Public Disclosure Policy
1. Purpose
Within the framework of Capital Markets Regulations, MIA Teknoloji A.Ş. adopts a transparent disclosure policy in order to share its past performance, future expectations, business developments excluding trade secrets, strategies, targets, and vision with authorized institutions, the public, investors, and shareholders in a timely, simultaneous, clear, complete, accurate, and continuous manner.
2. Authority and Responsibility
MIA Teknoloji A.Ş. endeavors to fully comply with the relevant regulations and legislation of the Capital Markets Law regarding public disclosure and transparency. For this purpose, within the scope of Section II of the Capital Markets Board’s Corporate Governance Principles, a Disclosure Policy has been prepared and approved by the Company’s Board of Directors. The Board of Directors is responsible for monitoring, reviewing, and improving the Disclosure Policy. The Investor Relations Department has been assigned to oversee and supervise the implementation of this policy.
3. Methods and Tools
Without prejudice to the provisions of Capital Markets Legislation, Borsa Istanbul regulations, and the Turkish Commercial Code (TCC), the methods and tools used in communications with authorized institutions, the public, investors, and shareholders under the Disclosure Policy are as follows:
- Material event disclosures submitted to Borsa Istanbul,
- Periodic financial statements, footnotes, and independent audit reports submitted to Borsa Istanbul via the Public Disclosure Platform (KAP),
- Interim and annual activity reports
- Written and visual press releases,
- Meetings and discussions with investors and analysts,
- Corporate website (www.miateknoloji.com).
The principles regarding these methods and tools are set out below.
a. Public Disclosure of Material Events
In accordance with the Capital Markets Board’s Communiqué No. II-15.1 on Material Events, a disclosure is prepared in cases involving “Inside Information” and “Continuous Information” that may affect the value of the Company’s capital market instruments traded on Borsa Istanbul or influence investors’ decisions.
The provisions regarding the postponement of disclosure under Article 6 of Communiqué No. II-15.1 are reserved. Material event disclosures are signed by authorized executives in accordance with the Company’s signature circular and are submitted electronically to Borsa Istanbul via KAP on the day the relevant event occurs. They are also simultaneously published on the Company’s corporate website.
b. Public Disclosure of Financial Statements
The Company’s financial statements and footnotes are prepared in accordance with International Financial Reporting Standards (IFRS) and are subject to independent audit.
Following approval by the Board of Directors, financial statements, footnotes, independent audit reports, and related documents are disclosed to the public electronically via KAP and submitted to Borsa Istanbul. They are also published simultaneously on the corporate website in Turkish and, when necessary, in English.
c. Disclosure of Period-End Activity Reports
Period-end activity reports prepared in compliance with CMB regulations are presented for shareholders’ review prior to the General Assembly meeting, published on the Company’s website, and submitted to Borsa Istanbul.
d. Written and Visual Press Releases
The Company complies with relevant CMB regulations in all written and visual press releases concerning its commercial activities, expectations, and current issues.
If such disclosures include matters subject to material event disclosure under Communiqué No. II-15.1, they are first announced via KAP before being released to the press. Visual media statements are made only by the Company’s designated spokesperson. All disclosures are reviewed in advance for compliance with applicable regulations and the Disclosure Policy.
e. Meetings and Communications with Investors and Analysts
The Company participates in meetings and conferences with existing and potential shareholders and brokerage analysts to enhance investor relations.
Presentations covering sector developments, Company strategies, and analytical explanations of financial statements are made, and questions are answered. Care is taken to ensure that such disclosures do not include trade secrets and comply with Communiqué No. II-15.1.
f. Corporate Website
The corporate website (www.miateknoloji.com) is actively used for public disclosure. Information disclosed to the public is accessible via the website.
Most content is provided in both Turkish and, when necessary, English, in accordance with Corporate Governance Principles. Information is published in a timely, accurate, complete, and understandable manner.
The website primarily includes:
- Material event disclosures
- Trade registry gazettes
- List of Board members
- Senior management list
- Audit Committee
- General Assembly minutes and attendance sheets
- Periodic financial statements and audit reports
- Annual activity reports
- Disclosure Policy
- Dividend Policy
- Investor Relations contact details
- Information Society Services
In addition, information on the Company’s products, services, and commercial activities is also provided.
g. Disclosure of Expectations and Targets
When deemed necessary, expectations and targets may be disclosed using the methods specified in Section 3.
Such disclosures include their underlying assumptions and supporting data, as well as potential risks and uncertainties. In accordance with Article 10 of Communiqué No. II-15.1, revisions are disclosed if projections prove inaccurate. Disclosures are made only upon approval by the Company’s authorized bodies.
h. Unfounded Market Rumors
The Company does not comment on market rumors or speculation. However, when requested by CMB or Borsa Istanbul, or when deemed necessary by the Board, appropriate disclosures are made through Investor Relations channels.
i. Analyst Reports
Analyst reports are considered the property of the issuing firm and are not published on the Company’s website. They are neither verified nor approved by the Company.
In limited cases and upon request, reports may be reviewed solely based on publicly disclosed information to prevent misinformation.
4. Criteria for Identifying Persons with Administrative Responsibility
Persons with administrative responsibility include Board members, auditors, and individuals with regular access to inside information.
Chairman, Board Members, auditors, coordinators, managers, and executives are deemed to have access to inside information. Relevant lists are maintained within the Central Registry System and published on the corporate website.
5. Authorized Persons for Public Disclosure
Information requests are evaluated by the Investor Relations Department. Responses are provided after assessing confidentiality and regulatory compliance.
Press and media disclosures may only be made by the Chairman, CEO, CFO, or Board Members. Other employees are not authorized to respond.
6. Protection of Inside Information
All necessary measures are taken to prevent misuse of inside information. Employees are informed about legal obligations and sanctions.
Inside information may not be used for personal benefit. Confidentiality obligations continue after employment. Trading based on inside information is prohibited.
Lists of persons with access are maintained and updated. Relevant confidentiality clauses are included in contracts. Violations result in immediate disclosure via KAP.
7. Communication with Capital Market Participants
The Company does not provide earnings guidance. Instead, it focuses on communicating strategic priorities and key business drivers.
Only authorized persons may communicate on behalf of the Company.
8. Unfounded Market Rumors
The Company does not comment on speculation. Media monitoring is conducted, and evaluations are made regarding potential market impact.
Where necessary, disclosures are made in accordance with Communiqué No. II-15.1.