Emergency Action Plan

                                                                      24 REAL ESTATE AND VENTURE CAPITAL PORTFOLIO MANAGEMENT

                                                                                             EMERGENCY AND CONTINGENCY PLAN

PURPOSE
The purpose of this plan is to outline the conditions, methods, procedures, and workflows related to the fulfillment of the company's obligations toward its clients, intermediaries, market participants, and third parties in the event of emergencies or unforeseen circumstances.
SCOPE
This plan covers the processes and actions that the employees of the Company will follow in the event of an emergency or unforeseen situation, as defined by the prepared plan.
RESPONSIBILITIES
Board of Directors
The Board of Directors is responsible for the approval of this plan.
General Manager
The General Manager is responsible for ensuring that the necessary resources for the implementation of this plan are provided.
All Employees
All employees of the Company are responsible for implementing this plan within the scope of their duties.
DEFINITIONS AND ABBREVIATIONS
Emergency and Unforeseen Situation: Refers to unplanned events that may cause injury or loss of life to employees and visitors, damage to the building or its equipment, partially or completely halt operations, or threaten the financial structure of the Company. Such events are declared an emergency by the Company's authorities.
In the event of an emergency and unforeseen situation where the continuity of information systems cannot be ensured, or significant damage occurs and requires a long period for recovery, it is the primary duty of the responsible personnel to assess the situation and decide on the necessary actions.
Possible Industrial Emergencies:
•    Natural Disasters (Earthquakes, Fires, etc.)
•    Explosions
•    Hazardous Chemical Substance Release
•    Incidents and accidents requiring first aid and evacuation
•    Food Poisoning
•    Sabotage
•    Failure of the Company's or third-party service providers' information and communication systems, unauthorized and malicious electronic attacks, breaches, and viruses.
Company: 24 Gayrimenkul ve Girişim Sermayesi Portföy Yönetimi A.Ş.
Board: Capital Markets Board (CMB)
IT: Information Technology
EMERGENCY AND UNFORESEEN SITUATION PLAN (EUSP)
BASIS
This procedure has been prepared in accordance with Articles 17 and 19 of the "Principles of Portfolio Management Companies and Their Activities" published in the Official Gazette No. 28695 on July 2, 2013, by the Capital Markets Board. It is based on the relevant regulations of the Capital Markets Board.
WORKFLOW PROCEDURE
Record Keeping and Storage of Documents:
All data and financial statements related to the Company, including documents and securities, are kept in physical and/or electronic form as per the Turkish Commercial Code (TCC) Article 82. Additionally, backups of these records are stored to prevent data loss. In case records are lost or inaccessible, backup systems will be activated.
Ensuring the Continuity of Information Systems:
In emergency and unforeseen situations, the continuity of operations is ensured through regular backups of the Company’s information systems and accounting data. These backups are kept for five years as per regulatory requirements.
Operational Risk Assessment Including Financial and Information Communication Infrastructure:
Financial assets of the Company and its funds are custodied by a third-party custodian institution. No excess cash is kept in the Company’s safe, only the cash required for daily operations.
Operational Risks Due to Personnel:
If there is a situation where an employee leaves, passes away, or a similar unforeseen event occurs, an emergency situation may be declared, which will affect business continuity. In such cases, other personnel from the same unit or those assigned the tasks will take over the duties. In the worst-case scenario, unit managers will assume the responsibilities of the missing personnel, and permanent replacements will be hired as quickly as possible.
Risks Due to Hardware and Software:
The Company’s servers and the components of the server mechanism may face technical issues or breakdowns caused by the internet service provider, potentially leading to an emergency situation. The Company’s IT services are outsourced, and regular maintenance is provided as per the contract.
Ensuring Communication Channels and Continuity:
In the event of an emergency or unforeseen situation, once the functionality of communication channels is assessed, communication with service providers, staff, and clients will be established through phone and email.
Ensuring Alternative Communication Channels for Company and Employees:
Employee contact details and their residence addresses are maintained up to date. In case of an emergency, alternative communication channels (mobile phones, emails) will be used to contact the staff.
Identification of Alternative Company Headquarters and External Locations:
If the building housing the Company becomes unusable due to an emergency or unforeseen event, remote access to the Company’s information systems will ensure continuity of operations. Employees will continue to work from a location with internet access as designated by the management.
Assessment of Potential Effects of the Emergency on Third Parties:
All assets of the clients are held by the portfolio custodian institution. In the event of an emergency, no loss of assets is expected.
Notification to the Regulatory Board and Routine Mandatory Reporting:
The personnel responsible for implementing the plan will immediately inform the Board about the emergency situation and the actions taken. If the responsible personnel are unavailable, the highest-ranking executive in the Company will provide instructions. Notifications will be carried out using the backup systems for the Company’s records.
If the Company Cannot Continue Operations:
In the event that the Company is unable to continue its operations due to an emergency situation, the Board of Directors will inform the clients (investors) and the custodian institution, and the transfer of the clients' assets to another institution will be carried out according to the clients’ instructions.
OUTSOURCED SERVICES
The Company has established workflows and internal control mechanisms for the outsourcing of services. The service provider must have the necessary technical infrastructure, financial power, experience, knowledge, and human resources to provide services of the desired quality. In case of disruption or failure of outsourced services, the service provider is expected to provide a detailed explanation and take action according to their own emergency plan.
EFFECTIVENESS
The Emergency and Unforeseen Situation Plan becomes effective upon approval by the Company’s Board of Directors. When contracts for outsourced services are signed, a copy is provided to the service provider. Additionally, this plan will be published on the Company’s website and shared with the Company’s staff.