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Competition Policy Statement

1. Introduction

Garanti BBVA’s Code of Conduct establishes compliance with the law as one of the principles of action of all those who form part of the Group by directing that “we must behave in accordance with the applicable laws and regulations.” Garanti BBVA believes that fair competition is one of the essential principles of a well-functioning market, which benefits the development, progress and well-being of society.

Section 3.14 of the Garanti BBVA Code of Conduct reinforces these principles by stipulating that the professional activity of the members of Garanti BBVA must be carried out “with respect for fair competition” and by avoiding “behavior which unlawfully restricts it or which might be considered as unfair competition”, such as:

- Negotiating or making agreements with competitors on pricing, product offerings, production levels, allocation of customers or markets or market share, boycotting of certain customers or suppliers; or any other type of unlawful behavior restricting fair competition.
- Behavior which might be construed as an abuse of a dominant position.

2. Scope of application

These principles are applicable to all entities that are part of Garanti BBVA group and compliance with these principles and aspects is mandatory for all its employees at all levels throughout the Group in all activities related to their positions and functions.

3. Key Aspects

Garanti BBVA determines and supervises the compliance with general principles for actions aimed at preventing violations of the Competition Law for employees at all levels of the Bank and its subsidiaries.

Within this scope, The following general principles for action must be followed:

a) In order to be able to implement the preventative actions that might avoid an anticompetitive practice, it is necessary to act with caution and common sense. It is preferable to seek advice in advance of, or to avoid, doing something that may raise concerns.

b) In addition to the aspect above, activities which may constitute a violation against the Competition Law and principles to adhere in order to prevent such risks are as follows:

i. It is not allowed to enter into agreements or practices between competing undertakings that, regardless of their form, could prevent or distort the normal functioning of competition.
ii. Contacts with competitors whose content and development present risks or doubts as to their compliance with the established principles or with competition law should be avoided.
iii. Under no circumstances shall any of the following practices be discussed or agreed upon with competitors: to fix prices, discounts, commissions, margins or any other trading conditions with customers or third parties (except in the framework of legitimate business collaboration agreements), to limit production, services, markets, technical development, or investments, to allocate customers, territories and/or markets, to coordinate the submission of bids in competitive tender procedures, whether by fraudulent bidding or by other means (except in the framework of legitimate business collaboration agreements) and to boycott certain customers or suppliers, other competitors or new undertakings trying to enter the market.

c) Sharing with or receiving from competitors (directly or through a third party) confidential data of a commercially sensitive nature that may reduce strategic uncertainty in the market should be avoided.

d) When attending meetings or events organized by trade associations, risk of engaging in potential anti-competitive behaviors should be avoided.

e) Any commercial collaboration agreements with other non-competitor companies outside the Garanti BBVA group must also comply with competition laws.

f) In markets where Garanti BBVA has a high market share, unilateral actions, practices or agreements, the purpose or effect of which is to drive competitors out of the market, prevent the entry of new competitors, or impose abusive conditions on customers or business partners, should be avoided.