Codes of Conduct

Code of Ethics and Compliance Procedure

1.Purpose and Scope

The purpose of this procedure is to identify potential risks and likelihoods of internal workplace violence, harassment, and psychological harassment (mobbing) within the organization, and to define the activities and solutions implemented by the Company in order to minimize such risks.

2.Responsible Parties

Senior management of MIA Teknoloji and all employees.

3. Implementation

3.1 Psychological Harassment (Mobbing) in the Workplace

3.1.1 Definition

Psychological harassment (mobbing) refers to malicious, intentional, and negative attitudes and behaviors carried out by one or more individuals against another individual or group in the workplace, which continue systematically over a certain period of time, aim to intimidate, isolate, or force the individual out of employment, and cause harm to the victim’s personality, professional status, social relationships, or health.

3.1.2 Elements

Not every negative behavior encountered in the workplace should be perceived as psychological harassment. In order for workplace behaviors to be considered mobbing, certain elements must be present.

Psychological harassment in the workplace must include the following elements:

• It must occur in the workplace,
• It may be perpetrated by superiors toward subordinates, by subordinates toward superiors, or among peers,
• It must be systematic in nature,
• It must be repeated with continuity and frequency,
• It must be intentional,
• It must aim to intimidate, isolate, or force the individual to resign,
• It must result in harm to the victim’s personality, professional status, or health,
• The negative attitudes and behaviors may be overt or covert.

3.2 Concepts and Situations Similar to Psychological Harassment

Considering that actions constituting psychological harassment may also arise from daily workplace relationships, problems, or conflicts, it is often observed that mobbing behaviors resemble ordinary communication issues or other negative workplace relations.

In some cases, individual characteristics and the impact of personal, family, or social life on professional life may become dominant, leading particularly sensitive individuals to perceive every negative situation or process encountered at work as psychological harassment. In other cases, mobbing allegations may be used as a form of “defensive mechanism” when an individual’s own mistakes or shortcomings are addressed.

Therefore, it is necessary to clarify certain concepts frequently confused with psychological harassment, such as workplace conflict, workplace violence, workplace incivility, and sexual harassment.

Workplace Conflict

Workplace conflict refers to disagreements arising between two or more individuals or groups for various reasons. Such conflicts do not target personality but rather focus on differences of opinion regarding how work should be performed.

In psychological harassment, however, disagreements manifest as unethical, unjust, and personal attacks that are continuous and result in severe consequences for the victim.

Workplace Violence

Workplace violence consists of criminal acts such as assault, physical harassment, threats, or damage to property.

Psychological harassment, on the other hand, is non-physical and primarily psychological in nature.

Workplace Incivility

Workplace incivility refers to a failure to observe minimum standards of respect in communication and behavior among employees. It is one of the concepts most frequently confused with psychological harassment.

Incivility represents a broader category of behavior than psychological harassment.

Sexual Harassment

Sexual harassment, although its boundaries may not always be clearly defined, is a more concrete concept and frequently becomes subject to criminal investigation and prosecution.

There may also be severe cases where sexual harassment occurs alongside psychological harassment.

4.Our Business Ethics Principles

a.Integrity

Honesty and integrity are our fundamental values in all business processes and relationships. We act with honesty and integrity in our relations with employees and all stakeholders.

b.Conflict of Interest

A conflict of interest refers to situations in which an individual or institution may improperly use their position to obtain personal or institutional benefits.

As MIA Teknoloji, we aim to avoid situations that may create conflicts of interest in business-related activities. In cases of potential conflict, we apply lawful and ethical methods to protect the interests of relevant parties. When in doubt, employees are expected to consult their managers, ethics advisors, or the Ethics Committee.

c.Protection of Trade Secrets and Confidentiality

Information is one of the most critical assets used by MIA Teknoloji to achieve its vision.

Ensuring the effective use, proper sharing, confidentiality, integrity, and accessibility of information is a shared responsibility of all companies within the Group and all employees.

Confidential information includes, but is not limited to: intellectual property rights, innovations, databases, printed communication materials, business processes, advertising, product packaging and labeling, business plans (marketing, product, technical), business strategies, strategic partnerships, partner information, financial data, personnel records, customer lists, pricing, product designs, know-how, specifications, supplier information, and all other written, graphical, or machine-readable information.

5.Our Responsibilities

a.Legal Responsibilities

We conduct all domestic and international activities in compliance with the laws of the Republic of Türkiye and international law, and provide accurate, complete, and timely information to regulatory authorities.

We maintain equal distance from all public institutions, administrative bodies, non-governmental organizations, and political parties without any expectation of benefit.

b.Responsibilities Toward Our Customers

We operate with a customer satisfaction–oriented and proactive approach, responding to customer needs accurately and promptly. We provide services on time and under promised conditions, and protect customer confidentiality with due care.

c.Responsibilities Toward Our Employees

We ensure that employee rights are fully and correctly exercised. We provide a fair, non-discriminatory, safe, and healthy working environment, support professional development, and respect work–life balance.

Discrimination based on language, race, color, gender, political opinion, belief, religion, sect, age, disability, or similar grounds is unacceptable.

No tolerance is shown toward physical, sexual, emotional harassment or mobbing. Retaliation against individuals who report violations or assist investigations is strictly prohibited.

d.Responsibilities Toward Suppliers and Business Partners

We act fairly and respectfully, fulfill obligations diligently, and protect confidential information of our business partners.

e.Responsibilities Toward Competitors

We compete fairly, lawfully, and ethically, avoiding unfair competition and supporting a healthy competitive environment.

f.Responsibilities Toward Society and Humanity

We value democracy, human rights, environmental protection, social responsibility, and anti-corruption efforts. We act with social awareness and respect the traditions and cultures of Türkiye and countries where we operate internationally.

Child labor is strictly prohibited in accordance with Turkish Labor Law and International Labour Organization (ILO) conventions.

g.Responsibilities on Behalf of MIA Teknoloji

We protect the Company’s reputation, act professionally, avoid misrepresentation, and use Company resources solely for business purposes. Company assets are protected against loss, misuse, or waste.

Corporate information assets—including hardware, software, services, and data—are subject to monitoring, reporting, and restriction when necessary.

6.Our Practices

Ethical Decision-Making Principles

Before taking action, the following questions should be considered:

• Is this action legal and compliant with Company policies?
• Is it fair and balanced?
• Would we be uncomfortable if it became public?
• How would a reasonable person perceive it?

Duties and Responsibilities

Employees

All employees are responsible for complying with laws, policies, ethics training, safety rules, reporting violations, and cooperating with investigations.

Managers

Managers are responsible for fostering an ethical culture, leading by example, supporting reporting, managing risks, and ensuring compliance.

Ethics Advisors

Ethics Advisors guide employees, report issues to the Ethics Committee, support investigations, and monitor effectiveness.

Reporting and Resolution of Violations

Violations must be reported through designated channels. Investigations are conducted confidentially. Disciplinary measures may include termination.

False or malicious reports constitute ethical violations and may result in legal action under applicable laws.