WEBSITE TERMS AND CONDITIONS OF USE

1. PURPOSE, SCOPE AND DEFINITIONS

These Website Terms and Conditions of Use (the "Terms of Use") set out the general rules, the rights and obligations and the limits of legal liability with which all natural and legal persons (the "User" or "Visitor") who access and/or in any way make use of the website at https://sonayyatirim.com/tr (the "Website"), owned and operated by Sonay Yatırım Anonim Şirketi (the "Company"), must comply.

In these Terms of Use:

• Company means Sonay Yatırım Anonim Şirketi, resident at Funda Sok. No:1 Levent Mah. Beşiktaş / İstanbul and operating in the fields of real estate, construction, infrastructure, energy, software/technology investments and the management of group companies,

• Website means the website accessed through the domain https://sonayyatirim.com/tr, its subdomains and mobile and digital channels,

• User / Visitor means each natural or legal person who accesses the Website by any device, reviews its content, uses the contact forms or benefits from the services offered,

• Content means all text, design, code, images, video, graphics, audio, project presentations, logos, data, reports and materials contained in or accessed through the Website.

2. ACCEPTANCE AND BINDING EFFECT

By entering the Website, browsing its pages, using any part of the site or submitting a request through the forms and channels offered on the site, the User irrevocably acknowledges, declares and undertakes that they have read and understood these Terms of Use, that they accept all of their provisions in full without any limitation, reservation or objection, and that these terms are legally binding upon them.

A User who does not accept any provision of these terms, in whole or in part, must immediately terminate their access to the Website and refrain from using the site. Continued use of the Website means that any changes made are also tacitly accepted.

3. NO INVESTMENT ADVICE (DISCLAIMER)

All corporate presentations, news, press releases, projects (including infrastructure, housing and real estate projects), affiliate and group company information, statements regarding fields of activity, sector assessments, financial data, forecasts and charts on the Website are presented to the User for general information purposes only.

No information, data or assessment published on the Website:

• constitutes investment advice, financial advice or market recommendation within the meaning of the Capital Markets Law No. 6362 and the related secondary legislation;

• constitutes an offer, an invitation to offer, an undertaking or a recommendation regarding the purchase, sale, lease, transfer of or any other disposition over any capital market instrument, financial instrument, real property, project or share;

• may be interpreted as guidance or a portfolio management service guaranteed to be suitable for the User's financial situation or risk and return preferences.

The User is solely and personally responsible for the consequences of any commercial, legal, financial or administrative transaction carried out in reliance on the information on the Website. Neither the Company nor its affiliates, directors, employees or representatives bear any legal, administrative or criminal liability for any direct, indirect, positive, negative, pecuniary and/or non-pecuniary damage, loss of profit or loss of data arising from decisions taken or transactions carried out on the basis of such information.

4. INTELLECTUAL AND INDUSTRIAL PROPERTY RIGHTS

All intellectual and industrial property rights in the Website's domain name, source code, software, database, page design, graphical interfaces, corporate logo, trade name, trademarks, slogans, photographs, project names, texts, architectural designs and all audiovisual works belong exclusively to Sonay Yatırım Anonim Şirketi or are lawfully used under licence.

Accordingly:

• The elements of the Website are protected nationally and internationally under the Law on Intellectual and Artistic Works No. 5846, the Industrial Property Law No. 6769, the Turkish Commercial Code No. 6102 and the Turkish Penal Code.

• Without the Company's prior express written permission, the content of the Website may not be copied, reproduced, adapted, published, distributed, communicated to the public, framed or mirrored on another website or medium, modified or used for commercial gain, in whole or in part.

• Access to the Website may not be interpreted as granting the User any ownership, use, licence or usufruct right over any intellectual property right, trademark, patent, utility model or copyright belonging to the Company or to third parties.

• The User is only entitled to view the Website for personal, non-commercial and lawful purposes.

In the event of an infringement of intellectual and industrial property rights, the Company reserves the right to bring actions for the determination, prevention and cessation of the infringement, to claim compensation for pecuniary and non-pecuniary damages, and to file criminal complaints with the Public Prosecutor's Offices against those responsible.

5. RULES OF USE AND PROHIBITED ACTIVITIES

When using the Website, the User is obliged to act in full compliance with Turkish law, public order, general morality, the rule of good faith and these Terms of Use. The User may under no circumstances engage in the following acts and activities:

• Attempting to endanger the security, integrity or functionality of the Website, attempting to gain unauthorised access or scanning for system vulnerabilities,

• Uploading, transmitting or spreading viruses, trojans, worms, logic bombs or similar malicious or harmful code/software to the Website or to the connected servers, networks or databases,

• Carrying out denial-of-service attacks (DoS / DDoS) or activities that place an excessive or disproportionate load on the server infrastructure,

• Using robots, spiders, scrapers, automated crawlers or similar data mining / automated data extraction tools without the Company's written permission in order to collect the Website's content, data or user information,

• Attempting to obtain the Website's software, source code or underlying architecture by reverse engineering, decompilation or disassembly,

• Transmitting content that damages the honour, dignity, commercial reputation, privacy or intellectual property rights of the Company, its affiliates or third parties,

• Using the communication channels on the Website to send unlawful, misleading, threatening, harassing, insulting, obscene or defamatory messages, or unauthorised commercial electronic messages (spam),

• Making misleading statements by presenting oneself as a member of staff, officer or representative of the Company, or by impersonating third parties.

Where the prohibited activities listed above are detected, the Company is entitled to block the relevant User's access to the Website immediately and without notice, to apply to judicial and administrative authorities, to initiate legal proceedings under the Turkish Penal Code No. 5237 and Law No. 5651 on the Regulation of Publications on the Internet and Combating Crimes Committed by Means of Such Publications, and to pursue legal remedies for compensation of any damage suffered.

6. LIMITATION OF LIABILITY

The Company takes reasonable technical and administrative measures within the framework of current technological means in order to ensure that the Website operates without interruption, without error, securely and free from viruses or other harmful elements.

Nevertheless, to the maximum extent permitted by the Turkish Code of Obligations:

• The Website and its content are provided to the User "as is" and "as available".

• The Company gives no express or implied warranty that the Website will operate without interruption, on time, securely or without error, that system failures will be remedied immediately, or as to the absolute accuracy, completeness or fitness for a particular purpose of the information on the site.

• The Company cannot be held liable for access barriers, data losses, delays or disruptions arising from internet service providers, telecommunications infrastructure, cyber attacks, power cuts, hardware failures, system updates or force majeure events beyond the Company's reasonable control.

• The Company bears no liability for any virus infection, corruption, damage or loss that may occur to the User's own computer hardware, software, network infrastructure or data as a result of using the Website, downloading files from the site or accessing the site. Taking the necessary antivirus and security measures is the User's own responsibility.

7. EXTERNAL LINKS (THIRD PARTY LINKS)

The Website may contain links to websites or platforms belonging to third parties or institutions, in order to provide convenience or information to the User or to give access to the Company's corporate social media accounts.

The Company:

• does not supervise or endorse the content, privacy policies, security conditions or accuracy of the linked external sites, nor the products and services offered on them;

• is in no way liable for any direct or indirect damage that may arise from visiting or using these sites or from benefiting from the content and services offered on them.

The User accepts in advance that, upon clicking such external links, they leave the Website and will be subject to the terms of use and privacy rules of the third-party site to which they are directed.

8. PRIVACY AND PROTECTION OF PERSONAL DATA

Personal data obtained while the User visits the Website, completes the contact forms on the site or contacts the Company by e-mail are processed and retained in full compliance with the Personal Data Protection Law No. 6698 (KVKK), the related secondary legislation and the decisions of the Personal Data Protection Board.

The following, published under separate headings on the Website:

• the KVKK Disclosure Notice,

• the Privacy Policy,

• the Cookie Policy (Cookie Disclosure Notice),

form an integral part and annex of these Terms of Use. By using the Website, the User accepts that they have read and understood the principles and procedures regarding the processing of personal data and the use of cookies set out in those policies and texts, and that they have consented to / been informed of the processing of their personal data in accordance with the legislation.

The Company is obliged, as a "content provider" and in respect of the Website servers under Law No. 5651 and the related legislation, to keep statutory traffic log records and to share this information in line with duly made requests from authorised public institutions and judicial authorities.

9. AMENDMENTS AND UPDATES

The Company reserves the right:

• to unilaterally update, amend or repeal these Terms of Use at any time in order to comply with changes in legislation, commercial requirements or technical developments,

• to change, renew, temporarily or permanently withdraw or restrict access to the content, design, services, information and visuals of the Website without prior notice.

The updated Terms of Use take effect immediately on the date they are published on the Website and become binding from that moment on all Users accessing the site. The User is therefore advised to review these Terms of Use periodically on each visit to the Website.

10. GOVERNING LAW AND DISPUTE RESOLUTION

Turkish law shall apply to the application and interpretation of these Terms of Use and to the resolution of any dispute arising from these terms or from the use of the Website.

The Courts and Enforcement Offices of Ankara shall have exclusive jurisdiction over any judicial, commercial or administrative dispute that may arise from these Terms of Use or from the use of the Website.

If any provision of these terms is declared invalid, void or unenforceable by a competent court or authority, that provision shall be deemed unenforceable only to that extent, and the remaining provisions of these terms shall remain in full force and effect.

11. EFFECTIVENESS AND CONTACT

These Website Terms and Conditions of Use entered into force on the date they were published on the Website.

For any questions, suggestions, requests or notifications regarding these Terms of Use, the Website or the content on the site, you may contact us through the following channels:

• Company name: Sonay Yatırım Anonim Şirketi

• Address: Funda Sok. No:1 Levent Mah. Beşiktaş / İstanbul

• Phone: +90 312 481 00 00

• E-mail: info@sonayyatirim.com

• Website: https://sonayyatirim.com/tr

This English text is a courtesy translation. In the event of any inconsistency, the Turkish version shall prevail.

14 September 2026

Sonay Yatırım Anonim Şirketi