4.A History and Development of the Company Turkcell İletişim Hizmetleri Anonim Şirketi is a joint stock company organized and existing under the laws of the Republic of Türkiye, was formed in 1993 and commenced operations in 1994. In July 2000, we completed our initial public offering with the listing of our ordinary shares on the Borsa İstanbul and our ADSs on NYSE. In October 2020, TVF BTIH, a subsidiary of TWF, the wealth fund of the Republic of Türkiye, acquired control of 26.2% of the outstanding shares of our company, making it our largest shareholder. 19.8% of our shares are controlled by our second largest shareholder IMTIS Holdings S.á r.l. (“IMTIS Holdings”), an entity in which Letterone Investment Holdings S.A. has an indirect economic interest. As Türkiye’s leading premium operator based on ICTA, Turkcell holds the largest mobile spectrum portfolio in the Turkish market. Following the 5G spectrum tender that was held on October 16, 2025, Turkcell has a total spectrum bandwidth of 394.4 MHz, which increased from the 234.4 MHz held prior to the auction. With the introduction of 5G services nationwide, Turkcell’s network supports end user speeds exceeding 2 Gbps, enabling customers to enjoy a better network experience and to access mobile services at speeds comparable to fiber broadband. 37 Table of Contents In the 5G spectrum tender, Turkcell secured a total of 160 MHz of additional spectrum across the 700 MHz and 3.5 GHz bands. Specifically, the Company was awarded 2x10 MHz FDD bandwidth in the 700 MHz band and 140 MHz of TDD bandwidth based on spectrum capacity in the 3.5 GHz band. These spectrum rights are valid through December 31, 2042. By acquiring the maximum allowable bandwidth under the tender’s spectrum caps, Turkcell reinforced its market leadership with a 41.6% share of the total mobile spectrum allocated to the operators in Türkiye. Commercial utilization of the newly acquired frequencies commenced nationwide on March 31, 2026, successfully preceding the targeted April 1 timeline and marking a significant milestone in our network evolution. Turkcell’s 5G rollout encompasses Non-Standalone (“5G NSA”) and Standalone (“5G SA”) data architectures, complemented by Voice over New Radio (“VoNR”) to provide a complete 5G service portfolio. Our Company is obliged to pay a monthly treasury share to ICTA, amounting to 15% of our gross revenue. Of this amount, 90% is considered as the treasury share, while remaining 10% is allocated to the universal service fund. In addition, the Company pays annual contributions in an amount equal to 0.35% of net revenue towards the ICTA’s expenses and 5% of net revenue to the ICTA as a frequency fee (TRx). Along with the new 5G allocation, Turkcell has obtained renewal rights for its existing authorizations (2G, 3G and 4.5G) from April 1, 2029 to December 31, 2042. Within this scope, during the period between April 30, 2029, and December 31, 2042, each year, 5% of gross sales revenues (excluding VAT) from mobile services will be paid to the ICTA. Our Company is also developing its fixed line networks, including fiber-optics connecting directly to the home, creating a fiber-to-the-home (“FTTH”) network. In order to fill the gap in the areas where fiber cannot be provided, feasibly deployed, or that are constrained by xDSL service, an alternative fixed wireless access (“FWA”) solution is also offered. Under the Universal Service Laws, we pay the Turkish Treasury a yearly treasury share equal to 1% of annual net revenue from fixed services and pay annual contributions of 0.35% of net revenue to the ICTA’s expenses. Turkcell through its Turkcell Dijital İş Servisleri A.Ş. (“Turkcell Digital Business Services”) subsidiary, operates in the data center and cloud infrastructure business and continues to seek to expand in this sector through partnerships. Turkcell and its subsidiaries (“Turkcell Group”) entered into a strategic partnership with Google and its subsidiaries (“Google Cloud”) to support the delivery of Google Cloud services across industries in Türkiye and to accelerate the adoption of cloud services by cloud customers. As part of this collaboration, Turkcell will provide the infrastructure for a planned new Google Cloud region in Türkiye, which is expected to become operational in or around the 2028–2029 timeframe. This new Google Cloud region will consist of three or more zones and further expand Turkcell’s data center portfolio. In addition to acting as a trusted Google Cloud partner and reseller in the market, this initiative is expected to strengthen Türkiye’s digital ecosystem by enabling high-performance, low-latency cloud services, supporting local data residency requirements. By responding to growing demand for cloud solutions, this partnership is expected to contribute to Turkcell’s long-term growth in data center capacity and cloud-related revenues. We have a strong track record of profitable operations with total revenues of TRY 241.5 billion, Adjusted EBITDA of TRY 104.0 billion and net income of TRY 17.6 billion for the year ended 2025 (excluding non-controlling interests). We have achieved these results while continuing to invest in our network to support our strategy of offering quality services and innovative solutions, with capital expenditures totaling TRY 90.0 billion for the year 2025. For a description of our capital expenditures and divestitures, see “Item 5. Operating and Financial Review and Prospects—A. Operating Results” and “Item 5. Operating and Financial Review and Prospects—B. Liquidity and Capital Resources.” For information on principal projects recently developed, in progress and anticipated, see “—B. Business Overview” and for our methods of financing “Item 5. Operating and Financial Review and Prospects—B. Liquidity and Capital Resources.” At year-end 2025 we had 46.2 million subscribers for the Group compared to 45.2 and 44.6 million in 2024 and 2023 (on a comparable scope basis, excluding the subscribers of the Ukraine subsidiaries sold in 2024 referenced below). In addition to our operations in Türkiye, we have international operations in Belarus and Turkish Republic of Northern Cyprus. For more information, see “—B. Business Overview—IX. International and Domestic Subsidiaries.” On December 29, 2023, we signed a share transfer agreement with NJJ Capital for the sale of our Ukrainian subsidiaries lifecell LLC (“lifecell”), UkrTower LLC (“UkrTower”) and Global LLC. On September 9, 2024, the Company announced that the transfer of shares, along with all rights and liabilities of lifecell, LLC Global, and UkrTower had been completed. We are the only company listed on both the NYSE and the Borsa İstanbul, and had a market capitalization of TRY 4.8 billion as of December 31, 2025. Turkcell has also been included on the Borsa İstanbul Sustainability Index since 2014, and is part of Borsa İstanbul Sustainability 25 Index, consisting of companies with high performance on corporate sustainability. 38 Table of Contents The SEC maintains a website (http://www.sec.gov) that contains reports, proxy and information statements, and other information regarding issuers that file electronically with the SEC. The address of our principal office is Turkcell İletişim Hizmetleri A.Ş., Turkcell Küçükyalı Plaza, Aydınevler Mahallesi, İsmet İnönü Caddesi, No:20, Küçükyalı B Blok Ofispark, 34854, Maltepe/İstanbul, Türkiye. Our telephone number is +90 (212) 313 10 00. Our internet address is https://www.turkcell.com.tr. Our authorized agent in the United States is Puglisi & Associates, 850 Library Ave., Suite 204, Newark DE 19711. The contents of our website and other websites referred to herein are not part of this Annual Report. 4.B Business Overview Since 1993, Turkcell has played a central role in the development of the telecom industry in Türkiye, first as a traditional mobile operator, then as a converged telecom operator and digital service provider, and most recently as a technology and telecommunications company. Over recent years, we have strived to pioneer the provision of digital services in the telecom industry and at the same time, have retained our position as the mobile market leader in Türkiye on the back of our service quality, value proposition and strong distribution network. In line with this strategic vision we provide a wide range of cutting-edge digital services over our leading network, on top of offering high-end mobile and fixed voice and data services. We are a technology company maintaining our strong position in the market due to our customer-oriented approach as well as our ability to quickly provide diverse solutions to meet our customers’ communication and digital needs throughout the day. Our organizational structure reflects our aim of increasing efficiency and simplifying our business processes, as well as strengthening our position as a provider of mobile and fixed broadband communications, digital services, digital business services and techfin services. We operate under a GSM (2G) license granted in April 1998, which was renewed on March 31, 2023 for a further six years until April 30, 2029, a 20-year 3G license granted in April 2009 and a 13-year 4.5G authorization certificate granted in October 2015. In the 4.5G (IMT) auction held on August 26, 2015, we were awarded a total frequency band of technology agnostic 172.4 MHz, the largest amount of spectrum of any operator in Türkiye. We commenced offering 4.5G services from April 1, 2016. The 4.5G license is effective for 13 years until April 30, 2029. Most recently, in the 5G spectrum tender held on October 16, 2025, Turkcell secured an additional 160 MHz of spectrum across the 700 MHz and 3.5 GHz bands. Along with the new 5G allocation, Turkcell has obtained renewal rights for its existing authorizations (2G, 3G and 4.5G) from April 1, 2029 to December 31, 2042. We have differentiated our network through its quality and speed of service built on extensive spectrum rights covering 41.6% of the total spectrum available to mobile operators in Türkiye, with a wide network coverage. We have also focused on building an advanced fiber network to support our mobile and fixed offerings, including broadband and TV services. We have our own fiber network of 67.1 thousand km that is currently capable of offering up to 10 Gbps. Through our extensive investments in LTE Advanced infrastructure, we became the first operator in Türkiye to support NarrowBand-Internet of Things (“NB-IoT”), which is required for new generation innovative applications on LTE Advanced networks. Use of this technology is now available on request across our whole LTE footprint and enables machines to communicate faster and more effectively. Furthermore, through our Cat-M network support which enables fleet management, asset tracking and smart metering, and which is presently supported by few operators in the world, we are able to provide higher data transfer throughput and have more mobility for machine-to-machine communications. Turkcell’s broad spectrum and strong 4.5G infrastructure are poised to support a smooth transition to 5G, which we launched on March 31, 2026. The existing spectrum assets and network equipment facilitate 5G speeds through a dual approach: initially using 4.5G and 5G frequency bands in NSA mode, followed by the eventual conversion of 4.5G frequencies bands to 5G, utilizing our modern 4.5G and 5G infrastructure. With this approach, we aim to boost maximum 5G speeds, creating a competitive edge in the market. We had 46.2 million subscribers for the Group, including Türkiye, Belarus and the Turkish Republic of Northern Cyprus as of December 31, 2025. In Türkiye, we had 43.9 million total subscribers (39.1 million mobile, 3.3 million fixed and 1.4 million IPTV subscribers) as of the same date. The Group had previously divided its main operating segments into three groups: Turkcell Türkiye, Turkcell International, and Techfin. As of March 31, 2025, consistent with the Group’s strategy to provide integrated communications and technology services and to ensure economic integrity, the Group revised its operating segments in accordance with IFRS 8 Operating Segments. The Group’s segments are now “Turkcell Türkiye” and “Techfin” and “Other.” See “Item 5. Operating and Financial Review and Prospects—V. Reportable Segments and Reporting Currency.” 39 Table of Contents I. Industry a. Overview Mobile telecommunications technologies evolve at a very fast pace and, approximately every decade, a new generation of advanced cellular technology becomes available for use in mobile networks. These technology transitions enable an enhanced user experience via the introduction of higher data speeds, reduced latencies, and larger capacities, thereby paving the way for more advanced applications for end users. Since Turkcell started its operations in 1994, mobile technology has evolved from GSM (2G) to UMTS/HSPA+ (3G) to LTE/LTE-Advanced (4G/4.5G), and to 5G, delivering significant improvements in capability and customer experience. 2G was originally intended to carry voice, with some limited data and messaging capabilities, whereas the focus in 3G shifted more toward data, along with simultaneous voice and data capabilities. 4G has brought fully IP-based architecture where everything is considered data. The advent of 4G/4.5G technologies has enabled the introduction of increasingly sophisticated services featuring lower latency and higher data speeds, and capabilities to provide a variety of enriched services beyond mobile broadband, especially for vertical markets such as health, smart cities, transportation, agriculture, education and entertainment. Turkcell currently offers services over 2G, 3G, 4.5G and 5G technologies. Traffic on 2G and 3G networks has been steadily declining as customers upgrade their devices, SIM cards and subscriptions and demand higher data speeds. Following the conclusion of the 5G spectrum auction on October 2025, nationwide 5G services were commercially launched in Türkiye on March 31, 2026. In anticipation of this transition, the Company had begun strategically evolving its network architecture to meet next-generation technical requirements and ensure seamless integration. Prior to the full-scale rollout, Turkcell participated in a localized commercial 5G pilot at İstanbul Airport in July 2022 in collaboration with other mobile network operators. Turkcell has upgraded LTE base stations to support 5G service in existing frequency bands and is rolling out 5G base stations to operate on newly acquired 5G spectrum. In addition, as 5G sites require significantly higher backhaul capacity, Turkcell is upgrading transport infrastructure and expanding fiber connectivity to its sites to support higher bandwidth requirements, which will be critical for large-scale deployment of 5G base stations. Türkiye has a wide range of fixed broadband services including fiber, cable, FWA, and xDSL (ADSL or VDSL services). xDSL services are the most commonly used fixed broadband services in Türkiye where Türk Telekomunikasyon A.Ş. (“Türk Telekom” and together with its mobile segment Türk Telekom Mobil (“TT Mobil”) and TTNET, the “Türk Telekom Group”) is the incumbent operator in these services. xDSL services are provided over copper lines with limited data transmission capacity. There are also a number of alternative internet service providers delivering xDSL services using Türk Telekom’s infrastructure, primarily on a regional basis. The fixed broadband market has been shifting from xDSL services to fiber infrastructure, given the higher speed and capacity demanded by customers. Fiber technology offers superior capacity, delivering high-speed connections ranging from 10 Mbps to 10 Gbps. While fiber penetration in Türkiye currently presents a significant growth opportunity compared to other Organization for Economic Cooperation and Development (“OECD”) averages, our Company is strategically positioned to bridge this gap. We are committed to expanding our fixed-line infrastructure, with a particular focus on Fiber-to-the-Home (FTTH) solutions. In order to fill the gap in the areas where fiber services cannot be provided, feasibly deployed, or that require higher speed internet services than provided by xDSL service, an alternative FWA solution is also offered by the Company. This solution, branded as Superbox, has become a success for broadband access in areas where fiber penetration is limited or not available at all. b. The Turkish Telecommunications Market We believe that the Turkish telecommunications market holds growth potential, supported by favorable demographics – such as a relatively young, tech-savvy population combined with an earlier age of first mobile device ownership and lower penetration levels compared to Western Europe and other developed markets. Additionally, the 2026 5G launch presents opportunities in IoT business and increasing data usage. According to a TurkStat announcement, as of December 31, 2025, the estimated median age of the Turkish population was 35, lower than elsewhere in Western Europe, with the majority of the total population of 86.1 million people living in urban areas. There are currently two other major operators in the telecommunications sector in Türkiye apart from Turkcell: Türk Telekom and Vodafone Telekomunikasyon A.Ş. (“Vodafone”). 40 Table of Contents Acquired in March 31, 2022, 60% of the shares of Türk Telekom are held by our largest shareholder, TWF (for which they also hold an additional 1.68% of shares in its free float). The Republic of Türkiye’s Ministry of Treasury and Finance owns a 25% stake and the remaining 15% of Türk Telekom shares are publicly traded. Vodafone Türkiye is a privately held company, through which Vodafone entered the Turkish mobile market by acquiring Telsim on May 24, 2006 from the Savings Deposit Insurance Fund. II. Strategy Since its establishment in 1994 as Türkiye’s first GSM operator, Turkcell has played a defining role in the development of the telecommunications sector. Over time, in line with our convergence strategy, we expanded beyond mobile services into fixed broadband services and evolved into an integrated operator. As a next step, by developing our digital product and service competencies, Turkcell adopted a digital operator vision. While telecommunications remains our core business, today we are positioned as a technology and communications company, with a strong focus on emerging technologies and increasing investments, aiming to become a technology leader in Türkiye. In line with this aim, our roadmap for 2026 is centered on strengthening our strong infrastructure of mobile and fiber networks along with developing state-of-the-art data centers. Turkcell has been the market leader in terms of mobile network coverage in Türkiye with the largest spectrum holdings acquired in each of the 3G, 4G, and 5G tenders, leading mobile network speeds and population coverage exceeding 99.9% (based on Company calculations using industry-standard simulation tools and methodologies in accordance with applicable ICTA guidelines). We further consolidated this leadership position following the 5G spectrum tender held in October 2025. By securing the maximum permitted spectrum under the tender rules, Turkcell has widened the gap with its competitors in terms of spectrum assets. With the launch of 5G services on March 31, 2026, we are determined to utilize our experience and innovative capabilities for new advanced services along with our extensive coverage and fastest network. In our fiber business, we continue to expand the roll-out of our fiber network in order to increase residential access and support 5G infrastructure. We focus not only on network expansion, but also on delivering the best customer experience with the fastest fiber connectivity in Türkiye. In light of the strong growth of cloud services and AI, we continue to develop next generation data centers. As Turkcell, we estimate that we are Türkiye’s largest data center operator and market leader based on the IT capacity that we operate. We aim to drive growth in the cloud business through strategic partnerships. In November 2025, we announced a strategic partnership with Google Cloud to establish Türkiye’s first hyperscale regional data centers, a major milestone for the country’s digital infrastructure. Turkcell plans to invest USD 1 billion by the end of 2032. The new Google Cloud region in Türkiye will deliver a broad suite of services, including data storage, cybersecurity and AI, thereby positioning the country as a regional hub for advanced cloud technologies. Along with a strong focus on data center and cloud business, we also cover a large range of other digital B2B services. Turkcell Digital Business Services, our technology service provider company, continues to provide tailor-made, end-to-end ICT solutions, which include connectivity, security services, system integration and managed services, new generation technologies and business applications. As part of our B2C services, our unique portfolio of digital services, such as TV, music, data storage and digital communication, are made available to our customers through our market-leading telecommunication capabilities. This sets us apart from global OTT players. Additionally, we continue to deliver digital financial services, or “techfin services.” Through digital financial services, we strive to provide our customers with a complete portfolio of digital solutions to meet their financial needs and address the ongoing demand in digitalization of the payments ecosystem. With the aim of maximizing shareholder value, we continue to pursue our efficiency and optimization orientation. One of the most important components of our optimization strategy is energy management. We anticipate that energy will be one of our leading cost items in the short to medium-term. By further investing in renewable energy, we aim to partially balance our group energy costs and increase energy efficiency. 41 Table of Contents For the effective management of our capital, we adopted an approach of portfolio optimization, in which we systematically review our wide range of products and services to keep the product range dynamic and to ensure continuous simplification and focus. We strive to maintain continuous efficiency by strategically allocating our resources to the most effective areas, supported by ongoing evaluation and optimization from both strategic and financial perspectives. We also have a corporate venture capital fund dedicated to investing in start-ups. Finally, we continuously assess macroeconomic conditions and explore opportunities within some of our subsidiaries to unlock their value. We are increasingly integrating data analytics and artificial intelligence into our processes to enhance operational excellence. Internally, we use artificial intelligence to optimize processes such as customer support and experience, operational planning, predictive analytics, network technical support, robotic process automation (RPA) and intelligent automation. As a leading technology company, we are also focused on “things for people,” pursuing growth opportunities in fields such as digital health, wearables and smart home systems. As a pioneer of value-delivering, sustainable technologies in the industry, we are actively exploring transformative technologies such as 6G and satellite systems with industry leaders. We may advance our capabilities in emerging technologies such as AI, IoT and satellite communications through strategic partnerships with leading companies that have deep expertise in their respective fields. Sustainability is one of the key pillars of our strategic plan. With our net zero target for 2050 as the core objective, we aim to advance our operations in alignment with sustainability principles at global standards. Our core principle across all our business activities and sectors is to maintain a people-centric approach. We are committed to providing a unique experience for both our customers and our employees. To better understand our customers, we leverage our analytical capabilities and embrace digitalization to enhance their overall experience. Our focus is on providing an effortless, personalized, and consistent experience that ensures security, value, and customer satisfaction. When it comes to employee satisfaction, we are committed to supporting their physical, social, financial, and psychological well-being. Additionally, we aim to strengthen our corporate culture, enhance talent management, and implement a strategic workforce management project to drive long-term success. III. Customer Segmentation and Services a. Customer Segmentation In Türkiye, as of December 31, 2025, we had a total of 43.9 million subscribers including 39.1 million mobile subscribers, 3.3 million fixed broadband subscribers and 1.4 million IPTV subscribers. Turkcell Türkiye divides its customers into three main categories: consumers, corporate and wholesale. Within each category, Turkcell further divides its customers into specific segments and sub-segments. The aims of the segmentation are to: ● attract new customers; ● increase the loyalty of existing Turkcell customers; ● respond to the changing needs of customers with the support of digital services; ● ensure brand loyalty; ● create a seamless series of positive brand experiences across all customer interaction points; and ● maximize our value proposition by making the right offers to the right customers using analytical competencies. As part of our focus on customers and our strategic vision to provide digital services, we take actions designed to increase our customer base and customer loyalty, in line with the targeted segments’ lifestyles, needs, priorities, and expectations. Turkcell Türkiye’s three main customer categories are described below. 42 Table of Contents Consumer Category Our consumer category comprises mobile and fixed broadband customers. Mobile subscribers within this category are managed under the mass segment or within three major sub-segments: youth, women and premium. In addition, we apply a micro-segmentation approach, aligning each customer with tailored offers that best meet individual needs and expectations. In line with our strategy to strengthen our position as a digital service provider and expand our customer base, Turkcell offers a wide range of campaigns and digital services, including BiP, fizy, TV+, and lifebox, in response to market dynamics and customer demand. Fixed broadband customers are consolidated under a single residential segment and managed within the consumer category alongside mobile consumers. This structure is intended to enhance synergies between mobile and fixed businesses. The residential segment includes fiber internet customers served through Turkcell’s own fiber infrastructure, as well as DSL, fiber and cable customers, served through resale arrangements. Turkcell’s fixed wireless access service, Superbox, is also managed under the residential segment. Corporate Category The corporate segment for our mobile and fixed services comprises small and medium businesses as well as enterprise customers. We deliver customized mobile and fixed communication solutions tailored to the specific needs of each segment. In parallel, we facilitate our customers’ digital transformation through an integrated portfolio of digital business solutions aimed at improving operational efficiency, strengthening connectivity and supporting sustainable long-term value creation. Wholesale Category Our wholesale category focuses on managing wholesale voice, data, roaming, tower and digital services with the national licensed operators, international operators and network-centric business owners such as data centers and content providers. For roaming services, the wholesale category strives to achieve the best international coverage for customers to have continuous communication wherever they travel and to enable all visitors to enjoy the service quality of Turkcell. For wholesale data and voice services, our main strategy is to become the regional junction point in an increasingly digitally hyper-connected world, and while promoting our infrastructure in the international market, we are focused on growing as a preferred wholesale partner of local operators in the domestic market as well. b. Services We are one of the most valuable brands in Türkiye, which we attribute to our focus on superior technology, a wide subscriber base and being recognized as a leading brand. We provide high-quality mobile and fixed voice, data, TV and digital services to our subscribers throughout Türkiye over our advanced network, and have developed to become what we believe to be the premier mobile service provider in Türkiye by differentiating ourselves from our competitors through our analytical capabilities and strong customer insights. Our mobile subscribers can choose between our postpaid and prepaid services. As of December 31, 2025, we had 7.6 million prepaid and 31.5 million postpaid subscribers, compared to 9.2 million prepaid and 29.1 million postpaid subscribers as of end of 2024. Postpaid subscribers increased to 80.7% of our mobile segment at the end of 2025, up from 76.0% at the end of 2024, reflecting our strategic objective to enhance the postpaid composition of our total mobile subscriber base. Currently, the majority of postpaid subscribers sign a subscription contract for 12 months and receive monthly bills for services. Turkcell provides a range of fixed services in Türkiye including, broadband, voice and IPTV to consumers, as well as a broader portfolio of services to corporate customers, ranging from traffic carriage to cloud-based solutions. These services are delivered through a combination of Turkcell’s own fiber infrastructure, infrastructure-sharing arrangements and leased lines. 43 Table of Contents Accordingly, Turkcell offers fixed broadband services over the cable infrastructure of Türksat, the government-owned provider of cable and wireless broadcasting, high-speed internet and direct-to-home broadcasting services in Türkiye. In addition to providing cable, fiber, and DSL services through the infrastructure of other internet service providers, Turkcell began offering fiber services over the infrastructure of Türk Telekom, the incumbent, at the beginning of 2025. Fixed broadband subscribers are categorized as “Turkcell Fiber” and “Resell Fixed Broadband.” As of December 31, 2025, we had 3.3 million fixed broadband customers, including 2.6 million Turkcell Fiber customers, served through our own infrastructure and 713 thousand Resell Fixed Broadband customers (611 thousand ADSL, 26 thousand cable, and 76 thousand fiber). This compares to 3.2 million fixed broadband customers as of December 31, 2024, including 2.5 million Turkcell Fiber customers served through our own infrastructure, 779 thousand Resell Fixed Broadband customers (738 thousand ADSL, 35 thousand cable, and 5 thousand fiber customers). In addition to conventional telecommunication services (mobile and fixed broadband services), we also provide a range of digital services related to communication, data center, cloud to enterprises, techfin services as well as music streaming, entertainment to individuals and cybersecurity. (i) Voice Services Voice services are among the key services that we provide to our customers. Voice services consist of high-quality mobile communication services on a prepaid and postpaid basis and fixed voice services for consumers and corporate customers. (ii) Broadband Services Our broadband services consist of mobile broadband, fiber to the home/building, xDSL, cable and FWA over our mobile network. Our capability to offer 4.5G in all of 81 cities in Türkiye has resulted in increased network abilities and data speeds. We believe that 4.5G services coupled with the wider availability of technological products has contributed to a more connected life for our customers, resulting in an increase in overall internet usage. As of December 31, 2025, the number of subscribers who have signed up for 4.5G on our network was 36.6 million. This represents 94% 4.5G subscriber penetration of our mobile subscribers in Türkiye. Smartphones, which combine the features of a mobile phone with those of other digital mobile devices (e.g., personal digital assistants, media players, GPS navigation, digital cameras, etc.) and have an operating system (e.g., iOS, Android, etc.) that allows access to the internet and runs a variety of third-party and proprietary software applications, are an important component of the growth of our mobile broadband and digital services businesses. Smartphone penetration on our network reached 91.1% by the end of 2025, slightly up from a 90.8% penetration during the same period in 2024. With the increasing demand for data, average mobile data usage reached 20.0 GB per month in 2025, as compared to 18.2 GB per month in 2024, while average mobile data usage of 4.5G users reached 20.7 GB per month in 2025, as compared to 19.2 GB per month in 2024. The table below shows the number of smartphones on our network and smartphone penetration for the periods indicated: ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ 2025 ​ ​ ​ 2024 ​ ​ ​ 2023 ​ Number of smartphones on our network (millions) ​ 28.8 28.8 28.7 4.5G compatible smartphone share in total smartphones ​ 96 % 95 % 94 % Penetration(1) ​ 91.1 % 90.8 % 89.8 % (1) Smartphone penetration is calculated as the ending number of smartphone subscribers (excluding smartphone subscribers with deactivated status) divided by the ending number of Turkcell mobile voice subscribers (excluding Turkcell subscribers with deactivated status). Our distributor, dealers, Financell (our finance company), and Turkcell offer joint campaigns to subscribers, which may include the sale of devices by the dealer and a communication service to be provided by us. In addition, we sell handsets ourselves as a principal bearing inventory risk. A variety of devices are offered through these campaigns, such as smartphones, LTE-enabled modems and tablets and some complementary products, including accessories, game consoles, headsets and virtual reality sets. We deliver attractive joint campaigns with models of brands in high demand and some local handset manufacturers. We believe this contributes to increased smartphone penetration and data usage, further building customer loyalty by offering a technologically advanced product at a competitive plan. 44 Table of Contents When we sell goods or services as a principal, income and payments to suppliers are reported on a gross basis in revenue and operating costs, respectively. If we sell goods or services as an agent, revenue and payments to suppliers are recorded in revenue on a net basis, representing the margin earned. We offer fixed broadband internet tariffs to our residential customers. We also offer internet and TV bundles, where we benefit from the use of our own fiber infrastructure. We rely on the incumbent’s network to provide fixed broadband and other services outside our own fiber infrastructure, and in these circumstances, we differentiate our offering through our unique brand and our competitive customer service. We do not offer IPTV service on DSL because our TV technology is IP-based and has a multicast structure, and for technical reasons DSL infrastructure cannot support this type of service, however, we have alternative solutions that also work with xDSL services, like TV+ Pro. While Turkcell Superonline has made significant progress in the fixed broadband business, we believe there remains further opportunity for growth in Türkiye’s fixed internet penetration. With the acceleration of digital transformations, the demand for faster connections has become mandatory in fixed broadband services. Recognizing this need, we have been focusing on increasing the penetration of ultra-fast broadband speeds, particularly in offering 1,000 Mbps services. Over the past three years, we have concentrated our efforts in expanding the reach and adoption of 1,000 Mbps services, ensuring that our customers benefit from the latest in fiber connectivity. By providing these speeds, we not only meet the growing needs of our users but also differentiate ourselves from the competition, supporting ARPU levels and further decreasing churn rates. The ratio of new customers subscribing to these packages increased from 10% in 2024 to 28% in 2025. In addition to the internet and TV bundles, our residential broadband customers are offered fixed broadband and fiber device bundled campaigns, where specific models of new technology devices are offered to customers with 24-month internet service contracts. We also serve our customers with our FWA service “Superbox,” which offers wireless high-speed internet access for customers and is primarily preferred by those who are at locations with no fiber infrastructure. Superbox is the first and the widest FWA service in Türkiye. The required equipment is included in the subscription plan and uses the LTE Advanced network as a backhaul to provide internet connectivity in customers’ premises. Globally, FWA services have an expanded addressable market with the rollout of 5G technology, further enhancing accessibility. Following the 5G tender held in October 2025, we introduced our 5G Superbox-ready tariffs. Superbox subscribers are considered as mobile subscribers as the service is provided over our mobile network. (iii) Digital Services and Solutions Over recent years, Turkcell has developed its own digital services and solutions. Turkcell offers a broad portfolio of mobile applications which are available for download on application stores by all users regardless of their choice of mobile operator. These applications are developed and maintained by Turkcell’s in-house mobile application development teams. In 2025, we had 4.4 million standalone paid users. - BiP is a free, reliable, friendly, and solution-oriented platform that connects all of its users in 192 different countries. BiP aims to meet all communication needs of its users with fast and secure instant messaging, HD voice and video calls. Users can enjoy outstanding messaging features such as disappearing messages, instant automated translation for more than 100 languages and money transfer. BiP differentiates itself with advanced features like Discover services for corporate and personal use, and a Channels section for audience engagement. It also includes a Status section for 24-hour content sharing and an ‘Emergency’ button that alerts pre-selected contacts with the user’s location. - TV+ is a multi-screen TV platform launched in 2014, providing over 150 channels for subscribers to enjoy an enhanced television experience. Distinguished by features such as live stream pause and rewind, cloud recording, and the ability to switch between four screens, TV+ supports Ultra HD 4K content and is accessible on various platforms including Apple TV, Android TV, TV+ Pro and Smart TV applications. TV+ Ready is the first to introduce a bundled Android TV offer in the Turkish market, allowing users access to additional apps through the Google Play store. In addition to TV+’s ease of use; the platform strengthens its archive in sports, TV series, movies, children’s content and documentaries to increase the loyalty of its users. In 2025, we expanded our premium content offering on TV+ through strategic technology integrations and content partnerships with leading global studios, including a deep integration with HBO Max and a curated film catalog agreement with Apple TV. According to Information and Communications Technology sector report for the third quarter 2025, TV+ has 17.3% market share in IPTV market, being in the fourth position, based on number of customers. 45 Table of Contents - fizy is an audio streaming service offering more than 87 million songs, podcasts, videos, audiobooks and radio channels with high quality sound. The service is available through subscription plans such as premium music, premium audiobook, student, family and duo, which are offered on monthly or yearly terms and include data allowances. Premium users can stream ad-free, listen and enjoy offline access to music and audiobooks, and experience higher sound quality. Premium users can access the service with ad-supported listening, allowing them to stream music while experiencing fizy. The application uses enhanced-AI technology for increased personalization. - lifebox, Turkcell’s personal cloud service, provides worldwide users with a secure space for photos, documents, contacts, and videos, along with auto-sync and easy sharing features. Users receive 5GB of free storage upon downloading, and the service includes AI-driven features like PhotoPick for Instagram. Launched in 2020, “lifebox transfer” facilitates fast, free file sharing. - GAME+ is a gaming platform through which we started offering a brand-new experience in 2021, initially over Turkish servers as part of our cooperation with the world’s most popular cloud gaming platform, NVIDIA GeForce NOW. As the platform evolved, GAME+ expanded beyond cloud gaming and now also offers Ubisoft+, making it a comprehensive gaming platform. By combining cloud gaming technology with a game subscription service, GAME+ eliminates the need for powerful hardware, expensive devices, or large disk space. With GAME+, users can easily access high-quality games and premium gaming content without the traditional hardware limitations. Digital Identity Management Services Mobile Signature, introduced in 2007 as the world’s first mobile signature solution, employs public key infrastructure (“PKI”) on SIM cards. This innovative technology enables mobile subscribers to legally sign electronic documents and transactions in a manner equivalent to a wet-ink signature. As of 2025, Mobile Signature has reached 96 thousand subscribers, allowing users to securely verify their identity and conveniently conduct transactions in the digital realm. One-Time Password (OTP) is used by service providers as a secondary factor for authentication of transactions. The service allows providers to send a single-use password via SMS to their end users to ensure transaction security. It is commonly used by banks and other financial institutions for online banking and login transactions. Turkcell Advertising Solutions provides digital advertising services for SMBs, including targeted SMS and bulk SMS, display and social media advertising, enabling measurable and performance-oriented campaigns. For agencies and large brands, the platform offers media planning and campaign execution across alternative digital channels beyond Turkcell-owned platforms, leveraging data-driven targeting, optimization and reporting capabilities. (iv) Digital Business Services Turkcell Digital Business Services acts as a driver of digital transformation for thousands of companies in Türkiye. By integrating Turkcell’s telecommunication expertise with its role as a “Digital Transformation Business Partner,” we deliver comprehensive end-to-end solutions that address the evolving needs of both private and public enterprise customers. Furthermore, we implement projects with high value propositions while helping our clients increase their profits by lowering operating costs and/or generating higher revenue. Our strategy is rooted in leveraging connectivity services, system integration, and managed services, data center and cloud solutions, and next-generation technologies such as business applications, IoT, AI, and big data analytics. This portfolio, combined with our core telecommunication capabilities, allows us to lead in critical dimensions in ICT. According to IDC reports, we are the leading ICT solutions provider in Türkiye in terms of revenues. We aim to sustain this leadership by providing tailored digital solutions that streamline operations and improve customer satisfaction in a fast-evolving market. In 2025, Digital Business Services revenues reached TRY 22,759.1 million, up 24.7% from TRY 18,255.7 million in 2024. This growth was driven by growth in recurring services revenues, which increased by 21.5% to TRY 16,477.9 million in 2025 from TRY 13,566.7 million in 2024. On the other hand, hardware revenues increased to TRY 6,281.2 million in 2025 up 34.0%, from TRY 4,689.0 million in 2024. 46 Table of Contents Fixed telco & Cyber Security Services We serve the Turkish market with our 68 thousand km end-to-end fiber infrastructure, enabling us to provide superior quality service. Turkcell’s value proposition of connectivity infrastructure has three main components: fixed data services, fixed voice and unified communications services and cyber-security services. Turkcell provides telecommunication services by using its own fiber infrastructure, mobile network capabilities and other communication technologies to meet the connectivity needs of its corporate customers. With Turkcell’s carrier grade software-defined networking in a wide area network (“SD-WAN”) infrastructure, Turkcell serves traditional and next generation network services within a single solution. Turkcell intends to continue to keep on building a multi-vendor architecture with a white-box approach onboarding several more of the leading software vendors under the Turkcell SD-WAN and SD Security offerings. Managed Security Services are provided to corporate customers for their cyber-security needs and includes DDoS protection, managed firewall services, endpoint security (XDR-MDR) services, new generation security services such as penetration and vulnerability services, threat intelligence services, managed security operation center and security orchestration automation response service. At the beginning of 2021, Turkcell started offering cloud-based security services, which enables flexible capacity offerings with different security products and vendors. With this initiative Turkcell’s cloud-based security service portfolio gained quick installation capabilities. Turkcell is currently offering several main security vendors’ products on its own cloud infrastructure and plans to add new vendors to its security portfolio. Turkcell manages a “Security Operation Center” named “Cyber Defense Center – CDC,” which allows enterprise customers to take a holistic security approach by enabling them to collect security logs and correlate items to proactively detect security incidents. Turkcell also manages a Security Orchestration, Automation and Response (SOAR) service. With this service, customers’ security incidents can be immediately notified to customers via e-mail, automatically assigned to analysts and response actions taken in other network tools. As of December 31, 2025, Turkcell managed over 7.2 thousand cyber security services in total for around 3.6 thousand customers. Data Center & Cloud Services Turkcell offers a wide range of data center solutions to its corporate customers. These services range from co-location solutions to cloud infrastructure (next generation virtual servers and virtual data centers), backup, disaster recovery, kubernetes-as-a-service, finance cloud and security services. As of the end of 2025, Turkcell managed over 26,000 virtual servers and protected more than 35 petabyte of data for its corporate customers. Given the demand in the market and the recent signing of our strategic partnership with Google Cloud as described below, we aim to make further investments in data centers over the next years. Turkcell currently manages 32 data centers, four of which are classified as new-generation data centers and are also available for third-party sales. These new-generation data centers hold Tier III certifications (Design, Facility and Operations) from Uptime Institute, as well as LEED Gold, PCI-DSS and ISO 9001, ISO 27001, ISO 27017, ISO 20000, ISO 22301, ISO 10002, ISO 50001, ISO 45001, ISO 14001, ISAE 3402 and TSE 50600 certifications. As of December 31, 2025, our four new-generation data centers in Türkiye had a total design white space capacity of 31,550 sqm and a total potential IT power capacity of 54 MW, of which 50 MW has been commissioned as active capacity. ● Kocaeli Gebze Data Center, opened in 2016, has 10,000 sqm white space and 17 MW of total IT energy capacity on an area of 33,000 sqm. ● İzmir Data Center, opened in 2018, has 2,350 sqm white space and 3.4 MW of total IT energy power capacity on an area of 14,500 sqm. 47 Table of Contents ● Ankara Temelli Data Center, opened in 2019, has 12,000 sqm white space and 20.9 MW IT energy capacity on an area of 46,200 sqm. ● Tekirdağ European Data Center, opened in 2021, has 7,200 sqm white space, and 12.5 MW of total IT power capacity on an area of 37,272 sqm. As Türkiye’s largest data center operator, we aim to “keep Türkiye’s data in Türkiye” to ensure the security and privacy of personal and sensitive data. In this context, Türkiye’s regulatory framework, which requires the localization of data generated by critical sectors and infrastructures, contributes to the development of our business and revenues by increasing the demand for our data centers. Among our small data centers, Kartal legacy data center, was phased out in 2025. As part of the planned site closure, the physical relocation of IT infrastructure to the Söğütözü Data Center is currently underway, with completion targeted for 2026. Turkcell delivers high-availability and reliable cloud services through its four Tier III design-certified data centers. As one of the pioneers in Türkiye’s data center market, the Company maintains a competitive edge through early strategic investments and a robust infrastructure. Beyond traditional hosting, we offer comprehensive cloud solutions via our proprietary platform, Turkcell Cloud (www.turkcellbulut.com). This unified platform enables users to leverage cutting-edge technologies and ensure business continuity while eliminating the need for upfront capital expenditures. To meet the stringent requirements of the public sector, our Government Cloud service provides enhanced security measures to protect sensitive data. Notably, Turkcell Cloud is also Türkiye’s first cloud platform to achieve ISO/IEC27017 certification for cloud computing information security, underscoring our commitment to international standards. Furthermore, Turkcell offers Multi-Cloud services, providing seamless access to global providers such as Google Cloud, thereby offering our clients a versatile and scalable digital ecosystem. Turkcell Group has entered into a strategic partnership with Google Cloud to accelerate cloud adoption in Türkiye through the local delivery of Google Cloud services. The collaboration includes the establishment of a new Google Cloud region in Türkiye, which is expected to become operational in or around the 2028–2029 timeframe with three or more availability zones, supported by Turkcell’s local infrastructure and expanded data center network. As Google Cloud’s strategic partner and authorized reseller, Turkcell will enable enterprises across all sectors to access high-performance, low-latency cloud services while meeting strict data residency and regulatory requirements. This partnership supports advanced use cases in AI, data analytics, application modernization and cybersecurity, which we believe strengthens Türkiye’s position as a regional hub for digital innovation. As part of Turkcell’s strategic growth targets for this business, Turkcell aims to increase its data center capacity by more than double by the end of 2032 and increase by sixfold its data center reach and cloud revenues in USD terms over the same period. Turkcell projects that its investment in connection with this partnership will be USD 1 billion by the end of 2032. This discussion contains forward-looking statements based on current expectations that involve risks and uncertainties. Actual results and the timing of certain events may differ significantly from those projected in such forward-looking statements due to a number of factors, including those set forth in “Item 3. Key Information—D. Risk Factors—Risks Relating to Our Business—Our growth strategy is partly dependent on making investments in new opportunities, in particular outside of our core telecommunications activities, which may not be successful and which could affect our business and financial condition.” Our Data Center revenues increased by 57% to from TRY 2,000.5 million in the year ended December 31, 2024 to TRY 3,148.5 million in the year ended December 31, 2025. In the year ended December 31, 2025, our cloud services revenues increased to TRY 1,945.8 million from TRY 1,511.9 million in the year ended December 31, 2024. System Integration and Managed Services—End to End Solutions We provide end-to-end solutions for customers as part of their digital transformation process by combining our telecom and IT services capabilities. In these projects, we analyze the needs of our customers from a wide range of industries and provide tailor-made solutions to individual needs. To date, we have implemented around 5,800 projects with a Total Contract Value (TCV) of TRY 38 billion (not restated for IAS 29) as of December 31, 2025. Our project management team delivers diverse solutions tailored to client processes, including system integration, IT outsourcing, network security, application management, and IoT services. 48 Table of Contents New Generation Technologies and Business Applications a. Digital Business Applications& Solutions Business Applications ensure corporate customers a competitive advantage by providing essential business industrial solutions. The product portfolio is mainly based on cloud-based SaaS (Software as a Service) productivity and digital transformation products. Through our global productivity and collaboration offerings, we cover the mail, storage and conferencing needs of corporate customers. Additionally, digital invoicing and digital learning solutions, along with next generation products, are available to streamline customer processes, and provide operational efficiency through new revenue streams, better customer reach and experience. We focus on process automation, remote order and entry-level e-commerce solutions tailored for SMEs as these have become crucial since the COVID-19 pandemic. With the rise of the enterprise applications market, as well as improvements in mobile internet, cloud services and mobile devices, corporations have been undergoing a strategically important process of digital and mobile transformation. Turkcell aims to be a strategic business partner to companies in all industries for transformation projects designed to render processes manageable via mobile devices anytime and anywhere. b. Internet of Things Products & Solution Management Turkcell has been serving the Machine-to-Machine (“M2M”) and IoT business since 2009. Its principal markets in Türkiye include car telematics, team tracking, fleet management, POS terminals, security alarms, smart metering, mobile health management, smart agriculture, smart energy and sales force automation applications. As of December 31, 2025, the number of M2M subscribers increased to 5.9 million, up from 5.0 million as of December 31, 2024. Turkcell strives to continue its pioneering M2M business by expanding its services with new-generation technologies such as IoT, NarrowBand-Internet of Things (“NB-IoT”) and Long-Term Evolution for Machines (“LTE-M”) which is a type of low-power wide-area network radio communication technology standard developed by 3GPP for M2M and Internet of Things applications. Demand for these technologies, particularly NB-IoT and connected vehicle solutions, has grown in recent years across multiple industries. In addition to these technologies, eSIM-based solutions tailored to customer needs are available for Turkcell customers. In line with increasing demand in the automotive ecosystem, Turkcell continues to enhance its connected car offerings, providing vehicle manufacturers with end-to-end solutions covering data, SMS, voice and e-call services, while supporting evolving regulatory and safety requirements. We also design Industry 4.0 and energy solutions that aim to increase the productivity of enterprises in the field of intelligent production and integrated digital energy management. We provide solutions to manage smart factories that are redesigned for operational efficiency and lower energy consumption. These smart services include workforce tracking, social distance management, environmental conditions monitoring, forklift security, machine production management and panic buttons for production facilities to help them to increase occupational safety and efficiency. In order to respond more effectively to rapidly evolving market dynamics and increasingly diverse customer needs, Turkcell has initiated the development of its own M2M Connectivity Management Platform (CMP). This platform is designed to offer flexible, scalable and end-to-end connectivity management capabilities, enabling customers to manage their IoT and M2M services more efficiently while supporting the introduction of new use cases across different verticals. c. Industry Specific Solutions Besides our value-added IT services, we implement digital transformation projects with our consultants, who are experts in their fields, designing vertical solutions that address the needs of each sector. For our target sectors, including health, manufacturing, retail, central and local authorities, logistics, finance, energy and SMEs, we offer solution sets that meet industry specific requirements. 49 Table of Contents In the health industry, as a system integrator who provides and operates all relevant technology services and solutions, we hold a leading position in the public-private partnership (“PPP”) City Hospitals market in terms of both the number of beds and the number of hospitals, based on our estimates using publicly available information from the Ministry of Health. Eight city hospitals (Yozgat, Adana, Eskisehir, Elazig, Bursa, Basaksehir, Tekirdag and Gaziantep) are in operation and the entire technology infrastructure, from hardware to software and from systems to operations, are managed by Turkcell. As of year-end 2025, total bed capacity of the eight PPP hospitals was over 10 thousand, strengthening our position as a market leader. In addition to PPP City Hospitals projects, we also execute additional system integration projects awarded through tenders, such as a vaccine tracking system, an electronic emergency case system for ambulances and a health provision system for the Grand National Assembly of Türkiye. With our experienced consultants, we follow industry-specific digital transformation trends and provide end-to-end solutions by using new emerging technologies such as IoT, big data, AI and machine learning. In the manufacturing industry, we have implemented Industry 4.0 projects which enable companies to harness the power of data in order to streamline their operations, reduce maintenance costs and ensure quality in the manufacturing process. Several Industry 4.0 projects were implemented in pharmaceutical, heavy industries, oil and gas and automotive supplier industries in 2025. For example, in 2025, private network projects were launched especially in the defense industry and the petroleum sector. These projects enabled the implementation of sector-specific use cases focused on efficiency at fuel filling stations. In addition, in the defense industry, we conducted R&D studies. We will continue to focus on this critical industry. In addition, we offer technological solutions for our customers’ sustainability issues. Finance and retail companies require energy monitoring and management systems that provide sustainable solutions. We applied special IoT solutions for these sectors and enabled at least 20% efficiency improvement in their energy use. We have also recently focused on private LTE/5G networks to enable our customers to communicate within their companies with greater accessibility, reducing non-productive time. By analyzing dynamic and real-time data through our big data services, we are able to support our customers’ strategic decision-making processes, thus contributing to their profitability and efficiency. Throughout their digital transformation journeys, we meet the needs of organizations from end-to-end, ranging from team and document management to digitalization of financial processes and staff trainings. For one of our clients in the finance sector, we are developing big data infrastructure for the organization’s mobile and web-based trading application, enabling simultaneous real-time and historical data analyses. Another project in the public sector focused on the creation of an open data platform by the execution of analytical models using sensor, mobility and local governance data in order to provide customized public services. Upon its completion in 2025, the project transitioned our data infrastructure to a big data architecture to enable scalable analytics, support high concurrent access and optimize resource management. In addition to the foregoing, comprehensive projects encompassing on-site maintenance, repair, and support services for the IT-based hardware of designated public institutions operating on a nationwide scale are undertaken by Turkcell DBS. We also provide various solutions for the retail industry in order to meet customer requirements by adding essential technologies such as machine learning and computer vision technologies. Some use cases are customer segmentation, customer activity at sales point, customer demographic analysis and visitor monitoring. d. Partner Ecosystem and Vendors We work with around 240 partners in our ecosystem. We have consolidated our partners into three different categories: (i) Sales partners: Through our sales business partners, we focus on creating new sales prospects for our products, services and system integration projects. Our wide network of these companies enables our services to achieve sales targets. (ii) Project solution/value add partners: We deliver project-based hardware, software and managed services solutions to our corporate customers together with our project solution partners. (iii) Product solution partners: Product solution partners offer and/or develop specific corporate product solutions for Turkcell corporate customers. 50 Table of Contents In 2025, we continued the “Partner Program,” which was launched in 2020, where we have created an incremental value of partnership for 35 sales business partners of different competencies in our ecosystem. We aim to grow our ecosystem qualitatively with a win-win approach, through which our partners are positioning our product/services together with their own solutions and services. We also continued the “Partner 360 Program,” which was launched in 2021, to enhance and further grow our partner ecosystem with new partners to focus on emerging technology opportunities. Our program also aims to provide additional synergies to generate mutual benefits and revenues to our existing ecosystem. With our global technological partnerships, we are deepening and adding new partners to the IT projects we implement for our customers by combining our ever-increasing competencies and extensive sales force. We aim to provide fast and effective solutions with the hardware and software catalog that we created specifically for the IT needs of our SME customers. See “Item 3. Key Information—D. Risk Factors” for a discussion of the regulatory changes affecting our digital services for consumers and corporates. (v) Techfin Services Turkcell focuses on techfin services through our digital payment services platform, Paycell, our finance company, Financell, our insurance company, Turkcell Dijital Sigorta A.Ş. (“Turkcell Dijital Sigorta”) and our insurance agency, Turkcell Sigorta Aracılık Hizmetleri A.Ş. (“Turkcell Sigorta”). In 2025, total techfin services revenues increased by 21.1% year-on-year to TRY 13,688.8 million. The main objective of Paycell is to provide consumers with easy access to financial services by offering fast, convenient and secure payment solutions through the combination of digital technologies and financial services categories to lead the transition into a cashless society. Paycell was established to provide techfin services, including mobile wallet, direct carrier billing (Pay Later), utility payments, POS solutions, prepaid cards (physical and virtual), domestic and international money transfers, Pay by Link, QR code payments and open banking services. We are committed to capitalizing on this well-established payment platform by leveraging our technological know-how as well as our advanced infrastructure. Paycell’s aim with end-to-end payment solutions is to bring the merchants and the consumers together, by offering ease-of-use, new technology and tangible benefits to consumers while facilitating further revenue generation for merchants through payment and CRM solutions. Our finance company, Financell, provides digital financing solutions to meet the product and service needs of Turkcell’s individual and corporate customers in various sectors by harnessing the agility of its infrastructure and the convenience of the mobile industry. Financell also provides shopping loans, automobile loans via merchant partnerships and solar panel loans via project firms. Operating in the non-life insurance sector, Turkcell Dijital Sigorta mainly provides device protection insurance products via Turkcell stores, Global Bilgi Pazarlama Danışmanlık ve Çağrı Servisi Hizmetleri A.Ş. (“Turkcell Global Bilgi”) call center and Turkcell digital channels. Turkcell Sigorta acts as an agent and arranges corporate insurance for Turkcell and its group companies that are based in Türkiye via Turkcell Dijital Sigorta and other insurance companies. (vi) Wholesale (i) International Roaming Our international roaming strategy has always been to achieve vast international coverage for our customers by providing continuous communication wherever they travel and to enable international visitors to enjoy the service quality of Turkcell. Our coverage extends to many countries worldwide through our roaming agreements. By December 31, 2025, Turkcell strengthened its roaming position in Türkiye, expanding to 210 destinations through agreements with 818 operators. 51 Table of Contents On January 20, 2015, we launched LTE roaming services for our subscribers in numerous locations around the world. As of December 31, 2025, our subscribers have experienced LTE roaming services with 364 operators in 151 destinations. We also provide international GPRS, MMS and 3G services. As of December 31, 2025, subscribers of 486 operators from 141 different locations have experienced LTE roaming services on the Turkcell network. We also provide roaming services for both postpaid and prepaid subscribers of foreign mobile operators visiting Türkiye. As of December 31, 2025, our subscribers can send international SMS to various destinations covered by our three SMS hub vendors. On June 29, 2021, we launched Non-Standalone (NSA) 5G roaming services for our subscribers in various locations around the world. As of December 31, 2025, our subscribers experienced NSA 5G roaming services with 172 operators in 80 destinations. On May 5, 2022, we launched the first Voice over LTE (“VoLTE”) outbound service in Türkiye. We have entered into direct international roaming agreements with GSM operators around the world, including in Cuba, Iran, Sudan, Libya and Syria. These arrangements have been entered into in the ordinary course of business and on arm’s-length terms that we believe to be in line with industry standards. Under roaming arrangements in the listed countries, our net revenues for roaming on our Turkish network totalled less than TRY 45.1 million (not restated for IAS 29) in 2025 while our net expense for our subscribers roaming on the networks of operators in the listed countries was less than TRY 12.8 million (not restated for IAS 29). In terms of revenue generation, we do not believe that our roaming arrangements with operators in Cuba, Iran, Sudan, Libya and Syria are material. For additional details regarding our international roaming agreements with Syria, please See “—XII. Disclosure Pursuant to Section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012 (“ITRA”).” (ii) Wholesale Voice Turkcell and Turkcell Superonline together supply wholesale voice service by establishing interconnection agreements with fixed line and mobile operators, MVNOs, international carriers and directory service providers, which provide “118” directory assistance services. As of December 31, 2025, Turkcell Superonline had interconnection agreements with over 90 national and international carriers. Turkcell has interconnection agreements with Türk Telekom, Vodafone, TT Mobil and other fixed telephony service operators and via these agreements, parties connect their networks to enable the transmission of calls to and from their mobile communications system. As of December 31, 2025, Turkcell had interconnection agreements with over 60 fixed line and mobile operators and carriers. In addition, as of December 31, 2025, Turkcell had agreements with six directory service providers. A full MVNO agreement was signed between Turkcell and NetGSM, a local telecommunications company, on November 5, 2020. Turkcell notified NetGSM of its MVNO service termination on August 2, 2024. Access services ceased on November 5, 2024, excluding SIM cards active before that date. To minimize the disruption and allow a grace period, Turkcell intended to maintain connectivity for those existing NetGSM SIM Cards for a transitional period from November 2024 based on fees determined by the ICTA. During the discussions, ICTA issued a decision requiring Turkcell to continue providing services to NetGSM until the resolution of the reconciliation process. ICTA subsequently issued another decision setting the mobile data access fees for 2024 and 2025 as a result of the reconciliation, and later required Turkcell to continue providing services to NetGSM for both existing and new subscribers. Turkcell has filed three lawsuits challenging these decisions while continuing to provide service to the lines active prior to November 5, 2024. The legal process is ongoing. As a result of the investigation conducted by the ICTA on this matter, Turkcell was fined TRY 50 million (not restated for IAS 29) for not providing Virtual Mobile Network Services to subscribers who were newly activated by NetGSM or who migrated to NetGSM via number portability. Turkcell filed a lawsuit against this administrative fine decision. In Türkiye, current interconnection rates are set by the ICTA’s decision on mobile termination rates (“MTRs”) and fixed termination rates (“FTRs”). For more information, see “—XIII. Regulation of the Turkish Telecommunications Industry.” 52 Table of Contents (iii) Wholesale Data Our vision on wholesale data is to become a premier regional wholesale provider, strategically bridging Europe, the Middle East and Asia. Leveraging Türkiye’s unique geography, we operate 19 strategic border crossings—including seven (five direct, two indirect) resilient routes to Europe and twelve high-capacity crossings to the East—to provide seamless connectivity. Our ecosystem offers a comprehensive suite of infrastructure and transmission services, from nationwide FTTx and IP Transit to advanced cybersecurity and VPN solutions. By partnering with Tier-1 operators and global content providers, we lead data localization efforts, ensuring direct network access and optimized traffic performance. Turkcell Superonline is the critical digital gateway for operators seeking scalable, secure, and high-performance connectivity across the region. Turkcell Superonline has been taking important steps aimed at developing İstanbul as the world’s newest and important internet and content base due to its geostrategic location by successfully handling the transformation of the “Silk Road” into the “Fiber Road.” Accordingly, the company provides a bridge between east and west, which supplies a continuous connection with partnerships, the Tier-1 operators and strategic partners between Asia, the Middle East and Europe. Turkcell Superonline provides telecom services to more than 150 international operators including Tier-1 companies, Content Delivery Networks (“CDNs”) and OTTs. As of December 31, 2025, we had the capacity to carry more than 39 Tbps of international traffic. IV. Tariffs Our charges for voice, data and digital services consist mainly of bundles and also monthly fees, subscription fees, and volume discount schemes and options under various tariff schemes. We have various segmented tariff plans for mobile that target specific subscriber groups (postpaid or prepaid, corporate or consumer). A majority of our customers choose all inclusive packages which include minutes to Turkcell and national calls, intra company calls (for the corporate segment), SMS and data. We offer our customers tailored solutions based on machine learning models, featuring diverse price levels and rich content options. We aim to provide the right offers to the right customers by considering parameters such as risk scores, usage patterns, tenure and other relevant factors. We also ensure that our customers reach the same offers through all channels. We use machine learning models to understand customers’ tendencies to purchase more or less inclusive packages. Additionally, we run a model that measures our customers’ churn tendencies. All these models are integrated into the offer management systems. Turkcell’s mobile offers are based on speed and quota. The tariffs are designed by taking different needs of each customer segment into consideration. Turkcell’s own fiber infrastructure enables fiber offers with speeds of up to 10 Gbps, which we usually offer as bundled with our TV product. Turkcell’s ADSL service offers speeds up to 16 Mbps. VDSL service provides higher speeds of up to 100 Mbps. Our cable internet offers are at speeds of up to 35 Mbps. Our FWA service Superbox offers speeds of up to 375 Mbps on 4.5G and up to 2.8 Gbps on 5G. Turkcell’s strategy is to provide the best customer experience through enriched value propositions and a well-invested infrastructure. A strong infrastructure, enhanced user experience and differentiated offers provide Turkcell with the flexibility to price its tariffs based on costs and investments, while also enabling the implementation of an inflationary pricing policy to a certain extent. Moreover, as Turkcell, we determine our prices according to macroeconomic and competitive conditions. Accordingly, we aim during these economic conditions to adjust our prices proactively to account for any increases in inflation. a. Consumer Tariffs and Loyalty Programs We mainly offer bundled tariffs including voice, data and SMS. We focus on providing a leading mobile experience in Türkiye, and in order to meet customer needs in different segments we offer a large portfolio of tariffs. Data quotas have become the key selling point in our tariffs which are enriched with our digital services. Our aim is to provide offers that are tailored to the individual needs of our customers, considering their tenure, data usage and risk score, thereby favoring customer retention. Our postpaid mobile tariffs are generally structured on a 12-month commitment basis. 53 Table of Contents To enhance customer experience and address common industry challenges, we provide our Smart Control Service to postpaid customers at no additional cost. This initiative enables users to prevent overages by granting them proactive control over their data consumption and expenditures. Our customers can easily purchase additional packages or change their tariff plans through all communication channels, enjoying a seamless and user-friendly experience. Customers restricted by the Smart Control Service can also connect directly to a customer representative when needed. In 2025, we launched Turkcell Tumbara – a free loyalty service that allows our customers to convert their unused mobile package benefits such as data, minutes and SMS into reward points. These points, as well as other additional points that can be earned through special promotions, are accumulated and can later be redeemed for various gifts. With Tumbara, we aim to strengthen engagement and focus on savings, whilst delivering a customer-centric experience. Turkcell Ailem (“Turkcell Family”), launched in November 2025 is, we believe, the industry’s first family group platform in Türkiye, offering innovative benefits, such as GB transfer, group creation and exclusive unlimited in-group calling under a single ecosystem. Accessible free of charge via the Turkcell App, the platform enables families to form groups of up to five members and enjoy collective advantages seamlessly. While empowering users with the advantages of teamwork, Turkcell Ailem also seeks to deliver an inclusive experience by offering special benefits to customers aged 65+, appealing to a broad demographic spectrum. Customers can easily create their own Turkcell Ailem groups through the Turkcell App and enjoy all these advantages at no additional cost. Turkcell aims to provide advantageous price schemes to its customers when they are abroad. With a customer-oriented focus, Turkcell offers alternative options depending on their roaming frequency. All Turkcell postpaid customers can enjoy the “Roam Like Home” offer, which allows them to use their domestic tariff while abroad by paying an additional daily fee. Alternatively, they can choose from our roaming packages, the Global and Traveler packages, which has various durations and content options. We have three applications called Platinum, GNC, and Turkcell Bizce which serve as platforms for our loyalty programs: ·Platinum is Turkcell’s premium customer program for both consumer and corporate subscribers. Customers who use Platinum and Platinum Black tariffs are eligible to use the privileges Turkcell Platinum offers through a specially designed application. Platinum tariffs offer richer package contents. The Platinum app offers one-on-one 24/7 customer service and gifts that suit the lifestyle of Platinum customers. Weekly discounts at popular online shopping brands, free GBs, device and accessory gifts, airport transfers, discounts on flight tickets and car rentals and fuel benefits are amongst the gifts that are offered through this Platinum program. ·GNC is a mobile application that offers entertainment and provides access to certain discounts for youth segment users. A number of entertainment platforms are available on GNC, which seek to increase engagement and provide advantageous offers and gifts. Young users can play GB-earning mobile games, attend game tournaments and win prizes on GNC. GNC also shares surprise data offers twice a week through gamification scenarios such as “Crack the Egg” and provides discounts and gift cards from bands that are popular with youth segment users in a platform “Galaxy,” where they collect stars to redeem gifts and discounts. ·Turkcell Bizce is a platform aimed at women that supports personal development and economic engagement for women. The platform provides customers free data packages via collecting coupons which also has tutorial videos and inspiring contents as well as games and special brand offers. The usage of Turkcell Bizce is data free. Shake & Win, Turkcell’s flagship loyalty campaign, continues to drive engagement by distributing over 400 million gifts in 2025. Providing customers the autonomy to select rewards has elevated satisfaction and secured consistent participation. Customer satisfaction was further enhanced through tailored benefits during significant occasions such as Ramadan and Eid al-Adha, alongside exclusive offerings for birthdays. By consistently providing these benefits, Shake &Win not only delivers exceptional value-for-money services but also contributes directly to high-quality customer retention efforts. Turkcell Gaming made significant strides in 2025 by offering specialized packages and benefits tailored for popular games and streaming platforms, with the goal of ensuring uninterrupted entertainment for our users. Furthermore, our data-rewarding (GB) games not only enriched the customer experience but also significantly contributed to the download, activity, and engagement objectives within the Turkcell app. 54 Table of Contents Turkcell Biz+ continues to offer a unique digital experience in 2025 with its flexible, commitment-free structure. Reaching over 100,000 users, this next-generation membership model provides privileges like a guaranteed 10 GB from Shake & Win, GB transfer, and exclusive brand partnerships. Turkcell Biz+ remains dedicated to delivering freedom and value without commitment. In fixed broadband products (fiber, DSL and cable internet), we have various tariffs for different internet speeds. We offer internet speeds ranging from 100 Mbps to 10 Gbps in fiber internet, which we provide through our own infrastructure. For resell products, our speed offerings are up to 1,000 Mbps for fiber, up to 100 Mbps for DSL and cable. To enhance our ability to respond swiftly to inflationary pressures, we have transitioned from offering tariffs on both a 12-month and 24-month commitment basis for fixed broadband to offering all our fixed tariffs on a 12-month commitment basis. Currently, 24-month commitments is only eligible as part of device campaigns. In addition, as of August 2025, we have transitioned our resell product (TTFiber, xDSL and cable) from commitment-based tariffs to non-commitment tariffs. We offer IPTV service, namely TV+, bundled only with our fiber internet service on our fiber infrastructure. Further, we also offer new technology device campaigns with fixed broadband internet packages. In 2020, we launched TV+ Ready, which enables TV+ to be used with any fixed broadband technology. For households located in areas where our fiber infrastructure is not available, we offer the FWA service, Superbox, served through our 4.5G network. The Superbox device is included in the subscription plan. b. Corporate Tariffs and Loyalty Programs Our strategic focus is on comprehensively addressing the diverse needs of corporate customer segments by integrating connectivity services with digital transformation solutions. Our tailored offerings, built on best-in-class network quality and superior customer experience, are designed to meet the specific requirements of each industry and customer segment. We provide a broad range of bundled packages that include voice minutes, data, SMS, company on-net services, roaming and international minutes, delivering reliable, high-performance communication solutions that emphasize quality, continuity and long-term value. Through the İşTurkcell Plus Loyalty Program, we provide our corporate customers with non-telecom benefits that support the optimization of business expenditures while enhancing employee satisfaction. By offering a broad range of benefits across categories such as car rental, insurance, healthcare, retail, vehicle maintenance and courier services, we strategically support our customers’ business operations and foster mutual, long-term loyalty. c. Wholesale Tariffs Based on Turkcell’s roaming agreements, Turkcell hosts subscribers of foreign operators on its network. When a subscriber of a foreign operator makes a call using Turkcell’s network, that subscriber’s operator pays us our inter-operator tariff for the specific call type. Inter-operator tariff is a wholesale tariff applied between mobile operators with roaming agreements. Interconnection rates in Türkiye are based on the ICTA’s decision on the interconnection tariffs for Turkcell, Vodafone, TT Mobil, Türk Telekom and fixed-line service operators. With respect to data sales, Turkcell aims to provide competitive prices to promote İstanbul as a regional hub for peering and IP transit services and international capacities, as well as to support the domestic wholesale market through its robust network with feasible commercial conditions. 55 Table of Contents V. Churn The mobile churn rate is the percentage of disconnected subscribers calculated by dividing the total number of subscriber disconnections during a period by the average number of subscribers for the same period. For these purposes, we define “average number of subscribers” as the number of subscribers at the beginning of the period plus one half of the total number of gross subscribers acquired during the period. Churn refers to subscribers who are both voluntarily and involuntarily disconnected from our network. Under our disconnection process, postpaid subscribers who do not pay their bills are disconnected and included in churn upon the commencement of a legal process to disconnect them, which commences approximately 180 days from the due date of the unpaid bill. Pending disconnection, non-paying subscribers are suspended from service (but are still considered as subscribers) and receive a suspension warning, which in some cases results in payment and reinstatement of service. As a regulatory rule, the operator can disconnect prepaid subscribers who do not top up above TRY 10 within 270 days. Under our churn policy, prepaid subscribers are disconnected from the system if they do not top-up above TRY 10 during a twelve-month period. Additionally, to eliminate lines that are unlikely to top up in the new year and to benefit from the tax paid to the regulatory authority for each active line at the beginning of the new year, the lines of subscribers who made their last top-up in the first quarter are closed within 270 days. Therefore, the deactivation process creates a seasonal effect in the last quarter of the year. We deactivated 326 thousand inactive prepaid customers in 2024 and 303 thousand in 2025 following their failure to make payment for a 270-day period. When new customers are gained, their lifecycle period is set at 155 days. After their first top-up, the lifecycle period is extended by 12 months. Otherwise, if they do not top-up after their activation, new prepaid customers lines are deactivated at the end of the 155 days. We present churn figures to reflect average monthly churn, which we believe is in line with market practice. In 2025, the average monthly mobile subscriber churn rate increased to 2.3%. The churn rate for the fixed broadband products is calculated in the same way as for mobile products, except in fixed broadband, customers who change infrastructure from fiber to DSL/cable or vice versa are also counted in the churn rate. The average monthly fixed churn rate increased at 1.7% in 2025. We believe we have an adequate allowance for doubtful receivables in our Consolidated Financial Statements for non-payments and disconnections amounting to TRY 1,174 million as of December 31, 2025 and TRY 1,081 million as of December 31, 2024. VI. Seasonality The Turkish mobile communications market is affected by seasonal peaks and troughs. Historically, the effects of seasonality on mobile communications usage have positively influenced our results in the second and third quarters of the fiscal year. Conversely, these effects have impacted our results in the first and fourth quarters. These seasonality effects have become less significant as we typically launch marketing campaigns to mitigate changes in demand levels. Summer holidays, local and religious holidays in Türkiye generally affect our operational results positively through higher consumption. The Turkish fixed broadband market is also affected by seasonal peaks and troughs. Historically, the effects of seasonality on fixed broadband usage have negatively influenced our results in the second and third quarters of the fiscal year. This is mainly due to the summer holidays, when both usage and number of subscriber acquisitions decrease and churn increases due to residents moving. VII. Mobile and Fixed Network a. Coverage Turkcell’s mobile network provides extensive coverage across Türkiye, including the Coastlines of the Black Sea, the Sea of Marmara, the Mediterranean Sea and the Aegean Sea. Enhanced coverage extends to sparsely populated areas, exceeding the minimum requirements for 2G licensing. The company aims to fully meet regulatory obligations for its 2G, 3G license agreements, IMT Authorization and the recent 5G Authorization. 56 Table of Contents Operating across the 700, 800, 900, 1800, 2100, 2600 and 3500 MHz bands, Turkcell continuously optimizes spectrum allocation and technology deployment in response to evolving customer demands, ensuring both wide coverage and high-capacity performance. Spectrum refarming is a strategic planning process to efficiently utilize frequency spectrum for newer technologies. With the increase in 4.5G usage, Turkcell focused on refarming the 2100 MHz band from 3G to 4.5G significantly enhancing LTE capacity and coverage. By the end of 2025, the 2100 MHz band accounted for 45% of total LTE bandwidth and carried the same proportion of total LTE traffic. In order to allocate 2100 MHz band for 4.5G services, 3G services moved to 900 MHz which increased 3G coverage with the help of lower frequency propagation. Also with the introduction of 5G, we have started refarming of some of our legacy frequencies such as 1800 MHz for more efficient use in the 5G network. As of December 31, 2025, our proprietary fiber network reached around 67.1 thousand kilometers and connected all cities across Türkiye. We offer fiber-to-the-home (“FTTH”) network and homepass in 30 cities, with the number of premises connected to our fiber network having reached 6.3 million. Through partnerships with Turk Telekom, Turksat and Vodafone, we are able to deliver fiber and cable (hybrid-fiber coaxial) internet service to more than 5 million additional households (by our calculation), bringing over total coverage to 81 cities. We also provide enterprise Wi-Fi services. In the fixed access network, we have two main network structures called fiber-to-the-building network (“FTTB”) and the FTTH network. We have started a transformation project to convert our FTTB network to FTTH network. With this transformation, we aim to provide multi-gigabit services to our customers and to reduce our carbon footprint. In FTTH networks, we are installing Gigabit Passive Optical Network (“GPON”) and 10-Gigabit-capable symmetric passive optical network (“XGS-PON”) equipment which is the latest access network termination for residential and corporate subscribers. These network structures enable Turkcell to offer high speed internet, TV and Voice over IP. The fixed access network also provides bandwidth requirement for mobile sites with metro ethernet services. b. Quality of Service The ICTA published the “Regulation on Quality of Service in the Electronic Communications Sector” on September 12, 2010, which became effective as of December 31, 2011 (See “—XIII. Regulation of the Turkish Telecommunications Industry” for further details). The Turkcell network currently exceeds the standards set by the ICTA. Typically, “dropped calls” are one of the important Quality of Service metrics on which we focus. The rate of calls that terminate involuntarily, or “dropped calls,” is calculated by dividing the number of dropped calls by the total number of calls. Turkcell’s dropped call rate is around 0.29%, which indicates that out of 10,000 calls only 29 end as dropped calls. The quality of service is continuously being enriched through extensive network optimization and investments in 2G, 3G, VoLTE and VoNR networks to improve both quality and capacity. According to various benchmarks, we believe that Turkcell has one of the best 3G and VoLTE dropped call rate performance compared to other networks worldwide. Customer experience is one of the key focuses for Turkcell, and there are several special solutions such as small cells, femtocells (small, low-power cellular base stations), Wi-Fi offload, in-building and high-capacity event solutions to enhance this experience. On the fixed network side, we continuously monitor traffic utilization in our access network to prevent saturation and upgrade capacity as soon as possible. Turkcell modifies and redesigns its network topology in anticipation of future requirements, which allows us to improve our quality of service performance. The optical transmission network relies on Dense Wavelength Division Multiplexing (“DWDM”) systems with Automatically Switching Optical Network (“ASON”) and Optical Transport Network (“OTN”) using protection mechanisms benefitting from alternative fiber routes wherever available. This increases the capabilities of re-routing in the event of service interruption. Thus, the delivered point to point services provide an availability experience up to 99.999%; a quality level defining the transmission network as an upper level “carrier-class” network. 57 Table of Contents c. Network Evolution (i) Radio Network Turkcell currently operates 2G, 3G, 4.5G and 5G networks. Nationwide 5G services officially started as of March 31, 2026 utilizing the 700 MHz and 3500 MHz frequencies acquired in the 5G spectrum tender as well as 1800 MHz frequency via partial refarming from the 4.5G network. Our 5G network can support NSA (Non-Standalone) and SA (Standalone) architectures that enable different flavors of 5G technologies to serve our customers with different 5G device capabilities with the outmost performance and capacity that can be made available to them. In the 5G spectrum tender held on October 16, 2025, Turkcell acquired 160 MHz of new spectrum from 700 MHz and 3.5 GHz bands, increasing its total spectrum assets from 234.4 MHz to 394.4 MHz. Turkcell was awarded 2x10 MHz FDD bandwidth from 700 MHz band and 140 MHz TDD bandwidth from 3.5 GHz band. By securing the maximum bandwidth permitted under spectrum caps, Turkcell maintained its spectrum leadership, currently holding 41.6% of total mobile spectrum allocated to operators in Türkiye. Nationwide commercial use of newly acquired spectrum commenced on March 31, 2026, with the official launch of 5G services in Türkiye. For voice services, VoLTE has been supported since day one to provide voice calls over our 4.5G network. We have activated Enhanced Voice Services (“EVS”) on our VoLTE service to further improve voice quality, making us one of the first mobile operators in the world to support this high-end feature. Applicable regulations require that our 2G network remain active until April 2029. However, the majority of our voice traffic is already carried over VoLTE. Along with the launch of 5G network, we have started to support VoNR services in addition to already existing 2G, 3G and VoLTE voice services. In order to provide a solution for VPN over wireless technologies like 4.5G, we announced the Mobile VPN offer to our corporate customers. Through this solution, corporates are able to connect to the internet cloud over a wireless interface using 4.5G technology, without sacrificing their service quality requirements. This is a fast and flexible solution for connections between their branch offices and headquarters. NB-IoT and eMTC (or LTE-M) are terms that typically refer to wireless communication technologies designed for IoT applications. These technologies are characterized by low power consumption, extensive coverage, and a requirement for low data rates. Through our investment in 4.5G infrastructure, we became the first operator in Türkiye to support NB-IoT and eMTC (LTE-M), which are required for a new generation of innovative IoT applications on 4.5G networks. These technologies are available on request across our entire 4.5G footprint and enable machines to communicate more effectively. Furthermore, through our LTE-M network support which enables fleet management, asset tracking and micromobility (such as rental scooters), we are able to provide higher data transfer throughput and have better mobility for IoT communications. We provide a “Wireless to the Home” or “FWA” service Superbox, which offers wireless high-speed internet access for customers without fiber connectivity. The service mainly uses 4.5G and 5G networks as a backhaul to provide internet connectivity at our customers’ premises. We aim to deliver the best possible experience to our customers by building our network infrastructure with the latest technologies available. Just as we deployed our 4.5G network with full 4x4 MIMO (multi-input multi-output) capability, we are now building our 5G network on advanced Massive MIMO infrastructure. Massive MIMO is an advanced wireless technology that leverages a large number of antennas to enhance communication between devices, enabling more users to connect simultaneously while delivering higher speeds and improved reliability. Together, these capabilities maximize spectral efficiency, further enhancing network capacity and overall user experience. Combined with the widest spectrum portfolio in Türkiye, we believe this provides Turkcell with a significant competitive advantage. Furthermore, we have been closely cooperating with our network vendors with a long-term perspective through projects that enable Turkcell to deploy the latest technologies even before they become available on the market. This puts Turkcell at the forefront of the technology race and allows for the evaluation of the benefits of new technologies during the development phase, and then their timely deployment once they become commercially available. 58 Table of Contents Turkcell continues to provide extensive support to projects involving domestic products, mainly in order to fulfill obligations related to the usage of domestically produced network equipment for 4.5G and 5G. Support for domestic and national product projects will be maintained following the 5G authorization. We cooperate with domestic companies regarding base stations, antennas, transports and infrastructure solutions. For example, the ULAK Project initially started as an initiative of the Undersecretariat for Defense Industries (“UDI”), aimed at designing and developing national software and hardware components for an LTE-Advanced communication system and enhancing Türkiye’s self-sufficiency in this area. ULAK has become a network vendor, producing 4.5G base stations. The 5th Generation Mobile Communication Infrastructure Development Projects were launched by the Transport, Maritime Affairs, Communication Research Center (UDHAM) within the Ministry of Transport and Infrastructure. In this context, we evaluated the project proposals of the companies determined by Turkcell and signed cooperation agreements with 8 companies on 11 projects. We support projects under the main topics of MIMO active antenna, core network, virtualization, 5G/NFV data security and OSS. Prior to the nationwide commercial launch of 5G, we have long promoted 5G technology by enabling our customers to experience these services through international roaming. Even before the local network was fully operational, subscribers with 5G-enabled devices and 4.5G SIM cards could access 5G services abroad via SMS activation. As of March 31, 2026, customers from 89 countries have been able to experience Turkcell’s 5G services. Turkcell’s Next Generation Communication R&D (“NG-R&D”) team was established in 2017 with an initial focus on 5G technologies. Over time, in line with the evolution of communication technologies and research priorities, the team has expanded its scope towards 6G and beyond. This transformation has been further reinforced by the establishment of 6GEN.LAB, a research laboratory supported under TÜBİTAK’s 1515 Frontier R&D Laboratory Program, focusing on 6G and AI-driven network technologies. Through this initiative, Turkcell aims to contribute to the design of autonomous 6G networks and to explore their integration into both vertical sectors and its own network infrastructure. Today, the team’s activities are structured around key focus areas, including intelligent and trustworthy networks, network management and automation, and physical layer and radio technologies. Within this scope, the team actively participates in national and international publicly funded research and innovation programs, including Horizon Europe and SNS (Smart Networks and Services) initiatives in Europe, EUREKA projects, and programs supported by TÜBİTAK, Türkiye’s national funding agency for research and development, contributing to the advancement of next-generation communication technologies. In the scope of 5G and beyond communications, Turkcell contributes to the activities of leading international industry and standardization organizations, including 3GPP, ITU, GSMA, NGMN, 6G-SNS-IA and the AI-RAN Alliance. These engagements include active participation in working groups, projects and programs, where Turkcell provides technical input, submits contributions and takes part in discussions that support both the tracking of emerging technologies and the alignment of its long-term strategy. In particular, Turkcell contributes to 3GPP standardization activities across Radio Access Network (RAN) and Service and System Aspects (SA) working groups, providing technical inputs to ongoing studies on 5G-Advanced and early 6G-related topics. The increasing focus on 6G standardization in 2025 has further strengthened the strategic importance of these contributions, supporting Turkcell’s positioning in next-generation communication technologies. A notable another example is the “Focus Group on Artificial Intelligence Native for Telecommunication Networks (FG-AINN),” established under the ITU Telecommunication Standardization Sector (ITU-T) in 2024. Turkcell played an active role in the formation of this group and held a leadership position during its initial phase (2024 and 2025). The focus group represents the first ITU-T initiative dedicated to AI-native design principles for future telecommunication networks and is considered an important step toward the architectural evolution of 6G. Turkcell’s Next Generation Communication R&D activities also generate tangible outputs in the form of intellectual property and scientific contributions, including patent filings and academic publications in collaboration with research partners. These efforts are complemented by a broad innovation ecosystem that brings together global technology vendors, local industry players, small and medium-sized enterprises, and leading universities and research institutions. Through these collaborations, Turkcell supports the development and validation of advanced technologies such as AI-native networks, advanced radio solutions and emerging 6G enablers, while also facilitating their potential transition toward commercial use. Turkcell continues to strengthen its ecosystem-driven approach through joint development activities and publicly funded projects, as well as through strategic collaborations with academic institutions and research centers. Selected outcomes of these efforts have also been recognized by international industry platforms. For instance, a joint innovation on Reconfigurable Intelligent Surfaces (RIS) was awarded at the GTI Awards in 2025, and Turkcell’s research contributions have also been acknowledged in international initiatives such as the one 6G Summit, reflecting its active role in shaping next-generation communication technologies. 59 Table of Contents (ii) Transmission Network We have been enhancing our IP/MPLS backhaul infrastructure to improve service capabilities and availability. Fiber backhaul bandwidth capacities have been upgraded to support speeds of up to 100 Gbps. Connections to mobile sites have been transitioned to fiber-optic interfaces, and the Microwave Radio Link network has been modernized to support Native Ethernet and Adaptive Modulation, enhancing availability and minimizing link outages caused by severe weather conditions. The transmission network, leveraging DWDM technology, delivers service capacities of 100 Gbps, 400 Gbps, 800 Gbps, and 1.2 Tbps, as well as readiness for capacities exceeding 1.6 Tbps per optical channel. In 2025, Turkcell launched a new nationwide Core WDM backbone, utilizing both Super-C and Super-L bands resulting a 12 THz optical band usage over a single pair of fiber. This optimization maximizes the efficiency of existing wide-area fiber-optic deployments. Additionally, time and phase synchronization capabilities are being deployed across all transport network segments to support LTE Advanced features and forthcoming 5G TDD band deployments. All fixed and mobile IP networks have been converged using high-capacity, state-of-the-art routers designed to support advanced technologies such as IPv6 and SRv6 to meet the capacity demands of 5G and future applications. (iii) Core Network Turkcell provides (i) voice services over 2G and 3G access, (ii) HD voice services over 4.5G and 5G access using VoLTE, VoNR, VoWiFi technologies, and (iii) fixed voice services to consumer and corporate customers. The 2G and 3G voice services are provided by IP based layered Next Generation Network (NGN) infrastructure. The VoLTE, VoNR and VoWifi voice services for 4.5G and 5G subscribers are provided by IMS (IP Multimedia Subsystem) and all subscribers can use seamless HD Voice technology via VoLTE VoNR and VoWiFi infrastructure. Seamless handovers are performed between VoLTE, VoNR and VoWiFi, between VoNR and VoLTE and 2/3G technologies in our core voice network. Fixed voice services are also provided by dedicated IMS infrastructure. Our entire voice network has all levels of geographic redundancy. The control layer (central resources) provides voice services from four central data centers that fully back up each other. The voice payload layer (local resources) is spread over many locations that are close to the subscribers. Turkcell provides a wide variety of data services to customers through high-speed and low latency data connectivity. Our access agnostic broadband core network architecture consists of 3GPP compliant network entities supporting mobile 2G, 3G, 4.5G and 5G (both 5G SA and 5G NSA) and fixed access technologies. The 5G SA supports 3GPP compliant 5G Slicing technologies and subscriptions. With respect to our sustainable network initiatives, we have completed analysis and pilot tests and commercially launched IPv6 service to our customers. Both IMS voice and broadband network services are deployed on Turkcell telco cloud infrastructure and are increasing due to its low cost and flexibility advantages. In addition to supplying the growing data and service requirements of existing 4.5G traffic, Turkcell has positioned its network to provide 5G services scaling on its own telco cloud. Network functions of 5G SAcore network are all developed on container-based cloud technologies in the industry. Hence, the transition to telco cloud infrastructure has also enabled the network to support 5G SA. Accordingly, we are growing our core network on container platform technology, which provides more flexibility and investment feasibility through deploying cloud-native network functions. This technology has been a critical enabler for the launch and scaling of our 5G core network. (iv) Fixed Network Turkcell’s own fiber-optic network delivers high speed internet services of up to 10 Gbps across 30 cities in Türkiye. We continue to invest in the latest fixed access technologies, including XGS-PON-ready infrastructure. With these capabilities, Turkcell believes that it is well-positioned to provide high customer experience. 60 Table of Contents Driven by our commitment to technology leadership, we were among the first operators to deploy Wi-Fi 6-enabled Home Gateways in response to the surge in in-home connectivity demand during the COVID-19 pandemic, significantly enhancing the residential user experience. Building on this momentum, we launched residential service packages featuring Wi-Fi 7-capable modems, enabling ultra-high-speed wireless connectivity and future-ready home networks. In parallel, we initiated virtualized access network projects and actively contributed to Open Networking Foundation (ONF) initiatives, supporting early-stage development efforts that foster knowledge sharing and accelerate the adoption of next-generation network technologies. We provide end-to-end Wi-Fi services for our enterprise customers, which enables their guests to access Wi-Fi. The Enterprise Wi-Fi service includes installation with authentication services, and further provides the necessary interface. (v) Services and Platforms We have an intelligent network and other service platforms enabling our services and we also provide secure and controlled access to the network for content and service providers to provide messaging and data services. This infrastructure is being improved to open up more capabilities on the network for application and content providers. New infrastructure also contains a portal where subscribers can easily buy services, receive promotions and enroll for campaigns. d. Network Operations We have primarily employed experienced internal personnel for network engineering and other design activities, while employing suppliers for our network infrastructure and as our partners in product/service development. Our suppliers install the base station cell site equipment and switches on a turn-key basis, while subcontractors employed by our suppliers perform the actual site preparation. e. Network Maintenance We have entered into several system service agreements. Under these agreements, our mobile and fixed communications network, including hardware repair and replacement, software and system support services, consultation services and emergency services are supplied by local providers. Our subcontractors perform corrective and preventive maintenance on our mobile and fixed communications network in the field, although providers repair all the network equipment. We have regional operation units with qualified Turkcell staff that operate and maintain our network in Türkiye. In addition, the Turkcell Service Operation Center, located in both İstanbul and Ankara, aims to ensure business continuity by monitoring our entire network 24 hours a day, 365 days a year, and performs necessary maintenance in response to any problems that may arise. f. Site Leasing If a new coverage area is identified, our technical staff determines the optimal base station location and the required coverage characteristics. The area is then surveyed to identify BTS sites. In urban areas, typical sites are building facades and rooftops. In rural areas, masts and towers are usually constructed. Our technical staff also identifies the best means of connecting the base station to the network. Once a preferred site is identified and the exact equipment configuration for that site is determined, we start the process of site leasing and obtaining necessary regulatory permits. Site leasing processes are carried out by our in-house team. We lease the land or rooftop sites and provide site management services (yearly rental payments, contract renewals, rework permits). If the decision is made to purchase the land, suitable alternatives are identified by Turkcell, and the acquisition is subsequently completed on behalf of Turkcell Gayrimenkul Hizmetleri A.Ş. (“Turkcell Gayrimenkul”), a wholly owned subsidiary of Turkcell. We also manage all these processes for technical demands for Turkcell Superonline and Global Tower. g. Internal Control and Continuous Improvement The Internal Control team is responsible for conducting second level control activities and process improvement work, in order to effectively manage business processes within the Turkcell Group. Internal Control activities are carried out within the framework of legal regulations, directives and with the authority granted by the CEO. Turkcell is responsible for analyzing risks and priorities related to processes under its purview, and for planning a risk-based internal control study, which is carried out on a routine basis, using both manual and automated tools. 61 Table of Contents In addition to evaluating the effectiveness of first-level controls carried out by business units, guidance is provided on improving processes by considering Turkcell Group’s sustainable values. If there are deficiencies detected as a result of the second level controls performed, they are shared with the relevant teams to ensure that action is taken and the relevant action plans are followed. Other areas of the team’s responsibilities are to carry out internal audits regarding the obligations of the Turkcell Group’s ISO certificates within the scope of legal regulations and to monitor Turkcell’s internal/external audit findings. ISO27001 and ISO27017 certifications are an international framework that helps companies protect their financial data, intellectual property and sensitive customer information. The Continuous Improvement Center designs end-to-end business processes based on key principles such as efficiency, resilience, lean methodology and a human-centered approach. The Center leads the promotion of a lean culture throughout the organization. Its responsibilities include implementing cross-functional process improvements and monitoring process key performance indicators (“KPIs”) to evaluate the effectiveness and outcomes of these initiatives. In addition, the Continuous Improvement Center is responsible for obtaining and maintaining ISO 9001 Quality Management System certification which is an international standard that supports organizations in enhancing quality and ensuring continuity in service and performance management. Furthermore, the Continuous Improvement Center is responsible for leveraging, scaling and governing next-generation, thereby enabling technologies that support continuous improvement. (i) Business Continuity Management Turkcell Business Continuity Management (“BCM”) identifies potential threats and their impact and provides a framework for building resilience with the ability to create an effective response that safeguards the interests of our key stakeholders, their reputation, brand and value-creating activities. We established the Business Continuity Management System (“BCMS”) to implement, operate, monitor, review, maintain and improve business continuity. Turkcell BCMS is assisted by business continuity coordinators at technical and non-technical groups. Regular BCM training and awareness programs are carried out throughout the organization. The effectiveness of BCMS is monitored every year through internal/external audits and integrated exercises, the results of which are reviewed in management review meetings. In 2025, we exercised and tested our business continuity plans, communication and warning procedures to ensure that they are consistent with the business continuity objectives. Turkcell Service Continuity Management aims to ensure the continuity and recovery activities of the services provided to our customers, by providing the continuity of the service commitment levels, managing the risks that may affect our services, including disasters and emergencies, and supporting the Turkcell Business Continuity Management System. Turkcell has also developed a Crisis Management Plan, which is aimed at effectively managing crises such as fire, terrorism, operational interruption, cyber-attack, food poisoning, epidemics and natural disasters (flood, earthquake, landslide). Turkcell’s Crisis Management Plan exercises, training and awareness activities are carried out periodically with the participation of crisis management teams and related groups. (ii) Enterprise Risk Management Turkcell’s Enterprise Risk Management (“ERM”) team is responsible for coordinating the process of identification assessment and oversight of actions by management and the company’s business units to manage the risks that may affect the Company’s business objectives. The ERM team supplies an information platform to management regarding the risks that may impact the decision-making process. The Turkcell ERM team aims to develop an approach of integrating risk management with the core management processes and foster an enterprise risk culture. To achieve this, Turkcell uses an ERM framework compatible with the COSO ERM framework and the ISO 31000 Standard. Based on ERM procedures, risks are identified and evaluated in terms of their impact and likelihood. Risk response controls, issues and actions are developed and the entire process is monitored. The ERM team reports to the Early Detection of Risk Committee, which supports the Board of Directors by detecting early signs of risks that may jeopardize the Company’s existence, development and continuity, taking necessary measures for identified risks, and managing risks within the scope of article 378 of the Turkish Commercial Code and the Communiqué on Corporate Governance of the Capital Markets Board. 62 Table of Contents The risks we monitor in line with the developments in the world are scripted, defined, leveled and recorded. For instance; the impact of the pandemic period on our company, the expectations for future earthquakes in Türkiye, the effects of climate change and the ongoing Ukraine-Russia war can be cited as examples of scenario-based studies. Cyber incidents occurring worldwide and in Türkiye are also analyzed. The effects that may occur if a similar cyber attack occurs in Turkcell and the preparations taken throughout the company are presented to the Early Detection of Risks Committee. VIII. Sales and Marketing We design our sales and marketing strategy around subscriber needs and expectations. We try to ensure the loyalty of our subscribers by providing offers, campaigns and our advanced service delivery platforms. a. Sales Channel We sell postpaid and prepaid services, fixed and mobile solutions and digital services to subscribers through a nationwide distribution network. Our sales activities are supported by one of the largest retail telecommunications dealer networks in Türkiye, consisting of 877 branded exclusive stores, many of which are located at prime locations, and 3,617 semi-branded dealers (i.e. digital sales points) as of December 31, 2025. As of January 1, 2025, we consolidated our distribution model under a single exclusive distributor in order to enhance operational efficiency, improve cost effectiveness and strengthen strategic control. This model enables closer collaboration with our distributor and more efficient resource utilization, and supports sustainable growth. Under this model, our exclusive distributor supplies both Turkcell products and a broad range of consumer technology goods, including handsets, tablets, notebooks, IoT devices, accessories, TV and smart home appliances, as well as aftersales services, to the dealer network. In parallel, seven exclusive Turkcell Distribution Centers focus solely on serving semi-branded dealers. In addition to our retail network, we operate a door-to-door sales force and home technology management team, which represents an important channel for delivering integrated solutions. We also maintain a dedicated corporate direct sales organization of more than 500 personnel, providing tailored solutions to corporate customers within their respective areas of expertise. Our nationwide distribution channel is a strategic asset that drives market differentiation and underpins the achievement of our sales targets. This comprehensive ecosystem comprises a robust network of Turkcell-branded stores, Turkcell Distribution Centers (managing semi-branded dealers), Corporate Small Business Solution Centers, and Home Internet Solution Centers. To ensure maximum accessibility, our footprint also extends to a wide array of alternative sales points, including digital channels, ATMs, and Point of Sale (“POS”) terminals for prepaid airtime and digital top-ups. Our non-branded dealer network ensures broad geographic penetration across Türkiye. Dealers are compensated based on the number of new subscribers acquired and the usage levels of those subscribers, complemented by additional performance-based incentive mechanisms. We categorize alternative sales channels into two main categories: call centers and non-telco sales. Through our call center, our web site (www.turkcell.com.tr) and the Turkcell mobile application, we provide customers with fast and secure access to our products and service portfolio on a 24/7 basis. Our telesales team proactively engage customers across the consumer, corporate, and residential segments, with a focus on both customer acquisition and retention. Non-telco channels include ATMs, online banking platforms, and chain retail stores. Alternative sales channels play a significant role in the sale of digital services. In addition to prepaid top-up transactions conducted through banking channels, these channels contribute to product sales through various campaigns for services such as fizy, TV+, lifebox, and GAME+. Weekly, monthly and annual service packages are offered through a promocode-based model to both Turkcell and non-Turkcell customers. Furthermore, the sale of digital products through technology stores and hypermarkets supports both revenue generation and brand awareness through collaborations. 63 Table of Contents During 2025, our digital sales channels continued to undergo comprehensive transformation. Accordingly, user experience and user interface components, as well as the overall shopping journey, were redesigned based on consumer insights. Payment options were expanded and diversified in response to evolving customer preferences. Our digital sales infrastructure is built around two core platforms: Turkcell’s official website, which has served as a sales channel since 2012, and the Turkcell mobile application. With a high volume of digital traffic, these platforms are positioned to serve as the primary hub for the Turkcell ecosystem, with the mobile application acting as the central digital convergence point. The Turkcell mobile application, Turkcell App, is our primary digital channel, enabling mobile and fixed broadband customers to track bills and usage, manage subscriptions, browse campaigns and offers, purchase packages and access Pasaj, our electronic marketplace. Turkcell App has reached 132 million downloads to date, with 21 million three-month active users and over 200 million visits per month as of December 31, 2025. The application also hosts Turkcell Celly, our chatbot that provides fast and convenient customer support, and serves as the platform for campaigns such as Shake and Win, through which customers receive data, minutes, or trial subscriptions to digital services. Fixed broadband subscribers are also able to manage their accounts through the application. In December 2020, Turkcell launched Turkcell Pasaj, a technology and electronics marketplace in Türkiye. Turkcell Pasaj offers a wide range of electronic products, from smart devices to new generation technologies, sources from Turkcell and leading third-party suppliers. Customers are offered multiple payment alternatives, including shopping credit, mobile payment and Paycell digital money, debit/credit cards and financing through Financell. Turkcell Pasaj offers same-day delivery in some cities and next-business-day courier delivery. The marketplace is fully integrated into the Turkcell mobile application, allowing both Turkcell subscribers and non-subscribers to browse products, compare prices and complete purchases securely within the app. In 2025, Pasaj continued to expand with new categories both in online retail and the marketplace offerings. Turkcell Pasaj also contributes to sustainability, notably by providing an online platform to revalue second-hand devices and convert the customer’s second-hand devices into cash. Pasaj aims to maintain a seamless customer experience while serving as a key sales channel for new technologies, supported by a customer satisfaction rating of 4.6 out of five based on our internal survey. By prioritizing digitalization, Turkcell aims to enhance customer experience and trust across all channels. Initiatives focused on customer satisfaction increased the app store rating to 4.5 by the end of 2025, while the share of digital channels in overall sales continued to grow steadily since 2019. On the corporate side, corporate clients are managed under four segments: public accounts, strategic accounts, major accounts and small business accounts. Turkcell’s account managers serve as the primary point of contact for public, strategic and major accounts, while dealers and telesales teams are responsible for the small business segment. Corporate customers are supported by pre-sales teams, solution architects, business development and product management teams. In addition, dedicated vertical solution teams develop industry-specific solutions for sectors such as retail, manufacturing, energy, healthcare, finance, transportation and logistics, with the objective of supporting the digital transformation of corporate clients. Turkcell also provides turn-key mobile and digital transformation and IT outsourcing projects for large corporations with the contribution of solution partners. b. Advertising By transforming from a digital operator journey into a technology ecosystem brand, Turkcell has become a leading player in Türkiye in the field of technology, providing a portfolio of both telecom and digital services that add value to its customers’ lives. In 2025, the outcome of the 5G authorization tender once again distinguished Turkcell as a leading operator, based on the attribution of the largest spectrum capacity of operators in Türkiye. We aim to bring the 5G technology to every corner of our country by utilzing the coverage and frequency bands that we obtained in the 5G tender. Our communication efforts are built on four key pillars that define our strategy and core strengths. The first pillar is our integrated mobile and fixed infrastructure, which we believe provides a clear competitive advantage. The second is our focus on consistently delivering high-quality service throughout the year. The third is our innovative approach across all areas of operation, enabling us to respond effectively to evolving needs. The fourth and final pillar is our portfolio of offers, products and services, tailored to our customers through behavior-based analysis. 64 Table of Contents c. Customer and Experience Management The key part of our customer and experience management strategy is to provide our customers with effortless, personalized and consistent experience across all channels. Our goal is to maintain a continuous relationship with our customers through fostering a high level of customer satisfaction and helping our customers feel safe and valuable. With respect to the provision of customer services, we mainly work with our subsidiary Turkcell Global Bilgi. In addition to conventional call center services, including telesales and collection, Turkcell Global Bilgi also provides research management, customer experience journey design, social media management and technological support services. Turkcell Global Bilgi develops its own digital platforms such as robotic process automation, cloud-based call center infrastructure and digital assistance. We audit Turkcell Global Bilgi’s operations along with monitoring whether customer services and customer satisfaction programs are executed in line with Turkcell’s customer strategies. In 2025, we launched a three-year transformation program to redefine the customer experience through technology and to strengthen our competitive position. Centered on the use of artificial intelligence, the program aims to deliver a faster, more personalized and smarter customer experience, while increasing customer satisfaction, improving operational efficiency and reducing resolution times at first contact. We aim to deploy AI-based voice bots and agents for a better customer experience. We have also intiated the upgrade of our chatbot to a next-generation solution with enhanced natural language capabilities and proactive problem-solving features. In 2025, our AI-powered self-service chatbot, Teknocan, played a central role in enhancing customer experience by providing fast, reliable, and uninterrupted service through customers’ preferred digital channels. During the year, the total number of interactions handled by Teknocan across mobile, fixed and Pasaj channels reached 83 million. Customer satisfaction levels among Teknocan users continued to increase, supported by a strong first-contact resolution performance, with approximately 98% of customers able to obtain the information or service they needed without switching to another channel. Teknocan delivers an end-to-end integrated experience through our patent-registered chatbot solutions, which differentiates us within the sector. Our ongoing investments in artificial intelligence not only enhance service processes, but also support the evolution of the chatbot ecosystem through innovative solutions and next-generation experience design. At the core of our customer experience strategy is the ability to provide customers with fast and accurate information. In this context, we complement the technological capabilities of our chatbot with human support when required, creating a balanced service model that combines digital efficiency with human interaction. Further, we continued to conduct numerous projects to improve customer experience over IVR, a digital platform connecting Turkcell to its customers. Through renewed proactive IVR scenarios and the integration of all IVR packages with the CRM infrastructure and offering these via text-to-speech technology, we managed to reduce our costs and started to offer more personalized offers to our customers. With Turkcell’s advanced TTS technology, the Turkcell Superonline IVR system has achieved a more natural, clear and high-quality structure in terms of voice consistency. Turkcell connects with social media users 24/7 with a total of 65 accounts on Facebook, X, Instagram, YouTube, LinkedIn and TikTok. Turkcell has ISO10002 Quality Management-Customer Satisfaction-Complaints Handling Certificate since 2011 and renews it annually within the scope of design, installation, operation, sales and after-sales services of global mobile communications within Turkcell functions. The ISO 10002:2018 certification was renewed in June 2024 for three years. With our environmentally friendly invoice project, our Digital Invoice usage rate reached 99.4% on mobile channels and 99.6% on fixed channels by the end of 2025. 65 Table of Contents d. Self-Service Customer Experience We are continuously researching and developing easier methods to offer our customers effortless service at every transaction. As part of these efforts, we have started to provide the option to convert existing physical SIM cards into e-SIM cards using secure identity verification methods. This service is particularly beneficial for customers residing abroad, allowing them to seamlessly and instantly switch their SIM cards through the Turkcell application without visiting a Turkcell store. This initiative, which was designed to address customer needs more efficiently and effectively, represents a significant milestone in Turkcell’s commitment to embracing technology and delivering customer-centric solutions. In 2025, we introduced how-to videos for our individual customers, which show them step by step how to carry out operations they need on their own, quickly and easily. These videos, which can be accessed at any time on YouTube, are shared with our relevant customers after SMS, chatbot and voice calls; ensuring that transactions are completed effortlessly and the experience continues seamlessly. At Turkcell, we remain dedicated to achieving excellence for our customers by listening to their needs and offering tailored solutions that enhance their experience. IX. Domestic and International Subsidiaries A component of our strategy is to grow or improve our business in our domestic market. Continued strong operations in the international countries in which we are currently present is important for us. We believe these operations offer growth opportunities and we expect them to provide additional value to the Group. While the continued improvement of our core operations remains a key priority, we also remain open to exploring opportunities both in Türkiye and in international markets. BeST On July 29, 2008, Beltel signed a share purchase agreement to acquire an 80% stake in BeST, which provides services using GSM and UMTS technologies, for a consideration of USD 500 million. On August 26, 2008, control of BeST was acquired from Belarus State Committee on Property and USD 300 million of the total consideration was paid. An additional USD 100 million was paid in December 2009 and a further USD 100 million was paid in December 2010. An additional payment of USD 100 million was required to be made to the seller in installments contingent of the financial performance of BeST. On November 30, 2022, the relevant contract was terminated by mutual agreement. On the same date, a new Investment Agreement was signed between Turkcell, BeST and Belarus to develop the telecommunications infrastructure between 2022 and 2032. Under this agreement, Turkcell is required to invest at least USD 100 million during the investment period and to pay an additional amount of USD 100 million over a period of 10 years. It is intended that this payment will be funded by 50% of BeST’s annual net income. In case the required amount is not reached at the end of the 10-year period, BeST or Turkcell shall make a lump sum payment to Belarus for the remaining balance. For more information, see Note 27 to our Consolidated Financial Statements elsewhere in this annual report. Simultaneously with the Investment Agreement, Turkcell signed a share purchase agreement to acquire a 20% stake in BeST from the State Committee on Property of the Republic of Belarus. The share transfer was completed on December 9, 2022. Responsible authorities of Belarus have rearranged the mobile communication interconnection fees between the operators in the country, considering the provisions of the Investment Agreement, and set a mobile call termination fee of BYN 0.001 for BeST for five years. In this regard, the decline in interconnection expenses will positively impact our operational profitability. Beltel, established to directly participate in BeST, merged with Turkcell on August 23, 2023. As of December 31, 2025, BeST had 1.6 million registered mobile subscribers, the majority of which were prepaid, and its three-month active subscribers reached 1.3 million. BeST is the leader of the MNP market in Belarus in terms of number of port-in subscribers and net customer gain, according to the Centralized Database of Ported-Numbers. BeST has 9 own stores, 129 exclusive and 391 non-exclusive sales points. Sales from its online channel have been continuously increasing with rising customer demand. In addition, digital subscription packs are sold at around 3,400 sales points across the country. 66 Table of Contents As of December 31, 2025, BeST operated 2G and 3G services in all cities with a population of more than 1,000 and provided 2G/3G services on all principal intercity highways and roads of the Republic of Belarus, which corresponds to a coverage of approximately 99.8% of the entire population of Belarus, or 93.1% geographical coverage. In Belarus, the LTE and 5G license are owned by LLC Belarusian Cloud Technologies (“beCloud”) and beCloud is the only infrastructure provider for LTE services. BeST offers 4G service since August 2016 on beCloud’s LTE infrastructure, serving in all regions and major cities of Belarus with an 94.0% 4G territory coverage and 98.7% population coverage as of December 31, 2025. The availability of 4G services has improved the quality of data services and customer experience. As of December 31, 2025, the share of 4G subscribers in the three-month active subscribers reached 86%. Rising 4G penetration led to a growth in average monthly data consumption per user to 22.7GB. The 4G network served 86% of total data traffic in 2025. BeST offers 5G service on beCloud’s infrastructure in major cities of Belarus since December 2025. BeST continues its transformation from a communications service provider to a digital operator, converting its subscribers into 4G users. Accelerating digital subscriptions and increasing its share in subscriber acquisition, enhancing self-service capabilities through mobile applications and web channels, modernization of retail channel to enhance digital customer experience in offline shops expanding digital service portfolio and penetration are the key initiatives that will continue to drive the digitalization journey in 2026. By bringing together connectivity and content to enrich customers’ digital experience, BeST is driving ARPU growth through data services and a diversified digital services portfolio in line with Turkcell’s strategy. Accordingly, BeST provides music, video, games, security, digital publication and digital education platforms within its digital services portfolio. By the end of 2025, 55% of three-month active subscribers are using at least one digital service and solution. BeST continues to enhance its mobile application with new services and functionalities. Following an extensive update, the platform has evolved from a simple self-service tool into a unified digital ecosystem that seamlessly integrates connectivity, finance, e-commerce and entertainment. BeST conducted a rebranding process and updated its brand identity in December 2025 to support its evolving service quality, improved customer experience and digital transformation process. The change aims to enhance the company’s brand perception, increase its reputation, reach new target audiences and attract new customer segments. In January 2022, the Republican Unitary Enterprise Beltelecom acquired a license to provide mobile communications services, which will allow the company to compete in the mobile communications market. The company announced that it plans to begin offering mobile services in 2024. However, as of the end of 2025, the service had not yet been launched. Following the U.S., the UK, Canada, and the EU imposing sanctions in 2022, alongside broader geopolitical developments linked to the conflict in Ukraine, Belarus faced significant economic challenges, resulting in a 4.7% year-on-year GDP decline. The halt in trade with Ukraine, which had been Belarus’s second-largest trading partner representing over 13% of its foreign trade, along with disruptions in EU trade and the closure of transit routes, further strained the economy. In response, Belarus strengthened economic cooperation with Russia, secured preferential trade conditions, and expanded ties with other Eurasian Economic Union (“EAEU”) member states and China, leveraging alternative markets and transport infrastructure to mitigate the impact. By 2023, GDP growth rebounded to 3.9%, followed by a maintained growth rate of 4.0% in 2024 and 1.3% in 2025 with Russia’s share in Belarusian exports rising to approximately 70%. Supporting this recovery, the National Bank of the Republic of Belarus gradually reduced interest rates to 9.50% during 2023, and maintained that level through 2024. In June 2025 interest rate was revised up to 9.75%. In Belarus, our business has been and may continue to be affected directly or indirectly by sanctions (including export controls that impact our ability to import equipment and software), regulatory and operational difficulties and no assurance can be given that the situation will change favorably in the future. For more information regarding the risks we face with regard to our business in Belarus, please refer to “Item 3. Key Information—D. Risk Factors—Risks Relating to Our Business—We hold interests in several companies outside of Türkiye that expose us to various local economic, business, political, social, financial, liquidity, regulatory and legal risks and may not provide the benefits that we expect, and our pursuit of acquisition opportunities may increase these risks.” 67 Table of Contents Lifetech LLC (“Lifetech”) Lifetech, which is a subsidiary of Turkcell Group, was established in 2012. It is 100% owned by BeST and has around 160 professionals located in Belarus as of December 31, 2025. Lifetech provides a full cycle of software development services and develops custom and platform-based solutions to Turkcell Group and other customers and carries out software development projects both in Belarus and other countries. Lifetech is a member of High-Technology Park of Belarus since 2019. Kıbrıs Telekom Kıbrıs Telekom, a wholly-owned subsidiary of Turkcell, was established in 1999 in the Turkish Republic of Northern Cyprus. As of December 31, 2025, Kıbrıs Telekom had 0.7 million registered subscribers. Kıbrıs Telekom operates its 2G, 3G, 4G, and 5G services under license agreements that have been progressively expanded and extended, with current terms aligning their expiration to 2041. The original foundation for these services was established on April 27, 2007, when Kıbrıs Telekom signed an agreement with the Ministry of Public Works and Transportation of the Turkish Republic of Northern Cyprus. Effective August 1, 2007, this 18-year agreement replaced a 1999 revenue-sharing model and granted GSM 900 and GSM 1800 licenses for a fee of USD 30 million including VAT to further enhance its infrastructure, the Company was awarded a 3G (IMT 2000/UMTS) license in 2008 for USD 10 million. Building on these legacy authorizations, Kıbrıs Telekom was awarded a combined 4G/5G (IMT-Advanced and IMT-2020) license on November 7, 2022, acquiring 247 MHz of new spectrum (in 700 MHz, 800MHz, 900MHz, 1800MHz, 2100MHz, 2600MHz and 3600MHz bands) for USD 19.1 million, including VAT. This enabled the launch of 4.5G services on September 7, 2023. Under this 18-year authorization, Kıbrıs Telekom is permitted to offer 5G services utilizing 4G spectrum starting September 7, 2026, with full 5G deployment across all awarded bands (including 700 MHz and 3600 MHz) scheduled for September 7, 2028. An option exists to accelerate this full deployment to 2027. Most recently, on April 27, 2025, the existing 2G/3G License Agreement was extended for 16.5 years to September 7, 2041. Concurrently, the Company acquired an additional 73.6 MHz of bandwidth (within the 900 MHz, 1800 MHz, and 2100 MHz bands) for a total fee of USD 5.9 million (excluding VAT). This fee is payable in six installments over a five-year period. In 2012, Kıbrıs Telekom acquired Internet Service Provider and infrastructure establishment and operation licenses. Kıbrıs Telekom applied for a right of way to major municipalities and the Ministry of Transportation in order to establish a national fiber-optic infrastructure. On January 24, 2014, a protocol was signed between Kıbrıs Telekom and the Ministry of Transportation for the right of way for highways. Total fiber-optic infrastructure implementation was at 69 kilometers by the end of 2025. In 2017, Lifecell Digital Limited (“Lifecell Digital”) was incorporated in order to operate as an Internet Service Provider company and offer converged telecom services. Lifecell Digital also acquired an infrastructure license in December 2018. In addition, Lifecell Digital was granted MVNO and call carrier licenses in May 2022. In July 2025, the TRNC authorities articulated an objective to develop and modernize the country’s digital infrastructure and, to this end, entered into a protocol with Türkiye aimed at establishing a nationwide fiber-optic network, including international connectivity through submarine fiber-optic cables. In this context, the Turkish incumbent, Türk Telekom, has established a dedicated subsidiary to undertake the deployment and operation of the fiber infrastructure in the TRNC. This protocol is expected to reshape the country’s fixed internet market over the next 25-year. Specifically, with its 5G FWA strategy, KKTCELL will become an innovative fixed internet provider and aim to establish a resell strategy for fiber. The new generation payment platform, TRNC Paycell, was launched in 2023 with the vision to become an enabler on financial inclusion with a combination of technology and financial services. Thanks to its mobile application features, TRNC Paycell has enabled its customers to make secure purchases using only phone number information, to transfer money 24/7 to any phone number they wish, and to pay using QR technology. The National Regulatory Authority determines mobile termination rates. Following an increase to TRY 0.06 in October 2023, the regulatory authority implemented a 37% reduction in November 2024, bringing the rate down to TRY 0.04. Most recently, in November 2025, MTRs were adjusted upward by 13%. 68 Table of Contents The National Regulatory Authority designated Kıbrıs Telekom as an operator having significant market power in the mobile access and call origination markets in July 2021. Due to this designation, Kıbrıs Telekom is obliged to provide access and call origination service to MVNOs. As of December 31, 2025, there are two companies that have MVNO licenses. As of January 1, 2025, Kıbrıs Telekom transitioned its home electronics and terminal business to a distributor management model. This transformation aims to centralize inventory management and enhance operational agility across the sales network. By leveraging this model, Kıbrıs Telekom seeks to optimize product availability through streamlined logistics and demand-based inventory planning. Furthermore, the transition facilitates rigorous sales performance, supporting sustainable growth and improved market reach. Turkcell Global Bilgi On October 1, 1999, Turkcell Global Bilgi was established to provide telemarketing, telesales, and call center services, particularly for Turkcell Group. Turkcell Global Bilgi manages customer contacts at every channel and offers digital technologies, technological support services and customer care services to more than 100 companies in particularly banking, retail, e-commerce, insurance public and the airline industry. By announcing its presence as a Customer Experience Center in 2016, Turkcell Global Bilgi started to more deeply analyze customer experiences, gaining vast experience in the process. On August 4, 2017, Turkcell Global Bilgi obtained an R&D center certificate from the Ministry of Science, Technology and Industry. Turkcell Global Bilgi offers comprehensive solutions that support digitalization in addition to contact center services. These solutions include robotic process automation (RPA) to automate business processes, cloud-based telephony solutions for managing communication infrastructures in cloud environments, as well as digital customer representatives, chat and chatbot applications, social media platforms and video contact center technologies. These digital technologies are developed and delivered as services to enable more efficient, faster and omnichannel management of customer interaction processes. As of December 31, 2025, Turkcell Global Bilgi had 17,503 employees. 58% of these employees serve Turkcell’s customers, 37% serve customers of third parties, with the remaining working as administrative personnel. Turkcell Superonline Turkcell Superonline was founded in 2009 through the merger of our subsidiary Tellcom (founded as Bilisim Telekomunikasyon in 2004 and became Tellcom in 2006) with the Superonline business acquired from the Cukurova Group. We believe that Turkcell Superonline differentiates itself through its superior network quality and leading-edge technology with its own fiber infrastructure along with commitment to after sale services quality. Turkcell Superonline operates across our three main customer categories; consumer, corporate and wholesale. Turkcell Superonline has a wide range of services. Fixed broadband, voice and TV services are provided to consumers. Fixed data, voice, data center & cloud along with cyber security services are among the services provided to corporates. Wholesale services include wholesale international and local data and voice services with over 300 business partners. As of December 31, 2025, Turkcell Superonline had 67.1 thousand km fiber backbone covering 81 cities in Türkiye and has 19 border crossings. The company offers fiber coverage in 30 cities and increased its homepasses to 6.3 million as of December 31, 2025, from 5.8 million in the previous year. Including partnership engagements, we are capable of covering 11.3 million households in 81 cities. Turkcell Superonline aims to continue to invest in and expand its own fiber-optic network and further utilize the group synergy created with Turkcell. Turkcell Superonline also has a fixed telephony services authorization, which enables it to provide call origination and termination for consumers and corporations. As of December 31, 2025, Turkcell Superonline had 2.6 million fiber and 1.4 million IPTV subscribers. Turkcell Superonline began to provide 1000 Mbps service to homes in May 2011 for the first time in Türkiye. Turkcell Superonline has rendered Türkiye as one of the first countries where a 1000 Mbps connection is provided to homes. Since 2018, Turkcell Superonline has a capability to offer 10 Gbps connections on a demand basis. 69 Table of Contents Out of the total of 19 border crossings, we have four terrestrial and one third party submarine border crossings to Europe, providing geographically diverse and resilient routes to major European hubs. To the East, our infrastructure comprises 12 border crossings, facilitating high-speed capacity services across the Middle East, CIS and Asia. The next-generation network enables the Company to deliver high quality solutions to telecommunications operators, multinational corporations and governmental institutions. In addition, Turkcell Superonline, TI Sparkle signed an Memorandum of Understading protocol for a new submarine project between İzmir and Hania-Crete allowing for an alternative self-owned submarine border connection to Mediterannian international lines simultaneously connecting to both Europe, the Middle and Far East. Turkcell Superonline has secured the tenders of BOTAŞ, Türkiye’s state-owned pipeline company, and TEİAŞ, Türkiye’s state-owned electric power transmission company, for the indefeasible right to use their installed fiber optic capacities on a national and regional basis, respectively. On May 7, 2025, we won the BOTAŞ tender for an additional 15-year term, complementing our existing regional TEİAŞ agreements, the earliest of which expires in 2033, which also grant rights to install and operate additional fiber optic cables. As an important portion of our fiber infrastructure backbone routes is established upon these specialized networks, our operations are inherently dependent on the continuity of these arrangements. Turkcell Superonline offers its local and foreign clients wholesale voice termination, international leased data lines, internet access, data center and infrastructure services. It is also authorized to provide satellite communication services, infrastructure operating services, internet services and wired broadcasting services, as well as mobile virtual network operating services. The company carries the majority of Turkcell’s traffic. Turkcell Superonline pursues a domestic wholesale business strategy as well providing wholesale products such as bit stream access via its FTTx fiber coverage, infrastructure services, backbone transmission, ethernet, IP transit capacities, cyber security and VPN services to operators, service providers and data center companies in the Turkish market. Turkcell Superonline is leading the localization strategy for Türkiye’s data and internet traffic by developing partnerships with internet exchange platforms, Tier 1 operators, global/local content and cloud service providers to enable direct access to all networks, and also commercializing internet traffic. Global Tower Global Tower was established in 2006 as a wholly owned subsidiary of Turkcell and commenced its operations in 2007 to provide infrastructure management by leasing places on towers to private and public entities and institutions. It is the first and only tower company in Türkiye. In addition to Türkiye, it has operations in Belarus and the Turkish Republic of Northern Cyprus. Today, it serves not only mobile network operators but also broadcasting, ISPs, energy, public institutions and other related industries. Its 100% owned subsidiary in Belarus, Beltower LLC (“Beltower”), was founded in 2016 and has a right of use agreement signed with BeST. Global Tower operates a unique portfolio of 10,646 towers, 9,694 of which are located in Türkiye. As of December 31, 2025, Global Tower operated 837 towers in Belarus, as well as 115 towers in the Turkish Republic of Northern Cyprus with right of use, through agreements with the tower owners to sublease them to third parties through revenue share agreements. Global Tower also provides service to around 427 mobile towers in Türkiye. Global Tower provides fast and high-quality service to its customers in collaboration with its business partners. In Türkiye, Global Tower manages the processes of renting, maintaining and installing towers in 18 structured regions with its four solution partnerships and two installation subcontractors. Global Tower helps customers expand their network, enables peer-to-peer telecommunications and provides broadcasting field infrastructure solutions, turn-key setup services and professional operation-maintenance services. With its project management, field rental, construction works, ready-for use field delivery solutions, it helps private and public institutions reach more customers. Global Tower’s wide service range consists of shared infrastructure services in tower/rooftop/in house fields, TV-radio infrastructure solutions, E2E and wind power infrastructure solutions, M2M/scada/telemetry infrastructure solutions, GSM-R solutions, mobile tower solutions, acclimatized system room solutions, energy infrastructure solutions, hybrid systems solutions (solar/wind), infrastructure maintenance and operation services, field acquisition and contract management services and satellite telecommunication solutions & services. 70 Table of Contents Global Tower obtained a satellite service license from the ICTA and initiated its satellite services where point-to-point or point to multipoint seamless and telco-grade data communication is needed. We provide closed satellite network solutions to our mobile network infrastructure, corporate customers and public institutions via our VSAT and SCPC satellite products. Our experienced satellite operations center and field operations and maintenance teams provide 24/7 services for over a thousand VSAT terminals. Turkcell Teknoloji Araştırma ve Geliştirme A.Ş. (“Turkcell Teknoloji”) Turkcell Teknoloji, a wholly owned subsidiary established in 2007, serves as the Company’s primary research and development hub. As of December 31, 2025, the Turkcell Teknoloji R&D Center employed over 1,000 researchers accredited by the Ministry of Industry and Technology of Türkiye. The subsidiary focuses on developing proprietary solutions across mobile communications, 5G and beyond, artificial intelligence (AI), blockchain, and fintech to drive digital transformation. Turkcell Teknoloji maintains a diversified R&D portfolio designed to address the evolving demands of the digital economy. The Company’s development efforts are concentrated across high-impact domains, including next-generation mobile communication solutions, 5G infrastructure, cybersecurity, and cloud-native platforms. Furthermore, the Company leverages its expertise in big data analytics, AI-driven automation (AIOps), and blockchain to deliver scalable B2B and B2C solutions, ranging from mobile financial systems and digital identity technologies to advanced media services such as IPTV and OTT platforms. Technological innovation remains a fundamental pillar of our corporate strategy. By closely monitoring global trends, Turkcell continues to invest in large-scale R&D initiatives to reinforce its infrastructure and maintain its leadership position within the Turkish technology ecosystem. These initiatives are focused on enhancing operational efficiencies and developing high-margin, value-added services tailored for diverse market segments. Our commitment to R&D excellence ensures that our proprietary solutions remain adaptable to emerging technological shifts while providing a competitive advantage. Turkcell Teknoloji’s solutions are being strengthened with state-of-the-art, AI-powered products under development in-house around strategic themes and supported by globally recognized certifications and validations, including strong performance in the U.S. Department of Commerce’s National Institute of Standards and Technology Face Recognition Vendor Test (NIST FRVT) 1:1. In our customer digital onboarding journeys, we utilize advanced AI-driven identity verification capabilities, complemented by in-house liveness detection models to enhance security and ensure regulatory compliance. Throughout subscription processes, we also verify customer identities digitally through standards-compliant OCR checks, improving both efficiency and security while expanding OCR-based document digitization across the organization to increase employee productivity and minimize operational risks. In parallel, we are strategically expanding the integration of Generative AI (“GenAI”) across both customer-facing and internal platforms. Within our digital channels, we have transitioned our mobile chatbot architecture from traditional AI-based NLU systems to Large Language Model (LLM)-driven intent classification, significantly enhancing contextual understanding and interaction. In the next phase, we plan to deliver hyper-personalized interactions in our chatbot. Internally, we have developed “Teknocan” a RAG-based enterprise platform that enables employees to interact with corporate knowledge bases, create custom AI agents, generate presentations, and retrieve information via MCP server integrations. To further elevate customer experience and operational intelligence, we have introduced our insight product, which consolidates customer interactions from call centers, chatbots, live chat, email, and back-office channels into a unified interface, enabling advanced content, sentiment, topic, and summarization analyses. This solution provides a clear and structured evaluation framework to uncover root causes of customer issues and surface experience gaps, while offering a comprehensive view of customer satisfaction and feedback. Complementing this, our Agent Assist solution being developed to deliver real-time, “next-best-action” recommendations to customer representatives, proactively presenting relevant information, reducing cognitive load during high-stress interactions, and ensuring consistent, high-quality service delivery across all touchpoints. In all the solutions mentioned above, to ensure the highest level of data sovereignty and prevent the leakage of sensitive or personal information, all these GenAI capabilities are powered by on-premise LLMs running exclusively on internal GPU infrastructure, providing a fully secured and isolated environment for corporate data. 71 Table of Contents In the fintech sector, Turkcell Teknoloji remains committed to advancing its innovation efforts by delivering cutting-edge digital products and services to meet the evolving needs of customers. Our recent initiatives have been expanded to incorporate AI and machine learning capabilities, paving the way for smarter and more intuitive solutions. We continue to offer a wide range of personalized financial products through these fintech solutions, tailored to both Turkcell customers and non-Turkcell customers, as well as the customers of Turkcell group companies. These solutions include machine-learning-driven tools for dynamic risk assessment, fraud detection, and personalized credit scoring and pricing, particularly during the loan disbursement phase. Additionally, during the payment collection process, we have upgraded our advanced payment systems to support seamless multi-currency transactions. Turkcell Teknoloji’s development and operations (“DevOps”) transformation has unified teams, accelerated delivery and strengthened governance. By embedding security protocols directly into the Software Development Life Cycle (SDLC), an approach known as DevSecOps, the Company has successfully ‘shifted security left.’ This integration automates security audits and quality assurance from the initial stages of development, significantly mitigating vulnerabilities and deployment-related risks. To maximize efficiency across the SDLC, we instrument and measure development, analysis, and testing workflows end to end; we systematically identify and remediate inefficiencies through data driven corrective actions; and we extensively leverage AI capabilities to augment code review, optimize test coverage and execution and accelerate defect detection and root cause analysis. Since 2018, Turkcell Teknoloji has been actively conducting research and development activities in blockchain technologies. Through extensive studies, the company has developed innovative products and services aimed at unlocking the value potential of this technology. In line with this vision, Turkcell has focused on solutions such as digital asset management, digital wallets, and digital identity systems. In 2025, as another significant milestone, Turkcell launched a new login method for identity verification on the Republic of Türkiye’s e-government platform through its digital identity product. This solution enables citizens to securely access a wide range of public services and government information online. Throughout this journey, Turkcell Teknoloji has closely monitored industry developments at both national and international levels and has actively pursued collaboration and partnership opportunities to drive innovation and deliver cutting edge blockchain based solutions. Turkcell Teknoloji has expanded its Cyber Security R&D focus this year to address complex challenges in Generative AI and automated testing. To handle the specific structure of the Turkish language, the company developed a unique hybrid architecture for Large Language Models. In application security, a new “Shift-Left” Dynamic Application Security Testing (DAST) solution was introduced, utilizing browser extension technology to manage multiple testing engines efficiently. In parallel, internal code auditing was also strengthened by a patent-pending analysis engine designed to detect sensitive data with high accuracy. Turkcell Teknoloji also redefined access control with a privacy-centric CAPTCHA system that aggregates behavioral analysis and Proof-of-Work into a dynamic risk score without using cookies. For network defense, a recursive discovery architecture was deployed to uncover unknown assets and validate potential vulnerabilities. Strategic management has been transformed by a new platform that allows teams to run instant “what-if” risk simulations. Additionally, Turkcell Teknoloji launched a domestic Cyber Threat Intelligence platform to ensure central tracking and full regulatory compliance. These combined efforts demonstrate a strong commitment to building specialized, reusable, and independent security technologies. Turkcell Teknoloji collaborates with a wide network of national and international R&D companies, universities, and research centers, playing an active role in both Türkiye’s research and development ecosystem and international collaborative programs. The aim is to expand the entrepreneurial ecosystem, support the vision of technoparks, and lead in R&D by fostering collaborations with all stakeholders committed to progress and innovation. Turkcell Teknoloji engages in collaborations with universities across Türkiye, supporting academic studies focused on software development life cycle artificial intelligence, blockchain, quantum technologies, and 5G and beyond. Through these partnerships, university-industry cooperation is enhanced, contributing to the creation of value-added products in the country. Turkcell Teknoloji actively participates in European collaborative research programs, including the EUREKA program, which fosters European competitiveness and integration while promoting R&D collaboration across more than 45 countries. Participation in such international collaborations allows Turkcell Teknoloji to access cutting-edge research, leverage diverse expertise, share knowledge, and accelerate technological advancements. Engaging in these projects enhances the company’s capacity for innovation and supports the development of globally competitive products and services. Turkcell Teknoloji is a board member of two EUREKA clusters: ITEA4 and Celtic Next, contributing to the establishment and progress of the European research agenda and participating in pioneering research and innovation projects. 72 Table of Contents A significant focus for Turkcell Teknoloji in international collaboration is the Horizon Europe program, the European Union’s key funding framework for research and innovation. The program, publicly funded by the European Commission, facilitates large-scale collaborative projects aimed at addressing global challenges and advancing scientific excellence. Turkcell Teknoloji actively engages in Horizon Europe projects to develop innovative solutions that align with European research priorities while contributing to global sustainability and digital transformation goals. Horizon Europe also provides a platform for Turkcell Teknoloji to build long-term collaborations with prominent European R&D institutions, technology providers, and industry leaders, fostering knowledge exchange and technological advancement. To further strengthen its strategic engagement in emerging technologies, Turkcell Teknoloji has initiated membership processes for the 6G-IA (6G Smart Networks and Services Industry Association) and ADRA (AI, Data, Robotics) EU partnership, aligning its efforts with Horizon Europe objectives for the advancement of AI-driven and next generation communication technologies. As of the date of this report, Turkcell Teknoloji is actively conducting 12 national and EU-funded and innovation projects, spanning a broad spectrum of advanced digital technologies and applied research domains. The Company’s R&D portfolio strategically integrates industrially oriented national projects with large-scale European collaborative initiatives. The projects are primarily focused on next-generation 5G and 6G communication networks, intelligent and energy-efficient network management systems, and cloud-to-edge computing architectures. Furthermore the portfolio leverages AI–driven optimisation and advanced machine learning to enhance operational efficiency, generative AI-supported software development, and logistics management. Key research areas also include post-disaster coordination technologies and the development of sustainable, cost-effective connectivity solutions. To date, the company has collaborated with over 300 stakeholders from 25 different countries in publicly funded projects. The company continues to focus on increasing Horizon Europe and EUREKA project applications and funded projects in the coming years. Intellectual property (IP) is a cornerstone of Turkcell Teknoloji’s innovation strategy. The company’s increasing number of patent applications is a testament to its commitment to technological advancement. By the end of 2025, a total of 612 national and 33 international patent applications were submitted by the Turkcell Teknoloji R&D Center. A total of 5,308 national and 313 international patent applications, along with 1,215 registered patents, have been recorded by Turkcell Teknoloji. Turkcell Satış A.Ş. (“Turkcell Satış”) Turkcell Satış sells telecommunication and IT products through our flagship store and provides a wide variety of products via our website “www.turkcell.com.tr.” In the last quarter of 2020, e-commerce business related to consumer electronics was rebranded under “Pasaj” and also started to serve as a marketplace platform for consumer electronic sales of third-party sellers. In addition, since Turkcell Satış is experienced in the sector, it also acts as an intermediary between producer and distributors to support the determination of products, pricing, amount to be sold, sales support components and management of their inventory. Our system integration projects and technology operations within the healthcare sector, including PPP City Hospitals, are executed through our subsidiary, Turkcell Satış ve Dijital İş Servisleri A.Ş. Turkcell Dijital İş Servisleri A.Ş. (“Turkcell Dijital” or “Turkcell Digital Business Services”) In March 2021, Turkcell Dijital İş Servisleri A.Ş. (often referred to as Turkcell Digital Business Services in the report) was incorporated and registered through carve out from Turkcell Satış in order to monitor its performance more coherently. Its area of operations include system integration and managed services, new generation technologies, business applications and supplying required hardware to cover end-to-end IT and technology related solutions and services for enterprises. Turkcell Digital Business Services aims to be a reliable technology partner that will provide tailor-made end to end IT solutions for enterprise customers. It enables customers to move forward with the most appropriate financial model in their new technology investment plans and focus more on their own business. It particularly targets sectors including health, manufacturing, retail, central and local authorities, logistics, finance, energy and SMEs. 73 Table of Contents Turkcell Finansman A.Ş. (“Turkcell Finansman” or “Financell”) Turkcell Finansman (referred to as “Financell”), a wholly-owned subsidiary of Turkcell, was established in October 2015 with the approval of the BRSA and launched nationwide in March 2016. It is the first finance company in Turkish telecommunications sector to be focused primarily on meeting the financial needs of individuals and corporate customers, and began by providing financing solutions to existing or new Turkcell customers for their smart devices, tablet, accessory or other device purchases. Companies that use Financell loans can finance their needs of hardware and devices with customized prices, interest rates and flexible payment plans. In 2019, Financell added corporate entities to its existing individual customer portfolio in support of Turkcell’s corporate business. In 2020, Financell started providing financing solutions also to Turkcell Superonline customers. In 2022, Financell started providing consumer loans via the Paycell platform for online and offline shoppers, auto loans, and solar panel loans via project firms. As at the end of 2025, as per Association of Financial Institutions data, Financell was the leading finance company in Türkiye in terms of number of customers. Financell’s main strengths are its ability to reach both telco and financial sector data and its robust risk modelling system. Our fully automated risk model utilizes over 5,000 data points using an advanced machine learning algorithm. Secondly, Financell has had the advantage of collecting the monthly loan payments via the customer’s Turkcell bill, which further reduces the unpaid risk. However, a regulation for payment companies including Paycell became effective in October 2023 that introduced a cap on the payment service amount that may be included in each monthly mobile invoice, which has increased and may continue to increase our unpaid risk and collection costs. See “Item 3. Key Information—D. Risk Factors—Risks Relating to Our Business—Changes in the regulatory environment in the sectors in which we operate could adversely affect our business and financial condition.” Since January 2020, installment periods for smartphone purchases in Türkiye have been subject to regulatory limitations based on retail price thresholds. As of December 31, 2025, devices with a retail price exceeding TRY 20,000 are restricted to a maximum three-month installment plan, while those priced below this threshold may be offered with up to a twelve-month plan. Although the regulatory threshold has been progressively adjusted—from TRY 3,500 in 2020 to TRY 5,000 in December 2021, TRY 12,000 in January 2023, and most recently to TRY 20,000 in December 2024—these constraints have exerted downward pressure on the volume of consumer loans disbursed by our finance subsidiary, Financell. To mitigate these impacts, Financell maintains a prudent risk management framework while diversifying its distribution network. Beyond Turkcell’s physical stores, website, and mobile application, Financell’s credit solutions are integrated into the Paycell platform, Turkcell and Financell call centers, and selected third-party merchants. The digital banking regulation in Türkiye was announced by the BRSA on December 29, 2021. Turkcell made its application to the BRSA for an establishment permit, which is the first step, on June 27, 2022. The application is still pending. If and when the approval is received, the remaining process would involve establishing a fully functioning digital bank, and we would apply once again for an operation permit to the BRSA. Financell maintains a diversified funding base comprising equity and debt financing. While bilateral loans from local and international banks remain the primary source of funding, the Company also utilizes local debt capital markets to optimize its liquidity position. Throughout 2025, Financell issued a series of short-term commercial papers with an aggregate nominal value of approximately TRY 2.0 billion (not restated for IAS 29), with maturities ranging from three to four months. These issuances demonstrate the Company’s continued access to local capital markets and its ability to manage short-term working capital requirements effectively. During 2025, Financell granted TRY 19.1 billion of loans. As of December 31, 2025, the total outstanding loan portfolio is at TRY 7.8 billion, compared to TRY 6.6 billion at year-end 2024 (both values are not restated for IAS 29). This contraction in the outstanding balance reflects the Company’s strategic focus on portfolio quality and the impact of prevailing regulatory installment limits. The Company’s Cost of Risk (CoR) increased to 4.1% as of December 31, 2025, from 2.9% in the prior year. This trend is closely monitored as part of our proactive risk management framework, reflecting broader macroeconomic conditions. 74 Table of Contents Turkcell Dijital Sigorta Turkcell Dijital Sigorta operates in the non-life insurance sector, under the brand Wiyo. The product portfolio consists of mobile phone protection, credit protection, accident & health (A&H) and compulsory earthquake insurance. Its flagship product, mobile phone protection insurance (Akıllım Güvende), positions the company as Türkiye’s only insurer specialized in smartphone insurance. The Company also provides Cyber Security Insurance covering Turkcell Group companies. Turkcell Sigorta Turkcell Sigorta acts as an agent and arranges corporate insurance for Turkcell and its group companies that are based in Türkiye via Turkcell Dijital Sigorta and other insurance companies, including the “Directors and Officers Liability Insurance,” which covers the liability of executives within the Turkcell Group with respect to their duties, and “Property and Casualty Group Policies,” which protect the assets of Turkcell and its group companies against risks such as fire, earthquake, flood and storm risks. Turkcell Ödeme ve Elektronik Para Hizmetleri A.Ş. (“Turkcell Ödeme” or Paycell”) Turkcell Ödeme became operational as of March 2012, presenting users with a convenient mobile payment solution and offering a streamlined experience under the “Paycell” brand. Paycell is a payment services platform providing digital payments and core financial solutions for both merchants and consumers. In August 2016, Turkcell Ödeme acquired a Payment Service Provider License from the BRSA to become the first mobile network operator subsidiary in Türkiye holding this license. With its brand “Paycell,” Turkcell Ödeme has expanded its merchant network by implementing easy and secure payment methods, both online and in stores, across a wide range of everyday services. Paycell offers a comprehensive digital financial ecosystem that simplifies daily life for customers through services such as direct carrier billing (Pay Later), money transfers, payments, wallet, and a prepaid card, while providing merchants with QR-based payment options and Android /virtual POS solutions as well as Pay by Link. We have further expanded our finance products with precious metal and shopping limit (consumer finance product). Paycell users are able to buy, keep or sell precious metals directly through the app. We introduced Paycell Shopping Limit, a consumer finance solution that enables purchases in up to 36 monthly installments, developed through the collobration of Paycell and Financell. Additionally, we integrated with the Interbank Card Center’s infrastructure to enable seamsless QR payments nationwide, allowing customers to pay effortlessly via their mobile phones. Since receiving its electronic money payment license in July 2017, Paycell has evolved into a comprehensive financial ecosystem. The platform has sustained its growth by integrating peer-to-peer money transfers, expanding merchant partnerships, and increasing the penetration of Paycell prepaid cards. To bolster its card issuance capabilities, Paycell has established long-term strategic partnerships with Visa, Mastercard, and TROY (by the Interbank Card Center). Reflecting our operational continuity, these collaborations involve ongoing incentive-based agreements with Visa and Mastercard. On the technological front, Paycell has significantly enhanced its contactless payment capabilities. Following the initial launch of NFC payments with TROY in December 2024, the service was expanded in 2025 to include all Visa and Mastercard holders on compatible Android devices. Furthermore, the app now enables QR-based payments, allowing users to utilize third-party bank cards stored within their Paycell digital wallets. Beyond its core B2C offerings, Paycell has strategically entered the B2B segment, leveraging its proven track record and corporate infrastructure to provide tailored solutions for business partners. In November 2023, Paycell became one of the first payment and electronic money institutions to qualify for participation in the CBRT’s Instant and Continuous Transfer of Funds (“FAST”) project. The FAST system enables instant and 24/7 money transfers, independent of EFT (Electronic Fund Transfer) hours. With the implementation of FAST, unique IBANs have been assigned to Paycell users, allowing money transfer processes to be executed quickly and seamlessly. With the integration of the FAST system, Paycell has enhanced the user experience by providing access to other services offered by the Interbank Card Center—delivering not only speed and convenience but also superior security and service continuity. 75 Table of Contents In 2025, Paycell obtained three new CBRT licenses, becoming the first payment and electronic money company to be fully licensed across all service areas subject to CBRT approval under the payment and electronic money regulations. Paycell has also integrated with the Interbank Card Center’s open banking infrastructure, enabling customers to link all their bank accounts in Paycell, view balances and transaction histories across different institutions, and initiate payments from their bank accounts—without switching between applications. Another development is a new collaboration aimed at increasing Paycell App adoption and deepening penetration among parents and students. Paycell and Okulyo, a student tracking solution provider, have joined forces to deliver a payment infrastructure that links the access cards students use at school entrances with the payments they make at schools. Paycell’s aim with end-to-end payment solutions is to bring the merchants and the consumers together by offering ease-of-use, new technology and financial benefits to consumers, while facilitating further revenue generation for merchants through payment and CRM solutions. Paycell POS offers collection and e-invoice processes in accordance with regulations on a single platform and provides cost efficiency for its merchants. Paycell continues to improve its products and services for merchants. The Android POS product, with its value added services such as RestaurantPOS, TaxiPOS, seeks to provide cost optimization and increase efficiency. Our Virtual POS product, where we provide a smooth end-to-end experience with ongoing developments made with integrators providing services in the e-commerce sector, not only seeks to provide cost savings for both our merchants in the market and Turkcell e-commerce channels, but also to provide value-added services and additional revenue for Paycell. Pay by Link, which is an ideal solution to make the online payment experience fast and secure, and can be used in many sectors, from the automotive industry to the service sector. Merchants can quickly and easily apply for POS products via the IstePaycell platform, via web and mobile application. Paycell expanded its financial services portfolio with international money transfer solutions, enabling fast, secure, and transparent cross-border transfers for both sending and receiving through partnerships with Mastercard and Remitly. Paycell allows consumers to receive money from 50 countries and send money to Mastercard cards and bank accounts in more than 80 countries via digital channels, enhancing financial accessibility while creating new revenue streams and cross-selling opportunities across its ecosystem. Paycell’s globalization efforts continue through various activities and initiatives. Following Paycell Northern Cyprus’ digital wallet application launched in July 2023, as of 2025, e-money and bill payment services in Turkish Republic of Northern Cyprus are now actively used by over 9,600 verified customers. In 2026, the Paycell Northern Cyprus application aims to increase usage rates and user activity through customer campaigns and standard promotional activities. In 2024, following a strategic shift decision, Paycell LLC ceased its operations in Ukraine, and on January 27, 2025, we decided to liquidate the company. In 2024, Paycell Europe gained traction in international money transfer and payment services in European Union countries, with over 2,700 verified customers using its money transfer application. In addition to enabling transfers to Paycell Wallet in Türkiye, Paycell Europe now offers direct transfers to Turkish bank accounts in partnership with Paytop. Furthermore, Paycell is expanding its corridors to facilitate money transfers to and from other countries. Paycell Europe continues to focus on international money transfer activities, prioritizing growth and service improvements in this area. While the company is researching opportunities to develop financial platform services in the future, its immediate focus remains on enhancing its money transfer services. As of December 31, 2025, Paycell had 6.7 million three-month active users. The Paycell app has been downloaded 35.0 million times to date. Paycell mobile payments three-month active users reached 5.5 million. The total transaction volume through Paycell reached TRY 175.1 billion in 2025 (not restated for IAS 29). Sofra Kurumsal ve Ödüllendirme Hizmetleri A.Ş. (“Sofra”) Sofra was incorporated on July 24, 2018. On October 21, 2024, Turkcell Ödeme acquired a 33.3% stake in Sofra from Posta ve Telgraf Teşkilatı A.Ş., thereby completing the acquisition of all remaining shares and reaching 100% ownership. Sofra offers meal cards issued under the “PAYE Card” brand, enabling personnel of customers to conveniently purchase food at member merchants. At the end of 2025, PAYE Card had 30 thousand active cardholders with services at around 8 thousand merchants. PAYE Card also has a virtual card feature which enables consumers to pay with QR at selected chain stores. 76 Table of Contents Turkcell Enerji Turkcell Enerji, a 100%-owned subsidiary of Turkcell, was established on February 20, 2017 with the vision of being a leader in the transformation of energy markets in Türkiye through digitalized, decentralized and decarbonized solutions. Turkcell Enerji owns an electricity supply license, issued by the Energy Market Regulatory Authority (EMRA), on May 11, 2017, for a period of 20 years. This enables the company to trade electricity and/or electrical capacity. Turkcell Enerji is able to supply electricity to eligible residential, commercial and industrial customers in Türkiye. Turkcell Enerji acquired the entire shares of Boyut Enerji by means of a share transfer completed on August 18, 2021. Boyut Enerji owns Karadag Wind Power Plant located in Izmir, Türkiye, which has an 18MW mechanical installed capacity. The plant commenced operations in 2016 and holds a license that will expire in 2057, and has a state purchase guarantee until the end of 2026. Turkcell Enerji continued to advance its renewable energy investments to support self-consumption. In 2025, a 163.5 MW solar power plant was installed and a further 62.3 MW solar power plant was commissioned. We aim to further expand our renewable energy capacity in 2026 while maintaining a strong focus on energy efficiency. TDC Veri Hizmetleri A.Ş. (“TDC”) We have identified the data center and cloud business as a strategic priority and are consequently allocating significant investments to support its growth. To optimize operational focus and scalability, we undertook a corporate restructuring. On July 11, 2024, TDC was incorporated and, on February 20, 2025, Turkcell Superonline’s data center assets were transferred to this new entity via a partial demerger. This organizational separation is designed to manage our data center and cloud operations more effectively through oversight. To further bolster our market position, we have also established a strategic partnership with Google Cloud. See “—III. Customer Segmentation and Services—b. Services—(iv) Digital Business Services Data Center & Cloud Services.” Atmosware Teknoloji Eğitim ve Danışmanlık A.Ş. (“Atmosware”) Atmosware, a wholly-owned subsidiary of Turkcell, was incorporated on October 8, 2021, to support Turkcell’s software development activities. Since its inception, Atmosware has expanded its scope and currently plays a critical role in executing our Company’s AI-driven digital transformation and software strategies. Atmosware focuses on providing software development services and technical solutions that enhance the operational agility of the Turkcell Group. By leveraging its deep technical expertise, the company reduces external dependencies and optimizes R&D expenditures. Beyond internal Group projects, Atmosware aims to commercialize its software capabilities by offering turn-key consulting and technology services for the AI-powered digital transformation processes of corporate clients across various sectors in Türkiye. Viewing technical talent management as a strategic priority, Atmosware operates as a specialized technology training center. The company cultivates a sustainable pipeline of highly skilled software developers to support our Company’s innovation capacity in cloud computing, data analytics, and next-generation communication technologies. This talent-centric service model positions Atmosware as a key enabler of Turkcell’s technological leadership and long-term sustainable growth. lifecell We acquired our interest in our former subsidiary lifecell (operating under the “life:)” brand on April 2, 2004, by purchasing the entire share capital of lifecell’s parent, CJSC Digital Cellular Communications. After the Russia invasion on February 24, 2022, lifecell continued its operations providing services to subscribers throughout Ukraine, except in areas where equipment has been damaged as a result of hostilities and access is currently impossible. lifecell together with other mobile operators launched national roaming throughout Ukraine. In 2023, despite the active hostilities and shelling by Russia, lifecell continued to restore the network infrastructure in Kherson, Mykolaiv, Kharkiv, Donetsk. As of December 31, 2023, lifecell had 11.7 million registered mobile subscribers, mainly prepaid. lifecell’s three-month active subscribers had reached 9.9 million as of December 31, 2023. 77 Table of Contents On December 29, 2023, Turkcell signed a share transfer agreement for the transfer of all shares, along with all rights and debts, of lifecell and Turkcell’s other Ukrainian businesses (Global Bilgi LLC and UkrTower) to NJJ Capital. On September 9, 2024, the transfer of shares, along with all rights and liabilities, of the above-mentioned companies was completed and Turkcell received USD 524.3 million in accordance with the share purchase agreement. As of September 9, 2024, the total sale value amounted to TRY 18,455.5 million, consisting of cash collected (TRY 17,778.0 million) and other receivable (TRY 677.5 million) related to the net cash/debt adjustment. The total gain on the sale was attributable to the net asset value of the companies (TRY 15,194.6 million) and accumulated foreign currency translation differences (TRY 5,560.3 million) related to foreign investments up to the sale date. The resulting total net income on the sale, after accounting for these factors, was TRY 8,821.2 million as of December 31, 2024. On August 4, 2025, based on the financial statements prepared as of the closing date, the final sale price was determined to be 538.7 million USD. Other receivables with a nominal value of 677.5 million TL related to the acquisition in 2024 were finalized with a nominal value of 490.1 million TL. The difference in nominal value of 187.4 million TL was reported under discontinued operations in 2025. Equity Accounted Investments Türkiye’nin Otomobili Girişim Grubu Sanayi ve Ticaret A.Ş. (“Togg”) Following Turkcell’s commitment on November 2, 2017 to “Türkiye’s Automobile Project,” Togg was incorporated on June 25, 2018, with six founding members. The agreement aimed to establish a framework for designing, developing and manufacturing electric and connected cars, creating a mobility ecosystem, and forming a local company to manage intellectual and industrial property rights. Following a shareholder restructuring on June 1, 2021, Turkcell (through its subsidiary Turkcell Gayrimenkul) increased its stake to 23%, joining AG Anadolu Grubu Holding A.Ş., BMC Otomotiv Sanayi ve Ticaret A.Ş., Vestel Elektronik Sanayi ve Ticaret A.Ş.as equal major shareholders, while Türkiye Odalar ve Borsalar Birliği holds the remaining 8%. Mass production at Togg’s Gemlik facility officially commenced on October 29, 2022. Togg operates a vertically integrated mobility ecosystem through its key subsidiaries, including Siro Silk Road Clean Energy Solutions (“Siro”) for battery production and technology, Togg Akıllı Ve Hızlı Şarj Çözümleri A.Ş. (“Trugo”) for charging network infrastructure and Togg Europe GmbH for its Europe activities. The total number of Togg T10X, the C-SUV model, in Türkiye increased to 88 thousand as of December 31, 2025, compared to 50 thousand units as of December 31, 2024. This performance reflected sustained demand in the domestic electric vehicle market and continued consumer acceptance of the Togg brand. In 2025, Togg expanded its product portfolio with the introduction of its second smart device, the T10F, a sporty fastback model. 2025 marked the beginning of Togg’s commercial export operations to Europe. Pre-order processes for the T10X and T10F commenced in September 2025 in Germany. The company adopted a controlled market entry strategy focused on service readiness, customer experience, and operational quality rather than rapid volume expansion. In Germany, more than 100 vehicles were delivered by year-end. The company continues to evaluate market conditions, customer feedback, and operational capacity as part of its phased expansion approach in Europe. Non-Consolidated Group Companies Turkcell Foundation Turkcell Foundation (“Turkcell Vakfı,” “Foundation”) was founded by our Company in 2018 in Türkiye. The Foundation is a not-for-profit organization aimed at reducing the public burden of the Turkish state by contributing to projects and charities that meet the social, educational, health, technological, environment, cultural, and moral current and future needs of the Turkish society. Following an application submitted by the Board of Trustees for the voluntary dissolution of the Foundation, a court decision was issued which became final on December 10, 2025, upon which the Foundation was formally dissolved. 78 Table of Contents X. Potential Investments Our efforts to selectively seek and evaluate new investment opportunities continue in order to pursue our strategy for growth by participating in those opportunities meeting our criteria. We may pursue inorganic growth opportunities both in Türkiye and internationally in order to leverage our experience and technological base. We may also pursue opportunities which include alliances, such as MVNOs, management service agreements and marketing partnerships, and that may be in the area of mobile or fixed telecommunications and services. We may also evaluate network sharing opportunities and participate in joint infrastructure companies within Türkiye. We will evaluate the opportunities of marketing the portfolio of our digital services in international markets to increase the users and our revenues from these services. We could also be interested in the acquisition of additional renewable energy production assets in accordance with Turkcell Group’s target of becoming a company meeting its electricity needs from eco-friendly resources. We participated in the establishment of Turkcell New Technologies Venture Capital Investment Fund on March 7, 2022. The fund’s commitment is TRY 750 million. Its aim is to invest in technology-oriented ventures with high growth potential thereby supporting the respective companies to reach their growth targets. Moreover, the goal is to create strategic and financial benefits, and accordingly long-term value for our Company, through the synergies expected to be generated by these ventures. From its establishment to the end of 2025, our Company has invested around TRY 500 million (not restated for IAS 29) through our fund for the current portfolio, for which our company has no binding obligation to contribute further capital. XI. Sustainability Sustainability Strategy Innovation and technology are the core catalysts of sustainable development. In this scope, mobile communication and digital technology applications play a major role in creating the infrastructure of sustainable development. Since we operate on a broad value chain that expands from mobile communication to digital applications, we aim to play a leading role in our operation ecosystem also with our sustainable integrated value model, as we do in every field. Accordingly, we observe to our stakeholders’ expectations, support sustainable development through our solutions shaped by international trends and best practices. By mitigating environmental, social and governance risks, we aim to strengthen our leading position in the sector while supporting long-term value creation for our stakeholders. Sustainability Governance and Committees We manage climate and environment related impacts across our value chain within the framework of our “Positive Imprint in Sustainability” strategy. Ultimate responsibility for the management of business processes under this framework rests with the Board of Directors. To ensure effective governance, the Board of Directors delegates certain responsibilities to its committees. The Corporate Governance Committee oversees the implementation and development of corporate governance principles, monitors investor relations and sustainability activities and submits recommendations to the Board of Directors. As part of the organizational change during 2025, the activities of the Integrated Value Creation Committee were terminated, and the monitoring and evaluation of sustainability related outputs were placed under the supervision of the Corporate Governance Committee. This restructuring aims to address the sustainability, investor relations, and corporate governance functions more effectively, in a coordinated and holistic manner under a single governance structure. The Sustainability Committee, composed of executives from different functions, determines sustainability priorities and reports on all activities and outcomes carried out under the ESG policies to the Board of Directors through the Corporate Governance Committee. Risks and opportunities, including those related to sustainability and climate change, are escalated to senior management through the Early Detection of Risks Committee when necessary. 79 Table of Contents The CEO contributes to the monitoring of progress toward sustainability and climate-related targets and oversees the alignment of the 2050 Net Zero target with the Company’s overall strategy. In addition, resource requirements and investment priorities related to sustainability initiatives are assessed within the relevant governance mechanisms. This governance structure is supported by the Investor Relations and Sustainability Department, operating under the Investor Relations and Corporate Finance Directorate. The Department develops short-, medium-, and long-term action plans, monitors progress against targets, evaluates sustainability performance and ensures coordination in the management of environmental and social impacts, particularly with regard to climate change. Efforts to manage ESG impacts and to enhance sustainability performance are carried out by the units responsible for the relevant business processes. In this way, ESG considerations are fully integrated into corporate strategic decision-making processes. Methodology An important part of the analysis of our sustainability performance with internationally accepted methodologies are the evaluations made within the scope of sustainability indices and evaluation systems. We provide information to the S&P Global ESG Index, MSCI ESG Index, Borsa İstanbul Sustainability Index (adopted London Stock Exchange Group’s (LSEG) ESG scoring metrics) and CDP Climate Change Program every year. As of December 2025, we achieved a significant milestone by rising to second place among 289 telecommunications companies worldwide in the ESG rating published by the London Stock Exchange Group (LSEG). Moreover in 2025, we became an A-list company in CDP Climate Change program. This assessment, in which only 877 companies were able to be included in the A-list among more than 22,000 reporting companies, reflects Turkcell’s strong performance in environmental sustainability. Turkcell also achieved the highest A rating in the CDP Supplier Engagement Rating, which evaluates primary actions and strategies for reducing greenhouse gas emissions and climate change risk across the supply chain. Turkcell continues to be a part of the BIST Sustainability 25 Index and lists the top 25 companies with the best sustainability performance in Türkiye. We have near term greenhouse gas emission reduction targets validated by the Science-Based Targets Initiative (“SBTi”) in order to bring our commitment to combating climate change to a systematic and rational framework. Our SBTi approved targets are in line with a 1.5C° trajectory. In this context, we aimed to reduce our absolute Scope 1 and 2 greenhouse gas emissions by 50.47% and absolute Scope 3 greenhouse gas emissions by 25% by 2030 compared to the 2020 base year. As of the end of 2025, these targets have been successfully achieved, supported by renewable energy certificates. We continue our emission reduction efforts in line with our SBTi targets. In June 2025, we committed to submitting our long-term target to SBTi, and we plan to have SBTi validated target by 2027. Moreover, Turkcell remained the first telecommunications company in Türkiye to balance its Scope 1 and Scope 2 emissions through renewable energy certificates (YEK-G) and carbon offset certificates (Gold Standard) procured in 2025. Under the responsible management approach, Turkcell manages environmental risks arising from its operations in accordance with international standards. In this context, we aim to improve resource efficiency, environmental protection, and the development of natural resources by taking measures, particularly with regards to mitigating the effects of climate change. Through these implementations, Turkcell reduces its environmental impact while enhancing the business value of the resulting resource efficiency. Efforts are underway in areas such as energy and water resource efficiency, waste management, circular economy practices, and responsible value chain applications. In line with this, Turkcell considers the risks and opportunities arising from climate change in its corporate policies and strategies, as well as its planning processes related to operational and service development. Turkcell closely follows those elements among its operations that may have an effect over climate, including energy consumption and greenhouse gas emissions. As the telecommunication sector uses electricity intensively, at Turkcell, we take energy consumption seriously and manage it according to international system standards, such as ISO 50001. The energy consumption points are continuously monitored and efforts are made to increase energy efficiency with the measures taken. Beginning in 2021, Turkcell started supplying all its electricity from certified renewable sources (YEK-G), and investing in renewable energy in line with the goal of achieving net zero operations by 2050. Turkcell meets 100% of its total electricity consumption from renewable energy sources, fully verified by renewable energy certificates. In 2025, a 163.5 MW solar power plant was installed and a further 62.3 MW solar power plant was commissioned. We aim to further expand our renewable energy capacity in 2026 while maintaining a strong focus on energy efficiency. 80 Table of Contents The Turkish Sustainability Reporting Standards (TSRS) entered into force on January 1, 2024, with the decision of the Public Oversight Authority in Türkiye. Please see “—XIII Regulation of the Turkish Telecommunications Industry—ee. Other regulations affecting our Company—v. Turkish Sustainability Reporting Standards (TSRS).” In line with decision, we published our first TSRS-compliant integrated annual report on sustainability matters in April 2025. For the 2025 reporting period, the TSRS-Compliant Sustainability Report was issued in March 2026 as a standalone document, rather than in an integrated format as in the previous year. Moreover, in December 2024, Turkcell published its sustainable finance framework, (with an independent second-party opinion from DNV) linked to the United Nations Sustainable Development Goals and aligned with the Green Bond Principles 2021 (with June 2022 Appendix 1), the Social Bond Principles 2023 and the Sustainability Bond Guidelines 2021 as published by the International Capital Market Association (ICMA). Turkcell’s Framework is also aligned with the Green Loan Principles 2023 and the Social Loan Principles 2023 as published by the Loan Market Association, the Asia Pacific Loan Market Association and the Loan Syndications and Trading Association. Building on these efforts, Turkcell issued a USD 500 million sustainable bond with a seven-year maturity at the beginning of 2025. XII.Disclosure Pursuant to Section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012 (“ITRA”) Based on our information and the information provided to us by our affiliates, as of December 31, 2025, we believe that certain of our business activities in 2025, and the business activities of certain of our affiliates, are subject to disclosure pursuant to Section 219 of ITRA. The data provided in this section have not been restated for IAS 29. During the year ended December 31, 2025, Turkcell had international roaming relationships with the following companies in Iran: Telecommunication Company of Iran, Irancell Telecommunications Services Company (“MTN Irancell”), and Rightel Communication Services Company PJS (“Rightel”). Turkcell had gross revenues of approximately TRY 43.6 million and gross margin of approximately TRY 35.5 million attributable to these agreements during the year ended December 31, 2025. Despite having an international roaming relationship with Gostaresh Ertebatat Taliya PJS (“Taliya”), there was no revenue or commercial engagement between the parties during the reporting period. Additionally, in Syria, our relationship with Syriatel generated gross revenues of approximately TRY 67.6 thousand and gross margin of approximately TRY 51.2 thousand. Turkcell has developed several digital services which may be available for download free of charge and may have been downloaded from within Iran. The Company believes that these downloads from within Iran have generated no revenue or profits. Turkcell Superonline provided transit IP and leased line services through network interface agreements with Telecom Infrastructure Company of Iran (“TIC”). During the year ended December 31, 2025, gross revenues attributable to these agreements were approximately EUR 360 thousand. Turkcell Superonline provided transit IP and leased line services through network interface agreements with Teleka Maedeh Co. (Telecom Idea). During the year ended December 31, 2025, gross revenues attributable to these agreements were approximately EUR 830 thousand. In addition, Turkcell Superonline will provide transit IP and is expected to provide leased line services through network interface agreements with Telecom Syria in 2026. We have made enquiries of our major shareholders regarding activities in Iran and Syria. One of our major shareholders TWF has indicated that it does not currently have, and has not recently had, any business relationships, operations or investments in Iran or Syria. TWF further stated that, its wholly-owned entity BOTAŞ does not have any ongoing activities, transactions or commercial engagements in Iran or Syria. In addition, Letterone Investment Holdings S.A., which has an indirect economic interest in our shareholder IMTIS Holdings, has indicated that one of its subsidiaries, Remedica Limited, has contracts with non-government organizations in Syria and Iran via well-known, reputable global pharmaceutical companies. 81 Table of Contents Although it is difficult to do with a reasonable degree of certainty, we have concluded that our Iranian business partners described in this section may be owned or controlled indirectly by the Government of Iran. However, to our knowledge, none of the services provided by Turkcell and our affiliates in Iran described in this section have been used by the Government of Iran to commit serious human rights abuses against the people of Iran. Furthermore, we understand that the U.S. Department of the Treasury’s Office of Foreign Assets Control has issued general licenses authorizing U.S. persons to engage in certain of the activities described in this section. We and our affiliates intend to continue the activities described in this section in 2026. XIII.Regulation of the Turkish Telecommunications Industry The data provided in this section have not been restated for IAS 29. a.Overview All telecommunications activity in Türkiye is regulated by the ICTA. The Electronic Communications Law No. 5809 (the “Electronic Communications Law”), which came into force on November 10, 2008, is the principal law governing telecommunications activity in Türkiye. The Electronic Communications Law was published to respond to the rapidly-evolving Turkish telecommunications industry, and all secondary regulations have been updated to be in accordance with this law. The duties of the ICTA, which may be exercised in a manner that is adverse to our operations and our financial results, include those described below. b.ICTA The ICTA has the authority to grant licenses and set fees in the electronic telecommunications industry. According to Article 8 of the Electronic Communications Law, electronic communications services are rendered and/or established (as in the case of an electronic communications network or infrastructure) and operated following ICTA authorization. Authorization is granted either through notification made in accordance with the principles and procedures determined by the ICTA, in cases where scarce resource allocation is not necessary, or by the granting of usage rights, in cases where scarce resource allocation is necessary (allocation of frequency, satellite position, etc.). Under the Electronic Communications Law, usage rights may be granted for up to 25 years; however, there is no clause relating to the term of notification. According to the Electronic Communications Law, the principles and procedures relating to the notification and granting of usage rights are determined by the ICTA through secondary regulations. According to the Authorization Regulation, the validity periods of authorizations granted via notification and those granted with usage rights may be granted for up to 15 years. Also, the ICTA can determine authorization validity and sufficiency control periods as three, seven or 15 years. According to the Electronic Communications Law, usage rights can only be restricted where the resources are required to be operated by a limited number of operators and for the purpose of ensuring the effective and efficient use of the scarce resources. In cases where the quantity of rights of use is limited, Article 9-6(a) of the Electronic Communications Law allows the Ministry of Transport and Infrastructure to determine the criteria, such as (i) the authorization policy regarding electronic communications services which cover the assignment of satellite position and frequency band on a national scale and which need to be operated by a limited number of operators, (ii) the starting date of the service, (iii) the duration of the authorization and the number of operators to serve. While the criteria are determined by the Ministry of Transport and Infrastructure, the authorization is still granted by the ICTA. The Electronic Communications Law establishes legal principles and broad policy lines that the ICTA must follow, some of which are stated below: ● Creation and protection of a free and efficient competitive environment. ● Protection of consumer rights and interests. ● Protection of the objectives of development plans and Government programs, as well as the strategies and policies set by the Ministry of Transport and Infrastructure. 82 Table of Contents ● Promotion of implementations that ensure that everyone can benefit from electronic communications networks and services. ● Ensuring non-discrimination among subscribers, users and operators under fair conditions. ● Ensuring the conformity of electronic communications systems to international norms. ● Protection of information safety and communication confidentiality. ● Determination of the procedures and principles related to the personal data and protection of privacy. The Electronic Communications Law also specifies general rules and principles relating to interconnection between operators. Agreements for interconnection are publicly available, but precautions are taken by the ICTA to protect the commercial secrets of the parties. The Universal Service Laws, Law No. 5369, determines the procedures and principles governing the provision and execution of universal service and the procedures and the rules relating to the fulfillment of universal services in the electronic communications sector. In accordance with Law No. 5369, the scope of universal services is determined and periodically reviewed, with the review period not exceeding every three years, and can be re-determined by the President of Republic of Türkiye. The legislation designates the following as universal services: fixed-line telephony services, public pay telephones, telephone directory services to be provided in printed or electronic environments, emergency call services, internet services, passenger services to residential areas where access is solely provided by sea and sea communication and sailing safety communication services. This law mandates that all operators designated to provide universal services, except for those obligated to pay Treasury Share, must pay 1% of their annual net sales revenue towards the universal service fund, while operators that are liable to pay Treasury Share must pay 10% of the Treasury share amount to the ICTA as universal service contribution. The General Directorate of Communication can demand that operators provide universal services on a national and/or geographical basis. Türk Telekom and the GSM operators are currently designated as universal services providers. The Council of Ministers Decision No. 2011/1880, which was published in the Official Gazette dated July 4, 2011 allowed the use of the universal service fund to extend the mobile GSM network coverage listed in the annex of the decision to uncovered areas with a population of 500 or below. On February 13, 2013, we were appointed as universal service provider after a tender process and the related contract was signed on February 20, 2013. Under the aforementioned contract, Turkcell duly carried out its undertakings for installing sufficient infrastructure to cover 1,799 rural locations and the investment and operating expenses are compensated by the universal service fund of the Ministry of Transport and Infrastructure. This contract was renewed until December 31, 2018, and the extension contained new requirements to provide mobile broadband services and to operate the new and existing networks together. The Ministry of Transport and Infrastructure has approved the extension of the contract under the same conditions by periods of six months through December 31, 2021. Furthermore, the maintenance, repair and operation services of the sites established within the scope of the Universal Phase-1 project that was carried out by Turkcell were transferred to Turksat as of April 1, 2022. The Electronic Communications Law also specifies general rules and principles relating to tariffs. According to the Electronic Communications Law, the ICTA may intervene in the structure of our tariffs or may impose certain criteria relating to the revision of our tariffs. Pursuant to the Electronic Communications Law, operators may freely determine the tariffs they apply in compliance with the relevant legislation and the ICTA arrangements. The Electronic Communications Law provides basic guidelines for the tariffs and pricing and thus leaves the detailed rules and enforcement to the ICTA. According to the law: (1) The tariff may be determined as one or more subscription fees, fixed fees, call charges, line rentals, and similar fee items. (2) Tariffs to be imposed in return for providing any kind of electronic communications services shall be subject to the following provisions: 83 Table of Contents (a) Operators shall freely determine the tariffs under their possession, provided that they comply with the regulations of the ICTA and the relevant legislation. (b) If an operator is designated as having significant market power in the relevant market, the ICTA shall be entitled to determine the procedures regarding the approval, monitoring and supervision of tariffs as well as the highest and lowest limits of the tariffs and the procedures and principles for the implementation thereof. (c) If an operator is designated as having significant market power in the relevant market, the ICTA shall be entitled to make the necessary arrangements to prevent anti-competitive tariffs such as price squeezing and predatory pricing and to supervise the implementation thereof. (3) Procedures and principles pertaining to the implementation of Article 13 of the Electronic Communications Law, submission of tariffs to the ICTA and publishing and announcing them to the public shall be determined by the ICTA. In addition to the duties and authorities stated above, the Law Regarding the Establishment of ICTA No. 2813 has been amended and the ICTA has been given the authority to apply a conciliation procedure for the receivables including administrative sanctions (except for the receivables that are intermediated for collection and the penalty requirement for the treasury share) and the debts of the ICTA. According to this provision, it is possible to settle on a part of the disputed amount and to waive the primary or secondary claims. Furthermore, the settled matters cannot be made the subject of a lawsuit or a complaint. Telegraph and Telephone Law No. 406 (the “Telegraph and Telephone Law”) has also been amended such that in the event that the treasury share is not paid in full in the given period, the ICTA may impose a penalty in the amount of the incomplete or unpaid treasury share. In 2020, as per the amendments to Articles 49 and 50 of the Electronic Communication Law, subscription agreements are allowed to be concluded either in writing or electronically through methods determined by the ICTA which enable the identity verification process of subscribers. Within this scope, the Regulation on the Identity Verification Process of the Applicant in the Electronic Communication Sector was published by the ICTA in the Official Gazette dated June 26, 2021. The Regulation introduced new methods and standards for identity verification in the electronic communications sector. According to the Regulation our Company bears the burden of proof in all transactions, including objections to the administrative or judicial processes. On December 25, 2025, amendments to the Electronic Communications Law were published in the Official Gazette, introducing more stringent subscriber identification and monitoring requirements. Subscription registrations must now be verified via biometric data (facial recognition or fingerprint templates) or specific authentication credentials, namely e-Government passwords or identity card PINs, rendering identification documents without electronic verification capabilities insufficient for subscription purposes. Operators are required to verify the active status of all subscribers through official records on a quarterly basis and must adhere to line ownership limits per individual or legal entity as determined by ICTA. Pursuant to Temporary Article 8, foreign nationals are required to update their subscription records within six months of the provision’s effective date. Furthermore, subscribers exceeding the line limits to be established by the ICTA are granted a six-month period to rectify their status following the ICTA’s determination. The ICTA is expressly authorized to extend both transition periods for an additional six months. Failure to comply within the prescribed or extended timelines will result in the mandatory disconnection of the affected services by the operator. Amendments to the Electronic Communications Law prescribe high-impact sanctions, such as significant administrative fines and the refund of unjustly collected subscriber fees, including accrued interest. The ICTA is expected to issue mandatory amendments to Regulation on Consumer Rights in the Electronic Communications Sector and the Regulation on the Identity Verification Process of the Applicant in the Electronic Communication Sector in accordance with the Electronic Communication Law. Pursuant to the 2022 amendments to Articles 3, 9, and 60 of the Electronic Communications Law, Over-the-Top (“OTT”) service providers offering interpersonal electronic communications—including voice, text, and visual communication services in Türkiye—are subject to authorization by the Information and Communication Technologies Authority (“ICTA”). Under this regulatory framework, OTT providers are required to comply with specific statutory rights and obligations as determined by the ICTA, tailored to the nature of the services provided. 84 Table of Contents Pursuant to ICTA Board Decision No. 2025/DK-YED/412, electronic communication service providers and third parties acting on their behalf, such as agents and dealers, are strictly prohibited from initiating voice calls or transmitting SMS/MMS for marketing, promotional or informational purposes to individuals other than their own subscribers. We expect that this regulation will have a material impact on our subscriber acquisition rates. c.Regulations Related to Market Analyses According to the Electronic Communications Law it is among the duties and authorities of the ICTA to conduct market analyses in the electronic communication sector, to identify the relevant market and the operator(s) with significant market power (“SMP”) in the relevant market. In the Mobile Call Termination Market, all three operators are designated as having SMP. Accordingly, the mobile termination rates of all operators are regulated by the ICTA. In the Mobile Access and Call Origination Market, only Turkcell was designated as having SMP. As of January 1, 2020, the Mobile Access and Call Origination Market was deregulated and Turkcell’s SMP designation was removed. For additional details and further steps regarding Turkcell’s SMP designation, see “—v. Access and Interconnection Regulation.” Regarding the fixed broadband markets, in 2019, the ICTA finalized “The Wholesale Central and Local Market Analysis.” By its Board decision dated December 31, 2019, the ICTA decided to designate Türk Telekom as the sole SMP for both markets. Access to fiber products (Fiber Bitstream, Virtual Unbundling of Local Access (“VULA”) and margin squeeze obligations were also imposed on Türk Telekom, in addition to its existing obligations. As a result of being SMP operator in relevant markets, Türk Telekom was obliged to publish reference offers. Türk Telekom’s Reference IP Bitstream Offer has been published and effective. The updating process is still ongoing for Türk Telekom’s other reference offers (Ethernet Bitstream, VULA, Local Loop Unbundling (“LLU”), Facility Sharing and Dark Fiber, Co-location and Building Access) in which terms and conditions are defined. Based on the wholesale fixed local and central access market analysis published in 2019, Türk Telekom is obligated to offer copper and fiber access products. ICTA has determined that Türk Telekom may decommission all networks relying on copper infrastructure (copper switch-off) in FTTH deployed locations. After issuing Building and Subscriber Notifications to the Internet Service Providers indicating that Türk Telekom’s fiber access is available on the premises, Türk Telekom will no longer fulfill new copper access or relocation requests. Türk Telekom may terminate copper-based access products 90 days after a Service Termination Notification is issued to internet service providers. The Wholesale and Retail Dedicated Capacity (Leased Lines) Market Analysis was amended by ICTA and published on December 4, 2025. The previous relevant market analysis was conducted in 2017. Accordingly, in the wholesale dedicated capacity transmission and termination markets, ICTA designated Turkcell Superonline and Türk Telekom as having SMP. In the retail dedicated capacity transmission and termination markets, only Türk Telekom has been designated as having SMP. Operators designated as having SMP are subject to several obligations such as access obligation (covering products deemed to fall within the relevant product/service markets), non-discrimination, transparency, the preparation and publication of reference access offer, cost-oriented pricing, account separation and cost accounting and co-location and facility sharing. In the wholesale and retail dedicated capacity transmission markets, ICTA identified effective competition on the routes between İstanbul–Ankara, İzmir–İstanbul, Kocaeli–Ankara, and Kocaeli–İstanbul. Consequently, at the traffic handover points located in the provinces where these intercity connections are established, ICTA decided that Turkcell Superonline and Türk Telekom shall be subject only to co-location and facility sharing obligations. d.Regulation on Quality of Service in the Electronic Communications Sector The Regulation on Quality of Service in the Electronic Communications Sector, effective since December 31, 2011, is applicable to all operators that provide service to end users and sets out the procedures and principles to control the conformity of the services of operators. Mobile telephone operators are required to meet new service quality requirements and submit a report based on these requirements every three months to the ICTA. Additional requirements for service quality must be fulfilled. If the operators fail to reach these requirements more than once in the same calender year, this may result in the imposition of penalties. The results of quality measurements can also be made publicly available on the website of the ICTA for a period of one month, stating that the operator has failed to comply with the service quality requirements. 85 Table of Contents e.Regulation on Administrative Fines, Sanctions and Precautions in the Electronic Communications Sector According to the Regulation on Administrative Fines, Sanctions and Precautions to be imposed on operators, effective as of February 15, 2014, the ICTA retains the right to impose fines in the event an operator submits incorrect or misleading documents or fails to submit documents as requested by the ICTA; does not submit such documents in a timely manner; does not permit inspection or audits to be made by the ICTA; uses unpermitted equipment or equipment not complying with standards or alters technical features of equipment; or does not pay fees arising from its use of licenses and frequencies; does not meet the regulations regarding numbering, number portability, calling line identification, access and interconnection, end-user tariffs, consumer rights, value added services, data protection, national security and public order, service quality and such or does not comply with the provisions of license agreements, telecommunications licenses and general authorizations or the legislation. The ICTA is authorized to impose sanctions and precautions as well as administrative fines. In 2018, there was an amendment to the aforementioned regulation which introduced a new provision addressing “natural persons” and “private legal entities which are not operators” under the Electronic Communications Law. According to the new provision, entities (including “natural persons” and “private legal entities which are not operators”) who fail to comply with the obligations determined by the ICTA regarding national cyber security activities and protective measures against cyber-attacks, or fail to implement the measures taken by the ICTA, will be subject to administrative fines. f.Regulation on Authorization regarding the Electronic Communications Sector In 2009, the ICTA published the “Regulation on Authorization regarding the Electronic Communications Sector” (“Authorization Regulation”), which determines the principles and procedures for the authorization of the companies that seek to provide electronic communication services and/or to install or operate electronic communications networks or infrastructure. In 2016 and 2021, there were major amendments to the aforementioned regulation. According to the amendments: (1) Operators authorized with the limited usage right authorization may sell devices, make installations, carry out maintenance or give consultations if it is related to or necessary for its field of activity. As a result of this amendment, Turkcell is able to sell devices in relation to electronic communication services. (2) Companies that apply to the ICTA for authorization should have paid the minimum amount of paid capital set by the ICTA. (3) All operators should obtain the consent of the ICTA prior to the transfer, acquisition or any other transaction regarding 10% or more of their shares. Those operators should also notify the ICTA within two months at the latest in case of a transfer, acquisition or any other transaction of their shares up to 10%. (4) Operators should provide free call center services. (5) Operators should keep the traffic data of their customers for two years. (6) Operators should provide information to the ICTA regarding the number of personnel and their qualifications. (7) The ICTA is entitled to decline authorization applications and proceed with operator inspections to confirm the accuracy of the information and documents submitted during the authorization application. (8) If the ICTA determines that the operator has not provided any services in the last three years, its authorization may be cancelled. (9) Operators should publish the information of their dealers (name, title, address, telephone, website) on the operator’s website and ensure compliance of the dealers with the standards which are determined by the ICTA. (10) Operators were required to apply to the ICTA with the necessary information and documents for authorization by December 31, 2023. Applications were made within the specified time period for the Turkcell Group companies impacted by this regulation: Turkcell Superonline and Global Tower. 86 Table of Contents g.Regulation on Mobile Number Portability Pursuant to Article 32 of the Electronic Communications Law, operators are required to supply operator number portability. MNP allows subscribers to keep their existing telephone number when changing their telephone operator, their physical location or current service plan. These regulations have been operational since the fourth quarter of 2008. A lawsuit has been filed requesting termination and cancellation of the execution of the “Regulation on Mobile Number Portability,” which was issued by the ICTA and entered into force through publication in the Official Gazette dated February 1, 2007 and numbered 26421. Upon the rejection of the case and the finalization of this decision, Turkcell made an individual application before the Constitutional Court against the decision. The Constitutional Court held that the claim regarding the violation of the property right was acceptable and that the property right was violated and decided to send a copy of the decision to the 13th Chamber of the Council of State for a retrial in order to eliminate the consequences of the violation of the property right. The Council of State canceled the Mobile Number Portability regulation. The defendant administration and intervenor TT Mobil appealed the decision. The company responded to the appeal requests in due time. The Council of State, Plenary Session of the Chambers for Administrative Cases decided to accept the defendants appeals and overturn the decision of the 13th Chamber of the Council of State regarding the repeal of the contested Regulation. The Company filed a timely application for correction of the decision. The Council of State, Plenary Session of the Chambers for Administrative Cases accepted Turkcell’s correction of decision request and upheld the decision of the 13th Chamber of the Council of State regarding the cancellation of the contested Regulation. Accordingly, the decision has been finalized in favor of the Company. In 2009, the ICTA issued a new Regulation on MNP, abolishing the 2007 regulation and amended certain Articles of this Regulation in November 2015. Mobile subscribers are eligible to make a porting request only after 90 days of the date of activation of their first mobile connection. Furthermore, the ICTA published the “Regulation Amending the Number Portability Regulation” and “Procedures and Principles Regarding Number Portability Implementation Process” on February 12, 2022, seeking to align the ongoing number portability procedures with the Regulation on the Applicant’s Identity Verification Process in the Electronic Communications Sector, as well as to increase measures to prevent involuntary port-outs and slamming. Regulations regarding the method to be applied in the control of identity information entered into force on December 31, 2022. h.Regulation on Security of Network and Information in Electronic Communications Sector In 2008, the ICTA published the “Regulation on Security of Electronic Communication,” which determines the principles and procedures for precautions to be taken by the operators for eliminating or derogating the risks caused by threats or weaknesses of (i) the physical area of the operators, data, hardware/software security and reliability, and (ii) sustaining the reliability of human resources. In accordance with the regulation, our Company is required to comply with TS ISO/IEC 27001 or ISO/IEC 27001 standards. Turkcell was the first mobile operator in Türkiye to receive the ISO/IEC 27001:2005 certification for its Network Operations function in 2008 covering all operations throughout Türkiye. In 2011, Turkcell’s IT function was also certified for ISO/IEC 27001:2005 and Turkcell’s ISO/IEC 27001:2005 scope became one of the largest among telecommunication operators in Europe. In 2015, the Information and Communications Technology and Network departments successfully passed ISO 27001:2013 audits and were deemed to be in compliance with the ISO 27001:2013 version. ISO/IEC 27001:2013 certification is regularly renewed every year. By having an ISO/IEC 27001:2013 certificate covering telecom infrastructure operations, Turkcell fulfills its regulatory obligations and offers its customers the benefits of an internationally-recognized secure management of operations and services. In July 2014, the ICTA repealed the above regulation and published the “Regulation on Security of Network and Information in Electronic Communications Sector” which requires the Company to set up and maintain a specialized team to detect, prevent and report all cyber events and work in coordination with the National Computer Emergency Response Center, in addition to the abovementioned obligations. 87 Table of Contents i.Presidency Circular on Information and Communication Security Measures The Presidency Circular on Information and Communication Security Measures dated July 6, 2019 (the “Circular”), aims to ensure the security of critical data, which may threaten national security or lead to the deterioration of the public order when the data privacy, integrity and accessibility are impaired. Pursuant to the Circular, the Presidential Office for Digital Transformation published an “Information and Communication Security Guide,” on July 27, 2020, which sets out the information and communication security measures to be followed by public institutions as well as the enterprises providing critical infrastructure services which includes telecommunication operators. The guide covers measures and related activities to be carried out by public institutions and concerned enterprises to ensure the security of their asset groups, applications and technology in accordance with degree of criticality, i.e. basic, medium and advanced. Accordingly, telecommunication companies shall determine the degree of criticality of their assets and draw a roadmap to implement effectively the concerned measures for asset groups with advanced criticality level in two years. The guide is expected to be updated periodically, and to be published on the website of the Presidential Office for Digital Transformation. Concerned public institutions and enterprises shall perform audits once a year internally or by an independent institution to determine the compliance of their activities and measures with the Guide. The Presidential Office for Digital Transformation also published on its website, in October 2021, “Information and Communication Security Audit Guide” which introduces the methodology to be followed in planning the audit, applying the audit procedures and reporting the audit results. j.Turkish Competition Law and the Competition Authority In 1997, the Competition Law (No. 4054) (the “Competition Law”) established a competition board (the “Competition Board”). The Competition Board consists of seven members who are appointed for a term of four years. It is an autonomous authority with administrative and financial independence established to ensure effective competition in markets for goods and services. The Competition Board can carry out investigations, evaluate requests for exemptions, monitor the market, assess mergers and acquisitions, submit views to the Ministry of Trade and perform other tasks stipulated by the Competition Law. The ICTA can apply to the Competition Board if it determines that agreements regarding access, network interconnection and roaming violate the Competition Law. Any person or legal entity may file a complaint with the Competition Board. The Competition Board can take necessary measures to prevent violations and may impose fines on those who are liable for such prohibited practices. The Competition Board may impose fines of up to 10% of the annual gross income of the operators, which is constituted by the end of the previous financial year and determined by the Competition Board. The ICTA and the Competition Board entered into a Protocol on Cooperation in 2002, followed by follow-up protocols in 2011 and 2015. The original protocol established a framework whereby the ICTA and the Competition Board can cooperate on legal actions and policies regarding measures, regulations and inspections that affect competition conditions and competition in the telecommunications sector. The follow-up protocols regulate the mechanisms to improve cooperation between the ICTA and the Competition Board. k.The Principles on Applications Regarding Anticompetitive Acts in Electronic Communications Sector One of the principles that the ICTA must follow is the creation and protection of a free and efficient competitive environment. The Electronic Communications Law specifies that the ICTA is authorized to set rules (that do not contradict the Turkish Competition Law) to prevent anticompetitive acts, to investigate the operators ex officio or upon a claim, and to take necessary measures against anticompetitive actions. Considering that applications regarding anticompetitive acts are made by different methods and based upon a variety of documents, the ICTA published the “Principles on Applications Regarding Anticompetitive Acts in Electronic Communications Sector” on December 20, 2017 in order to clarify these points. l. Regulation on Base Station Implementation in Electronic Communication Sector In 2012, according to Law No. 6360 and Municipality Law No. 5393, the Metropolitan Municipalities were authorized to give site selection certification to the BTS considering the requirements of city and building aesthetics and electronic communication services. The Site Selection Certificate Regulation was published in the Official Gazette dated January 27, 2018, and entered into force on the date of its publication. According to this regulation, a fee (TRY 34,514 plus 20% VAT per station for the year 2026) will apply only to BTS established after December 6, 2012. 88 Table of Contents m.Zoning Law and Construction Certificate Requirement of Base Stations On October 1, 2009, the Supreme Court of Appeals rescinded the regulation regarding the exemption for base stations from obtaining construction permits. The existing zoning law in Türkiye now requires mobile operators to obtain construction certificates for all existing and new base stations, resulting in the shutdown of certain stations for which certification cannot be obtained. In Türkiye, nearly half of the premises were built illegally without any permission. As a result, a number of municipalities started taking legal action such as affixing seals to suspend construction, or demolition orders against base stations, negatively affecting our coverage, quality of service and customer experience. We have also taken legal action requesting nullity of those acts. Legislative work has been done to fill the legal gap caused by the annulment decision of the Supreme Court. The amendments adopted in the Zoning Law have entered into force as of November 17, 2020. With these amendments, three segments were designated according to the characteristics of electronic and communication systems: (i) the masts and towers higher than 15 meters became subject to a license, and (ii) (a) the masts and towers lower than 15 meters and (b) the masts and towers lower than 10 meters on the rooftops became subject to obtaining a permission. A Site Selection Certificate was still to be obtained prior to the license/permit applications. Masts and towers over 15 meters that were established and/or were to be established on the parcels and land, were to be specified in the 1/1000-scale implementary zoning plan; however, it was not required for the other types of BTS’s. There was no license and permission requirement for the stations established between July 2, 2004 and October 1, 2009. It was mandatory for stations established before July 2, 2004 and between October 1, 2009 and November 17, 2020 to apply within a year and the necessary documents within three years. The fines imposed on electronic communication stations established before November 17, 2020 were to be voided, and demolition decisions were not to be applied. However, these legal provisions were reviewed by the Constitutional Court, which, in its decision dated June 1, 2023, ruled that three specific provisions were unconstitutional and therefore annulled: (i) the use of the term “permit” in the paragraph regulating procedures for stations established before the amendment of the law, (ii) the exemption granted to stations installed between 2004 and 2009, and (iii) the provision preventing demolition decisions for stations built before the amendment. The rest of the provisions from the Zoning Law remain in effect. Following the Constitutional Court’s annulment decision published on October 18, 2023, the gap created in the processes related to rooftop electronic communication systems was addressed with a new legal provision, which was published and came into effect on December 12, 2024. This amendment introduced a regulation requiring license applications for the base stations built between 2004 and 2009 to be submitted within a year, with the aim of resolving existing gaps and uncertainties in the process for these periods. Any delay or failure to receive approval for these applications, or any further regulatory changes, could result in additional costs and obligations in connection with our base stations. n.Regulation on the Internet The Law on the Regulation of Broadcasts via the Internet and the Prevention of Crimes Committed Through such Broadcasts has been revised by Law No. 6518, which became effective on February 19, 2014. The new law required that all internet access providers, which include all mobile and fixed network operators, as well as all internet service providers, form a Union of Internet Access Providers (“UAP”) within three months, which was duly established. After the establishment of the UAP, if any internet service provider or any operator giving internet services fails to become a member of the UAP, it shall also be fined in an amount equal to one percent of the previous year’s revenues. In addition, the law raised the existing fines for not removing content as requested by the court. The law also introduced URL-based blocking of websites which requires capital as well as operating expenditures for all internet access providers. o.GSM Licensing in Türkiye The terms of license agreements are governed by the Authorization Regulation, which provides that the ICTA must approve the transfer of licenses to third parties, ensure continuation of services in the event of cancellation of a license and approve the investment plans submitted by licensees. A GSM license is subject to the ICTA’s right to suspend or terminate operations under the license on the grounds of security, public benefit, and national defense, or to comply with the law. However, suspension or takeover of facilities under these circumstances is subject to the payment of compensation to the operator. The ICTA can also inspect such licensee and nullify its license if the licensee has materially failed to comply with the terms of its license. The ICTA may also terminate licenses in cases of gross negligence or non-payment of the authorization fee. 89 Table of Contents The licensee is responsible for installing telecommunications equipment in conformity with international signalization systems and abiding by the numbering plans. Furthermore, the licensee is obligated to make the necessary investments to offer the licensed service, including the design of the service, the making of financial investments and the installation and operation of the facility required for the service. Licensees are allowed to determine the prices for services, subject to the regulations of the ICTA. Upon the expiry of a license, including termination, the facilities and immovables, in operating condition, are to be transferred by the licensee in accordance with the license agreement. p.Our GSM (2G) License Agreement General Since April 1998, we have operated under a 25-year GSM license for which we paid an upfront license fee of USD 500 million. In 2002, we signed a renewed license agreement for our GSM license. Our Company is obliged to pay a monthly treasury share to ICTA, amounting to 15% of our gross revenue. Of this amount, 90% is considered as the treasury share, while the remaining 10% is allocated to the universal service fund. This payment obligation is applicable to all of our licensing agreements, including our 3G license, 4.5G (IMT) authorization, and 5G (IMT-2020) authorization. If such payments are not duly paid twice in any given year, a penalty in an amount equal to triple the last monthly payment shall be payable to the Turkish Treasury. However, as a result of the aforementioned amendments made to the Telegraph and Telephone Law, it has been provided that in the event that the treasury share is not paid in full in the given period, the ICTA has the right to impose a penalty in the amount of one full amount of the incomplete or unpaid treasury share. In addition, we must pay annual contributions in an amount equal to 0.35% of our gross revenue to the ICTA’s expenses. After the tender relating to the allocation of additional GSM 900 frequency bands conducted by the ICTA in June 2008, the license agreement was amended to include the additional frequency band, and was signed in February 2009 by Turkcell and the ICTA, which made small additional changes in the articles of the license agreement entitled performance bond and allocated frequency bands, and was signed again in February 2016 with small amendments. The license agreements of Turkcell were last amended in 2019. Terms and Conditions Under the license agreement, we hold a licensed concession to provide telecommunications services in accordance with GSM-PAN European Mobile Telephone System standards in the 900 MHz frequency band. Our license covers 55 channels and allocates telephone numbers between the 530 and 539 area codes in the national numbering plan. Our license also permits us to establish customer service centers, sign contracts with subscribers and market our services to subscribers. Our license was issued with an effective date of April 27, 1998, for an initial term of 25 years until 2023, which was renewed on March 31, 2023 for a further six years until April 30, 2029. We paid a license fee of USD 500 million to the Turkish Treasury upon the effectiveness of our license. On an ongoing basis, we must pay 15% of our gross revenue, defined as of March 2006 to exclude interest charges for late collections from subscribers and indirect taxes such as VAT (which was increased from 18% to 20% effective July 2023), as well as other expenses and the accrued amounts that are recorded for reporting purposes to the Turkish Treasury. Since 2005, we are required to pay 90% of the treasury share to the Turkish Treasury and 10% to the Ministry of Transport and Infrastructure as a universal service fund contribution. Since January 1, 2018, all of our treasury share is paid to the ICTA, which then transfers it to the Turkish Treasury and the Ministry of Transport and Infrastructure as detailed above. The calculation method for the treasury share was later revised as of December 31, 2017 by law numbered 7061 which is published at the Official Gazette on December 5, 2017 and consequently, the following are not be considered in calculation of the treasury share: overdue interests which are accrued to the subscribers for any unpaid balance, accrual amounts for the purpose of reporting, reflecting the installation and maintenance costs of the mobile radio stations to other mobile operators and finally, amounts for the purpose of correction accounting records which occur in the same year due to errors (such as customer information, type of business, amount and price). Furthermore, under the Authorization Regulation, all kinds of share transfers, acquisitions and actions of the operators which are authorized by a Concession Agreement must be communicated to the ICTA, and such share transfers, acquisitions and actions shall be made with the written approval of the ICTA if they result in a change of control component of such operators. The “control component” is defined as “the rights that allow for applying a decisive effect on an enterprise, either separately or jointly, de facto or legally.” Our license subjects us to a number of conditions. It may be revoked in the event that we fail to meet any of these conditions. 90 Table of Contents Coverage Our GSM (2G) license requires that we meet coverage and technical criteria. We had to attain coverage of 50% of the population of Türkiye (living in cities or towns of 10,000 or more inhabitants) within three years of our license’s effective date and at least 90% of the population of Türkiye (living in cities or towns of 10,000 or more inhabitants) within five years of the effective date of our license. This coverage requirement excludes coverage met through national roaming and installation sharing arrangements with other GSM systems and operators. Upon the request of the ICTA, we may also be required, throughout the term of our license, to cover at most twenty areas each year. Except in the event of force majeure, we must pay a late performance penalty of 0.2% of the investment in the related coverage area per day for any delay of more than six months in fulfilling a coverage area obligation. We met and surpassed all coverage obligations before their due dates. Service Offerings Our license requires that we provide services that, in addition to general GSM phone services, include free emergency calls and technical assistance for customers, free call forwarding to police and other public emergency services, receiver-optional short messages, video text access, fax capability, calling and connected number identification and restrictions, call forwarding, call waiting, call hold, multi-party and three-party conference calls, billing information, and the barring of a range of outgoing and incoming calls. Service Quality Generally, we must meet all the technical standards of the GSM Association as determined and updated by the European Telecommunications Standards Institute and Secretariat of the GSM Association. Moreover, we must meet the standards that the ICTA imposes under “Regulation on Quality of Service in the Electronic Communications Sector.” Tariffs The license agreement regulates our ability to determine our tariff for GSM services. The license agreement provides that, after consultation with us and consideration of tariffs applied abroad for similar services, the ICTA sets the initial maximum tariffs (price caps). Thereafter, our license provides that the maximum tariffs shall be adjusted at least every six months. The license agreement provides a formula for adjusting the maximum tariffs. For the adjustment of the maximum tariffs established in Turkish Lira, the formula is: the Turkish Consumer Price Index announced by the Ministry of Commerce minus 3% of the Turkish Consumer Price Index announced by the Ministry of Commerce. For the maximum tariffs established in U.S. Dollars, the same method is applied to the USA Consumer Price All Item Index Numbers. Although we believe the tariff structure in our license will, in most instances, permit adjustments designed to offset devaluations of the Turkish Lira against the U.S. Dollar or inflation, any such devaluation that we are unable to offset will require us to use a larger portion of our revenue to service our non-Turkish Lira foreign currency obligations. Additionally, in the event that the ICTA were to establish maximum tariffs at levels below those that would enable us to adjust our rates to offset devaluations or inflation, this could have a material adverse effect on our business, consolidated financial condition, results of operations and/or liquidity. The maximum tariffs set by the ICTA may constitute the highest rates we may charge for the services included in these customized service packages. Please refer to the Mobile Retail Price Cap section under “Item 5. Operating and Financial Review and Prospects—D. Trend Information—b. Regulations affecting our prices” for the approved price caps for voice and SMS. Relationship with the ICTA The license agreement creates a mechanism for an ongoing relationship between us and the ICTA. The ICTA and Turkcell coordinate their activities through a License Coordination Committee (“the Committee”), which is responsible for ensuring the proper and coordinated operation of the GSM network, assisting in the resolution of disputes under the license agreement and facilitating the exchange of information between the parties. q.License Suspension and Termination The ICTA may suspend our operations for a limited or an unlimited period if necessary for the purpose of public security or national defense, including war and general mobilization. During suspension, the ICTA may operate our business, but we are entitled to any revenues collected during such suspension, and our license term will be extended by the period of any suspension. 91 Table of Contents Our license may be terminated under our license agreement upon a bankruptcy ruling that is not reversed or dismissed within 90 days, upon our failure to perform our obligations under the license agreement if such failure is not remedied within 90 days, if we operate outside the allocated frequency ranges and fail to terminate such operations within 90 days or if we fail to pay our treasury fee. In the event of termination, we must deliver the entire GSM system to the ICTA. If our license is terminated for our failure to perform our obligations under our license, the performance guarantee given by us in an amount equal to 1% of the license fee may be called. The license agreement makes no provision for the payment of consideration to us for delivery of the system on such termination. In the event of a termination of our license, our right to use allocated frequencies and to operate the GSM system ceases. At the end of the initial term in 2023, we applied to the ICTA to extend the GSM license period. Following our application to the ICTA for the extension of our spectrum usage rights in 900 MHz band and our GSM license, ICTA notified Turkcell on March 31, 2023 in writing that it was resolved to extend the term of both within the framework of “Procedures and Principles for Defining the Term Extension Conditions of the GSM Concession Agreements and the GSM 1800 Concession Agreement” until April 30, 2029. Along with the new 5G allocation, Turkcell has obtained renewal rights for its existing authorizations (2G, 3G and 4.5G) from April 1, 2029 to December 31, 2042. Within this scope, during the period between April 30, 2029, and December 31, 2042, each year, 5% of gross sales revenues (excluding VAT) from mobile services will be paid to the ICTA. Under our license agreement, any dispute arising from scope, implementation and termination of the agreement shall be brought before the Committee. If the dispute is not settled within 30 days before the Committee, it shall be referred to the parties. If the dispute is not resolved by the parties within 15 days, then it shall be settled by an arbitral tribunal in accordance with ICC Rules. The governing law of any arbitration is Turkish law and any such arbitration shall be conducted in English. Disputes relating to national security or public policy shall not be subject to arbitration proceedings. Additionally, the Law No. 7061 dated November 28, 2017, has introduced the settlement mechanism set forth in a provision of the Tax Procedural Law No. 213 for the disputes in relation to the payment of the treasury share. r.Authorization of 3G License In 2008, the ICTA conducted a tender process to grant four separate licenses to provide IMT 2000/UMTS services and infrastructure. We were granted the A-type license, which provides the widest frequency band, at a consideration of EUR 358 million (excluding VAT). We signed the license agreement relating to 3G authorization on April 30, 2009 and then the agreement was renewed and resigned in February 2016 with minor amendments which do not change the core of the service. The license agreement has a term of 20 years, until April 2029. The 3G License Agreement has provisions that are generally similar to those contained in our license agreement relating to 2G. However, with respect to dispute resolution, while our 2G license provides for arbitration for the settlement of disputes, under the 3G License Agreement, disputes arising between the parties shall ultimately be settled by the Council of State of the Republic of Türkiye. With the 3G License Agreement, as opposed to the 2G License Agreement, the Company assumed an obligation related to its electronic communications network investments, such as the obligation to obtain at least 40% of its electronic communications investments from suppliers that have a research and development center in Türkiye and the obligation to obtain at least 10% of its electronic communications investments from suppliers that are small and medium sized enterprises established in Türkiye. According to the Authorization Regulation, breaches by operators resulting in the termination of the GSM concession agreement for any reason shall also result in the termination of the operator’s concession agreement signed for IMT-2000/UMTS service. Also, if the GSM concession agreement is not renewed at the end of its natural expiration, the ICTA may continue to allow the utilization of the needed infrastructure by IMT-2000/UMTS services on terms and conditions to be set by the ICTA itself. 92 Table of Contents The statutes, rules and regulations applicable to our activities and our 2G and 3G licenses are generally subject to change, in some cases, incomplete, and have been subject to limited governmental interpretation. Precedents for and experience with business and telecommunications regulations in Türkiye are generally limited. In addition, there have been several changes to the relevant legal regime in recent years. There can be no assurance that the law or legal system will not change further, or be interpreted in a manner that could materially and adversely affect our operations. s.IMT (4.5G) Authorization In the IMT tender held on August 26, 2015 to grant spectrum usage for 800 MHz, 900 MHz, 1800 MHz, 2100 MHz (FDD, TDD) and 2600 MHz (FDD, TDD), the Company purchased a total of 172.4 MHz, the broadest 4.5G spectrum allocation of any operator in Türkiye (including widest frequency bands on 1800 MHz, 2100 MHz and 2600 MHz) for EUR 1,623.5 million (excluding VAT and interest payable on the installments). The tender gave equal opportunity to the operators in the low frequency bands utilized for coverage while enabling competition in higher frequency bands mainly used for capacity. The Company has reached a total frequency bandwidth of 234.4 MHz and our ownership in total bandwidth in the market increased to 43% (234.4 MHz / 549.2 MHz) with the new frequencies acquired. The operators can utilize the new spectrum in a technology-neutral way. The ICTA granted Turkcell’s IMT Authorization on October 27, 2015. The IMT Authorization is effective for 13 years until April 30, 2029. According to the license, Turkcell started to provide 4.5G services from April 1, 2016. The IMT Authorization License Agreement has provisions that are generally similar to those contained in our license agreement relating to 2G and 3G. Accordingly, the Company: (a) must achieve population coverage of 95% of the population of Türkiye and coverage of 90% of the population within 81 provinces and 973 sub provinces within eight years, (b) must cover 99% of motorways, high speed railroads and tunnels with lengths more than one kilometer within three years, 95% of divided multilane roadways within six years and 90% of conventional railroads within ten years, and (c) is obliged to share actively with other mobile operators, any new 3G or 4.5G site which it will decide to build within settlement areas with a population of less than 10,000 and highways, divided multilane roadways, tunnels, high speed railroads and conventional railroads, from the effective date of the license granted to the Company. We have not always been, and in the future may not be, in full compliance with the coverage obligations under our licenses, most recently with respect to 3G settlement coverage and coverage of tunnels in 4.5G. Due to past non-compliance, the ICTA imposed administrative fines on our Company in 2022 and required us to establish a total of 400 3G sites. We complied with this requirement, establishing 200 3G sites in 2023 and another 200 3G sites in 2024. We were also required to install a sufficient number of 4.5G sites in tunnels that were not in compliance, which increased our investment costs. 93 Table of Contents In addition, when building its infrastructure for 4.5G networks, Turkcell and its competitors are required to purchase up to 45% of its network related hardware (i.e. base stations, switches, routers and as such) and software from local suppliers, and purchase 10% of the network equipment and software from local SMEs engaged in production in Türkiye. The local network related hardware purchase requirement is defined over three periods: 30% for the first year, 40% for the second year and 45% for the third and subsequent years, as well as 30% for the average of the first four-year period (2015-2019), 40% for the average of the second four-year periods (2019-2023) and 45% for the average of the third (2023-2027) and subsequent four-year periods. Reporting on these requirements must be made to the ICTA on a yearly basis. If the Company expects not to meet the requirement for locally produced hardware and software due to the lack of sufficient local supply and other relevant conditions, the Company must file an application to the ICTA six months before the due date to request an easing or removal of the requirement. In accordance with the regulation, operators have requested the removal of this requirement for eight annual reporting periods, between 2015 and 2023, and the average of the first two four-year period containing 2015-2019 and 2020-2023 (the Company has fulfilled 45% of its purchase obligations for the period 2022, 2023, 2024 and the average of the second four-year periods between 2019-2023). However, operators’ requests to waive this requirement for the reporting periods between 2015-2021 and the average of the first four-year period have been rejected by the ICTA; in this context, administrative fines, amounting to TRY 95.5 million in total (not restated for IAS 29) were applied to the Company for three periods between 2015 and 2018. Some of the lawsuits relating to the cancellation of these administrative fines are ongoing. Although, we are challenging the imposition of these fines, we may not be successful. Additionally, administrative fines may also be applied for not meeting the requirements of 2018-2021 reporting periods and the average of the first four-year reporting periods. This also may result in material adverse effects on our financial results. In addition to the above mentioned obligations, in the context of the 4.5G license, the Company assumed the obligation to obtain at least 40% of its electronic communications investments from suppliers with a research and development center in Türkiye, as well as the obligation to obtain at least 10% of its electronic communications investments from small and medium sized enterprises suppliers that are established in Türkiye and manufacture local products. Furthermore, with the ICTA Board Decision dated November 16, 2021 and published on January 13, 2022, the ICTA amended the Procedures and Principles Regarding the Inspection and Supervision of “Investments Regarding Hardware and Software to be Used in Mobile Operators’ Networks” in a way to expand the local product obligations in the 4.5G authorization agreement. The amended regulation requires the share of equipment purchased from a single supplier within an investment period not to exceed 50% of total investments and the operators must inform the ICTA and comply with the Board decisions before the investments to be made relating to critical network elements. Breaches of the abovementioned obligations and breaches resulting in the termination of the GSM and IMT-2000/UMTS concession agreements for any reason shall also result in the termination of the operator’s 4.5G authorization. t.IMT-2020 (5G) Authorization The tender entitled “Authorization for the Establishment and Operation of Mobile Electronic Communications Infrastructures and the Provision of Services, and the Inclusion under this Authorization of the Infrastructure and Services Covered by the Existing Authorizations Expiring on April 30, 2029” was conducted on October 16, 2025. As part of this tender, a frequency allocation of 2x10 MHz was designated for each operator in the 700 MHz frequency band, and 80 MHz was designated for each operator in the 3.5 GHz frequency band. In the subsequent phase of the tender process, five packages of 20 MHz each in the 3.5 GHz frequency band were offered for auction, and operators were permitted to acquire up to a maximum of three such packages. As a result of the tender, Turkcell: ● Was awarded the right to acquire a 2x10 MHz frequency package in the 700 MHz band for a total price of USD 429,000,000 (excluding VAT), and was granted the first “Right of Selection” pursuant to which it selected the end of the relevant frequency band; and ● Acquired, frequency packages totaling 140 MHz in the 3.5 GHz frequency band for a total price of USD 795,000,000 (excluding VAT), thereby becoming the operator with the highest capacity in this band. In addition, by acquiring the first package in this frequency band, Turkcell was granted the first “Right of Selection” in respect thereof and selected the end of the relevant frequency band. 94 Table of Contents Furthermore, this tender regulates the inclusion of previous authorizations ending on April 30, 2029 under the new 5G authorization framework. The total tender price amounted to USD 1,224 million (excluding VAT). Turkcell elected to settle the principle amount in three equal installments of USD 408 million each. The entire VAT amount was paid with the first installment. Accordingly, the first payment of USD 652.8 million (consisting of the first installment plus the total VAT) was made on January 2, 2026. The second and third installments of USD 408 million each will be paid no later than December 25, 2026 and May 2, 2027, respectively. Under this authorization, the following additional coverage obligations were imposed: (a) Upon request by the Authority, Turkcell is required to provide priority coverage to a maximum of 150 settlements or locations per year. Of these locations, no more than 50 may be selected from settlements with a population of fewer than 200. (b) By January 1, 2028, excluding the locations covered under the Universal Service legislation, Turkcell is required to provide mobile electronic communications services in such a manner as to ensure coverage for at least 95% of the population in each neighborhood or village with a population of 500 or more, assessed separately for each settlement. (c) Without prejudice to maintaining the existing coverage area and service quality in the locations where services are currently provided, and for the period from April 30, 2029 until the expiry date of this authorization, December 31, 2042: · Separately for each metropolitan municipality, Turkcell is required to provide coverage to 95% of the population within the boundaries of the metropolitan municipality and all affiliated districts within three years, and, for metropolitan central districts, to ensure a minimum downlink data rate of at least 25 Mbit/s per user with a probability of 95%; · Separately for each of all other provinces and districts, Turkcell is required to provide coverage to 95% of the population within the boundaries of the relevant province and district within five years, and, for provinces and districts, to ensure a minimum downlink data rate of at least 15 Mbit/s per user with a probability of 95%; and · Excluding the locations covered under the Universal Service legislation, Turkcell is required to provide services in each neighborhood and village with a population exceeding 500, separately for each settlement, in a manner ensuring coverage of at least 95% of the population of the relevant settlement. While building infrastructure for 5G networks, Turkcell and its competitors are required to procure network related hardware (i.e. base stations, switches, routers and as such) and software as follows: · At least 40% must be procured from suppliers having an R&D Center in Türkiye that employs a certain number of researchers. · Operators are required to make investments related to 5G services and infrastructure from local manufacturers’ products at a rate of 50% in the first year, 55% in the second year, and 60% in the third year and subsequent years. As of April 30, 2029, which is the expiration date of the existing authorizations, at least 60% of all service and infrastructure procurements within the scope of authorization shall be made from local manufacturers. In addition, operators are required to procure at least 15% of their annual investments from local SMEs engaged in production in Türkiye. · Investments must be procured from products that comply with the definition of a National Communication Product at a rate of 5% in the first year, 10% in the second year, and 15% in the third year and subsequent years. Depending on the market availability of products that meet the definition of a National Communication Product, the ICTA may increase the applicable ratios by up to two times. Operators must also take measures to procure the equipment to be used for establishing Mobile Private Networks from National Communications Products. 95 Table of Contents · All independent software and hardware units to be used in an operator’s network must be interconnected with one another through open interfaces, in compliance with international standards and, where technically feasible, with standards such as Open Radio Access Network. Operators that fail to fulfill their obligations regarding the procurement of National Communication Products are required to transfer an amount corresponding to the investment value of the products not procured or not able to be procured under the obligation into an account (fund) to be established within their own organization for the relevant period. u.Licenses and Authorizations of our Subsidiaries In addition to the foregoing, our subsidiaries BeST and Kıbrıs Telekom hold GSM licenses in Belarus and the Turkish Republic of Northern Cyprus, respectively, and all of them have obtained 3G licenses. Kıbrıs Telekom has also obtained 4G and 5G licenses and Internet Services Provider and infrastructure establishment and operation licenses. If BeST and Kıbrıs Telekom fail to comply with the terms and conditions of their license agreements, they may incur significant penalties, which could have a material adverse effect on our strategy for international expansion and our business and results of operations. In addition, our subsidiaries Global Tower, Turkcell Superonline, Turkcell Enerji, Paycell, Financell, Lifecell Digital, Lifecell Müzik Yayın ve İletim A.Ş. (“Lifecell Müzik”) and Lifecell TV Yayın ve İçerik Hizmetleri A.Ş. (“Lifecell TV”) have licenses to perform their business. Failure to comply with the terms of such licenses may lead to significant penalties and adversely affect their, as well as our, results of operations. i.Belarus License Agreement BeST owns a license for mobile services without technological limitations (mobile technology neutral), issued on August 28, 2008, for a period of 10 years. However, in accordance with the Edict of the President of Belarus dated November 26, 2015, numbered 475, the license is issued without limitation of the period of validity. Starting from March 1, 2016, the license is valid from the date of the licensing authority’s decision on its issue and for an unlimited period. Under the terms of its license, BeST has coverage requirements for 2G and 3G networks. BeST had been provided with additional time by the license authority to fulfill all 2G signal coverage requirements regarding the settlements. Management of the company keeps working with the regulatory body regarding 2G license requirements and has applied for certain license requirement adjustments. We expect to have some regulatory changes in 2G mobile networks operations and those changes may eliminate coverage requirements in 2G network in the upcoming years. 3G related license requirements have been fulfilled. Pursuant to applicable legislation of the Republic of Belarus the construction and operation of LTE, LTE-Advanced, and IMT-2020 technology telecommunications infrastructure may be carried out exclusively by LLC “beCloud” in its capacity as the Single Infrastructure Operator. BeST provides 4G and 5G mobile telecommunication services to its subscribers through the use of beCloud’s infrastructure. ii.Turkcell Superonline Authorizations Turkcell Superonline was authorized as a Fixed Telephony Service Provider as of November 19, 2004 (for 15 years), Infrastructure Provider as of March 6, 2006 (for 25 years), Internet Service Provider as of February 15, 2005 (no duration specified), Satellite Communication Service Provider as of March 24, 2009 (no duration specified), Cable Broadcast Service Provider as of November 23, 2009 (no duration specified) and Mobile Virtual Network Operator as of July 14, 2015 (for 15 years). Upon the expiry of the term of Turkcell Superonline’s Fixed Telephony Service Provider authorization on November 19, 2020 the ICTA extended the authorization period by one year. Pursuant to the amendment to the Authorization Regulation on May 1, 2021, the validity periods of all the authorizations granted to operators were extended to match the expiry date of the longest-term authorization of the operator. Thus, the expiry date for all the authorizations of Turkcell Superonline has been determined as March 6, 2031. 96 Table of Contents Turkcell Superonline was authorized as a Platform Operator and Infrastructure Operator in accordance with the Radio and Television Supreme Council’s (“RTUK”) decision numbered 24, dated March 26, 2014. Such authorizations have been provided by the RTUK, according to the rules of the Media Law and also the RTUK By-Law on Broadcasting via Cable Networks. In accordance with the Media Law and its regulations, the Platform Operator Authorization and Infrastructure Operator Authorization are provided annually. Within the scope of the Platform Operator Authorization and Infrastructure Operator Authorization, Turkcell Superonline has the right to operate the platform and infrastructure of TV services. Pursuant to the same amendment, it was stipulated that companies that do not provide services related to their authorizations within three years from the date they are granted will have their authorizations revoked. In this regard, there is a risk that Turkcell Superonline’s authorization for the Platform Operator and Infrastructure Operator could be revoked. v.Access and Interconnection Regulation The Access and Interconnection Regulation became effective upon issue by the ICTA on September 8, 2009, and abolished the Access and Interconnection Regulation which was published on May 23, 2003. The Regulation sets forth the rights and obligations of the operators relating to access and interconnection, and establishes rules and procedures pertaining to their performance of such obligations. The Regulation primarily sets forth applicable principles, details of access and interconnection obligations, financial provisions, and policies and procedures regarding negotiations and contracts for access and interconnection. The Regulation is driven largely by the goal of improving the competitive environment and ensuring that users benefit from electronic communications services and infrastructure at a reasonable cost. Under the Electronic Communications Law, the ICTA may compel a telecommunications operator to accept another operator’s request for access to and use of its network. All telecommunications operators in Türkiye may be required to provide access to other operators. The operators who are compelled to provide access to other operators may be obliged to provide service and information on the same terms and qualifications provided to their shareholders, subsidiaries, and affiliates by the ICTA. In accordance with Article 7 of the Electronic Communications Law, the ICTA may determine those operators that have significant market power in the relevant market as a result of market analysis. After determination of the operators of SMP, the ICTA may impose additional liabilities for such operators in order to protect the competitive environment. In January 1, 2020, the “Mobile Access and Call Origination Market” was deregulated and Turkcell’s SMP designation was removed. Turkcell Superonline was designated by ICTA as having SMP in the nationwide wholesale dedicated capacity transport and termination markets under ICTA’s November 2025 “Wholesale and Retail Dedicated Capacity Markets” market analysis document. Turkcell Superonline is subject to regulatory obligations such as access, non-discrimination, transparency, publication of reference access offers, cost-oriented tariff control, accounting separation and cost accounting and facility sharing. These remedies can materially constrain Turkcell Superonline’s commercial and operational flexibility (including the ability to design products, set prices, negotiate terms and manage capacity), and may require significant compliance investments (e.g., implementing regulated wholesale processes, KPI/SLAs, internal controls, cost accounting models, reporting, auditability and dispute-handling capabilities). On December 15, 2005, the ICTA designated Turkcell, Vodafone, and TT Mobil as “operators holding significant market power” in the “GSM Mobile Call Termination Services Market,” and in subsequent years, based on market analysis decisions, the ICTA continued to designate three operators as holding significant market power in the “Mobile Call Termination Market.” On August 29, 2023 in relation to the “Mobile Call Termination Market Analysis” published in 2020, the ICTA decided to extend the validity period of the current market analysis for an additional three years, as evaluations indicated no significant changes in the relevant market conditions. As a result of the significant market power designation in the “Mobile Call Termination Market,” Turkcell, as well as TT Mobile and Vodafone, are required to provide interconnection services. Following the last Mobile Call Termination Market Analysis, dated September 23, 2020, the ICTA decided to remove the cost-based pricing obligation for SMS/MMS termination services. The latest ICTA decision regarding SMS termination rates (on mobile networks), dated December 14, 2021, updated, equalized and gradually increased SMS Termination Rates as of April 1, 2022 until January 1, 2024. 97 Table of Contents Since January 1, 2024, SMS termination rates have been determined commercially between the parties. If an agreement cannot be reached regarding such rates, operators can apply to the ICTA to request a reconciliation procedure. Commercial agreement procedures remain ongoing. As the commercial negotiations conducted by the operators had remained inconclusive, the ICTA has determined SMS termination unit rates for the past three years as a result of reconciliation procedure. However, bilateral commercial negotiations were conducted successfully between operators for 2025 and 2026, and the SMS interconnection rate for 2025 was set at TRY 2.6 kr/SMS and for 2026 was set at 3.2 kr/SMS. MMS termination rates have been determined commercially since 2022. Please refer to the table under Interconnection Rates/Mobile Termination Rates section, under “Item 5. Operating and Financial Review and Prospects—D. Trend Information—b. Regulations affecting our prices” for the approved MTRs. Consequently, according to the Electronic Telecommunications Law, the ICTA may oblige such operators to provide access and to submit their reference offers for interconnection to the ICTA for review, and may require amendments to the offers. Operators are obliged to make the amendments requested by the ICTA in a prescribed manner and within a prescribed period. In addition, the operators are obliged to publish their reference offers for interconnection, which have been approved by the ICTA, and provide access under the conditions specified in their reference offers and interconnection, which have been approved by the ICTA. The ICTA regulates FTRs as well, and designated Türk Telekom as having significant market power. As a result of the market analysis regarding Fixed Call Termination Market in December 2020, the ICTA decided to switch to IP-based next-generation network structure (from traditional Time-Division Multiplexing network) in interconnection services, thus adopted a single-stage fee structure and temporarily determined Türk Telekom’s IP interconnection rate as 1.71 kr/min until January 1, 2022. Subsequently, the ICTA has published a glide path for call termination rates for all fixed operators for the years 2022-2024, where the interconnetion rate is unchanged. Please refer to the table under Interconnection Rates/Fixed Call Termination Rates section, under “Item 5. Operating and Financial Review and Prospects—D. Trend Information—b. Regulations affecting our prices” for the approved termination rates. As of 2026, interconnection fees have been fixed at TRY 1.47 for all fixed operators. Our Company’s Access and Interconnection Agreements Concluded with Other Operators Turkcell and Turkcell Superonline have interconnection agreements with various operators including Türk Telekom, Vodafone, TT Mobil and Fixed Telephony Service Operators whereby they allow us to connect our networks with theirs to enable the transmission of calls to and from our mobile/fixed communications systems. The interconnection agreements establish understandings between the parties relating to various key operational areas, including call traffic management, and the agreements entail that we and the other parties will agree on the contents of various manuals setting forth additional specifications concerning matters that are not specifically covered in the interconnection agreement, such as quality and performance standards and other technical, operational and procedural aspects of interconnection. The interconnection agreements specify that the parties shall comply with relevant international standards, including standards adopted by the GSM Memorandum of Understanding, the Telecommunications Standards Bureau of the International Telecommunications Union, and the European Telecommunications Standards Institute. In the absence of applicable international standards, the interconnection agreements provide that the parties will establish written standards to govern their relationship. The interconnection agreements outline the applicable interconnection principles and provide the technical basis and rationale for technical specifications and manuals to be agreed to by the parties. In addition, the parties agree to provide the other party with information that is necessary to enable the performance of their interconnection obligations, the provision of services, or the utilization of equipment and/or buildings as contemplated in the interconnection agreement. i.Interconnection/Call Termination Agreements Please refer to the tables under Interconnection/Mobile Call Termination Rates and Fixed Call Termination Rates section under “Item 5. Operating and Financial Review and Prospects—D. Trend Information—b. Regulations affecting our prices” for the effective termination rates in interconnection agreements. 98 Table of Contents ii.International Transit Traffic Services Agreements Turkcell entered into International Transit Traffic Services Agreements with operators who applied to Turkcell for an agreement. Under these agreements, we may carry calls to these operators’ switches for onward transmission to their destinations and these operators should provide the termination of these calls on the relevant network. These operators charge us at various prices identified within the scope of the agreement for calls directed to numerous networks around the globe. iii.SMS Termination Agreements During 2011, Turkcell entered into SMS Termination Agreements with alternative operators who applied to Turkcell for an agreement. Please refer to the table under SMS/MMS Termination Rates section, under “Item 5. Operating and Financial Review and Prospects—D. Trend Information—b. Regulations affecting our prices” for the effective rates in SMS termination agreements. As of December 31, 2021, operators which originate message services are obliged to establish direct interconnection with mobile network operators where the calls will be terminated in accordance with the ICTA Board Decision dated March 24, 2020. iv.MVNO Agreement A full MVNO agreement was signed between Turkcell and Netgsm, a local telecommunications company, on November 5, 2020. If neither party submits a request for termination at least three months before the expiration date, the agreement is automatically renewed for an additional one-year term under the same terms and conditions. The scope of the agreement is wholesale mobile communication services including data, voice and SMS. Wholesale data rates were determined by the ICTA as a result of the conciliation process carried out between the parties and were added to the contract. Netgsm has been offering consumer and enterprise mobile bundle tariffs in the local market. On August 2, 2024, Turkcell issued a notice to terminate NetGSM’s MVNO services and ceased providing access services on November 5, 2024, except for the SIM Cards already active in Turkcell’s network prior to such date. To minimize the disruption and allow a grace period, Turkcell intended to maintain connectivity for those existing NetGSM SIM Cards during the following months based on fees determined by the ICTA. During the discussions, ICTA issued a decision requiring Turkcell to continue providing services to NetGSM until the resolution of the reconciliation process. ICTA subsequently issued another decision setting the mobile data access fees for 2024 and 2025, and later required Turkcell to continue providing services to NetGSM for both existing and new subscribers. Turkcell has filed three lawsuits seeking the annulment of these decisions while continuing to provide service to the lines active prior to November 5, 2024. The legal process is ongoing at the appeal stage. As a result of the ICTA’s investigation into this matter, Turkcell was fined 50 million TL (not restated as IAS 29) for not providing Virtual Mobile Network Services to subscribers who were newly activated by NetGSM or who migrated to NetGSM via number portability. Turkcell filed a lawsuit against this administrative fine decision. v.Agreements Concluded with Directory Service Providers Turkcell entered into agreements relating to the provision of directory services which are licensed by the ICTA to provide directory services. These agreements determine the principles and procedures related to the access of companies to the Turkcell database, the provision of directory services to subscribers and the clearing procedure of the parties. Such agreements are valid and binding for a term of one year. However, if neither party notifies the other party one month before the expiration of the agreement of its request to terminate, the agreement will automatically be renewed for another one-year term. w.Regulation on Co-Location and Facility Sharing The ICTA has required operators to share certain facilities with other operators under certain conditions specified in the Electronic Communications Law and to provide co-location on their premises for the equipment of other operators at a reasonable price. Under the Regulation, operators holding significant market power are required to provide access and services to all operators on equal terms. Operators with significant market power are also required to perform unbundling of their services, which means that they have to provide separate service of, and access to, transmission, switching, and operation interfaces. Furthermore, the ICTA may establish rules applicable to the division of the costs of facilities among parties. 99 Table of Contents The ICTA published a Communiqué concerning “Co-Location and Facility Sharing” on December 2, 2010 (which abolished the Regulation published on December 31, 2003). According to the Communiqué, the ICTA should determine operators to be co-location incumbent if operators do not enable co-location, or where is a dispute against competition, or end-users. Similarly, the ICTA may set tariffs if the tariffs for co-layout are not determined on a cost basis. The Communiqué defines the criteria for operators who are incumbents for facility sharing, and also states the items which must be considered for determining the Facility Sharing prices. Subsequently, the provisions that regulate the ICTA approval of the examination fee determined by the Co-Location and Facility Sharing incumbent have been removed, opening up the Co-Location and Facility Sharing process to negotiation. In addition, the Facility Sharing incumbent’s right to allocate a facility for its own network and investment plans has been reduced to 25% of the facility. On December 6, 2016, the ICTA published “The Regulation on the Procedures and Principles of Sharing of Cellular System Antenna Installations and Radio Access Networks.” According to this Regulation: ● The number of sharing types has increased. The terms and conditions of sharing on highways, railways and within tunnels is now a separate section. ● In regions where the population is lower than 10,000, if an operator is unable to use the antenna installations built by another operator before the IMT licensing, the operator must notify the ICTA about the situation and the ICTA may let the operator build a new antenna installation. This operator is obliged to make an installation facilitating the sharing by all types with at least two other operators. The operator cannot turn down any sharing requests involving installations set up after IMT licensing in motorways, high speed and very high-speed railways, dual carriage highways, tunnels and conventional railways, except for indoor installations. ● In regions where the population is higher than 10,000 at the time of application to ICTA to build a new installation, provided that there are no physical, technical, administrative and legal barriers, the operator is obliged to offer the types of sharing to the maximum extent possible. ● In regions where the population is lower than 10,000, except indoor installations, new antenna installations which were established between the date of the IMT authorization and the issue date of this regulation, all settlements and motorways, high speed and very high-speed railways, dual carriage highways, tunnels and conventional railways must be brought in line with the conditions set by this Regulation. In the 4.5G authorization document, in provinces with a population of less than ten thousand and at sites to cover highways, dual carriageways and railroads, any new 3G or 4.5G site to be built must be shared actively by all operators within this region. We informed the ICTA that we support any local R&D and P&D, as long as it complies with international technical and financial standards and can be sustainable. However, the 4.5G authorization document does not provide details on compliance with international standards. The ICTA may oblige operators to buy and use locally produced products, independent of quality standards, if a local vendor produces sufficient equipment to support the mobile operators’ demands. This may cause technical problems in our network. Should such technical problems occur, it could negatively affect our quality of service, leading to increased costs for the 4.5G infrastructure roll-out and could adversely affect our customer experience. See “Item 3. Key Information—D. Risk Factors—Risks Relating to the Telecom Industry—The obligations and costs of our license agreements may limit, in some cases, our flexibility in responding to market conditions, competition and changes in our cost structure, impact our prices or result in penalties in the event of non-compliance.” 100 Table of Contents Infrastructure providers are subject to “Directive of Deployment of any Cable and Similars Used in Fixed and Mobile Telecommunication Infrastructures or Networks” which was published in the Official Gazette dated December 27, 2012. As per this regulation; all fixed infrastructure providers must prioritize facility sharing and co-location in their investments which mandates operators to check if there is any available infrastructure exists or not for the planned route. If it is determined that there is another operator’s infrastructure on the planned route, the use of this infrastructure should be prioritized, if possible. Our fiber business must excavate to lay new cables and repair existing cables, and there is an obligation to obtain permission for excavations from authorized municipalities or institutions. Since June 2018 operators primarily have to request from the most prevailing operator in terms of infrastructure in Türkiye—Türk Telekom—to seek if Türk Telekom’s infrastructure is available to share for the operator-requested route and to perform the needed excavation work on their behalf (Türk Telekom’s reference offer public consultation process for facility sharing is still ongoing, there is no existing agreed commercial offer for Türk Telekom’s infrastructure excavation work on behalf of operators). After Türk Telekom’s rejection of infrastructure sharing, operators may ask for the right of way confirmation from the Ministry of Transport and Infrastructure. Having the right of way confirmation, operators shall apply to the public authorities to get permission for the required excavation work. x.Regulation on Consumer Rights in the Electronic Communications Sector One of the main duties of the ICTA is the protection of consumers, thus the ICTA extensively regulates topics related to consumers including subscription processes, charging and billing, contract conditions including the term of contract and the information to be provided to consumers. As such, the ICTA carries out numerous inspections in order to assess compliance levels to said regulations and non-compliant operators may face severe administrative fines. Conversely, our compliance with the ICTA’s regulations may increase the costs of doing business and could negatively impact our financial results. The most recent framework for consumer protection is provided by the “Regulation on Consumer Rights in the Electronic Communications Sector,” which was published on October 28, 2017. This regulation abolishes other predating regulations on consumer protection. The Regulation imposes numerous obligations on operators with respect to transparency and informing consumers, the subscription process and the provision of services, tariffs and campaigns, contracts, charging and billing and the cancellation of subscriptions. An amendment to the Regulation was made on January 18, 2022, seeking to align the regulation with “The Regulation on the Applicant’s Identity Verification Process in the Electronic Communications Sector” and to impose new obligations on operators, including increasing the number of channels through which subscribers can apply to cancel their subscriptions and granting subscribers the right to cancel their subscriptions without paying a cancellation fee if the internet service quality does not meet the “Address-Based Internet Speed Test Criteria” (“Criteria”) – that will be determined by the ICTA when the regulation regarding the standards of Fixed Internet Service Quality is finalized. The effective date of the articles related to applicants’ identity verification processes was March 1, 2022, while the effective date of the other articles was December 31, 2022. “The Regulation on the Verification Process of the Applicant’s Identity in the Electronic Communications Sector” was first published on the Official Gazette of June 26, 2021 and later amended on December 31, 2021. The Regulation determines the process to be applied for the verification of the applicant’s identity in cases where subscriber transactions (subscription contract, number porting application, qualified electronic certificate application, registered e-mail application and SIM change) are carried out in an electronic medium. The ICTA is expected to issue mandatory amendments to the Regulation on Consumer Rights in the Electronic Communications Sector and the Regulation on the Identity Verification Process of the Applicant in the Electronic Communication Sector in accordance with the amendments to the Electronic Communications Law published in the Official Gazette dated December 25, 2025. Preventing bill shock has been one of the ICTA’s objectives, resulting in several regulations that impose obligations on the operator to offer upper limits to bills and to remind and inform the subscriber on their levels of use. “The Procedures and Principles Regarding the Services with Limited Amount of Use and the Applications of Upper Limits of Bills” was published on August 19, 2016 and has been in force since 2017. The ICTA has duties to ensure the safe use of Internet as well. The ICTA’s board decision dated August 22, 2011 obliged operators to offer the “Safe Internet Service” to requesting subscribers free of charge. The ICTA Decision dated June 8, 2021 mandated the “Safe Internet Service Family Profile,” which can restrict subscribers from accessing certain internet addresses and content, to be the default profile for new mobile and fixed subscriptions, unless otherwise requested by the subscriber. 101 Table of Contents The ICTA decision dated June 21, 2018 favoring subscribers with special needs, veterans, and widows/widowers and orphans of martyrs was published and came into effect on January 1, 2019. The decision requires operators that have more than 200 thousand subscribers to offer their services to these groups that are “in need of social support” at a 25% discount. The discount is to be offered upon proof of identity and the subscriber’s special need. By means of a Board Decision the ICTA decided that, effective from March 3, 2023, the number of postpaid and prepaid individual lines should be limited to 15 per each Turkish citizen and three per each foreigner, while the number of “Prepaid and Postpaid Individual Lines” that can be provided to each person in the same month in total, by an authorized retailer should be limited to four. y.Regulation on Data Privacy in the Electronic Communications Sector Under Article 51 of the Electronic Communications Law, the ICTA is authorized to determine the principles and procedures related to the processing of personal data and protection of privacy. Accordingly, the ICTA published “Regulation Concerning the Processing of Personal Data and the Protection of Privacy in the Electronic Communications Sector,” of which a revised version came into force on June 4, 2021. This regulation aims to determine the procedures and principles of personal data processing and the protection of privacy in the electronic communications sector. The regulation sets out the sector-specific rules such as security measures, notification of data breach and data breach risks, obtaining explicit consent, data transfers, traffic and location data, caller ID blocking. z.Law on the Protection of Personal Data Türkiye, as part of its legislative reforms to align with the EU legislation has adopted an extensive data protection regime. The Law on the Protection of Personal Data (the “Law”), which came into force on April 7, 2016, regulates the processing and transfer of personal data of natural persons and the protection of privacy. The Law establishes several obligations for processing and transferring personal data including but not limited to fair and lawful processing, protection of personal data, obtaining consent, providing notice of processing, registration with the Registry of Data Controllers and notification to the Data Protection Authority (“DPA”) in the event of a data breach. According to the Law, the DPA is authorized to impose sanctions and precautionary measures as well as administrative fines which are specified in the Law. The Law also determines the rights of the data subjects, such as the right to apply to the data controller to learn whether their personal data has been processed, to learn whether it is being used in accordance with the purpose of the processing, to learn the third parties to whom the personal data is transferred in Türkiye or abroad, to request the rectification, erasure or destruction of personal data, and to request notification of such actions to third parties to whom the data has been disclosed. As per Article 16 of the Law, the By-Law on the Data Controllers Registry, which specifies the procedures and principles regarding the registration of Data Controllers was published on December 30, 2017 and came into force on January 1, 2018. Pursuant to this regulation, data controllers are obliged to register with the registry prior to processing personal data, and exemptions from the registration requirement are to be determined by the Data Protection Board. Accordingly, the Company registered with the registry within the set deadline by the Data Protection Board. Data controllers that are not established in Türkiye also have the responsibility to register with the Registry via their representative that they will assign and data controllers are obliged to prepare a personal data processing inventory that includes the purposes for processing of personal data, data categories, data subjects, the maximum retention period of the data and technical and organizational measures taken regarding data security. In addition to the aforementioned by-law, on October 28, 2017, the Regulation Regarding the Deletion, Destruction and the Anonymization of Personal Data was published and came into force on January 1, 2018. The objective of the Regulation is to set forth procedures and principles regarding the deletion, destruction or anonymization of personal data processed wholly or partly by automated means or by non-automated means which form part of a data filing system. Furthermore, the Communiqué on the Principles and Procedures to be Followed in Fulfillment of the Obligation to Inform and the Communiqué on the Principles and Procedures for the Request to the Data Controller was published and came into force on March 10, 2018 regulating principles and procedures in relation to the obligation to provide notice to data subjects and rules and processes for data subjects to exercise their rights regarding personal data. With respect to international data transfers, the DPA has not yet published the list of countries that have an adequate level of protection to date. 102 Table of Contents Failure to comply with the Law may result in the imposition of administrative sanctions, including fines of up to TRY 17.1 million by DPA as of January 2026. The Company is implementing a compliance program addressing requirements arising from the Law and its secondary legislation, as well as the General Data Protection Regulation (“GDPR”). The GDPR applies to several products and services of our Company provided to data subjects in the European Union. Under the GDPR, certain data controllers are required to appoint a Data Protection Officer (“DPO”). While Turkish data protection legislation does not mandate such an appointment, the Company proactively designated a data protection lead in 2022 to oversee its data privacy framework and ensure the continued efficacy of its data management practices. This designation, maintained on a voluntary basis, reflects the Company’s commitment to aligning its internal governance with international best practices and enhancing its focused approach to global data protection standards. The Law No. 7499 on Amendment of the Code of Criminal Procedure and Certain Laws, which includes critical amendments to the Law on the Protection of Personal Data, was published in the Official Gazette on March 12, 2024. Significant changes regarding the processing of sensitive personal data, cross-border transfers of personal data, administrative sanctions, and legal remedies against administrative fines took effect on June 1, 2024. This amendment introduced new revisions for cross-border transfers of personal data to align with the GDPR (“General Data Protection Regulation”) that became applicable after September 1, 2024, where explicit consent is not mandatory. According to this new system, if there is an adequacy decision taken by the DPA, cross-border transfers of personal data are possible without explicit consent. If there is no adequacy decision, cross-border transfers of personal data without explicit consent are possible if appropriate safeguards are provided. If there is no adequacy decision or appropriate safeguards, cross-border transfer of personal data may still be possible without explicit consent in some special cases. Details on the subject were described in the Guide on Cross-Border Transfer of Personal Data published by the DPA on January 2, 2025. Additionally, the DPA issued standard contract templates to be signed between the parties for cross-border data transfers on July 10, 2024. aa.Regulation on Electronic Commerce Law No. 6563 on the Regulation of Electronic Commerce published in the Official Gazette on November 5, 2014, amended Article 50 of the Electronic Communications Law, providing that without the prior consent of the subscribers, unsolicited electronic communications for the purposes of direct marketing or messages with adult content is prohibited. An “opt-in” mechanism has been adopted for electronic messages; however, this provision does not apply retroactively to the databases which were established by obtaining the data subjects’ consent before the Law No. 6563 on Regulation of Electronic Commerce entered into force on May 1, 2015. The Electronic Commerce Law and “Commercial Communications and Commercial Electronic Messages Regulation” published in accordance with this law excludes messages that are sent to the subscribers and users of the operators about their own products and services, and these messages are regulated in “The Principles and The Procedures Regarding the Communication with the Purposes of Advertising and Marketing” published by the ICTA on July 9, 2015. According to electronic commerce legislation, sending commercial electronic messages is also subject to the prior consent of recipients. Violation of this legislation may result in an administrative fine. As per the amendments to the “Commercial Communications and Commercial Electronic Messages Regulation” dated January 4, 2020 a centralized commercial electronic communication management system (“CCECMS”) for obtaining, exercising, and tracking opt-in/opt-out requests and complaints from recipients of electronic commercial communications was established under the supervision of the Ministry of Trade. Pursuant to the amendments, service providers are required to be registered with CCECMS and transfer every consent obtained under the Commercial Communications and Commercial Electronic Messages Regulation to CCECMS. Further, service providers and intermediary service providers initiating the commercial electronic message transmission on behalf of service providers are obliged to verify the consent status of the recipients over the CCECMS. In case service providers fail to comply with the Electronic Commerce Law and Commercial Communications and Commercial Electronic Messages Regulation, administrative fines may be imposed by the Ministry of Trade. 103 Table of Contents bb.Registered Email Service Regulation Registered Electronic Mail Service began in July 2012. Mobile operators cannot provide registered electronic mail service; however, the service may create a new mobile business area with new bundled mobile products, which are able to service our subscribers. cc.Regulation on Refurbished Products The regulation on the refurbishment of used mobile phones and tablets, warranty conditions of refurbished devices, authorization of refurbishment centers, and regulation of the obligations of market actors entered into force on August 22, 2020. The Turkish Standardization Institute determined the standards for refurbishment centers on February 17, 2021, and authorized the refurbishment centers. In this context, consumers may access to second-hand mobile phones with a higher reliability, and so, more second-hand devices are expected to be included in the ecosystem. dd. Regulations Regarding the Southeastern Türkiye Earthquakes The ICTA published the Board Decision entitled “Measures to be Taken Due to Earthquake Disaster” on February 14, 2023. According to this Decision, among other obligations, free of charge services and additional benefits were to be provided and bills were to be postponed for at least a month, for subscribers who had received mobile services or subscribers whose registered address or fixed service facility address was located in the provinces where a state of emergency was declared as of February 6, 2023. In addition, on April 6, 2023, the “Presidential Decree on the Field of Electronic Communication and Water Structures Inspection Services under the State of Emergency” was published in the Official Gazette. As of today, the above-mentioned articles are no longer in force as the state of emergency has been lifted. However, an investigation was initiated against our Company in connection with our communications infrastructure during the Southeastern Türkiye Earthquakes. Several alleged violations were identified regarding our alleged failure to take necessary measures to ensure uninterrupted communication during disasters and emergencies. In the event that our defenses are not accepted, there is a risk of administrative fines being imposed on our Company. ee.Other regulations affecting our Company i.Amendments to the Turkish Insolvency and Restructuring Regime The Enforcement and Bankruptcy Law No. 2004 prevents a contractual arrangement by which a contractual event of default clause is stipulated to be triggered in the event that an application is made by a Turkish company for debt restructuring upon settlement within the scope of the Turkish Enforcement and Bankruptcy Law No. 2004. In addition to this, on March 15, 2018, changes were introduced to the Turkish Enforcement and Bankruptcy Law No. 2004, one of which provided that the contractual termination, default and acceleration clauses of an agreement cannot be triggered by the making of a concordat application by the debtor and such application shall not constitute a breach of such agreement. ii.Communiqués on Management and Audit of Information Systems The Communiqué on Information Systems Management of the Capital Markets Board of Türkiye (“CMB”) numbered VII-128.9 and Communiqué on Independent Audit of Information Systems numbered III-62.2, which entered into force on January 5, 2018, introduced new obligations with regards to information systems for certain legal persons, including our Company. 104 Table of Contents The Communiqué on Information Systems Management defines the technical procedures for sustainability and secure operation of information systems in a very detailed way. Notably, with regards to data protection; specific measures are to be taken as precautions to protect the secrecy of the data received, processed and stored with regard to information system operations. This Communiqué sets out various methods to be used for physical and environmental safety, network security, identity verification, limited access through authorized persons, data integrity and preserving the confidentiality of the data stored in information systems. On March 13, 2025, Communiqué on the Procedures and Principles of Information Systems Management numbered VII-128.10 was published in the Official Gazette and replaced the communique numbered VII-128.9. The new communique expanded the scope of compliance obligations and brought new requirements for the covered institutions and companies. The Communiqué on Independent Audit of Information Systems provides the rules, policies and principles on the independent audit of the information systems. The Communiqué provides that CMB certified independent auditor companies shall audit and report to the entities whether the audited entity is in line with the information system management principles in terms of its operations, equipment and software pursuant to the Communiqué. The frequency of the audits to be conducted by CMB certified independent auditors varies for each entity subject to CMB regulations. On March 13, 2025, CMB amended Communiqué on Independent Audit of Information Systems. Although these amendments required periodic independent information systems audit for certain institutions and companies, public companies were exempted from this obligation. Although the Communiqués do not include specific penalties in the event of non-compliance, Article 103 (General Principles) of the Capital Markets Law will apply. In order to strengthen the control environment, the Information Systems Compliance Committee has been established as an oversight body. iii.Regulations on Crypto Assets The Law No. 7518 Amending the Capital Markets Law (“Crypto Law”) entered into force upon its publication in the Official Gazette dated July 2, 2024. Crypto Law defined the concepts of crypto asset, crypto asset trading platform, crypto asset custody service and crypto asset service providers (“Crypto Service Providers”). While the Capital Markets Board (“CMB”) will have the authority to regulate crypto assets that provide rights specific to capital market instruments, the duties and authorities of other governmental institutions arising from the legislation regarding crypto assets will be reserved. On March 13, 2025, the CMB took regulatory steps to implement establishment and operational principles of Crypto Service Providers as well as working procedures, principles, and capital adequacy of Crypto Service Providers. iv.Cyber Security Law On March 19, 2025, the Cyber Security Law was published in the Official Gazette. The Cyber Security Law establishes the Cyber Security Directorate and Cyber Security Board and mandates institutions, corporations (including public companies) and natural and legal persons to comply with its provisions. As per this new law, among others, local and national products are to be prioritized for cybersecurity procurement and all public institutions, organizations, and natural and legal persons are responsible for implementing cybersecurity policies and strategies, as well as for taking the necessary measures to prevent or mitigate the impact of cyberattacks. The new law regulates the imposition of prison sentences and fines on natural and legal persons for non-compliance (up to 5% of the gross sales revenue reported in the independently audited annual financial statements). v.Turkish Sustainability Reporting Standards (TSRS) Türkiye has introduced the Turkish Sustainability Reporting Standards (TSRS), which became effective on January 1, 2024, following the decision published in the Official Gazette on December 29, 2023. Developed by the Public Oversight, Accounting and Auditing Standards Authority (POA), the TSRS are based on the International Financial Reporting Standards (IFRS) S1 and S2, established by the International Sustainability Standards Board (ISSB). These standards aim to enhance transparency and accountability by requiring businesses to disclose sustainability-related financial information. 105 Table of Contents The TSRS framework comprises two primary standards: TSRS 1 – General Requirements for Disclosure of Sustainability-related Financial Information: This standard requires entities to disclose information about sustainability-related risks and opportunities that could reasonably be expected to affect the entity’s cash flows, access to finance, or cost of capital over the short, medium, or long term. TSRS 2 – Climate-related Disclosures: This standard focuses on climate-related risks and opportunities, including physical and transition risks, and requires entities to provide relevant disclosures that could impact their financial performance. Under TSRS, companies are required to report on sustainability and climate-related risks and opportunities that could reasonably be expected to affect their financial performance. The standards apply to companies that meet at least two of the following criteria for two consecutive reporting periods: total assets of 1 billion Turkish Lira, annual net sales revenue of 2 billion Turkish Lira, or an average of 500 employees. By aligning with international sustainability reporting frameworks, the TSRS aims to enhance transparency and accountability, facilitating Turkish companies’ access to global markets and compliance with regulations. ff.Major regulations affecting our Subsidiaries Financell Financell is a financing company and is thereby subject to the Financial Leasing, Factoring, Financing and Saving Financing Companies Law No. 6361. The objective of this law is to regulate the establishment and operating principles of these companies as well as the principles and procedures governing their contracts with clients. The Regulation on the Financial Leasing, Factoring, Financing and Saving Financing Companies Establishment and Operation Principles also regulates loan durations and other financing principles. Although Financell has to abide by the BRSA’s regulations due to its financing license, it also has to abide by the CBRT’s regulation on loans and borrowings, the Personal Data Protection Law, the Prevention of Laundering Proceeds of Crime Law and secondary regulations issued by the Financial Crimes Investigation Board, as well as the Ministry of Trade’s regulations on the Consumer Credit Contract with its contents and essentials for its contracts with consumers. Turkcell Dijital Sigorta Turkcell Dijital Sigorta’s main purpose is to act as an insurance company. The company is mainly subject to the Insurance Law No. 5684. The objective of this law is to regulate the establishment and operation principles of insurance companies as well as the principles and procedures applicable to their relations with their clients. As the main regulatory body, the Insurance and Private Pension Regulation and Supervision Authority (“IPRSA”) supervises the activities of Turkcell Dijital Sigorta. Secondary legislation such as communiqués, sector announcements and general terms issued by the IPRSA, also plays an essential role in the activities of Turkcell Dijital Sigorta. The company was granted its license in 2023. Turkcell Dijital Sigorta must comply with the Ministry of Trade’s regulations within the framework of consumer protection regulations regarding insurance products that are sold to consumers. Under the insurance legislation; within the scope of the “Circular on Minimum Capital Amounts Envisioned for Insurance Branches” by the IPRSA decision, the minimum paid-in capital amounts required for insurance companies applying for a license after the publication date of the circular have been increased. Turkcell Sigorta Turkcell Sigorta is, operating in the field of insurance intermediation as a registered insurance agent at the registry held by Turkish Union of Chambers and Commodity Exchanges. Turkcell Sigorta’s activities are subject to the supervision of the IPRSA and Executive Committee of Insurance Agencies (within the Union of Chambers and Commodity Exchanges). The main activity of Turkcell Sigorta is to offer insurance products to customers on behalf of the insurance companies it represents by operation of the agency agreements. 106 Table of Contents Paycell Following the enactment of the law on payment and securities settlement systems, payment services and electronic money institutions no.6493, Paycell obtained the Payment Service Provider (PSP) license in August 2016 from the BRSA, as well as an Electronic Money Issuer License in July 2017. On November 12, 2019, the BRSA’s regulatory powers in this regard were transferred to the CBRT. The CBRT has introduced new regulations regarding “open banking” as well as new license types, such as Payment Initiation Service (PISP) and Account Information Service (AISP). Paycell applied for such licenses in order to provide services that allow its customers to access their banking information, monitor their accounts across various financial institutions, and perform payment transactions through a single interface by directly integrating with other financial institutions. The Regulation on Payment Services and Electronic Money Issues and Payment Service Providers and the Communiqué on the Information Systems of Payment and Electronic Money Institutions and Data Sharing Services in the Payment Services of Payment Service Providers have been published in the Official Gazette dated December 1, 2021. With the regulation, open banking services have been defined and an application to open a banking license has been enabled. With the decision of the Central Bank of the Republic of Türkiye (CBRT) dated March 5, 2025, Paycell’s application for authorization to operate in the field of open banking and its application for money transfer activities have been approved. Thus, Paycell has become an authorized institution entitled to provide all types of payment services within the scope of Law No. 6493 and to carry out all related transactions, including the issuance of electronic money. Paycell is also subject to the Law No. 5549 on the Prevention of Laundering Proceeds of Crime, published in the Official Gazette dated October 18, 2006, as well as its secondary regulations, and to the supervision of the Financial Crimes Investigation Board (FCIB) within this scope. With the amendments published in the Official Gazette dated December 25, 2024, changes have been made to the secondary regulations related to the Law affecting payment and electronic money institutions. Paycell has taken all necessary actions in accordance with the relevant dates set out in the legislation. Turkcell Enerji The operations of Turkcell Enerji are concentrated in the electricity market, which is heavily regulated in Türkiye. The governing law is the Electricity Market Law, while the Energy Market Regulatory Authority (“EMRA”) is the central regulatory body issuing licenses and setting tariffs and quality standards. Electricity market activities in Türkiye subject to the EMRA licensing regime include power generation, power supply, system operation (at both transmission and distribution level) and market operations for which each activity requires the issuance of a separate license. Turkcell Enerji holds a power supply license issued by EMRA on May 11, 2017 that is valid for 20 years. Its license allows Turkcell Energy to buy and sell electricity capacity and energy in both wholesale and retail markets at unregulated prices. Furthermore, Boyut Enerji, the subsidiary of Turkcell Enerji, holds an electricity generation license from EMRA that is valid for 49 years and the license period of its wind power plant will expire in 2057. In addition to this, Turkcell Enerji completed the installation of a 163.5 MW solar power plant in 2025 and commissioned a 62.3 MW solar power plant. Lifecell Müzik & Lifecell TV The operations of Lifecell Müzik as a music service and Lifecell TV as an OTT TV platform are within the scope of the Regulation on the Provision of Radio, Television and On-demand Broadcasting Services over the Internet (the “Regulation”), which came into force on September 1, 2019. As per the Regulation, media service providers broadcasting and platform operators transmitting broadcasting services on the internet must obtain a broadcasting license and broadcasting transmission authorization, respectively, from the RTUK. RTUK granted an on-demand broadcasting license over the internet to Lifecell Müzik valid for ten years as of August 29, 2019. Also, Lifecell TV has been granted an authorization for broadcasting transmission over the internet that is renewed on a yearly basis. 107 Table of Contents 4.C Organizational Structure The following chart lists each of our key subsidiaries and our proportionate direct and indirect ownership interest as of April 3, 2026. ● On January 21, 2025, Dijital Eğitim Teknolojileri A.Ş. merged with Turkcell Dijital İş Servisleri A.Ş. through a simplified merger procedure. ● On January 27, 2025, the Board of Directors resolved to liquidate Paycell LLC. ● On February 20, 2025, Turkcell Superonline transferred its data center assets to TDC through a partial demerger transaction. ● On February 25, 2025, the shares of Turkcell Teknoloji held by Turktell Bilişim Servisleri A.Ş. were transferred to Artel Bilişim Servisleri A.Ş. (“Artel”) through a partial demerger transaction. This transfer solely represents a change in shareholding; Turkcell Teknoloji continued to operate as a separate legal entity following this transaction. ● On March 10, 2025, Rehberlik Hizmetleri Servisi A.Ş. completed its liquidation process and ceased operations. ● On May 7, 2025, Lifecell Bulut Çözümleri A.Ş. merged with Lifecell Dijital Servisler ve Çözümler A.Ş. (“Lifecell Dijital Servisler”) through a simplified merger procedure. ● On December 31, 2025, Artel merged with the Company through a simplified merger procedure, upon which all assets and liabilities of Artel — including the shares of Turkcell Teknoloji— were transferred to the Company. As a result, Turkcell Teknoloji became a direct subsidiary of the Company. ● On April 1, 2026, the registered company name of BİP İletişim Teknolojileri ve Dijital Servisler A.Ş. was amended to Turkcell Dijital Teknoloji Satış A.Ş. For information on the countries of incorporation of our key subsidiaries, see “—B. Business Overview.” 108 Table of Contents 4.D Property, Plant and Equipment As of December 31, 2025, we operated 74 facilities including network data centers, of which 70 were located in Türkiye, with the rest in the Turkish Republic of Northern Cyprus. We own and lease buildings in İstanbul, including our headquarters, mobile switching centers, network data centers, customer service offices and warehouses. Our buildings in Türkiye and outside of Türkiye are used for the purposes of administration, sales and other service centers, as well as marketing and operation of mobile switching centers and network data centers. As of December 31, 2025, we also had 179 owned and 1,162 leased vehicles used for operational and administrative purposes. For a further discussion of our facilities and equipment in the countries in which we operate and environmental issues relating to the use thereof, see “—B. Business Overview” and “Item 3. Key Information—D. Risk Factors—Risks Relating to Our Business—Environmental risks and climate change could significantly impact our businesses.” I.Core Network Infrastructure Our broadband core infrastructure consists of Evolved Packet Core and 5G Converged Core systems for mobile access and Border Network Gateways for fixed access, which provide broadband mobility and connectivity to our customers. Mobile and fixed broadband infrastructure also consist of broadband network services. We are growing our broadband network in line with increasing customer data demand on our telco cloud infrastructure to enable Turkcell to meet growing customer demands for flexibility. We have IP Multimedia Subsystem (“IMS”) network infrastructure located in four major network data centers, working in full redundancy and capable of fulfilling high voice demand in case of emergency conditions such as natural disasters. The IMS network is deployed on telco cloud infrastructure which enables more agile capacity and service capability management. Our internet communications infrastructure contains multiple (and geographically redundant) transit and peering connections to the foremost global service and OTT providers in addition to CDN infrastructure located in our data centers to deliver a high-quality internet experience for both mobile and fixed customers. II.Access Network Infrastructure Access Network infrastructure includes 2G BTSs, 3G NodeBs, 4.5G e-NodeBs and 5G g-NodeBs which are located on rooftops and towers, Base Station Controllers (“BSC”) and Radio Network Controllers (“RNC”) at network data centers. BTSs, NodeBs, e-NodeBs and g-NodeBs consist of fixed transmitter/receiver equipment and the antennas to actualize the coverage area for voice and data connections. 2G BTSs and 3G NodeBs are connected to and controlled by BSC or RNC, respectively. 4.5G e-NodeBs and 5G g-NodeBs have an important difference in that they are directly connected to the 4.5G Core Network and 5G Core Network. In addition to macro sites that serve large areas, there are sites using small base stations called small cells, which serve certain specific and limited areas. We have been adding small cells to densify our network and meet certain performance objectives (enhanced user experience, higher speeds, higher capacity, improved coverage, etc.). Depending on the suitability and cost-effectiveness of the candidate solution, we are using small cell systems, repeaters or relay systems to augment our service quality. In addition to these macro site types and the small cells, we also deploy specially designed indoor systems for special areas and buildings such as stadiums, concert venues, shopping malls and airports. In 2009, the ICTA resolved that operators may transfer the right of use of their towers to third parties. In accordance with this resolution, we transferred the rights of certain towers to our subsidiary, Global Tower. III.Transmission Network Infrastructure Turkcell’s mobile backhaul infrastructure leverages multiple transport technologies to ensure an efficient, resilient and cost-effective transmission network. Connectivity between sites is provided through 10/100 GE over dark fiber and Ethernet over DWDM, where applicable. At cell sites, the majority of site connectivity is delivered via point-to-point microwave radio links that are owned and operated by Turkcell, accounting for approximately 53% of the overall network. 94% of our fiber connectivity to our cell sites is currently provided by our subsidiary, Turkcell Superonline. 109 Table of Contents The rest of the leased lines are provided by Türk Telekom and Vodafone. As a result, we believe that the overall infrastructure capacity usage is fully optimized and a high grade of availability is achieved through topology resiliency and packet base IP mobile backhaul network infrastructure. Turkcell has fiber backbone covering all 81 cities of Türkiye with full flexible WDM optical ASON domain currently carrying 261 Tbps traffic. Based on an average more than 40% capacity increase each year, we have built two overlay high speed (200G/400G per channel) full flexible backbone WDM networks utilising optical ASON which increases flexibility and reliability. In addition, we started building another WDM backbone domain, optimized to carry 800G, 1.2 Tbps and even 1.6 Tbps per channel in longer distances with the usage of the “L” band in the frequency spectrum, in addition to the conventional “C” band used today. Turkcell links Europe to Asia by providing international services with more than 39 Tbps of international capacities running on our transport network.