Purpose and Scope

Dener Makina Sanayi ve Ticaret A.Ş. (“Dener Makina”) Sanctions and Export Controls Compliance Policy (“Policy”) 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 service, spare parts, software and the sharing of technical information, in compliance with the sanctions and export control regulations of the Republic of Türkiye, the United Nations (“UN”), the United States (“U.S.”), the European Union (“EU”), the United Kingdom and, where applicable, other relevant jurisdictions.

Regulations relevant to Dener Makina’s activities are taken into account, particularly the economic and trade sanctions imposed under United Nations Security Council resolutions and by the U.S. 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.

U.S. Sanctions: Refers to the economic and trade sanctions imposed by the U.S. Federal Government, OFAC and other authorized U.S. authorities.

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

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

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

Sanctions: Refers to economic and financial sanctions, trade restrictions, asset-freezing decisions, embargoes and export controls imposed by the Republic of Türkiye, the UN, the U.S., the EU, the United Kingdom or other applicable authorized authorities.

Sanctions Target: Refers to persons, entities, countries, regions, governments, banks, vessels, aircraft or other assets included on sanctions lists or prohibited or restricted from transactions under applicable regulations.

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

Sanctions Targets may particularly include the following persons and entities:

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

General Principles

Dener Makina is committed to taking the necessary measures to comply with national and international sanctions and export control regulations. No direct or indirect business relationship is established with Sanctions Targets or countries and regions where commercial activities are prohibited under applicable regulations.

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

If there is any doubt that a transaction may violate sanctions or export control rules, the transaction is suspended. Orders are not approved, shipments are not made, technical support is not provided and payments are not accepted before the necessary assessment is completed.

Where a permit or licence is required to carry out a transaction, the relevant competent authorities are contacted. The transaction does not proceed without obtaining the required authorization.

Implementation of the Policy

Dener Makina conducts risk-based checks before establishing a legal or commercial relationship with customers, suppliers and other business partners. These checks may be repeated during the business relationship, particularly at the stages of ordering, shipment, payment, service and contract renewal.

The following information may be assessed as part of the controls:

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

If non-compliance or reasonable suspicion is identified, the transaction is immediately suspended and the necessary actions are taken.

Customers and business partners are checked against current sanctions lists.

The installation location, end user and intended use of the machine are verified.

Unusual shipping routes, payments by third parties and unexplained bank changes are reviewed.

If business partners avoid providing information or documents, provide contradictory information, fail to disclose the end user or request unusual payment and shipping methods, the transaction is subject to additional review.

Dener Makina may include provisions concerning compliance with sanctions and export control rules in contracts signed with business partners. Business partners may be required to undertake that products will not be directed to prohibited persons, countries, regions or end uses.

Payments, Records and Information Requests

Dener Makina may receive requests for information and documents concerning specific transactions from banks, correspondent banks, public institutions or other competent authorities. Responses to such requests must be prepared accurately, completely, on time and without misleading information.

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

All payment and collection transactions are carried out in compliance with applicable legislation, through the actual parties to the commercial transaction and with accurate records. Dener Makina does not participate in any transaction intended for money laundering, terrorist financing, proliferation financing or circumvention of sanctions.

Reporting and Review

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

If a suspicious transaction or conduct is encountered, the following reporting channels may be used:

Reports are assessed confidentially. No pressure, discrimination or retaliation is taken against employees or business partners who make reports in good faith.

Disciplinary Measures and Sanctions

Violation 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 the Policy is violated by business partners, the relevant transaction may be suspended, the order may be cancelled or the contract may be terminated. Where necessary, the competent public authorities may be notified and legal proceedings may be initiated against the responsible persons.

Conduct contrary to the Policy is assessed and concluded by Dener Makina management within the framework of applicable legislation and internal company regulations.

Document Updating, Retention and Publication

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

If there are changes in legislation, sanctions lists, export control regulations or the Company’s activities, the Policy is reviewed and updated as necessary. Dener Makina management or the relevant unit appointed by management is responsible for communicating the updated Policy to the relevant employees and, where deemed necessary, business partners.

Effective Date