Emergency and Contingency Action Plan

  1. Ana Sayfa
  2. Emergency and Contingency Action Plan

Emergency and Contingency Action Plan

Purpose:

Allbatross Portfolio Management Inc. has prepared this plan to handle emergency and unforeseen situations and ensure business continuity. The main objectives of this plan are:

  • Ensuring the continuity of customer services,
  • Fulfilling legal and third-party obligations on time,
  • Preventing complexity and disruption in business processes and minimizing financial impacts,
  • Protecting the Company's assets and cash flow in unexpected situations,
  • Establishing the conditions for fulfilling obligations during emergencies and unexpected situations.

The preparation of this emergency and contingency plan is based on the relevant provisions outlined in the III-55.1 Portfolio Management Companies and Principles Regarding the Activities of These Companies Communiqué.

Definition of Emergency and Contingency Situations:

The Company defines situations that may disrupt its regular operations or prevent service delivery as follows:

  • Natural disasters (earthquakes, fires, storms, floods, etc.),
  • Events such as terrorist attacks or wars,
  • Unexpected situations in the building where activities are conducted,
  • Failures or external attacks on information technology systems,
  • Health or traffic accidents preventing a significant portion of personnel from coming to work,
  • Extraordinary situations in money and capital markets.

The content of the emergency and contingency action plan and the roles and responsibilities of committee members have been shared with all Company employees. In the event of an extraordinary situation, the plan will be implemented by a sufficient number of knowledgeable personnel.

Responsibility:

All personnel are required to know and implement the requirements of this plan. The Board of Directors and the Emergency and Contingency Action Committee are responsible for implementing the plan and making necessary preparations.

Emergency and Contingency Action Plan Committee:

An Emergency and Contingency Committee has been established with the participation of relevant officials appointed by the Board of Directors to ensure effective implementation and coordination of the action plan. The committee members are as follows:

  • [Emergency Officer] Information Systems Manager: Yalçın OBUZ
  • [Emergency Officer] Risk Management System Manager: Orçun ERGÖKNAR

The responsible personnel for the emergency and contingency action plan are determined by a decision of the Board of Directors. Their contact information is communicated to the Capital Markets Board (SPK) and other relevant institutions. If there is a change in the responsible personnel, the new contact information will be re-notified to the relevant institutions.

Alternative Service Channels in Emergency and Contingency Situations:

If the Company's primary office location becomes unusable, identifying an alternative service location is crucial for ensuring business continuity.

In this context, the factory and head office of QUA GRANITE HAYAL YAPI VE ÜRÜNLERİ SANAYİ TİCARET A.Ş. at Söke OSB Mahallesi 4. Sokak No:1 Söke /Aydın, is designated as the "Business Continuity Center" for emergencies.

Company Measures for Emergency Situations:

  • Storing all financial records and valuable documents, required to be maintained by the Turkish Commercial Code Article 82, both in printed and/or electronic formats,
  • Regularly backing up data from the Company's information technology systems and retaining these backups for at least five years,
  • Evaluating all Company operations, including financial and information communication infrastructure, to minimize operational risks,
  • Providing alternative communication channels to maintain continuous communication with service recipients,
  • Regularly identifying and monitoring alternative Company centers and external organizations to ensure continued operations,
  • Conducting continuous monitoring and assessment to measure the impacts of emergencies and take appropriate actions,
  • Keeping the Capital Markets Board (SPK) and other relevant institutions regularly informed about intervention responsibilities,
  • Preparing for situations where business operations cannot continue, including providing access to client accounts and transferring these accounts to another Company.

Business Processes, Legal Compliance, and Implementation:

As Allbatross Portfolio Management Inc., we are committed to providing updated information on business continuity and compliance with legal regulations.

The Company is obligated to inform stakeholders about:

  • How business continuity will be maintained in emergencies,
  • The relevant business process procedures.

This information will be provided:

  • When signing the portfolio management agreement,
  • Through the Company's website.

This action plan was approved by the Board of Directors on April 19, 2024, and is effective as of that date. It may also be updated following changes in legal regulations or the Company's structure.

We present this information to our valuable investors and kindly request you to contact us for any questions or feedback.

Best regards,
ALLBATROSS PORTFÖY YÖNETİMİ A.Ş.