Dear valued members of the investigation commission of the TBMM (Turkish Grand National Assembly), dear Ministers, As part of your investigation, you listened to ErtanÇomaklı, who is the expert witness for the report that constituted the pretext to appoint trustees to the KozaIpek Group. He advised the members of the TBMM commission not to be deceived too easily.
As it is essential that you are correctly informed for this historic task of yours, I have felt obliged to go so far as to convey to you some information about the KozaIpek Group.
I have listed and answered one by one, all the claims of this individual, which constituted the pretext for the court to appoint trustees, giving explanations between the lines.
I don’t want you to think that I have exaggerated;this is taken directly from the original report.
First and foremost, there are 3 reasons why KozaIpek was raided.
- 122 million TL was sent from Ereğli Iron and Steel to the Koza Foundation.
- 7 billion USD was siphoned abroad by bank transfer. In question was: the source and the control of this money and whether MASAK(Financial Crimes Investigation Board)had been informed of it.
- Donations of gold were collected and shown to have been produced at the mining plants.
As answers:
- Ereğli Iron and Steel and Akbank declared that no such transaction had ever taken place. It was documented. The subject was closed.
- It was discovered that a major tragic mistake had been made by adding up only the openings and not the closings of the accounts of the companies’ deposits in each three-month interest period. It was discovered that no such money was ever sent abroad and that this is a banking regulation. While taking into account that 7 billion USD is in fact Turkey’s total foreign investment, it came to light that it was not possible to send 7 billion USD abroad by bank transfer without MASAK being informed. By law, the banks have to inform MASAK.
- It was understood that in order to process scrap gold, donated gold in our case, it is necessary to have gold refineries and that no single refinery was present at any of KozaIpek’s plants. During the one-year management of the trustees, the gold production targets, which had anyway been set previously, were realized. If there isn’t a claim that the trustees collected donations of gold to enable them to meet the pre-planned production target, then this absurd claim has lost its validity.
The KozaIpekGroup is the second highest tax paying company in the private sector in Turkey.
Since the day our company was founded, besides being inspected regularly by all the relevant state bodies and institutions:the Ministry of Finance, the SPK(Capital Markets Board of Turkey), MASAK(Financial Crimes Investigation Board), and MIGEM (General Directorate of Mineral Research & Exploration); it has also beenregularly auditedby the SPK approved company, PwC (PricewaterhouseCoopers), one of the five biggest audit companies in the world, and it has been declared to the public and written in the reports at the end of every year that all the financial accountsare accurate and reflect the truth.
According to the law, independent audit companies are,like companies, responsible to the state and to all the investors. Our ore reserves have always been regularly inspected by an international engineering company,the SRK (earth and water resource services); reports have been issued;and those reports have been regularly published on our website ever since our company was founded.
The SRK report is regarded as an expert report for the wholeof the mining industry worldwide.
Metal analysis is done both in our own laboratories and in the international laboratories of ‘ALS’. Their accuracy is confirmed. According to these results, the feasibility is checked, the plant is designed and the process isdecided on. The whole mining world is agreed on the dependability of the ‘ALS’.
For the determination and confirmation of both the past and the future production of our ore reserves, 850 km ofborehole samples, which have been regularly analysed since our company was founded, are still kept at our plants. See addendum, the pictures of the borehole samples.
In international mining, if SRK approval is requested, it is compulsory to keep these borehole samples. (Koza requested this.)
Our accounting system has been configured to fit Turkish tax regulations; and it has been prepared in accordance with UFRS(International Financial Reporting Standards) for international investors; and it has been approved by responsible independent audit companies such as PwC.
The Ministry of Finance has inspected the financial accounts of our companies at least three times in the last two years. They have completed all their inspections and have reported that no irregularities have been detected.
According to the reports of the responsible independent audit companies, PwC and SRK, companies approved by the SPK, and all the official audit institutions of the state: theMinistry of Finance, the SPK, and MASAK, all our financial accounts reflect the truth.
All the money that comes to Koza Gold comes only from the gold stock market.
The tax was paid in full.
All the money taken out of the companies has been recorded and is lawful.
All the donations, as part of our feelings of social responsibility, are official and lawful. Since the day our company was founded, it has been declared to the public that according to the decision taken by the general assembly, at the beginning of every fiscal year, 2-3% of our income after tax is donated.
A percentage of the donations that was not given to our foundation was used to build schools which were donated tothe Ministry of Education and the rest was given to official state institutions.
Our foundation that belongs to the KozaIpek Group does not accept donations from outside.
The KozaIpekGroup’s Foundation founded IPEK UNIVERSITY which is a public institution. www.ipek.edu.tr
Ipek University does not accept donations from outside either. It was founded by the decision of theTBMM(Turkish Grand National Assembly). It is subject to the inspection of YOK (Council of Higher Education). Not one single problem was reported during the inspections by YOK and the General Directorate of Foundations. The university,which has not as yet had a graduate, was closed down by a KHK (Decree having force of law) in a day. No one has shown any justification or reason for this. No one has asked for any explanation or defence?
The income of our group all comes from its operations. The onlyincome coming from outside, is from the international public offering of Koza Gold Co. Ninety percent of the investors in this public offering are international companies.
Our group has no other source of income.
All official government institutions, the Ministry of Finance, the SPK(Capital Markets Board of Turkey), MASAK(Financial Crimes Investigation Board), MIGEM (General Directorate of Mineral Research & Exploration), and the international independent audit companies PwC (PricewaterhouseCoopers) and SRK have done and have completed numerous inspections and audits of our group of companies and statements of our financial accountshave been sentto national and international investors.