Emergency and Contingency Plan

01 — Scope of Emergency and Unforeseen Circumstances

02 — Business Continuity Organisation

03 — Business Continuity Plan, Workflow and Procedures

Retention of records and negotiable instruments

All records and negotiable instruments required by legislation to be kept in printed form are held in printed form in the company’s archive. Instruments not sent to the archive are kept current within the company in partly locked cabinets and also in electronic form. Records such as securities entry and exit slips, the general ledger journal, transaction result forms, client order forms, session tracking forms, account statements, cash receipt and payment vouchers and transaction distribution lists are held electronically in the Optimus operating system.

Continuity and backup of information systems

A computer allocated to the company is available at the Alternative Working Centre designated under the emergency and contingency framework. This centre is far enough away not to be affected by extraordinary events and also has the necessary security. All backups are taken digitally in this protected environment. Printed documents are retained for the maximum statutory retention period and electronic backups for the period specified in the legislation. The full environment supporting business continuity has been established. Data providers (Matriks, İdeal, Foreks), all office software, information access systems and technical equipment such as telephone, fax and printer are ready for use.

Operational risk assessment

For unexpected hardware faults, a power unit and a backup server that are significant and replaceable are held in the information technology unit; software problems can be addressed immediately by the software provider over an online connection. For power cuts there are two UPS units to which all hardware is connected, and the main generator in the building housing the head office comes into service within ten seconds. Two separate data lines are used (TurkNet, Superonline); the system is configured with a BGP structure between routers so that if one line fails the other takes over without interruption. If the connection with the data broadcaster is interrupted, data is taken over the internet; should both fail, clients are informed through member representatives. Where the head office cannot be used because of natural disaster, terrorism, war or similar events, the alternative company centre is used.

Alternative communication channels for clients

When an emergency or unforeseen circumstance arises, the Emergency Committee examines the operability of all the company’s communication channels (telephone, fax, electronic) and determines which are available. The member designated by the committee uses the open communication channels and mobile telephones to advise clients how to reach the company. Transactions are carried out at the Alternative Working Centre using the communication equipment allocated to the company; contact both with clients and with MKK, Takasbank, the Capital Markets Board and other third parties for settlement is maintained from this centre. Remote access systems, FIX-API systems, MKK and Takasbank connections and the backups of the VİOP systems installed at the Alternative Working Centre serve as alternative communication channels for client transactions.

Alternative communication channels for employees

The duties and powers of the committee and of the company’s employees in emergency and unforeseen circumstances have been shared with them. It is assumed that, where an extraordinary event occurs, sufficient and competent personnel will be available to implement the Emergency Action Plan. In an extraordinary situation arising during or outside working hours, members of the responsible team are themselves responsible for reaching the Alternative Working Centre. The team members responsible for implementing the plan have been informed of the contact details, and the Emergency Committee convenes at that centre as soon as possible after an emergency is declared.

Assessment of possible effects on counterparties

Because all client assets (all cash and capital markets instruments) are held at Takasbank, no loss of client assets arises in the event of an emergency or unforeseen circumstance. The necessary Alternative Company Centre has been established under this plan so that clients, third parties and public institutions and organisations are not affected by such situations.

Informing the Board and mandatory notifications

Where an emergency or unforeseen circumstance arises and an extraordinary situation is declared, the company’s employees are informed first and all clients thereafter. The Capital Markets Board, BİST, MKK, VİOP, Takasbank and all other relevant official institutions are informed using the fastest available means of communication. Where activities are disrupted, the instructions of the official market regulators are followed so that the routine notifications required of the company are not interrupted. Routine mandatory notifications are made from the alternative company centre and/or from the help desks allocated by the relevant institutions.

Transfer of accounts if activities cannot continue

Where the Board of Directors resolves that the company cannot continue its activities because of an emergency or unforeseen circumstance, clients are informed and the operations required to transfer client assets are carried out with client approval. That resolution is announced continuously on the website. After activities have been suspended, and in line with the approval to be obtained from the Capital Markets Board, clients may apply directly to the Central Securities Depository and give instructions to effect their transfers. Board resolutions on the measures taken are notified to the Capital Markets Board for information.

04 — Emergency and Contingency Plan Officers

05 — Alternative Company Centre

06 — Legal Basis