PURPOSE 1.

Respect for Human Rights is a fundamental value and principle for Başaran Halı Teksil San. ve Ltd. Şti. This policy has been published based on international human rights declared in line with sustainable development and social responsibility purposes. The purpose of Başaran Halı Human Rights Policy is to explain the respect we show to basic human rights and the value we give to our employees, to establish a human rights-oriented approach in our relations with all our internal/external stakeholders and stakeholders by providing a modern and decent work environment. The policy is also an integral part of Başaran Halı Social Responsibility Policy and Ethics Management Handbook.

2.SCOPE

This policy applies to the businesses we own and the facilities we manage as Başaran Halı. Başaran Halı also expects its suppliers and business partners, institutions and organizations and their employees and all stakeholders with whom it has business relations to implement these principles, guides and encourages all stakeholders and undertakes to include them in agreements. We take due diligence to identify and prevent human rights risks to people in our business and our communities as part of our business risks. Where we identify adverse human rights impacts arising from our business activities, we commit to provide or cooperate in remediation in a fair and reasonable manner. Where we are linked to or involved in such adverse impacts through our dealings with third parties, we seek to ensure remediation in accordance with legal and ethical principles.

3RD RESPONSIBLE

Başaran Halı is committed to contacting the authorities when it sees that human rights are at risk in the places where it operates and aims to work with certain independent local stakeholders to eliminate rights violations. The Chairman of the Board of Directors of Başaran Halı and the company managers in the areas of activity are primarily responsible for the implementation of the Human Rights Policy. Başaran Halı Human Rights Policy is supervised by Başaran Halı senior management and disciplinary board.

4. BASIC PRINCIPLES, COMMITMENT AND IMPLEMENTATION PRINCIPLES

This Policy is guided by international human rights principles, including the Universal Declaration of Human Rights, including those contained in the International Bill of Rights, the International Labor Organization's (ILO) 1998 Declaration on Fundamental Principles and Rights at Work, the United Nations Global Compact, and the United Nations Guiding Principles on Business and Human Rights.

DISCRIMINATION: As Başaran Halı, it is our principle to treat all our employees with dignity. We strive to ensure that our employees are not discriminated against on grounds such as race, gender, national origin, ethnicity, religion, language, age, caste, disability, marital status, pregnancy, diseases, sexual orientation, definitions expressing gender, political opinion or other status protected by applicable laws, and to be a workplace free of harassment, physical or psychological violence, disrespect. Gender-sensitive, equal opportunities and treatment in recruitment and employment are the main pillars of our policy. We do not tolerate disrespectful or inappropriate behavior, unfair treatment or retaliation of any kind, regardless of personal characteristics, position or status. Written disciplinary rules in accordance with national legislation are established and information on the subject is explained verbally and in writing in terms and language that employees can understand. (See Employee Handbook-Disciplinary Penalty List)

DIVERSITY AND INCLUSION: We value the differences of the people we work with and try to make them feel included. At Başaran Halı, we are committed to equal opportunity and we make recruitment, placement, development, training, remuneration and promotion decisions based on the qualifications, performance, skills and experience of the employee. Diversity in our workforce is essential to achieve our goals. Therefore, we strive to attract, develop and retain employees with different backgrounds and experiences.

WORKING HOURS, WAGES AND PERSONAL RIGHTS: Our employees are not overworked beyond the standard hours specified in national laws. These hours are exceeded only in accordance with the exceptions defined by the ILO where overtime is permitted. Overtime does not seriously increase the likelihood of occupational hazards and may under no circumstances exceed the limits defined in national legislation. Overtime is paid at a rate of at least % 125 of the standard rate.

We set our remuneration policy and benefits competitively according to the industry, the local labor market and in accordance with the terms of applicable labor contracts. We conduct our operations in compliance with applicable laws on wages and working hours. We entitle our employees to rest breaks every working day and to vacation time every seven days. We provide opportunities for our employees to develop their talents and potential and to make progress.

We pay our employees wages in accordance with wages mandated nationally by government minimum wage legislation or industry standards approved through collective bargaining, whichever is higher. Wages refer to standard working hours.

The salaries of our employees are paid regularly, on time, consistently and fully in kind in legal tender. Partial payment in the form of an “allowance in kind” is only recognized in accordance with ILO specifications. We conduct a fair wage analysis to accurately assess the wage gap and work progressively towards the payment of a living wage that is sufficient to ensure a reasonable standard of living for workers and their families.

We ensure that workers' wage levels reflect their skills, responsibilities, seniority and training; where a wage rate is set for production, quota or piece work, we allow workers to earn a minimum wage that meets or exceeds applicable legal minimum wages, industry standards or collective bargaining agreements (where applicable) during standard working hours; we ensure that workers of all genders and categories (such as migrant and local workers) receive the same wage for equal work and qualifications; we apply deductions only under conditions permitted by law or fixed by collective agreement. We provide employees with the social rights that are legally granted and do not allow them to have a negative impact on, for example, their salaries, seniority levels, positions or promotion prospects.

PREVENTING INSECURE WORK: Başaran Halı ensures that work is carried out on the basis of a recognized and documented employment relationship established in accordance with relevant national legislation, custom or practice and international labor standards (whichever provides greater protection) to ensure that recruitment processes and employment relationships do not create insecurity, social or economic vulnerability for its employees. Ensure that, prior to employment, workers are provided with clear information in their own language and are informed in their own language about their rights, responsibilities and conditions of employment, including working hours, wages and payment conditions. (See Employee Handbook) Support employees, regardless of gender, in their role as parents or caregivers, including migrant and seasonal workers who may leave children in their home countries. We aim to provide reasonable and, where necessary, flexible working conditions. We undertake not to deliberately use employment arrangements in a way that contravenes the original intent of the law, including apprenticeship or training schemes where there is no intention to provide skills or regular employment, seasonal or contingency working arrangements when used to undermine worker protection, labor-only contracting and contract substitution, and subcontracting in a way that undermines workers' rights.

FREEDOM OF ASSOCIATION and collective bargaining rights: Our workplace is free to organize within legal limits. We respect the right of our employees to join, form or not join a labor union without fear of reprisal or intimidation. We are committed to bargaining collectively in a free and democratic manner, regardless of gender, ensuring meaningful representation of all workers, again regardless of gender and without discrimination, not discriminating against workers who are union members, not denying worker representatives and recruiters access to or interaction with workers in the workplace, and engaging in constructive dialogue with the freely chosen representatives of our employees who are represented by a legally recognized labor union.

PREVENTING CHILD LABOR and SPECIAL PROTECTION FOR YOUNG WORKERS: We do not employ child labor. We prohibit the hiring of people under the age of 18 for positions that require heavy and dangerous work. We expect the same from our business partners. We do not directly or indirectly employ children below the age of compulsory schooling as defined by law, unless exceptions recognized by the ILO apply, we protect children from all forms of exploitation, we establish robust age verification mechanisms as part of the recruitment process that do not subject workers to any form of degrading or disrespectful treatment. To ensure the protection of affected children, we take special care in the case of child dismissal, acting as set out in PR-26 Child Labor Rehabilitation Procedure.

Prevention of bonded or forced labor and human trafficking

We prohibit all forms of forced labor, including prison labor, bonded labor, military labor, modern forms of slavery and all forms of human trafficking. We do not engage in slavery, forced labor, bonded labor, indentured, indentured servitude, trafficking or involuntary servitude, including state-imposed forced labor practices, and we abide by international principles of responsible recruitment, including the “Employer Pays Principle”, when engaging in direct or indirect employment relationships with all workers, especially members of vulnerable groups such as temporary and migrant workers, and we demand the same from our recruitment partners.

Başaran Halı demands that no recruitment fee be charged to workers at the time of recruitment, that clear and transparent, understandable employment contracts be made, that employees are not subjected to deception and coercion in any way, that their freedom of movement is not restricted without pressure and that their identity documents are not taken hostage, and that they have the right to free, comprehensive and accurate information,freedom to terminate the contract, change employer and return safely to one's home country, the right to free dispute settlement and access to effective remedies, and to progressively compensate workers for damages within a reasonable timeframe and in accordance with the same international principles if past or actual violations of the principles are found.

WORKPLACE SAFETY, SAFE AND HEALTHY WORKPLACE

We are committed to providing a workplace free from violence, harassment and intimidation. We provide security services for employees when necessary and in a manner that respects the dignity, privacy and reputation of the employee. The safety and health of our employees is paramount. Our policy is to provide a safe and healthy workplace and to comply with applicable occupational health and safety laws, regulations and internal requirements. We strive to provide and maintain a healthy and productive workplace environment by identifying and resolving risks that may cause accidents, injuries and health problems. Başaran Halı respects the healthy working and living conditions of employees and local communities without prejudice to the specific expectations set forth herein. Provides special protection to vulnerable persons including but not limited to young workers, new mothers or women expecting children and persons with disabilities, complies with national occupational health and safety legislation or international standards where national legislation is weak or poorly implemented, assesses, identifies, prevents and establishes systems to mitigate potential and actual threats to the health and safety of employees. Regularly trains all departments and individuals at all stages of employment on occupational health and safety and provides information on potential occupational health and safety risks to workers and the public, including affected communities. It takes effective measures to prevent employees from being exposed to accidents, injuries or illnesses that occur during work, arising out of work or related to work, and aims to minimize the causes of workplace hazards as much as possible with these measures. Başaran Halı undertakes to try to ensure the protection of workers in case of accidents, including compulsory insurance plans, to keep records of all health and safety incidents at the workplace and in all other facilities provided or required to be provided to workers, to take all appropriate measures to ensure the stability and safety of equipment and buildings used by workers and to provide protection and preparedness against foreseeable emergencies, and to obtain all relevant licenses and documents required by national legislation. This definition also includes worker housing provided or mandated by the employer or recruitment partner.

Başaran Halı has established relevant committees such as the Occupational Health and Safety Committee to ensure the development and effective implementation of systems that provide a safe and healthy working environment and to ensure active cooperation between management and employees and/or their representatives. These committees aim to represent the diversity of workers, raise workers' awareness and respect their right and responsibility to leave the premises and/or stop work in dangerous situations and uncontrolled hazards without asking permission, provide adequate occupational medical assistance and related facilities, and ensure that all workers have equal access to these services. Health services (including insurance) serve the unique concerns and needs of all gender and age groups, provide access to safe and clean drinking water, free food and rest areas, and where appropriate, do not restrict access to cooking and food storage areas.

Başaran Halı has an adequate number of safe, separate toilets with adequate levels of privacy for all genders, and hand soap, paper towels and sinks in all work areas. When residential facilities are provided or mandated, they are not made available to workers without ensuring that they are clean and safe and meet all workers' basic needs.

Effective and specialized Personal Protective Equipment (PPE) is provided to all workers free of charge, taking into account the needs of different categories of workers, such as pregnant and breastfeeding women, and workers are compensated for damages if it is determined that the principles have not been followed in the past or currently.

ENGAGEMENT WITH SOCIETY AND STAKEHOLDERS: Başaran Halı recognizes that it is a part of the society in the places where we conduct our business, and while doing our business, we establish a relationship with all our stakeholders, including vulnerable, disadvantaged or sensitive groups for various reasons, on human rights issues that are important to them, making them feel that their views are listened to and taken into account. We believe and strive to ensure that local problems are best addressed at the local level.

ENVIRONMENTAL RESPONSIBILITY AND WATER RESOURCES: As Başaran Halı, we are aware of the potential impacts of our land and water use within our value chain on human rights and we address this issue with special practices. In parallel with our Environmental Policy, we respect the human need for water resources and safe drinking water and the protection of both ecosystems and communities through proper sanitation.

As Başaran Halı, in parallel with our ISO 50001:2018 Energy Management Systems activities, we fill out the HIGG FEM platform annually in order to evaluate the environmental impacts arising from our production and inform our stakeholders. We continue our efforts to take measures to reduce our water use and water pollution. We strive to positively impact future generations' access to natural resources by following national and international environmental legislation.

COMPLIANCE, MONITORING, GUIDANCE, REPORTING and BUDGET: We strive to create workplaces where open and honest communication between all employees is valued and respected. As Başaran Halı, we are committed to complying with applicable labor and employment laws wherever we operate. The Company's Board of Directors is responsible for overseeing the determination and operation of notification, investigation and sanction mechanisms in case of non-compliance with this policy, rules and regulations. The responsibility for the policy rests with the General Manager and the Board of Directors at the highest level. In the event that situations and inappropriate behaviors contrary to this policy are detected, criminal sanctions may be imposed in accordance with the provisions of the relevant legislation in national and international locations where we operate.

Başaran Halı also ensures that employees are familiar with the Human Rights Policy through the training process. Any employee who believes that there is a conflict between the language of the policy and the laws, customs and practices of the place where he or she works, who has questions about this policy, or who wishes to confidentially report a potential violation of this policy, should communicate these questions and concerns to local management, Human Resources, the Management Systems Manager or the Employee representative.

Employees may also report suspected policy violations by emailing ethic@basaranhali.com.tr or etik@basaranhali.com.tr or by calling (+90 342 357 04 04 04- Dahili159). No retaliation or adverse action will be taken against any employee who reports concerns under this policy. In addition, Başaran Halı attaches importance to the principles of confidentiality in compliance with the policy and therefore undertakes that the identity of the whistleblower will be kept confidential upon request for the reporting of violations.

The Company will investigate and respond to employee concerns and take appropriate corrective actions in response to any violation. Measures to be taken for material and moral damages caused by non-compliance identified within Başaran Halı based on clear evidence will be compensated from the company budget. The Human Rights Policy is in line with the rules set out in Başaran Halı's Ethics Handbook and Social Responsibility Policy. This policy, including translations and related information, can be found on Başaran Halı's website: https://basaranhali.com.tr

STAKEHOLDER INFORMATION: As part of our sustainability efforts in all areas, we are committed to regularly reviewing our commitments, efforts and statements on human rights in accordance with this Human Rights Policy and reporting the results to all our stakeholders on an ongoing basis. This reporting refers to the UN Guiding Principles Reporting Framework. Başaran Halı reserves the right to change this policy at any time. Nothing in this policy replaces the employment contract between Başaran Halı and its employees and participation in this program does not guarantee that the employment relationship between Başaran Halı and the employee will continue.

5.RESOURCES

• United Nations (UN) Universal Declaration of Human Rights (1948)
• International Labor Organization (ILO) Tripartite Declaration of Principles on Multinational Enterprises and Social Policy (1977);
• UN Guiding Principles on Business and Human Rights (UNGP) (2011)
• Guidelines for Multinational Enterprises developed by the Organization for Economic Cooperation and Development (OECD) (2011)
• Amfori BSCI CoC References - Turkish - December 2021