Purpose and Scope

The Sanctions and Export Controls Compliance Policy (“Policy”) of Dener Makina Sanayi ve Ticaret A.Ş. (“Dener Makina”) sets out the fundamental principles, standards, and controls to be implemented to ensure the Company’s compliance with international economic sanctions and export control obligations.

Dener Makina aims to conduct all its activities, including sales, manufacturing, exports, imports, shipments, payments, collections, technical services, spare parts, software, and the sharing of technical information, in accordance with the sanctions and export control regulations of the Republic of Türkiye, the United Nations (“UN”), the United States of America (“US”), the European Union (“EU”), the United Kingdom, and, to the extent applicable, other relevant jurisdictions.

Regulations relevant to Dener Makina’s activities are taken into account, particularly United Nations Security Council resolutions and the economic and trade sanctions administered by the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”).

This Policy applies to Dener Makina’s managers, employees, shareholders, subsidiaries, and persons acting on behalf of the Company. Dener Makina also expects its customers, distributors, dealers, suppliers, consultants, and other business partners to act in accordance with this Policy.

Definitions

EU: Refers to the European Union.

US Sanctions: Refers to economic and trade sanctions imposed by the US Federal Government, OFAC, and other competent US authorities.

UN Sanctions: Refers to sanctions resolutions adopted by the United Nations Security Council and implemented by member states.

Export Control Regulations: Refers to legislation governing the export, re-export, transfer, or use of products, machinery, spare parts, software, technology, technical information, and services.

Embargo: Refers to the complete or partial restriction of commercial activities with certain countries, territories, individuals, or entities for economic, political, or security reasons.

Sanctions: Refers to economic and financial sanctions, trade restrictions, asset freeze orders, embargoes, and export controls imposed by the Republic of Türkiye, the UN, the US, the EU, the United Kingdom, or other competent authorities, as applicable.

Sanctions Target: Refers to individuals, entities, countries, territories, governments, banks, vessels, aircraft, or other assets included on sanctions lists or with which transactions are prohibited or restricted under the relevant regulations.

Business Partners: Refers to Dener Makina’s customers, suppliers, dealers, distributors, representatives, contractors, subcontractors, consultants, transport companies, and other third parties.

Sanctions Targets may include, in particular, the following individuals and entities:

• Individuals and entities included on current sanctions lists,
• Companies directly or indirectly owned or controlled by sanctioned persons,
• Individuals and entities located in countries or territories subject to comprehensive sanctions or embargoes,
• Individuals and entities acting on behalf of or for the account of sanctioned governments.

General Principles

Dener Makina is committed to taking the necessary measures to ensure compliance with national and international sanctions and export control regulations. No direct or indirect business relationships shall be established with Sanctions Targets or with countries and territories where commercial activities are prohibited under applicable regulations.

The actual customer, end user, country of use, and intended use of the machinery, spare parts, software, and technical services sold by Dener Makina are reviewed as necessary. Products must not be diverted to another country, entity, or end user for the purpose of circumventing sanctions.

If there is any doubt as to whether a transaction may violate sanctions or export control rules, the transaction shall be suspended. No order shall be approved, shipment made, technical support provided, or payment accepted before the necessary assessment has been completed.

Where a permit or licence is required to carry out a transaction, an application shall be made to the relevant competent authorities. The transaction shall not proceed until the necessary authorisation has been obtained.

Implementation of the Policy

Dener Makina performs risk-based checks before establishing legal or commercial relationships with customers, suppliers, and other business partners. These checks may be repeated throughout the business relationship, particularly at the order, shipment, payment, service, and contract renewal stages.

The following information may be assessed as part of these checks:

• Identification and trade registry details of customers and business partners,
• Ownership and control structure and beneficial ownership information,
• End user and intended end use,
• The country and facility where the product will be installed or used,
• Delivery address, shipping route, and payment details,
• Required permits, licences, and other documents.

If non-compliance or reasonable suspicion is identified, the transaction shall be suspended immediately and the necessary action taken.

Customers and business partners are screened against current sanctions lists.

The machine’s installation location, end user, and intended use are verified.

Unusual shipping routes, third-party payments, and unexplained changes of bank are examined.

Transactions are subject to additional review if business partners refuse to provide information or documents, submit conflicting information, fail to disclose the end user, or request unusual payment or shipping methods.

Dener Makina may include provisions requiring compliance with sanctions and export control rules in its contracts with business partners. Business partners may be required to provide undertakings that products will not be diverted to prohibited persons, countries, territories, or end uses.

Payments, Records, and Information Requests

Dener Makina may receive requests for information and documents relating to specific transactions from banks, correspondent banks, public institutions, or other competent authorities. Responses to such requests must be accurate, complete, timely, and free of misleading information.

Information requests, responses, and related documents are appropriately recorded and retained in accordance with the Company’s document retention rules.

All payments and collections are conducted in accordance with applicable legislation, through the actual parties to the commercial transaction, and are accurately recorded. Dener Makina shall not be a party to any transaction intended to facilitate money laundering, terrorist financing, the financing of the proliferation of weapons of mass destruction, or the circumvention of sanctions.

Reporting and Review

Dener Makina encourages employees, managers, and business partners to report situations that may constitute a breach of sanctions, export control rules, or this Policy.

The following reporting channels may be used if a suspicious transaction or conduct is encountered:

Reports are assessed confidentially. Employees or business partners who report concerns in good faith shall not be subjected to pressure, discrimination, or retaliation.

Disciplinary Measures and Sanctions

Violations of this Policy by Dener Makina employees or managers may result in disciplinary measures, including termination of employment, depending on the nature of the violation.

If business partners violate this Policy, the relevant transaction may be suspended, the order cancelled, or the contract terminated. Where necessary, the competent public authorities may be notified and legal proceedings may be initiated against those responsible.

Conduct that violates this Policy shall be assessed and addressed by Dener Makina management in accordance with applicable legislation and internal company regulations.

Document Updates, Retention, and Publication

Dener Makina ensures that the current version of this Policy is published on the Company’s website or through other corporate communication channels deemed appropriate. The Policy and its previous versions are securely retained within Dener Makina’s document management system.

The Policy is reviewed and updated as necessary in the event of changes to legislation, sanctions lists, export control regulations, or the Company’s activities. Dener Makina management, or the relevant department designated by management, is responsible for communicating the updated Policy to the relevant employees and, where deemed necessary, business partners.

Entry into Force

Dener Makina Sanayi ve Ticaret A.Ş.