About the Disclosure Policy

1. Purpose

Blume Metal Kimya A.Ş. operates with transparent and close communication, both in its management and with its shareholders. Our company’s goal is to increase the market value of Blume Metal Kimya A.Ş. for its shareholders while making its shares an attractive investment instrument for potential investors. To this end, the management of Blume Metal Kimya A.Ş. has adopted as a principle the implementation of strategic plans and the sharing of their results with the public, shareholders, investors, capital market professionals and capital market participants in a complete, fair, accurate, timely and clear manner, within the framework of financial reporting standards and the provisions of the Capital Markets Legislation. Blume Metal Kimya A.Ş. complies with the Capital Markets Legislation, the Turkish Commercial Code legislation and the regulations of Borsa İstanbul A.Ş. (BIST) regarding public disclosure; it shows great sensitivity and care in implementing the principles set forth in the CMB Corporate Governance Principles. The Disclosure Policy covers all personnel and consultants of Blume Metal Kimya A.Ş.; it regulates the written and verbal communication of Blume Metal Kimya A.Ş. with capital market participants. The Disclosure Policy of Blume Metal Kimya A.Ş. has been prepared in accordance with Article 17 of the Capital Markets Board’s Communiqué on Material Events (Serial II, No. 15.1) and is announced to all stakeholders via Blume Metal Kimya A.Ş.’s website, www.blumemks.com.

2. Authority and Responsibility

The Disclosure Policy has been created and approved by the Board of Directors within the framework of the CMB Corporate Governance Principles. The authority and responsibility for monitoring, supervising and developing the public disclosure and disclosure policy of Blume Metal Kimya A.Ş. rests with the Board of Directors. Our Investor Relations Department, under our Company’s General Directorate, is tasked with overseeing and monitoring all matters related to public disclosure.

3. Public Disclosure Methods and Tools

Disclosures are made through tools such as material event disclosures, financial statements and reports, annual activity reports, the corporate website, presentations, investor meetings and teleconferences, information letters, press releases, and the Trade Registry Gazette. Subject to the provisions of the Capital Markets Legislation and the Turkish Commercial Code, the methods and tools used by Blume Metal Kimya A.Ş. are:

• Material event disclosures made through the Public Disclosure Platform (KAP),
• Financial statements and footnotes, independent audit report, declarations and activity report periodically transmitted to KAP,
• Announcements and notices made through the Turkish Trade Registry Gazette,
• Corporate website (www.blumemks.com) disclosures.

4. Disclosure of Financial Statements to the Public

The financial statements and footnotes of Blume Metal Kimya A.Ş. are prepared in accordance with Turkish Accounting Standards / Turkish Financial Reporting Standards (TAS/TFRS). Annual and semi-annual financial statements are disclosed to the public after undergoing independent audit. Before being disclosed to the public, the financial statements and footnotes are submitted to the Board of Directors for approval, with the prior favourable opinion of the Audit Committee. Following approval, the financial statements and reports are transmitted to KAP, disclosed to the public, and published on the website. Activity reports, financial statements and footnotes from previous periods can be accessed on the website.

5. Disclosure of the Activity Report to the Public

The activity report is prepared in accordance with the Capital Markets Legislation and the CMB Corporate Governance Principles, approved by the Board of Directors, and disclosed to the public together with the financial statements. In addition, a detailed annual activity report is prepared for submission to the relevant authorities.

6. Disclosure of Material Events to the Public and Authorised Persons

Material event disclosures of Blume Metal Kimya A.Ş. are prepared by our Investor Relations Department, signed electronically, and transmitted to KAP. The disclosures are prepared in an accurate, understandable and non-misleading manner. The disclosures are announced at www.blumemks.com within the business day following their disclosure to the public and are kept for five years.

7. Persons Authorised to Make Public Disclosures

Written and verbal information requests are evaluated by the Investor Relations Department. Press releases can only be made by the Chairman of the Board of Directors, the Vice Chairman of the Board of Directors, or the Deputy General Manager. Unauthorised employees cannot answer questions from capital market participants; such requests are directed to the Deputy General Manager’s office.

8. Persons with Administrative Responsibility and List of Those with Access to Inside Information

Persons with administrative responsibility are those who, directly or indirectly, have regular access to inside information of Blume Metal Kimya A.Ş. The list is maintained by the Investor Relations Department and is submitted to the CMB or BIST upon request. Everyone on the list is obliged to comply with the rules of confidentiality.

9. Communication with Capital Market Participants

Blume Metal Kimya A.Ş. does not provide guidance regarding interim and annual operating results.

10. Unfounded Rumours in the Market

Blume Metal Kimya A.Ş., as a principle, does not comment on rumours or speculation. If the CMB or BIST requests verification, or if management deems it appropriate, the necessary disclosure may be made.

11. Postponement of Disclosure of Inside Information to the Public

Blume Metal Kimya A.Ş. may postpone the disclosure of inside information to the public in order to protect its legitimate interests or to avoid misleading investors. In such a case, measures are taken to ensure confidentiality.

12. Meetings and Discussions with Investors and Analysts

Blume Metal Kimya A.Ş. communicates with existing and potential shareholders, answers investor questions, but does not confirm or assume responsibility for analyst reports. Only publicly available information is shared when necessary.

13. Disclosure of Forward-Looking Assessments to the Public

The company may disclose its forward-looking expectations to the public when it deems necessary. Such disclosures may be made at most four times a year. It is stated that these are based on assumptions and may differ.

14. Quiet Period

Blume Metal Kimya A.Ş. applies a quiet period prior to the announcement of financial results in order to prevent information asymmetry. No disclosures on financial matters are made during this period. The quiet period begins on the day following the end of the relevant financial period and ends one business day after the announcement.

15. Market Disruptive Actions

The Board of Directors of Blume Metal Kimya A.Ş. takes the necessary measures to ensure that persons with access to inside information do not engage in market disruptive actions.

16. Blume Metal Kimya A.Ş. Website (www.blumemks.com)

The address www.blumemks.com is actively used for public disclosure. The website contains corporate information, the articles of association, financial statements, general assembly announcements, activity reports, policy documents and investor information. The site is secured, is arranged in Turkish, and is structured in accordance with the CMB Corporate Governance Principles.