Corporate Governance Principles Compliance Report

Procedure for combatting the laundering of the proceeds of crime and the financing of terrorism.

Alternatif Bank takes all the measures necessary to prevent the laundering of the proceeds of crime (money laundering) through our Bank and the utilization of our Bank as a tool for financing terrorism. We aim to:

Ensure our Bank’s compliance with the legal requirements in connection with the matter. Acquire the knowledge about the legal and the administrative duties of our employees. Protect the respectability of our Bank and the quality of our customer portfolio.

In order to achieve the foregoing targets, our Bank puts the following policies into practice:

Our Bank and our Bank’s personnel are required to know and to comply with the regulations and the information provided by the governmental and professional institutions participating in the combat with the laundering of the proceeds of crime and the financing of terrorism in national and international level;

Our Bank’s personnel are trained to acquire knowledge on their legal and administrative duties regarding the combat with the laundering of the proceeds of crime and the financing of terrorism; and their knowledge is updated regularly;

In the combat against the laundering of the proceeds of crime, our Bank cooperates with principally any and all kinds of entities and institutions, provided that such cooperation is not in violation of the applicable regulations.

AntiMoney Laudering & Know Your Customer Policy

AML Questionnaire for Correspondents

Policy

USA Patriot Act Certification

Wolfsberg Questionnaire

Alternatif Bank has established and successfully pursues a Social and Environmental Risk Management System (SEMS) to outline the principles for the determination and assessment of the social and environmental risks of its lending facilities made or to be made available to its customers. The fundamentals of assessing and determining these principles are defined in the Social and Environmental Risk Management System.

The objectives of the system are:

Alternatif Bank continuously endeavors to ensure effective social and environmental management practices in its lending activities and aims to minimize the possible negative effects of these activities on public health and safety.

Banking License

1. Law No. 5549 on Prevention of Laundering Proceeds of Crime

2. Regulation on Program of Compliance with Obligations of Anti-Money Laundering and Combating the Financing of Terrorism

3. Regulation on Measures Regarding Prevention of Laundering Proceeds of Crime and Financing of Terrorism

4. Law NO.6415 on the Prevention of the Financing of Terrorism

FATCA (The Foreign Account Tax Compliance Act) is a USA law aimed at foreign financial institutions (FFIs) outside of the U.S.A to report information on the FFI's USA accounts to American IRS (Internal Revenue Service).

Türkiye has consented to being included on the FATCA Model 1 IGA country list as Jurisdictions that have reached agreements in substance as per 03 June 2014. Therefore, Foreign Financial Institutions (FFIs) operating in Turkey will be treated as FATCA compliant as of the date of 1 July 2014.

Alternatifbank A.Ş. has completed its FATCA registration process along with its subsidiaries. Hereby, Alternatifbank A.Ş. declares being fully FATCA compliant in the status of Reporting FI under a Model 1 IGA.
The obtained Global Intermediary Identification Number (GIIN) of Alternatifbank A.Ş. is as follows and the W8-BEN-E form can be reached on the following link.

GIIN: ZQS923.00004.ME.792

W8-BEN-E