Tax Policy

Introduction

The purpose of the Sabancı Group Tax Policy, which is approved by the Board of Directors with resolution no:1887 and dated September 1, 2021, is to set out the policy governing the management of taxes by Hacı Ömer Sabancı Holding A.Ş., its affiliates (hereinafter “Sabancı”, “Group” or “We”).

Taxation is an important and fundamental topic for Sabancı and for our stakeholders, in terms of compliance, and our value, and therefore we actively manage, monitor, control and fulfill our legal obligations our Group tax affairs.

With this policy, it is aimed to ensure standardization, transparency, predictability and equal treatment in tax affairs for Sabancı Group and all participants.

Tax Governance, Risk Management and Organization

Sabancı Group actively seeks to identify, evaluate, monitor, manage tax risks and correctly apply the tax legislation to its business operations. In doing so, we aim to minimize tax risk and encourage practices that lead to the prevention and reduction of significant tax risks through internal information and control systems.

Hacı Ömer Sabancı Holding A.Ş. is responsible for the Group’s tax strategy. Responsibility in this matter has been delegated to the Holding CFO, and the CFO works with the Head of Financial Affairs and Accounting Department and the Structure, Tax & Financial Regulations Management for the effective management of tax policies.

Structure, Tax & Financial Regulations Management of the Group, which has necessary financial and human resources, is responsible for monitoring tax governance and tax management in Sabancı and works closely with other department and business areas.

All tax transactions carried out by Group Companies are regularly checked and the detected risks are eliminated. In addition, when necessary, support can be obtained from independent auditors and Sworn Tax Advisors.

All documents regarding our tax liabilities are kept for legal periods.

Structure, Tax & Financial Regulations Management of the Group additionally monitors international tax developments to identify the potential impact for the Group and liaises with the relevant finance personnel to address any changes required.

All Sabancı employees are obliged to adopt and follow the Group Tax Policy in all business activity and in all decision-making

Tax Planning and Compliance

Sabancı Group is committed to acting with integrity and supporting and encouraging transparency on all tax matters.

We see tax as a very important part of our social responsibility and we are committed to comply with all relevant tax laws and obligations in each countries where we operate. We pay right amount of taxes at the right time in accordance with where value is created. We acknowledge the increased focus on our decision-making processes related to tax affairs, not how much tax we pay and where it is paid.

We engage in responsible tax planning aligned with our commercial substance and economic activities. We do not engage in tax evasion and artificial tax arrangements that aims to achieve results that are contrary to the intention of legislation.

We are committed not to use so-called ‘tax havens’ for tax planning purposes.

Accordingly, we utilize tax incentives or opportunities to obtain tax efficiencies where these are not considered to impair these commitments.

Transfer Pricing

Our transfer pricing policy is developed in line with arm’s length principle as well as local and international law. In all related party transactions, we closely manage to ensure that taxes are paid where value is being created in.

In line with the OECD Guidelines and local regulations, we are fulfilling three tiered transfer pricing documentation including Local File, Master File, Country-by-Country Reporting and we provide to the countries through the Turkish Tax Administration

Relationships with Tax Authorities and Transparency

We recognize the interest of our various stakeholders in our tax affairs, including insight into our tax management and fulfillment of disclosure requirements.

Wherever we operate, we seek to establish and maintain an open and constructive dialogue with tax authorities and other government bodies, based on the disclosure of all relevant facts and conditions. We seek to provide clarity and establish certainty on all relevant local tax regulators in advance.

We ensure that all tax filings are submitted on a timely basis and provide tax-related information and documentation requested by the competent Tax Authorities as quickly and completely as possible.

We will engage in dialogue with policymakers as a way of ensuring equal conditions for all market participants.

We fully comply with the relevant tax transparency legislation in all jurisdictions and seek to meet the tax transparency expectations of relevant stakeholders.

Revision

This tax policy is reviewed by Structure, Tax & Financial Regulations Management annually to ensure we remain compliant as tax laws change. In case of updates, following the completion of the necessary approval processes, updated tax policy come into force after being approved by the Board of Directors of Sabancı Holding.

Tax Contributions

This report covers direct taxes for 2021. Tax contributions are shown on figures below as aggregated basis.

The total number of employees in the companies of the Sabancı Group subject to consolidation is 33,739 and 91.0% of them work in the companies residing in Türkiye. Additional details on revenue, corporate taxes of the Group are shown on figures below: