CONFLICT MINERALS POLICY

CONFLICT MINERALS POLICY

As Formfleks A.Ş., we are committed to protecting our natural resources by continuously improving our activities in our facilities, recognizing that the resources of our ever-shrinking world are not infinite.

Conflict minerals such as Tin, Tungsten, Tantalum, Gold and their derivatives (“3TG”) are not used in the production of NVH, Interior-Exterior Trim, Heat Shield and Engine Lower parts in Formfleks fields of activity.

In this context, Formfleks attaches importance to a sustainable, transparent and ethical supply chain, and adopts the following considerations regarding the procurement of conflict minerals from conflict-affected and high-risk areas (CAHRA-Conflict-Affected and High-Risk Areas).

In order to avoid any actions that contribute to the financing of conflict, Formfleks A.Ş. expects our business partners to comply with the same considerations and to act in accordance with the “OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas” standards.

In this context, Formfleks A.Ş. expects you, our business partners, to fulfill the following points as part of its effort to manage the risks related to conflict minerals:

• Commitment not to procure Tin (Sn), Tantalum (Ta), Tungsten (W) and Gold (Au) directly from entities that directly or indirectly finance the conflict in the Democratic Republic of the Congo or neighboring countries for use in their products, and that the materials procured do not contain “conflict minerals” mixed in,
• Identification of products with a high probability of 3TG use, identification and evaluation of supply sources,
• Cooperate with its own suppliers to verify the use of 3TGs and potential sources of these minerals,
• Work to adopt a policy on conflict minerals consistent with Formfleks A.Ş. policies,
• When a situation related to conflict minerals is detected in the supply chain or a risk is foreseen, to apply to the notification channels detailed below and to work in coordination with Formfleks A.Ş. to eliminate the risk, if necessary, to stop cooperation with risky suppliers.

If Formfleks A.Ş. determines that any Business Partner’s efforts to comply with this policy are inadequate and the Business Partner fails to cooperate in the development and implementation of reasonable corrective steps, Formfleks A.Ş. reserves the right to take appropriate action, up to and including termination of the business relationship with the Business Partner.

AUTHORIZATIONS AND RESPONSIBILITIES

All employees and directors of Formfleks A.Ş. are responsible for complying with this Policy and for implementing and supporting Formfleks A.Ş.’s relevant procedures and controls in line with the requirements in this Policy. Formfleks A.Ş. expects all Business Partners to act in accordance with this Policy to the extent applicable to the relevant party and transaction, and takes the necessary steps for this.

In case of being aware of any action that is considered to be contrary to this Policy, applicable legislation or Formfleks A.Ş. Code of Business Conduct and Ethics, the Human Resources Leader, Formfleks A.Ş. Ethics Representatives, Legal Representative and Internal Audit Leader should be contacted.

You can submit your questions or any notifications regarding ethical violations by calling “444 38 45”, sending an e-mail to “erkurtholding@etikhat.com.tr” or via Formfleks A.Ş. Ethics Notification Channels via “www.etikhat.com.tr”.