Disclosure Policy

The Aksa Akrilik Kimya Sanayii A.Ş. (Aksa) Board of Directors has drawn up a disclosure policy whereby shareholders and stakeholders have regular and reliable access to prompt, accurate and complete information about potential influences on capital market instruments and about the Company's management as well as its financial and legal status. This policy excludes information that is considered a trade secret and other data that may harm the Company by inhibiting its competitive power. Regarding disclosures made to the public, Aksa never acts in violation of the Turkish Commercial Code, Capital Markets Legislation or the regulations of the authorized institutions in this context, which are the Capital Markets Board (SPK) and the Istanbul Stock Exchange (ISE), nor does it go against the Corporate Governance Principles of the Capital Market. The Aksa Disclosure Policy is drafted by the Board of Directors, presented to the General Meeting of Shareholders and announced to the public through its publication on the corporate website. If any changes are made in the Disclosure Policy, these items are presented to the Board of Directors for approval, then presented at the General Meeting of Shareholders and finally published on the corporate website. The Assistant General Manager of Finance has been appointed to the task of observing and monitoring all matters involving the implementation, follow-up and disclosure to the public of the Aksa Disclosure Policy. 

Media and Methods used in Public Disclosure

In addition to legal regulations, all information related to Aksa is disclosed to the public by means of the following methods and communication tools:

• Corporate website,

• Annual Report,

• Meetings with shareholders and potential investors,*

• Meetings with banks, financial institutions and brokerage firms,*

• Announcements and programs broadcast through the media corporations,

• Electronic data distribution channels,

• Fax and electronic mail,

• GSM communication (WAP and similar technology).

*Meetings may be held face-to-face, via telephone or by tele-conference. 

Scope of the Disclosure Policy

Providing they do not involve trade secrets or inhibit the competitive power of the Company, questions posed by shareholders and stakeholders are answered within a maximum of five business days. Only those financial and legal occurrences or other situations that seem likely to occur that might affect 5% of assets are disclosed to the public. Public disclosures are made by submitting a special circumstance disclosure form to the Istanbul Stock Exchange and publishing the disclosure on the corporate Internet site. 

Corporate Website

Aksa's corporate website is: www.aksa.com. Aksa makes effective use of the corporate website in making public disclosures and in ensuring transparency. All information disclosed to the public is also accessible on the website, configured and arranged in a user-friendly manner. The Aksa website includes information required by the Capital Markets Corporate Governance Principles. It is constantly updated and efforts are ongoing to regularly incorporate security measures that prevent tampering with data published on the site. Disclosures made on the Corporate Internet site are not a substitute for the notifications and special circumstance announcements that are required by the provisions of Capital Market Regulations. 

Shareholder Relations Department

Since relationships with shareholders are handled by the offices of the Assistant General Manager of Finance, a separate department for this purpose has not been established. An electronic mail address (yatirimciiliskileri@aksa. com) has been designated for communications with shareholders. Questions addressed to Aksa by telephone, fax, electronic mail or other means are answered by the Assistant General Manager of Finance or his/her appointed representative, in writing or verbally, within a maximum of five business days. 

Public Disclosure of Financial Statements

After being submitted to the ISE as attachments to the documents required by law, periodic financial statements of the Company are published on the corporate website within two business days. In addition, annual financial statements are also submitted to shareholders in the Annual Report. 

Public Disclosure of the Annual Report

The Annual Report, prepared in accordance with the Turkish Commercial Code, Capital Market Regulations and Capital Market Corporate Governance Principles, is published on the corporate website within a maximum of 15 days prior to the date of the Ordinary Meeting of Shareholders. In addition, shareholders and stakeholders who wish to do so may request a printed annual report by telephone from the office of the Assistant General Manager of Finance or by contacting Aksa via yatirimciiliskileri@aksa.com. 

Public Disclosure of Special Circumstance

Disclosure Forms In cases where the circumstances specified in the Capital Market Board's published "Communiqué on the Principles of Public Disclosure of Special Circumstances" have taken place, these disclosures are first submitted to the ISE and then published on the corporate website within the following two days. 

Public Disclosure of General Meetings of Shareholders

In addition to those announcements foreseen by legal regulations, the date, time, agenda and sample of a letter of proxy are published on the corporate website at latest fifteen days before the date of the General Meeting of Shareholders.

Meetings with Shareholders and Potential Investors

Requests received from shareholders and potential investors are answered periodically on a quarterly basis or when requests come in during interim periods, at a special meeting and/or by electronic mail. Additionally, the Company may conduct a Road Show at least once a year to promote the Company to foreign investors abroad and provide information about the Company's strategic and financial status. This information however, may not be different than what has been previously disclosed to the public. In other words, the information must be that which has already been released to the public.

Meetings with Banks, Financial Enterprises and Brokerage Firms

Written or oral requests received from banks and financial enterprises or brokerage firms are answered on a quarterly basis or when requests come in at interim periods, at a meeting and/or by electronic mail. An effort is made to keep stakeholders and potential investors informed about the Company's financial status and its strategic and financial goals through brokerage firms. This information however, may not be different than what has been previously disclosed to the public. In other words, the information must be that which has already been released to the public. 

Announcements, Interviews, etc. Conducted through the Media

An effort is made to keep stakeholders and potential investors informed about the Company's financial status and its strategic and financial goals through the various channels of the media. Communications with the media are handled with the approval of the General Manager. Media requests for interviews are answered by the General Manager or by the person delegated to do so by the General Manager. The information provided in the interview however, may not be different than what has been previously disclosed to the public. In other words, the information must be that which has already been released to the public.

Code of Ethics

The Company Code of Ethics is disclosed to the public through publication on the corporate website within two business days of its approval by the Aksa Board of Directors. In the event that any changes are made to the Code of Ethics, these changes are also published on the corporate website subsequent to the Board's approval 

Dividend Distribution Policy

The profit distribution policy developed by the Aksa Board of Directors is presented to the General Meeting of Shareholders and included in the annual report. It is subsequently published on the corporate website within two business days following the General Meeting. In the event that any changes are made in the Dividend Distribution Policy, those changes are presented to the General Meeting of Shareholders after approval by the Board and are subsequently published on the corporate website. 

Insider Trading

In order to prevent insider trading, that is, the use of information not as yet made public, the names of management, employees and other persons/organizations that are in a position to be privy to such information that may affect the value of capital market instruments are listed by the Assistant General Manager of Finance and published on the corporate website.  

Disclosures of Future Activities

Within the scope of its disclosure policy, Aksa may disclose its future expectations to the public, if deemed necessary. Disclosure of future activities is subject to the approval of the Board of Directors and carried out only by those persons authorized to make public disclosures. Future expectations that are disclosed to the public are announced together with the grounds and reasons for these expectations with accompanying statistical data. This information may not contain exaggerations, may not be misleading and under all circumstances, must be associated with the Company's financial standing and operational results. The utmost care is also taken to ensure that disclosure to the public of the results of audits conducted by independent auditors and disclosure of information on future activities are consistent with international standards. If any disclosed projections for the future are not later realized, the revised data, tables and reports, along with the grounds on which they are based, are then announced to the public. 

Other Disclosures

In the event that sale/purchase transactions conducted in the last one year or net positions in derivative products based on Aksa shares owned by members of the Board, executives or shareholders, who possess 5% of the Company's capital either directly or indirectly, exceed 1% of their direct or indirect holdings in the Company, this information is published on the website.

The Company reserves the right not to make disclosures to the public about rumors in the press or unfounded news stories based on unfounded information.Persons authorized to make disclosures to the public may speak on behalf of Aksa at conferences, panels, sessions, interviews and the like. The information imparted in such talks however, may not be different than what has been previously disclosed to the public. In other words, the information must be that which has already been released to the public.

Since joint efforts with the Public Disclosure Platform (KAP), the SPK-ISE-TÜBİTAK Information Technology and the Electronic Research Institute (BİLTEN) are still in the testing stage, at the moment financial statements, special circumstance disclosures and other notifications sent to the ISE are electronically mailed to KAP on the first business day after the information is published in the daily bulletin, within the framework of the regulations set down by the authorized institution. With the completion of the KAP project, documents and information heretofore sent in hard copy form will be from then on signed by authorized persons and delivered in electronic format. Written statements, disclosures and similar announcements submitted by authorized persons are valid only if they bear two signatures under the Company seal. 

Persons Authorized to Make Disclosures

The following persons are entitled to respond to any questions and disclosure requests concerning Aksa management, activities, financial data or the sector:

• Chairman and Members of the Board,

• General Manager,

• Coordinator,

• Assistant General Manager of Finance,

• Accounting Manager,

• Assistant Accounting Manager. Unless a special appointment is made, no employees other than those listed above are authorized to respond to questions.