ANTI-BRIBERY AND CORRUPTION POLICY

Document No: AIZ-ABC-001
Version: 1.0
Effective Date: October 1, 2025
Prepared by: Compliance Officer
Approved by: Board of Directors
Website: www.aizonatrading.com
E‑mail: compliance@aizonatrading.com

1. Objective
The purpose of this policy is to define the rules and procedures for the operations of Aizona Precious Metals Inc. (“Aizona” or “the Company”).
the complete prevention of bribery, corruption, conflicts of interest, and unethical behavior in their relationships
to ensure that employees and business partners adhere to the principles of honesty, transparency and accountability.
The goal is to ensure its movement.

2. Scope
Policy; Aizona's board members and employees and those acting on behalf of or for the account of Aizona
agents, consultants, subcontractors, suppliers, distributors and business partners; as well as domestic and international
It includes its affiliates.

3. Definitions
Bribery: Offering a direct or indirect benefit to do or not do something.
giving, requesting, or accepting.
Corruption: The abuse of power in the public or private sector for the purpose of personal gain.
Facilitation Payment: Payments made to public officials to expedite routine procedures.
informal payments.
Benefit: Any kind of advantage such as cash, gifts, travel, hospitality, donations, employment, etc.

4. Fundamental Principle – Zero Tolerance
Aizona has zero tolerance for bribery and corruption. Employees and business partners are directly involved in this process.
It is prohibited to offer, demand, or accept bribes, either directly or indirectly. This prohibition applies to public institutions.
relationships with officials, transactions with business partners/customers, and transfer of benefits through intermediaries.
includes.

5. Legal Grounds
• Turkish Penal Code (TCK) Article 252 – The Crime of Bribery
• OECD Convention Against Corruption (1997)
• UK Bribery Act (2010)
• US FCPA (Foreign Corrupt Practices Act, 1977)
• MASAK Legislation and Measures Regulation
• Istanbul Stock Exchange Ethics and Compliance Standards

6. Implementation Principles
6.1 Gifts and Hospitality: Gifts/hospitality that could influence business decisions are unacceptable;
Those that are reasonable and of symbolic value may be accepted with the approval of the Compliance Officer.
6.2 Donations and Sponsorships: Must be transparent, documented in writing, and for the public good; not to political parties or
Indirect payments to public officials are prohibited.
6.3 Working with Third Parties: Due diligence for intermediaries/consultants/suppliers
This is done; anti-bribery clauses are added to the contracts.
6.4 Facilitation Payments: Prohibited.
6.5 Record Keeping and Accounting: All transactions are recorded accurately, completely, and in a traceable manner; no confidentiality or secrecy is maintained.
Accounts cannot be kept without proper records.
6.6 Notification and Reporting: In case of suspicion, report to the Compliance Officer or via the ethics hotline.
It is mandatory; whistleblowers are protected against anonymity and retaliation.
6.7 Training: All personnel receive "Ethics and Anti-Bribery" training at least once a year; new
Employees agree to this policy by signing.
6.8 Disciplinary Sanctions: In case of violation, disciplinary sanctions, including termination of employment, will be applied; if necessary.
In such cases, the judicial authorities are notified.

7. Responsibilities
Board of Directors: Approval, implementation, and oversight of policy.
Compliance Officer: Implementation, monitoring, reporting, and training activities.
All Employees: Compliance with policy provisions and reporting of suspicious situations.

8. Notification Channels
E‑mail: compliance@aizonatrading.com
Ethics Reporting Hotline: [Private online portal address]
Written Notification: Aizona Precious Metals Inc. – Compliance Department, Istanbul

9. Review and Update
The policy is reviewed by the Compliance Officer at least once a year or in case of legislative changes.
It is reviewed and updated with the approval of the Board of Directors.

10. Entry into force
This policy was decided by the Board of Directors of Aizona Precious Metals Inc. on [dd.mm.yyyy].
It has entered into force and is binding on all employees and business partners.