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Business Ethics, Transparency and Compliance

Business Ethics, Transparency and Compliance

At FPS, we are committed to conducting our business with the highest ethical standards and integrity. We prohibit all forms of bribery, corruption and anti-competitive behavior in our business and comply with the laws and regulations of the jurisdictions in which we operate. Ethical business conduct is not only a compliance requirement but a foundation of our corporate culture.

5

Number of legal professionals in Legal and Compliance Department

Policy

Our Legal and Compliance Department, led by the Vice President, Human Resources & Legal and Compliance and reporting directly to the CEO, is responsible for overseeing all ethics and integrity-related policies and procedures.

This includes policy development, training coordination, and responding to concerns raised through internal channels and contractual arrangements related to business ethics and integrity. The department comprises five in-house legal professionals and supports all entities globally.

Our team monitors and maintains the following policies and procedures:

Legal and Compliance Department provides oversight on ethics, integrity, and compliance globally.

Actions and Initiatives

The FPS Code of Conduct outlines our expectations regarding ethical behavior and guides colleagues and stakeholders in maintaining integrity, transparency, and respect. The Code includes:

  • Expectations for behavior and compliance

  • Processes for addressing violations

  • Mandatory annual online training modules

  • A closing questionnaire to ensure understanding and commitment

Violations of the Code, related policies, or applicable laws may result in disciplinary action, including termination of employment or business relationships.

Criminal prosecution may apply where laws are breached. The Code is reviewed and updated regularly to reflect our evolving vision, values, and legal requirements, and is made accessible online to colleagues and business partners.

We maintain a 24/7 ethics and compliance hotline hosted by a third-party provider ETHICO to provide colleagues with a place to report violations of our ethics policy that may impact on the business without fear of repercussions.

At FPS, we encourage colleagues to report fraud, bribery, accounting, auditing, other financial practices, discrimination, harassment, violations of law, or other unethical activities.

In 2025, 3,803 colleagues received anti-corruption and business ethics training.

Our Human Resources (HR) and Legal Department evaluate these feedback and reports and ensure necessary action will be taken in terms of our business code of conduct and ethical compliance.

All FPS colleagues receive the Code of Conduct upon joining the company and all our colleagues have read and acknowledged the Code of Conduct.

To ensure ongoing awareness, we require annual refreshment training across all entities. In 2025, 3,803 colleagues received anti-corruption and business ethics training, which covered:

  • Types of corruption (Bribery, Facilitation Payments, Kickbacks)

  • Conflict of interest

  • Gifts and hospitality guidelines

  • Third-party risk management

  • Whistleblowing and non-retaliation principles

  • Legal obligations and internal reporting mechanisms

Awareness is reinforced through internal communications, informative media shared with colleagues, and recognition of Global Ethics Day across all FPS locations.

Aysem Yeliz Esmersoy, FPS leadership team

“Our role in legal and compliance goes simply
beyond responding to risks and requirements. It is about anticipating future challenges and fostering a proactive culture of ethics, compliance, and sustainability.”

Ayşem Yeliz Esmersoy

Legal & Compliance Senior Manager

Total number of employees that have received training on anti-corruption
Description
2023
2024
2025
Senior Management
28
14
24
Middle Management
129
60
88
Junior Management
86
92
105
Other Colleagues
2,860
2,245
3,586
Total
3,103
2,411
3,803

100%

of colleagues received communication on anticorruption and bribery policies

100%

of our leadership received communication on anticorruption and bribery policies

0 Cases

of anti-competitive behavior or antitrust violations

0 Cases

of non-compliance with laws and regulations recorded

0 Cases

of identified leaks, thefts, or losses of customer data

0 Cases

of substantiated complaints received concerning breaches of customer privacy received from outside parties or regulatory bodies

LEGAL DISCLAIMER

This Sustainability Report, reflecting FPS’ current sustainability initiatives and targets, has been developed based on information available at the time of preparation and is provided for informational purposes only as of the date of publication. This report contains statements regarding current expectations, objectives, plans, and future developments related to sustainability matters. Such statements are based on information, assumptions, and circumstances existing at the time of publication and may change over time due to evolving conditions and circumstances beyond the control of FPS. While FPS aims to present accurate and up-to-date information, no representation or warranty, express or implied, is made regarding the completeness, accuracy, or reliability of the information contained herein. Certain figures and data may be subject to rounding or future revision. Unless expressly stated otherwise, nothing in this report shall constitute a legally binding obligation, representation, warranty, or commitment by FPS. This report should be read together with FPS’ policies and applicable legal and regulatory requirements.