Policies

A. Purpose and Scope

Emlak Konut Real Estate Investment Trust Inc. (EKGYO) ensures, through its Disclosure Policy, that shareholders, investors, and stakeholders are informed in a timely, complete, accurate, and effective manner regarding both its past performance and its future plans, expectations, strategies, objectives, and vision, in accordance with the regulations set forth under the Capital Markets Legislation, the Turkish Commercial Code, the Borsa Istanbul Regulations, and all other applicable laws and related regulatory provisions.

The Disclosure Policy covers all information, documents, electronic records, and data relating to activities that do not qualify as Inside Information or Trade Secrets, are known by Board Members, senior executives, and employees, and do not pose any legal restriction or objection to public disclosure.

B. Methods and Tools for Public Disclosure

EKGYO uses the following methods and tools for the purposes of its Disclosure Policy, within the framework of the procedures and time periods specified for the periodic tables and reports set out in Articles 38 and 39 of the Communiqué on Principles Regarding Real Estate Investment Trusts (III-48.1).

• - Special situation disclosures
• - Financial Statements and Notes thereto periodically submitted to Borsa Istanbul, Independent Audit Report
• - 3-Monthly Reports
• - Annual Activity Reportss
• - Corporate website (http://www.emlakkonut.com.tr)
• - Investor and Analyst Meetings
• - Press releases
• - Press conferences

Access to the EKGYO corporate website is provided via www.emlakkonut.com.tr. The latest version of EKGYO’s Articles of Association, periodic financial statements and reports, prospectuses, public offering circulars, and General Assembly meeting agendas are published on the website.

The website will be continuously updated to accurately reflect the latest status of the Company’s shareholding and governance structure. The Company will promptly respond to all information requests received through the website.

Bulletins to be prepared by EKGYO for the purpose of public disclosure and/or within the scope of its corporate communication activities are drafted by the Press and Public Relations Directorate of EKGYO, with external expert support obtained for matters requiring specialized knowledge.

I. Informing the Press

Meetings are held and press releases are prepared by EKGYO, in line with the content of the relevant material event disclosures, for the purpose of informing the public on matters that directly relate to its operations, such as ongoing projects and mid- to long-term strategies. The principle of equal treatment is strictly observed among all members of the press invited to such meetings.

• - Principles for Monitoring News and Rumors Published in the Media and on Internet Platforms Concerning EKGYO, and Procedures for Related Public Statements

EKGYO monitors news and market rumors published in national or international media outlets and other communication channels in accordance with its press monitoring procedures. In cases where such news or rumors contain information that is first-time public disclosures or that differs from information previously disclosed, EKGYO evaluates whether the content may have an impact on the value or price of the Company’s shares or on investors’ investment decisions. When deemed necessary, the Company issues public statements within the framework of the principles set forth under the capital markets regulations.

As a matter of principle, EKGYO does not comment on market rumors or speculation. However, public statements may be issued in relation to unfounded news when a verification request is received from the Capital Markets Board of Türkiye (CMB/SPK) and/or Borsa Istanbul, in accordance with the provisions of the Capital Markets Legislation, or when the Company’s management determines that providing a response is necessary and more appropriate.

II. Principles for Access to Presentations and Reports Disclosed at Investor Information Meetings and Press Conferences

Matters related to informing investors and analysts are managed by the Investor Relations Directorate of EKGYO. Meeting requests received from natural or legal persons are evaluated, and when the number of applicants reaches 10 participants within a single week, the request holders are notified of a scheduled meeting date. Presentations delivered and/or explanatory information notes provided during such meetings are published on the EKGYO corporate website following the presentation, teleconference, or related speech. EKGYO representatives may periodically attend national and international conferences or meetings to share information with investors and analysts, and the presentations used at these events are also published on the EKGYO website. Questions submitted via telephone or email are answered within a maximum of 10 business days following receipt, and in any case no later than 10 business days (or 10 working days if required by internal SLA).

C. Inside Information and Measures Taken to Ensure Confidentiality Until Public Disclosure

Inside information refers to non-public, specific, and concrete information concerning an event or circumstance that may have an impact on the value or price of capital market instruments issued by EKGYO or influence investors’ investment decisions, which a reasonable and rational investor would consider material when making an investment decision, and which, if used in trading, could provide its holder with an advantage over other investors who do not have access to the same information, and which, if disclosed to the public, may create a significant effect on the price or value of the relevant capital market instrument or on investment decisions of investors.

EKGYO employees who possess inside information, as well as other parties in communication with the Company, will be duly informed that they are obligated to safeguard the confidentiality of such information throughout the material event formation process and until its public disclosure on Borsa Istanbul. Persons acting on behalf of or for the account of EKGYO shall not, under any circumstances, disclose or share any information that has not yet been publicly announced and may qualify as a material event or inside information with third parties. In the event it is determined that inside information has been disclosed to third parties without request or consent, and it is concluded under capital markets regulations that confidentiality can no longer be ensured, EKGYO shall immediately issue a material event disclosure without delay. Where such disclosure is identified to be unintentional or unauthorized, and the loss of confidentiality is confirmed, the Company will promptly file the required special circumstance statement (material event disclosure) in compliance with the Capital Markets Legislation.

EKGYO prepares a list of natural and legal persons who have access to inside information, in accordance with the Capital Markets Board (SPK/CMB) Communiqué No. II-15.1 on Material Events (Special Circumstances). This list includes persons acting on behalf of or for the account of EKGYO, as well as employees affiliated with the Company by employment contract or otherwise who have access to inside information. The list is compiled and updated through the submission of inside-information access records by the relevant business units to the Administrative Affairs and Human Resources Directorate of EKGYO via the Company’s internal coordination channels.

The list of persons with access to inside information maintained by EKGYO will be kept continuously up to date in accordance with the evolving scope of projects and related subject matters. The relevant list will be made available to duly authorized official institutions and regulatory bodies upon request. EKGYO ensures that the persons included in the list are provided with written notification and informed of their obligations regarding the protection and confidentiality of inside information.

EKGYO may delay the public disclosure of inside information in order to prevent harm to its legal rights and legitimate interests, within the framework of the provisions of the Capital Markets Board (SPK/CMB) Communiqué No. II-15.1 on Material Events (Special Circumstances).

D. Communication with Shareholders and Persons Authorized to Make Public Disclosures

By evaluating whether any information request directed to EKGYO qualifies as a trade secret and whether it contains content that may influence investment decisions or affect the value or price of capital market instruments within the framework of the Capital Markets Board (SPK/CMB) Communiqué No. II-15.1 on Material Events (Special Circumstances),

• - Chairman and members of the Board of Directors,
• - Audit Committee Chair and members,
• - Managing Director,
• - Investor Relations Department

Responses will be provided in written or verbal form by the authorized persons. Employees other than these authorized individuals are not permitted to respond to information requests. EKGYO employees shall refer any inquiries directed to them to the Investor Relations Directorate, and are required to redirect questions received to the Investor Relations Directorate without providing any direct response.

E. Authority and Responsibility

The Disclosure Policy is established by the Board of Directors of EKGYO through a Board Resolution, and the monitoring, oversight, and further development of the Policy fall under the authority and responsibility of the Board of Directors. Any amendments or changes to the Disclosure Policy are adopted and approved by a Board Resolution.

These policy provisions are administered by the Investor Relations Department.

F. Principles used in determining persons with administrative responsibility

Persons Discharging Managerial Responsibilities are board members and persons who, even though they are not board members, have direct or indirect regular access to inside information and have the authority to make managerial decisions affecting the company's future development and business objectives. EKGYO has determined Persons Discharging Managerial Responsibilities as Board Members and EKGYO Senior Management.

G. Principles for the Disclosure of Forward-Looking Assessments

The Company's assessments regarding its forward-looking plans and forecasts that qualify as inside information may be disclosed to the public by persons authorized to make public disclosures within the framework of the principles specified in capital markets legislation. Forward-looking assessments are based on reasonable assumptions and estimates, and changes may be made to these forward-looking assessments in case of deviations due to unforeseeable risks and developments. Differences may occur between actual results and expected results in forward-looking assessments due to risks, uncertainties and other factors. In such cases, the resulting differences are disclosed to investors within a reasonable time period.

Forward-looking assessments may be made, in addition to disclosures to be made within the framework of the principles in capital markets legislation, by utilizing press and media outlets, press conferences and/or press releases, national and international conferences or meetings, or other means of communication.