1. PURPOSE

The purpose of this plan is to determine the conditions, methods, and procedures under which ED Capital Portfolio Management Inc. (“Company”) will fulfill its obligations to its personnel, customers, intermediary institutions, market participants, shareholders, and third parties in emergency and unforeseen situations.

In the event that critical processes are interrupted due to a reason falling within the scope of an Extraordinary Situation, this plan aims to define the necessary organization, operations, and procedures to ensure that such processes are sufficiently carried out at ED Capital Portfolio Management Inc.’s alternative working location (Extraordinary Situation Center), thereby enabling the continuation of services as soon as possible and minimizing data losses.

The Extraordinary Situation Plan also defines the roles and responsibilities of ED Capital Portfolio Management Inc. employees who are responsible for implementing this Plan.

2. DEFINITION OF EMERGENCY AND UNFORESEEN SITUATIONS

Emergency and unforeseen situations that may disrupt the Company’s normal operations and/or prevent the provision of services are defined as follows, without limitation:

• Natural Disasters (Earthquake, Fire, Storm, Flood, etc.)
• Unforeseen incidents occurring in the building where operations are carried out (fire, explosion, flooding, etc.)
• Terrorist Attacks, War, Civil Unrest, etc.
• Failure of the Company’s information technology systems, external attacks on the Company’s systems (unauthorized and malicious access, viruses, cyber-attacks, etc.)
• Inability of a large portion of personnel to attend work due to illness, strikes, traffic accidents, etc.
• Extraordinary conditions in money markets preventing transactions in money and capital markets and disrupting collection and payment systems.

Within the scope of emergency and unforeseen situations, information technology systems refer to the systems that enable the Company to carry out its activities normally, transmit and execute client orders, perform clearing and custody operations, and store and monitor client accounts.

3. EMERGENCY AND UNFORESEEN SITUATION COMMITTEE

All Company personnel are obliged to know and implement the regulations mentioned in this procedure and the provisions set forth in the Capital Markets Board’s Communiqué on Principles Regarding Portfolio Management Companies and Their Activities (III-55.1).

Senior management is primarily responsible for fulfilling the duties assigned to them under this plan and for making the necessary preparations in advance.

In order to effectively implement the Emergency and Unforeseen Situation Plan, an Emergency and Unforeseen Situation Committee is established, hereinafter referred to as the “EUSC.”

The Committee convenes at least once a year to review actions taken and developments related to emergency and unforeseen situations within the Company. Upon the call of the Chairman, the Committee may also convene without waiting for the regular meeting date. The Committee is authorized to determine the severity of the emergency and unforeseen situation, recall personnel from leave, make temporary assignments, and take decisions aimed at maintaining the Company’s routine operations.

In cases where:

A – The working environment becomes unusable, continuity of information technology systems cannot be ensured, or a long period is required to remedy damage to the working environment and/or information systems,

B – The working environment is physically intact but systems function improperly for a short period (less than two days),

the Committee’s primary duty is to determine whether the disruptions in information technology systems fall under situation A or B and to take the measures specified in the Emergency and Unforeseen Situation Plan.

4. EMERGENCY AND UNFORESEEN SITUATION WORKFLOW

I. Storage of all records and valuable documents required to be kept under financial statements and current legislation, in printed and/or electronic form in accordance with Article 82 of the Turkish Commercial Code

All records and valuable documents are stored in printed form in the Company’s archive. Valuable documents not sent to the archive are kept in fireproof cabinets within the Company. All documents are stored electronically on an up-to-date basis, and copies of customer agreements and approved instructions are also kept at the Custodian Institution. In all cases, storage is carried out in compliance with capital markets legislation and the provisions of the Turkish Commercial Code.

II. Ensuring the continuity of information technology systems to enable uninterrupted operations, taking backups, and storing such electronic record backups for a period of 5 years

At the alternative working center designated for emergency and unforeseen situations, two computers have been installed for Company use. Data providers (Reuters, Bloomberg, Matriks) have been set up, and all necessary office software and information access systems required to maintain operations have been installed. Telephones, fax machines, printers, and other technical equipment required for operational continuity are ready for use.

Data of critical systems and applications are backed up and stored in a secure and protected environment located at a sufficient distance so as not to be affected by the same Extraordinary Situation causing the interruption. In the event of disruption of existing systems, continuity of operations will be ensured through backup systems.

All Company records are stored by the Information Technology Department in accordance with storage principles established under the emergency and unforeseen situation plan, and electronic record backups are retained for 5 years.

III. Operational risk assessment, including financial and information communication infrastructure

Considering operational risks, it is observed that there is no significant risk that would prevent Company operations due to the infrastructure established under Article 4-II. In emergency and unforeseen situations, a sufficient number of qualified personnel will be employed at alternative locations to carry out operations and ensure smooth functioning.

IV. Alternative Communication Channels

a) Provision (ensuring operability) and continuity of communication channels with customers

In the event of an emergency and unforeseen situation, the Emergency and Unforeseen Situation Committee (EUSC) examines the operability of the Company’s communication channels (telephone, fax, and electronic means) and determines which channels are open or closed. A member designated by the EUSC informs customers, using available communication channels and mobile (GSM) phones, about which channels they can use to reach the Company.

If all communication channels (telephone, electronic means, fax) are closed, customers are contacted via mobile phones and informed of the available communication channels.

Communication will be ensured through communication tools allocated for Company use at the alternative working center. Additionally, continuity of communication with customers receiving portfolio management services is ensured through the custodian institution where their accounts are held.

b) Provision (operability) and continuity of alternative communication channels with Company employees

The content of the Emergency and Unforeseen Situation Plan and the roles and responsibilities of team members have been shared with all Company employees. The plan has been distributed to all personnel, and signatures have been obtained confirming that it has been read and understood. It is assumed that, in the event of an Extraordinary Situation, a sufficient number of knowledgeable personnel will be available to implement the plan.

In an emergency and unforeseen situation, Company emergency coordinators communicate with Company personnel regarding the situation. Access of responsible persons to alternative working locations is arranged as follows:

1. Arrangements regarding access of responsible persons to alternative working locations in emergency and unforeseen situations are as follows:

• In situations occurring during working hours, suitable transportation will be provided to the relevant persons by the unit manager with the support of the Operations Department.
• In situations occurring outside working hours, members of the EUSC team are responsible for arranging their own transportation.
• Team members responsible for implementing the emergency and unforeseen situation plan have been informed of communication details.
• Relevant personnel will convene at alternative working locations within 2 hours from the announcement of an Extraordinary Situation decision to continue critical business processes.
• It is planned that critical system applications will be made ready within 2 hours following the Extraordinary Situation decision.

Ensuring uninterrupted continuation of Company operations

Backups have been taken to ensure continuity of information technology systems for uninterrupted operations, and electronic record backups are stored for five years.

Critical business processes and functions have been identified to cover all Company units. Systems and workflows enabling customer portfolio transactions (such as daily portfolio and cash flow planning) as well as clearing and custody operations have been prepared and backed up to meet critical functions.

An alternative working area has been designated for emergency and unforeseen situations. Necessary hardware and software to ensure continuity of operations are ready for use at the alternative working area. Data transmission services have been established, and all required office programs and information access systems have been installed. Telephones, fax machines, printers, and similar technical equipment required for operational continuity are ready for use.

System and data record backups are taken regularly. Data of critical systems and applications are stored in a secure and protected environment at a sufficient distance not affected by the Emergency and Unforeseen Situation causing the interruption, in accordance with the provisions of the Turkish Commercial Code and specific Capital Markets Board regulations.

V. Alternative Company Center

In the event that the Company’s primary workplace becomes unusable, the alternative working center where services will continue has been designated as Kızılay Neighborhood, Şehit Adem Yavuz Street No: 11/5, Çankaya, ANKARA. All necessary preparations and arrangements have been completed at the alternative working center to enable the Company to continue its operations.

If it is also not possible to continue services at this location, the EUSC will determine the most suitable location for service provision and promptly inform personnel, customers, and other relevant parties.

VI. Evaluation of possible effects of the emergency and unforeseen situation on counterparties and efforts to minimize such effects

Since customer assets (cash and capital market instruments) are held at the custodian institution, there is no risk of loss of customer assets due to emergency and unforeseen situations.

However, if communication with customers is completely disrupted and cannot be restored through alternative means, or if operational transactions cannot be carried out despite communication being established, services provided to customers may not be fulfilled. Necessary centralized organization has been established under this emergency and unforeseen situation plan to ensure that customers, third parties, and public institutions are not adversely affected.

VII. Informing the Capital Markets Board (the “Board”) about measures taken and determining how routine mandatory notifications will be made

In emergency and unforeseen situations, the Emergency and Unforeseen Situation Committee (EUSC) has been established to coordinate and monitor all operations (see Article 3). This team includes Company senior management and department representatives. In the absence of members, instructions of the most authorized available member/senior manager will be followed. A member appointed by this team will activate stored Company records and establish communication with customers. Relevant public institutions such as the Capital Markets Board, Borsa İstanbul A.Ş., Istanbul Clearing and Custody Bank Inc. (Takasbank), Central Registry Agency Inc. (MKK), etc., will be contacted.

The meeting point designated by the most authorized member is the alternative working center. The coordination team will proceed, as conditions allow, to ED Capital Portfolio Management Inc.’s relevant center located at Kızılay Neighborhood, Şehit Adem Yavuz Street No: 11/5, Çankaya, ANKARA.

Routine notifications will be completed within the required periods by authorized and mutually back-up personnel in the relevant departments, in accordance with the instructions and guidelines of the emergency coordinator. The main center for mandatory notifications is ED Capital Portfolio Management Inc.’s address at Kızılay Neighborhood, Şehit Adem Yavuz Street No: 11/5, Çankaya, ANKARA and the relevant telephone number.

VIII. Customer access to accounts and transfer of such accounts to another company if a decision is made that operations cannot be continued

Thanks to all measures taken and the established infrastructure, continuity of operations has been planned and tested. Since customer assets are held at the Custodian Institution independently of the Company, no risk is foreseen.

In Extraordinary Situations, contracted suppliers and support service companies will be able to provide services under the terms specified in their agreements.

If the Board of Directors decides that the Company cannot continue its operations due to an emergency and unforeseen situation, customers will be informed, and necessary procedures for the transfer of customer assets will be carried out with customer approval.

IX. Establishment of workflow procedures and internal control mechanisms for outsourced services

Workflow procedures and necessary internal control mechanisms have been established for outsourced services. Supplier selection emphasizes the existence of an infrastructure and communication network capable of providing services during Emergency and Unforeseen Situations. Additionally, business continuity management plans will be obtained from outsourced service providers and incorporated into our plans. Outsourced services are carried out under agreements confirming that the service provider has adequate technical equipment, infrastructure, financial strength, experience, expertise, and human resources to deliver services at the required quality, as well as an action plan to be implemented in case of service interruption or disruption.

In the event of interruption or disruption of outsourced services, the service provider is expected to provide detailed information on the duration of the interruption and to take action in accordance with its own emergency plan.

5. LEGAL BASIS

This Plan has been prepared in accordance with the provisions of the Capital Markets Board’s Communiqué No. III-55.1 on “Principles Regarding Portfolio Management Companies and Their Activities.”

6. EFFECTIVENESS AND NOTIFICATION

The Emergency and Unforeseen Situation Plan enters into force as of its publication date and is updated in line with changes in legal regulations or Company structure.

The Company is obliged to inform service recipients about how business continuity will be ensured in emergency and unforeseen situations and related workflow procedures. Such notification must be made during the signing of the portfolio management agreement and additionally via the Company’s website.

The Emergency and Unforeseen Situation Plan and related workflow procedures must be approved by the Company’s Board of Directors, and at least one Company employee at the level of Deputy General Manager, along with an alternative designated employee, must be appointed by the Board as responsible persons for implementation of the plan. The titles and all communication details of these persons must be notified to the Board, MKK, Takasbank, and other institutions designated by the Board.