1. Purpose

Apollo IoT Yazilim ve Enerji Teknolojileri A.Ş. is committed to maintaining high standards of integrity, transparency, and responsible business conduct. This Whistleblower Policy establishes a safe, confidential, and structured mechanism through which employees and external stakeholders may report concerns about misconduct, unethical behavior, legal violations, or actions that may negatively impact people, the environment, or the company.

Apollo encourages all individuals to raise concerns in good faith. This policy ensures that all reports are handled fairly, confidentially, and free from any form of retaliation.

2. Scope

This policy applies to all individuals interacting with Apollo, including:

• Employees (full-time, part-time, and temporary)
• Contractors and consultants
• Business partners and resellers
• Customers
• Suppliers and vendors
• Former employees
• Any other external stakeholders

3. What Can Be Reported

Concerns that may be reported under this policy include, but are not limited to:

• Fraud, corruption, or bribery
• Legal or regulatory violations
• Unethical business conduct or conflicts of interest
• Environmental or social harm
• Health and safety concerns
• Misuse or misappropriation of company resources
• Violations of data privacy or information security obligations
• Attempts to conceal any of the above

Apollo particularly encourages the reporting of concerns related to environmental impacts, sustainability practices, and the responsible use of energy resources.

4. Reporting Channels

Apollo provides dedicated, accessible reporting channels for both internal and external stakeholders. All channels support anonymous submissions.

4.1 Internal Stakeholders (Employees, Contractors, Consultants)

Employees and internal stakeholders may submit concerns through:

• Apollo Internal Whistleblower & Concerns Form is an anonymous Google Form accessible to all employees and internal stakeholders. Submissions are routed directly to the Founder team for review, bypassing direct management lines.
• Direct written communication with the Founder team, where the reporter prefers non-anonymous disclosure.

4.2 External Stakeholders (Customers, Partners, Suppliers, and Others)

External stakeholders may submit concerns through:

• Apollo’s External Whistleblower & Grievance Form is a dedicated form hosted on the Apollo website and powered by HubSpot. This form is publicly accessible and supports anonymous submissions. Submissions are reviewed directly by the Founder team.
• Official written communication via Apollo’s published contact channels, for stakeholders who prefer direct non-anonymous contact.

All reports submitted through these channels are received and reviewed directly by the Apollo Founder team,ensuring independence from operational decision-making and potential conflicts of interest in the handling of reports.

5. Confidentiality

Apollo treats all reports with strict confidentiality. The following measures are in place to protect the identity and information of individuals who raise concerns:

• Anonymous submissions through the designated reporting forms do not collect personally identifiable information unless voluntarily provided by the reporter.
• Where a reporter’s identity is known, their personal information is accessible only to the Founder team and, if required, to any external advisor engaged for the purpose of the investigation.
• Information related to a report is not shared with the subject of the report or with individuals not directly involved in the review process.
• Apollo will not disclose the identity of a whistleblower without their explicit consent, except where legally required to do so.

Personal Data Protection

Apollo processes personal data collected through whistleblower reports in accordance with the Turkish Personal Data Protection Law No. 6698 (KVKK). Personal data collected within the scope of this policy may include identity information, contact details, and information relating to the reported concern. Such data will be processed solely for the purpose of evaluating reports, conducting investigations, and ensuring compliance with legal obligations.

Where whistleblower reports are submitted through digital platforms operated by third-party service providers (such as reporting forms or cloud systems), personal data may be stored on secure servers located outside Türkiye. Apollo will ensure that any such transfers are carried out in accordance with applicable data protection laws and appropriate safeguards.

Data Retention

Records relating to whistleblower reports will be retained only for the period necessary to conduct investigations and comply with legal obligations, and generally not longer than five years unless otherwise required by law.

6. Protection from Retaliation

Apollo strictly prohibits retaliation against any individual, whether an employee or an external stakeholder, who raises a concern in good faith under this policy.

Prohibited retaliatory actions include, but are not limited to:

• Dismissal, demotion, or disciplinary action against an employee whistleblower
• Harassment, intimidation, or exclusion of the reporting individual
• Termination or adverse modification of a commercial or contractual relationship with an external whistleblower
• Refusal to engage in or continue fair business dealings with a supplier, partner, or customer who has raised a concern in good faith
• Any other action that disadvantages the whistleblower for having made a report

Apollo is committed to actively monitoring for and preventing retaliation, including during and after any investigation process.

This protection applies throughout and after the investigation process.

7. Mechanisms to Ensure Whistleblower Protection

Apollo has implemented the following specific mechanisms to ensure that whistleblower protections are practical and effective:

• Independent Reporting Line: All whistleblower reports are received and reviewed exclusively by the Founder team, ensuring that reports are not handled by direct managers or individuals who may be the subject of the report.
• Anonymous Submission Channels: Both the internal Google Form and the external HubSpot form support anonymous submissions. No identifying metadata is collected or linked to anonymous submissions without the reporter’s knowledge.
• Conflict of Interest Protocol: Where the concern involves the Founder team, Apollo will engage an independent external advisor or legal counsel to manage the review process, ensuring impartiality.
• Non-Retaliation Monitoring: Apollo’s Founder team is responsible for actively monitoring that no retaliatory actions are taken against any individual who has submitted a report, and for investigating any suspected retaliation.
• Documentation and Record-Keeping: All reports and related actions are documented and retained in a secure, access-restricted log maintained by the Founder team.

Compliance Oversight

Apollo may appoint a Compliance Officer or an internal Ethics Committee to support the review and investigation of whistleblower reports where necessary.

8. Investigation and Resolution Process

Fair Investigation Principles

Apollo will ensure that investigations are conducted objectively, confidentially, and in accordance with the principles of fairness and proportionality. Individuals who are the subject of a report will be treated fairly and in accordance with the presumption of innocence until the investigation is concluded.

All reported concerns will be reviewed and assessed by the Apollo Founder team. The following process applies:

• Acknowledgement: Where the reporter has provided contact information, Apollo will acknowledge receipt of the report within approximately 5 business days.
• Initial Assessment: The Founder team will conduct an initial review of the concern to determine whether a formal investigation is warranted.
• Investigation: Where a formal investigation is required, Apollo will gather relevant information, engage appropriate internal or external resources, and assess the concern objectively and impartially.
• Resolution: Apollo will determine and implement appropriate corrective actions based on the findings of the review.
• Communication: Where possible and appropriate, Apollo will communicate with the reporter regarding the progress and outcome of the review. 

For anonymous reports where no contact information has been provided, Apollo will take appropriate corrective action internally. The reporter will not be individually contacted; however, where the concern relates to a systemic issue affecting a broader group of stakeholders, Apollo may communicate relevant updates through general internal or external communications.

For straightforward concerns, Apollo aims to complete its initial assessment and identify corrective actions within approximately 1–2 weeks. For complex matters requiring deeper investigation, Apollo aims to resolve the issue within approximately 3–4 weeks, depending on the nature and scope of the concern.

Where necessary, Apollo may engage independent external advisors, legal counsel, or auditors to assist with the investigation process.

Anonymous reports will be reviewed to the extent possible. However, the ability to investigate such reports may be limited if insufficient information is provided.

8.1 Corrective Actions and Resolution

When an external stakeholder concern or grievance is validated, Apollo determines and implements appropriate corrective actions based on the nature and severity of the issue.

These actions may include:

• Internal review and operational adjustments
• Service improvements or direct engagement with the stakeholder
• Suspension or termination of the commercial relationship where retaliation or serious misconduct is confirmed (Section 9.2)
• Legal or contractual remedies, where applicable

Apollo ensures that concerns are addressed in a timely and proportionate manner, with a focus on resolving the issue and preventing recurrence.

Where appropriate, the Founder team communicates the outcome and corrective actions to the stakeholder.

For anonymous submissions where the reporter cannot be contacted directly, Apollo takes corrective action internally and, where relevant, may reflect improvements through operational changes or general stakeholder communications.

When an employee concern or grievance is validated, the Apollo Founder team determines and implements appropriate corrective actions based on the nature and severity of the issue.

These actions may include:

• Operational improvements or clarification of internal processes
• Direct engagement with relevant teams to resolve the issue
• Disciplinary action where a policy violation is confirmed (Section 9.1)

Apollo ensures that concerns are addressed in a timely and proportionate manner, with a focus on resolving the issue and preventing recurrence.

Where appropriate, the Founder team communicates the outcome and any corrective actions taken to the employee.

For anonymous submissions where the reporter cannot be contacted directly, Apollo takes corrective action internally and, where relevant, may communicate improvements through general internal communications.

In cases where a reported concern does not meet the criteria to be classified as a grievance, Apollo will document the rationale for this determination.

Where contact information is available, Apollo will communicate the reasoning to the reporting party through appropriate channels.

9. Consequences of Retaliation

Apollo takes violations of this policy seriously. The following consequences apply to any party found to have retaliated against a whistleblower:

9.1 Internal Stakeholders (Employees and Contractors)

Any employee or contractor found to have engaged in retaliation against a whistleblower will be subject to disciplinary action. Depending on the severity of the violation, this may include a formal warning, corrective measures, or termination of employment or engagement.

9.2 External Stakeholders (Partners, Customers, Suppliers, and Others)

Where an external party, such as a customer, business partner, or other third party, is found to have taken retaliatory action against an individual who raised a concern in good faith, Apollo will treat this as a material breach of its standards for responsible business conduct. Depending on the nature and severity of the retaliation, Apollo may suspend or terminate its commercial or contractual relationship with the relevant party, and may take further legal or contractual remedies as appropriate.

10. Good Faith Requirement

This policy is intended to facilitate genuine, good faith reporting of concerns. Individuals who submit false or deliberately misleading reports may not be entitled to the protections provided under this policy and may be subject to appropriate action.

Individuals who knowingly submit false allegations or act in bad faith may be subject to disciplinary action and may also incur legal liability under applicable laws.

11. Commitment to Responsible Business Practices

Apollo encourages open communication and responsible reporting as a core element of its commitment to ethical governance, transparency, and sustainability. This policy supports Apollo’s broader mission to help organizations manage energy use responsibly and reduce their environmental impact.

Apollo reviews this policy periodically and updates it as necessary to reflect changes in the company’s operations, applicable legal requirements, or best practices in responsible business conduct.

12. Policy Approval and Effective Date

This policy has been approved by Apollo’s management and enters into force as of the date of publication. Apollo may review and update this policy periodically to reflect changes in legal requirements or operational practices.

Apollo IoT Yazilim ve Enerji Teknolojileri A.Ş.  |  Whistleblower Policy Apollo v1.0