Cullinan Belek

We operate with an open vision of the global market by developing innovative services. We guide the strategies of our Hotel and conduct our activities within the framework of our principles of equality, transparency, and clarity. Through our central management team and hotel managers, we provide ideas, question, guide, and oversee our hotel; however, we adopt an approach that does not interfere directly with operational activities. Additionally, we facilitate and support collaboration for proposals set by our hotel. Our Sustainability Management follows a similar process, advancing with the support and guidance of central management alongside Sustainability teams led by General Managers and Quality Managers in our hotel.

Cullinan Hotel has adopted as its quality policy the aim of raising Turkey's profile globally, being renowned as an exemplary institution in all its operations, and continuously developing its business volume alongside quality. We are always in a state of continuous improvement to be better. We measure and enhance our service quality to take steps that ensure the satisfaction of all internal and external stakeholders, and we view contributing to individual competencies through training as the most important part of the whole, believing in the power of continuous learning. To create spaces where guests and staff feel safe, we construct facilities that comply with all national and global environmental laws, occupational health and safety regulations, building safety standards, and human rights legislation, while regularly conducting necessary controls and reviews.

Our Food Safety Policy aims to prepare and present the finest flavors of traditional Turkish and world cuisines in accordance with hygiene rules, meeting the expectations of guests and staff through the Cullinan Quality Management System (CQM) and trained personnel. All processes, from food acceptance to consumption, are kept under control. While ensuring safety, we take preventive measures to reduce costs and increase profitability by following technological developments and minimizing resource usage, also incorporating suppliers into our auditing and training processes to support local producers' awareness of safe food.

Our Environmental and Sustainability Policy at Cullinan Hotel evaluates the environmental impacts of all institutional steps and strives to continue with options that minimize negative outcomes, aiming to eliminate them whenever possible, while contributing to the development of local communities in all our activities. We work to use energy resources as efficiently as possible and minimize waste generation, guiding our employees and guests toward awareness. We aim to reduce the use of natural resources and increase the use of recycled products. We are prepared for risks related to pollution and emergencies (fire, explosion, flood, earthquake, leakage, etc.) and comply with environmental legal regulations.

Hotel management requires the use of significant natural resources. We take this responsibility seriously and incorporate environmental management into key roles across the organization. We strive to meet the high standards required for the Sustainable Development Goals in our hotel. We closely monitor current action plans and continuously improve our management by reviewing our environmental performance with each innovation. We consider it our responsibility to help our guests become more environmentally friendly.

To enhance our competitiveness, we implement a range of waste reduction programs across all operational departments in our Hotel under the motto “Zero Waste.” This initiative aims to transition to a circular economy, prevent waste, protect the environment, reduce pollution, raise public awareness, and promote an eco-friendly lifestyle for the future. When waste is unavoidable, we ensure the separation of waste, with particular attention to hazardous waste, for recycling and proper disposal. We provide regular training to our employees to ensure the ongoing integration of waste reduction practices and to encourage suggestions for change.

Global warming, an aging population, rapid urbanization, depleting resources, economic fluctuations, and digitalization. We are aware that these factors have global impacts and that we need to reduce our environmental footprint amidst the rapid changes we are experiencing. Turkey's primary goal in the global fight against climate change is “to participate in international efforts, defined by common sense in light of neutral and scientific findings, in collaboration with international parties to prevent climate change, in line with sustainable development policies, and according to the principle of common but differentiated responsibilities, considering Turkey's specific circumstances.” We will strive to set targets aligned with our country's goals, working with the government, the private sector, local authorities, and civil society organizations to produce common solutions, and we will share our institutional activities and objectives with the public.

In order to move towards carbon offsetting and ultimately zero carbon initiatives, we will track our consumption and prefer products produced using climate-friendly methods, fuel-efficient vehicles, high-energy efficiency technologies, and energy sources that produce less carbon. We will make green choices and encourage all our stakeholders to do the same, creating momentum for the growth of renewable energy supply on behalf of the company.

As AYG Group, we commit to a significant step towards zero-emission electricity generation through our ongoing Solar Power Plant project, ensuring that consumption is supplied from renewable energy sources and neutralizing carbon emissions.

Energy consumption is meticulously monitored to achieve overall reductions each year and to reduce associated carbon emissions. We continue to empower our teams with technical services to identify the latest innovations in technology and renewable energy systems that facilitate reductions without compromising guest experience. We continuously analyze energy savings through maintenance, supervision, and monitoring, and we plan our new investment projects with a focus on energy production and reducing our environmental impact through the use of renewable energy sources. By utilizing cogeneration system, we ensure that a portion of electrical

and thermal energy is produced on-site, reclaiming the thermal energy generated during electricity production back into the system to achieve energy savings.

We are aware of the value of water resources. We continue to strive to generally reduce consumption each year. All water sources, including greywater, are disposed of properly by local regulations, without negatively impacting local environments or populations.

In our Hotel, Landscape plants that consume as little water as possible are preferred. Water savings are achieved through smart irrigation systems and low-flow / dual-flush bathroom fixtures. Employee training includes the importance of protecting water resources and educating staff on consumption awareness. Guests are reminded of conservation measures through information channels on their room televisions and are kindly asked to contribute.

In our hotel, the use of chemicals is involved in maintenance, repair, and cleaning activities. Every effort is made to minimize the use of chemicals and to prevent accidental spills. Employees who are required to use chemicals are properly trained, and Personal Protective Equipment (PPE) is provided. All chemicals used are approved, labeled, and packaged appropriately, and Material Safety Data Sheets (MSDS) are obtained to ensure compliance with the training data.

Necessary precautions have been taken in our chemical storage areas to prevent leaks, spills, and other incidents that could harm the environment, and storage is conducted in accordance with regulations, the type of chemical, and the manufacturer's storage instructions. Concentrated products are preferred whenever possible. An automatic dosing system is utilized in all applicable areas to minimize the amount of chemicals used for disinfection. For pest control, we request the permits and licenses for the products used by the service companies we hire, ensuring they are safe for human health and the environment, and that they are used in appropriate dosages. In production areas, we utilize natural pest control methods, such as fly-catching EFK devices, to protect food safety and human health.

Our Obligations to Guests;

• To provide the most accurate and best service promptly.

• To keep promises made.

• To act fairly, honestly, and in accordance with principles of equality.
 

Our Obligations to Employees;

• To create a work environment that is honest, fair, safe, and considers diverse opinions.

• To provide a healthy environment where personal rights are fully utilized.

• To ensure a work environment free from any form of discrimination and harassment.

• To allow continuous self-improvement and encourage development.
 

Our Obligations to Product and Service Providers;

• To fulfill obligations promptly.

• To receive fair and competitive offers.

• To adhere to confidentiality principles.
 

Our Obligations to Shareholders;

• To increase and manage the company's assets in a way that provides the highest returns.

• To ensure sustainable growth.

• To be accountable to shareholders regarding financial statements and business results.

• To provide complete, accurate, and timely information.
 

Our Obligations to Competitors;

• To avoid unfair competition.

• To act in compliance with Competition Law.

• To engage in competition only within legal and ethical frameworks.
 

Our Obligations to Society;

• To be a good corporate citizen.

• To contribute to community development.

• To avoid harming the environment and natural resources.

• To protect and enhance the environment and natural resources.

We prioritize the health, happiness, and safety of all our employees in the workplace. Under the Cullinan Group, we host many cultures, beliefs, and diverse backgrounds in similar conditions, thanks to our employees from various roles around the world and the large number of staff from the regions where our hotel are located.

Our Human Resources department plays a key role in ensuring compliance with workplace welfare and human rights legislation. All contracts, working hours, wage structures, discipline, and complaint procedures are by national laws, and all employees are free to join local unions that provide support for disciplinary actions and complaints if needed. Our management maintains an open-door policy and is accessible to resolve employment issues. A high percentage of Cullinan employees are hired from the local area, which not only is important for local employment but also makes our staff a fantastic source of local knowledge for guests with questions about the area they are visiting.

The recruitment process begins with orientation training, where we explain our offers to colleagues and our expectations from them and enhance their competencies through training

from experts in various fields. In addition to personal development training, we provide professional development training, contributing to continuity in the profession and service with individuals who specialize both theoretically and practically, thereby promoting decent work, economic growth, and quality education.

In case of internal promotions, we prioritize current employees in accordance with the "Promotion Directive," considering their potential and competencies, and supporting them in areas where they may be lacking by contributing to their training. We promote equal opportunity by prioritizing candidates from groups at risk of discrimination when all other qualifications are the same. We value and respect the contributions and ideas of employees from all age groups in our activities, which are managed by a team focused on success and composed of the best in their fields.

We declare our intention to measure the total employment rates of residents in the areas where our Hotel are located and to contribute to increasing employment rates by providing vocational training after hiring. In our hotel, we help individuals choose the role or position in various departments that aligns best with their skills and development, ensuring they work in an environment where they feel most fulfilled and happy.

The health and happiness of children are of the utmost importance. Children’s Rights are for all children, regardless of their place of birth or the language they speak. No child is discriminated against because of the beliefs or opinions of their elders. Some children may be more vulnerable due to past experiences, levels of dependency on others, communication needs, or other issues. Collaborating with children, youth, their parents, caregivers, and other intermediaries is essential to support the health and happiness of children. Conditions must be created that ensure the dignity of children with physical or mental disabilities, promote their self-confidence, and facilitate their active participation in community life. Efforts should also be made for their individual development, including cultural and spiritual aspects.

As Cullinan Hotel, we work to ensure that our young guests, the children of our employees, and children in our region are safe and happy.

Our Policy to Protect Vulnerable Groups;

Each of our Hotel conducts a regional analysis of protected and vulnerable groups and incorporates protective practices in their procedures for these groups while establishing behavior rules for employees. In our hotel:

• We develop and implement an effective security policy and related procedures.

• We provide effective management for employees through supervision, support, and training.

• We ensure that all necessary and relevant checks are completed before safely hiring employees.

• We work to empower local communities in the areas where our hotel is located, raising awareness among families about improving living standards, fostering positive attitudes towards tourists, eliminating gender-based actions and discrimination, and promoting a hospitable approach. We emphasize the positive impact of being a safe city for everyone by supporting institutions that will raise social awareness in this area.

• We commit to supporting local authorities in ensuring that there are adequate security measures around Hotel, at historical cultural sites, and in tourist areas, preventing issues such as verbal and physical harassment, terrorism, organized crime, drug dealing, theft, fraud, and ensuring there are no deserted streets or homeless individuals.

Due to the fact that bribery and corruption are not only ethically wrong but also legally punishable offenses, employees are expected to demonstrate sensitivity in this regard, treating it as part of their personal duties and responsibilities independent of their work life.

Cullinan Hotel has adopted the principle of complying with all laws and regulations regarding bribery and corruption in the countries in which it operates and represents, as well as adhering to universal legal standards and ethical and professional principles. Our company acts with a "zero tolerance" approach toward bribery and corruption and is committed to conducting its operations fairly, honestly, legally, and ethically. In all Hotel managed by Cullinan Hotel, regulations, procedures, and other regulations support the lawful, accurate, fair, and honest execution of activities, and a much more sensitive stance is taken in combating bribery and corruption to ensure the protection of the rights of all stakeholders. The Anti-Corruption and Anti-Bribery Policy has been implemented as a reflection of the importance placed on this issue.

Cullinan Hotel explicitly prohibits bribery and corruption in all its operations in the countries where it operates. It is prohibited for individuals covered by the Anti-Corruption and Anti-Bribery Policy to offer payments or anything of value to gain an unlawful and unethical advantage for the Company, or to obtain similar advantages from other organizations and individuals, regardless of whether such practices are common in the country of operation or industry. Any behavior that can be considered bribery or corruption, regardless of the material value of the benefit involved or whether anything is done in return for the other party, is strictly forbidden. Even if the value of the benefit is very low, or if an offer is made but the commitment has not yet been fulfilled, it would still be a violation of the Anti-Corruption and Anti-Bribery Policy.

In the Cullinan Hotel Group, the legal rights of government institutions, suppliers, guests, employees, and other stakeholders are protected. Accounting transactions are recorded fully, accurately, and fairly, and internal control systems are established to prevent unrecorded transactions.

The future of sustainable tourism depends on our actions today as much as on the actions of future generations. We want to inspire young people to see tourism as a wonderful career option that expands horizons, embraces diversity, celebrates destination cultures, and protects the environment, ensuring that everything we enjoy at Cullinan continues to be appreciated by others. We aim to continuously increase our support for students to develop themselves through the

training they receive within our institution while gaining experience through a high number of internships. By organizing career days at high schools and university tourism faculties, we contribute to webinars both in our cities and in other provinces, allowing students to visit our Hotel.

We aim to reduce our environmental impact by ensuring purchases are made from suppliers as close to the hotel as possible and minimizing CO2 emissions during delivery.

In connection with contracted purchases, individual bulk material and service procurement (operational bulk procurement), and retail material and service purchases, we consider the environmental sensitivity of materials chosen, including fuels, chemicals, pest control substances, all types of fossil fuel-consuming vehicles and equipment, electrical devices, appliances containing refrigerants, noise-producing devices, consumables, plastic materials, and construction materials, ensuring they have the necessary permits and certifications and taking energy efficiency classes into account. Products purchased for Cullinan Hotel are prioritized based on the following criteria:

• Made from recycled materials or recyclable

• Produced sustainably or sourced from sustainable resources

• Fair Trade / Organic / FSC / MSC, etc.

• Delivered with minimal packaging

• Contributing to energy and water conservation

• Environmentally sustainable

• Traceable

• Suppliers from nearby areas

• We review procurement and contracting processes to ensure that living cultural heritage and traditions are evident not only in cuisine but also in furniture, decoration, stores, events, and other services. Through our ongoing efforts and designated personnel to measure and manage local purchases, we aim to increase our local procurement rate by identifying local vendors within the market.

Due to rapid population growth, it is anticipated that in the coming decades, the current population increase process will occur more quickly and intensively, leading cities to face significant transformations. This will especially result in environmental and cultural losses, putting cultural heritage at risk. Therefore, there is a need to develop new policies that facilitate the protection of cultural and natural heritage and to make strategic decisions.

As Cullinan Hotel, we need to ensure the continuity of our history, heritage, and scientific and cultural knowledge. The success of our destinations is directly related to the living

culture, traditions, and people that shape our regions. Respecting and valuing these social aspects and contributing to their learning by our colleagues and guests is among our priorities. We want the benefits that tourism brings to the destination to be accessible to the entire population. To promote our cultural heritage to all our guests, we share regional information through our website, information channels, and Guest Relations staff.

• Future generations have the right to know the living species. We understand the vital and socio-economic value and importance of biodiversity through a healthy environment, healthy animals, and healthy people approach amidst ecosystem degradation, climate change, and disaster risk, and we commit to working towards the conservation of biodiversity.

• We take responsibility for creating habitats to support ecosystem services, contributing to soil formation, nutrient cycling, and water cycling. We plan to support cultural values by aiming to enhance recreational and aesthetic values, educational and inspirational values, as well as moral and spiritual values, along with contributions to science and education.

• To protect aquatic life, we aim to restore fish stocks to their original conditions as soon as possible, reaching levels that will provide maximum sustainable yield based on biological characteristics. We demonstrate our commitment to effectively managing fish harvesting, ending overfishing, illegal, unreported, and unregulated fishing practices that harm nature, and implementing science-based management plans in our supplier audits and procurement processes. We conduct training for employees to raise awareness and announce that spearfishing and underwater hunting with firearms are prohibited in our inland waters and near water sources. For pest control efforts (especially mosquito larvae) conducted at the facility or near riverbanks, we prefer practices that do not disrupt biodiversity (such as natural predators or bacteria). We ensure that the renewal of river/pond waters within the hotel and the discharge of treated wastewater do not disrupt coastal ecosystems and water quality, adhering to legal regulations.

• We conduct risk analyses before awareness-raising activities regarding factors threatening coastal and marine biodiversity, agricultural biodiversity, and biodiversity in mountain ecosystems.

• We plan and aim to implement practices that we can support to ensure the sustainable management of all types of forests, to end deforestation, to restore degraded forests, and to significantly increase afforestation and reforestation. We oppose the illegal hunting and trafficking of protected flora and fauna species and commit to supporting efforts to address the supply and demand issues of illegal wildlife products. Additionally, we advocate for measures to reduce the impact of invasive species on land and marine ecosystems, to prevent their spread, and to ensure the control or eradication of more hazardous priority species. We also commit to supporting efforts to combat the illegal

hunting and trafficking of protected species by enhancing the capacity of local communities to develop sustainable livelihoods.