TÜPRAŞ-TÜRKİYE PETROL RAFİNERİLERİ A.Ş.

Regulatory Filings • Jun 13, 2025

Türkiye Petrol Rafinerileri A.Ş. Disclosure Policy

1.	PURPOSE AND SCOPE	3
2.	METHODS AND TOOLS	3
2.1.	Authorized Persons for Disclosure (Spokespersons)	3
2.2.	Tools Used for Disclosure	3
2.3.	Activities Carried Out by the Investor Relations Department	4
3.	POLICIES ON MATERIAL EVENT DISCLOSURES	6
3.1.	Responsibility	6
3.2.	Persons with Administrative Responsibility	6
3.3.	Public Disclosure of Inside Information	6
3.4.	Ensuring the Confidentiality of Insider Information	6
3.5.	Postponement of Public Disclosure of Inside Information	7
3.6.	Fulfilment of Verification Obligation	7
3.7.	Public Disclosure of Forward-Looking Statements	8
4.	OTHER PUBLIC DISCLOSURE POLICIES	9
4.1.	Exercise of Shareholder Rights	9
4.2.	Public Disclosure of Financial Statements	9
4.3.	Public Disclosure of Activity Reports	9
5.	AUTHORITY AND RESPONSIBILITY 10
6.	APPROVAL AND AMENDMENT STATUS 10

1. PURPOSE AND SCOPE

The purpose of the Türkiye Petrol Rafinerileri A.Ş. ("Tüpraş") Disclosure Policy, is to determine the methods and principles that Tüpraş will use to share information and developments, otherthan trade secrets, that may affect the price of its shares or the investors' decision, including operational and financial performance and expectations, in a timely, accurate, complete, direct, understandable, adequate and easily accessible manner and in accordance with the principle ofequal treatment.

While following an active and transparent disclosure policy, Tüpraş, in accordance withKoç Group Code of Ethics and Tüpraş Code of Ethics and Business Conduct and its Implementation Principles, complies with the applicable legislation, especially the Turkish Commercial Code (the "TCC") and the Capital Markets Board (the "CMB") and the Borsa Istanbul ("BIST") regulations in all matters related to public disclosure, and aims to implement an effective disclosure policy.

2. METHODS AND TOOLS

2.1. Authorized Persons for Disclosure (Spokespersons)

In principle, with the exception of the forms, declarations and reports signed in accordance with the signature circular, the announcements and disclosuresto be made on behalf of Tüpraş within the framework of the above-mentioned purpose and scope, shall be made by members of the Board of Directors, General Manager, Chief Financial Officer or the Corporate Communications Director.

In addition, the Investor Relations Department (the "IRD"), consisting of the Chief Financial Officer, the Investor Relations Managers and employees, can communicate on behalf of Tüpraş for explaining Tüpraş to existingand potential investors, intermediary institutions and financial institutions domestic and abroad,meeting incoming information requests, including those of analysts and financial experts working in such institutions and answering questions submitted to them within the frameworkof investor relations.

2.2. Tools Used for Disclosure

As per the CMB and BIST regulations and the TCC, Tüpraş can use the following communication methods and tools for public disclosure:

• − Material event disclosures and company general information form announced on the Public Disclosure Platform (the "PDP").
• − Financial statements, independent audit reports and annual reports, sustainability reports and integrated reports announced in the PDP.
• − Corporate Governance Compliance Report and Corporate Governance Information Form announced in the PDP.
• − Corporate website (https://www.tupras.com.tr) and corporate applications on digital platforms,
• − Information and supportive documents prepared for investors, presentations about the company,
• − Investor and analyst meetings; interviews and meetings with capital market participants, including those in the digital platforms,
• − Prospectus, circulars, issuance documents, announcements, and other documents to be prepared in accordance with the CMB regulations,
• − Press releases made via media tools,
• − e-Company and e-GKS (Electronic General Assembly System) platforms of the Central Registry Organization (Merkezi Kayıt Kuruluşu ("MKK")
• − Declarations and announcements made through the Turkish Trade Registry Gazette and daily newspapers.

Depending on the nature of the disclosure, it is possible to use only one of these methods and tools, as well as use more than one tool if and when necessary.

2.3. Activities Carried Out by the Investor Relations Department

The Investor Relations Department of Tüpraş regularly communicates with both existingand potential shareholders, analysts and capital market experts, to respond the inquiries of investors and other capital market participants in the most efficient way and makes necessary disclosures to ensure the capital market instruments of the company traded in the financial markets achieve their fair value. The Investor Relations Department manages the communication with shareholders and all other stakeholders in order to avoid asymmetric distribution of information and to ensure the distribution of information in an easily accessible,understandable, analysable, timely and accurate manner.

The primary purpose of the Investor Relations Department is to conduct the mutual relationship between the company and investors in the most effective way. In this context, the Investor Relations Department serves as a bridge between the company's senior management and investors. On one hand the investors are informed on the investment case, on the other hand, periodic reporting is carried out in order to notify senior management on investors' evaluation and feedback. Hence, a two-way communication is facilitated.

Disclosure Meetings

In order to ensure that operational and financial performance, vision, strategy and goals of Tüpraş, and the value created for its stakeholders are best explained and presented to investors and analysts, the Investor Relations Department officials often meet with capital market participantssuch as brokerage firms, analysts, investors.

The representatives of the Investor Relations Department, who strive to meet all the interview requests that they receive during the year, also regularly attend face-to-face or digitally organized conferences and meetings in Turkey and abroad. In addition, it also holds one-to-one meetings with investors. From time to time, the General Manager and Chief Financial Officer may also participate in these meetings, hereby facilitating more effective communication between senior management and existing and potential investors.

In order to ensure effective financial communication, presentations are prepared on the financial results on a quarterly basis, and analyst meetings or teleconferences are held with the participation of the Chief Financial Officer, Investor Relations Executives, where necessary, the Executives Responsible for Financial Reporting, and from time to time General Manager to respond investors' and analysts' questions.

The dates of the teleconferences and meetings that Tüpraş will hold with analysts and investors domestic and/or abroad are disclosed to public on corporate website of Tüpraş

(www.tupras.com.tr) for investors. The investor presentation, which is updated monthly and published on the website, is also used in these meetings. In addition, teleconferences and webcasts are held to enable wide access and their recordings are published on the site.

The Company applies a "Quiet Period" to prevent the asymmetric distribution of information and public disclosure before specific information is confirmed. The Quiet Period starts two weeks before the quarterly earnings releases and annual financial reports are announced and ends with the public disclosure of the related financial statements.

When the date of a quarterly earnings release is set before the end of the relevant quarter, a material event disclosure regarding the financial calendar is published and the disclosure date is also announced via the Investor Calendar on the corporate website. Such a disclosure includes information about the dates when a Quiet Period will be in place.

During the Quiet Period, no information about the financial position of the Company, except for the already publicly available information, will be shared. Meeting requests of the analysts, investors and other capital market players regarding the financial situation will not be accepted and their questions on these issues will not be answered. Without prejudice to the applicable CMB regulations, the Quiet Period will not prevent the Company's spokespersons from participating in conferences, forums and panel sessions, giving speeches or making statements provided that they do not contain financial guidance.

Information and Supportive Documents

While aiming to inform investors in the best way possible by using the tools such as presentations, investor bulletins, summary financials, website, annual report, teleconferences, investor meetings, corporate applications on digital platforms, etc., the Investor Relations Department ensures that all these tools are prepared, published and updated in accordance with the legislation.

With the regularly updated website and information notes made available to investors on the website, it is also aimed that capital market participants can closely follow the developments related to Tüpraş and access investor relations tools. Explanations regarding the activity reports and content of the websites are included in the relevant section below.

A list of analysts covering Tüpraş and their contact information are available to investors in the investor relations section of Tüpraş corporate website. Tüpraş has no authority or responsibility to review, verify or approve analyst reports or models.

Information Requests

To ensure that the shareholders, investors, analysts and other capital market participants exercise their right to receive information effectively, the Investor Relations Department responds as soon as possible to any questions, complaints, opinions and suggestions related to or for the evaluation of existing information disclosed to public within the scope of this Policy, received via telephone and e-mail, and ensures that the information in the "Investor Relations" section of the Tüpraş website is disclosed and updated in a timely manner.

Website

The "Investor Relations" section of Tüpraş website is allocated to the financial and nonfinancial information that existing and potential investors and analysts may need in thevaluation of company shares or in the monitoring of the performance of Tüpraş and is actively used in public disclosures. The majority of the information found on the website is prepared in Turkish and English and is always kept up to date.

Management Reporting, Corporate Communications, Investor Relations, Corporate Governance and Information Technologies departments are responsible for coordination of the design and content of the Tüpraş website. The content of the website is prepared in such a way that it may contain various information that all stakeholders can use.

Determination and management of the content in the investor relations section is under the authority and responsibility of the Investor Relations Department. This section is a platform where investors and analysts can monitor the detailed and comprehensive information they will need to evaluate the company and monitor the performance of the company and the share.

In addition to the information and documents envisaged to be included within the scope of investor relations and legal mandatory requirements as per TCC and Corporate Governance Principles, the website also includes the policies and practices of Tüpraş such as"Dividend Policy", "Disclosure Policy", "Remuneration Policy for Members of the Board of Directors and Executive Management" "Board of Directors Diversity Policy" and "Donation and Sponsorship Policy" and "Tüpraş Code of Ethics" as well as analysis and evaluations; historical information and statistics.

3. POLICIES ON MATERIAL EVENT DISCLOSURES

3.1. Responsibility

Chief Financial Officer is authorized and responsible for the fulfilment of the material event disclosure obligation of Tüpraş, Corporate Governance Department and Investor Relations Department and Financial Planning and Reporting Department under the Chief Financial Officer acts in coordination with the relevant departments in the fulfilment of this task.

In principle, material event disclosures are made in Turkish and English via the Public Disclosure Platform (PDP) with the electronic certificates of the General Manager and Chief Financial Officer and are published on the corporate website as well. However, if the electronic certificate of any of the General Manager and Chief Financial Officer cannot be used, it is also possible to use electronic certificates of other authorizeddirectors.

3.2. Persons with Administrative Responsibility

At Tüpraş, list of persons with administrative responsibilities includes members of the Board of Directors of Tüpraş , as well as the persons, who have directly or indirectly regular access to insider information related to Tüpraş and who have the authority to make administrative decisions that affect the future development and commercial objectives of Tüpraş. These persons, who have regular access to information and also have the authority to make administrative decisions, consist of the members of the Board of Directors of the Company and its main shareholder, the General Manager, the Assistant General Managers, Directors directly reporting to the General Manager and the Chief Legal Officer and the senior executives of Koç Holding (CEO, relevant President, Directors, Chief Legal and Compliance Counsel and Secretary General) working at Tüpraş. Introductory information about the persons with administrative responsibility within the company is currently announced on the Tüpraş website in the Board of Directors and Senior Management sections.

3.3. Public Disclosure of Inside Information

For all matters required by the capital market legislation on Tüpraş and for significant changes in the operations or financial, management or capital structures of non-public subsidiaries of Tüpraş, Tüpraş shall immediately make a public disclosure throughthe PDP, except in cases where the public disclosure is postponed. Unless legally mandatory to do so, information disclosed to the public shall not contain information that may adversely impact competitiveness of Tüpraş and damage shareholders and other stakeholders' interests. Trade secrets shall not be disclosed.

The Investor Relations Department and the Corporate Communications Directorate may only make an announcement to the relevant persons and public after the public disclosure at the PDP.

3.4. Ensuring the Confidentiality of Insider Information

Tüpraş employees and other parties in possession of inside information are informed oftheir obligation to keep such information confidential during the occurrence/ the development of the inside information and until its public disclosure in principle in writing or via e-mail.

As a general principle, Tüpraş employees and third parties acting on behalf of Tüpraş shall not share any information, deemed as inside information, which has not yet beendisclosed to the public, with third parties. If the company determines that those who are in possession of inside information disclosed such information to third parties without the prior knowledge of the company, and the confidentiality of information shall no longer be ensured, as per the CMB regulations, the company shall make a material event disclosure.

If the disclosure of information is postponed, persons with access to the subject information at the time of postponement are informed about their obligations and sanctions that may be applicable in case of breach. In addition, any contract entered into with third parties who has/will have access to any inside information shall contain confidentiality provisions to ensure that such parties take the necessary measures to prevent any confidentiality breach.

3.5. Postponement of Public Disclosure of Inside Information

Tüpraş, at its own risk, may postpone the public disclosure of inside information in orderto protect its legitimate interests, as long as this does not cause investors to be misled and it is able to ensure the confidentiality of such information. In this case, Tüpraş shall take all possible measures to ensure the confidentiality of inside information in accordance with the capital market legislation. In cases where no special decision has been taken by the Board of Directors that includes the postponement of information, the General Manager will decide on whether the disclosure of information will be subjectto postponement, by taking the opinions of the Assistant General Manager (Financial) and other Assistant General Managers.

3.6. Fulfilment of Verification Obligation

Tüpraş works with a media-monitoring agency to screen domestic news and content aboutTüpraş appearing in national media, digital and social media platforms. Every morning, Corporate Communications Directorate circulates relevant news to senior executives and all other relevant departments of Tüpraş. In addition, Corporate Communications Directorate follows the news on various channels and circulates the same to the relevant departments of Tüpraş. News appearing in the subscribed data broadcast channel are also followed.

If there are any news or rumours appearing in media etc., that contains information that is either different than what was previously disclosed to the public or makes any information public for the first time, potentially material enough to affect the value of Tüpraş's capital market instruments or the investors' decisions, a disclosure shall be made to confirm the accuracy or deny the relevant news. For such assessment, the following principles, as well as the circulation or level of recognition of such media channel shall be taken into account. The comments, analyses, assessments and estimates based on publicly disclosed information about Tüpraşare not in scope of this obligation).

The following principles apply in fulfilment of the verification obligation by Tüpraş:

• a. If the news is not important enough to be deemed as inside information, in principle, no disclosure is made about the subject. However, Corporate Communications Directorate evaluates whether there is any benefit in organizing a press release on such a subject, which does not require a material event disclosure as per CMB regulations.
• b. If a material event disclosure or any other means of disclosure in accordance with CMB regulations has already been made about the news, no action is taken.
• c. In principle, no comment is made regarding the questions from the media about inside information, the disclosure of which is postponed, or the issues that are not on the company agenda, as well as rumours and news, which are obvious to be unfounded.
• d. In case of inaccurate news or news that contain significant errors or deficiencies, that may be regarded as material information or that may potentially affect the investment decisions or the price of the capital market instruments, a material event disclosure is made about the subject.
• e. If the news published in the press is about a case the public disclosure of which was postponed.
  • If the news contains accurate and important information that may affect the investor's decisions, it is assumed that the reasons for postponement limited to the information in question are no longer valid and, limited to this information, a disclosure is made immediately.
  • If the news contains information that is incorrect, erroneous or has significant deficiencies, a disclosure shall not be made, as there will be no leakage of inside information.
• f. If deemed necessary to protect the interests of Tüpraş and itsinvestors, a material event disclosure may also be made for unsubstantiated news or the issues for which the disclosure is considered useful.

g. Independent of the material events disclosure, if deemed appropriate by the Corporate Communications Directorate, it is possible to make a press release or inform press and public through corporate social media accounts of Tüpraş.

3.7. Public Disclosure of Forward-Looking Statements

Tüpraş can disclose forward-looking statements to the public as per the principles set outin the capital market legislation. For such disclosures, the following principles shall befollowed:

• − Forward-looking statements along with their main underlying assumptions can be disclosed no more than four times within a year, in principle following the disclosure of quarterly financial statements.
• − The disclosure may be disseminated through investor presentations or quarterly activity reports both of which are published on PDP and on the company web site or by means of a material event disclosure if deemed necessary.
• − In the disclosure, it shall be explicitly stated that actual results may differ significantly from the expectations due to possible risks and uncertainties, as well as other factors.
• − If the expectations and assumptions expressed in the forward-looking statements disclosed to the public are not realized significantly or turn out to be impossible to be realized, the revised expectations shall be disclosed to the public through material event disclosures without any limitation in terms of the number of the disclosure.
• − In case of significant differences between the expectations previously announced to the public and the actualizations, the reasons for such differences are also included in the forward-looking statements.
• − Forward-looking statements may include, but are not limited to, production, forecasts of investments,profitability ratios,

4. OTHER PUBLIC DISCLOSURE POLICIES

4.1. Exercise of Shareholder Rights

As per the TCC and the CMB regulations and the Articles of Association of Tüpraş, information and documents such as prospectus, announcement texts, information document about the general assembly, capital increase, dividend payments, and merger and division procedures are disclosed in the PDP within defined periods and shareholders are informed accordingly. In addition to the outletsspecified in the regulations, above listed documentsshallalso be published at www.tupras.com.tr, the same day, to facilitate investors' access.

4.2. Public Disclosure of Financial Statements

The financial statements of Tüpraş are prepared on a consolidated basis in accordance with Turkish Financial Reporting Standards within the framework of the CMB regulations andare disclosed to the public quarterly within the periods determined by the CMB. The annual consolidated financial statements are subject to full scope independent audit and the six-month consolidated financial statements are subject to limited independent audit. The consolidated financial statements and explanatory notes of Tüpraş, in Turkish and English, can be accessed retrospectively on Tüpraş A.Ş website.

Before the disclosure to the public, the consolidated financial statements and explanatory notes are submitted to the Board of Directors for approval together with the opinion of the Audit Committee within the framework of the CMB regulations. After the responsibility statement is signed, the financialstatements, footnotes, and the independent audit report, if any, aredisclosed via the PDP.

In addition to the information disclosed in the consolidated financial statements, additional information such as product margins, capacity utilization rates, production and sales volumes, foreign currency positions and profitability excluding one-offs may be disclosed in the investor presentations prepared for each financial statement period in order to enable investors to perform the analysis they request.

4.3. Public Disclosure of Activity Reports

Tüpraş prepares activity reports for the same periods with its financial statements and discloses them to the public within the defined periods in accordance with the procedures established by the CMB. The contents of the activity report are prepared in accordance with international standards, the TCC, CMB regulations and CMB corporate governance principles.The activity report is prepared by the Corporate Governance Department and submitted to the Board of Directors for approval together with the opinion of the Audit Committee and disclosed to the public afterthe approval of the Board of Directors.

Although in principle the activity report is disclosed to public together with the financial statements of Tüpraş, it may not always be possible to disclose them simultaneously, especially due to the fact that the annual activity report is prepared printed. In this case, the annual activity report is disclosed to public after the financial statements, together with the statement of responsibility in the PDP and on the website of Tüpraş, at least three weeks before the ordinary general assembly and, in any case, within the period determined within theframework of the CMB regulations.

Accessible on the website in Turkish and English, printed copies of the annual activity report can be obtained from the Corporate Governance Department of Tüpraş.

Interim activity reports, prepared quarterly, are disclosed to the public via the PDP and are made available to investors on the company website.

5. AUTHORITY AND RESPONSIBILITY

The Board of Directors is responsible for the preparation, execution, supervision, amendment and disclosure to the public of the Disclosure Policy, in accordance with the relevant legislation, especially the TCC, CMB and BIST regulations.

The Disclosure Policy, which is approved by the Board of Directors is disclosed to the public in Turkish and English on the PDP and on the corporate website. In case of amendments to the Disclosure Policy, the Policy is updated by the Corporate Governance Department under the Assistant General Management (Financial) and submitted to the Board of Directors' approval. The new policy approved by the Board of Directors is disclosed to the public on the PDP and on the corporate website.

Although the Board of Directors of Tüpraş is responsible for the Policy, for execution and implementation of the principles and procedures set out in this Policy, depending on the context, the Investor Relations Department under the Assistant General Management (Financial) and/or the Corporate Communications Directorate of Tüpraş are responsible.

Investors and/or stakeholders may submit their questions, complaints, opinions and suggestions within the scope of this Policy of Tüpraş to the Investor Relations Department.

6. APPROVAL AND AMENDMENT STATUS

This Policy has been approved by the Tüpraş Board of Directors decision dated 15 June 2025 and numbered 22.

With the entry into force of this Policy, the Policies listed in the table below, which have been previously disclosed to the public, are repealed.

Decision of the Board of Directors	Disclosure Date of the
Date	Number	Policy in the PDP
05.04.2010	-	05.04.2010
12.06.2015	11	12.06.2015
13.02.2018	05	13.02.2018
05.05.2021	19	05.05.2021