SİPAY ELEKTRONİK PARA VE ÖDEME HİZMETLERİ A.Ş. (“Our Company”) INFORMATIVE TEXT ABOUT ULTIMATE BENEFICIAL OWNER

Within the scope of Article 13 of the Law on Prevention of Laundering Proceeds of Crime (Law No. 5549), our Company obligated to whether payment users are acting on someone else’s account, in accordance with Article 17 of the Regulation on Measures Concerning the Prevention of Laundering Proceeds of Crime and Financing of Terrorism, and hereby article 17/A ensure that the real beneficiary is recognized in accordance with the law.

Our company is making this notification in order to remind those who act on their own behalf or on behalf of someone else, within the scope of Article 15 of Law No. 5549, of their responsibilities and to ensure that the necessary measures are taken, before its branches, representatives and similar affiliated units.

The term “Beneficial Owner” is commonly referred to as the “Ultimate Beneficial Owner” in international texts. This designation implies that it pertains not to intermediaries involved in transaction execution, but rather to the individual or entity ultimately impacted by the transaction

The Ultimate Beneficial Owner Form must be completed in accordance with the provisions outlined in Tax Procedure Law General Communique No. 529. The relevant form can be accessed by logging in to the Interactive Tax Office (gib.gov.tr/internet tax office/other notification and information entries) using the taxpayer’s Revenue Administration Internet tax office password. You can locate the “Notification Form for the Ultimate Beneficial Owner ” under the “Other Notification and Information Entries” menu on the page.

When filling out this form, legal entities:

  1. a) Real person partners who have shares exceeding twenty-five percent of the legal entity, including bearer bonds,
  2. b) If it is suspected that the real person partner with more than twenty-five percent of the shares of the legal entity is not the Ultimate Beneficial Owner, or if there is no real person partner with such a share, the real person or persons who ultimately control the legal entity,
  3. c) In cases where the Ultimate Beneficial Owner cannot be determined within the scope of paragraphs (a) and (b), the real person or persons with the highest level of enforcement authority; will be reported as Ultimate Beneficial Owner.

In organizations such as ordinary partnerships or business partnerships that do not have legal personality:

  1. a) Real person or persons who have ultimate control over entities that do not have legal personality,
  2. b) If the Ultimate Beneficial Owner cannot be determined within the scope of paragraph (a), the real person or persons with the highest level of executive authority in the entity without legal entity will be declared as the Ultimate Beneficial Owner, in the capacity of a senior manager.

Natural persons who own shares exceeding twenty-five percent of the legal entity must be reported in any cases will be reported as Ultimate Beneficial Owner.

However, if there is a change in the actual beneficiary information, necessary notifications must also be made in accordance with the Articles 6/3 and 7/9 of the General Communique No. 529.