreement on Human Rights for our suppliers and customers and to make them sign under at least for 5.
2- Creating a more formal way to communicate misbehaviors against Human Rights to auditing department (call center or written digital suggestion box, or periodic calls to identify these issues )
3- Internal Human Rights Audits & Preparation of Human Rights Risk Assessment Reports.
4- Awareness raising or training of employees on Human Rights
5- Increase women Board Members or Management Team Members by 1
6- Keep the number of Scholarships same for the following 2 years.

• Periodic review of results of the Internal Audit team by senior management, and take the necessary actions such as Investigations, legal cases, rulings, fines and other relevant events related to Human Rights
• Track Safety results before and after TISK AI Safety tool. Implementation of the new AI Safety tool in one of our plants to start with, organized by TISK. Currently we have an agreed special service company responsible from all the safety issues and management is hands on for all safety issues.

Işıklar ties himself with International Labor Organization’s (ILO) standards and regulations. All blue collar workers have access to join labor union which has been organized in that specific plant and they can be part of the collective bargaining represented by the people they have selected internally. These bargainings take place every two years and finalized most of the time with mutual understanding of parties. As part of the agreement workers not only receives a rate much higher than the inflation rate but also many different fringe benefits including, social aids, shoes jackets etc…There is no children working in our plants and any kind of discrimination is totally forbidden.
• All Businesses in Işıklar Group have right for freedom of association & effective recognition of their right to collective bargaining. Three of our companies have agreements with labor unions. Işıklar Ambalaj deals with Seluloz-Is Paper Industry Labor Union, Cemas deals with Birleşik Metal and Niğbaş with Çimse-İş.
• No employees at Işıklar are forced to do a specific job, in cases where their colleagues are absent or are not sufficient in terms of numbers to perform the specific job, they are asked to give support and work temporarily at that specific job.
• There is no child labor in Işıklar Premises and therefore abolition of it does not make sense.
• Işıklar does not discriminate in any kind of jobs or employees, the main criteria for Işıklar is the capability of the person to do the job and her/his performance.
• Işıklar’s Rule of Business Ethics clearly defines to uphold the freedom of association and collective bargaining and the elimination of forced labor, child labor and employment discrimination
• Use of Status Power in the Workplace Abuse of status power may originate from misuse of personal power (title, physical, personal, age) of the employee or the misuse of collective power (power originating from majority). Responding in an appropriate and constructive attitude towards the errors made by employees in a reasonable and logical level, evaluations performed for the improvement of employees in the performance system etc., are examples of normal use of status power.
• Employees have access to their salaries regularly every 5th day of the month, this the company’s first priority to pay the salaries on time.
• We expect all our business partners and suppliers to adhere to the Global Compact Labor principles, we have a framework agreement with the suppliers of our subsidiaries.
• Migrants can of course work in our plants as long as they are officially present in the country and have all their necessary documents.
• Specific goals in the area of Labor Rights for the upcoming year is to identify any issue from the employer’s point of view if there is a point which bothers them from the Labor Right Point of View.
• Description of how the company monitors and evaluates performance.
• We will implement an employee satisfaction survey, in combination with an hot line to Audit Manager

Our Actions
• In order to be aware of any Human Right issues in our subsidiaries, we have organized an Internal Audit Department, which makes regular audits in general and on specific issues as workers reach the audit team with such a claim by either phone or e-mail.

• Labour rights are well defined in our signed contracts with Labor Unions and the workers representatives are well trained about the content and they are responsible to train their colleagues and bring the issues to the related commissions if necessary. In our subsidiaries where there is no labor union, company managers are responsible to manage these issues.

• We ensure Health and Safety for all employees via agreed special service companies responsible from all the safety issues and management is hands on for all safety issues in all of our subsidiaries. We are planning to start using a new artificial safety software sponsored by TISK in coming years.

• In our subsidiaries, HR departments are responsible to prepare salary lists under the control of their General Manager, and they submit these lists to Central HR who checks and compares with other subsidiaries for any inconsistencies. Afterwards CEO for approves, and after all these steps, a list of all salaries on company and function basis goes to the desk of the Chairman of the Board for a final approval and clearance for implementation. There is no discrimination on salaries for any reason; the only criteria is the job description, responsibilities and performance.

• Company Managers consult with employees and industry associations about the labor policies and actions.

• Plant Managers and Labor Union Representatives are responsible for the protection of labour rights within the organization. Their main reference is our Rules of Ethics Handbook and ILO and rules and regulations.

• Global Compact, Ecovadis (Işıklar Ambalaj), and Avetta (Işıklar Ambalaj) are international entities we are involved in.

• Demographics is diverse in our Group from all over Turkey and same for our plants abroad. We don’t categorize people by their age, gender or sex, for us the main criteria is performance and reliability.
• If there is any unlikely violation of the Global Compact Principles we first warn and train again, penalize at the second case and stop working at the third one.
• Our Internal Audit team make the necessary investigations in all of our subsidiaries regarding our Business Ethic Rules and will do the same for Global Compact as well.
• Senior Management reviews the Internal Audit reports as they are published. Ecovadis, Avetta and Multinational Customers make external audits from time to time.

We commit ourselves to better the environment in our capacity as a member of the industrial community. We are trying to install this spirit and understanding in our employees. Our targets are:

• Contribute to a greener World.
• Pursue our operations conforming to all environmental rules and regulations.
• Minimize waste and effluents.
• Continue operations complying to nature continuously audit our environmental systems and create ways for improvement.
• Train employees and make available the necessary means to elevate their awareness.
• We expect our suppliers to conform to our environmental policy.
• Cooperate with local institutions to augment Environmental awareness.
• Increase utilization of renewable energy.
• Reduce carbon emissions through investments.
• Use alternative eco-friendly means of transportation.
• Reduce greenhouse gas emissions and minimize harm to nature.
• Reduce our carbon footprint.
 We are working on a Policy requiring business partners and suppliers to adhere to the Global Compact environmental principles.

 We are targeting to replace most of our energy consumption by renewable energy and preferably with Solar Energy. We have already realized the first investment at Çemaş with 6 MW capacity replacing already 23% of electrical consumption of Çemaş. We are also planning similar solar energy investments at Işıklar Ambalaj (Konya) and Işıklar İnşaat Malzemeleri AŞ (Bartın) , Niğde Construction Materials Plant, and a wind power system in Çorlu Metemteks Textile Plant.

 Işıklar Ambalaj one of our leading subsidiaries already has ISO 14001 Environment Quality Certificate and this reflects the Groups sincerity on environment issues. Therefore people receive all necessary awareness and system trainings regularly.

 All waste materials in our subsidiaries and head offices are collected and discarded by licensed companies according to environmental rules and regulations. We have waste treatment facilities especially in Konya packaging plant and wastes are either discharged after the cleaning process or send to cement factories for burning via licensed companies. Similar processes are available at all other plants.

 One of the industries we are in is the totally eco-friendly paper packaging industry. We are spending huge effort to replace plastics with paper. As long as paper industry implements a planned tree implantation program and manage the issue in an industrial way, this process increases the tree population rather than decreasing it.

 We are planning to start a program with our suppliers to promote them the idea of environment protection and asking them to report and to minimize their carbon footprint.

 We are planning to work on an Environmental management system to identify, monitor and control the Group company's environmental performance and first of all we will measure and identify each subsidiaries carbon footprint and and ask action plans minimize it.

 We understand it’s essential to allocate to some people responsibilities for environmental protection within the company. We have responsible persons in each company but this will be better organized in Group basis as well and be well coordinated.

In case there is an incident in any of our premises environment team members take the necessary to stop and minimize the first negative effects of the incident as quickly as possible. Then after investigation of the Internal team as well, we plan the actions which will stop any repeating incident. This will be reported to the Board and tracked periodically by the Group Environment Responsible people. External audits may be invited in case of necessity.

Işıklar’s approach on Anti-Corruption issues have been very clearly emphasized in our Business Ethics Handbook; Relations with Government Agencies, Private Institutions/Companies, Non-Governmental Organizations and Media It is essential that the relations of the company with government agencies, private institutions/companies, non-governmental organizations and media are correct and consistent. Relations of the company with public administration, political organizations, unions and other organizations have to be based on the principles of truth, honesty, equality and independency. It is strictly forbidden to personally make a donation/give a gift to a government agency, nongovernmental organization on behalf of Işıklar Holding Group. Employees need to avoid conditions which may cause a speculation about the relation of Işıklar Holding Group with the media, conditions which may cause negative evaluation and implementations and attitudes which may damage the reliability, reputation and consistency of the company or sector, or which may generate unfair competition. Such requests and cases need to be notified to Human Resources Directorate or Public Relations Department. We are fully supporting UN Convention against corruption.
We are planning to develop a Policy requiring business partners and suppliers to adhere to the Global Compact anti-corruption principles and set specific goals in the area of anti-corruption for the upcoming year

 We have developed an Internal Audit System where all employees’ even people from 3rd parties can reach and inform us about any issue going wrong about the company and the people.

 People are periodically trained about ethic rules and sign under but the frequency and the content quality will be reviewed.

 Plant Manager or whoever is the highest grade is directly responsible for the anti-corruption issues in that location.

 Gift Accepting and Giving Policy : It is essential that Işıklar Holding Group employees do not accept gifts or interest that may affect their objectivity, decisions and attitude, and not to make directly or indirectly an attempt on giving those kind of gifts or interests to 3rd parties and
Companies. Employees do not request gifts from other people and/or institutions in which the company has a business relationship and they do not imply on that subject. They cannot accept and gift, money, check, property, free holiday, special discounts etc. which may put the company under obligation. Gifts and promotion materials to be given to customers, dealer and 3rd parties who have a business relationship with the company, are confirmed by Top Management of the Company

Relations with Government Agencies, Private Institutions/Companies, Non-Governmental Organizations and Media It is essential that the relations of the company with government agencies, private institutions/companies, non-governmental organizations and media are correct and consistent. Relations of the company with public administration, political organizations, unions and other organizations have to be based on the principles of truth, honesty, equality and independency. It is strictly forbidden to personally make a donation/give a gift to a government agency, nongovernmental organization on behalf of Işıklar Holding Group. Employees need to avoid conditions which may cause a speculation about the relation of Işıklar Holding Group with the media, conditions which may cause negative evaluation and implementations and attitudes which may damage the reliability, reputation and consistency of the company or sector, or which may generate unfair competition. Such requests and cases need to be notified to Human Resources Directorate or Public Relations Department.
In case there is an incident in any of our premises environment team members take the necessary to stop and minimize the first negative effects of the incident as quickly as possible. Then after investigation of the Internal team as well, we plan the actions which will stop any repeating incident. This will be reported to the Board and tracked periodically by the Group Head of HR people. External audits may be invited in case of necessity.