Santiago Principles Self-Assessment®
TWF 2025
Pillar 1: Legal
Principle 1
1. The legal framework for the SWF should be sound and support its effective operation and the achievement of its stated objective(s).
1.1. The legal framework for the SWF should ensure legal soundness of the SWF and its transactions.
1.2. The key features of the SWF’s legal basis and structure, as well as the legal relationship between the SWF and other state bodies, should be publicly disclosed.
Being the exclusive fund manager of Türkiye Wealth Fund (hereinafter referred to as ‘TWF’), Türkiye Wealth Fund Management Company (hereinafter referred to as ‘TWF ManCo’), a joint-stock company subject to private law, was established by Law No. 6741 dated 19 August 2016, which was published in the Official Gazette on 26 August 2016.The Decree of the Council of Ministers dated 17 October 2016 (hereinafter referred to as the ‘Decree’) setting forth the procedures and principles governing the structure and operations of TWF ManCo (Turkish name: Türkiye Varlık Fonu Yönetimi Anonim Şirketi), was published in the Official Gazette on 9 November 2016.
Law No. 6741 and the Decree establish the legal relationship between TWF and its fund manager, TWF ManCo. Both documents are publicly available in the Official Gazette of the Republic of Türkiye (https://www.resmigazete.gov.tr/) and on TWF’s website (www.tvf.com.tr).
Since the legal basis and structure of TWF are defined under Law No. 6741, any amendments to this law are published in the Official Gazette. In addition, related regulations are disclosed and regularly updated on TWF’s website.
Following the Law No. 6741 and the Decree, TWF ManCo’s Articles of Association and TWF’s Bylaws were published in the Türkiye Trade Registry Gazette on 28 December 2016 and 30 January 2017, respectively. Any amendments to TWF’s Bylaws or TWF ManCo’s Articles of Association of are also publicly disclosed in the Trade Registry Gazette.
TWF was established as a separate legal entity. However, its legal personality is limited to the registration of its assets. Accordingly, TWF is managed and represented by TWF ManCo, as stipulated in Article 1 of Law No. 6741. Pursuant to Article 5 of Law No. 6741, the assets and rights transferred to TWF shall be registered under TWF’s name and are separate from those of TWF ManCo.
According to Article 2 of Law No. 6741, TWF ManCo is wholly owned by the Privatization Administration, which is an affiliated institution of the Ministry of Treasury and Finance.
- The original text in the Official Gazette can be found in Turkish language at: https://www.resmigazete.gov.tr/eskiler/2016/08/20160826-1.htm
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The original text in the Official Gazette can be found in Turkish language at: https://www.resmigazete.gov.tr/eskiler/2016/11/20161109-14.pdf English translation may be prepared by TWF upon request.
Principle 2
2. The policy purpose of the SWF should be clearly defined and publicly disclosed.
TWF’s policy purpose is defined by Article 1 of Law No. 6741, as published in the Official Gazette, and includes the following objectives:
- Enhancing the value of assets within TWF,
- Providing equity to strategic investments in Türkiye,
- Making equity investments to support Türkiye’s international economic objectives,
- Reinforcing the improvement and deepening of financial markets.
In addition, TWF’s mandate, covering these objectives along with its strategic sources, is publicly available on TWF’s website under the ‘Our Mandate’ section.
Section 2 of Decree No 2016/9429 outlines the operational principles of the TWF ManCo, while Section 5 stipulates that its annual activities shall be publicly disclosed.
Furthermore, the Articles of Association of TWF ManCo’s and the Bylaws of TWF also include provisions concerning policy purpose and scope of activities.
3. As this is a source open to private and public institutions residing in Türkiye, English translation may be prepared by TWF upon request.
Principle 3
3. Where the SWF’s activities have significant direct domestic macroeconomic implications, those activities should be closely coordinated with the domestic fiscal and monetary authorities, so as to ensure consistency with the overall macroeconomic policies.
As an affiliate of the Presidency of the Republic of Türkiye, TWF is positioned as the strategic investment arm of the state, with the goal of supporting national macro-economic objectives.
TWF ManCo, acting on behalf of TWF, operates in alignment with the government priorities. The President of the Republic of Türkiye, H.E. Recep Tayyip Erdoğan, also serves as the Chairman of the Board of Directors of TWF ManCo.
In addition, TWF is included in the Medium-Term Program, which initiates the national budget process and helps shape public policies and allocate resources based on strategic goals.
Principle 4
4. There should be clear and publicly disclosed policies, rules, procedures, or arrangements in relation to the SWF’s general approach to funding, withdrawal, and spending operations.
4.1. The source of SWF funding should be publicly disclosed.
4.2. The general approach to withdrawals from the SWF and spending on behalf of the government should be publicly disclosed.
TWF’s sources and methods of financing are set forth under Article 4 of Law No. 6741 and are published in the Official Gazette.
TWF’s main sources of finance include assets and cash surpluses transferred by the government bodies, income from dividends, licenses, and real estate, as well as borrowings from domestic and international financial markets through loans and the issuance of capital market instruments.
The general principles governing expenditures from TWF’s assets are defined in Article 11 of the Bylaws of TWF, which are publicly disclosed in the Trade Registry Gazette.
All financing or investment activities are announced on TWF’s website under the ‘Disclosure’ section.
Principle 5
5. The relevant statistical data pertaining to the SWF should be reported on a timely basis to the owner, or as otherwise required, for inclusion where appropriate in macroeconomic data sets.
TWF complies with Article 18 of the Decree and is committed to publishing annual reports on its website under the ‘Reports’ section. TWF annually collects and reports financial and ESG data related to its portfolio companies through various digital systems. The collected data is also subject to assurance audits conducted by specialized organizations. In addition, TWF provides relevant data sets to the Presidency of the Republic of Türkiye and shares information with the relevant government authorities when required.
Pillar 2: Institutional
Principle 6
6. The governance framework for the SWF should be sound and establish a clear and effective division of roles and responsibilities in order to facilitate accountability and operational independence in the management of the SWF to pursue its objectives.
TWF adheres to the highest standards of corporate governance to promote long-term value creation and contribute to sustainable economic, social, and environmental development.
Pursuant to Article 6 of the Decree, the organizational structure and job descriptions within TWF ManCo are clearly defined to ensure accountability and operational independence in management. TWF ManCo’s Operational Management Team’s responsibilities are as follows:
- Conducting research and due diligence on projects and investment opportunities,
- Carrying out pre-feasibility analyses for selected projects or opportunities,
- Conducting detailed assessment with the support from external expert advisors, and
- Managing the contracting process and facilitating final approval procedures.
Oversight of compliance with applicable laws and internal policies is vested in the Board of Directors, which exercises this function in accordance with Article 375 of the Turkish Commercial Code. The Board also holds the authority for the final approval of all investments. In addition, the roles and responsibilities of the Board are comprehensively outlined in Articles 12, 13, 14, and 15 of TWF ManCo’s Articles of Association.
In line with Article 19 of the Decree, and to ensure the effective fulfilment of the Board’s duties and responsibilities, the following committees have been established within the Board in accordance with corporate governance regulations under the Capital Markets Law No. 6362:
- Audit Committee,
- Corporate Governance Committee, and
- Early Detection of Risk Committee.
In addition, an Executive and Human Resources Committee has been formed. The roles and responsibilities of the committees are defined in Article 16 of the Articles of Association of TWF ManCo.
4. The Turkish version of such Turkish Commercial Code can be found at https://www.mevzuat.gov.tr/mevzuat?MevzuatNo=6102&MevzuatTur=1&MevzuatTertip=5
Principle 7
7. The owner should set the objectives of the SWF, appoint the members of its governing body(ies) in accordance with clearly defined procedures, and exercise oversight over the SWF’s operations.
The objectives of TWF are defined under Law No. 6741. In line with this Law, TWF’s strategic objectives and operations are overseen by the Board of Directors of TWF ManCo, which comprises representatives from the Government, public sector and private sector, bringing diverse backgrounds and expertise.
Pursuant to Article 2 of Law No. 6741, the Board of TWF ManCo is required to consist of at least five members, who are appointed in accordance with the Presidential Decree on the Appointment Procedures of Senior Government Executives and State Institutions and Organizations. In accordance with Article 13, paragraph 2 of the Decree, H.E. the President of Republic of Türkiye is appointed as the Chairman of the Board of TWF ManCo.
As per the Law No. 6741, TWF is subject to a three-stage audit mechanism -independent external audit, Presidential audit, and Parliamentary audit- through the activities of the Fund are subject to comprehensive oversight.
5. The Turkish version of such Presidential Decree can be found at https://www.mevzuat.gov.tr/MevzuatMetin/19.5.3.pdf
Principle 8
8. The governing body(ies) should act in the best interests of the SWF, and have a clear mandate and adequate authority and competency to carry out its functions.
Pursuant to Article 1 of Law No. 6741, TWF is managed and represented by its fund manager, TWF ManCo. In line with Article 365 of the Turkish Commercial Code, which stipulates that joint-stock companies are governed and represented by their boards of directors, the Board of Directors of TWF ManCo is the responsible body for exercising this function.
The Board convenes under the chairmanship of H.E. President of the Republic of Türkiye. In accordance with Article 13 of Decree, members of Board of Directors and the General Manager are required to meet the qualifications set forth in Article 3 of the relevant Presidential Decree, which include having adequate experience in international institutions and the private sector). The current composition of the Board of Directors is publicly disclosed on our website.
The Board serves as the ultimate decision-making authority for all investment and financing transactions of TWF and is authorized to represent and legally bind TWF ManCo in accordance with the relevant provisions of the Turkish Commercial Code and TWF ManCo’s Articles of Association.
The formation and operation of the Board are detailed in the Articles of Association:
• Article 12 (“The Company shall be managed, represented and bound by a board”),
• Article 13 (“The term of office of the board members shall be specified in accordance with the provisions of the related legislation”),
• Article 15 (“The board shall fulfil the duties granted by related legislation”).
The Articles of Association are officially published in the Trade Registry Gazette. Further, as stipulated in Article 6 of TWF’s Bylaws, also published in the Trade Registry Gazette, the administrative and financial rights related to the assets in TWF’s portfolio are exercised by the Board of Directors of TWF ManCo.
In line with Article 369 of the Turkish Commercial Code, the duty of care and duty of loyalty are the indispensable attributes of the Board Members, who are legally liable under the Bylaw for the prudent performance and protection of the company’s interests.
In accordance with the strategic objectives set out in the Law No. 6741, the Board approved the Mandate of TWF by a Board Resolution dated 24 October 2018.
As outlined in the Bylaws of TWF and Articles of Association of TWF ManCo (as explained above), the Board is vested with a clear mandate, adequate authority, and competency required to perform its functions effectively. The Board acts in good faith and with the sole purpose of fulfilling TWF’s mandate.
Principle 9
9. The operational management of the SWF should implement the SWF’s strategies in an independent manner and in accordance with clearly defined responsibilities.
The ultimate responsibility and independent authority to represent TWF and TWF ManCo, as well as to define and set strategies, belong to the Board of Directors, in accordance with Article 365 of the Turkish Commercial Code. Pursuant to Article 367 of the Turkish Commercial Code and Article 15 of TWF ManCo’s Articles of Association, the Board has delegated the authority to carry out day-to-day business operations, including matters related to human resources and finance, to the operational management team.
According to Article 13 of the Decree, the Board of Directors is authorized to determine the qualifications required for TWF ManCo personnel. Furthermore, under Article 14, executives and personnel of TWF ManCo are required to exercise the necessary professional care and diligence in their work and decision-making processes, avoid conflicts of interest, and refrain from any actions or transactions that could compromise their integrity and impartiality.
TWF ManCo has a senior management composed of experienced professionals and operates under a well-established organization chart, with departments formed based on their technical functions and operational workflow. The roles and responsibilities of these departments are outlined in internal procedures.
Acting under delegated authority from the Board, (as defined in Article 6 of the Decree and Articles 12–15 of TWF ManCo’s Articles of Association), the Operational Management Team carries out all day-to-day investment activities, including project research and due diligence, pre-feasibility analyses, detailed assessments with external advisors, and managing the contracting and final approval processes.
The operational management team submits investment and financing proposals to the Board, which retains exclusive authority for final approval. While operating with a high degree of independence, the operational management team reports monthly to the Board. The Board exercises its oversight of all activities carried out by the operational management team through executive-level committees.
Principle 10
10. The accountability framework for the SWF’s operations should be clearly defined in the relevant legislation, charter, other constitutive documents, or management agreement.
The Law No. 6741 and the Decree stipulate the corporate governance framework which constitutes the basis for establishment of executive-level committees, such as the Audit Committee, Corporate Governance Committee and Early Detection of Risk Committee. In addition, an Executive and Human Resources Committee has been formed.
These committees are established to ensure the effective fulfilment of the duties of the Board of Directors:
- The Audit Committee is primarily responsible for overseeing the quality and accuracy of the financial statements, including those of TWF’s subsidiaries, monitoring the implementation and efficiency of accounting system, and controlling the independent external audit.
- The Corporate Governance Committee identifies whether the corporate governance principles are being implemented within TWF ManCo, determines the reasons if they are not, as well as any conflicts of interest arising from non-compliance, and provides recommendations to the Board of Directors to improve corporate governance practices.
- The Early Detection of Risk Committee carries out activities aimed at the early identification of risks that may endanger TWF ManCo’s existence, development, and continuity, the implementation of necessary measures regarding identified risks, and the effective management of those risks.
- Executive and Human Resources Committee is tasked with achievement of TWF's mandate and roadmap by guiding the development and implementation of clear, consistent, and sustainable strategies and human capital practices.
This legal and institutional structure reflects TWF’s commitment to corporate governance standards, in line with the Capital Markets Law and supports three-stage audit mechanism consisting of independent external audit, Presidential audit, and the Parliamentary audit.
In accordance with Article 16 of the Decree, TWF ManCo, TWF, sub-funds under TWF and companies to be established by TWF are subject to independent external audit , Presidential audit and Parliamentary audit, as specified under Article 6 of Law No. 6741. This principle is further reflected in Article 20 of TWF ManCo’s Articles of Association and Article 10 of TWF’s Bylaws.
Principle 11
11. An annual report and accompanying financial statements on the SWF’s operations and performance should be prepared in a timely fashion and in accordance with recognized international or national accounting standards in a consistent manner.
TWF complies with Article 18 of the Decree and is committed to publishing its annual and financial statements regularly on its official website.
TWF’s Consolidated Financial Statements are prepared on an annual basis in accordance with Turkish Financial Reporting Standards as issued by the Public Oversight Accounting and Auditing Standards Authority of Türkiye (POA) which are aligned with the International Financial Reporting Standards.
Since the reporting period related to the 2021 activities, TWF has published its integrated annual report in alignment with International Integrated Reporting Framework and in compliance with Global Reporting Initiative (GRI) Standards.
Accordingly, TWF’s annual report consolidates material information regarding its strategy, governance, performance of its portfolio companies, as well as outlook, in a way that reflects the ESG (Environmental, Social and Governance) context in which it operates. An independent limited assurance opinion was obtained for the 26 environmental and social key performance indicators of the Issuer and its Portfolio Companies for the 2024 TWF integrated annual report.
In addition, contingent liabilities and off-balance sheet items including commitments, collaterals, pledges or mortgages are disclosed in the independent external audit report.
Principle 12
12. The SWF’s operations and financial statements should be audited annually in accordance with recognized international or national auditing standards in a consistent manner.
As per the Law No. 6741, TWF has a three-stage audit mechanism which includes independent external audit, Presidential audit and The Parliamentary audit.
Independent External Audit
TWF’s Consolidated Financial Statements have been prepared on an annual basis in accordance with Turkish Financial Reporting Standards as issued by the Public Oversight Accounting and Auditing Standards Authority of Türkiye which are aligned with the International Financial Reporting Standards.
The Consolidated Financial Statements have been audited by "PricewaterhouseCoopers-PwC" in accordance with the Standards on Independent Auditing that are part of the Turkish Standards on Auditing issued by POA which are in compliance with international independent audit standards.
TWF ManCo’s Board of Directors adopts a resolution and submits the appointment of the independent external auditor for the final approval of the General Assembly. The external audit conducted for TWF’s Consolidated Financial Statements is submitted to the Board of Directors of TWF ManCo for its approval.
Presidential Audit
At least three central administration audit officers, appointed by the President, audit TWF’s operations and independently audited financial statements. The appointed auditors must have expertise in capital markets, finance, economy, treasury, banking, and development areas. These auditors prepare and submit an audit report to the President.
Parliamentary Audit
Following the submission of the audit report to the President, the Planning and Budget Commission of the Turkish Parliament discusses and audits the TWF’s financial statements and its activities.
In addition, TWF conducts its internal audit led by the Audit Committee, which is structured as an independent body from the operational management team.
Principle 13
13. Professional and ethical standards should be clearly defined and made known to the members of the SWF’s governing body(ies), management, and staff.
The members of Board of Directors and the General Manager of TWF ManCo are required to meet the qualifications set forth under Article 3 of the relevant Presidential Decree. These include adequate experience in international institutions and private sector, as well as not having been convicted of crimes against the security of the state, crimes against the constitutional order, or of embezzlement, bribery, fraud, forgery, breach of trust, rigging of tenders, or other related offenses.
Article 9 and Article 14 of the Decree, along with Article 6 of the Bylaws, set out the fundamental principles to be followed regarding conflict of interest and confidentiality.
In 2024, TWF ManCo initiated the Compliance Project, which encompassed a comprehensive risk assessment, consultations with senior management, and a review of existing practices. This process resulted in the establishment of the Compliance Program, duly approved by the Board of Directors in 2025. The Program introduces a risk-based framework of rules, policies, and procedures, and includes follow policies: Anti-Bribery and Anti-Corruption Policy, Code of Ethics, Statement on Anti-Money Laundering, Social Investment Policy,
Conflict of Interest Policy, Compliance Policy, and Trade Sanction Policy. Designed as a dynamic process and an organizational culture shaped collectively by employees, the Program aims to foster integrity, accountability, and transparency across TWF and its relationship with the stakeholders. These policies are published on TWF’s website under “Policies” section.
All policies are regularly communicated to all employees and archived in an internal shared drive that is easily accessible. In addition, online training materials on professional and ethical standards, developed for public institutions, are made available to all employees.
Principle 14
14. Dealing with third parties for the purpose of the SWF’s operational management should be based on economic and financial grounds, and follow clear rules and procedures.
All dealings and transactions with third parties are based on economic and financial grounds. TWF ManCo conducts a procurement process prior to purchasing of good and services from third parties. Third-party appointments and contractual relationships are governed in accordance with the Procurement Procedure, which sets out the rules and standards.
Any dealings with third parties are conducted in line with the relevant internal policies, including the Anti-Bribery and Anti-Corruption Policy, Code of Ethics, Conflict of Interest Policy, Social Investment Policy, Compliance Policy, Anti-Money Laundering Policy, and Trade Sanctions Policy.
Principle 15
15. SWF operations and activities in host countries should be conducted in compliance with all applicable regulatory and disclosure requirements of the countries in which they operate.
As of August 2025, TWF does not hold any overseas investments; however, certain portfolio companies maintain existing operations abroad. TWF remains fully committed to complying with all applicable laws and regulations in any jurisdiction where future investments may be made.
Principle 16
16. The governance framework and objectives, as well as the manner in which the SWF’s management is operationally independent from the owner, should be publicly disclosed.
TWF ManCo is a joint-stock company and the exclusive fund manager of TWF.
The governance framework of TWF and TWF ManCo is established under TWF under Law No. 6741, Decree, TWF’s Bylaws, and the Articles of Association of TWF ManCo. This framework ensures that the corporate governance standards are implemented.
The Board of Directors of TWF ManCo is the authorized and responsible body overseeing the fulfilment of these objectives. The Board comprises representatives from the Government, public sector and private sector, bringing diverse backgrounds and expertise.
According to Articles 6 and 12 of the Decree, the Board performs its duties assigned by TWF ManCo’s under TWF ManCo’s Articles of Association, TWF’s Bylaws, relevant procedures and principles, general assembly resolutions, and applicable legislation. The Board is authorized to take decisions on all matters not specifically reserved by Bylaw, regulation, or other governing documents.
In line with Article 19 of the Decree, and to ensure the effective fulfilment of the Board’s duties and responsibilities, the following committees have been established within the Board in accordance with corporate governance regulations under the Capital Markets Law No. 6362:
- Audit Committee,
- Corporate Governance Committee, and
- Early Detection of Risk Committee.
In addition, an Executive and Human Resources Committee has been formed.
The composition of the Board and its committees, as well as the Mandate and objectives, are publicly disclosed on TWF’s official website.
The Board operates independently and acts in alignment with Türkiye’s national economic objectives. The Corporate Governance Committee supports the Board in ensuring its effective and independent execution of duties and responsibilities.
Principle 17
17. Relevant financial information regarding the SWF should be publicly disclosed to demonstrate its economic and financial orientation, so as to contribute to stability in international financial markets and enhance trust in recipient countries.
TWF complies with Article 18 of the Decree and is committed to publishing annual and financial statements on its website on a regular basis under the “Reports” section.
Since the reporting period related to the 2021 activities, the annual report which is in line with the International Reporting Framework and GRI, also include developments and outcomes related to TWF’s ESG (Environmental, Social and Governance) efforts.
Pillar 3: Investment
Investment and Risk Management Framework.
Principle 18
18. The SWF’s investment policy should be clear and consistent with its defined objectives, risk tolerance, and investment strategy, as set by the owner or the governing body(ies), and be based on sound portfolio management principles.
18.1. The investment policy should guide the SWF’s financial risk exposures and the possible use of leverage.
18.2. The investment policy should address the extent to which internal and/or external investment managers are used, the range of their activities and authority, and the process by which they are selected and their performance monitored.
18.3. A description of the investment policy of the SWF should be publicly disclosed.
TWF’s investment policy is fully aligned with its mandate and strategic objectives, which are defined under Article 1 of Law No. 6741 and publicly disclosed on its official website. This clear articulation of purpose provides a solid foundation for a coherent and disciplined investment strategy.
Besides, as per its Social Investment Policy, which was published in 2025, TWF prioritize societal benefit and the United Nations Sustainable Development Goals in its investment decisions and operations, and to set out the fundamental principles governing such approach.
TWF’s governance framework, established under Law No. 6741, the Presidential Decree, the Articles of Association of TWF ManCo and TWF’s Bylaws, ensures that all investment decisions are made in accordance with sound portfolio management principles and are aligned with the TWF’s risk tolerance and long-term strategic goals. All investment activities are conducted in-house through the TWF’s dedicated investment teams. External managers are only engaged on a project-specific basis to provide advisory services where specialized expertise is required.
As required under Article 18 of the Decree, TWF publishes its annual reports on its official website. These reports provide transparency on investment activities, financial performance, and asset allocation, thereby supporting public accountability and consistency with TWF’s investment policy.
Furthermore, in July 2022, the Board adopted a Sustainability Policy to formally integrate ESG (Environmental, Social and Governance) factors into the investment decision making processes and activities. The policy, which is publicly available, reinforces TWF’s commitment to responsible and forward-looking investment practices. Independent Limited Assurance Opinions were obtained for 26 key environmental and social performance indicators covering both the TWF ManCo and TWF’s portfolio companies. Together, these practices demonstrate that TWF’s investment policy is clearly defined, publicly disclosed, and implemented in a manner consistent with its strategic objectives and prudent portfolio management standards.
Principle 19
19. The SWF’s investment decisions should aim to maximize risk-adjusted financial returns in a manner consistent with its investment policy, and based on economic and financial grounds.
19.1. If investment decisions are subject to other than economic and financial considerations, these should be clearly set out in the investment policy and be publicly disclosed.
19.2. The management of an SWF’s assets should be consistent with what is generally accepted as sound asset management principles.
TWF seeks to maximize the value of its portfolio assets and the return from its investments in accordance with its approved mandate. Investment decisions are primarily based on economic and financial grounds and are aimed at achieving optimal risk-adjusted returns, consistent with TWF’s long-term objectives. TWF’s governance framework establishes a clear separation between ownership oversight and operational execution, ensuring that investment decisions are taken with due care and diligence.
TWF ManCo’s operational management team comprises experienced investment professionals who carry out comprehensive due diligence and pre-feasibility processes before any investment decision is made. These processes are essential to identifying commercially viable opportunities and mitigating risk in alignment with sound asset management principles.
TWF ManCo manages TWF’s assets transparently and on a commercial basis, in line with the approved mandate. To ensure this, investment evaluation follows a structured approach comprising the following phases:
- Conducting research and due diligence on projects and investment opportunities,
- Carrying out pre-feasibility analyses for selected projects or opportunities,
- Conducting detailed assessment with the support from external expert advisors, and
- Managing the contracting process and facilitating final approval procedures.
It should also be noted that, as articulated in the Social Investment Policy, every investment decision should incorporate environmental, social, and governance principles into its decision-making processes. The Sustainability Policy also guides TWF on how to integrate ESG (Environmental, Social and Governance) principles into the investment processes.
TWF’s investment activities and performance are publicly disclosed through its annual reports, which include financial statements, ESG metrics, and portfolio developments. In addition, disclosures are made to the Public Disclosure Platform (KAP) when required, further strengthening transparency and accountability.
Principle 20
20. The SWF should not seek or take advantage of privileged information or inappropriate influence by the broader government in competing with private entities.
TWF is committed to complying with the relevant Principle.
TWF does not possess or have access to any privileged information through the government that could distort competition in the market or provide an unfair advantage over other private entities.
TWF strives to act with accountability, discretion, and transparency in all of its business and operational activities. These principles are embedded in TWF ManCo’s decision-making processes to ensure alignment with internationally recognized corporate governance standards.
Principle 21
21. SWFs view shareholder ownership rights as a fundamental element of their equity investments’ value. If an SWF chooses to exercise its ownership rights, it should do so in a manner that is consistent with its investment policy and protects the financial value of its investments. The SWF should publicly disclose its general approach to voting securities of listed entities, including the key factors guiding its exercise of ownership rights.
With a primary focus on enhancing the value of assets, alongside other key investment goals such as providing equity to strategic investments in Türkiye, making equity investments to support Türkiye’s international economic objectives, and reinforcing the improvement and deepening of financial markets, TWF is represented on the Board of Directors of its portfolio companies to monitor and evaluate their financial performance indicators. When necessary, TWF may exercise its ownership rights to safeguard its interests, as appropriate.
The members of the Boards of Directors of the portfolio companies are publicly disclosed through the Trade Registry Gazette.
With respect to listed entities within its portfolio, TWF acts in accordance with the applicable laws and regulations.
Principle 22
22. The SWF should have a framework that identifies, assesses, and manages the risks of its operations.
22.1. The risk management framework should include reliable information and timely reporting systems, which should enable the adequate monitoring and management of relevant risks within acceptable parameters and levels, control and incentive mechanisms, codes of conduct, business continuity planning, and an independent audit function.
22.2. The general approach to the SWF’s risk management framework should be publicly disclosed.
All risk-related matters, both financial and operational, are overseen by the Board through the Early Detection of Risk Committee, established under Article 19 of Decree. The Committee is responsible for identifying risks that may endanger the existence, development, and continuity of the TWF ManCo at an early stage, ensuring the implementation of necessary measures in response to identified risks, and managing those risks effectively.
Pursuant to Article 10 of the Decree, a risk management system shall be established, and also Article 19 of the Decree mandates the establishment of the Early Detection of Risk Committee. Furthermore, in accordance with Article 16 of the AoA, the relevant committee is responsible for the early detection of risks, the implementation of necessary measures related to identified risks, and the overall management of these risks.
All related documents are publicly available: The Risk Appetite Policy, Risk Acceptance Policy, and Operational Risk Policy.
These policies set out the framework for determining TWF’s risk appetite, cascading it throughout the organization in a top-down approach, and monitoring compliance. The targeted risk level for each significant risk type is defined in line with TWF’s risk capacity and its strategic objectives. To support the identification, assessment, and management of risks, TWF has adopted key risk management policies, including Risk Appetite Policy, Risk Acceptance Policy and Operational Risk Policy. These policies set out the framework for determining TWF’s risk appetite, its top-down transfer and follow-up within TWF. The targeted risk level for each significant risk type is defined in line with TWF’s risk capacity and its strategic objectives.
The Risk Management unit reports monthly to the Early Detection of Risk Committee, providing insights considering evolving economic indicators.
In addition, TWF’s annual integrated report has a dedicated section on risk management.
TWF’s approach to risk management is versatile and dynamic. Risks are carefully identified and managed within our established risk tolerance framework, covering the following areas:
- Portfolio Investment Risk
- Interest Rate Risk
- Liquidity Risk
- Currency Risk
- Legal and Compliance Risk
- Operational Risk
- IT Risk
- Counterparty Credit Risk
- Reputational Risk
- People Risk
In addition, TWF is subject to independent external audit.
Principle 23
23. The assets and investment performance (absolute and relative to benchmarks, if any) of the SWF should be measured and reported to the owner according to clearly defined principles or standards.
TWF is committed to transparency and accountability and publishes its annual and financial statements regularly through its website, in accordance with Article 18 of the Decree.
Since the reporting period related to the 2021 activities, TWF has published its annual integrated report in alignment with International Integrated Reporting Framework, and in compliance with Global Reporting Initiative (GRI) Standards.
The annual integrated report presents TWF's assessment and reporting of both the financial and ESG (Environmental, Social and Governance) performance of its portfolio companies. It outlines the investment measurement approach and explains how it aligns with TWF’s long-term value creation strategy.
This report also includes key financial ratios such as profitability, liquidity and leverage metrics, providing a comprehensive view of financial performance.
In addition, the established audit framework is an important mechanism that supports accountability and transparency in the institution.
Principle 24
24. A process of regular review of the implementation of the GAPP should be engaged in by or on behalf of the SWF.
TWF’s relevant departments prepare and regularly review the implementation of the Generally Accepted Principles and Practices (GAPP).
