PUBLIC POLICY

1. Purpose

The Information Policy created by the Board of Directors of Elit Turizm Yatırım A.Ş. aims to communicate to shareholders accurate, clear and transparent information about the insights and developments of the company regarding past performance and future expectations for the brand.

2. Method and Tools

Elit Turizm Yatırım A.Ş. uses the following tools to inform the public:

• National and local press (newspapers, magazines, etc.)

• National and local visual media (TV, internet, etc.)

• Social media platforms (Facebook, Instagram, LinkedIn, YouTube, Twitter)

• Corporate websites

• Corporate Portal

3. Authority and Liability

The Information Policy was created by the Board of Directors in accordance with the Corporate Governance Principles.

 It sets forth the principles of written and oral communication with the employees, guests, public authorities, suppliers, and various non-governmental organizations.

Official Spokespeople

Official spokespeople of Elite World Hotels & Resorts can provide information within the framework of the authorization table below:

Communications Spokespeople:

4. Content for Corporate Website

In accordance with the Corporate Governance Principles, Elite World Hotels & Resorts website of Elit Turizm Yatırım A.Ş. is available in Turkish, English, Arabic, and Persian languages at www.eliteworldhotels.com.tr. Content of the website is provided under the following topics.

• Corporate

• Our Hotels

• Our Products

• Our Services

• Human Resources

• Elite World Club Card

• Elite World Blog

• Elite World Portal

• News

• Press

• Contact

• Confidentiality and Ethical Rules

5. Principles of Communication

The core values of Elite World are Hospitality and Guest Satisfaction, Respect, Sincerity, Innovation, Creativity, Leadership, Credibility and Loyalty. The principles of communication defined in the light of the values of Elite World are covered under this article.

5.1 Factual Information

It is very important that information provided is based on facts. Top priority of Elite World Hotels & Resorts is to create and maintain an environment that is based on trust and ethical behaviors. Elite World Hotels & Resorts always avoid from providing misleading and wrong messages, making unrealistic promises and creating false expectations. Elite World Hotels & Resorts must do exactly as it says or as it plans.

5.2 Unity of Voice

Elite World Hotels & Resorts is engaged with several internal and external stakeholders. Any statement by any employee of the organization regardless of their role may be deemed as an official statement made on behalf of the organization. The style and tone of a statement may vary depending on the target audience, but its content must remain the same. Thus, it is essential that all communications reflect the organization's viewpoint and that certain target audiences who are interacting with the organization are forwarded to the relevant communication department of Elite World Hotels & Resorts. Accordingly, all media representatives, as well as representatives of official authorities and NGOs, must be forwarded to Corporate Communications and Brands Department. Media inquiries must be responded to by appropriately trained professional employees who are assigned by Corporate Communications and Brands Department. It is advised that such inquiries are always answered in writing rather than over the phone.

5.3 Equal Treatment

It is critical that Elite World Hotels & Resorts simultaneously inform all stakeholders. This is crucial for maintaining employee engagement and trust levels high as well as for fulfilling the expectations of external parties who make their decisions according to the information provided by Elite World and shape how Elite World Hotels & Resorts is perceived by public opinion. Information provided must be consistent and preferably shared with all stakeholders simultaneously, and if legally permitted, employees must receive news directly from the organization rather than via third parties. Exceptions may apply due to legal arrangements. When it is necessary to communicate information with a particular target group first, a general information statement must be distributed to other stakeholder groups as soon as feasible after such an announcement. People who obtain the information in advance must be informed that it must be kept private and not used until it is made available to the general public.

5.4 Maintaining Our Position

The perceptions of people outside Elite World Hotels & Resorts may not be consistent with the perception within the organization. It is expected that our organization may occasionally face harsh criticism, to which we must respond appropriately and persuasively while also demonstrating our position. All appropriate channels shall be used to express our viewpoints in situations that have an influence on the operations or reputation of our business. This is particularly critical in media relations. Our objective is to address relevant circles with factual information and to take a strong position against groups that voice opinions or criticisms for predetermined reasons.

5.5 Privileges and Integrity

Elite World Hotels & Resorts must treat all news channels equally in light of current events, with the exception of the unique situations outlined in the section below. The media expects Elite World Hotels & Resorts to treat them with integrity, just as Elite World wants the media to treat them with integrity. Even though Elite World Hotels & Resorts may enjoy an advantage in granting privileges to a news channel about a particular news story, Elite World might ultimately suffer as a result. This may cause a trust issue with Elite World's relationships with other news channels as a result. Elite World's departments must refrain from taking sides in order to gain an advantage. Violation of this principle by any department may negatively affect Elite World Hotels & Resorts.

5.5.1. If a certain news channel is pursuing a story about Elite World Hotels & Resorts on its own, information provided to that channel cannot be shared with rival channels. In other words, Elite World Hotels & Resorts must not infringe on any privilege that a news channel independently established.

5.5.2. It is acceptable to collaborate with a news channel when such news channel devotes especial attention to a news story. Such a news piece must follow the overall trend rather than being a "breaking news" item on competing channels.

5.5.3. The Corporate Communications and Brands Department must be consulted when choosing the written and verbal news channels to send announcements to or communicate with in order to determine whether they would be interested in receiving the information. This decision must be made after taking into account previous interactions with the specified channel or news reporter as well as previous inquiries for announcements or information of this nature.

6. Privacy

Elite World Hotels & Resorts respects the right to privacy of its guests and employees and complies with all local rules and government principles and provisions pertaining to privacy and confidentiality. Policy principles regarding privacy are as follows:

6.1. Any type of data that could provide someone an advantage or disadvantage by discriminating against them based on their race, religion, national or ethnic origin, political engagement, gender, age, or disability is considered information that must not be shared outside of Elite World Hotels & Resorts.

6.2. Any behavior that endangers an individual's safety or privacy or discloses confidential information of Elite World is prohibited by Elite World Hotels & Resorts.

6.3. For guests, information that can be disclosed include name, surname, passport number, Turkish identity number, work and home address, marital status, contact details, check in & check-out dates, activity dates, registration dates, and the amount expenditure. Such information shall be kept confidential if requested so by the guest.

6.4. For employees, Elite World Hotels & Resorts prohibits the use of a password for access or login to a computer of someone else, or allowing someone else to do so without proper authorization in order to gain unauthorized access to confidential or proprietary information.

6.5. Conflict of Interest

Employees of Elite World Hotels & Resorts are not permitted to utilize their positions or the information given to them as a result of such positions in a manner that could lead to a conflict between Elite World's interests and the interests of the individual.

7. Awards

The public announcement of awards earned by Elite World Hotels & Resorts from various organizations is crucial because it acknowledges the awarders and helps in drawing attention from society to the programs, facilities, and activities of organizations. The Corporate Communications and Brands Department's policy is to provide the broadest amount of support possible for the awards received while adhering to journalism standards and sound journalistic decisions.

The four components outlined below form the foundation of an effective communication activity:

1. Publications by Elite World Hotels & Resorts (corporate e-magazine, portal)

3. Dissemination of information via websites and news bulletins

4. Standards and practices of foreign news media

An award announcement which was not properly documented or recorded may cause negative impacts on the organization presenting the award and Elite World Hotels & Resorts.

Press releases are written or edited by the Corporate Communications and Brands Department in accordance with the policy principles outlined below, and they are distributed only after receiving approval from the appropriate departments.

Policy principles regarding awards are as follows:

7.1 An award or commitment must be formally acknowledged as such before any internal or external communication strategy is put into action.

7.2 In principle, an award must be approved by the organization presenting the award. No announcement can be made without obtaining approval for those described above.

7.3 Corporate Communications and Brands Department evaluates the need to prepare and distribute a press bulletin announcing any award which may be deemed news worthy by media outlets. The scope and timing of this is determined by the Corporate Communications and Brands Department.

8. Social Activities

Elite World Hotels & Resorts' involvement in social projects designed to benefit and support society, as well as the public announcement of such projects made by Elite World Hotels & Resorts, are crucial for developing a good rapport between Elite World Hotels & Resorts and the city/country. Such announcements are distributed to internal and external target audiences in accordance with the principles described below. Policy principles regarding social activities are as follows:

8.1 An Elite World Hotels & Resorts social program, project, or activity must be introduced or made public after consulting with the Corporate Communications and Brands Department and receiving the approval of Marketing Director and CEO.

8.2 Decision to prepare a news release about the project or activity is taken by the Corporate Communications and Brands Department.

8.3 Consideration is also given to the privacy of the subjects of such news articles. If a member of such a community requests to remain anonymous, their identity will not be made public, regardless of whether one of their affiliates tells a better story or presents Elite World's place in society in a more favorable light.

9. Activity News

Elite World Hotels & Resorts designs various social activities and projects in order to provide social advantage and support. Policy principles regarding the announcement of the said activity and projects to relevant internal and external audiences are defined below:

9.1 Subject to the approval of the CEO, Corporate Communications and Brands Department is consulted when deciding on whether to announce to the public the social programs, projects and activities conducted by Elite World Hotels & Resorts.

9.2 Decisions on the announcement news for the projects and activities are taken after the relevant department is consulted by the Corporate Communications and Brands Department.

9.3 Privacy rights of people that are subjects of the news releases shall always be protected. Even while revealing such names would result in favorable press for Elite World Hotels & Resorts and might promote its social position, participation in an activity by people who prefer to remain anonymous must be kept a secret.

9.4 Any organizations or persons invited to speak at an event hosted by the management and administrative departments of Elite World Hotels & Resorts must be informed by the event's organizer of the presence of the media.

10. Relationship with Sellers

Elite World Hotels & Resorts values its relationships with companies from which it receives products and services. Elite World Hotels & Resorts must prevent any promotional activity that could jeopardize its integrity and the independence of its name, both factually and in terms of appearance. According to this policy, Elite World Hotels & Resorts shall not approve any quote, news release or any other communication which might be interpreted as an official confirmation of the products or services of an organization by Elite World Hotels & Resorts or its departments.

Policy principles regarding relationships with sellers are as follows:

10.1 Before being made public by the company, every quote, news release, or other material mentioning Elite World Hotels & Resorts must be reviewed and approved by the Corporate Communications and Brands Department.

10.2 This policy also covers requests from companies to shoot films at Elite World Hotels & Resorts, utilize the Elite World Hotels & Resorts logo, or otherwise use its "brand", which may only be performed subject to prior express consent and in accordance with Elite World Hotels & Resorts' policy.

11. Relationship with Press

This policy aims to identify the individuals who will interact with the media on behalf of Elite World and to further clarify the role that may be played by department heads and coordinators by giving journalists interviews about their areas of expertise to promote Elite World Hotels & Resorts on the media.

Elite World Hotels & Resorts’ engagement with the media is managed by the Corporate Communications and Brands Department, which serves a contact point between Elite World Hotels & Resorts and the society and is in charge of a variety of tasks including editorial, marketing, publishing, and other public relations efforts.

The Corporate Communications and Brands Department is the primary point of contact for the media seeking an expert executive to provide insights on the news subject. The official spokesperson of Elite World Hotels & Resorts is the CEO. Opinions to be provided to the media are subject to following conditions:

11.1 When functional managers of Elite World Hotels & Resorts prove to be more knowledgeable spokespersons on a given subject than the CEO, the CEO will, depending on the situation, designate another employee to speak to the media (see Table of Media Spokespeople).

11.2 In their areas of academic specialization, department heads and coordinators are strongly encouraged to offer commentary to the news media. The Corporate Communications and Brands Department always creates an opportunity to serve as a point of contact between the media and members of Elite World Hotels & Resorts.

11.3 Members of Elite World Hotels & Resorts contacted by the media must always consult the Corporate Communications and Brands Department before agreeing to give interviews or provide insights.

12. Entry into Force

Public Information Policy shall enter into force upon approval of the Board of Directors. In the event that the Public Information Policy needs to be modified, the Board of Directors' approval is necessary before any changes are implemented and their justifications are published.