Compliance

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The companies of the Fund group are an important part of the national economy, which imposes a special responsibility on the Fund. The Board of Directors and Management Board of the Fund have adopted a zero-tolerance policy for corruption in any form. Within the framework of leadership in this area, the Fund is creating tools aimed at preventing illegal actions among employees of the entire group of companies: approval of the Code of Conduct and Anti-Corruption Policy, establishment of anti-corruption compliance services, functioning of the centralized Hotline, 8 800 080 4747 that provide an opportunity to anonymously report any information about corruption and other violations.

The image of the Fund depends on each employee of the Fund group. The task of the Fund is to demonstrate high standards of ethics and rejection of corruption in relations with counterparties, public authorities and, of course, among themselves.

For any questions related to ethics and anti-corruption issues, please contact the Compliance Service, in case of violations, please contact the centralized Hotline.

Dauren Akshalov, Head of Compliance Service

Successful companies are built on trust. It is important for potential investors that the company conducts an honest and open business. Therefore, Samruk-Kazyna JSC builds its work in accordance with the best compliance practices on anti-corruption issues.

The Compliance Service in accordance with the Regulations on the Compliance Service of Samruk-Kazyna JSC is an independent structural unit, organizationally subordinate and functionally accountable to the Board of Directors of Samruk-Kazyna JSC.

The main purpose of the activity is implementation of the Compliance Program, determination of anti-corruption policy, as well as monitoring implementation of anti-corruption measures, including the assessment of corruption risks in Samruk-Kazyna JSC and its subsidiaries.

Compliance

(English) «conformance».

This function monitors the compliance of the company’s internal procedures with international and local regulatory standards. First of all, this concerns the fight against corruption based on the best international practice.

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Regulations on the Compliance Service of Samruk-Kazyna JSC

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Whistleblowing Policy of Samruk-Kazyna JSC

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Anti-Corruption Policy of Samruk-Kazyna JSC

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Policy on Settlement of the Conflict of Interest of Samruk-Kazyna JSC

Code of Conduct of Samruk-Kazyna JSC

The Code of Conduct of the Fund replaced the outdated Code of Conduct. The Code of Conduct is a more comprehensive document and, in addition to ethics standards, includes standards of conduct and duties of employees, questions and answers, as well as explanations.

The document was developed on the basis of internal assessment of compliance risks and in accordance with the principles of the Organization for Economic Cooperation and Development (OECD) on combating bribery and corruption and it is risk-oriented.

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Code of Conduct of Samruk-Kazyna JSC

Fundamental values of the Fund

Meritocracy

· We choose respected professionals.

· We give everyone, regardless of their role, the opportunity to speak out.

· We reward for achieving results.

Excellence

· We work rationally and according to the highest quality standard, using best practice and technology.

· We undertake to create added value.

· We are curious, we constantly learn and develop the Fund.

Respect

· We take care of everything that surrounds us.

· We act on the principles of trust and respect.

· We respect the laws and traditions.

Integrity

· We are loyal to our commitments.

· We do what we say.

· We are always fair and honest.

Team

· We work in the team and trust the team.

· We put team interests over personal ones.

· We build long-term and trusted relations with stakeholders.

Hotline of Samruk-Kazyna JSC

Samruk-Kazyna JSC (hereinafter – the Company) pays special attention to the development and maintenance of a corporate culture that demonstrates commitment to the principles of integrity, transparency and honesty.

In order to further maintain a positive image, Samruk-Kazyna JSC is pleased to announce the launch of a Hotline for timely detection and prevention of violations of legislation and/or the Code of Conduct, including cases of fraud, corruption, discrimination, unethical behavior and other violations related to the Company’s activities.

THE HOTLINE IS OPERATED BY AN INDEPENDENT OPERATOR, KPMG, ON THE FOLLOWING PRINCIPLES:

You can report any violations of the Code of Conduct, including corruption, discrimination, unethical behavior and other violations

WE GUARANTEE

confidentiality and anonymity (at the request of the person who applied)

of registration and processing of 100% of requests with subsequent provision to the responsible persons of the Company

APPEALS CAN BE PROVIDED BY ALL PERSONS IN RUSSIAN, KAZAKH AND ENGLISH THROUGH THE FOLLOWING COMMUNICATION CHANNELS:

by phone 8 800 080 4747 (Toll-free in the territory of the Republic of Kazakhstan),

to the email mail@sk-hotline.kz

via the internet portal www.sk-hotline .kz

via WhatsApp Messenger by number +7 771 191 8816

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