DISCLOSURE POLICY OF
TSKB GAYRIMENKUL YATIRIM ORTAKLIGI A.Ş.
A. Purpose and Scope
The aim of this policy is to inform the shareholders, investors and stakeholders on the past performance, future plans and expectations as well as strategies, goals and vision of TSKB Gayrimenkul Yatirim Ortakligi A.S. (TSKB REIT) on time, in full, in a correct and efficient way in line with the provisions brought along by the Regulations of the capital market, the Turkish Trade Code, the Regulations of the İstanbul Stock Exchange and other related regulations.
The information policy covers information consisting of any type of information, document, electronic recording and data know by the members of the Board of Directors, the executives and employees and which is related to activities, which are not considered to be “trade secrets” and which can be disclosed without any legal fears.
B. Methods and Tools To Inform The Public
TSKB REIT uses following methods and tools within its information policy:
- Public Disclosure of Special Circumstances
- Financial Statements and footnotes, portfolio value table, the independent auditors’ report sent periodically to the İstanbul Stock Exchange.
- Annual Reports
- Corporate web site (www.tskbgyo.com.tr)
- Investor and Analyst Meetings
- Press Releases
- Press Meetings
C. Insider information
Insider information is the information, which with reference to a concrete incident it may influence the value of the capital market instruments issued by the Company and the investment decisions of the investors; with which a rational investor may consider the investment decision as meaningful; with reference to the situations not announced to the public, when used for the trading of the capital market tools, which can bring an advantage to its user in comparison to other investors, who are not informed about and when it is announced, which may have influence on the value of the subject capital market tool or the investment decisions of the investors.
Employees of the Company having this kind of internal information and other parties in contact with, are informed about their liability of protecting the secrecy of such information during the process of the Public Disclosure of Special Circumstances and the period passed from the arising of special circumstances until its explanation at the İstanbul Stock Exchange. As a general principle, employees working in the name and on behalf of the Company do never share information, which has not been made public and which has the nature of Special Circumstances with third parties. If such people are found to have disclosed such insider information to third parties, an immediate explanation on the special circumstance of disclosure shall be given if it is found that the secrecy of the information cannot be provided within the Regulations of the Capital Market.
Real persons or entities working for the Company or in the name and on behalf of the Company prepare a list of people, who work for them by an employment contract or in another form and those who access insider information, within the frame of the “ Communiqué on the Principles of the Public Disclosure of Special Circumstances”. The preparation and actualisation of the list is realized when related departments inform the Human Resources Department of the Company about the people, who have access to insider information.
It is essential to keep the list of people updated, who have access to insider information within the frame of changing projects and issues. The mentioned list can be provided to official authorities and institutions upon request. People on the list have to be notified in written about their liability to protect insider information.
D. Shareholders and individuals authorized to communicate with and to make announcements to the public
Any type of demand for information requested from the Company will be evaluated for its nature as a trade secret and whether it can influence the investment decisions and the value of the tools of the capital market within the scope of the Principles of the Capital Markets Board on “Public Disclosure of Special Circumstances” of the Communiqué Series VIII, No. 54.
Such demands are answered in written or verbally by
- The Chairman and members of the Board of Directors,
- The Chairman and members of the Audit Committee
- The General Manager
The Shareholders and the Relations Department. All other employees except the mentioned are not authorized to answer questions. The employees of the Company direct the questions placed in to the sharers as well as to the Relations Department.
E. Authorization and Responsibility
The Information Policy of TSKB REIT has been set by the Board of Directors, whereas the Board of Directors is authorized and responsible of the monitoring, supervision and development of the policy.
F. Enforcement
The Information Policy accepted by the resolution No. 102 dated 22.03.2010 by the Board of Directors and coming into force with the going public of the Company has been updated with its present version at the Board of Directors hold on 14.05.2010.