1. INTRODUCTİON

These principles have been adopted to define the standards that employees of Sabah Yatak San. Ve Tic. A.Ş. must adhere to.

The principles have defined what is expected of Sabah Bedding employees, regardless of their identity, background, or place of work.

The standards have been based on the following core values:

• Internationally recognized human rights

• Ethical and legal conduct

• Professionalism

These rules encompass all levels of management and employees at Sabah Bedding. All employees must adhere to these principles and requirements, and refer to these rules as guidance when acting on behalf of Sabah Bedding.

This policy is designed to outline the framework of fundamental ethical rules that all Sabah Bedding employees must adhere to, aiming to provide guidance for the decisions they make and the behaviors they exhibit while fulfilling their responsibilities. Employees are expected to act within the framework of general moral principles and exercise discretion. This policy may be updated or modified at any time. Sabah Bedding is always open to suggestions for changes to these rules from employees.

2. OUR BUSINESS RELATIONSHIPS

As a result of its activities carried out with 40 years of experience, the respected image and corporate brand created is the most valuable asset of Sabah Bedding. In order to maintain and enhance the corporate reputation of Sabah Bedding, the basic business principles that all employees throughout the company must adhere to in their activities are listed below.

Sabah Bedding, all employees to understand and embrace the company's values and ethical principles while carrying out its activities.

2.1. Honesty

Sabah Bedding prioritizes honesty, transparency, and high business ethics values in all its activities, expecting all parties it collaborates with to act in accordance with the same values.

Sabah Bedding avoids engaging in any behavior that undermines mutual trust in its business relationships with employees, suppliers, competitors, the environment, society, and humanity.

2.2. Confidentiality

Confidential information refers to any type of financial, strategic, technical, commercial, or other information owned by the company and not known to third parties. Disclosure of such information could potentially cause harm to the company and/or its stakeholders or provide benefit to others. This includes information covered by confidentiality agreements with third parties, as well as any similar matters.

Employees of Sabah Bedding are expected to take care to protect information belonging to Sabah Bedding and all stakeholders. Employees only share this information with relevant individuals within the scope of designated authorities.

Confidential information is not shared with third parties upon departure from Sabah Bedding. Employees are required to return any and all documents or electronic copies they have received and that belong to Sabah Bedding during their employment.

Employees who have recently joined Sabah Bedding cannot share confidential information related to their previous employers within Sabah Bedding.

Employees of Sabah Bedding are expected to protect the confidentiality of attributable confidential financial information, trade secrets, personnel-related information and documents, agreements with business partners, and any other information and documents that could weaken Sabah Bedding's competitive advantage.

Employees of Sabah Bedding are expected to refrain from sharing information obtained or possessed with unauthorized individuals, internal or external authorities, or from using it for speculative purposes (directly or indirectly).

2.3. Fair Working Environment

Sabah Bedding believes in and supports the rights and freedoms of individuals wherever it operates.

In line with this, Sabah Bedding does not discriminate under any circumstances based on individuals' ethnic origin, gender, race, nationality, economic status, religion, or other beliefs. This applies to all relationships, including recruitment, promotion, working conditions provided, and interactions with customers and suppliers.

Sabah Bedding is responsible for ensuring that working conditions and the products they produce comply with human health and safety standards.

Every employee has the right to fair, courteous, and respectful treatment from their subordinates, superiors, and colleagues. Creating a fair, healthy, and safe working environment where employees are respected and all relevant legal regulations are complied with will enhance employee performance, development, and commitment.

2.4. Compliance with the Law

Sabah Bedding is obliged to comply with national laws. Employees are not allowed to engage in illegal activities under the pretext of serving the interests of the company or their personal interests.

2.5. Human Resources

The indispensable fundamental principles of Sabah Bedding for ensuring quality human resources management are summarized below:

• Promotes collaboration among employees in the workplace.

• When hiring and promoting employees, it prioritizes the qualifications, skills, and competencies required for the job.

• Ensures that employees are placed in positions where they can utilize their potential, create value, and contribute to achieving company goals.

• Ensures that employees' rights are fully utilized.

• Creates necessary training and development opportunities within the available resources for employees to improve themselves and perform their jobs better.

2.6. Quality, Environment, Occupational Health and Safety, and Continuous Improvement

Sabah Bedding has established and implemented an integrated management system in Quality, Environment, Occupational Health and Safety matters, in line with a management approach based on objectives, risks, and the environmental impacts of our activities, to prevent pollution, injuries, and health deterioration.

2.7. Public Activities

Sabah Bedding conducts its relations with governmental institutions and organizations in accordance with ethical principles and in compliance with laws and regulations.

3. EXTERNAL RELATIONS WITHIN THE SABAH BEDDING STRUCTURE

The following fundamental principles guide Sabah Bedding's relationships with its stakeholders:

3.1. Relations with Government Institutions

• Complying with the legislation of the countries where business relations are conducted or contemplated,

• Managing, recording, and reporting business and accounting systems in accordance with the law.

3.2. Social Responsibility

• Supporting efforts that contribute to economic and social development,

• Being sensitive to issues affecting society and supporting developmental efforts.

3.3. Customer Relations

• Creating value for customers, meeting their needs and demands at the highest level,

• Producing high-quality products,

• Establishing a long-term trust with customers in our relationships,

• Aiming to be the preferred brand by increasing sales and post-sales customer satisfaction,

• Avoiding providing misleading or incomplete information to customers.

3.4. Supplier relationships

• Collaborating to create value in supplier relationships,

• Maintaining open, direct, and clear communication with suppliers,

3.5. Competitor Relations and Competition

• Avoiding any behavior, whether direct or indirect, that aims to prevent, distort, or limit competition, beyond what the laws allow.

• Refraining from engaging in information exchange or discussions with competitors to create competitive conditions.

4. EMPLOYEE RESPONSIBILITIES

Sabah Bedding employees' primary responsibility is to ensure that the name "Sabah" is synonymous with professionalism, integrity, and honesty, and to elevate it to the next level. In this context, the following behaviors are expected from Sabah Bedding employees:

• Always complying with the law,

• Conducting their tasks and operations within the limits of their authority and seeking guidance from their managers in matters beyond their authority,

• Fulfilling their duties within the framework of basic moral and humane values,

• Acting fairly, in good faith, and with understanding in all relationships for the common good,

• Avoiding accepting bribes from any individual or organization or giving bribes to any individual or organization, regardless of the circumstances,

• Adhering to all principles and practices that support business ethics in all activities undertaken,

• Steering clear of any behavior, statement, or written disclosure that binds the company without permission,

• Avoiding behaviors that may disturb or harm other employees or disrupt the harmony of the work environment,

• Protecting all company assets, including document and information systems, from hazards, abuse, theft, and sabotage,

• Refraining from directly or indirectly using working hours and company resources for personal gain.

4.1. Asset and Information Management 4.1.1. Utilization of Company Resources

Comprehensive Sabah Bedding Policies regarding the use of company resources are outlined below:

4.1.1.1. The Internet and Electronic Mail Policy

• Employees are expected to use internet access and email services solely for business purposes.

• Sabah Bedding's internet access and email system are considered company resources. Sabah Bedding reserves the right to monitor and review internet usage and email communications.

• Çalışanlar gizli bilgilerin ifşa olmaması ve yasal olmayan bilgileri elde etmemek adına yeterli özeni göstermelidir. 4.1.1.2. Compliance with Information Technology Policies

Employees are always required to comply with Information Technology policies. The following policies are outlined below:

• Not using unlicensed software,

• Not compromising on connection security,

• Not accessing or downloading content from adult, gambling, harmful, or illegal sites. 4.1.1.3. Equipment and Supplies

Office equipment, office furniture, fax machines, computers, software, hardware, devices, and similar equipment belong to Sabah Bedding and cannot be used for personal purposes.

4.1.1.4. Personal Errands

Sabah Bedding employees cannot use Sabah Bedding facilities for personal errands.

4.1.2. Information Management

• Ensuring that all legally required records are maintained.

• Avoiding responding to requests for confidential information related to the company's affairs by third parties without the approval of senior management.

4.1.3. Security and Crisis Management

• Taking necessary precautions to protect company employees, information, and administrative facilities from natural disasters.

• Taking personal precautions to prevent theft or loss of company assets.

4.2. Avoidance of Conflict of Interest

Conflict of interest is defined as the clash between the personal interests of employees and the potential interests of their family, friends, acquaintances, or associated individuals and organizations, which may hinder them from impartially fulfilling their duties.

Sabah Bedding expects its employees to avoid situations where conflicts of interest may arise and to promptly inform their manager in case of any potential conflict.

4.2.1. Avoidance of Related Party Transactions or Personal Interest Transactions

• Avoiding unfair gains and income for third parties, related parties, or any individual by leveraging one's position or power,

• Steer clear of conflicts of interest related to the tasks undertaken,

• Refraining from consuming the time or diverting the attention of other employees during task execution, or situations that hinder concentration on primary tasks,

• Promptly informing the relevant manager if an employee has a first-degree family relationship with a customer or supplier who holds a decision-making position in the same sector,

• Employees are required to disclose any shareholding or involvement in another company or investment. Any changes in status that could be perceived as a conflict of interest or similar nature must be promptly reported to at least two levels of managers above.

4.2.2. Receiving and Giving Gifts

When establishing or maintaining a business relationship with Sabah Bedding, prospective individuals and entities are expected to:

• When dealing with Sabah Bedding, except for gifts and related activities in line with business tradition, general culture, and customs, refrain from accepting or offering any gift/activity that may compromise the ability to think independently and make decisions.

• Avoid soliciting or accepting discounts or materials from suppliers, customers, or third parties that may be perceived as inappropriate outside of commercial norms, or offering them to third parties.

4.2.3. Information Leakage

Employees are required to refrain from disclosing any confidential information belonging to Sabah Bedding to third parties. Any actions contrary to this provision will result in the employee being personally responsible for all consequences. Employees must be fully aware that trading confidential information violates the law. Furthermore, any behavior contrary to this provision would constitute a breach of the employee's employment contract and should under no circumstances be carried out.

4.3. Records and Files 4.3.1. Accurate and Complete Business Files

Employees should act in good faith to prevent inaccuracies in Sabah Bedding records and documents, as well as in their internal and external communications or the use of any communication channel, including telephone and electronic communication devices.

4.3.2. Financial Reporting

All Sabah Bedding resources, assets, liabilities, and documents are recorded in accordance with relevant statutory provisions and Generally Accepted Accounting Principles.

4.3.3. Collaboration with Auditors

Sabah Bedding employees are expected to collaborate with both internal and external auditors during the examination of Sabah Bedding's books, records, and activities.

5. THE RESPONSİBİLİTİES OF MANAGERS

• Ensuring the establishment and continuity of the company culture and work environment within the framework of ethical rules,

• Representing ethical standards through behavior and attitude, and communicating ethical rules to employees,

• Being open and tolerant to questions, complaints, suggestions, and feedback regarding ethical rules,

• Providing guidance to employees on what needs to be done, promptly reporting feedback to the Ethics Committee,

• Establishing and improving the structure within the scope of responsibilities to minimize ethical risks in all processes,

• Responsible for implementing necessary methods and practices to ensure compliance with ethical rules.3

6. REPORTİNG AND RESOLUTİON OF NON-COMPLİANCE TO THE ETHİCS COMMİTTEE

Any practice that occurs outside of the Business Ethics Rules or legal regulations that our company is obligated to comply with must be reported by our employees to their respective managers, Human Resources Department, or the Ethics Committee as soon as it is identified. Reports are evaluated through internal processes and mechanisms of the company, leading to a decision and subsequent implementation of that decision. Violations of company principles, policies, Business Ethics Rules, or procedures are dealt with according to the Discipline Management Procedure.

Individuals who approve, condone, or are aware of inappropriate behaviors and activities that violate rules but fail to report them to the appropriate authorities are also subject to disciplinary actions. Our zero-tolerance approach applies rigorously to individuals exhibiting negative attitudes or behaviors within disciplinary review boards.

Instances of non-compliance with the Business Ethics and Conduct Rules are addressed and resolved within the Ethics Committee of Sabah Bedding. Our Ethics Committee is established to prevent conflicts of interest within the scope of Sabah Bedding's Business Ethics and Conduct Rules and to evaluate relevant feedback regarding violations of ethical standards.

Our employees and all stakeholders can easily submit any feedback, suggestions, or complaints directly to the Ethics Committee via email at sustainability@sabahbedding.com.

7. ETHICS COMMITTEE OPERATING PRINCIPLES

• The identity of individuals reporting to the Ethics Committee or lodging complaints is kept confidential.

• Individuals reporting to the Ethics Committee are protected under its confidentiality and cannot be subjected to pressure, discrimination, or mobbing due to their reports.

• The Ethics Committee manages the evaluation and decision-making process with sensitivity to confidentiality.

• It has the authority to directly request information, documents, and evidence from the relevant department. It may examine any information and documents solely related to the evaluation/complaint at hand.

• The evaluation process is documented from the moment of reporting or complaint. Information, evidence, and documents are attached to the record.

• The relevant record is signed by the chairman and members of the Ethics Committee.

• The evaluation is conducted as quickly as possible while ensuring accuracy, and a conclusion is reached promptly.

• Decisions made by the Committee are implemented immediately.

• Detailed information about the decision is provided to relevant departments and authorities.

• The chairman and members of the Committee act independently and without influence from department managers or internal hierarchies while performing their duties. They are not subject to any external pressure or persuasion.

• The Committee may seek expert opinions if necessary and can benefit from expert views while ensuring confidentiality measures during the evaluation process.

• The evaluation process is conducted following the "Discipline Management Procedure.

8. OTHER RESPONSİBİLİTİES

The Board of Directors is responsible for the effective implementation and support of Sabah Bedding's ethical principles or the company-specific rules created in this context regarding Business Ethics.

All policies related to Ethical Principles are reviewed, revised, documented, and revisions are announced to Sabah Bedding upon the recommendation of the Board of Directors by the Management Systems Manager.

9. FAİLURE TO COMPLY WİTH ETHİCAL RULES

Failure to comply with the principles of business ethics and/or company policies and procedures may subject individuals to disciplinary investigation leading to termination of employment. The disciplinary process for such investigations also applies to those who, despite being aware, fail to report possible violations or initiate the necessary procedures, as well as to those who approve or oversee inappropriate behavior that violates ethical principles. Non-Retaliation Policy: Employees cannot be subjected to retaliation for reporting suspected or actual violations of the ethical policy in good faith. Retaliation is a serious violation of Ethical Principles and must be reported promptly.

10. ZERO TOLERANCE POLİCY REGARDİNG VİOLATİONS OF RULES

Sabah Bedding adopts a zero tolerance approach towards violations of its Ethical Principles, including failure to accurately report violations or retaliation against whistleblowers. Sabah Bedding may enforce disciplinary measures against employees who violate these rules or retaliate against reporters.