TR

Disclosure Policy

REYSAŞ REAL ESTATE INVESTMENT TRUST INC.
INFORMATION DISCLOSURE POLICY

Objective

The fundamental public disclosure policy of REYSAŞ Real Estate Investment Trust Inc. (REYSAŞ REIT) is to maintain an active and transparent communication with shareholders, investors, and capital market professionals (collectively referred to as capital market participants) by sharing the Company’s historical performance and future expectations in a complete, fair, accurate, timely, and comprehensible manner, in accordance with generally accepted accounting principles and Capital Market Legislation.

Except for information considered trade secrets, REYSAŞ REIT believes that sharing the strategies, critical elements, risks, and growth opportunities related to its operations with the public will help create a more effective market for its capital market instruments.

REYSAŞ REIT complies with the regulations of the Capital Markets Board (CMB) and Borsa Istanbul (BIST) regarding public disclosures, and exercises utmost care to implement the principles outlined in the CMB’s Corporate Governance Principles.

This Information Disclosure Policy has been prepared within the framework of Section II/article 1.2 of the CMB Corporate Governance Principles and approved by the Board of Directors.

Scope

The Information Disclosure Policy covers all affiliated companies, employees, and consultants within REYSAŞ REIT and regulates the Company’s written and verbal communication with capital market participants.

Responsibility

The Board of Directors is responsible for monitoring, reviewing, and improving the Information Disclosure Policy.

The Capital Markets and Corporate Governance Coordination Unit has been assigned to oversee and monitor all matters related to public disclosure.

Public Disclosure Methods and Tools

Without prejudice to the provisions of the Capital Markets Legislation and the Turkish Commercial Code (TCC), the primary public disclosure methods and tools used by REYSAŞ REIT are as follows:

  • Material event disclosures sent by fax to BIST (Electronic PDP disclosures are made within the legal timeframe),

  • Periodic submission of financial statements and footnotes, independent audit reports, declarations, and activity reports to BIST in sealed envelopes (Electronic PDP disclosures are made within the legal timeframe),

  • Announcements and notices (such as prospectuses, circulars, ordinary/extraordinary general assembly calls, etc.) published in the Turkish Trade Registry Gazette and in local or national daily newspapers,

  • Announcements made via print and visual media,

  • Disclosures made to data distribution agencies such as Reuters, Foreks, Euroline, etc.,

  • Information meetings and presentations held face-to-face or via teleconference with capital market participants,

  • Corporate Website (www.reysasgyo.com.tr),

  • Communication tools and methods such as telephone, mobile phone, email, fax, etc.

Public Disclosure of Financial Statements and Authorized Persons

REYSAŞ REIT’s financial statements and footnotes are prepared in accordance with the Capital Market Legislation and International Financial Reporting Standards (IFRS); they are audited in accordance with International Auditing Standards (IAS) and disclosed to the public. Before public disclosure, the financial statements and footnotes are reviewed by the Audit Committee and approved by the Board of Directors, with a declaration of accuracy signed by the Financial Affairs Manager and the Chairman of the Board.

Following Board approval, the financial statements and footnotes, along with the independent audit report and annexes, are submitted to BIST in a sealed envelope, in line with CMB and BIST regulations. Once publicly disclosed, they are also submitted electronically through PDP within the legal timeframe.

Public Disclosure of the Annual Report and Authorized Persons

The annual report is prepared in compliance with the Capital Market Legislation and CMB Corporate Governance Principles; it is approved by the Board of Directors and submitted to BIST in a sealed envelope in accordance with CMB and BIST regulations. It is also published on the Company’s website (www.reysasgyo.com.tr). Investors may also obtain the report from our Investor Relations Unit.

Public Disclosure of Material Events and Authorized Persons

Material event disclosures related to REYSAŞ REIT and its listed subsidiaries and affiliates are prepared under the supervision of the Capital Markets and Corporate Governance Coordination Unit. In principle, these disclosures are signed electronically by authorized persons and submitted via PDP within the legal timeframe.

Other Disclosures and Authorized Persons

Other disclosures (such as prospectuses, circulars, etc.) not mentioned above must be signed and disclosed to the public within the authority limits defined in the Company’s signature circular.

Authorized Persons for Public Disclosures

Apart from the disclosures mentioned above, written and verbal information requests received from capital market participants are responded to by the Financial Affairs Manager, REYSAŞ REIT Investor Relations Unit, or the Capital Markets and Corporate Governance Coordination Unit within their authority.

Unless specifically authorized, other REYSAŞ REIT employees cannot respond to inquiries from capital market participants. Such inquiries are directed to the Investor Relations Unit.

Communication with Capital Market Participants

REYSAŞ REIT does not provide guidance on interim and annual operating results. Instead, it prefers to share significant factors affecting operating results, strategic approaches, and key elements that aid in better understanding the sector with capital market participants.

Unless otherwise stated in the information disclosure policy, only persons authorized to make public disclosures may communicate on behalf of REYSAŞ REIT and its subsidiaries and affiliates, regardless of whether they are publicly traded. The Investor Relations Coordination Unit is present in all meetings with capital market participants. In non-public interviews, no significant or undisclosed information is shared.

Face-to-Face or Telephone Meetings

One-on-one or group meetings with capital market participants, whether in person or by phone, will not include any new disclosures, will not update previously disclosed information, and will not include significant or undisclosed information.

Presentations and/or Speeches

REYSAŞ REIT announces presentations, teleconferences, and speeches to capital market participants in advance whenever possible. Prepared presentations and/or explanatory information notes are published on the website (www.reysasgyo.com.tr).

Meetings Following the Disclosure of Financial Statements

REYSAŞ REIT acknowledges that meetings with capital market participants may be held via telephone or teleconference following the disclosure of financial statements. Efforts are made to broadcast such meetings simultaneously over the internet. Any important matters discussed are published on the website (www.reysasgyo.com.tr).

False Market Rumors

When unfounded rumors circulate in the market, authorized persons make press statements regarding such rumors. However, in accordance with the Capital Market Legislation, if no confirmation is requested by the CMB and/or BIST or if the management deems it unnecessary or inappropriate to respond, no statement will be made.

Disclosure of Expectations

In line with the information disclosure policy, REYSAŞ REIT may disclose its expectations from time to time. Documents disclosing such expectations clearly state that potential risks, uncertainties, and other factors may cause actual results to differ materially from expectations.

Expectations are communicated verbally only during pre-planned and scheduled meetings and events, and only by persons authorized to make public disclosures.

If it becomes evident that the assumptions and estimates in publicly disclosed information or periodic financial statements and reports will not materialize, revised information, tables, and reports, along with their justifications, are immediately disclosed to the public.

Analyst Reports

REYSAŞ REIT considers analyst reports the property of the firm that prepared them and does not publish them on its website. REYSAŞ REIT does not review, verify, approve, assume responsibility for, or disseminate such reports or earnings models. However, in certain limited cases and upon request, to prevent misinformation, it may review analyst reports by using only publicly available and historical data, and only concerning a specific subject.

REYSAŞ REIT Website (www.reysasgyo.com.tr)

The Company’s website (www.reysasgyo.com.tr) is actively used for public disclosure, as recommended by the CMB Corporate Governance Principles. Disclosures on the website do not substitute for the mandatory notifications and material event disclosures required by Capital Market Legislation.

All public disclosures by REYSAŞ REIT are accessible through the website, which is structured accordingly. All necessary precautions are taken to ensure website security. Particular attention is given to prominently displaying notices related to general assembly meetings, agenda items, information documents, reports related to the agenda, and information on participation methods.

Efforts to improve the website are continuously pursued.