Company Information Disclosure Policy
The objective of Ihlas Ev Aletleri İmalat San. ve Tic. A.Ş. (IHEVA) is to pursue a transparent and effective disclosure policy to inform shareholders in a simultaneous, complete, transparent, and accurate manner, according to related laws and the CMB Corporate Governance Principles. All information that is not within the purview of trade secrets must be disclosed to the public by law. The objective of the disclosure policy is to share the Company's past performance, future expectations, strategies, targets and vision (not pertaining to trade secrets) with the public, related authorized entities, existing and potential investors, and shareholders through active and open communications.
In all the public disclosures, IHEVA complies with the CMB legislation and all ISE regulations. Moreover, IHEVA aims to implement the most effective communications policy according to the CMB Corporate Governance Principles.
Authority and Responsibilities:
IHEVA’s Disclosure Policy has been established by the Board of Directors. At IHEVA, the pursuance, observance and development of the public disclosure policy is under the authority and responsibility of the Board of Directors, which has appointed the executive director of Investor Relations and Financial Affairs for the coordination of the disclosure function. Authorized persons fulfill their responsibilities in close cooperation with the Corporate Governance Committee, Auditing Committee, and Board of Directors.
Methods and Tools:
Information disclosures are made through various tools, such as material events disclosures, financial statements and reports, annual reports, Company website, presentations, investor meetings and information notes, and press releases. The key public disclosure methods and tools are as follows:
Material Events Disclosures:
IHEVA’s material events disclosures are prepared by the Investor Relations unit, under the supervision of the executive director of Financial Affairs. The disclosures are signed by signatory executives and announced according to CMB and ISE regulations.
The Company takes the following measures to ensure the confidentiality of this information until the material events are disclosed to the public:
The Company places great importance on all company employees adhering to the rules on the use of insider information in order to ensure that the balance between transparency and protection of the Company’s interests is maintained. Various types of measures are taken to prevent the illegal use of insider information. Documented and disseminated throughout the organization, the “Rules of Ethics” expressly state the code of conduct that must be adopted by IHEVA employees in their business life.
Information that may be classified as trade secrets, which is acquired during the employment term and belongs to the Company, whose policy precludes anyone other than authorized parties to have knowledge of this information, is classified as “Company Information." All employees protect and do not use, either directly or indirectly, company information during and beyond their employment periods.
Confirmation of News or Rumors:
If any news or rumors from media organizations contain any information that has already been made public in material events disclosures, registration statements, circulars, announcements approved by the Board of Directors, and financial statements, and that does not provide any additional information, a material events disclosure is not required.
On the other hand, though the related official information may not require a material events disclosure, should the Company request an explanation of the news or rumor in question, this matter is brought forward by the executive director of Financial Affairs and made public through a material events disclosure.
If the news or rumor in question contain any issue that requires a material events disclosure according to the related official information, diligent attention is given to forwarding the required disclosure to the related stock exchange before the start of the opening session, no later than 09.00 a.m., without waiting for a warning, statement or request from the Board of Directors or the related stock exchange, to ensure the uninterrupted continuity of market transactions and sessions.
Public Disclosure of Financial Statements:
The financial statements of IHEVA are prepared according to the provisions specified by the CMB and disclosed to the public after having been audited independently according to the International Standards of Auditing (ISA). Before public disclosure, financial statements and their footnotes are submitted to the Board of Directors for approval with assent obtained from the Auditing Committee according to the Capital Markets Law. After the authorized persons have signed the accuracy statement, then the financial statements and their footnotes and the independent auditing report are sent to the ISE according to the Capital Markets Law and ISE regulations. The financial statements and their footnotes are retroactively accessible on the Investor page of IHEVA's website. Moreover, the Investor Relations unit prepares periodic presentations on information notes or financial data and ratios, and places them on the corporate website to ensure a better understanding of financial affairs.
The content of the annual report is prepared according to international standards, Capital Markets legislation, and CMB Corporate Governance Principles. The annual report is then submitted for approval to the Board of Directors. The annual report is made public on the corporate website. Capital markets participants may obtain the printed version of the annual report in Turkish or English from the Investor Relations unit, if requested.
Appointment of Employees with Administrative Responsibility:
Employees with access to internal information are given administrative responsibility according to the scope of the information.
However, managers and other staff members with detailed information on the Company’s business activities in part and restricted information in whole are not considered employees with access to internal information as noted above.
However, members of the Board of Directors, the general manager, some of the department directors, and most top managers working in the headquarters, who have both detailed information on current business affairs and also on future plans are considered employees having access to internal information.
A list of employees is prepared in line with these criteria and sent to the Capital Markets Board and the related stock exchanges, if requested, according to the applicable CMB communiqué.
The Company Web Site and Contents:
All mandatory information in the Company’s corporate governance principles may be accessed on the Corporate, Human Resources, and Investor pages on IHEVA’s website. Most of the information on the website is both in Turkish and English.
The main content of the website is as follows:
Notices and Announcements through the Turkish Trade Registry Gazette and Daily Newspapers:
According to the Capital Markets Law, Turkish Commercial Code and the Articles of Association, the announcements of the General Shareholders Meetings, capital increases, and dividend payments are announced through the Turkish Trade Registry Gazette as well as through daily newspapers.
Questions or information requests in writing from the media on various developments and on general business affairs are reviewed and given either positive or negative responses.
Meetings and Contacts with Investors and Analysts:
An Investor Relations unit has been established at IHEVA to maintain well-organized relations with both existing and potential shareholders, to answer investors’ questions productively, and to work for the improvement of corporate values. Relations with shareholders are managed by this unit in coordination with the executive director of Financial Affairs.
The shareholders and the analysts may also closely follow developments at IHEVA through the website regularly updated by the Investor Relations Unit and the information notes disseminated to the shareholder via Internet.
Disclosures on Anticipatory Declarations:
Authorities of Ihlas Holding A.Ş. or IHEVA may release anticipatory declarations from time to time on information disclosure policies. The anticipatory declarations in written documents of the Company are released according to certain assumptions; therefore, investors must be advised that realized results may differ significantly from expected results in anticipatory declarations due to risks, uncertainties, and other factors.