Disclosure Policy

Viking Kağıt Ve Selüloz A.Ş. (Viking Kağıt, the Company) has formed a disclosure policy on the basis of transparency and accuracy so as to provide timely, accurate, complete, intelligible information to shareholders, the public and other stakeholders on matters apart from trade secrets on the principles of easy and equal availability at low cost to all within the frame of the Capital Market legislation, the Turkish Commercial Code, legal regulations of the İstanbul Stock Exchange (ISE) on which the Company’s shares are traded and the Capital Market Board’s (CMB) Corporate Governance Principles, as well as other applicable legislation.

The Company’s Board of Directors has the authority and responsibility for the formulation, monitoring, reviewing and further development of the Disclosure Policy. The Disclosure Policy and any modifications thereto approved by the Company’s Board of Directors will be publicly disclosed via the corporate website and will also be presented for the information of the General Assembly of Shareholders.

Corporate Governance Committee and Investor Relations Unit provide the Company’s Board of Directors with information and suggestions on matters related to the Disclosure Policy.

A)Methods and Means of Public Disclosure

Viking Kağıt makes use of the following methods and means in disclosing all necessary financial information and in providing other explanatory notes and disclosures in line with the provisions of the Capital Market legislation and the Turkish Commercial Code (TCC):

Material event disclosures transmitted to the ISE via facsimile (such disclosures are posted on the corporate website in Turkish and English languages)
Financial statements and notes to such statements, annual reports, independent audit reports and statements submitted periodically to the ISE in sealed envelopes (such reports are posted on the corporate website after they are announced at the ISE)
Annual reports are made available in hard copy in Turkish, and electronically on the corporate website in Turkish and English languages
The corporate website is accessible at (www.viking.com.tr)
Promulgations and announcements published in the Turkish Trade Registry Gazette and other newspapers such as the call for the general meeting, prospectus, list of authorized signatures etc.
Press statements made via printed and/or visual media
Disclosures made to data dissemination and news agencies like Reuters, Foreks, AP, Bloomberg etc.
Informative face-to-face or teleconference meetings and contacts held with investors and analysts
Communication methods and tools such as telephone, email, mobile phone (wap and similar technologies), facsimile and so on

B)Scope of the Disclosure Policy

a-Financial Statements

Annual and interim financial statements of Viking Kağıt are drawn up in accordance with the provisions of the Capital Market legislation and International Financial Reporting Standards (IFRS); are independently audited within the period of time stipulated by the legislation and submitted to the Board of Directors for approval upon obtaining the clearance of the Audit Committee. After being approved by the Board of Directors, financial statements drawn up as mentioned above and annual reports are submitted to the ISE and the CMB in sealed envelopes along with the statement of liability signed by the General Manager, Financial Affairs Director or the Accounting Manager. Public Disclosure Platform (in Turkish: KAP) notification in relation to financial statements, notes and independent audit reports is also made within the frame of Capital Market legislation as and when they are publicly disclosed. The Company’s financial reports are accessible on the corporate website under the section Investor Relations. In addition, the Investor Relations Unit prepares periodical informative memos or presentations about financial data and ratios so as to elaborate on financial reports, which are then disseminated electronically and posted on the website.

b-Individuals Authorized to Make Public Disclosure

Press statements to the printed and/or visual media and to data dissemination channels such as Reuters, Foreks, Bloomberg etc. may be given by the Chairperson of the Board, the General Manager, or other officials to be deemed fit thereby.

Queries received by the Company by phone, facsimile, email, post or various other means from capital market participants will be responded to in writing and/or orally by the Investor Relations Unit within the shortest time possible. When there is a need to disclose an information that has not been publicly disclosed previously in response to such queries, such need will be considered by the Company’s General Manager, Financial Affairs Director, Investor Relations Unit and senior executives having an influence across the Group and handled within the frame of the Company’s disclosure policy. All queries directed at the Company and all disclosures in this scope shall be released to the public after being approved by the said working group.

Apart from those mentioned above, no Viking Kağıt employee, unless specifically assigned, is authorized to respond to queries received from capital market participants. All queries and all information requests received will be referred to the Investor Relations Unit.

c-General Meetings

The announcement for the General Meeting, agenda items, informative documents on agenda items, methods of attendance to the general meeting and all other relevant information and documents are made available to the public at the company headquarters at least 15 days prior to the general meeting and concurrently start appearing in a manner to draw the attention on the corporate website in Turkish and English.

Minutes of the general meetings are posted on the corporate website in Turkish and English after the meeting.

After being approved by the Board of Directors, the annual report, which is prepared in accordance with the Capital Market legislation and CMB’s Corporate Governance Principles, is presented to the shareholders for their review, and is also posted in Turkish and English languages under the Investor Relations section of the corporate website accessible at (www.viking.com.tr ) The hard copy of the relevant report can be demanded from Viking Kağıt Investor Relations Unit at any time.

At general meetings, Company officials make presentations that sum up the activities in the relevant year and give detailed answers to questions directed by the attendants.

d-Viking Kağıt Corporate Website

The Investor Relations section under the Company’s website accessible at www.viking.com.tr is structured in the format and provides the content in Turkish and English languages, in line with the guidelines provided in the CMB’s Corporate Governance Principles. The website is kept up-to-date, and used as a detailed and active communication channel that can be made use of by shareholders, investors, analysts of brokerage firms and other stakeholders. An email address (investorrelations@viking.com.tr) has been created to respond to online information requests.

While the Company’s main website provides detailed information on a broad range of topics from the Company’s corporate identity to its products, main topics presented under the Investor Relations section of the website are summarized below:

- Information on the members of the Board of Directors and the Company’s senior management

- Corporate Governance Policies and the committees set up

- The Company’s articles of association

- Detailed information on corporate social responsibility

- Corporate Governance Principles Compliance Report

- Annual Reports, Financial Statements

- Material Event Disclosures

- Information on Investor Relations Unit

- Data and analyses on share performance

- Mission and strategic goals

- Trade Registry information

- Shareholding Structure and Capitalization

- Subsidiaries and Affiliates

- Press statements

- Information on analysts evaluating the Company and analyst reports

- Investor presentations

- Agendas, invitations and minutes of general meetings, and proxy forms

- Prospectus and circulars

- Frequently asked questions

The Investor Relations Unit is responsible for keeping the Investor Relations section of the website up-to-date.

e-Forward Looking Disclosures

Viking Kağıt can publicly disclose its future expectations, if so deemed necessary, within the frame of its disclosure policy. Disclosures on expectations can be made only by individuals authorized to make public disclosures. The Investor Relations Unit must be informed on these disclosures before they are made. Information presented in this frame must not contain exaggerated predictions, must not be misleading, and must be relevant to the Company’s financial standing and operating results.

Regarded as internal information by the Company, forward-looking disclosures are publicly disclosed simultaneously in the case of planned disclosures, and as soon as possible in other cases, within the frame of the Capital Market legislation.

In the event it is subsequently discovered that any estimation in relation to a forwardlooking disclosure will not be realized, the same will be publicly disclosed along with the reasons therefor, and such information will be revised accordingly.

f-Criteria for Identifying Individuals with Administrative Responsibilty

Individuals with administrative responsibility, who have regular access to internal information although they are not members of the Company’s administrative or supervisory bodies and who have authority to make administrative decisions affecting the Company’s future development and business targets, are determined according to the scope of information accessible thereby.

Accordingly, executives having detailed information only about part of the Company’s business affairs and limited knowledge on the whole of its operations and other employees are not considered among individuals with administrative responsibility under the CMB Communiqué Serial: VIII, No: 54.

General Managers having knowledge and influence for the entire Company that entail also the future plans, and certain senior executives having an influence across the Group are considered as individuals with administrative responsibility in this frame.

g- Monitoring the News and Rumors about the Company

The Company follows-up national printed and visual media via a media monitoring agency hired for this purpose in Turkey. Relevant news is reported to senior management every morning and their content is reviewed. In addition, news is monitored also via Euroline and Reuters, subscription services that are available to the senior management and Investor Relations Unit.

In the event the Company is requested to make a statement about news and rumors on matters which are covered by the media but which do not give rise to material event disclosure obligation according to the Communiqué, a press statement is given about the subject and/or the subject is addressed on the corporate website.

h- Ensuring Confidentiality until Public Disclosure of Material

Transactions, which will be subject to a Board of Directors resolution, will not be publicly disclosed before the relevant Board of Directors decision is adopted, and such transactions will be kept confidential.

In order to ensure the balance between transparency and preservation of the Company’s interests, importance is attached to ensure that all Company employees exercise utmost attention to observe the rules on the use of insider information. All necessary measures are taken to prevent the use of insider information.

All employees protect internal information of the Company during and after their employment with Viking Kağıt, and do not use them to derive benefits either for themselves or for third parties. No Viking Kağıt employee will engage in any activity that will generate revenues or compensate a loss through trading of the shares of Viking Kağıt or any other Yaşar Group company or other firms relying on insider information received due to one’s duty.