Öz-Ege Tobacco Inc.

Company Policy

Top management of Öz-Ege Tobacco Inc. operating in İzmir/Turkey implements the Company Policy which applies to employees and all legal and real persons with whom Öz-Ege Tobacco Inc. deals, in the light of the principles listed below.

• In order to adapt to the changing environment by using the continuous development strategy, to make the system embedded through regular reviews.

• To follow the principle of continuous training.

• To abide by national and international laws and labor contracts.

• To allocate appropriate funds and qualified staff in order to ensure effective implementation of STP criteria.

• To inform our employees and our growers about STP company policy by placing posters in high-traffic spots in the company facilities and putting texts in our company website. To make our employees aware of their roles within the STP criteria system.

• To take appropriate measures to promote good labor practices.

• To take measures to prevent worst forms of child labor and to ensure compliance with our policy on child labor; to abide by ILO0138 convention on Minimum Age for Employment and ILO0182 convention on Banning and Eradicating child labor under improper conditions.

• To take measures with a view to improve health and safety at work for employees, suppliers and visitors.

• To provide for health and safety at work in accordance with relevant international standards.

• To protect and enrich natural environment in every stage of the production process.

• To support and encourage farmers to use the most appropriate pesticides in pest control to protect the environment and people.

• Fully comply with all national and international laws regarding pest management and crop protection.

• To work with stakeholders when necessary to ensure product compliance and crop integrity.

• To take necessary measures to protect the environment and bio-diversity; to prepare and implement management plans for bio-diversity and environment: to mark areas rich in bio-diversity on maps, to investigate impact of tobacco growing on environment, to co-operate with concerned establishments for preserving bio-diversity and to monitor and report activities.

• Tobacco production shall be affected by the increases in carbon (greenhouse gas) emissions and the resulting increases in temperatures. Therefore to prepare action plans involving employees and growers, to measure environmental impact of company vehicles, to reduce waste discharge; to reduce energy usage, to monitor climate change; to work on reducing petrol consumption by company vehicles; to set yearly targets for reducing greenhouse gas (carbon) emissions; to prepare plans to actively contain and reduce damage to the environment; to reduce operating costs and make savings by taking environmental measures and more specifically to take measures to reduce carbon emission per kilogram of tobacco production.

• Encouraging farmers for adequate and appropriate use of fertilizers to reduce the negative effects of fertilization on soil and climate.

• To keep usage of natural resources at minimum levels.

• To address water challenges in tobacco growing areas and promote sustainable use of water resources.

• To reduce waste discharge, to minimize harm to the environment by re-using waste as much as possible; and to prevent all forms of environmental pollution.

• To minimize harm to the environment by developing plans to avoid accidents that damage the environment.

• To utilize nature –friendly technologies in all new investment projects.

• To make our employees feel that they are members of a big family living in harmony and instill awareness for quality and environment and create team-work spirit.

• To try to have our suppliers embrace the Company policy and to obtain their co-operation.

• To take into consideration the impact of our vehicles used for growing and processing tobacco on the environment and pay attention to health and safety at work.

• To remove foreign substances from tobacco both during growing and processing.

• To hire qualified people without discriminating on basis of language, religion, race, nationality, gender and beliefs; to abide by ILO100 convention on Equal Pay for Equal Work and ILO111 convention on Discrimination (Employment and Career).

• To provide guidance to our growers in agricultural activities such as selecting tobacco varieties, safely dealing with diseases and harmful organisms, caring for and preserving soil and water and to increase their awareness levels for nature and provide training programs in good farming.

• To analyze socio-economic conditions of farmers and help them attain better living conditions.

• To review the targets set and activities performed within the framework of STP program at least once every year and monitor the results continuously.

• Through Agronomy team, to monitor and keep records of compliance with STP program principles; to ensure continuity of the program by allocating funds and human resources.

• To prevent entry to the facilities of the Company and use/consumption of all kinds of weapons such as fire-arms, explosives and knives, alcoholic beverages and narcotic drugs.

• To enable all employees and growers to monitor our loyal adherence to the Company Policy and provide them with the means to report violations to top management.

Board of Directors of

Öz-Ege Tobacco Inc.

Mahmut Özgener    Rikardo Aliberti

13.01.2020 / Rev7