PASHA BANK ENG 20

Corporate Governance Compliance Report and Information Form Company Compliance Status Description Yes Partial No Exempted Not Applicable 1.6.3 - The reasons for retaining earnings, and their allocations, are stated in the relevant agenda item. X 1.6.4 - The board reviewed whether the dividend policy balances the benefits of the shareholders and those of the company. X 1.7. TRANSFER OF SHARES 1.7.1 - There are no restrictions preventing shares from being transferred. X 2.1. CORPORATE WEBSITE 2.1.1.-The company website includes all elements listed in Corporate Governance Principle 2.1.1. X Frequently Asked Questions section is not available. 2.1.2-The shareholding structure (names, privileges, number and ratio of shares, and beneficial owners of more than 5% of the issued share capital) is updated on the website at least every 6 months. x The information on real person shareholders who own more than 5% of the issued capital is not available on the corporate website. 2.1.4 -The company website is prepared in other selected foreign languages, in a way to present exactly the same information with the Turkish content. X Important information is prepared in English. Related information is updated as needed. 2.2. ANNUAL REPORT 2.2.1-The board of directors ensures that the annual report represents a true and complete view of the company’s activities. X 2.2.2 - The annual report includes all elements listed in Corporate Governance Principle 2.2.2. X 3.1. CORPORATION’S POLICY ON STAKEHOLDERS 3.1.1- The rights of the stakeholders are protected pursuant to the relevant regulations, contracts and within the framework of bona fides principles. X 3.1.3-Policies or procedures addressing stakeholders’ rights are published on the company’s website. X 3.1.4 - A whistleblowing programme is in place for reporting legal and ethical issues. X 3.1.5-The company addresses conflicts of interest among stakeholders in a balanced manner. X 72 Annual Report 2020 PASHA Bank Information on Management and Corporate Governance Practices