Compliance, Service, and Ethics Commitment

1. Legal Compliance and Scope of Services

• Conducts its activities in full compliance with current legal regulations.
• Aims to increase the regulatory compliance of the institutions it serves and to reduce financial crime risks.
• Adopts a risk-based approach and reserves the right to decline clients or terminate service when necessary.

2. A Clear Stance Against Illegal Activities

• Does not provide direct or indirect services to any person, institution, or platform operating in violation of the legislation of the Republic of Turkey.
• Does not take part in any activity that supports, facilitates, or helps sustain the operations of such entities.
• Provides all of its services with the aim of enhancing the security of the financial system and preventing the proceeds of crime.

3. Legal Explanation Regarding the Sharing of Links and URLs

Achernar may, from time to time, share domain names, URLs, and similar digital indicators with the institutions it serves. These disclosures:

• Are solely for the purposes of detection, analysis, and reporting.
• Are provided to support the internal control, risk management, and compliance processes of the relevant institutions.
• Are intended to contribute to Information and Communication Technologies Authority (BTK) reporting procedures, statutory notification obligations, and the taking of necessary legal action.

Such data shared by Achernar:

• Does not in any way aim to promote, direct traffic to, or encourage the use of the platforms in question.
• On the contrary, is shared for the purpose of detecting, blocking, and removing such entities from the system.

All disclosures made in this context constitute a good-faith, preventive activity carried out in the public interest, within the framework of current legislation.

4. Operational Approach

Achernar's service model is not limited solely to internal controls. It also encompasses proactive processes such as:

• Identifying risk sources outside the financial system
• Detecting and analyzing illegal structures emerging on digital platforms
• Supporting actions aimed at eliminating these structures
• Providing actionable data to Compliance and Risk teams

among other proactive measures of this kind.

5. Principle of Ethics and Responsibility

Achernar:

• Adheres to ethical rules, transparency, and reliability in all its activities.
• Regards protecting the integrity of the financial system as a top-priority responsibility.
• Commits to acting in accordance with the principle of full regulatory compliance.

This text has been prepared to clearly set out Achernar's service approach, legal compliance framework, and ethical stance.