As stated in the previous Communiqué, ultimate beneficial owner must be a real person.

a-) Ultimate beneficial owners are real person/persons who own more than 25% of the shares of the legal entity

b-) If any suspicion arises about the real person owning more than 25% of the shares not being the ultimate beneficial owner or there are not any real persons owning more than 25% of the shares, the real person/persons ultimately in control of the legal entity are the ultimate beneficial owners.

c-) If the ultimate beneficial owner cannot be determined according to the criteria above, top executive officers are ultimate beneficial owners.

The real persons who own more than 25% of the shares of the legal entity must be reported in any case. If ultimate beneficial owners are determined according to the criteria b-) and c-) above, the names of these real persons must be submitted in the Ultimate Beneficial Ownership Form.

The real person/persons not owning directly or indirectly more than 25% of the enterprise can still have ultimate control over an entitty through different means and these real persons are considered as ultimate beneficial owners too. The necessary explanations are submitted in the Form.

Top Executive Officers are the real person/persons who have the authority to make strategic decisions regarding the legal entity and the real person/persons who have the executive control in running the usual daily operations like the Chairman of the Board, Chief Executive Officer, Chief Financial Officer, Financial Director.