Santiago Principles Self-Assessment

Türkiye Wealth Fund

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  • Pillar 1: Legal
  • Pillar 2: Institutional
  • Pillar 3: Investment
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 as ‘TWF’), Türkiye Wealth Fund Management Company (hereinafter referred as ‘TWF ManCo’), a joint-stock company subject to private law, was established with the Law No. 6741 published in the Official Gazette on 26 August 2016.The Decree of the Council of Ministers dated 17 October 2016 (hereinafter referred as the ‘Decree’) regarding the process and principles of 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.  The Law No. 6741 and the Decree are publicly available information under the Official Gazette of the Republic of Türkiye and TWF’s website.  

Putting aside the mainly formal and conceptual amendments directed to the harmonisation to constitutional changes related to adoption of presidential government system, some material amendments on “Exemptions and Exceptions” section of the Law No. 6741 were made with the law changing the Law No. 6741 adopted on 26 May 2022, published on 28 May 2022.

The current version of the Law No. 6741 can be reached at TWF’s website.

Following the Law No. 6741 and the Decree, TWF ManCo’s Articles of Association and TWF’s by-laws were also published in the Türkiye Trade Registry Gazette on 28 December 2016 and 30 January 2017 respectively. Some sections of the Articles of Association of TWF ManCo and by-laws of TWF were amended on 31 March 2021 and these amendments were published in the Trade Registry Gazette dated 5 April 2021.  

TWF is managed and represented by TWF ManCo, being said, according to the Article 5 of the Law No. 6741, assets and rights transferred to TWF shall be registered under TWF’s name. With the latest amendments which were published in the Official Gazette numbered 31849 and dated 28 May 2022, the wording in Article 8 of the Law No. 6741 has been aligned with the general structure of the Law No. 6741 and therefore the ambiguity related to whether TWF ManCo or TWF shall be the founder has been removed in the direction that TWF shall be the funding shareholder in the companies and sub-funds to be established. 

In accordance with the Law No. 6741, TWF may establish strategic partnerships. With the latest amendments published on 28 May 2022, it has been outlined for such partnerships that the companies and sub-funds to be established by TWF and/or TWF ManCo will benefit same exemptions and exceptions granted for such companies and sub-funds on the condition that TWF remains the controlling shareholder.

Pursuant to Article 14, paragraph 1 of the Articles of Association of TWF ManCo, Board of Directors should convene at least 6 times in a year. 

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 pursues highest standards of corporate governance for long-term value creation, contributing to sustainable economies, societies, and the environment. 


Following Article 6 of the Decree, the organizational structure and job descriptions are clearly defined. 

TWF’s Operational Management Team are responsible for;    

  • Conducting research and due diligence on projects/investment opportunities,  
  • Carrying out pre-feasibility analysis for the selected projects/investments,   
  • Conducting detailed analysis by getting support from expert advisors, and 
  • Contracting stage and final approval process. 


TWF’s Board provides final approvals and runs the execution.  

As per Article 19 of the Decree; Executive and Human Resources Committee, Corporate Governance Committee, Early Detection of Risk Committee and Audit Committee which are attached to the Board are established under the scope of Turkish Capital Markets Law No. 6362 in accordance with the corporate governance regulations.

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 mandate and strategic objectives are to enhance the value of assets within the Fund, to provide equity to strategic investments in Türkiye, to make equity investments in order to support Türkiye’s international economic objectives, to reinforce the improvement and deepening of financial markets which is disclosed on its website, gives a clear understanding of its investment policy. 

TWF received approval for its mandate by Board Resolution on 24 October 2018, and its strategic investment plan by its Board resolutions dated 17 April 2019. 

All investment decisions are subject to final approval by the Board and TWF will continue publishing its annual reports through its website as per Article 18 of the Decree.  

As of September 2022, TWF has drafted its ESG Policy which has been recently approved by its Board of Directors. The approved policy will be published on our website subsequently. The purpose of this policy is to establish a framework to govern TWF’s approach to ESG, which includes providing guidance on integrating ESG factors into TWF’s investment decisions and activities across its operations. The Policy is expected to be publicly disclosed and relevant sub-policies related to responsible investment are expected to be developed in the medium term.