Code of Ethics

Ziraat REIT's (“Firm”) Business Code of Conduct and Ethics (the Code) is applicable to shareholders and employees of the Firm. The Code focuses on providing standards which are designed to encourage and promote integrity and to minimize or eliminate wrongdoing. It has provisions dealing with the treatment of tenants, shareholders, suppliers and competitors. The Code specifies procedures respecting the proper use of the Firms's capital to generate maximum return at optimum risk levels. It also has provisions respecting confidentiality of information and conflicts of interest. All Ziraat REIT employees are expected to conduct themselves in accordance with this Code.

Shareholders

Ziraat REIT is committed to increasing shareholder value; aims to manage its investments through minimizing risks and maximizing long term value and return.

Firm believes in shareholder equality and thereby aims to treat each shareholder with the same degree of access and importance. Shareholders are encouraged to share their views and Firm aims to maintain an open communication channel with all of its investors.

Firm is regulated and observed by the Capital Markets Board and is thereby obliged to operate at the highest degree of transparency and professionalism.

All the shareholders are informed about  structure, financial stituation and performance in an open and timely manner. Such information will be updated continuously with the aim of providing investors the information they require in the most efficient and effective fashion.

Employees

Firm believes in maintaining a safe, healthy, and productive working environment free from discrimination, harrasment, and abuse.

Firm’s management maintains an open and ongoing dialogue with all employees and encourages employee participation in business policy formulation.

Firm believes in promotion based on merit and the value of individual contribution.

Employees are expected to conform to the highest levels of professionalism and integrity in all their communications and business relations.

Employees are expected to adopt company policies and safeguard the company's reputation and image.

Employees are expected to interact with their colleagues in a respectful and professional manner consistent with all relevant laws. Any conduct that is inconsistent with this standard shall be reported to management without delay.

Laws, Rules and Regulations

Firm complies with all applicable laws and regulations (primarily Turkish Commercial Code and Turkish Capital Markets Law) related to its operations.

Firm’s Directors and employees are expected to familiarize themselves with the laws, rules and regulations that govern Firms’s business operations and seek legal advice where appropriate.

Firm respects the rights and freedoms of its employees and those whom it has business relationships with.

Firm conducts its financial business according to generally accepted accounting standards, also known as International Financial Reporting Standards (IFRS) and Turkish Accounting Standarts (TMS).  Firm’s internal controls assist in achieving business objectives, mitigating risks and meeting ethical obligations to our stakeholders.  These internal controls are designed to provide reasonable assurance that our operations are effective and efficient; our financial reporting is reliable; and that we comply with laws and regulations.

Firm believes in fair competiton principles and acts with honesty and integrity in each of its business relationships.

Customers, Suppliers and Partners

Firm is comitted to establishing trust and fulfilling its commitments in all of its business relations. Firm will treat its customers in a professional and honest manner consistent with the principles of equality and honesty.

Firm aims to develop mutually rewarding long-term relationships.

Firm aims to conduct business with companies and individuals who share in the values and principles outlined in this Code.

Compliance With The Code

All Firm employees are, without exception, expected to comply fully with the principles described herein. Should an employee act in a manner inconsistent with this code, management shall be informed without delay. No employee shall be held liable or otherwise responsible for any loss of business accrued through his or her compliance with this Code.