Valued 7D team;

Work principles of fairness, equity, transparency and honesty stated by our founding members have been our standard.

7D partners and team act in responsibility to the society, the environment and business partners. These set of responsibilities represent the basis of 7D business ethics.

7D title means perfection. 7D which represents the 7th dimension covers a wide range of disciplines starting from planning that ends up with facility management.

Prevailing understanding in this field is to focus to create perfect design. This qualification is the outcome of our founding partners’ experience of over 40 years in global professional operations. This qualification is an asset not easily found in organizations and also creates added value to the individuals. Correct conception and adoption of the idea of overriding competition is our expectation.

The ETHICS POLICY of 7D Project Development Architecture Engineering and Consultancy Inc. is set out to raise the corporate value of the company. This policy ensures all employers and employees to develop high standard attitudes and be aware of the effect of their behavior and attitudes in corporate life. All employers and employees have to obey the principles and rules defined in the below mentioned 7D Project Development Architecture Engineering and Consultancy Inc. ETHIC POLICY. These set of rules can only be sustained with the support and attitudes of company staff. This will assure the persistence of our corporate identity.

Our “ETHICS POLICY” handbook has been prepared and approved by the Board of Directors. 7D Ethics Policy is a summary of principles to be followed by all employees as well as managers and directors that will stipulate the CORPORATE identity. Ethics Policy also appears on the corporate website (www.7dproject.com) and internal circulars.

We thank you for your support to this program that will lead your company and yourselves to a higher quality future professional life.

With our best regards

7D Project development Architecture Engineering Consulting Inc.

Board o Directors
7D ETHICS POLICY:

Founders, shareholders and all staff of 7D; all our relations with individuals, employers and service providers always depends on moral standards of the highest level. Following moral principles and values will lead us in all that we do and what we're going to do after today.

Honesty: All our staff has signed this text to be truthful; to ourselves, to service providers, to employers and to each individual in our society.

Integrity: All our staff is obliged to fulfill their promises on time and in required quality.

Respect: To be respectful and objective to all company staff being aware that each and every individual is distinctive and unique.

Confidence: To give confidence by open and sincere internal communication and teamwork.

Responsibility: To reveal clearly and explicitly any behavior observed against our regulations and company principles, inform related departments, and try to acquire information in case of a doubtfulsituation.

Citizenship Awareness: To obey laws and regulations of the Republic of Turkey and any other country that we cooperate. To act as a responsible citizen to improve the community we are living in.

This study aims to clearly define business strategies of our company that includes obligations of our employees.

“Business Ethics” covers all managers including founding partners, members of the board and staff. From now on these people will be nominated as “EMPLOYEES”

As employees, our responsibility is to keep honesty and business ethics. In our interactions with third parties, it is our obligation to be honest, reliable and act in conformity with business ethics.

Business ethics provide grounds for creating a common understanding about expectations in our area of responsibility besides the existing rules and regulations. Such assessments reveal the business ethics principles that define us as a company and practical and guiding directives to better understand and follow our principles. However it is no possible to include all topics and details in this study. These directives are designed to handle most frequently encountered general concerns; it is not a book of rules. In the first place it aims to lead our employees. Please read business ethics carefully, spare time to ponder on them, after you fully comprehend, put your signature to confirm your approval.

Please consult your manager in case you have any questions about these rules or if you witness the breach of ethical rules in the workspace.

Main principle of this study can be summarized as;
“We always need to be honest fair and respectful as representatives of the Company”

BUSINESS ETHICS POLICY

Conflict Of Interest

Conflict of interest roots from the clash of personal interests of an employee vs company interests, that occur or that may occur. It is essential that Company employees stay away from conditions that may cause conflict.

It is expected that 7D Project Development Architecture Engineering and Consultancy Inc. employees fulfill their responsibilities by keeping company interests over those of themselves, their family and friends.

Using Company resources, title, identity and power for personal benefits should be avoided; and employees are expected to stay away from conditions that may have adverse effect on company title and image. Employees should avoid any initiative that may be conceived as providing interests to their acquaintances.

Ability of decision making is an important asset of yours. Conflict of interest impairs your ability of decision making. You are expected always to follow Company interests.

Below mentioned performance is expected from our employees to prevent conflict of interests.

• Avoid creating situations that may imply provision of interest for themselves or their acquaintances, they keep out of decision making process in cases where their own and/or their acquaintances’ benefits are in question, • Never go into financial relationship neither with our customers nor with our project partners and provide personal advantage using business relations, • Do not yield to pressures that may result against Company interests, do not provide personal benefits from the client/project partners, do not transfer benefits by establishing relationship between the project stakeholders, • They utilize their time and labor for the benefit of the Company. They do not undertake further responsibilities that may end up with conflict of interests. They may not work for any other real or corporate party other than 7D, • They may not utilize the information they acquire during their duties in order to lead to an unfair advantage. • They may not be effective in decisions about promotion or rewarding of their spouses or close relatives in the Company, • In case of recruitment of kinship among employees, rotation, promotion and assignment situations, it is necessary not to have an organizational bond between them horizontally or vertically.

Accuracy of Records

Accurate and well-preserved business records are necessary and very important to conduct our business. Employees are responsible for ensuring the accuracy of records and documents and their compliance to laws and regulations. These records are essential for the execution of the Company's activities and in fulfilling their obligations to its employees, suppliers, project stakeholders, clients and public authorities.

Use of Company Assets and Resources

Company assets are for the use of the Company and may not be used for personal purposes. Property, assets, equipment, vehicles, computers, computer software, etc. that are allocated to the use of the personnel for conducting routine work, delivered with stock record forms and may not be used for personal interests or interests of another individual by any employee.

All employees should follow economy principles. "Saving in everything" principle is applied strictly by all employees. Employees should be aware that benefit from the company's assets for personal purposes, is deliberately violation of "Business Ethics".

Relations with Client and Project Stakeholders

It is one of 7D’s objectives to provide the promised and best quality service in most economical methods to our employers. All our employees try to help our suppliers and clients with an honest, consistent, reliable and solution-oriented attitude. They show utmost care for a healthy flow of information between our clients and project stakeholders. Each one of our employees is in the capacity as the representative of 7D in any environment. It is our belief that success is closely related to our relationship with our clients based on honesty, ethics and mutual confidence.

Policy of Accepting and Presenting Gifts

The impartiality of a 7D employee is not to accept gifts or benefits that may influence their neutrality, their decisions and behavior. It is essential to avoid direct or indirect intervention of presenting gifts and provide direct benefit towards organizations and third parties that could influence their neutrality, decisions and behavior.

The employees never demand gifts or imply such, from persons/institutions that the Company has commercial interaction with. They may not accept any gifts, money, checks, stocks, real estate, free holidays, special discounts, etc. that could put the Company under liability.

Types of gifts and promotion material that will be presented to the client and business counterparts and their delivery method will be approved by the Company Top Management.

Security of Information

Confidential information or commercial secrets of the Company and documents of personal information about our employees and project stakeholders will be handled with highest level of confidentiality. Our employees may never use this information for personal purposes and share with third parties.

All this information that belongs to the Company is not available for third parties and their security is under the responsibility of the employees.

Electronic Mail

Electronic mail should only be used for business. For personal affairs please do not use company mail. The electronic mail should not be used to transmit illegal and immoral messages that will put yourself and/or the company in a difficult position.

Relations with Public Authorities, Private Institutions/Organizations, Non Profit Organizations and Media

The Company’s relations with Public Authorities, Private Institutions/Organizations, Non Profit Organizations and Media should be within principles of rectitude, honesty, equality and independence. It is strictly forbidden to present donations/gifts to any government office or non-profit organization personally in the name of 7D.

The employees will avoid any conduct that may lead to speculation, and create situations that may give raise to negative evaluation and could damage the confidence, reputation and stability of the company or the sector, or any application that can create unfair competition.

Such demand of the state should be forwarded to the Director of Administrative Affairs.

Respect in the Workspace and Corporate Life

7D employees act with respect to each other. None of the employees would display uncomforting or disturbing manner their co-workers, clients of project stakeholders or get into a behavior of damaging other people's property. Utmost respect is shown to the families and private lives of the employees.

The company is obliged to create a safe and productive work environment. The company shows sensitivity and care at the highest level for protection of personal data of its employees.

Because of continuous development, necessary planning will be done for the employees to reach the desired performance level, and organize training needed. Parallel to the financial prosperity of the Company, training programs will be launched for all employees.

Everyone who works at the company, are considered as equal regardless of their race, language, creed, age, gender, nationality, disability, and other legally protected categories without discrimination.

Any behavior that is unwanted, unwelcomed and not responded by the addressee means to constitute harassment.

Any request that is annoying or including a sexual compromise or any behavior that will lead to a feeling of threat and unwelcomed by the other person is harassment.

All kinds of aggressive and cynical behavior directed to the disability of an employee with a physical incapacity are also harassment. All employees display consideration in their behavior to each other.

In this context, all employees show the necessary attention in their behavior toward each other.

Preventing Unwanted Behavior in the Workplace

Use of Status Power in the Workplace

Misuse of status power may be caused by either personal power of the individual (Title, physical, personal, age) or collective power (power derived from numerical superiority). Such behavior is named as inacceptable by the Company.

Reasonable and logical errors made by the employee to be treated by an appropriate and constructive manner, studies and appraisals for employee improvement, etc. are examples of correct use of status power.

Harassment, Target Point, Select as Victim

Every one of us deserves respect and has human pride. Any behavior or action that will violate this, especially any kind of sexual harassment, is unacceptable.

Avoid behavior and rumors that will cause an employee to feel isolated; he should not be made a target point, harassing behavior should be avoided that would create psychological anxiety. An example to this may be systematic and planned behavior to wean, degrade the performance of a person, or to cause a person to resign. (E.g. criticism of an employee's private life in public, constant interruption of his/her word, constantly being scolded in front of other employees, ignorance of his/her success, etc.)

7D takes all measures to prevent such behavior and expect the same sensitivity from all employees.

Relations with the Environment

It is vital to protect the world we live in. As 7D we are aware of the importance of a healthy and clean environment. We expect our employees to fully implement health, safety and environmental measures. We pay great attention to plan, construct and manage workspaces that protect our employees and our existing resources. This care also covers the use of protective equipment, attainment of required precautions, thus creating a safe working environment.

APPLICATION OF ETHICS POLICY

Conformity to Business Ethics

The employees should take all necessary measures to avoid breach of these rules.

In case they observe infringement of rules the employees should immediately inform their manager, if not Director of Administrative Affairs or Human Relations Manager. To be available for the employers and to answer their questions, provide training and to give consulting is one of our 7D top management’s goals. Managers will compel all opportunities to provide this support.

Ethics Policy is reviewed every year considering technological innovations, global and environmental conditions, company dynamics and recommendations from our valued employees.

It is rather difficult how above mentioned organizational principles will apply to all individual cases we may face in the future. So we can ask ourselves;

Am I doing the right thing to do?
Is what I do suitable to community values?
Will what I do protect my Company image?

Please do not forget that we are a family. We are an influential family mentioned along with our title, with our generated and shared moral values and having strong belief in love and respect between old and young from the very beginning. Our title is one of the most valuable assets of this family. We are all responsible to protect and cherish this asset.

With our cordial regards

7D Project development Architecture Engineering Consulting Inc.

7D Proje Geliştirme Mimarlık Mühendislik Danışmanlık A.Ş. ® All rights reserved. I 2016