D-MARKET Electronic Services & Trading

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. On December 29, 2025, we amended our Code of Conduct to align more closely with the Code of Conduct of our controlling shareholder, Kaspi.kz. The amendments expand the principles of ethics and business conduct, add provisions addressing compliance with financial crime and monitoring legislation, sanctions, anti-corruption and fraud management, address corporate loans and guarantees under Section 402 of the Sarbanes-Oxley Act of 2002, expand conflict of interest guidelines and enhance the enforcement framework administered by the Group Compliance Unit and the Ethics Committee, among other updates. 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 2025.