Persons authorized to access internal information

The persons who work for the Business through an employment agreement, or otherwise, and who have regular access to insider information, and the persons who do not have managerial responsibilities, yet have temporary access to insider information are included in the List of Persons Having Access to Insider Information. While determining the List of Persons Having Access to Insider Information, managers and other personnel who do not have enough information to affect the value, or price of the securities or the investment decisions of investors are not considered as the persons with managerial responsibilities who can access insider information. Nonetheless, members of the Board of Directors of the Business; the persons who, while not being a member of the Board of Directors, directly or indirectly, have regular access to insider information, and who are authorized to make decisions affecting prospective plans and objectives of the Business (“Persons with Managerial Responsibilities”), and the persons, who are closely related to those with managerial responsibilities, and other persons acting for and on behalf of the Business with direct, indirect, regular or occasional access are included in the List of Persons Having Access to Insider Information. The list of those who have access to inside information is kept by the Central Securities Depository, and, in case of any amendments, is updated in accordance with relevant legislation.

The Business takes any and all necessary measures to protect the confidentiality of insider information until it is disclosed to the public in accordance with the legislation. The Business, and the persons acting for and on behalf of the Business cannot share any information with third parties, which may be deemed as insider information, and which has not been disclosed to the public yet. The persons within the Business, who have, or may have access to inside information are advised in writing of protection of the insider information and consequences of any possible violations in order to ensure compliance with their confidentiality obligations.

In case of unintentional disclosure of an insider information by such persons to third parties, a disclosure of material events shall be made as and when it is concluded that confidentiality of information can no longer be ensured within the scope of CMB regulations.