Business Continunity Principles

1. BUSINESS CONTINUITY PLAN

The QNB Invest Business Continuity Plan aims to ensure the continuation of the Company's operations with minimum disruption and loss during all emergencies, ranging from minor incidents to major disasters. Accordingly, while only specific sections of this comprehensively prepared plan may be utilized when needed, it is also possible to activate the entire plan if necessary. The Plan is built upon the following management framework:

EMERGENCY ACTION: Includes immediate measures to be taken for the safety of employees, physical environments, and infrastructure during the first minutes and hours following events that prevent the Company from continuing its normal operations.

CRISIS MANAGEMENT: Events that cause an interruption in the Company's core activities and/or have a corporate impact are considered a "crisis." A crisis is managed with a strategic perspective involving the participation of senior management.

BUSINESS RECOVERY: Refers to the recovery activities for products, processes, and services that would cause significant damage in terms of finance, customer relations, legal obligations, and corporate image due to the interruption of normal operational activities during emergency actions and crisis management.

2. BUSINESS CONTINUITY MANAGEMENT STRATEGY AND OBJECTIVE

The strategic objective is to make necessary/critical operations functional as soon as possible, at a minimum level that is acceptable to the customer. The strategy to be followed following an incident will be based on the following goals:

  • Protecting personnel and attending to physical injuries;
  • Assessing the magnitude of the incident;
  • Controlling the threat;
  • Evaluating the arising problems and their consequences;
  • Activating temporary operations as quickly as possible;
  • Managing internal and external communications.

3. BUSINESS CONTINUITY POLICY

QNB Invest's policy is to continue meeting customer needs even under the most adverse conditions. Within this framework, it is aimed to conduct operations and services by giving the highest value to the safety of employees, the health of the public and staff, and the protection of the environment and property. Furthermore, the successful implementation of the Plan aims to ensure the welfare of customers and employees and to protect the interests of shareholders.

4. THREATS AND SCENARIOS

"Scenario-based business recovery plans" have been prepared to ensure seamless business continuity by identifying threats such as fire, earthquake, flood, snowstorm, system outages, infrastructure failure, and terrorist attacks that may cause disruption to services and responsibilities toward customers, commercial counterparties, and legal and regulatory authorities.

5. BUSINESS RECOVERY STRATEGY

a. Operational Risk Assessment

In the event of a disruption to all services and other activities of QNB Invest, the impacts and damages to the company regarding:
Finance
Legal Obligations
Customer Relations
Reputation/Image

have been determined through Business Impact Analyses conducted with all business units. Consequently, the importance levels and recovery times of all company activities have been established, and detailed business recovery plans have been prepared for critical processes.

b. Alternative Location

All transaction data, other required data, and necessary systems carried out to ensure business continuity are backed up at a different location and kept ready to be activated in the event of a disaster. In the event of an interruption to existing information technology systems, the continuity of activities will be maintained via backup systems.

Additionally, alternative locations have been established for emergency and unexpected situations, data providers for daily operations have been installed, and all necessary office programs and information access systems required to sustain our activities have been loaded. Technical devices and facilities required for the continuity of transactions, such as telephones, faxes, and printers, are kept ready for use.

c. Maintenance of Records

All types of records and valuable documents that are required to be kept in accordance with financial statements and current legislation are stored in printed and/or electronic format for the period specified within the framework of legal regulations.

6. COMMUNICATION

A Crisis Management Team, Emergency Action Team, and Business Recovery Team have been formed to coordinate all operations in an Emergency and Unexpected Situation. These teams consist of senior executives and necessary business unit personnel.

In the event of a disruption to Business Continuity and the activation of business continuity plans, customer information and communication will be provided via www.qnbinvest.com.tr, by sending SMS or e-mails centrally to all customers, or through press releases.

Responsibility has been assigned at the Assistant General Manager level for establishing contact with all official institutions such as the Capital Markets Board (SPK), BIST, VIOP, Takasbank, and MKK. Routine notifications will be finalized within the required timeframe by individuals in the Business Recovery Teams according to the instructions of the Business Recovery Team manager.

The main center where mandatory notifications will be made is: Atatürk Mah. Sütçü İmam Cad. No.113 – 117 A Ümraniye/ Istanbul.

7. IMPACTS OF EMERGENCY ON THE COUNTERPARTY AND TERMINATION OF ACTIVITIES

Since customer assets are held at the Custodian Institution independently of our company, no risk is foreseen regarding damage to customer assets due to an emergency or unexpected situation. However, in the event that communication with customers cannot be established or customer instructions cannot be fulfilled due to an emergency and unexpected situation, interruptions may occur in the services provided to customers.

The QNB Invest business continuity plan aims to continue the company's activities with minimum disruption and loss in emergencies; to continue meeting customer needs even under the most adverse conditions; and to conduct company operations and services by giving the highest value to employee safety, public and staff health, and the protection of environment and property.
Thanks to all these measures and the established infrastructure, the continuity of company activities is planned. However, despite the actions taken, if the Board of Directors decides that the company cannot continue its operations due to an emergency and unexpected situation, customers will be informed of this situation, and the necessary procedures for the transfer of customer assets will be carried out upon customer instruction.