KAFEİN YAZILIM HİZMETLERİ TİCARET A.Ş.

Environmental & Social Information • Jul 26, 2024

COMMUNICATION ON PROGRESS QUESTIONNAIRE

KAFEIN YAZILIM HIZMETLERI TICARET ANONIM SIRKETI

01.01.2023 - 31.12.2023

Page references are linked to the company's 2023 GRI Sustainability Report.

For access to the report please click here.

GOVERNANCE

Policies and Responsibilities

G1. Does the board/highest governance body or most senior executive of the company: (2021) Linked to: GRI Disclosures 2-12, 2-14, 2-22 (Select apply) all that
Issue an annual statement about the relevance of sustainable development to the company
Issue an annual statement that addresses impacts on both people and the environment
Issue an annual statement highlighting a zero tolerance for corruption
Sign off on organizational sustainability targets
Supervise Environmental, Social, and Governance reporting
Regularly review potential risks related to the business model
None of the above

Please provide additional information: GRI Content Index -SDG Link (p.74-86), Impacts Across the Value Chain (p.56-57), Anti-Bribery and Anti-Corruption (p.66-69), Goals and Progress Chart (p.73) Kafein Sustainability Strategy (p.23), Risks and Conflict of Interest Management (p.16-17)

G2. Does the company have a publicly stated commitment regarding the following sustainability topics?

Linked to: GRI Disclosure 2-23 (2021)

(Select one answer option per line)

	No, this is not a current priority	No, but we plan to within the next two years	Yes, focused on our own operations	Yes, focused on our own operations and suppliers	Yes, focused on our own operations and the value chain (including suppliers, consumers, communities, other business relationships)
Human Rights
Labour Rights/Decent Work
Environment
Anti-Corruption

Please provide a link, upload the document, and/or provide additional information: UNGC Statement of Support (p.6), Sustainability Practices Based on Supply Chain (p.37-38)

G3. Does the company have a code of conduct in place regarding each of the following sustainability topics?

Linked to: NASDAQ G6.1; GRI Disclosure 2-23 (2021) (Select one answer option per line)

	No, this is not a current priority	No, but we plan to within the next two years	Yes, focused on employees	Yes, focused on employees and suppliers	Yes, focused on our own operations and the value chain (including suppliers, consumers, communities, other business relationships)
Human Rights
Labour Rights/Decent Work
Environment
Anti-Corruption

Please provide additional information: Company website (www.kafein.com.tr)- Investor Relations - Corporate Governance - Policies - Ethical Principles and Code of Conduct Policy & Anti Bribery and Anti Corruption Policy

G4. Has the company appointed an individual or group responsible for each of the following sustainability topics?

Linked to: GRI Disclosure 2-13 (2021)

(Select one answer option	per line)
	No one is specifically responsible for this topic	Yes, with limited influence on outcomes (e.g., limited access to internal information, limited decision-making authority)	Yes, with moderate influence on outcomes (e.g., has access to relevant information, reports to senior manager)	Yes, with direct influence of some outcomes (e.g., has access to relevant information, includes one or more senior manager with decision making rights)	Yes, with direct influence at the highest levels of the company (e.g., has access to relevant information, includes most senior members of company)
Human Rights
Labour Rights/Decent Work
Environment
Anti-Corruption

G5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?

Linked to: GRI Disclosures 2-9, 2-13 (2021) (Select one answer option per line)

	No formal structure	Yes, with limited influence on outcomes (e.g., limited access to internal information necessary to understand risks, poor representation from relevant departments or functions)	Yes, with moderate influence on outcomes (e.g., includes representatives of some functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, reports to senior manager)	Yes, with direct influence on some outcomes (e.g., includes representatives of functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, involves one or more members of senior management)	Yes, with direct influence at the highest level of the company (e.g., full access to relevant information, involves members at highest level of company)
Human Rights
Labour Rights/Decent Work
Environment
Anti-Corruption

Please provide additional information: Management Structure and Composition (p.13-14)

Prevention

G6. Does the company have a process(es) to assess risk?

Linked to: GRI Disclosure 205-1 (2016)

(Select one answer option per line)

	No, this is not a current priority	No, but we plan to within the next two years	Yes, related to our own operations	Yes, related to our own operations and suppliers	Yes, related to our own operations and the value chain (including suppliers, consumers, communities, other business relationships)
			[Prompts G6.1]	[Prompts G6.1]	[Prompts G6.1]
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

G6.1 During the assessment of risk, has the company identified those suppliers and/or other business relationships where the risk related to human rights, labour, environment and/or anti-corruption may be particularly severe?

(Select one answer option per line)

	No	Yes
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

Please provide additional information:

G7. Does the company have a due diligence process through which it identifies, prevents, mitigates, and accounts for actual and potential negative impacts on sustainability topics?

Linked to: GRI Disclosures 2-12, 2-23-a-ii, 3-1, 3-3-d (2021) (Select one answer option per line)

	No, this is not a current priority	No, but we plan to within the next two years	Yes, related to our own operations [Prompts G7.1]	Yes, related to our own operations and suppliers [Prompts G7.1]	Yes, related to our own operations and the value chain (including suppliers, consumers, communities, other business relationships) [Prompts G7.1]
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

Please provide additional information: Kafein Sustainability Strategy & Sustainability Topics (p.23-24), Materiality Analysis & Materiality Matrix (p.25-26), Sustainability Management and Responsibility (p.20-21)

G7.1 During the due diligence process, has the company identified those suppliers and/or other business relationships where the risk of adverse impacts on human rights, labour, environment and/or anti-corruption may be particularly severe?

Linked to: GRI Disclosures 2-23-e, 3-1 (2021) (Select one answer option per line)

	No	Yes
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

Please provide additional information:

Concerns and Grievance Mechanisms

G8. Does the company have a process(es) through which members of the company's workforce can raise concerns about the company's conduct on sustainability topics? Linked to: Reporting Guidance on the 10th Principle Against Anti-corruption – B3; GRI Disclosure 2-26 (2021) (Select one answer option per line))

	No, this is not a current priority	No, but we plan to within the next two years	Yes, we have an informal process (e.g., through supervisors, others) [Prompts G8.1]	Yes, we have a formal process [Prompts G8.1]
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

Please provide additional information: Stakeholder Communication and Notification Mechanisms (p.22)

If respondent answers either of the 'Yes' options in G8, the below question will be displayed.

G8.1. Please provide additional detail regarding the process(es) the company has through which members of the company's workforce can raise concerns about the company's conduct.

Linked to: GRI Disclosure 2-26 (2021); WEF Common Metrics (Select one answer option per line)

	No	Yes
Is the process communicated to all employees/workers in local languages
Is the process available to non-employees (e.g., suppliers, consumers, communities, and other business relationships)
Is the process confidential (e.g., whistleblowing process)
Are there processes in place to avoid retaliation
Can concerns be raised about suppliers or other business relationships (e.g., clients, partners, etc.)
Other (Please provide additional information) [If mandatory] yes, makes text box

Please provide additional information: Company website (www.kafein.com.tr) - Investor Relations - Corporate Governance - Policies - Stakeholder Policy & Ethical Principles and Code of Conduct Policy

Lessons

G9. How does the company capture lessons regarding each of the following sustainability topics?

Linked to: GRI Disclosure 3-3-e (2021) (Select one answer option per line)

	No lessons are regularly captured	Conducts investigation/review of incidents as needed	Conducts investigation/review of incidents and changes organizational policies, processes, and practices accordingly	Conducts investigation/review and leverages learnings to influence both internal and external affairs
Human Rights
Labour Rights/Decent Work
Environment
Anti-Corruption

Please provide additional information: Committees Established within the Board of Directors (p.14-16), Compliance with Laws and Regulations (p.71)

Executive Pay

G10. Is executive pay linked to performance on one or more of the following sustainability topics?

Linked to: CDP W6.4 (2022); CDP F4.3a (2022); CDP C1.3a (2022); Nasdaq G3 2335; GRI Disclosure 2-19 (2021); WEF Common Metrics (Select one answer option per line)

	No, this is not a current priority	No, but we plan to within the next two years	Yes
Human Rights
Labour Rights/Decent Work
Environment
Anti-Corruption

Please provide additional information: Company website (www.kafein.com.tr)- Investor Relations - Corporate Governance - Policies - Remuneration and Compensation Policy

Board Composition

G11. Please provide details regarding the company's board/highest governance body:

Linked to: UNCTAD, ISAR D.1.2 (2019), UNCTAD, ISAR D.1.3 (2019); GRI Disclosures 29 (2021), 405-1 (2016) (Percentage & Commentary for each line)

	Number	Not applicable
Total number of board members (#)	6 ____	____
Male (%)	67 ____	____
Female (%)	33 ____	____
Non-binary (%)	0 ____	____
Under 30 years old (%)	0 ____	____
30-50 years old (%)	17 ____	____
Above 50 years old (%)	83 ____	____
From minority or vulnerable groups (%)	0 ____	____
Executive (%)	50 ____	____
Independent (%)	50 ____	____

Please provide additional information: Management Structure and Composition (p.13-14), Management Structure as Gender/Age (p.42)

Data Assurance

G12. Do you produce sustainability reporting according to: Linked to: Nasdaq G9.1 (Select all that apply)

• National/local regulation on sustainability
• Security exchange regulations
• Non-Financial Reporting Directive of the European Union (NFRD)/Corporate Sustainability Reporting Directive (CSRD)
• Global Reporting Initiative (GRI)
• Sustainability Accounting Standards Board (SASB, now consolidated into the IFRS Foundation)
• International Integrated Reporting Council (IIRC, now consolidated into the IFRS Foundation)
• Climate Disclosure Standards Board (CDSB, now consolidated into the IFRS Foundation)
• Task Force on Climate-related Financial Disclosures (TCFD)
• Other voluntary frameworks (Please provide additional information) [Makes text box mandatory]
• No sustainability reporting according to any frameworks nor regulations outside of this Communication on Progress

Please provide additional information: About the Report (p.5)

G13. Is the information disclosed in this questionnaire assured by a third-party?

Linked to: CDP C.10.1 (2022); GRI Disclosure 2-5 (2021) (Select all that apply)

• Limited assurance for minority of metrics (e.g., GHG emissions only)
• Limited assurance for majority of metrics
• Reasonable assurance for minority of metrics
• Reasonable assurance for majority of metrics
• Other (Please provide additional information) [Makes text box mandatory]
• No assurance for any metrics

Please provide additional information: GHG Emissions Only

HUMAN RIGHTS

Materiality

HR1. Which of the following has the company identified as material human rights topics connected with its operations and/or value chain, whether based on their salience (e.g., the most severe potential negative impacts on people) or another basis?

Linked to: GRI Disclosure 3-2 (2021) (Select all that apply)

• Freedom of association and the effective recognition of the right to collective bargaining
• Child labour
• Forced labour
• Non-discrimination in respect of employment and occupation
• Safe and healthy working environment
• Working conditions (wages, working hours) [Prompts additional line 'Working conditions (wages, working hours)' in Questions L1, L2, L3, L4, L5, L12]
• Freedom of expression [Prompts additional line 'Freedom of expression' in Questions HR2–HR7]
• Access to water and sanitation [Prompts additional line 'Access to water and sanitation' in Questions HR2–HR7]
• Digital security/privacy [Prompts additional line 'Digital security/privacy' in Questions HR2–HR7]
• Gender equality and women's rights [Prompts additional line 'Gender equality and women's rights' in Questions HR2–HR7]
• Rights of indigenous peoples [Prompts additional line 'Rights of indigenous peoples' in Questions HR2–HR7]
• Rights of refugees and migrants [Prompts additional line 'Rights of refugees and migrants' in Questions HR2–HR7]
• Other ____________________

Please provide additional information: Kafein Sustainability Topics (p.24)

Note: Labour rights topics (Freedom of association and the effective recognition of the right to collective bargaining, child labour, forced labour, non-discrimination in respect of employment and occupation, and a safe and healthy working environment) are a subset of human rights and for completeness, were included in this question. Regardless of these labour topics being selected as material in this question or not, all companies will be asked to provide additional details about these labour rights topics in the next section (L.1 and following). For the other human rights topics selected as material in this question, seven additional questions will be asked in the following section.

Commitment

HR2. Does the company have a policy commitment in relation to the following human rights topics? Matrix will be populated only for the human rights topics selected in HR1. Linked to: GRI Disclosures 2-23-a-iv, 2-23-b, 3-3-c (2021) (Select one answer option per line)

Human Rights Topics:	No, and we have no plans to develop a policy	No, but we plan to within the next two years	Yes, included within a broader policy or as a stand-alone policy [Prompts HR 2.1]	Please input the year the relevant human rights policy was last reviewed (YYYY)
Digital security/privacy				2023 __
Gender equality and women's rights				2023 __

Please provide a link, upload the document, and/or provide additional information: Personal Data Protection and Privacy Provisions (p.53), Diversity and Equal Opportunity (p. 40-42) If respondent answers 'Yes' in HR2, the below question will be displayed for each relevant topic.

HR2.1. For each human rights policy commitment, is it:

Linked to: GRI Disclosures 2-23-c, 2-23-d, 2-23-e (2021) (Select all that apply for each line)

Human Rights Topics:	Aligned with international human rights standards	Publicly available	Approved at most senior level of the company	Applied to the company's own operations	Applied to the company's own operations and suppliers	Applied to the company's own operations and the value chain (including suppliers, consumers, communities, other business relationships)	Developed involving human rights expertise from inside and outside the company	Other (Please provide additional information) [Makes text box mandatory]
Digital security/privacy
Gender equality and women's rights

Please provide additional information:

Prevention

HR3. Within the reporting period, has the company engaged with potentially affected stakeholders or their legitimate representatives in relation to the following human rights topics? Matrix will be populated only for the human rights topics selected in HR1. Linked to: GRI Disclosures 3-1-b, 3-3-f (2021) (Select one answer option per line)

Human Rights Topics:	No engagement on this topic	To better understand the risks/impacts in question	To discuss potential ways to prevent or mitigate the risks/impacts in question	To agree on a way to prevent/mitigate the risks/impacts in question	To assess progress in preventing/mitigating the risks/impacts in question	To collaborate in the prevention/mitigation of the risks/impacts in question
Digital security/privacy
Gender equality and women's rights

Please provide additional information: Stakeholder Communication and Notification Mechanisms (p.22), Kafein Sustainability Topics (p.24) Materiality Analysis & Materiality Matrix (p.25-26)

HR4. What type of action has the company taken within the reporting period with the aim of preventing/mitigating the risks/impacts associated with the following human rights topics? Matrix will be populated only for the human rights issues selected in HR1. Linked to: GRI Disclosure 3-3-d (2021)

(Select all that apply for each line)

Human Rights Topics:	No action within reporting period	Provided internal training/capacity building for the direct workforce	Built capacity among relevant business relationships (e.g., suppliers, consumers, communities)	Conducted an audit process and/or corrective action plan	Collective action with peers or other stakeholders to address the issue	Collaborated with governmental or regulatory bodies	Other (Please provide additional information) [Makes text box mandatory]
Digital security/privacy
Gender equality and women's rights

Please provide additional information: Sustainability Practices Based on Supply Chain (p.37-38), Education Opportunities at Kafein (p.43-47)

The company is certified by ISO 27001: Information Security Management System. The certification helps organizations secure and manage their and their customers' confidential information. It is an international framework that helps companies protect their financial data, intellectual property and sensitive customer information.

HR5. Who receives training for the following human rights topics? Matrix will be populated only for the human rights topics selected in HR1.

Linked to: GRI Disclosure 3-3-d (2021) (Select all that apply for each line)

Human Rights Topics:	No training provided	Select employees	All employees	Contractors	Direct suppliers	Indirect suppliers	Other – such as partners, clients, etc.
Digital security/privacy
Gender equality and women's rights

Please provide additional information: Kafein Inhouse Trainings & Legally Mandatory Trainings (p.45)

HR6. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following human rights topics? Matrix will be populated only

for the human rights issues selected in HR1. Linked to: GRI Disclosure 3-3-e (2021) (Select one answer option per line)

Human Rights Topics:	No monitoring of progress	Review topics on ad hoc basis	Set annual targets/goals, track progress over time (internal programmes only)	Set annual targets/goals, track progress over time (internal and external programmes)	Other (Please provide additional information) [Makes mandatory] text box
Digital security/privacy
Gender equality and women's rights

Please provide additional information:	Goals and Progress Chart (p.73), Compliance with Laws and Regulations (p.71)
----------------------------------------	------------------------------------------------------------------------------	--

Response

HR7. Within the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to adverse impact(s) associated with the following human rights topic(s)? Matrix will be populated only for the human rights topics selected in HR1.

Linked to: GRI Disclosure 3-3-d-ii (2021) (Select one answer option per line)

Human Rights Topics:	No remedy provided/enabled	Yes, remedy provided/enabled	No adverse impact identified or caused	Choose to not disclose
Digital security/privacy
Gender equality and women's rights

Please provide additional information: ____________________________________________________________________________

HR8. Briefly describe additional relevant, practical actions the company has taken within the reporting period and/or plans to take to implement the human rights principles, including goals set and any challenges faced and actions taken towards prevention and/or remediation. Linked to: GRI Disclosures 3-3-c and 3-3-d (2021)

(Text Box)

Empower: Social Principles (p.39-54)

LABOUR

Commitment

L1. Does the company have a policy commitment in relation to the following labour rights topics? For the user, the "Working conditions (wages, working hours)" option would be visible only if selected in HR1.

Linked to: GRI Disclosure 3-3-c (2021) for topics GRI 407 (2016), GRI 409 (2016), GRI 408 (2016), GRI 406 (2016), GRI 403 (2018) (Select one answer option per line)

Labour Topics:	No, and we have no plans to develop a policy	No, but we plan to within the next two years	Yes, included within a broader policy or as a stand-alone policy [Prompts L1.1; (first L1.2 labour only)] topic	Not applicable (Please provide additional information) [Makes text box mandatory]	Please input the year the relevant labour rights policy was last reviewed (YYYY)
Freedom of association and the effective recognition of the right to collective bargaining					2023 _
Forced labour					2023 _
Child labour					2023 _
Non-discrimination in respect of employment and occupation					2023 _
Safe and healthy working environment					2023 _

Please provide a link, upload the document, and/or provide additional information:

If respondent answers 'Yes' in L1, the below question will be displayed for each relevant topic.

L1.1. For each labour rights policy commitment, is it:

Linked to: ILO C155 - Occupational Safety and Health Convention 1981 (No. 155); GRI Disclosures 2-23-c, 2-23-d, 2-23-e (2021) (Select all that apply for each line)

Labour Topics:	Aligned with international labour standards	Publicly available	Approved at most senior level of the company	Applied to the company's own operations	Applied to the company's own operations and suppliers	Applied to the company's own operations and the value chain (including suppliers, consumers, communities, other business relationships)	Developed in consultation with workers and their representatives	Developed involving labour rights expertise from inside and outside the company	Other (Please provide additional information) [Makes text box mandatory]
Freedom of association and the effective rec ognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Safe and healthy working environment

Please provide additional information:

If respondent answers 'Yes' in L1 regarding 'Freedom of association and the effective recognition of the right to collective bargaining,' the below question will be displayed.

L1.2. Does the company's policy on freedom of association and collective bargaining:

Linked to: GRI Disclosure 2-30 (2021) (Select all that apply)

• Reference the respect for the right of all workers to form and join a trade union of their choice without fear of intimidation or reprisal and protect workers against acts of antiunion discrimination
• Prohibit any acts of interference in trade unions
• Facilitate collective bargaining with the trade union representatives ✓
• Provide trade union representatives with the information required for meaningful bargaining in the context of bona fide negotiations
• Reference the respect for the right of workers to submit grievances without suffering
• We do have a policy on freedom of association or collective bargaining but it does not include any of these details
• We do not have a policy on freedom of association or collective bargaining

Please provide additional information: Freedom of Association and Right to Collective Bargaining (p.52)

Although the company supports the active recognition of freedom of association and the right to collective bargaining, there is no union actively negotiated.

Prevention

L2. Within the reporting period, has the company engaged with potentially affected stakeholders or their legitimate representatives in relation to the following labour rights topics? For the user, the "Working conditions (wages, working hours)" option would be visible only if selected in HR1. Linked to: GRI Disclosures 3-1-b and 3-3-f (2021) for topics GRI 407 (2016), GRI 409 (2016), GRI 408 (2016), GRI 406 (2016), GRI 403 (2018) (Select one answer option per line)

Labour Topics:	No engagement on this topic	To better understand the risks/impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/mitigate the risks/impacts in question	To assess progress in preventing/ mitigating the risks/ impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question	Other (Please provide additional information) [Makes text box mandatory]
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Safe and healthy working environment

Please provide additional information: Stakeholder Communication and Notification Mechanisms (p.22), Materiality Analysis (p.26), Hazard Identification and Risk Assessment (p.51-52)

L3. What type of action has the company taken within the reporting period with the aim of preventing/mitigating the risks/impacts associated with the following labour rights topics? For the user, the "Working conditions (wages, working hours)" option would be visible only if selected in HR1. Linked to: GRI Disclosure 3-3-d (2021) for topics GRI 407 (2016), GRI 409 (2016), GRI 408 (2016), GRI 406 (2016), GRI 403 (2018) (Select all that apply for each line)

No action within reporting period	Provided internal training/ capacity building for the direct workforce	Built capacity among relevant business relationships (e.g., suppliers, consumers, communities)	Conducted an audit process and/or corrective action plan	Collective action with peers or other stakeholders, in particular workers' organizations, to address the issue	Collaborated with governmental or regulatory bodies	Other (Please provide additional information) [Makes text box mandatory]

Please provide additional information: Legally Mandatory Trainings (p.45), OHS Trainings & Hazard Identification and Risk Assessment (p.50-52)

L4. Who receives training for the following labour rights topics? For the user, the "Working conditions (wages, working hours)" option would be visible only if selected in HR1. Linked to: GRI Disclosure 3-3-d (2021) for topics GRI 407 (2016), GRI 409 (2016), GRI 408 (2016), GRI 406 (2016), GRI 403 (2018) (Select all that apply for each line)

Labour Topics:	No training provided	Select employees	All employees	Contractors	Direct suppliers	Indirect suppliers	Other – such as partners, clients, etc.
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Safe and healthy working environment

Please provide additional information:

L5. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights topics? For the user, the "Working conditions (wages, working hours)" option would be visible only if selected in HR1.

Linked to: GRI Disclosure 3-3-e (2021) for topics GRI 407 (2016), GRI 409 (2016), GRI 408 (2016), GRI 406 (2016), GRI 403 (2018) (Select one answer option per line)

Labour Topics:	No monitoring of progress	Review topics on ad hoc basis	Set annual targets/goals, track progress over time (internal programmes only)	Set annual targets/goals, track progress over time (internal and external programmes)	Other (Please provide additional information) [Makes mandatory] text box
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Safe and healthy working environment

Please provide additional information: Goals and Progress Chart (p.73), Compliance with Laws and Regulations (p.71)

Performance

L6. Do(es) the existing collective bargaining agreement(s) provide(s) more favourable rights than those provided in legislation, where appropriate? (Select all that apply)

• Yes, by providing more favourable conditions related to wages
• Yes, by providing more favourable conditions related to working hours
• Yes, by providing more favourable conditions related to health coverage and/or sick leave
• Yes, by providing additional rights not otherwise provided (Please provide additional information) [Makes text box mandatory]
• There is (are) no existing collective bargaining agreement(s) ✓
• No

Please provide additional information: Although there is no Collective Bargaining Agreement, private health insurance is offered to all employees through personnel agreements. By 2023, 97% of personnel are paid above the minimum wage.

L7. Within the reporting period, what was the percentage of women in managerial positions? (%)

Linked to: UNCTAD, ISAR C1.1 (2022) (Text box with option for 'Unknown')

	Percent women (%)	Unknown
Managerial position	__27____

Please provide additional information: Management Structure as Gender/Age (p.42)

L8. What was the average ratio of the basic salary and remuneration of women to men (comparing jobs of equal value) within the reporting period?

Linked to: GRI Disclosure 405-2 (2016) (Text box with option for 'Unknown')

	Salary ratio (%)	Unknown	Choose to not disclose [Makes mandatory] text box
Women/Men (%)	________

Please provide additional information: Remuneration Principles and Compensation Policy (p.69-71)

L9. Within the reporting period, how frequently were workers injured (injuries per hour worked)?

Linked to: ISAR C.4.2; GRI Disclosure 403-9 (2018) (Text box with option for 'Unknown')

	Frequency of injury	Unknown	Choose to not disclose [Makes mandatory] text box
Frequency of injury	0 ________
Please provide additional information: ________________	OHS Indicators Table (p.51-52)

L10. Within the reporting period, what was the company's incident rate (injuries per worker)?

Linked to: ISAR C.4.2; GRI Disclosure 403-9 (2018) (Text box with option for 'Unknown')

	Incident rate	Unknown	Choose to not disclose [Makes mandatory] text box
Incident rate	0 ________

Response and Reporting

L11. Within the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to adverse impact(s) associated with the following labour rights topics? For the user, the "Working conditions (wages, working hours)" option would be visible only if selected in HR1. Linked to: GRI Disclosure 3-3-d-ii (2021) for topics GRI 407 (2016), GRI 409 (2016), GRI 408 (2016), GRI 406 (2016), GRI 403 (2018) (Select one answer option per line)

Labour Topics:	No remedy provided/enabled	Yes, remedy provided/enabled	No adverse impact identified or caused	Choose to not disclose [Makes mandatory] text box
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Safe and healthy working environment (also in note)
Please provide additional information: ________________

L12. Briefly describe additional relevant, practical actions the company has taken within the reporting period and/or plans to take to implement the labour principles, including goals set and any challenges faced and actions taken towards prevention and/or remediation.

Linked to: GRI Disclosures 3-3-c and 3-3-d (2021) for topics GRI 407 (2016), GRI 409 (2016), GRI 408 (2016), GRI 406 (2016), GRI 403 (2018) (Text Box)

Empower: Social Principles (p.39-54)

ENVIRONMENT

Commitment

E1. Does the company have a policy commitment in relation to the following environmental topics?

Linked to: CDP C4.1 2022, CDP F6.1 2022, CDP W6.1 2022, GRI Disclosure 3-3-c (2021) for topics GRI 303 (2018), GRI 304 (2016), GRI 305 (2016), GRI 306 (2020), GRI 302 (2016) (Select one answer option per line)

Environmental Topics:	No, and we have no plans to develop a policy	No, but we plan to within the next two years	Yes, included within a broader policy or as a stand-alone policy [Prompts E1.1]	Not applicable (Please provide additional information) [Makes text box mandatory]	Please input the year the relevant environment policy was last reviewed (YYYY)
Climate change					2024 ______
Water					2024 ______
Oceans					______
Forests/biodiversity/land use					2024 ______
Air pollution					2024 ______
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)					2024 ______
Energy & resource use					2024 ______

Please provide a link, upload the document, and/or provide additional information:

The company has been certified with the ISO 14001 Environmental Management System Standard since 20.09.2022. ISO 14001 standard aims to standardize the damage companies cause to nature to a minimum. Their practices are parallel to meeting regulatory obligations.

If respondent answers 'Yes' in E1, the below question will be displayed for each relevant topic.

E1.1. For each environmental policy commitment, is it:

Linked to: CDP C4.1 2022, CDP F6.1 2022, CDP W6.1 2022; GRI Disclosures 2-23-c, 2-23-d, 2-23-e (2021) (Select all that apply for each line)

Environmental Topics:	Aligned with international environmental standards	Publicly available	Approved at most senior level of the company	Applied to the company's own operations	Applied to the company's own operations and suppliers	Applied to the company's own operations and the value chain (including suppliers, consumers, communities, other business relationships)	Developed involving environmental expertise from inside and outside the company	Other (Please provide additional information) [Makes text box mandatory]
Climate change
Water
Forests/biodiversity/land use
Air pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & resource use

Please provide additional information: ____________________________________________________________________________

Prevention

E2. Within the reporting period, has the company engaged with potentially affected stakeholders or their legitimate representatives in relation to the following environmental topics?

Linked to: GRI Disclosures 3-1-b and 3-3-f (2021) for topics GRI 303 (2018), GRI 304 (2016), GRI 305 (2016), GRI 306 (2020), GRI 302 (2016), and GRI Disclosure 201-2-a-iv (2016) (Select one answer option per line)

Environmental Topics:	No engagement on this topic	To better understand the risks/impacts in question	To discuss potential ways to prevent/mitigate the risks/impacts in question	To agree on a way to prevent/ mitigate the risks/impacts in question	To assess progress in preventing/ mitigating the risks/impacts in question	To collaborate in the prevention/ mitigation of the risks/impacts in question	Other (Please provide additional information) [Makes text box mandatory]
Climate change
Water
Oceans
Forests/biodiversity/land use
Air pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & resource use

Please provide additional information: Environmental/Ecological Risks and Management (p.18), Materiality Analysis & Materiality Matrix (p.25-26), International Standards, Initiatives and Certifications (p.61-64)

E3. What type of action has the company taken within the reporting period with the aim of preventing/mitigating the risks/impacts associated with the following environmental topics?

Linked to: GRI Disclosure 3-3-d (2021) for topics GRI 303 (2018), GRI 304 (2016), GRI 305 (2016), GRI 306 (2020), GRI 302 (2016), and GRI Disclosure 201-2-iv (2016) (Select all that apply for each line)

Environmental Topics:	No action within reporting period	Provided internal training/capacity building for the direct workforce	Built capacity among relevant business relationships (e.g., suppliers, consumers, communities)	Conducted an audit process and/or corrective action plan	Collective action with peers or other stakeholders to address the issue	Collaborated with governmental or regulatory bodies	Other (Please provide additional information) [Makes text box mandatory]
Climate change
Water
Oceans
Forests/biodiversity/land use
Air pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & resource use

Please provide additional information:

In 2022, Kafein Online Training and Development Portal is developed where all employees can access over 2,000 online trainings including environmental, ESG and and sustainability subjects.

The company has ISO 14064-1 Corporate Greenhouse Gas Standard and ISO 5001 Energy Management System Standard since 07.12.2023. The Corporate Greenhouse Gas Standard provides information on the principles and requirements for planning, developing and reporting greenhouse gas inventories within a company. In addition, the Energy Management System Standard ensures that organizations establish the processes and systems necessary to improve energy efficiency, the implementation and sustainability of these processes and systems and it also encourages organizations to effective energy management, cost reduction and environmental awareness.

The company has a commitment to donate at least 1000 sappling on yearly basis to Turkish Foundation for Combating Erosion, Reforestation and Protection of Natural Habitats (TEMA) based on the company's forest positive strategy.

E4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?

Linked to: GRI Disclosure 3-3-e (2021) for topics GRI 303 (2018), GRI 304 (2016), GRI 305 (2016), GRI 306 (2020), GRI 302 (2016), and GRI Disclosure 201-2-a-iv (2016) (Select one answer option per line)

Environmental Topics:	No monitoring of progress	Review topics on ad hoc basis	Set annual targets/goals, track progress over time (internal programmes only) [Prompts E4.2] E4.1;	Set annual targets/goals, track progress over time (internal and external programmes) [Prompts E4.2] E4.1;	Other (Please provide additional information) [Makes text box mandatory]
Climate change
Water
Oceans
Forests/biodiversity/land use
Air pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & resource use

Please provide additional information: Goals and Progress Chart (p.73), Protect: Environmental Principles (p.27-38)

If respondent answers in E4 that they set annual targets, the below question will be displayed for each relevant topic.

E4.1. For each environmental topic for which the company sets timebound goals/targets, what kind of targets has the company set? Linked to: CDP F6.1 2022; GRI Disclosure 3-3-e (2021) for topics GRI 303 (2018), GRI 304 (2016), GRI 305 (2016), GRI 306 (2020), GRI 302 (2016), and GRI Disclosure 201-2-a-iv (2016) (Text box for each line)

Please provide a description of targets (e.g., what is the target, absolute vs. intensity, externally verified, on track, etc.)

Climate change	The target is having lower carbon emissions than the European sverage (1,210 kg Co2e) in terms of carbon footprint per capita. The company continues to comply with the target by having 1,055 kg Co2e/per capita in 2023.
Water	The company aims to increase the capacity, awareness and knowledge of its employees through in-company training/courses on water consumption. It also plans to reduce corporate water consumption with efficient fixtures and consumption practices. We have 7 trainings on "Water" subject in the company's Online Training Portal, including microplastics and protecting our seas. The water consumption started to be measured as of 2023 and is calculated as 48 m³ for the base year. Consumption will be monitored and reported in the future.
Forests/biodiversity/land use	The company has committed to donate 1000 saplings every year as of 2024 withing the scope of the company's Donation and Aid Policy. Pursuant to the Board of Directors Resolution No. 02 dated 22.01.2024, the company donated TRY 75,000 to the Turkish Foundation for Combating Erosion, Reforestation and Protection of Natural Habitats (TEMA)
Air pollution	By 2030, the environmental strategy is to reduce Scope I, Scope II and Scope III emissions by 35% compared to the base year of 2022. Based on the calculations, a total carbon footprint of 263,790 tCO2e for 2023 was found. (2022: 203.762 tCO2e) Due to pandemic, full remote working in the first quarter of 2022 and returning to the office two days a week in the last quarter of 2023 caused a slight increase in corporate carbon footprint. As of 2022,the company has received ISO 14064-1: Corporate Greenhouse Gas certification.
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)	The company transfered all internal process and applications (Administrative and HR affairs, BoD meetings, General Assemblies, etc). which produces significant amount of paper waste into alternative electronic/cloud based platforms or company's online employee portal. Starting by 2024, the company initiated an active waste management process at the source (paper, batteries, glass, electronics etc.) and will report them in the following reporting period. 4.8 tons of domestic solid waste was reported in 2023. (2022:4.8 tons)
Energy & resource use	It is aimed to have saving in the amount of electrical energy (Kwh) spent per square meter. This rate was measured as 124.59 kWh/ m² in 2023, with a 9% saving compared to the previous year. (2022: 135.77 kwh/ m²) Additionally, as of 2022, the company has ISO 5001: Energy Management System certification. Additionally, As of 2022,the company has received ISO 5001: Energy Management System Standard certification.
Please provide additional information: ________________

If respondent answers in E4 that they set annual targets, the below question will be displayed for each relevant topic.

E4.2. For each environmental topic in which the company sets timebound goals/targets, how is progress against goal/target tracked?

Linked to: GRI Disclosure 3-3-e (2021) for topics GRI 303 (2018), GRI 304 (2016), GRI 305 (2016), GRI 306 (2020), GRI 302 (2016), and GRI Disclosure 201-2-a-iv (2016) (Select all that apply for each line)

Environmental Topics:	Progress is reviewed against goals annually or more frequently	Progress is reported internally to the most senior level	Progress is reported externally	Other (Please provide additional information) [Makes mandatory] text box
Climate change
Water
Forests/biodiversity/land use
Air pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & resource use

Please provide additional information: ____________________________________________________________________________

E5. Within the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to adverse impact(s) associated with the following environmental topics?

Linked to: GRI Disclosure 3-3-d-ii (2021) for topics GRI 303 (2018), GRI 304 (2016), GRI 305 (2016), GRI 306 (2020), GRI 302 (2016), and GRI Disclosure 201-2-a-iv (2016) (Select one answer option per line)

Environmental Topics:	No remedy provided/ enabled	Yes, remedy provided/ enabled	No adverse impact identified or caused	Choose to not disclose
Climate change
Water
Oceans
Forests/biodiversity/land use
Air pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & resource use

Please provide additional information: ____________________________________________________________________________

Climate Action

E6. What were the company's gross Scope 1 and/or Scope 2 global greenhouse gas (GHG) emissions within the reporting period? Linked to: CDP C6.1 2022, CDP C6.3 2022; GRI Disclosures 305-1, 305-2 (2016); ISAR B.3.1; ISAR B.3.2 (Select one answer option per line)

	Measured total emissions (tCO2e)	We did not measure our gross emissions (Please information) provide additional [Makes mandatory] text box
Scope 1 emissions	127.623
Scope 2 emissions	136.166

Please provide additional information: Scope I (Direct Emissions) & Scope II (Indirect Emissions) (p.31-32)

E7. What were the company's gross Scope 3 global greenhouse gas (GHG) emissions within the reporting period? Linked to: CDP C6.5 2022; GRI Disclosure 305-3 (2016)

(Radial – Select One)

We measured Scope 3 GHG emissions [Please input the measured tCO2e in the text box below] [Prompts E7.1]

We did not measure Scope 3 GHG emissions

Please provide measured tCO2e and/or additional information: 4.23 tCO2e Scope 3 GHG Emission If respondent answers in E7 that they measure Scope 3 emissions, the below question will be displayed.

E7.1. Which Scope 3 categories are included in the company's Scope 3 emissions calculation?

Linked to: GRI Disclosure 305-3 (2016); CDP C6.5 2022 (Select all that apply)

• Purchased goods and services
• Capital goods
• Fuel- and energy-related activities
• Upstream transportation and distribution
• Waste generated in operations
• Business travel
• Employee commuting
• Upstream leased assets
• Downstream transportation and distribution
• Processing of sold products
• Use of sold products
• End-of-life treatment of sold products
• Downstream leased assets
• Franchises
• Investments
• Other upstream
• Other downstream

Please provide additional information: Scope III (Other Indirect Emissions) (p.32)

E8. What percentage of the company's revenue was invested in R&D of low-carbon products/services within the reporting period?

Linked to: CDP C4.3c 2022; CDP4.2b 2022; (partially linked to) ISAR A.3.3 (Text Box with option for 'Unknown')

	Percent of revenue (%)	Unknown	Not applicable (Please provide additional information) [Makes mandatory] text box
R&D for low-carbon products/services	3.90 ________

Please provide additional information: As of 31.12.2023, the company has reported R&D Expenses of TRY 43,210,566 in areas such as Cyber Security, Robotic Process Automation, GDPR Solutions, E-Health Technologies.

E9. Has the company acted to support climate change adaptation and resilience?

Linked to: GRI Disclosure 201-2-a-iv	(2016)
(Select apply) all that

• We have taken action to increase company-wide resilience to climate change
• We have taken action to increase resilience in our supply chains
• We have taken action to increase resilience in the communities in which we operate
• We have provided funding for climate change adaptation and resilience initiatives and projects
• We have not taken actions to build climate change resilience in the reporting period
• Unknown

Please provide additional information: ____________________________________________________________________________

Energy/Resource Use

E10. Please report the company's renewable energy consumption as a percentage of total energy consumption within the reporting period.

Linked to: ISAR B.5.1; GRI Disclosure 302-1 (2016) (Text Box with option for 'Unknown')

	Percent of total energy consumption (%)	Unknown
Renewable energy consumption/total energy consumption	0 ________

Please provide additional information: No renewable energy consumption within the reporting period.

Technology

E11. What percent of the company's revenue came from low-carbon products/services within the reporting period? If applicable, please give a description of the products/services included in your calculation (e.g., relevant certifications).

Linked to: SASB CG-MR-410a.1a; WEF Common Metrics (Text box with option for 'Unknown' or 'Not applicable')

	Percent of total revenue (%)	Unknown	Not applicable (Please provide additional information) [Makes mandatory] text box
Low-carbon products and services/total revenue for the reporting period	2.3 ____
			TRY 12.838.901 revenue is generated from the Robotic Process Automation(RPA) and TRY 12.648.958 revenue is generated from Weight and Balance Project

Please provide additional information: (a software project that can make more precise weight and balance calculations, save fuel, time and human resources, increase flight safety, and increase data reliability with source system integrations to be used in aircrafts)

Additional Topic-specific Questions

E12. Which of the following has the company identified as material environmental topics connected with its operations and/or value chain (e.g., based on the most severe actual or potential negative impacts on people and/or the environment)? Linked to: GRI Disclosure 3-2 (2021)

(Select all that apply)

• Water [Prompts E13, E14]
• Forests, Biodiversity, and Land use [Prompts E15, E16, E17]
• Air pollution [Prompts E18]
• Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.) [Prompts E19, E20, E21]
• None of the topics have been identified as material by the company

Please provide additional information: _

Additional Topic-specific Questions: Water

E13. Please provide details regarding the company's water withdrawal and consumption (own operations) within the reporting period. Linked to: ISAR B.1.3; CDP W1.2b 2022, CDP W1.2d 2022; SASB CG-HP-140a.1; GRI Disclosures 303-1, 303-3, 303-5 (2018) (Text boxes with option for 'Unknown' or 'Not applicable')

	Known (Volume of water in megaliters)	Unknown	Not applicable (Please provide additional information) [Makes mandatory] text box
Total water withdrawal	_____
Fresh surface water withdrawal:	_____
Groundwater withdrawal:	_____
Brackish surface water/seawater withdrawal:	_____
Produced water withdrawal:	_____
Third-party water withdrawal:	_____
Percentage of water withdrawn in regions with high or extremely high water stress(%):	_____

Please provide additional information: The company is in Technology Development Zone (Technopark) and complies with Technopark legislation regarding common water consumption. Due to presence in the software industry, there is no industrial wastewater generated within the scope of operations or activities. There is no water withdrawn from underground or above ground, recycled, or discharged.

	Known (Volume of water in megaliters)	Unknown	Not applicable (Please provide additional information) [Makes mandatory] text box
Total water consumption	0.048 _____
Fresh surface water consumption:	_____
Groundwater consumption:	_____
Brackish surface water/seawater consumption:	_____
Produced water consumption:	_____
Third-party water consumption:	_____
Percentage of water consumed in regions with high or extremely high water stress (%):	_____

Please provide additional information: ____________________________________________________________________________

E14. Please provide details about the company's water intensity of products in regions with high or extremely high water stress.

Linked to: CDP W1.3 2022; CDP W1.3a 2022 (Text box with option for 'Unknown' or 'Not applicable')

	Unknown	Not applicable (Please provide additional information) [Makes mandatory] text box
Water intensity of products (cubic meter/\$ OR cubic meter/product type):	_____

Please provide additional information: As a software company, no product created by withdrawning water.

Additional Topic-specific Questions: Forests, Biodiversity, and Land Use

E15. Please report the number and area (in hectares) of sites owned, leased, or managed by the company in or adjacent to protected areas and/or key biodiversity areas (KBA).

Linked to: GRI Disclosure 304-1 (2016); ISAR B6.1, WEF Common Metrics (Text box with option for 'Unknown' or 'Not applicable')

	Unknown	Not applicable (Please provide additional information) [Makes mandatory] text box
Sites	________
Hectares	________

Please provide additional information: No area in or adjacent to protected/biodiversity areas.

E16. In hectares, please report the area of natural ecosystems converted in areas owned, leased, or managed by the company (if any) within the reporting period.

Linked to: CDP F1.3 2022; GRI Disclosure 304-1 (2016) (Text box with option for 'Unknown' or 'Not applicable')

	Area (hectares)	Unknown	Not applicable (Please provide additional information) [Makes mandatory] text box
Conversion of natural ecosystems	________

Please provide additional information: No area of natural ecosystems converted in areas owned, leased or managed by the company.

E17. Is the company supporting or implementing project(s) focused on ecosystem restoration and protection?

Linked to: CDP F6.11 2022; GRI Disclosure 304-3 (2016) (Select one answer option per line + text box)

	No	No, but we plan to within the next 2 years	Yes	If yes, project(s) area to date (hectares)
Forest ecosystem restoration				______
Other ecosystem restoration				______
Reforestation				3 ______
Natural regeneration				______
Agroforestry				______
Set-aside land				______
Biodiversity offsetting				______
Other (Please provide additional information)				______

Please provide additional information: The company adopt a commitment to donate 1000 sapling every year to combat with deforesting. (The calculation was made with the assumption of planting 300-350 saplings covers 1 hectare area.)

Additional Topic-specific Questions: Air Pollution

E18. Where applicable, please report the company's emissions of the following pollutants within the reporting period.

Linked to: GRI Disclosure 305-7 (2016); ISAR B.3.1 (Text box with option for 'Unknown' or 'Not applicable')

Air pollutant:	Emissions (t)	Unknown	Not applicable (Please provide additional information) [Makes mandatory] text box
NOx	0 ________
SOx	0 ________
Volatile organic compounds (VOCs)	0 ________
Hazardous air pollutants (HAPs)	0 ________
Particulate matter (PM10)	0 ________
Persistent organic pollutants (POPs)	0 ________
Other (Please provide additional information)	0 ________

Apart from the Scope I,II,III emissions, the company does not emit greenhouse gases (GHG), ozone depleting substances (ODS), nitrogen oxides (NO) and sulfur oxides (SO) within the scope of its activities. Please provide additional information:

Total Carbon Footprint (p.32-33)

Additional Topic-specific Questions: Waste

E19. In metric tonnes, please report the company's total weight of waste generated within the reporting period.

Linked to: GRI Disclosure 306-3 (2020); (partially linked to) ISAR B.2.1 (Text box with option for 'Unknown' or 'Not applicable')

	Waste generated (t)	Unknown	Not applicable (Please provide additional information) [Makes mandatory] text box
Solid waste	11.4 ________

Please provide additional information:

E20. Please report the company's hazardous waste as a percentage of total waste (e.g., hazardous waste ratio) generated within the reporting period.

Linked to: GRI Disclosures 306-4, 306-5 (2020); ISAR B.2.3 (Text box with option for 'Unknown' or 'Not applicable')

	Hazardous waste ratio (%)	Unknown	Not applicable (Please provide additional information) [Makes mandatory] text box
Hazardous waste	0 ________

Please provide additional information: No hazardous (flammable, combustible, corrosive, reactive, toxic, etc.) waste generated within the reporting period. E21. In metric tonnes, please report the company's estimated consumption of single-use plastic, wherever material along the value chain, within the reporting period.

Linked to: WEF Common Metrics

(Text box with option for 'Unknown' or 'Not applicable')

	Single-use plastic (t)	Unknown	Not applicable (Please provide additional information) [Makes mandatory] text box
Single-use plastics	________
	Please provide additional information: ________________

Overall Environment

E22. Briefly describe additional relevant, practical actions the company has taken within the reporting period and/or plans to take to implement the environment principles, including goals set and any challenges faced and actions taken towards prevention and/or remediation.

Linked to: GRI Disclosures 3-3-c and 3-3-d (2021) for topics GRI 303 (2018), GRI 304 (2016), GRI 305 (2016), GRI 306 (2020), GRI 302 (2016) (Text Box)

Protect: Environmental Practices (p.27-38)

ANTI-CORRUPTION

Commitment

AC1. Does the company have an anti-corruption compliance programme?

Linked to: GRI Disclosure 3-3-c (2021) for the topic GRI 205 (2016) (Radial – Select One)

No, this is not a current priority

No, but we plan to within the next two years

Yes [Prompts AC1.1]

Please provide additional information: ____________________________________________________________________________ Company website (www.kafein.com.tr)- Investor Relations - Corporate Governance - Policies - Anti Bribery and Anti Corruption Policy

If respondent answers 'Yes' in AC1, the below question will be displayed.

AC1.1. If yes, in what year was this programme last reviewed? (YYYY)

____________________________________________________________________________ 2022

Please provide additional information: ____________________________________________________________________________

AC2. Does the company have policies and recommendations for employee procedures in case of doubt and/or in situations that may represent a conflict of interest, e.g. with regard to gifts and hospitality, donations, sponsorship, or interactions with public officials? (Radial – Select One)

No, and we have no plans to develop any policy/recommendation

No, but we plan to within the next two years

Yes, included within a broader policy or as a stand-alone policy

Please provide a link, upload the document, and/or provide additional information: ____________________________________________________________________________

Prevention

AC3. Who receives training on anti-corruption and integrity?

Linked to: WEF Common Metrics; GRI Disclosure 205-2 (2016) (Select all that apply)

• Select employees [Prompts AC3.1]
• All employees [Prompts AC3.1]
• Contractors [Prompts AC3.1]
• Direct suppliers [Prompts AC3.1]
• Indirect suppliers [Prompts AC3.1]
• Other such as partners, clients, etc. [Prompts AC3.1]
• No training provided

Please provide additional information: ____________________________________________________________________________

If respondent answers any option in AC3 besides 'No training provided', the below question will be displayed for each chosen category.

AC3.1. How often is such training provided?

(Select one answer option per line)

	One time only	Every two or more years	Every year	Unknown
All employees

Please provide additional information:

ISO 370001 Anti-Bribery and Anti-Corruption Training is a mandotary training for all employees. A total of 384 personnel participated in the training for 2023, and the total training hours were 76.

AC4. Does the company monitor its anti-corruption compliance programme?

Linked to: GRI Disclosure 3-3-e (2021) for the topic GRI 205 (2016); SDG Action Manager - SDG 16: Peace, Justice, and Strong Institutions (Select all that apply)

• Yes, through review on ad hoc basis
• Yes, through internal employee self-evaluations
• Yes, through automated controls monitoring
• Yes, through external independent monitoring
• Yes, through other mechanisms (Please provide additional information) [Makes text box mandatory]
• No, we do not monitor the anti-corruption compliance programme (Please provide additional information) [Makes text box mandatory]

Please provide additional information: Since 2019, the company is certified with ISO 37001: Anti-Corruption Management Systems which specifies requirements and provides guidance for the establishment, implementation, maintenance, review and improvement of an anti-corruption management system.

Performance

AC5. Please report the company's total number and nature of incidents of corruption within the reporting period.

Linked to: GRI Disclosure 205-3 (2016); WEF Common Metrics ; ISAR D.2.1 (Select one answer option per line)

	Number of incident(s) (Please describe the nature of the incidents in the text box below)	Unknown	Choose to not disclose
Confirmed within the reporting period, but related to previous years	0 ____
Confirmed within the reporting period, and related to the reporting period	0 ____

Please provide additional information: Compliance Indicators (p.71)

Response and Reporting

AC6. Within the reporting period, what actions has the company taken to address suspected incidents of corruption?

Linked to: GRI Disclosure 3-3-d (2021) for the topic GRI 205 (2016); Reporting Guidance on the10th Principle Against Anti-corruption – B3; ISAR D.2.1 (Select all that apply)

• Initial case assessment
• Internal investigation
• Review by risk/ethics committee
• Review by board of directors
• External audit/review
• Other (Please provide additional information) [Makes text box mandatory]
• ✓ Not applicable/no incidents in the reporting period

AC7. Does the company engage in collective action against corruption?

Linked to: GRI Disclosure 3-3-d (2021) for the topic GRI 205 (2016) (Radial – Select one)

• No, this is not a current priority
• No, but we plan to within the next two years
• Yes (Please provide additional information) [Makes text box mandatory]

Please provide additional information: ____________________________________________________________________________

AC8. Briefly describe additional relevant, practical actions the company has taken within the reporting period and/or plans to implement the anti-corruption principle, including goals set and any challenges faced and actions taken towards prevention and/or remediation.

Linked to: GRI Disclosures 3-3-c and 3-3-d (2021) for the topic GRI 205 (2016) (Text Box)

Comply: Corporate Governance (p.66-72)