ASELSAN A.Ş.

Based on public information, there is no readily available evidence that the company publishes a statement from the Chief Executive Officer or the Chair of the Board supporting the ethics and anti-corruption agenda of the company.

Based on public information, there is no readily available evidence that the Chief Executive Officer or the Chair of the Board demonstrate a strong personal, external facing commitment to the ethics and anti-corruption agenda of the company.

Based on public information, there is no readily available evidence that the company’s Chief Executive Officer demonstrates a strong personal, internal-facing commitment to the ethics and anti-corruption agenda of the company, actively promoting the ethics and anti-corruption agenda at all levels of the company structure.

Based on public information, there is evidence that the company publishes a statement of principles representing high standards of ethical business conduct, including honesty, integrity, transparency, responsibility and accountability.

Based on public information, there is no readily available evidence that the company belongs to one or more national or international initiatives that promote anti-corruption or business ethics with a significant focus on anti-corruption.

Based on public information, there is some evidence that the company’s Audit Committee has some corporate responsibility for its ethics and anti-corruption agenda, working with the Internal Audit department and Ethical Committee. However, specific roles and responsibilities are not made explicitly clear. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company has appointed a person at a senior level within the company to have responsibility for implementing the company’s ethics and anti-corruption agenda. However, TI does note the role of the Ethical principles Committee.

Based on public information, there is no readily available evidence that there is regular Board level monitoring and review of the performance of the company’s ethics and anti-corruption agenda. TI notes that the Internal Audit department assesses compliance with the code of ethics and the company states that there is review when an issue occurs. However, it is not clear that there are scheduled major reviews.

Based on public information, there is no readily available evidence that there is a formal, clear, written plan in place on which the review of the ethics and anti-corruption agenda by the Board or senior management is based, and no evidence of improvement plans being implemented when issues are identified.

Based on public information, there is some evidence that the company has a process for review and where appropriate updates its policies and practices in response to actual or alleged instances of corruption. However, the formality of the process with regard to updating policies and processes is not clear. The company therefore scores 1.

Based on public information, there is evidence that the company has a formal enterprise risk management procedure and an Early Detection and Management of Risk Committee. However, it is not clear that there is an anti-corruption risk assessment as part of this.

Based on public information, there is evidence that the company has a formal Enterprise Risk Management procedure and an Early Detection and Management of Risk Committee. However, it is not clear that there is an anti-corruption risk assessment as part of this and no evidence was found to indicate that this is applied to operational business decisions.

Based on public information, there is no readily available evidence that the company conducts due diligence that minimises corruption risk when selecting or reappointing its agents.

Based on public information, there is no readily available evidence that the company has contractual rights and processes for the behaviour, monitoring, control, and audit of agents with respect to countering corruption.

Based on public information, there is evidence that the company makes clear to suppliers, through policy terms, its stance on bribery and corruption and the consequences of breaches to this stance. It is not clear that the company has contractual rights to apply sanctions in the event of breaches of the contract. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company explicitly addresses the corruption risks associated with offset contracting.

Based on public information, there is no readily available evidence that the company conducts due diligence that minimises corruption risk when selecting its offset partners and offset brokers.

Based on public information, there is evidence that the company has an anti-corruption policy that prohibits corruption. However, it is limited with regard to bribery and some other forms of corruption such as kickbacks. The company therefore scores 1.

Based on public information, there is no readily available evidence of a zero-tolerance anti-corruption policy.

Based on public information, there is evidence that the company’s anti-corruption policy is accessible to Board members, employees and third parties. The company’s ethic principles are available in Turkish and English.

Based on public information, there is evidence that the company’s anti-corruption policy is easily understandable and written in clear language.

Based on public information, there is evidence that the company’s anti-corruption policy is applicable to employees and members of the Board.

Based on public information, there is evidence that the company has a policy on potential conflicts of interest. Despite including a brief definition, the company does not provide a number of examples of potential conflicts of interest. The company therefore scores 1.

Based on public information, there is evidence that the company has a policy for the giving and receipt of gifts to ensure that such transactions are bona fide and not a subterfuge for bribery. However, there is a lack of clarity with regard to the policy and no reference is made publicly to upper limits or a threshhold that requires senior authorisation. The company therefore scores 1.

Based on public information, there is evidence of a statement on the giving and receipt of hospitality, that ensures that such transactions are bona fide and not a subterfuge for bribery. However, there is a lack of clarity with regard to the policy and no reference is made publicly to upper limits or a threshhold that requires senior authorisation. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company has a policy that explicitly prohibits facilitation payments.

Based on public information, there is no readily available evidence that the company prohibits political contributions, or regulates such contributions in order to prevent undue influence or other corrupt intent.

Based on public information, there is no readily available evidence that the company has a clear policy on engagement in lobbying activities, in order to prevent undue influence or other corrupt intent, or discloses the issues on which the company lobbies.

Based on public information, there is evidence that the company regulates charitable contributions in order to prevent undue influence or other corrupt intent. The company also discloses the recipients of such contributions.

Based on public information, there is some evidence that the company provides written guidance to help Board members and employees understand and implement the firm’s ethics and anti-corruption agenda. However, the Ethical Principles and Rules of Conduct document prepared for this purpose is not publicly available. The company therefore scores 1.

Based on public information, there is evidence that the company has a training programme on its Ethical Principles and Rules of Conduct, which include an anti-corruption policy. However, there is no readily available evidence of an explicit anti-corruption module. The company therefore scores 1.

Based on public information, the company provides all new employees with training on the company’s Ethical Principles and Rules of Conduct, which include an anti-corruption policy.

Based on public information, there is no readily available evidence that the company provides targeted anti-corruption training to members of the Board.

Based on public information, there is no readily available evidence that the company provides tailored ethics and anti-corruption training for employees in sensitive positions. TI notes that the company affirms to train employees according to the role of the employees, but it is unclear if this includes ethics and anti-corruption training.

Based on public information, there is some evidence that the company has a process by which employees declare conflicts of interest to the Board of Directors and the Corporate Governance Committee. However, the formality of this process is not clear and it is not clear who should report the conflict. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company is explicit in its commitment to apply disciplinary procedures to employees, Directors and Board members found to have engaged in corrupt activities.

Based on public information, there is some evidence that the company has channels that are easily accessible and secure, to guarantee confidentiality or anonymity where requested by the employee, to report concerns or instances of suspected corrupt activity. However, there appear to be no independent channels and it is not clear how well the available channels are publicised. The company therefore scores 1.

Based on public information, there is evidence that across geographies, all employees have access to at least one whistleblowing channel. The company therefore scores 1. To score higher the company would need to provide evidence that across geographies, all employees have access to more than one reporting channel.

Based on public information, there is no readily available evidence that the company has formal and comprehensive mechanisms to assure itself that whistleblowing by employees is not deterred, and that whistleblowers are treated supportively.

Based on public information, there is evidence that the company has well-publicised resources available to all employees where help and advice can be sought on corruption-related issues. However, it is not clear that all of these individuals have been trained for this job. The company therefore scores 1.

Based on public information, there is evidence that there is a commitment to non-retaliation for bona fide reporting of corruption. However, there is no readily available evidence that disciplinary measures are applied to employees who breach this policy. The company therefore scores 1.