Objective

The purpose of this plan, prepared by Oragon Company for Real Estate Portfolio and Project Capital Management, is to establish the conditions, procedures, and methods necessary for the company to fulfill its responsibilities to its clients, intermediaries, market shareholders, and third parties in emergency and unforeseen situations. It also defines the operational measures to handle such cases effectively.

Definitions

• Information Processing Systems: Systems that enable the company to conduct its activities normally, transmit and execute client orders, conduct barter transactions, manage clearing and settlement operations, and store and monitor client accounts.
• Board of Directors: The Capital Markets Board.
• The Plan: Emergency and Contingency Plan.
• The Company: Oragon Company for Real Estate Portfolio and Project Capital Portfolio Management.
• The Law: Turkish Commercial Code.

Scope

The plan covers procedures to be followed by the company's staff in cases where company operations or services provided by external institutions are disrupted due to emergencies or unforeseen events. Key scenarios include:

• Natural disasters such as earthquakes, fires, floods, storms, and similar catastrophes.
• Wars, terrorist attacks, civil unrest, etc.
• Unexpected situations like fires, floods, or explosions occurring at company premises or facilities providing external services.
• Suspension of transactions or failures in collection and payment systems due to unforeseen events in financial markets.
• Absence of company staff or external service providers due to illness, pandemics, traffic accidents, or labor strikes.
• Disruptions in the company’s or external providers’ information and communication systems, including unauthorized cyberattacks, breaches, and viruses.

Persons Responsible for Plan Implementation

The plan must be approved by the company's Board of Directors. Individuals responsible for its implementation are to be appointed by the Board, comprising at least one deputy general manager and an alternate staff member. Notifications are made to the Board, the Central Registry Agency, Istanbul Clearing and Settlement Bank, and other institutions specified by the Board.

If information processing systems cannot be maintained, and/or significant time is needed to repair damages caused by an unforeseen emergency, or if the work environment becomes physically unsuitable, the primary duty of the responsible individuals for plan implementation is to assess the situation and determine the necessary actions.

The adequacy of the procedures outlined in the plan is reviewed annually by those responsible for its implementation, considering company activities and organizational changes, such as opening or closing branches. Necessary amendments to the procedures are made accordingly.

Implementation and Workflow

• The retention of financial data and all types of records and negotiable instruments that are required to be kept in accordance with existing legislation in printed and/or electronic media, as per Article 82 of the Turkish Commercial Code.

 The company's financial data and all types of records and documents required to be kept in accordance with legislation are retained in printed copies and stored securely in fire-resistant steel protection cabinets in the archive room within the company. Additionally, Electronic backups are maintained for all records. In case of damage or inaccessibility, records can be restored from the system.

• Ensuring the continuity of IT systems for the uninterrupted continuation of the company's activities, taking backups and retaining the backups of the mentioned electronic records for five years.

The company’s data and the fund's accounting data are systematically backed up to ensure the continuity of IT systems for the uninterrupted continuation of the company's activities in case of emergencies and unforeseen circumstances. The backups are stored in different locations for at least five years. Additionally, cloud storage systems provided by companies are also used, and backups of server data and important files on users' computers are kept through instant synchronization via the cloud. Internet access in the company is provided via an ADSL line and a fiber internet line. Company employees use laptops, enabling short-term work continuity on battery power during power outages. In case of long-term outages, if necessary, all employees can continue their work from any point connected to the electricity.

• Evaluation of operational risks, including financial infrastructure and information technology

Measures outlined in (b) minimize risks associated with information processing system failures. The company's financial assets and funds are held in the custody of the depository institution and other financial institutions, if any. No amounts of cash exceeding daily needs are kept in the cash register. In addition, client-issued financial instruments such as checks, bonds, and other financial documents received from clients are not kept in the company's treasury but are held in banks. Consequently, financial risks are minimized. Backup staffing plans are in place for illness or resignations.

• Providing and ensuring the continuity of alternative communication channels with service recipients
  In the event of emergencies and unforeseen circumstances, and after determining the operability of communication channels, contact with service recipients is maintained via phone and email.
  
  
• Providing and ensuring the continuity of alternative communication channels with the company and its employees
  Contact information and residential addresses of the company’s employees are updated. In the event of emergencies and unforeseen circumstances, alternative communication channels are used to contact employees. Mobile phones and emails can be used as communication channels.
• Alternative Company Headquarters
  In the event that the company's main office becomes unusable due to an emergency and unforeseen circumstances, no specific address has been predetermined as an alternative company headquarters. Since the company does not engage in production, it does not require a specific work area. In such a case, the company is able to rent any ready office and resume its activities in a short time using its backup records.
• Assessment of Potential Impacts of Emergency and Unforeseen Situations on Counterparties
  Assets belonging to serviced funds are fully retained by the depository service provider. No loss occurs during emergencies.
• Reporting to the Board about the measures taken and the procedure for mandatory routine notifications
  Individuals responsible for implementing the plan must immediately inform the board of any emergency or unforeseen situation and the measures taken in response. In the absence of the individuals responsible for implementing the plan, the instructions of the current senior manager of the company will be followed. Mandatory routine notifications will be made in writing or verbally in a timely manner, using the most appropriate method after evaluating the current situation. Notifications will be made using backups of the company's records.
  
  
• Accessing customer accounts and transferring accounts to another company in case the company decides it cannot continue operating

In the event that the company's board of directors decides that the company cannot continue its operations due to an emergency and unforeseen situation, the depository institution responsible for safeguarding the assets of funds established by the company will be notified of the situation, and the assets of the affected funds will be transferred accordingly. For funds managed on behalf of other asset management companies, the respective asset management company will be informed of the situation. The management contracts for the affected funds will be terminated, and management authority will be transferred to the respective asset management company.

Outsourced Services

The company outsources certain services under the framework of formal contracts, ensuring that the service provider possesses the necessary technical equipment, infrastructure, financial capacity, expertise, technical knowledge, and human resources to deliver the required service at the desired quality.

In the event of an interruption or disruption in the outsourced service, the service provider is expected to provide a detailed explanation regarding the duration of the outage and take the necessary actions in accordance with their emergency plan.

Implementation

The plan taks effect upon Board approval. A copy of the plan is provided during portfolio management agreement signing and is published on the company’s website.