POLICY OF PREVENTING LAUNDERING OF CRIME INCOME AND FINANCING OF TERROR

Cem Ofset Matbaacılık San.Tic. A.Ş (hereinafter referred to as “Cem Ofset”) aims to support all efforts both nationally and internationally in the fight against money laundering, financing of terrorism and other related crimes, and to comply with all laws and other legal regulations. Money laundering can be defined as concealing the illegal source of the proceeds obtained from crime. The money laundering process generally consists of 3 stages:

 Placement (putting the proceeds of crime into the financial system)

Separation (removing the proceeds of crime from its source)

Integration (the introduction of the fund that has been disconnected from its illegal source into the financial system in a laundered manner)

Business institutions can be used at any stage of the money laundering process. Even if it is not intended, there is a risk of damaging the reputation of an organization involved in money laundering. Cem Ofset’s basic principles in trade are listed below;

 Compliance with all legal regulations,

Cooperating with regulatory authorities in national and international context,

Compliance with ethical business principles.

Cem Ofset is audited by the Ministry of Finance and complies with legal regulations. Another purpose of the legal regulations is to prevent money laundering and financing of terrorism and to determine the principles to be applied in these matters.

Cem Ofset, in other countries where in both in Turkey activities of laundering proceeds of crime prevention of terrorism financing and laundering of the proceeds of crime to ensure compliance with regulations on the prevention of other related criminal activity develops programs and implements. This program;

 Written policies and procedures,

The control that will test the effectiveness and developments of the program in practice,

Both Turkey and other countries operating current legislation to take appropriate actions show that guarantee the internal audit and control systems,

To provide training to relevant personnel on the subject covers.

The Policies and Procedures are briefly as follows;

’Know Your Customer’’ Principle:

To have accurate and sufficient information about customers, to monitor transactions, to monitor whether the activities of customers and / or suppliers are compatible with income, assets, occupation information, etc. “Know Your Customer” is the basis of CEM OFSET’s customer acceptance policy on the prevention of money laundering and terrorist financing. Great importance is attached to the principle of “Know Your Customer” in order to be protected from persons and acts associated with money laundering and terrorist financing; In this context, it is implemented by adopting a policy in line with the relevant international standards and applicable legislation. In terms of CEM OFSET, the basic precondition for establishing a continuous business relationship with customers and performing transactions; Identification of customers and / or suppliers in a timely, complete and correct manner within the framework of current legislation and company policy and procedures.

Establishing a Business Relationship:

No business relationship is entered into with customers and / or suppliers without providing the necessary information and documents. No business relationships are entered into with anonymous and code names. Black list checks are made at customer acceptance

Casing:

Records of customer information and documents and transactions are kept for 8 years.

National and International Cooperation:

It works in cooperation with regulatory authorities when necessary.

Organization: Within the body of CEM OFSET, the applications related to the activities are evaluated by getting support from the relevant units regarding financial, administrative and legal issues.

Compliance Officer: A Compliance Officer works in CEM OFSET to ensure that the activities are carried out in compliance with the legislation and sector rules and principles. Compliance Officer; to carry out the necessary work to ensure compliance with regulations, to ensure communication and coordination, to ensure the implementation of the compliance program; To manage evaluation, monitoring and control activities and to follow the results of training activities, to submit the studies on the training program for laundering proceeds of crime and the prevention of terrorism financing for the approval of the Board of Directors, and to ensure the effective implementation of the approved training program, about transactions that may have been communicated to him or that may be suspicious he learned conducts research and evaluations and reports any transactions deemed suspicious to the General Manager. While performing these duties, the Compliance Officer works in cooperation with the Finance, Operations and Legal Consultants, and accordingly meets with the relevant persons at certain periods and evaluates the works. Suspicious transaction reports is maintained in the state’s maximum privacy notices that are designated for people with maximum security measures notified by the Republic of Turkey Laws. Company employees carry out transactions with the assurance that they do not face any negative approach or sanctions due to their compliant behavior and work in consultation with the Compliance Officer.

 Following the recommendations, principles, standards and guidelines provided by the national legislation and international organizations regarding the subjects within the scope of risk and carrying out the necessary development studies, – For the groups determined as high risk as a result of the risk assessment, additional measures are taken as a minimum to reduce the risk to be undertaken: o Developing procedures for continuous monitoring of transactions and customers, o Entering into a business relationship, maintaining the current business relationship or binding the execution of the transaction to the approval of the senior management o Obtaining as much information as possible about the purpose of the transaction and the source of the assets subject to the transaction, o Providing additional information and documents within the scope of knowing the customer, taking additional measures to confirm and authenticate the information provided. – The following countries and regions as well as the customers residing or associated with these countries and regions, suppliers are closely monitored within the high risk category in terms of country risk