ENVIRONMENTAL AND SUSTAINABILITY POLICY

As a Senior Management we commit to undertake

To continuously improve the effectiveness and efficiency of our Management Systems and ensure amiable customer satisfaction by applying responsible, honest, principled approach and Professional management,

To constantly protect and increase the reputation of our company operating in the hospitality industry,

To render the services that meet our customers’ current and future expectations by following the developments in the sector,

To work efficiently without compromising quality,

To create mutual value within the framework of the management systems applied on our facilities by cooperating with our suppliers and applying the win-win concept,

To undertake the primary role in raising awareness among our employees, guests and the local community and ensuring its sustainability with the sense of social responsibility brought by our brand, and make and apply the decisions in this direction,

To create an appropriate infrastructure with regard to our services and products and ensure that from-farm-to-fork processes are kept under control in order to provide the most effective implementation of Food Safety Management System within the scope of national and international regulations and Food Safety Management System standard,

To comply with the requirements of existing International and National Legislation and Environmental Management System Standard, minimize the amount of pollution arising from our activities, closely follow and implement technological developments in order to ensure the proper use of natural resources; share our efforts towards protection of the environment with our employees, guests, suppliers and the community; identify targets to ensure continuous improvement, conduct the necessary research, design and application with regard to the principles of protection of biodiversity and energy efficiency cycle,

To endeavor to be decisive and have continuous efforts, in order to minimize any negativity by taking into consideration of health and safety of our employees and customers no matter what language, religion, race or gender.

To continue training of our employees by perceiving it as a never ending process and through valuing our employees' satisfaction and participation.

OUR SUSTAINABILITY APPROACH

Since 2010, work has been carried out yearly for the process of implementing quality management systems applications, following the below basic topics.

ENVIRONMENT

We commit to comply within the requirements of existing International and National Legislation and Environmental Management System Standards, minimise the amount of pollution arising from our activities, closely following and implementing technological developments in order to ensure the proper use of natural resources; share our efforts towards protection of the environment with our employees, guests, suppliers and the community; identify targets to ensure continuous improvement, conduct the necessary research, design and application with regard to the principles of protection of biodiversity and energy efficiency cycle.

Targets are given on an annual basis in all of our hotels in order to keep the environmental damage to a minimum. These targets are determined by Hotel Management and all Department Managers, taking into account the consumption of previous years and changes made within the hotel.

Below are the main targets that are followed in the hotels (however each hotel has further individual targets): -

*Electrical consumption

*Water consumption

*LNG / LPG consumption

*Chemical consumption

*Organic and recyclable waste amounts

*Hazardous waste amounts

The activities carried out in order to achieve these targets are defined in the Targets tables. In order to achieve the targets, standard activities are carried out at each hotel, to provide regular training to all staff, to record consumptions regularly, to share recorded consumptions with all Hotel managers on a monthly basis, and to ensure that the targets are reviewed with the Management in a Meeting and to carry out internal audits on behalf of part of the evaluation process. Apart from these activities, other activities implemented in the hotel are also included in the Target Table.

EMPLOYEE RIGHTS

We commit to undertake and endeavor to be decisive and have continuous efforts, in order to minimise any negativity by taking consideration of health and safety of our employees and customers no matter what language, religion, race or gender.

In order to emphasis the importance given to employees, there are Key Performance Indicators (KPI) and Targets held in each hotel. These targets and KPIs are determined by Hotel Management and all department managers that take into account the data of previous years and the changes made within the hotels.

Destinations and KPIs may vary in hotel specificity, they basically follow the below areas.

*Number of staff motivation activities

*Staff / Manager survey evaluations

*Evaluation of staff requests and complaints

The activities carried out in order to achieve these targets are defined in the KPI table. However, in order to achieve the objectives, the standard activities carried out at each hotel are to provide regular training to all personnel, to evaluate the survey results are evaluated with Senior Management, reviewing Personnel Requests and Complaints.

LOCAL COMMUNITY

We commit to undertake to create mutual value within the framework of the management systems applied on our facilities by cooperating with our suppliers and applying the win-win concept. To undertake the primary role in raising awareness among our employees, guests and the local community and ensuring its sustainability with the sense of social responsibility brought by our brand, and to make and apply the decisions regarding this direction.

Every Hotel plans activities at the beginning of the season for the Local Communities. Social Responsibility issues are also included in this planning and it is aimed to contribute to the development of the regions where our hotels are located.

We cooperate with the local cooperatives located in the regions where we operate. In this way, we support the local development and development of farmers and producers in the region. In addition, we provide awareness for our guests by making promotions about cooperatives in our hotels.

QUALITY

We commit to undertake to continuously improve the effectiveness and efficiency of our Management Systems and ensure amiable customer satisfaction by applying honest, principled approach and professional management, to constantly protect and increase the reputation of our company operating in the hospitality industry, to render the services that meet our customers' current and future

expectations by following the developments within the sector, to work efficiently without compromising quality.

To continuously improve the effectiveness and efficiency of our Management Systems, to ensure a smiling customer satisfaction with a responsible, honest, principled understanding and professional management, to ensure the reputation of our company operating in the hospitality sector. We are committed to protecting and utilising time, following developments in the sector, providing the service that meets today's and future customer expectations, and working efficiently without sacrificing quality.

In accordance with Quality Management Systems, quantitative and measurable targets and KPIs for each department have been determined. The main objectives are Guest Evaluations of each department. Each department plans activities within itself in order to achieve the targets set out in regard to guest evaluations. Again what is important the training given to the personnel. In addition, the activities to be implemented regarding daily guest comments play a decisive role in the quality role.

OCCUPATIONAL HEALTH and SAFETY (OHS)

We commit to undertake to endeavor to be decisive and have continuous efforts, in order to minimise any negativity by taking consideration of health and safety of our employees and customers no matter what language, religion, race or gender. To continue training of our employees by perceiving it as a never-ending process and through valuing our employees' satisfaction and participation.

There are OHS Boards established within each Hotel for Occupational Health and Safety. There are also out-sourced OHS Specialists that give support to our boards. These boards meet regularly and plan regular activities for each hotel and evaluate information from previous meetings.

It is aimed to provide OSG trainings to all personnel within the hotels and training activities are evaluated at each board meeting.

FOOD SAFETY

We commit to undertake to create an appropriate infrastructure with regard to our services and products and ensure that from-farm-to-fork processes are kept under control in order to provide the most effective implementation of Food Safety Management System within the scope of National and International regulations and Food Safety Management standards.

Department-based targets are established regularly in all our hotels, especially with main issues mentioned above, and the relevant Department Managers are to ensure that they to continue their work in order to achieve these goals. Targets are determined at the beginning of the season by discussing working with all relevant Department Managers and the current situation is evaluated at least twice a year together with the relevant Department managers. Actions are planned to match each goal. There are also department-based KPIs. KPI data is entered on a monthly basis and current situations are

evaluated by the Quality Department and the relevant Department Managers. The objectives cover many topics involving natural resource consumption (electricity-water-chemical- waste, etc.). Department managers are free to choose their own activities but with the KPI’s kept in mind that include environmental-sustainability or social responsibility. Also, our Environmental Consultants, Occupational Health and Safety Consultants, Hazardous Materials Safety Consultants and Building Energy Managers also give support in our hotels for all of these activities.

At the end of each year, the Target Table is evaluated together with the Hotel Managers and the results are shared with the Central Quality Department. These tables explain targets that are unattainable and deviated. In the light of these assessments, the targets of the next year are created.