Ahmet Veli Menger Holding Inc. will perform its duties in line within ethical principles and righteousness in any location throughout the world. We commit to enhance continuously the quality of our services, products, works and shall gain recognition for our values of candor, justice, respect, responsibility, honesty and sound business practices. Any illegal or immoral behavior of our executives, directors and employees or affiliates is not to the benefit of our company. The company will not deviate from its values and principles for short-term interests. The success of this company is the total accumulation of moral values of both men and women who work here. Therefore, all of us are expected to adhere to high standards of individual ethics.

The company's executives, directors and employees will never let their personal interests to conflict with the interests of the company and customers and they will not allow the existence of such an impression. The company's executives, directors and employees will not act as if they represent Ahmet Veli Menger Holding Inc. in their personal businesses, partnerships or commercial relations. The company's executives, directors and employees will not use the parties that the company has relations with, in order to enhance their personal businesses or personal interests at the expense of the interests of our clients or our affiliates.

Bribe, commission or similar payments and remunerations will not be provided to any person or organization to make business activities seem more appealing or to impress third parties. The company's executives, directors and employees will also abstain from receiving impressive gifts, donations, payments, rewards or excessive entertainment, etc. which make business activities seem more appealing or by which they will be impressed.

The company's executives, directors and employees have to take appropriate measures for the on-going protection of information such as but not limited to those that are patented, confidential or commercially critical. Such information may consist of strategic business plans, operation results, marketing strategies, customer lists, personal records, future purchases or disposals, new investments and production costs, processes and methods of the company, customers or affiliated companies. Ahmet Veli Menger Holding Inc. and affiliated companies thereof have to deal with critical information such as patented, confidential or commercially critical information with regards to individuals or institutions in secrecy and sensitiveness and must publish them only in need to be known basis.

The following principles should be followed while working with internal information:

Non disclosure to anyone, except those within the company who need to use this information, will be made until the company makes public announcement germane thereto.

The staff must not do activities like purchasing or selling the securities of the company until the company makes public announcement of information germane thereto and it is fathomed by public.

The staff will not purchase and sell securities of another company which have not been announced to public when they know that such securities have a tendency to be affected by the activities of the company.

The company's executives, directors and employees will avoid from obtaining competitive intelligence in ways contrary to the law and abstain from acting according to intelligence obtained in such ways. The company's executives, directors and employees will endeavor to abstain from making exaggerated or depreciatory comparisons about the skills or services of the opponents.

The company's executives, directors and employees will have proper personal lives and will not allow their personal lives to affect their skills of providing appropriate service to customers, company or product quality.

The company's executives, directors and employees will accept to report any non-ethical, dishonest, shady and illegal behaviors or conducts violating the rules of company's policies directly to management.

Violation of these ethical codes may result in facing disciplinary action, or even a possible dismissal. The level of disciplinary action will be assessed according to voluntary disclosure and the cooperation of the violator during subsequent inquiries in partial moral violations.

Remember good ethics leads to good business!