Code of Ethics

TAV Airports Holding's Code of Ethics sets out the rules and principles that all executives and employees are obligated to comply with in order to contribute financial value to its shareholders and to enhance its corporate value. With this Code of Ethics, an attempt is made to ensure that the conduct of TAV executives and employees are of the highest standards and that they are aware of the impact of their conduct and attitudes on the Company. Furthermore, the Code ensures that ethics of the highest standard are displayed and best methods are employed regarding Company activities and shareholders.

The Company has publicly announced the Code of Ethics on the TAV Corporate Intranet within the framework of its disclosure policy, published it on the Company's Intranet, and shared it with its employees in the programs that have been prepared for them.

Conflicts of Interest

Conflict of interest is created when the private interests of the employee and the interests of the company are in conflict, or in case there is a potential for such conflict. While undertaking their corporate responsibilities, TAV Airports Holding employees are expected to hold the corporate interest above their own interests and the interests of their families and acquaintances, and thus carry out their responsibilities.

The employees are to avoid any attempts which may be construed as pursuing the interests of their own or those of acquaintances.

Situations Causing Conflicts of Interest

While carrying out their duties, employees are responsible for protecting the interests of the company.

Circumstances given below are considered as conflict of interests:

• Commercial relationships between family members or up to third degree relatives of employees and the company,
• Property or interest relationships between family members, up to third degree relatives of employees or the competitors,
• Business relationships with companies that family members and up to third degree relatives work in,
• Borrowing from companies with which there are business relations or entering into commercial relationships.
  
  

Preventing conflicts of interest

Possible conflicts of interest as well as cases defined by the company management are declared to the employees and the company management takes the necessary precautions. Managers and employees are obliged to inform the management about the observed conflicts of interest. After the identification of such an incident, the Corporate Governance Committee evaluates the matter and takes the necessary actions.

Responsibility to take care in the performance of duties

Employees are obliged to meticulously carry out the duties they have undertaken through employment contracts. They are also obliged to take action to acquire/develop the qualifications and the knowledge required by their duties. They are responsible for the damages inflicted on the company intentionally, due to negligence and carelessness.

The employees are responsible for delegating the works assigned to them to their subordinates, and to ensure timely completion, carrying out the instructions issued by their executives.

All employees must be aware of the fact that they represent the company, and they are obliged to protect the reputation of the company towards third parties.

They are obliged to abstain from behaviors and actions which may lead to difficulties for the company. All employees are obliged to manage their relations with other employees, shareholders and stakeholders in compliance with the code of ethics.

No employee may gain interest from third parties or authorities in relation with his/her job, establish private business relations, nor request or make payments.

Confidentiality and Responsibility to Keep Secrets

All employees, regardless of whether it is related to their duties or not, are obliged to keep the information and trade secrets they have acquired regarding the Company. This liability continues even after the termination of their relationship with the Company.

The Responsibility to Protect the Company Interests

Employees are responsible for protecting the interests of the Company and the work place and must abstain from all conduct that may damage these. The employees may not utilize company means for their personal interests.

Prohibition of working in another job

Employees are not allowed to work in or accept any formal/private, permanent/temporary, and paid/no charge job or to carry on a business without the permission of the company.

Responsibility to declare personal information and revisions

Employees are obliged to declare all revisions concerning the family, civil status and addresses, as well as information about the personal details, family or acquaintance details taken as the basis for the rights and liabilities governed by the contracts and/or regulations; and the documentation which is the basis for such information, to the Personnel Directorate in a timely manner.