ANTI-BRIBERY AND CORRUPTION POLICY

SCOPE
This Code of Business Conduct and Ethics ("Code") covers a range of business practices and procedures. This
Code cannot and does not cover every issue that may arise or every situation in which ethical decisions must be
made, but rather sets out key guiding principles of conduct and ethics that TROY HOLDING CORP. and its branches, expects of its employees, directors and officers (including, without limitation, the Chief Executive Officer and the Chief Financial Officer). All references to "Employees" in this Code includes all employees, directors and officers of the Corporation).

PURPOSE
The Company is proud of the values with which it conducts business. It has and will continue to uphold the
highest levels of business ethics and personal integrity in all types of transactions and interactions
Given the variety and complexity of ethical questions that may arise in the Company’s course of business, this
Code of Business Conduct and Ethics serves only as a rough guide. Confronted with ethically ambiguous
situations, the Covered Parties should remember the Company’s commitment to the highest ethical standards
and seek advice from supervisors, managers or other appropriate personnel to ensure that all actions they take
on behalf of the Company honor this commitment.

ETHICAL STANDARDS

1) Conflict of Interests
A conflict of interest exists when a person’s private interest interferes in any way with the interests of the
Company. A conflict can arise when a Covered Party takes actions or has interests that may make it difficult to
perform his or her work for the Company objectively and effectively.
Conflicts of interest may not always be clear-cut, so if you have a question, you should consult with your
supervisor or manager or, if circumstances warrant, the chief financial officer or chief legal officer of the
Company. Any Covered Party who becomes aware of a conflict or potential conflict should bring it to the
attention of a supervisor, manager or other appropriate personnel or consult the procedures described in
Section E of this Code.
All directors and executive officers of the Company ( and the chief executive officers and chief financial officers
of Troy Precious Metals Trading Inc’s Branches) shall disclose any material transaction or relationship that
reasonably could be expected to give rise to such a conflict to the Chairman of the Company’s Audit Committee.
No action may be taken with respect to such transaction or party unless and until such action has been
approved by the Audit Committee

2) Fair Dealing
Covered Parties shall behave honestly and ethically at all times and with all people. They shall act in good faith,
with due care, and shall engage only in fair and open competition, by treating ethically competitors,
suppliers, customers, and colleagues. Stealing proprietary information, possessing trade secret information that
was obtained without the owner’s consent, or inducing such disclosures by past or present employees of other
companies is prohibited. No Covered Party should take unfair advantage of anyone through manipulation,
concealment, abuse of privileged information, misrepresentation of material facts, or any other unfair practice.

3) Confidentiality
Covered Parties must maintain the confidentiality of confidential information entrusted to them, except when
disclosure is authorized by an appropriate legal officer of the Company or required by laws or regulations.
Confidential information includes all non-public information that might be of use to competitors or harmful to the
Company or its customers if disclosed. It also includes information that suppliers and customers have entrusted to the Company. The obligation to preserve confidential information continues even after employment ends.

4) Compliance with Laws, Rules and Regulations
Obeying the law, both in letter and in spirit, is the foundation on which the Company’s ethical standards are built.
In conducting the business of the Company, the Covered Parties shall comply with applicable governmental
laws, rules and regulations at all levels of government in the Republic of Turkey. Although not all Covered
Parties are expected to know the details of these laws, it is important to know enough about the applicable local
and national laws to determine when to seek advice from supervisors, managers or other appropriate personnel.

ANTI BRIBERY – CORRUPTION POLICY

Purpose
The purpose of Anti-Bribery is to ensure compliance with global rules, ethical and professional principles, laws
and regulations against bribery and corruption applicable in all Troy Branches as well as Head Office.
Bribery is a person's gaining advantage within the framework of an agreement reached with a third person so
that such person acts in breach of the requirements of his/her duty by doing or not doing a work, speeding up or
slowing down thereof, etc. Bribery and corruption may occur in various different ways, among these:

•  Cash payments,
•  Political or other donations,
•  Commission,
•  Social benefits
•  Gift, hosting,
•  Other benefits can be mentioned.

Our policy is clear: we do not tolerate the direct or indirect offer, payment, solicitation or acceptance of bribes in
any form. Facilitation payments are also prohibited. Our Anti-Bribery Policy includes specific instructions to
staff, such as requirements to avoid or declare potential conflicts of interest, and others that concern the offer or
acceptance of gifts and hospitality.
All Employees are expected to comply with all of the provisions of this Policy. This Policy will be strictly enforced
and violations will be dealt with immediately, including subjecting the Employee to corrective and/or disciplinary
action, including without limitation, dismissal or removal from office. Any third party agent who violates the terms
of this Policy, who knows of and fails to report to Troy management potential violations of this Policy, or who
misleads investigators making inquiries into potential violations of this Policy or who otherwise refuses to fully
cooperate with investigators, may have their contracts terminated.
Employees, who have concerns or questions about violations of this Policy, should report them to authorized
people. As the case of potential situation, it will be investigated each matter so reported and report to The Audit
Committee. The Audit Committee will have primary authority and responsibility for the enforcement of this
Policy, subject to the supervision of the Board of Directors.
When the bribery is proved, the Bribery is notify to authorized institution, and then Troy disengages with related
persons immediately.