Report - COP Prototype

2022 Communication on Progress

Turkiye Sinai Kalkinma Bankasi (TSKB)

Published date

June 27, 2022

No. of questions

Supplemental files

TSKB 2021 Integrated Annual Report TSKB 2021 Integrated Annual Report

CEO Statement

Signed

Governance

Policies and Responsibilities

1. Does the Board / highest governance body or most senior executive of the company:

Issue an annual statement about the relevance of sustainable development to the company

Issue an annual statement that addresses impacts on both people and the environment

Issue an annual statement highlighting a zero tolerance for corruption

Sign off on organizational sustainability targets

Supervise Environmental, Social, and Governance reporting

Regularly review potential risks related to the business model

None of the above

Optional comment

Integrated Annual Report – Governance Structure page 30 – 35 Sustainability Policy and other complementary policies: https://en.tskb.com.tr/en/sustainable-banking/tskb-surdurulebilirlik-yonetim-organizasyonu/our-sustainability-policy

2. Does the company have a publicly stated commitment regarding the following sustainability topics?

	No, this is not a current priority	No, but we plan to have a commitment within 2 years	Yes, and the commitment is focused on our own operations	Yes, and the commitment includes our own operations and the value chain	Yes, and the commitment includes our own operations and the value chain along with communities and society
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

In our Integrated Annual Report, we set short-, medium- and long-term targets specific to 6 different capitals, in line with our strategy. Also, we have different policies and programmes related to above sustainability topics. Sustainability and other policies: https://en.tskb.com.tr/en/sustainable-banking/tskb-surdurulebilirlik-yonetim-organizasyonu/our-sustainability-policy Code of Banking Ethics & Policies: https://en.tskb.com.tr/en/investor-relations/corporate-governance/code-of-banking-ethics-and-policies

3. Does the company have in place a code of conduct regarding each of the following sustainability topics?

	No, this is not a current priority	No, but we plan to have a code of conduct within two years	Yes, focused on employee conduct	Yes, focused on employees and suppliers	Yes, focused on employees, suppliers, and other business relationships
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

Code of Banking Ethics & Policies: https://en.tskb.com.tr/en/investor-relations/corporate-governance/code-of-banking-ethics-and-policies Sustainability and other policies: https://en.tskb.com.tr/en/sustainable-banking/tskb-surdurulebilirlik-yonetim-organizasyonu/our-sustainability-policy

4. Has the company appointed an individual or group responsible for each of the following sustainability topics?

	No one is specifically responsible for this topic	Yes, with limited influence on outcomes (e.g., limited access to internal information, limited decision-making authority)	Yes, with moderate influence on outcomes (e.g., has access to relevant information, reports to senior manager)	Yes, with direct influence of some outcomes (e.g., has access to relevant information, includes one or more senior manager with decision making rights	Yes, with direct influence at the highest levels of the organization (e.g., has access to relevant information, includes most senior members of organization)
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

Integrated Annual Report – Governance Structure page 30 – 35

5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?

	No formal structure	Yes, and with limited influence on outcomes (e.g., limited access to internal information necessary to understand risks, poor representation from relevant departments or functions)	Yes, with moderate influence on outcomes (e.g., it includes representatives of some functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, reports to senior manager)	Yes, with direct influence on some outcomes (e.g., it includes representatives of functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, it involves one or more members of senior management)	Yes, and with direct influence at the highest level of the organization (e.g., full access to relevant information, it involves members at highest level of organization)
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

Integrated Annual Report – Strategy page 24 - 29 Integrated Annual Report – Governance Structure page 30 – 35 https://en.tskb.com.tr/en/sustainable-banking/sustainability-management

Prevention

6. Does the company have a process or processes to assess risk?

	No, this is not a current priority	No, but we are planning to develop one in the next two years	Yes, related to our own operations	Yes, related to our own operations and entire value chain and other business relationships
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

Optional comment

Critical Position Succession Plan: Integrated Annual Report – Human Capital page 68

6.1. During the assessment of risk, which business relationships are reviewed?

	A few suppliers or business relationships [approximately less than 25 %]	Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]	Most suppliers / relevant business relationships [approx. 51 - 99 %]	All suppliers / relevant business relationships outside the supply chain
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

7. Does the company have a due diligence process through which it identifies, prevents, mitigates, and accounts for actual and potential negative impacts on sustainability topics?

	No, this is not a current priority	No, but we are planning to develop one in the next two years	Yes, related to our own operations	Yes, related to our own operations and entire value chain and other business relationships
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

Optional comment

Anti-bribery and anti-corruption Results 2021: https://www.tskb.com.tr/i/assets/document/pdf/2021%20Results%20.pdf Integrated Annual Report – Human resources principles page 72 Integrated Annual Report – ERET Model page 77-78

7.1. During the due diligence process, which business relationships are reviewed?

	A few suppliers or business relationships [approximately less than 25 %]	Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]	Most suppliers / relevant business relationships [approx. 51 - 99 %]	All suppliers / relevant business relationships outside the supply chain
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

Concerns and grievance mechanisms

8. Are there any processes through which members of the company’s workforce can raise concerns about the company’s conduct related to human rights, labour rights, environment, or anti-corruption?

No, this is not a current priority

No, but we plan to within two years

Yes, we have an informal process (e.g., through supervisors, others)

Yes, we have a formal process

Optional comment

https://www.tskb.com.tr/hizmetler/surdurulebilir-bankacilik/sikayet-mekanizmasi/sikayet-formu Whistleblowing Mechanism at TSKB: https://en.tskb.com.tr/i/assets/document/pdf/ANTI-BRIBERY-AND-ANTI-CORRUPTION-PROGRAMME-2021.pdf

8.1. Please provide additional detail regarding the process(es) the company has through which members of the company’s workforce can raise concerns about the company’s conduct.

	No	Yes
Is the process communicated to all employees/workers in local languages?
Is the process available to non-employees (e.g., contractors, vendors, suppliers)?
Is the process confidential (e.g., whistleblowing process)?
Are there processes in place to avoid retaliation?
Can concerns be raised about suppliers or other business relationships (e.g., clients, partners, etc.)
Other (Please provide additional information)

9. Does the company provide or enable access to effective remedy to right holders / stakeholders where it has caused or contributed to the adverse impact?

	No process to enable remedy to stakeholders	Remedy available to some stakeholders (i.e., some geographies, employees only)	Remedy is available to all affected stakeholders	Remedy is available to all stakeholders, and suppliers are expected to have similar policies
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Lessons

10. How does the company capture lessons regarding each of the following sustainability topics?

	No lessons are regularly captured	Conducts root cause analyses/investigation of major incidents	Conducts root cause analyses/investigation and changes organizational policies, processes, and practices accordingly	Systematically conducts root cause analyses/investigation and leverages learnings to influence both internal and external affairs
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Executive Pay

11. Is executive pay linked to performance on one or more of the following sustainability topics?

Board Composition

12. Percentage of individuals within the company’s Board / highest governance body by:

	Number/Percentage	Not applicable (Please provide additional information)
Total number of board members (#)	11
Male (%)	73
Female (%)	27
Non-binary (%)	0
Under 30 years old (%)	0
30-50 years old (%)	9
Above 50 years old (%)	91
From minority or vulnerable groups (%)	0
Executive (%)	9
Independent (%)	27

Data Assurance

14. Is the information disclosed in this questionnaire assured by a third-party?

No assurance for any metrics

Limited assurance for minority of metrics (e.g., GHG emissions only)

Limited assurance for majority of metrics

Our Bank's Integrated Annual Report 2021 and the independent audit reports included in the Annual Report are audited by Güney Bağımsız Denetim and SMMM A.Ş. (EY). In addition, non-financial information was also subject to a limited assurance review by PwC Bağımsız Denetim ve SMMM A.Ş. (PwC Türkiye). Moreover, our Bank is also audited by the British Standards Institution (BSI) in compliance with ISO 14001 for the Sustainability Management System and ISO 14064-1 for the accounting and verification of greenhouse gas emissions derived from our operational activities.

Reasonable assurance for minority of metrics

Reasonable assurance for majority of metrics

Other (Please provide additional information)

Optional comment

Integrated Annual Report page 128 - 139

Human Rights

Commitment

2. Does the company have a policy commitment in relation to the following human rights issues?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy
Rights of women and/or girls
2020
Freedom of expression
2015
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

Human Rights Policy: https://www.tskb.com.tr/i/assets/document/pdf/TSKB-Human-Rights-Policy.pdf Gender Equality Policy: https://www.tskb.com.tr/i/assets/document/pdf/TSKB_Gender_Equality_Policy.pdf Equal Opportunities Policy: https://en.tskb.com.tr/i/assets/document/pdf/TSKB_Equal_Opportunities_Policy.pdf

2.1. For each human rights policy, is it:

	Aligned with international human rights standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving human rights expertise from inside and outside the company?	Other (Please provide additional information)
Freedom of expression
Digital security / privacy
Rights of women and/or girls
Access to culture
Rights of indigenous peoples
Free, prior and informed consent
Rights of refugees and migrants
Access to water and sanitation

Prevention

3. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following human rights issues?

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing /mitigating the risks/impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

2021 Integrated Annual Report - Social, Intellectual and Manufactured Page: 88 - 107

4. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this human rights issue?

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

2021 Integrated Annual Report - Social, Intellectual and Manufactured Page: 88 - 107

5. Who receives training for the following human rights issues?

	No training provided	Select employees	All employees	Contractors	Direct suppliers of the organization	Indirect suppliers of the organization	Other – such as partners, clients, etc.
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

6. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following human rights issues?

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

TSKB 2021 Integrated Annual Report - Social Capital Page 102

Response

7. During the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to adverse impact associated with the following human rights issue(s)?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Rights of women and/or girls
In 2021, there has never been such an event that TSKB should have been involved in.
Freedom of expression
In 2021, there has never been such an event that TSKB should have been involved in.
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the human rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

Develops a Company Human Rights and Employee Rights Policy, which pledges full compliance with the Universal Declaration of Human Rights, ILO Conventions ratified by Türkiye and the regulatory framework and legislation governing the human rights and work life in Türkiye. Discloses the policy and the roles and responsibilities associated for its implementation. https://www.tskb.com.tr/i/assets/document/pdf/TSKB-Human-Rights-Policy.pdf

Labour

Commitment

1. Does the company have a policy commitment in relation to the following labour rights principles?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy	Not applicable (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
2015
Child labour
2015
Non-discrimination in respect of employment and occupation
2019
Occupational safety and health
2015
Working conditions (wages, working hours)
2012

Optional comment

• TSKB takes care to implement the requirements of international conventions to which our country is a party, such as the International Labor Organization and the United Nations Universal Declaration of Human Rights, in line with basic principles such as human rights, labor rights, and social justice. Although collective bargaining is legally possible, employees have individual employment contracts. • Forced labor and child labor are included in the non-financed list in TSKB's Environmental and Social Impact Policy. https://www.tskb.com.tr/i/assets/document/pdf/TSKB-ENVIRONMENTAL-AND-SOCIAL-IMPACT-POLICY.pdf • TSKB published its Gender Equality Policy in January 2019. https://www.tskb.com.tr/i/assets/document/pdf/TSKB_Gender_Equality_Policy.pdf • TSKB published its OHS Policy in February 2015. https://www.tskb.com.tr/i/assets/document/pdf/Tskb-Occupational-Health-and-Safety-Policy.pdf • TSKB published its Remuneration Policy in September 2012. https://www.tskb.com.tr/i/assets/document/pdf/TSKB_Remuneration_Policy.pdf

1.1. For each labour rights policy, is it:

	Aligned with international labour standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving labour rights expertise from inside and outside the company?	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Prevention

2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following labour rights issues?

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing/ mitigating the risks /impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this labour rights issue?

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders, in particular workers' organizations, to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Aiming to fully comply with UN Declaration of Human Rights, UN Global Principles Act and Turkey’s legislation that arranges human rights and business life in Turkey, TSKB is against forced labor and child labor in Turkey and worldwide and supports the initiatives towards prevention of such illegal practices. Never discriminating among its employees, all assessments related to employees are free from all prejudice or discrimination (of gender, mental / physical handicap, age, race, religion, language, sect, belief, cultural or social class). TSKB takes measures against the types of conduct that might cause ill treatment or abuse, while allowing its employees to share their complaints anonymously. Other hand, TSKB hereby commits itself not to knowingly involve in directly financing any project about forced labour or child labour. It is aimed to raise awareness of the employees with the "Unconscious Bias" training, which we include under the title of diversity and inclusion.
Child labour
Aiming to fully comply with UN Declaration of Human Rights, UN Global Principles Act and Turkey’s legislation that arranges human rights and business life in Turkey, TSKB is against forced labor and child labor in Turkey and worldwide and supports the initiatives towards prevention of such illegal practices. Never discriminating among its employees, all assessments related to employees are free from all prejudice or discrimination (of gender, mental / physical handicap, age, race, religion, language, sect, belief, cultural or social class). TSKB takes measures against the types of conduct that might cause ill treatment or abuse, while allowing its employees to share their complaints anonymously. Other hand, TSKB hereby commits itself not to knowingly involve in directly financing any project about forced labour or child labour. It is aimed to raise awareness of the employees with the "Unconscious Bias" training, which we include under the title of diversity and inclusion.
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Optional comment

In both its headquarters buildings in İstanbul and in its branches TSKB is mindful of being in full compliance with all occupational health & safety laws and regulations currently applicable in Turkey. In addition, the bank also abides by a policy that takes into account internationally accepted occupational health & safety practices as well. The bank’s physical conditions and technical infrastructure are regularly checked for compliance with occupational health & safety laws and regulations. Current information about activities related to health and safety issues is published on the bank’s corporate intranet. Within the scope of the Occupational Health and Safety Law, it is obligatory for all employees to attend the "Occupational Health and Safety" trainings when starting work and to renew these trainings every three years. As the Human Resources Department, we conduct periodic training programs with our Bank's Occupational Safety Specialist and Doctor every year.

4. Who receives training for the following labour rights issues?

	No training provided	Select employees	All employees	Contractors	Direct suppliers of the organization	Indirect suppliers of the organization	Other – such as partners, clients, etc.
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

5. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights issues?

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Not applicable
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Performance

6. What is the percentage of employees covered under collective bargaining agreements?

	Percent of employees (%)	Unknown
Employees covered under collective bargaining (%)	0

Optional comment

Employees have individual employment contracts.

7. What is the percentage of employees in a trade union or other workers' organization?

	Percent of employees (%)	Unknown	Not applicable (Please provide additional information)
Employees in a trade union or on a worker committee (%)
Employees have individual employment contracts.

Optional comment

Employees have individual employment contracts.

8. In the course of the reporting period, what was the percentage of women in:

	Percent of women (%)	Unknown
Senior leadership level position	51
Non-executive board	27

9. What was the average ratio of the basic salary and remuneration of women to men (comparing jobs of equal value) during the reporting period?

	Salary ratio (%)	Unknown	Choose to not disclose
Women / Men (%)	0.1

Optional comment

https://en.tskb.com.tr/en/sustainable-banking/tskb-and-sustainable-banking/human-resources

10. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?

	Frequency of injury	Unknown	Choose to not disclose
Frequency of injury	0

Optional comment

In 2021 only 3 injuries occurred. https://www.tskb.com.tr/i/assets/Work%20Accident%20Data%202021%20.pdf

11. In the course of the reporting period, what was the company’s incident rate?

	Incident rate	Unknown	Choose to not disclose
Incident rate	0

Optional comment

No incident occurred, during the course reporting period

Response and Reporting

12. In the course of the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to the adverse impact associated with the following labour rights issues?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Although collective bargaining is legally possible, employees have individual employment contracts.
Forced labour
In 2021, there has never been such an event that TSKB should have been involved in.
Child labour
In 2021, there has never been such an event that TSKB should have been involved in.
Non-discrimination in respect of employment and occupation
In 2021, there has never been such an event that TSKB should have been involved in.
Occupational safety and health
In 2021, there has never been such an event that TSKB should have been involved in.
Working conditions (wages, working hours)
In 2021, there has never been such an event that TSKB should have been involved in.

13. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the labour rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

Environment

Commitment

1. Does the company have a formal policy on the following environmental topics?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy	Not applicable (Please provide additional information)
Climate Action
2021
Water
2015
Oceans
Turkey is surrounded by four seas; Marmara Sea (internal), Black Sea, Aegean Sea, Mediterranean. Therefore, we believe that the questions regarding "Oceans" are not applicable for our case and no selection has been made for the actions related to oceans within the questionnaire other than "Not applicable".
Forests / Biodiversity / Land Use
2015
Air Pollution
2015
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
2015
Energy & Resource Use
2015

Optional comment

TSKB Sustainability Policy and its complementary policies can be accessed via https://en.tskb.com.tr/en/sustainable-banking/tskb-surdurulebilirlik-yonetim-organizasyonu/our-sustainability-policy. In addition, TSKB’s Climate Change and Adaptation Policy is available via https://en.tskb.com.tr/i/assets/document/pdf/TSKB%20Climate%20Change%20Mitigation%20and%20Adaptation%20Policy.pdf Turkey is surrounded by four seas; Marmara Sea (internal), Black Sea, Aegean Sea, Mediterranean. Therefore, we believe that the questions regarding "Oceans" are not applicable for our case and no selection has been made for the actions related to oceans within the questionnaire other than "Not applicable".

1.1. For each environmental policy, is it:

	Aligned with international environmental standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving environmental expertise from inside and outside the company?	Other (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Prevention

2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following environmental issues?

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing/ mitigating the risks/ impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question	Other (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with these environmental topics?

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Optional comment

TSKB, as per its own Sustainability Management System, has the right to monitor and advice further mitigative actions for the selected investments of its Borrowers. Moreover, TSKB has in-house reporting and training actions to avoid/mitigate potential environmental risks as mentioned in the topics.

4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Climate Action
Water
Oceans
Not applicable
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

4.1. For each environmental topic in which the company sets timebound goals / targets, what kind of targets has the company set?

	Description of targets (e.g., what is the target, absolute vs. intensity, externally verified, on track, etc.)
Climate Action	Between 2021 and 2025, we aim to have a 60% share of loans linked to climate and environment-focused SDGs in the total loan portfolio. (Tracked yearly with external verification)
Energy & Resource Use	We aim to extend loans of at least USD 150 million to renewable energy projects by the end of 2022. (Tracked yearly with external verification)
Water	Finish Water Index We aim to have all Bank employees fill out the water-saving awareness questionnaire in order to determine the total water commitment of the employees and to raise awareness on this issue. (Tracked yearly)
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)	Business World Plastics Initiative Platform 0,5-ton plastic reduction target per year (Track yearly)
Oceans

4.2. For each environmental topic in which the company sets timebound goals / targets, how is progress against target / goal tracked?

	Progress is reviewed against goals annually or more frequently	Progress is reported internally to the most senior level	Progress is reported externally	Other (Please provide additional information)
Climate Action
Energy & Resource Use
Water
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Oceans

5. In the course of the reporting period, has the company been involved in providing or enabling remedy for any actual impacts associated with the following environmental issue(s)?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Climate Action
Water
Oceans
Not applicable
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Climate Action

6. What were the company’s gross global greenhouse gas emissions for the reporting period?

Scope 1 Emissions

Full

None

Emissions (tCO2e)

449

Scope 2 Emissions

Full

None

Emissions (tCO2e)

Scope 3 Emissions

Full

Partial

None

Emissions (tCO2e)

2748447

Optional comment

The quantification and reporting of the carbon footprint have been independently verified by BSI against the specifications defined in ISO 14064-1:2018. The verification activity has been carried out in accordance with ISO 14064-3:2019 and the principles of ISO 14065:2016. Electricity consumption was sourced from a renewable power plant with an I-REC certificate. Therefore, the amount of Scope 2 emissions (category 2 as per ISO 14064-1:2018) was reported and verified as “0” ton CO2e. TSKB’s Scope 3 emissions data includes the “financed emissions” (category 5 as per ISO 14064-1:2018). Financed clients, which are operating in carbon-intensive sectors (non-renewable power generation, cement, and iron-steel sectors) and have provided their verified MRV reports to TSKB, have been considered while calculating the “financed emissions” of TSKB. Both Scope 1 (Process and fossil fuel burning-related emissions obtained from the clients’ MRV Reports) and Scope 2 (electricity consumption-related) emissions of the clients have been taken into account. Outstanding risks and total equity and debt data have also been used to calculate the TSKB’s attribution factor for each client as per the PCAF’s methodology. The selected industries cover nearly 7.5% of the TSKB loan book but cause a significant part of TSKB’s total financed emissions when the breakdown of the global and/or Turkey’s GHG emissions as per sectors is considered. tCo2e Direct Category 1: 448.2 Indirect Category 2: 0 Indirect Category 3: 177.2 Indirect Category 4: 172.9 Indirect Category 5: 2,748,096 Direct GHG Emissions: 449 tCo2e Indirect GHG Emissions: 2,748,096 tCo2e Emissions from biogenic sources: - Total Direct and Indirect GHG Emissions: 2,748,869 tCo2e

7. What percentage of the company's revenue was invested in R&D of low-carbon products/services during this reporting period?

Percent of revenue (%)

Unknown

Not applicable (Please provide additional information)

Optional comment

The percentage of the Bank’s operating expenses in R&D of low-carbon products/services during this reporting period is 2.8

8. Has the organization acted to support climate change adaptation and resilience?

We have taken action to increase organization-wide resilience to climate change

We have taken action to increase resilience in our supply chains

We have taken action to increase resilience in the communities in which we operate

We have provided funding for climate change adaptation and resilience initiatives and projects

We have not taken actions to build climate change resilience in the reporting period

Other (Please provide additional information)

Unknown

Optional comment

TSKB published its Climate Risk Report in compliance with TCFD recommendations in 2021, which is available via https://www.tskb.com.tr/i/assets/document/pdf/TCFD-eng-2021-05-24.pdf As TSKB, we also search for new developments worldwide regarding the adaptation pillar of the green financing. Hence, we position ourselves in line with the emerging areas under the climate change adaptation subject. In 2021, TSKB published its Adaptation Theme Study Report which is available online at: https://en.tskb.com.tr/i/assets/document/pdf/TSKB-Adaptation%20Theme%20Study.pdf

Energy / Resource Use

9. Please report the company's renewable energy consumption as a percentage of total energy consumption in the reporting period.

% of total energy consumption

100

Unknown

Technology

10. What percent of the company's revenue came from environmentally friendly products / services during this reporting period?

Percent of total revenue (%)

0.1

Percent of the company's fee& commission revenue came from environmentally friendly products/services is 3.1

Unknown

Not applicable (Please provide additional information)

Overall Environment

21. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the environment principles, including any challenges faced and actions taken towards prevention and/or remediation.

Our Bank is an institution that internalizes sustainability in the Turkish market from its mission to business model and processes, in parallel with the global development of the concept of sustainability. Our Bank supports Türkiye's sustainable development with its products and services. In this context, our Bank has structured the Sustainability Management System (SMS) to cover all its business processes, in order to mitigate the environmental and social impacts arising from its banking activities and to support Türkiye's transition to a low carbon economy. The Sustainability Policy is the main framework of TSKB SMS. As of the end of 2021, TSKB SMS has been managed as per the Sustainability Policy dated February 26, 2015. Our Bank supports its Sustainability Policy with complementary policies under the environmental, social and governance themes. All sustainability works across our Bank are managed by the Sustainability Committee, which was established in 2014 and consists of 3 Board Members, CEO and 2 Executive Vice Presidents as of the end of 2021. A Sustainability Subcommittee was established in order to roll out sustainability activities throughout our Bank and to ensure their integration with all business processes in parallel with our vision, strategy, targets and business plans on sustainability and climate change. This Subcommittee has evolved into the Sustainability Management Committee in 2021. A team of 14 people consisting of TSKB CEO, Executive Vice Presidents directly related to sustainability and the heads of Sustainability Working Groups reports their activities to the TSKB Sustainability Committee. 2021 Integrated Annual Report – Governance Structure Page 30 – 34 2021 Integrated Annual Report – Natural Capital Page 73 – 87 2021 Highlights Third Sustainable Bond Issuance – Integrated Annual Report Page 53 Syndicated loan linked to sustainability KPIs – Integrated Annual Report Page 53 Sustainable bilateral borrowing agreements – Integrated Annual Report Page 53 ESG Risk Rating Improvement - Integrated Annual Report Page 87 TSKB and Climate Change – Integrated Annual Report Page 80 – 81

Anti-corruption

Commitment

1. Does the company have an anti-corruption compliance programme?

No, it is not an immediate business priority

No, but we plan to in the next two years

Yes

2021

Optional comment

https://en.tskb.com.tr/i/assets/document/pdf/ANTI-BRIBERY-AND-ANTI-CORRUPTION-PROGRAMME-2021.pdf

2. Does your company have policies and recommendations for employees on how to act in case of doubt and/or in situations that may represent a conflict of interest, e.g. with regard to gifts and hospitality, donations, sponsorship, or interactions with public officials?

No, and we have no plans to develop a policy

No, but we plan to in the next two years

Yes, included within a broader policy

Yes, articulated as a stand-alone policy

Optional comment

https://en.tskb.com.tr/i/assets/document/pdf/GIFTS%20AND%20HOSPITALITY%20POLICY.pdf

Prevention

3. Who receives training on anti-corruption and integrity?

Optional comment

As indicated in TSKB’s Anti-Bribery and Anti-Corruption Policy; The Policy is accessible by all the staff on the Bank’s intranet site. The entire Bank staff is regularly provided with the “Prevention of Laundering Proceeds of Crime”, “Competition Law” and “Anti-Bribery and Anti-Corruption Policy” trainings. The employees shall sign a document declaring that they would comply with the provisions of the Anti-Bribery and Anti-Corruption Policy and accept the results of any violating actions.

3.1. How often is such training provided?

	One time only	Every year	Every two or more years	We do not collect this data
All employees
Select employees
Contractors
Direct suppliers of the organization
Other – such as partners, clients, etc.
Indirect suppliers of the organization

4. Does the company monitor its anti-corruption compliance programme?

No, we do not monitor the anti-corruption compliance programme

Review issues on ad-hoc basis

Yes, through internal employee self-evaluations

Yes, through automated controls monitoring

Yes, through external independent monitoring

Yes, through other mechanisms

As indicated in TSKB’s anti-corruption compliance programme and policy; The Board of Directors is responsible for ensuring the Bank’s Anti-Bribery and Anti-Corruption Policy to be made written, implemented and updated. The audit of compliance with the provisions of Bank’s Anti-Bribery and Anti-Corruption Policy is carried out as part of the internal audit.

Response and Reporting

5. Please report the company's total number and nature of incidents of corruption during the reporting year.

	Number of incident(s)	Unknown	Choose to not disclose
Confirmed during the current year, but related to previous years	0
0
Confirmed during the current year, and related to this year	0
0

Optional comment

2021 Results: https://www.tskb.com.tr/i/assets/document/pdf/2021%20Results%20.pdf 2020 Results: https://www.tskb.com.tr/i/assets/document/pdf/2020%20Results.pdf

6. Within the reporting period, what measures has the company taken to address suspected incidents of corruption independently or in response to a dispute or investigation by a government regulator?

Initial case assessment

Internal investigation

Review by risk / ethics committee

Review by board of directors

External audit / review

Other (please provide additional information)

Not applicable/no incidents in the reporting period

7. Does your company engage in Collective Action against corruption?

No, it is not an immediate business priority

No, but we plan to in the next two years

Yes (please explain)

TSKB's Anti-Bribery and Anti-Corruption Policy explains TSKB's views and stance on the fight against corruption. https://en.tskb.com.tr/i/assets/document/pdf/ANTI-BRIBERY-AND-ANTI-CORRUPTION-PROGRAMME-2021.pdf https://en.tskb.com.tr/i/assets/document/pdf/TSKB%20Anti-Bribery%20and%20Anti-Corruption%20Policy%20EN%20web.pdf

8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the anti-corruption principle, including any challenges faced and actions taken towards prevention and/or remediation.

Our Bank organizes regular trainings for its employees every year on the fight against bribery and corruption. It also reviews its policies and programs and pays utmost attention to compliance with the policy and program.