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Item 16B. Code Of Ethics

We have adopted a Code of Conduct that applies to all our employees, officers and directors. The Code of Conduct covers a broad range of matters including the handling of conflicts of interest, compliance issues and other corporate policies such as equal opportunity and non-discrimination standards. The full text of the Code of Conduct is available on our website at https://investors.hepsiburada.com. No waiver was granted by the board of directors in favor of any employee with respect to any breach of ethical duties arising under the Code of Conduct in 2024.

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