Purpose and Scope
The purpose of this policy is to carry out operations without harm to people or the environment, without loss or accidents, as part of the Enderpen community; and to continuously support laws and regulations related to "Occupational Health and Safety" in terms of workflow conditions. Protecting human resources—which is a fundamental right socially and an inevitable necessity economically—is a key condition for human and societal well-being.

This policy applies to all Enderpen and affiliated company employees, subcontractors/suppliers, and visitors.

Objective
Our goal in occupational health and safety efforts is to ensure that adequate safety measures are taken at Enderpen and affiliated company workplaces to protect employees. This includes enhancing employees' medical, physical, and psychological well-being, eliminating harmful factors in the workplace through hygienic measures, ensuring compatibility between work and worker, detecting occupational diseases and health issues, ensuring treatment, objectively and scientifically assessing the degree of harm encountered, ensuring workplace safety, preventing possible accidents, and increasing productivity.

Responsibilities
Employees, subcontractors/supplier personnel, and visitors at Enderpen workplaces and facilities are responsible for complying with this policy. Everyone is obliged to take necessary actions within their authority to maintain a healthy and safe working environment.

Policy Commitments
Occupational health and safety practices are to be carried out in compliance with legal regulations and evolving conditions, aligning with legislation and standards, and with the goal of continuously improving employee performance. Enderpen is committed to taking all necessary precautions in its workplace and related facilities in line with current OHS regulations and other health and safety requirements, including providing tools, equipment, and personal protective gear, and ensuring their proper use when needed.

With the rapid advancement of industry and technology and the emergence of new job sectors, our core objective is to prevent threats to employee health and safety by taking sufficient precautions and mitigating risks caused by technical equipment and working conditions. All employees receive training on occupational health and safety during onboarding and at regular intervals throughout their employment, and a training participation certificate is issued for each employee.

Our aim is to regularly review our occupational health and safety systems and practices based on the human-focused principle of “All accidents and occupational diseases are preventable,” and to raise awareness among employees in order to achieve our zero-accident and zero-occupational-disease target. This proactive approach focuses on preventing and identifying risks and crises early during operations. Through risk analysis, continuous improvement, and training, potential crises are minimized. Risk analysis helps identify and reduce potential crises, preventing their occurrence.

Employee Right to Occupational Safety
The right to occupational safety is the workplace manifestation of the universal rights to life, physical integrity, and health. In line with industrialization and technological development in both Turkey and the world, necessary precautions are taken in advance to eliminate issues related to employee safety at our workplaces.

Review
Accordingly, we commit to maintaining the continuity of our Occupational Health and Safety Management System through periodic objectives and reviews, and we declare this as our Occupational Health and Safety Policy.

Information Security Policy

Purpose
The purpose of the Information Security Policy is to ensure the business continuity of Ender PVC Construction Elements Industry and Trade Inc. and to prevent information security incidents or minimize the risk of damage by reducing the impact of potential threats.

In this context, the establishment of an Information Security Management System (ISMS) compliant with the ISO 27001:2013 standard has been targeted.

Scope
This policy covers the information assets within Ender PVC Construction Elements Industry and Trade Inc. It is applicable to all employees at all company locations, as well as to internal and external suppliers/contractors.

Responsibility
Within the scope of this policy, the Information Security Management Board is responsible for ensuring the confidentiality, integrity, and availability of the company’s information assets, and for keeping process-related risks at an acceptable level as approved by senior management. The Board is also responsible for ensuring that the Information Security Management System is established and operated in accordance with the ISO 27001:2013 standard. Compliance with the requirements of the Personal Data Protection Law (KVKK) is also included in these responsibilities.

Policy
The goal of the policy is to protect the company’s information assets—including both internal data and data shared by stakeholders—against intentional or unintentional threats from both internal and external sources.
This policy has been approved by the Coordinator of Ender PVC Construction Elements Industry and Trade Inc.

The Information Security Policy ensures the following requirements:

Identification of processes and information assets, and conducting related risk assessments using a methodological approach

Protection of information from unauthorized access

Ensuring the confidentiality of information

Preserving the integrity of information

Ensuring information is accessible whenever business processes require it

Fulfillment of legal obligations and contractual commitments

Development and continuous improvement of business continuity plans

Provision of Information Security training to all employees

Reporting and investigation of all Information Security breaches or suspected breaches to the Information Security Management Board

Procedures and associated instructions have been defined to support this policy.
Information Security is ensured in line with business requirements.
The Information Security Management Board ensures the development, documentation, and continuous improvement of this policy and all related documents within the Information Security Management System.
All levels of management are responsible for ensuring that their departments comply with this policy and its related procedures.
Compliance with the Information Security Policy is mandatory for all employees.

Masterline PVC

By using lead-free raw materials in its production processes, Masterline prioritizes quality in doors and windows across all seasons, while maintaining an environmentally friendly approach.

Our Main Objectives:

With years of experience in the industry, our primary goal is to deliver the principle of "Quality in Product and Service" in accordance with Quality Management System standards and requirements, providing the best conditions for our customers.

In today’s world where competition is rapidly increasing both globally and nationally, we aim to uphold our reputation by standing behind our promises and becoming the preferred brand for consumers in both domestic and international markets.

To enhance stakeholder satisfaction, we use calcium-zinc-based stabilizers to ensure our profiles always have a bright appearance and maintain their technical and optical shine for a long time.

To provide a healthy and safe working environment.

To define objectives that eliminate hazards and reduce risks.

To follow technological developments and innovations with a goal of continuous improvement.

To encourage participation from all employees by listening to their ideas through meetings and assigning responsibility to each individual to raise awareness.

To proactively manage occupational health and safety risks in accordance with all relevant legal regulations and standards.

In this context, every Masterline PVC employee:

Values quality and product safety,

Focuses on high-performance targets,

Implements process-oriented and innovative operational methods,

Maintains the habit of continuous improvement based on regular review.

PURPOSE
The purpose of this Code of Ethics is to define the principles and rules that all managers and employees of Masterline PVC Building Components Industry and Trade Inc. must comply with in order to add financial value for shareholders and increase the corporate value of the company. These rules aim to ensure that all Masterline managers and employees exhibit high standards of behavior, remain aware of the institutional impact of their conduct and attitudes, apply the most accurate methods, and display the highest quality conduct. All members of the Board of Directors, managers, and employees are expected to comply with the Masterline Code of Ethics outlined below.

SCOPE
The Code of Ethics applies to all employees within Masterline and its affiliated companies. It is both essential and mandatory for every employee to adhere to these principles. Implementation of these principles is the guarantee of the excellence that Masterline strives to achieve. The principles are broad and general in nature and provide the minimum required standard.

RESPONSIBILITY
Creating an environment in line with ethical principles is the responsibility of our managers. Accordingly, members of the Board of Directors and all managers must first acknowledge the importance of these ethical principles and adhere to them. Through their behavior and actions, they set an example for others, take responsibility for embedding and sustaining these principles in their respective departments, and work toward establishing a company culture where norms, values, and principles are instilled and adopted. They ensure that employees have an open communication environment regarding company operations and ethical issues. In their decisions and actions, they always demonstrate honesty and integrity, particularly in the presence of actual or potential conflicts of interest between personal gain and their responsibilities to the company. Any known or suspected violation of the ethical principles must be reported immediately to the Ethics Committee.

In addition, members of the Board of Directors, Group Presidents, and Human Resources Managers/Staff are assigned to support the enforcement of the Masterline Code of Ethics.

If any uncertainty arises regarding the implementation of a principle in a specific situation, the issue must be escalated to a higher-level manager.

Any Masterline employee with questions or comments regarding the principles—whether case-specific or applicable to present or future situations—must initiate internal communication within the company.

4.1. GENERAL RULES
4.1.1. Integrity
Accuracy and honesty are our core values in all our business processes and relationships. We act with transparency and integrity in our interactions with employees and all stakeholders.

4.1.2. Respect for Law
We conduct all our activities in compliance with legal regulations. Employees are not permitted to engage in any illegal activity under the assumption that it serves company or personal interests. Accuracy and legality in financial and commercial records are essential. If there is legal uncertainty regarding any matter, it should be referred to the Ethics Committee, the Group President, or the Legal Director.

4.1.3. Confidentiality
Confidential information includes company-owned data unknown to third parties, which, if disclosed, could harm Masterline and/or its stakeholders or benefit others. This includes financial, strategic, technical, commercial information, employee personal rights, and information under confidentiality agreements with third parties. Our employees are expected to protect this confidential information and use it only for company-related purposes. Information belonging to Masterline and its stakeholders must be safeguarded carefully. Employees must share such information only with authorized individuals within the defined scope. Confidential information cannot be used for personal gain, including insider trading. Employees must not disclose any confidential information even after leaving the company. All confidential documents or digital files received during employment must be returned upon departure. Official statements are announced to investors, shareholders, and the public through designated Masterline units based on the principle of equality, completeness, simultaneity, and clarity.

4.1.4. Personal Securities Investments
While managing personal investments, employees must avoid buying shares or investment instruments of companies that may create a conflict of interest with their responsibilities at Masterline. Individuals who have access to non-public information are prohibited from using such information for personal or third-party gain (insider trading). Persons who may engage in insider trading include members of the Board of Directors of a publicly traded company, managers (those at or above the director level), auditors, and those who may have access to insider information due to their profession or proximity. These individuals may trade Masterline company shares only based on publicly disclosed information and for investment purposes (holding for more than 3 months qualifies as an investment). Other Masterline employees may freely trade company shares using publicly disclosed information with no holding period restriction. These rules also apply to employees' spouses and children, whose actions are considered as if performed by the employees themselves.
4.2. USE OF COMPANY RESOURCES
All financial and non-financial resources of the company must be used with utmost care. These resources may not be used for personal purposes such as private spending, gifting, donations, or political contributions.

4.2.1. Office Supplies and Equipment
Office supplies, printed materials, and all types of company-owned equipment may only be used for company-related work and must not be taken outside the company. Resource-saving practices must be followed during use. Upon departure, employees must return all items entrusted to them—including documents and equipment—through a formal handover process.

4.2.2. Communication Tools
Email must be used solely as a means of business communication and should not be used for personal reasons. Employees are encouraged to prefer email over phone calls whenever possible. Fax machines, photocopiers, internet, and similar tools should not be used for personal purposes.

4.2.3. Company Vehicles
Employees who are assigned a company vehicle must use it with care and attention. Traffic fines are to be paid from the employee’s own budget. Employees may not request reimbursement from the company for damages caused by their own negligence.

4.2.4. Workspaces
Company buildings may not be used for buying or selling goods or services unrelated to the company’s field of operation. Outside working hours, no documents or materials that could be considered confidential may be left on desks or exposed. The following rules apply to the use of Masterline office premises:

Posters or handwritten notes may not be displayed.

Political or campaign activities are prohibited, and no fundraising may be conducted for such purposes.

Publications that are illegal or contrary to company policies may not be distributed.

Harmful items such as alcohol, drugs, or weapons may not be kept on the premises.

Confidential and critical documents under the employee’s responsibility must not be left on desks or cabinets at any time, whether during or outside working hours.

Workspaces must be kept tidy and orderly.

Gambling or lottery tickets may not be played, distributed, or sold.

4.2.5. Representation Expenses
Representation expenses are to be used for customer and business meetings. These expenses must be used only for their intended purposes, and funds cannot be transferred between expense categories.

4.2.6. Giving Gifts or Making Donations on Behalf of the Company
In accordance with the principles set by company management, gifts may be given on behalf of the company as long as they are in line with institutional goals, comply with current legislation, and would not put Masterline in a difficult position if made public. Gift and promotional materials to be given to third parties with whom there is a business relationship must be approved by senior management; once approved, no further permission is required for distribution.

4.2.7. Time Management
Time is one of the company’s most valuable resources. Employees must use time efficiently and refrain from conducting personal business during working hours. Managers may not assign employees tasks for their own personal matters. The organizer of a meeting is responsible for ensuring time is used effectively. All participants must come prepared, and scheduled start and end times must be respected by everyone involved.
4.3. RELATIONSHIPS
4.3.1. Relations with Clients, Institutions, and Organizations Engaged in Business with the Company
All employees must act truthfully, consistently, reliably, helpfully, and punctually in their relationships with individuals and entities doing business with the company, including our customers. Business agreements made with these parties must be conducted in accordance with relevant legislation, company policies, and procedures. The following principles must be considered when drafting such agreements:

Business partners are selected based on company policies and objective criteria.

All operations are carried out in line with established procedures.

Before signing contracts or protocols, legal counsel and related departments must be consulted.

Selection of suppliers or partners must be made objectively, without external influence, and based on benefit/cost and performance criteria.

4.3.2. Relations with the Media
Statements to any media outlet, interviews, or participation as a speaker at seminars or conferences require prior approval from senior management. No personal financial benefit can be obtained from such activities.

4.3.3. Relations with Public Authorities
Relations with public institutions and regulatory authorities must be conducted in accordance with the law and company policies/procedures. All information requested by official authorities must be accurate and provided in a timely manner.

4.3.4. Shareholders
As Masterline, our main goal is to create sustainable economic value for all our stakeholders. In this regard, our objective is to safeguard the interests of all shareholders. Partnerships and business relationships are built on long-term structures based on trust. In internal company operations, stakeholder rights and interests must be treated equally and fairly. The aim is to create value for all stakeholders. All corporate activities must be conducted within a framework of financial discipline and accountability. Communications to shareholders and the public—including financial statements, strategies, and investment plans—must be accurate, timely, complete, and understandable.
4.4. OBLIGATIONS TOWARD THE COMPANY
4.4.1. Acceptance of Gifts, Invitations, Donations, and Contributions
Gifts: Employees may not request or imply the desire for gifts from customers, subcontractors, or suppliers. No gift, money, check, property, free vacation, or special discount that would impose an obligation on the company or the recipient may be accepted. Gifts exceeding a value of 50 TL that are not expected to influence decision-making may only be accepted with prior notification to a superior. In any case, the total value of such acceptable gifts may not exceed 500 TL.

Invitations: Employees may participate in business meetings and events—provided these do not influence their decisions and do not conflict with company policies or interests—only with verbal or written approval from a superior.

Donations and Contributions: No donations or contributions may be accepted from individuals or organizations with whom the company has a business relationship. All offers of donations or contributions must be reported to upper management.

4.4.2. Avoiding Conflicts of Interest
A conflict of interest arises when personal interests conflict with company interests or those between customers and suppliers. Masterline employees must avoid activities that may lead to such conflicts. Using company resources, name, or influence for personal benefit, or engaging in conduct that may damage the company’s name and reputation, is strictly prohibited.

Employees, managers, and board members must refrain from any initiative that could provide benefits to themselves or their close relations. Company positions, assets, and confidential information may not be used for personal gain. Employees may not obtain private advantages from customers or suppliers, nor may they act as intermediaries for such benefits. In cases of potential conflict, equal and fair treatment must be ensured for all parties involved. Employees must act impartially and are expected to follow the rules below to prevent conflicts of interest:

Avoid entering into debtor-creditor relationships with customers/suppliers or accepting/co-signing for such obligations.

Do not attend events, trips, or vacations fully or partially funded by customers/suppliers without prior approval from a superior.

Do not accept inappropriate or unusually valuable gifts or favors from customers/suppliers or use authority to gain special privileges (e.g., significant discounts).

Avoid engaging in business relationships with spouses, relatives, or close friends without upper management’s approval if it benefits the company.

Avoid influencing promotion or reward decisions involving spouses or close relatives within the company or its affiliates.

4.4.3. Working Outside the Company
Employees may not accept any official or private duty, whether temporary or permanent, paid or unpaid, without formal permission from the company. They are also not allowed to engage in trade or run their own business.

4.4.4. Protection of Health, Safety, and the Environment
Managers and employees must act with due diligence to ensure that all company operations are conducted in a way that is healthiest, safest, and least harmful to the environment.

4.4.5. Non-Discrimination
Managers and employees must act fairly and equally toward all individuals, without prejudice, and must not tolerate any form of harassment. No one may be subjected to discriminatory treatment based on age, language, race, nationality, health status, gender, marital status, religion, sect, political opinion, or philosophical belief. Violations of these principles may result in disciplinary action up to and including termination of employment. Employees may submit complaints directly to the Human Resources Department, bypassing their first and second-line supervisors if necessary.

4.4.6. Personal Aid and Donations
Company employees are free to provide personal financial or moral aid, make donations, or participate in charitable organizations outside of company responsibilities.
5. RESOLVING NON-COMPLIANCE WITH THE CODE OF ETHICS
Employees who violate the Code of Ethics, or the company’s policies and procedures, may be subject to various disciplinary actions, including possible termination of employment. These disciplinary actions also apply to those who condone or direct unethical behavior, or who are aware of such violations and fail to report them appropriately.

5.1. ETHICS COMMITTEES
5.1.1. Masterline Ethics Committee
The Ethics Committee consists of a Member of the Masterline Board of Directors, the Group President or Vice President, the Human Resources Director, the Legal Director, and the Audit Director. The Human Resources Department serves as the secretary of the committee. New members may be added or removed with the approval of the Committee Chair, who is the Chairman or Vice Chairman of the Board of Directors. Committee decisions are implemented with the approval of the Chair or Vice Chair of the Board.

For cases involving employees below the managerial level, the Masterline Ethics Committee is formed by the relevant Department Head, the Human Resources Director, the Legal Director, and the Audit Director. New members may be appointed with the approval of the Committee Chair.

5.1.2. Company Ethics Committee
The Company Ethics Committee is chaired by the Plant Manager appointed by the relevant Group President or their designee and includes the Human Resources Manager, an auditor appointed by the Audit Director, and a company or contract-based lawyer (depending on availability). New members may be added with the approval of the Senior Company Executive. Preference is given to members with direct relevance to the issue or department.

This committee is responsible for handling matters involving employees below the managerial level. The secretary of the committee is appointed by the Senior Company Executive.

5.2. DUTIES OF THE ETHICS COMMITTEE
The Ethics Committee is responsible for investigating and resolving complaints and reports regarding violations of the Masterline Code of Ethics.

5.3. PRINCIPLES OF MEETINGS AND DECISIONS
If a violation of the Code of Ethics occurs or becomes known in any unit of the group/company, it must be reported in writing or via email to the Human Resources Department through the appropriate supervisor. External reports may also be submitted via email to info@masterline.com.tr.

Upon receiving a report, the Human Resources Department must convene the Ethics Committee in writing within 6 business days. If the case requires disciplinary action, the Committee must meet within 6 business days and initiate an investigation if necessary. Once the investigation is complete, the Committee reconvenes to make a decision. Decisions are implemented and recorded in the decision log. Decisions are made by majority vote. In case of a tie, the vote of the Committee Chair counts as two. Within 6 business days following the decision, the result must be communicated to the employee and any necessary actions must be taken. Until a decision is made, the employee is presumed innocent and the employer is considered unaware of the issue.

5.4. AUTHORITY OF THE ETHICS COMMITTEE
To properly evaluate and conclude investigations, the Ethics Committee has the authority to:
a) Review the personnel file of the involved employee,
b) Request or receive information from relevant authorities,
c) Interview witnesses and experts directly,
d) Obtain a defense statement from the person under investigation,
e) Conduct any other necessary examination or research.

The Committee may seek expert opinions and take necessary precautions to preserve confidentiality throughout the investigation.

ENFORCEMENT
This Code of Ethics has been in effect since January 7, 2016. Any matters not explicitly mentioned in this document shall be handled in line with the views and guidance of the Senior Management.

PUBLIC DISCLOSURE
The Masterline Code of Ethics must be made publicly available and accessible to all employees. The same obligations apply in the case of any updates or changes to the code.

Masterline’s Commitment to Sustainability
At Masterline, we adopt an environmentally conscious approach in the production of PVC door and window systems, placing sustainability at the core of our business strategy. In line with the European Union Green Deal and the United Nations Sustainable Development Goals, we integrate environmental, social, and economic sustainability into all our operations. Through comprehensive strategies in emission control, water and energy management, waste reduction, and social responsibility, we work toward a more sustainable future.

01 — Compliance with the EU Green Deal
Aligned with the goals of the European Union Green Deal, Masterline aims to build a carbon-neutral production model for PVC door and window systems. We are committed to reducing our carbon footprint through renewable energy use, energy efficiency practices, and emission reduction technologies. Our products follow circular economy principles and are designed with sustainability in mind.

02 — Supporting the UN Sustainable Development Goals
We incorporate the UN Sustainable Development Goals (SDGs) into our strategic roadmap—especially SDG 9 (Industry, Innovation, and Infrastructure), SDG 12 (Responsible Consumption and Production), and SDG 13 (Climate Action). Our manufacturing processes emphasize eco-friendly production, energy and resource efficiency, and continuous environmental improvement.

03 — Emission Management
We actively monitor emission sources and implement innovative solutions to minimize greenhouse gas emissions. We invest in renewable energy and low-carbon technologies and support carbon offset projects to neutralize any remaining impact.

04 — Energy Management
By implementing advanced technologies in our production lines, we maximize energy efficiency and reduce consumption. Our solar panel systems convert operational energy usage into green energy. These efforts help us minimize environmental impact and support sustainable production.

05 — Water Management
We apply smart water management systems to minimize water consumption throughout production. Recycling and monitoring practices help protect water resources and reduce waste.

06 — Waste Management
We incorporate recycling practices across all PVC production processes. By reusing production waste and minimizing overall output, we operate under a zero-waste philosophy. All hazardous and non-hazardous waste is handled in compliance with regulations.

07 — Eco-Friendly PVC Products
Our products are developed using sustainable materials. Masterline’s PVC systems stand out for being durable, recyclable, and energy efficient, helping customers live more sustainably.

Social Sustainability
08 — Social Responsibility as a Business Value
At Masterline, social sustainability is a fundamental element of our corporate model. We are deeply committed to human rights, occupational health and safety, ethical business conduct, and community engagement.

09 — Human Rights
We promote and protect human rights throughout our value chain. We foster an inclusive and discrimination-free workplace, and we apply a zero-tolerance policy against any violations.

10 — Occupational Health and Safety
Ensuring a safe and healthy work environment is a top priority. Through regular training and inspections, we take all necessary precautions to prevent accidents and protect employee well-being.

11 — Business Ethics
Ethical conduct is at the core of Masterline’s values. We act with integrity, transparency, and fairness in all our business dealings. We also encourage ethical behavior among employees through ongoing guidance and training.

12 — Community Engagement and Social Impact
We see social responsibility as a duty. From education to healthcare, and from environmental initiatives to local development, we support impactful projects. One of our key contributions is the construction of a 32-classroom school in Şehitkamil, Gaziantep, reflecting our commitment to education and long-term community value.

As the Masterline family, we proudly manufacture from our facilities in Gaziantep and Ankara, delivering our high-quality PVC products to numerous countries around the world.

Thanks to our ongoing commitment to continuous improvement, innovation, and R&D, we are recognized as one of the leading companies in the industry.

Our professional teams work with cutting-edge technologies, maintaining a strong focus on customer satisfaction and sustainability—all in alignment with the evolving demands of the modern era.

In this context, Masterline collaborates with some of the industry's most respected global brands, including Weber, KraussMaffei, Greiner, Renolit, LG, Henkel, and Trinity.

Our fully automated, state-of-the-art facilities are designed to support environmentally responsible production. Through initiatives such as our Solar Power Plant (GES) project, efforts to reduce carbon footprint, and green energy solutions, we lead the way in sustainability. We produce our new generation insulated sliding systems without the use of lead or heavy metals—demonstrating our commitment to health, safety, and the environment.

As the Masterline family, we proudly manufacture from our facilities in Gaziantep and Ankara, delivering our high-quality PVC products to numerous countries around the world.

Thanks to our ongoing commitment to continuous improvement, innovation, and R&D, we are recognized as one of the leading companies in the industry.

Our professional teams work with cutting-edge technologies, maintaining a strong focus on customer satisfaction and sustainability—all in alignment with the evolving demands of the modern era.

In this context, Masterline collaborates with some of the industry's most respected global brands, including Weber, KraussMaffei, Greiner, Renolit, LG, Henkel, and Trinity.

Our fully automated, state-of-the-art facilities are designed to support environmentally responsible production. Through initiatives such as our Solar Power Plant (GES) project, efforts to reduce carbon footprint, and green energy solutions, we lead the way in sustainability. We produce our new generation insulated sliding systems without the use of lead or heavy metals—demonstrating our commitment to health, safety, and the environment.