PrimeTek Code of Conduct

1. Purpose and scope

This Code sets the standards of conduct for everyone who works at or for PrimeTek Informatics Bilisim AS (“PrimeTek”): the Board, management, employees, and contractors working on our behalf. It also states what we expect of our business partners (section 9).

PrimeTek develops and licenses the PrimeUI software libraries and related design tools. We deliver software digitally and do not manufacture physical goods.

The Code is based on Turkish law and on the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, and the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct. Where this Code sets a higher standard than local law, we follow this Code.

2. Responsibility and governance

The Board of Directors has overall responsibility for this Code. Management is responsible for implementing it and for compliance and sustainability matters, including occupational health and safety, data protection, and environmental responsibility. The General Manager acts as Compliance Officer and is the point of contact for all questions about this Code.

Compliance with this Code is mandatory. Every employee and contractor receives the Code when they join and confirms in writing that they have read it and will follow it. The Code is reviewed at least once a year, and all staff renew their acknowledgement after each review.

Breaches are taken seriously and may lead to disciplinary measures under applicable employment law, up to termination of employment or of a contract.

3. Employee rights and working conditions

Equal treatment. We hire, pay, and promote on merit. We do not tolerate discrimination on grounds such as gender, age, ethnic or national origin, religion, disability, sexual orientation, marital status, or political opinion.

Respect and harassment. We do not tolerate harassment, bullying, intimidation, or degrading treatment, whether verbal, physical, or sexual.

Fair wages. All employees are employed under written contracts, registered with the Social Security Institution (SGK), and paid at least the statutory minimum wage, on time and in full.

Working hours. Working hours, overtime, rest breaks, and paid leave follow Turkish Labour Law No. 4857 and are recorded.

Health and safety. We comply with Occupational Health and Safety Law No. 6331. We retain an authorised occupational health and safety service provider for an occupational safety specialist and a workplace physician, keep a current risk assessment and emergency plan, provide the required training, and take part in the safety arrangements of our office building.

Personal freedom. Employees are free to move within and leave the workplace, and have unrestricted access to sanitary facilities, drinking water, and rest areas.

4. Freedom of association and collective bargaining

Employees are free to form and join trade unions and employee representative bodies of their choice, and to bargain collectively, as guaranteed by the Turkish Constitution and Law No. 6356 on Trade Unions and Collective Labour Agreements. No employee is disadvantaged for exercising these rights. Management is the point of contact for any union or employee representatives.

5. Human rights

No child labour. We do not employ anyone below the legal minimum working age. Age is verified from official identity documents before employment begins.

Young workers. Should we ever engage a person under 18, for example as an intern, we apply the protections of Turkish law, including the ban on night work and on hazardous work and the limits on working hours.

No forced labour. All work is voluntary. We do not use forced, bonded, or compulsory labour or human trafficking, do not withhold identity documents or wages, and employees may end their employment on the notice required by law.

6. Business integrity

Bribery and corruption. We do not offer, give, request, or accept bribes, kickbacks, facilitation payments, or any improper advantage, whether dealing with public officials or private parties. Gifts and hospitality are permitted only when modest, occasional, and transparent.

Conflicts of interest.Anyone who has a personal or financial interest that could affect a business decision must disclose it to the Compliance Officer and stay out of that decision.

Fair competition. We comply with competition law, including Law No. 4054 on the Protection of Competition. We set our prices independently and publish them, and we do not agree prices, divide markets, or exchange competitively sensitive information with competitors.

Money laundering. We comply with anti-money laundering law, including Law No. 5549. We receive payments only through regulated channels: our merchant of record for online sales and bank transfers through licensed banks.

Sanctions and export control. We do not do business with persons or entities on applicable sanctions lists and we comply with applicable export control rules.

Accurate records. Our books, invoices, and tax filings are complete and accurate.

7. Data protection, information security and intellectual property

We process personal data in line with Law No. 6698 on the Protection of Personal Data (KVKK) and our published Privacy Policy, and collect only the data we need. We protect confidential information belonging to customers and partners and use it only for the purpose for which it was shared. We respect the intellectual property of others and protect our own.

8. Environmental protection

We comply with applicable environmental law. Our activity is office-based software development, so our footprint comes mainly from office energy use, IT equipment, cloud hosting, and business travel. We keep it low by delivering all products digitally, using electronic invoicing and records, preferring video calls to travel, using equipment for its full working life, and disposing of electronic waste through licensed channels.

9. Business partners

We expect our suppliers, resellers, contractors, and other business partners to meet standards equivalent to this Code, in particular to:

• respect employee rights and provide fair working conditions, fair wages, lawful working hours, and a safe workplace;
• respect freedom of association and the right to collective bargaining;
• respect human rights and use no child labour or forced labour;
• refuse bribery and corruption, avoid conflicts of interest, compete fairly, and comply with anti-money laundering law;
• comply with environmental law and minimise their environmental impact;
• where they supply physical goods, source minerals and metals responsibly, with due diligence on tin, tantalum, tungsten, and gold from conflict-affected and high-risk areas in line with the OECD Due Diligence Guidance.

We share this Code with our business partners and take its principles into account when selecting them. Where we learn of a serious breach by a partner, we raise it with them and, if it is not remedied, end the relationship.

10. Raising concerns

Anyone, inside or outside PrimeTek, can report a suspected breach of this Code or of the law, including concerns about human rights, working conditions, or the environment in our business or our supply chain. Reporting is free of charge.

• By email: [email protected]
• By post: PrimeTek Informatics Bilisim AS, Ankara Technology Development Zone, Universiteler Mah. 1605 St. No:3, Cyberpark Foundation Building, 1st Floor No:103, Bilkent, Cankaya, Ankara, Türkiye

Reports may be made anonymously. Every report is handled confidentially by the Compliance Officer, acknowledged where a reply address is given, and investigated. Concerns involving the Compliance Officer may be addressed directly to the Board of Directors at the postal address above. Nobody who raises a concern in good faith will suffer retaliation or any disadvantage for doing so.

11. Adoption

This Code was adopted by the Board of Directors of PrimeTek Informatics Bilisim AS and takes effect on October 1, 2026.