DISCLOSURE POLICY

Formation of Olmuksa Disclosure Policy as mentioned below and the announcement to the public.

The management of Olmuksa International Paper-Sabancı Ambalaj San. ve Tic. A.Ş. is proud of being in a transparent and close communication with its shareholders. The main aim of the Management is to make the shares of Olmuksa International Paper-Sabancı Ambalaj San. ve Tic. A.Ş. attractive investment instruments for potential investors while increasing the value of Olmuksa International Paper-Sabancı Ambalaj San. ve Tic. A.Ş. for current shareholders. The principal target of Olmuksa International Paper-Sabancı Ambalaj San. ve Tic. A.Ş. Management is to share information on the performance and forward looking developments within the scope of the Generally Accepted Accounting Principles (GAAP) and the Capital Market Legislation (CML), in a fair, complete, accurate and comprehensive way with the shareholders, investors and the Capital Market experts (together with capital market participants) equally.

Olmuksa International Paper-Sabancı Ambalaj San. ve Tic. A.Ş. complies with the CML, Capital Market Board (CMB) and Istanbul Stock Exchange (ISE) Regulations with respect to public informing and also applies the Corporate Governance Principles of CMB with maximum care.

Disclosure Policy applies to all employees and advisers of Olmuksa International Paper-Sabancı Ambalaj San. ve Tic. A.Ş. and it regulates the written and oral communication between Olmuksa International Paper-Sabancı Ambalaj San. ve Tic. A.Ş. and the Capital Market participants.

Disclosure Policy is prepared and approved by the Board of Directors within Corporate Management Principles of the CMB. Monitoring, controlling and development of policy of Olmuksa International Paper-Sabancı Ambalaj San. ve Tic. A.Ş. for informing and disclosing the public is under the authority and responsibility of the Board of Directors.

Finance Director within the Company organization is in-charge of observing and controlling all issues concerning public informing.

Disclosure is performed by means of information tools such as special case public disclosers, financial statements and reports, annual reports, internet page, presentations, investor meetings and teleconferences, information letters and press releases. Basic tools and methods used to inform the public by Olmuksa International Paper-Sabancı Ambalaj San. ve Tic. A.Ş. while saving the provisions of CML and Turkish Commercial Code are listed below:

• Special case public disclosures forwarded to ISE (notifications are made simultaneously in electronic environment to Public disclosure project (KAP))

• The financial tables and footnotes, independent audit report, declarations and activity report forwarded to ISE, (KAP notifications are made simultaneously in electronic environment)

• Announces and notifications made by means of Turkish Trade Registry Journal and Daily Newspapers (guidelines, circular, calls for general assembly etc.)

• Press statements made by means of written and visual media,

• Disclosure meetings and interviews made face to face or via tele-conferences with capital market participants

• Corporate Website (www.olmuksa.com.tr),
• Disclosures made over Communication mediums and methods like phone, cell phone (wap and similar technologies), e-mail, fax etc

The financial statements and footnotes of Olmuksa International Paper-Sabancı Ambalaj San. ve Tic. A.Ş. are prepared on a consolidated basis and comply with the International Financial Reporting Standards (IFRS); audited independently with respect to International Audit Standards (IAS) and disclosed to the public by being forwarded to ISE. Before disclose, financial reports and disclosures are approved by the Board of Directors after the Audit Committee within the CML.

After the approval of the Board of Directors, the financial reports, disclosures, independent audit report and other attached documents are sent to ISE with a closed envelope as the CMB and ISE regulations order. At the moment when financial reports, disclosures, and independent audit board are disclosed, they are published in KAP project electronically as well.

The annual report prepared according to the CML and the Corporate Governance Principles of CMB; it is approved by the Board of Directors and is disclosed to public with the financial tables via our corporate web page (www.olmuksa.com.tr).

Public disclosure of Olmuksa International Paper-Sabancı Ambalaj San. ve Tic. A.Ş. is prepared by Finance Directorate.

Declarations of public disclosure of Olmuksa International Paper-Sabancı Ambalaj San. ve Tic. A.Ş are forwarded to ISE after being signed by General Manager, Finance Director on principle. If that is not possible, the public disclosure is sent to ISE after being signed by General Manager or Finance Director and Sales and Marketing Director. The disclosure of special cases is sent to ISE by fax. It is also sent as KAP Information electronically.

Any information is counted as special and important information when there is a great chance that any reasonable investor might find it important and special.

If any employee of Olmuksa International Paper-Sabancı Ambalaj San. ve Tic. A.Ş. finds out that important information, which has not been disclosed before, has been disclosed involuntarily, the employee immediately reports the situation to General Management. In this case, General Management ensures that the appropriate special position disclosure is prepared in line with provisions of CML and is forwarded to ISE by preparing the same.

Olmuksa International Paper-Sabancı Ambalaj San. ve Tic. A.Ş. broadcasts public disclosure in its internet site (www.olmuksa.com.tr) within business day after public is disclosed information at the latest and maintains the said disclosures for five years in its internet site.

Apart from the disclosures given above, written and oral requests for information given by capital market participants or any institution/person are processed within the authority of General Management. In conducted assessment, according to the content of request, it is checked if it is commercial secret and if it is any type that may affect the investment decisions and the value of capital markets instruments within the scope of Capital Markets Board's Communiqué of VIII Serial and No 54 on Essentials of Public Disclosure of Special Cases. The written and oral requests of information are answered by relevant unit after the assessment of General Manager.

Press statements for written and visual media and to data distributors like Reuters, Forex etc can only be made by Chairman of the Board of Directors and General Manager.

Despite that without being specially charged, employees of Olmuksa International Paper-Sabancı Ambalaj San. ve Tic. A.Ş. cannot answer questions coming from capital market participants. Incoming requests for information are forwarded to General Management.

People who have administrative responsibility are people who access to insider information related either directly or indirectly to Olmuksa International Paper-Sabancı Ambalaj San. ve Tic. A.Ş. moreover, who are authorized to have administrative decisions affecting the future development and commercial targets of Olmuksa International Paper-Sabancı Ambalaj San. ve Tic. A.Ş. .

Olmuksa International Paper-Sabancı Ambalaj San. ve Tic. A.Ş. never comments on expectations about interim periods and annual results. Instead of this, Olmuksa International Paper-Sabancı Ambalaj San. ve Tic. A.Ş. comments on critical subjects affecting activity results, strategic methods and subjects that make the sector and the activities more understandable and informs the capital market participants. Only authorized individuals who do public disclosures can make comments to the public in name of Olmuksa International Paper-Sabancı Ambalaj San. ve Tic. A.Ş. unless otherwise specified in the disclosure policy.

Olmuksa International Paper-Sabancı Ambalaj San. ve Tic. A.Ş. does not generally comment on market rumors or speculation as a rule. Follow up of the news and rumors included in press-media organs and at internet sites about Olmuksa International Paper-Sabancı Ambalaj San. ve Tic. A.Ş. is made by Finance Directorate and they are informed to General Management. General Management decides if these news and information would make any impact on capital instruments.

It is decided by Finance Directorate if it is necessary to make a public disclosure within the framework of 18th article of Capital Markets Board's Communiqué of VIII Serial and No 54 on Essentials of Public Disclosure of Special Cases. However, the Company responds to rumors or speculation in certain circumstances including upon request by CMB and or ISE within the framework of provisions of CML or if the Company determines such response is appropriate.

In Olmuksa International Paper-Sabancı Ambalaj San. ve Tic. A.Ş. the General Manager is responsible for carrying out relations with either present or potential shareholders in a regular manner, responding the questions of investors in a most effective manner and performing studies for rising the value of the company.

General Manager and/or Finance Director use various tools such as roadshow, teleconference, e-mail, fax, analyst presentations, explanation/announcement for direct disclosure that are necessary for making Olmuksa International Paper-Sabancı Ambalaj San. ve Tic. A.Ş. reputable and preferable in international investment area and emphasizing the advantageous features of it when compared to similar institutions and making Olmuksa International Paper-Sabancı Ambalaj San. ve Tic. A.Ş. more preferable than other companies for institutions investing in emerging markets. All incoming meeting requests from shareholders are positively responded and interviews at the highest level possible to provide opportunities.

Olmuksa International Paper-Sabancı Ambalaj San. ve Tic. A.Ş. regards analyst reports as proprietary information belonging to the analyst's company and will not provide such reports on the Company's website (www.olmuksa.com.tr). Olmuksa International Paper-Sabancı Ambalaj San. ve Tic. A.Ş. will not review, confirm, endorse, adopt or disseminate analysts' reports or earnings models. However, in certain limited circumstances, upon request, the Company may review specific factual assertions that an analyst intends to include in a report for the factual accuracy of historical information that is publicly available.

Olmuksa International Paper-Sabancı Ambalaj San. ve Tic. A.Ş. in order to prevent asymmetric information distribution and unauthorized disclosure about annual reports, avoids talking in specific periods of the calendar year about financial results and about other subjects with capital market participants. These periods are called "quiet periods". For Olmuksa International Paper-Sabancı Ambalaj San. ve Tic. A.Ş. the quiet period starts at the 15 of the following month after the three-month period and annual accounting period ends and will end one business day after when financial reports and footnotes are disclosed to the public.

Olmuksa International Paper-Sabancı Ambalaj San. ve Tic. A.Ş. during the quiet period;

• will not talk about the financial status of Olmuksa International Paper-Sabancı Ambalaj San. ve Tic. A.Ş. at one to one meetings or group meetings with capital market investors except the information that has been disclosed before,

• Except it is required and the CML are followed, it will not comment about its activities and financial status,

• Except the information disclosed before, questions will not be answered in one to one meetings or meetings with small groups. If such a situation is possible, the disclosure will be made on the website (www.olmuksa.com.tr).

13. Olmuksa International Paper-Sabancı Ambalaj San. ve Tic. A.Ş.'s Website (www.olmuksa.com.tr)

Olmuksa International Paper-Sabancı Ambalaj San. ve Tic. A.Ş.'s Website, which is in (www.olmuksa.com.tr) internet address, as recommended by CMB Corporate Management Essentials is actively used in informing the public. The information available on Olmuksa International Paper-Sabancı Ambalaj San. ve Tic. A.Ş.'s Website does not represent the disclosure of special case announcements regarding CML. All disclosure of Olmuksa International Paper-Sabancı Ambalaj San. ve Tic. A.Ş. can be accessed through the webpage. The webpage is based on this and it includes sections. All precautions are taken for the security of the webpage. The webpage is prepared and designed in Turkish and in English as CMB Corporal Management Essentials claim. Especially the announcements for General Assembly meetings and for agenda and other information, documents and reports are available on the webpage very clearly. Activities for the development of the webpage are kept running.

Important headings that may be seen at website are summarized as follows: