Emlak Konut

Corporate Governance Information Disclosure Policy

A. Purpose and Scope

After the public offering of the shares of Emlak Konut Gayrimenkul Yatırım Ortaklığı A.Ş. (EKGYO) according to the “Instruction Policy”, Emlak Konut Gayrimenkul Yatırım Ortaklığı A.Ş. (EKGYO) will ensure that the shareholders are fully, truthfully and duly instructed on the Company’s plans, expectations, strategy, objectives and vision, in addition to its past performance, in accordance with the requirements of the investors and beneficiaries, Securities Legislation, the Turkish Commercial Code, İstanbul Stock Exchange Legislation and other relevant legislation.

The instruction policy will include all types of information, documents, electronic records and data known by the Board of Directors and the senior executives, and by employees on operations which are not classified as “Confidential Data” and “Trade Secret”, and could be made public without being subject to any legal restriction.

B. Methods of Informing the Public

EKGYO will use the methods and mediums below to comply with the instruction policy in accordance with the duration and conditions stated in the Capital Markets Board (CMB) Communique on Principles Regarding Real Estate Investment Companies Serial VI, No 11.

  • Special case statements
  • Financial tables and footnotes, portfolio value table, independent audit report; all of which will be periodically delivered to the İstanbul Stock Exchange.
  • Three monthly reports
  • Annual activity reports
  • Institutional website (http://www.emlakkonut.com.tr)
  • Financier and analyst Meetings
  • Press releases
  • Press conferences

The EKGYO web site will be accessible at www.emlakkonut.com.tr/. The final versions of the EKGYO real contract, financial schedule and reports, prospectuses, public offering circulars and general board meeting agendas will be available on the website.

The website will be consistently updated to reflect any changes in partnership status and administration constitution. The company will respond as soon as possible to any requests for information via the website.

The Press and Public Relations Office of the EKGYO will prepare any bulletins included in the Company’s institutional communication activities, and/or any bulletins intended for the instruction of the public, receiving support in subjects that require outside expertise.

I. Press Instructions

Abiding by the content of special case instructions, meetings will be held and press bulletins prepared to distribute information on EKGYO ongoing projects and medium and long-term strategies. There will be equal opportunity given to members of the press for invitations to press conferences.

II. Investor Instructions

The Investor Relations Department of the EKGYO will conduct information sessions for investors and analysts. Meeting requests by natural or legal entities will be evaluated and if more than 10 people request a meeting within one week, a meeting date will be scheduled and the participants will be informed. Questions by phone or via e-mail will be answered within 10 days maximum.

C. Confidential Information

Confidential information is data related to a real event that may affect the value of the capital market instruments exported by the EKGYO and the investment decisions of the investors; data that may be regarded as meaningful to an investor; that is related to conditions that are not made public; that may provide an advantage to the user if used in the trading of capital market instruments with respect to other investors that are unaware of this information; that may have an effect on the value of the capital market instrument in question or the investment decisions of investors if made public.

Other parties that are in communication with the EKGYO employees who hold confidential information will be informed that they are held responsible for the protection of the confidentiality of this information in the special case formation process, and in the period from the special case formation onward, until it is declared by the İstanbul Stock Exchange. Employees working in the name and on the account of EKGYO will by no means share any information with third parties that is not yet made public and may be considered a special case. Should any of these employees unintentionally reveal confidential information to third parties, and if EKGYO concludes that the confidentiality of the information may be compromised, within the scope of the Capital Markets Board regulations, EKGYO will immediately make a special case declaration.

EKGYO will prepare a list of persons working who are affiliated to EGKYO under a labor contract or in any other way, and natural or legal entities acting in the name and on the account of EGKYO who have access to internal information, within the framework of the “Notification of the Guidelines on Public Declarations of Special Cases” of the Committee of the Capital Market [SPK]. The process of preparing and updating the list of the persons who have access to confidential information will be conducted by respective entities to the Administrative Affairs and Human Resources Office.

EGKYO will consistently update the list of those who have access to confidential information in accordance with the scope of projects and subjects. The list in question will be submitted to the respective public enterprises and institutions for review upon request. EGKYO will ensure that the persons listed are informed, in writing, regarding the protection and confidentiality of confidential information.

EGKYO may postpone the declaration of the confidential information with the intention of preventing any possible harm to its legal rights and benefits in accordance with the Capital Markets Board [SPK] Communiqué on the Notification of the Guidelines on Public Declarations of Special Cases Series VIII, No: 54.

D. Shareholders and Persons Authorized to Communicate and Distribute Public Instructions

The EGKYO may evaluate any requests for information, i.e. whether such information is qualified as a trade secret and/or whether it may affect the investment decisions and the value of capital market instruments, within the framework of the Committee of the Capital Market [SPK], Communiqué on the Notification of the Guidelines on Public Declarations of Special Cases Series VIII, No: 54.

The following persons

  • CEO and board members,
  • the Head of the Audit Committee and members,
  • the Chief Executive,
  • the Investor Relations Department

will respond in writing or orally. Only these persons are authorized to respond to requests for information. EGKYO employees should direct any inquiries to the Investor Relations Department.

E. Authority and Responsibility

The Instruction Policy will be created by the EGKYO Board of Directors with the Decision of the Board of Directors. The Board of Directors has the authority and responsibility for the prosecution, protection and development of the policy. Changes to the Instruction Policy will be made with by decision of the Board of Directors.

F. Validity

The Instruction Policy will become valid with the public offering of EGKYO.

G. INSPECTION

The provisions of this policy will be inspected by the internal auditing department.