Ethics Violation Notification Form

Privacy Notice under the Law on the Protection of Personal Data

(Within the Scope of the Ethics Line Reporting Application)

This Privacy Notice has been prepared to inform you regarding the processing of personal data provided by you during the Ethics Line Reporting Application conducted by Çolakoğlu Metalurji A.Ş. (“Company”), in accordance with the Law on the Protection of Personal Data No. 6698 (“KVKK”) and the relevant legislation.

1. Data Controller

Çolakoğlu Metalurji A.Ş. acts as the data controller with respect to the processing of personal data shared within the scope of the Ethics Line Reporting Application.

Address: Rüzgarlıbahçe Mahallesi, Çam Pınarı Sokak, No:1, İç Kapı No:16, Beykoz / Istanbul

Email: kvkk@colakoglu.com.tr

Registered Electronic Mail (KEP): colakoglumetalurji@hs02.kep.tr

2. Collected Personal Data and Purposes of Processing

Within the scope of the notifications submitted through the Ethics Line system, the following personal data may be processed if provided by you. The system allows users to submit anonymous notifications; in such cases, no personal data is processed. Only the date of form submission is recorded through the notification form, and no technical data such as IP address, session information, document metadata, or log records are processed.

Personal data that may be processed:

Identification Data: Name, surname (for non-anonymous notifications)
Contact Information: Email address, phone number
Employment Information: Department, position, company details
Notification Content: Allegations of ethical violations, description of events, attached files (if any)

Data of Other Individuals Related to the Notification: Personal data limited to the scope of the allegations

These personal data are processed for the purposes of evaluating ethical violations, conducting internal audit and compliance activities, managing investigation procedures, monitoring adherence to Company policies, ensuring activities are conducted in accordance with applicable legislation, and, where necessary, contacting relevant parties.

3. Methods and Legal Basis for Collection of Personal Data

Your personal data are collected through:

Notifications submitted via the Ethics Line application (web form, email, phone, oral statements)
Documents and explanations provided by you

Notifications submitted via the web form are recorded automatically. After submission, the record is directly stored in the system, without any pre- or post-submission review, approval, or manual modification.

Oral, phone, or email notifications are collected partially automatically when digitized into the system.

No personal data is processed in anonymous notifications; KVKK provisions apply only to identified notifications.

In accordance with Article 5 of KVKK, your personal data are processed based on the following legal grounds:

the explicit consent of the data subject,
necessity for the establishment, exercise, or protection of a right,

where processing is necessary for the legitimate interests of the data controller,

4. Transfer of Personal Data

Collected personal data may be shared, strictly limited to the purposes described above, with:

Relevant departments within the Company (Internal Audit, Legal, HR, Compliance, etc.),
Audit/review firms, lawyers, and/or consultancy companies if required,
Authorized public institutions and organizations under legal obligations.

The Ethics Line Reporting Application is fully developed and operated by Çolakoğlu Metalurji A.Ş. on the Company’s own servers; personal data are not transferred to any third-party platform or abroad.

5. Methods to Exercise Your Rights

Under Article 11 of KVKK, you have the following rights regarding your personal data:

To learn whether your personal data are being processed,
To request information if your data have been processed,
To learn the purpose of processing and whether your data are used in accordance with that purpose,
To know the third parties domestic or abroad to whom your data have been transferred,
To request correction of incomplete or inaccurate data,
To request deletion or destruction of your data when the reasons requiring processing no longer exist,
To object to results arising from automatic systems that are against you,
To request compensation for damages due to unlawful processing.

You can submit your requests with sufficient identity information to the Company via:

In writing: Delivered in person, by post, or via notary to:

Rüzgarlıbahçe Mahallesi, Çam Pınarı Sokak, No:1, İç Kapı No:16, Beykoz / Istanbul

Electronically:

kvkk@colakoglu.com.tr
colakoglu@colakoglu.com.tr
colakoglumetalurji@hs02.kep.tr (KEP address)

Applications are concluded within thirty (30) days from the date of receipt, depending on the nature of the request. If the submitted information or documents are incomplete or unclear, the applicant may be contacted for clarification.

If your request is rejected, the response is deemed insufficient, or you do not receive a response within the prescribed time, you may file a complaint with the Personal Data Protection Board within thirty (30) days following the Company’s response, and in any event within sixty (60) days from the date of your initial application. Please note that it is mandatory to apply to the data controller before filing a complaint with the Board.

6. Retention and Deletion of Personal Data

Personal data obtained within the scope of the Ethics Line Reporting Application are retained in accordance with the relevant legal provisions and the Çolakoğlu Metalurji A.Ş. Personal Data Retention and Deletion Policy until the related notification, internal audit, and/or investigation processes are completed and necessary procedures finalized.

In cases not explicitly regulated by legislation, personal data are deleted, destroyed, or anonymized within one (1) year from the date the purpose of processing ends. This process is conducted in compliance with Article 7 of KVKK and the Regulation on the Deletion, Destruction or Anonymization of Personal Data.

Within the scope of this Privacy Notice, if the reports and notifications you submit through the Ethics Line managed by Çolakoğlu Metalurji Anonim Şirketi are not provided anonymously, your identity, contact, and transaction security information, as well as any data related to the reported incident, will be securely processed within the technical infrastructure of the central Ethics Line platform and will be used solely for the purpose of managing and handling the ethics reporting process.

What is your relationship with Çolakoğlu Metalurji and Group Companies? *

Do you wish to remain anonymous? (Although ÇM prefers reports to be made under a real name, requests from individuals who do not wish to disclose their identity will be handled in accordance with the principle of confidentiality. If you do not want to share your name, please check the box below.)

Yes

Name and Surname *

How would you like to be contacted?

Phone E-Mail

Phone Number *

Person(s) or department(s) subject to the complaint

I don’t know

Details of the Incident Subject to Violation *

Details on how the violation was detected

If the information regarding the violation was shared with someone else, details of that sharing

Attachments

Drag and drop one or more files here, or click to upload

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