EN

Code of Ethics

REYSAŞ REAL ESTATE INVESTMENT COMPANY INC.
DISCLOSURE POLICY

Purpose

The primary public disclosure policy of Reysaş Real Estate Investment Company Inc. (Reysaş REIC) is to ensure the full, fair, accurate, timely, and understandable disclosure of the Company’s past performance and future expectations within the framework of generally accepted accounting principles and Capital Markets Legislation to shareholders, investors, and capital market professionals (collectively, capital market participants) equally, while maintaining active and transparent communication at all times. Reysaş REIC believes that sharing its strategies, critical elements, risks, and growth opportunities regarding its operations with the public — excluding trade secrets — will contribute to creating a more efficient market for its capital market instruments.

Reysaş REIC complies with the Capital Markets Legislation regarding public disclosure, including the regulations of the Capital Markets Board (CMB) and Borsa Istanbul (BIST); and pays utmost attention to implementing the principles stipulated in the CMB’s Corporate Governance Principles.
This Disclosure Policy has been prepared in accordance with Section II/Article 1.2 of the CMB’s Corporate Governance Principles and has been approved by the Board of Directors.

Scope

This Disclosure Policy covers all affiliated companies and employees of Reysaş REIC, as well as its consultants, and regulates written and verbal communication with capital market participants.

Responsibility

The Board of Directors is responsible for monitoring, reviewing, and improving the Disclosure Policy.
The Capital Markets and Corporate Governance Coordination Unit has been assigned to oversee and monitor all matters related to public disclosure.

Public Disclosure Methods and Tools

Without prejudice to the provisions of the Capital Markets Legislation and the Turkish Commercial Code (TCC), the main public disclosure methods and tools used by Reysaş REIC are as follows:

  • Material event disclosures sent to BIST via fax (in practice, disclosures are made electronically through the Public Disclosure Platform (KAP) within the legal time frame),

  • Periodically submitted financial statements and footnotes, independent audit reports, declarations, and annual reports sent to BIST in a sealed envelope (also disclosed electronically via KAP within the legal timeframe),

  • Announcements and notices published in the Turkish Trade Registry Gazette and in daily local or national newspapers (prospectus, circulars, ordinary/extraordinary general assembly meeting calls, etc.),

  • Statements made through written and visual media,

  • Disclosures made to data distribution agencies such as Reuters, Foreks, Euroline, etc.,

  • Informative meetings and interviews held in person or via teleconference with capital market participants,

  • Corporate Website (www.reysasgyo.com.tr),

  • Communication tools and technologies such as telephone, mobile phone, e-mail, fax, etc.

Disclosure of Financial Statements and Authorized Persons

Reysaş REIC’s financial statements and footnotes are prepared in accordance with the Capital Markets Legislation and International Financial Reporting Standards (IFRS); audited in accordance with International Auditing Standards (IAS); and publicly disclosed.
Before public disclosure, financial statements and footnotes are approved by the Board of Directors with the favorable opinion of the Audit Committee. They are signed for accuracy by the Chief Financial Officer and the Chairman of the Board.
Following Board approval, these documents are submitted to BIST in a sealed envelope in line with CMB and BIST regulations and disclosed electronically via KAP within the required timeframe.

Disclosure of the Annual Report and Authorized Persons

The annual report is prepared in accordance with the Capital Markets Legislation and the CMB’s Corporate Governance Principles, approved by the Board of Directors, and submitted to BIST in a sealed envelope, in compliance with CMB and BIST regulations. It is also made publicly available via the Company’s website (www.reysasgyo.com.tr). Investors may also obtain the report from the Company’s Investor Relations Department.

Disclosure of Material Events and Authorized Persons

Material event disclosures of Reysaş REIC and its publicly traded subsidiaries are prepared under the supervision of the Capital Markets and Corporate Governance Coordination Unit and are signed electronically by authorized signatories and disclosed via KAP within the legal timeframe.

Other Disclosures and Authorized Persons

Other disclosures (such as prospectuses and circulars) are signed and disclosed within the authority defined in the Company’s signature circular.

Persons Authorized to Make Public Disclosures

Except for the disclosures mentioned above, written and verbal information requests from capital market participants are responded to by the Chief Financial Officer, Investor Relations Unit, or the Capital Markets and Corporate Governance Coordination Unit, within their defined authority.
Unless specifically authorized, Reysaş REIC employees may not respond to questions from capital market participants. Such inquiries are redirected to the Investor Relations Unit.

Communication with Capital Market Participants

Reysaş REIC does not provide guidance on interim or annual results. Instead, the Company shares with capital market participants significant matters affecting performance, strategic approaches, and key elements that support understanding of the sector.

Unless otherwise stated in this Disclosure Policy, only persons authorized to make public disclosures may communicate on behalf of Reysaş REIC and its subsidiaries (whether listed or unlisted).
The Investor Relations Coordination Unit attends all meetings with capital market participants. In private interviews, no undisclosed or material information is shared.

Meetings and Phone Conversations

No new or updated information will be provided in individual or group meetings conducted via phone or face-to-face with capital market participants, and no undisclosed or material information will be disclosed.

Presentations and/or Speeches

Reysaş REIC announces presentations, teleconferences, or speeches intended for capital market participants in advance when possible. Prepared presentations and/or informative documents are published on the corporate website (www.reysasgyo.com.tr).

Meetings Following the Disclosure of Financial Statements

Reysaş REIC is aware that meetings with capital market participants may be held via phone or teleconference after the release of financial results.
The Company endeavors to provide simultaneous online access to such meetings. Key outcomes from these meetings are published on the Company’s website (www.reysasgyo.com.tr).

Market Rumors and Unfounded News

When it is learned that unfounded rumors or speculative news are circulating in the market, persons authorized to make public disclosures may make a press statement regarding such rumors.
However, without a confirmation request from the CMB or BIST, or unless the Board deems it necessary or appropriate, no statement may be made on such rumors in accordance with the Capital Markets Legislation.

Disclosure of Expectations

In line with its Disclosure Policy, Reysaş REIC may, from time to time, disclose its expectations. These written documents clearly indicate that various risks, uncertainties, and other factors may cause actual results to differ materially.
Expectations are communicated only during previously scheduled meetings or events, and solely by persons authorized to make public disclosures.
If it becomes evident that disclosed estimates or assumptions will not materialize, revised information and documents are disclosed immediately with explanations.

Analyst Reports

Reysaş REIC considers analyst reports as the property of the respective analyst firm and does not publish them on its website (www.reysasgyo.com.tr).
The Company does not review, verify, approve, take responsibility for, or disseminate analyst reports or earnings models.
However, in certain limited cases, and upon request, the Company may review such reports only to avoid public misinformation, using only publicly disclosed and historical data, and limited to specific topics.

Reysaş REIC Website (www.reysasgyo.com.tr)

In line with the CMB Corporate Governance Principles, Reysaş REIC actively uses its website (www.reysasgyo.com.tr) for public disclosure.
However, disclosures on the website do not replace the public disclosures and material event announcements required under Capital Markets Legislation.
Access to all public disclosures made by the Company is provided through the website, which is structured accordingly.
All necessary measures are taken to ensure website security.
Special emphasis is given to including information on general assembly meetings, agenda items, explanatory documents, related reports, and procedures for participation.
Continuous efforts are made to improve the website.