Code of Ethics

1. Purpose:

This procedure defines the ethical and moral values of Qua Granite Hayal Yapı Ve Ürünleri San. Tic. A.Ş, and describes the behaviors and manners to be adopted in this regard. It is aimed to guide employees in their decisions and behaviors while fulfilling their duties, and to create a peaceful and productive working environment through these ethical and moral values.

2. Scope

This procedure covers the ethical and moral values that the employees should comply with at all business places of Qua Granite Hayal Yapi ve Ürünleri San. Tic. A.Ş.

3. Definitions Company:

All business places of Qua Granite Hayal Yapı Ve Ürünleri San. Tic. A.Ş., are herein called as “the Company”.

Personnel, Employee: All employees of the Company, who are employed under the fixed, indefinite, partial, full-term service contracts are herein referred to as "Personnel", "Employee" and, as appropriate, "related person" or "relevant person”.

Code of Ethics and Moral Value: They are the principles and standards guiding the persons in determining “how decisions should be made and how jobs/roles should be done”.

4. Responsible Personnel

The Department of Human Resources defines the ethical and moral values and determines the appropriate behavior methods. It determines the valuation principles and enables to take action in case of any inappropriate situation.

The Board of Directors and the all-Company employees are responsible for complying with and ensuring the compliance with this procedure.

5. Practice

Ethical and Moral Values are the standards of corporate behavior and decision-making in accordance with the duties and principles specified based on the core values through an institutional perspective. These values guide people in business life and regulate internal and external communication. Ethical and Moral Values aim to:

Create standard behavior models in the face of increasing location and number of employees.

Make it easier for those from different cultures to take role in the company,

Prevent discrimination in business life on issues such as ethnicity, language, religion, and gender.

Define the areas we are sensitive to

To achieve our competitive advantage with the quality of our products, not with unethical business practices, with the belief of fair, free and open competition,

In case of detecting any behavior against ethical and moral values, it should be reported to the Disciplinary Board regardless of the position and duty of the persons concerned. Action shall be taken against the persons concerned in accordance with the provisions of the Disciplinary Board Regulation.

6. Ethical and Moral Values

a. Honesty

Qua Granite employees are selected among reliable, hardworking, self-sacrificing, loyal persons with high ethical and moral values and certain knowledge. They respect the laws and internal company regulations and comply with the instructions and procedures. Employees cannot support or provide benefits to any activity, association, person or organization using the company name without the approval of the Board of Directors. They pay the maximum attention to the effective and correct use of the company resources and avoid from causing unnecessary expenses. They do not use and prevent the use of company resources and assets as well as the opportunities provided by the company for their personal interests, and prevent their use.

b. Sense of Mission

They are open to change and development, thinks positively and adds value to the company by training personnel. They are aware that they take a role in a company that has determined its goals along with its vision and mission. In line with this awareness, it provides personal development by investing in themselves. They act with the awareness of providing customer satisfaction. Managers avoid from behaviors and jokes with their subordinates, which are in violation with the basic moral codes and which might be misinterpreted and result in gossips even if in good faith. Employees are liable for being aware of the Company Policy and applicable legislation regarding their duties and acting accordingly. Employees puts maximum care and attention in fulfilling the assigned task, and they aim to perform the work done more quality, faster and more economically. Employees might not engage in any behavior to damage the reputation of the Company in public or cause it to be in a legal situation, both while carrying out their business and during their private lives. Employees who attach great importance to the customer satisfaction convey all customer complaints to the Customer Representative as soon as possible.

c. Responsibility

They represent the company in the best way, anytime, anywhere. All employees act in a reasonable and respectful manner among themselves. All employees protect and use the fixtures delivered to them carefully. Employees who are provided with instructions in contrary to the Company values, procedures and laws should report it to the superior immediately without following the instructions in question. Unless the Employees other than those specified in the signatory list are authorized by their superior expressly, they cannot act to represent the company against third parties, and cannot communicate in this regard. Employees avoid all kinds of actions and actions to damage the image and reputation of the company, and they exactly follow the predetermined or generally accepted dressing codes and behavior codes by the company management during the working hours. Employees do not act in an insensitive and unresponsive way against the situations contrary to the company's interests and report such situations to the relevant units.

d. Confidentiality:

Employees have the ability to keep secret. Employees do not talk about or discuss the matters related to their duties outside the company and do not cause any negative comments. Employees do not leak confidential and private information (especially those with financial, engineering and design content) that have learned as a requirement of their positions or jobs to the outside of the company, and do no participate in any interviews, or give any statements or declarations to visual or written media organizations without the approval of the company management. Employees do not share or disclose the confidential or private information that they have learned about the other employees of the company due to their duties, with anyone outside the company. Employees should comply with the company's commercial information and confidentiality obligations even after leaving the company. Any kind of documents (handwriting, notes, computer files and e-mails, technical drawings, documents of ideas created by brainstorming, patents, etc.) that they use or create when performing their duties are deemed as the property of the company and cannot be taken out of the company and used without permission. These documents should be truthful. If no longer valid, the documents should be destroyed in accordance with the company policy or, if necessary, should be kept in accordance with the company policy and the provisions of the current legislation regarding the storage of such documents.

e. Gift Acceptance

• Cash, gift certificates or precious metals cannot be accepted as gifts by employees in any way.

• Company employees can never give gifts to other employees or their families on behalf of the company.

• Food-type gifts received by the departments are consumed collectively within the department.

f. Conflict of Interests

Any employee should not place their private interests above the interests of the Company.

All employees are supposed to look after the interests of the company while performing their jobs.

Employees should avoid from behaviors and attitudes to benefit themselves or their relatives.