Onar Holding Corp

Evaluation of Disclosure Controls and Procedures

We have established and maintain a system of disclosure controls and procedures, as such term is defined in Rules 13a-15(e) and 15d-15(e) of the Exchange Act, that are designed to provide reasonable assurance that information required to be disclosed in our reports filed with the Securities and Exchange Commission pursuant to the Exchange Act, is recorded, processed, summarized and reported within the time periods specified in the rules and forms of the Commission and that such information is accumulated and communicated to our management, including our Chief Executive Officer (CEO), to allow timely decisions regarding required disclosures.

In connection with the preparation of this Quarterly Report on Form 10-Q, our management, with the participation of our Chief Executive Officer (our Principal Executive Officer and Principal Financial Officer), carried out an evaluation of the effectiveness of our disclosure controls and procedures as of June 30, 2026, as required by Rules 13a-15(e) and 15d-15(e) of the Exchange Act. Based on the evaluation described above, our management, including our Principal Executive Officer and Principal Financial Officer, concluded that, as of June 30, 2026, our disclosure controls and procedures were not effective.

Changes in Internal Control Over Financial Reporting

As disclosed in the 2025 Annual Report and the Company’s Quarterly Report for the quarter ended March 31, 2026, management identified material weaknesses in the Company’s internal control over financial reporting that had not been fully remediated, and has been implementing a multi-period remediation plan under the leadership of the Company’s Vice President of Finance.

During the quarter ended June 30, 2026, management continued to implement that remediation plan under the leadership of the Company’s Vice President of Finance. Building on the actions taken during the first quarter of 2026, which included the adoption of a formal documentation policy for significant and non-routine transactions, the implementation of a period-end close checklist to standardize close and reconciliation procedures, and the establishment of a monthly financial review cadence, during the second quarter the Company: (i) hired an additional staff bookkeeper, further improving segregation of duties within the accounting function; (ii) continued to operate its two-person approval process for all outgoing payments and its monthly financial review cadence; (iii) completed a second consecutive quarter-end close using its standardized close checklist.

The material weaknesses described in the 2025 Annual Report will not be considered remediated until the applicable controls have operated for a sufficient period of time and management has concluded, through testing, that they are operating effectively.

Except as described above, there were no changes in our internal control over financial reporting (as defined in Rules 13a-15(f) and 15d-15(f) under the Exchange Act) during the quarter ended June 30, 2026 that have materially affected, or are reasonably likely to materially affect, our internal control over financial reporting.