Compliance and anti-corruption management

1. Compliance-risk management

Anti-corruption compliance service of Baiterek NMH JSC is part of the corporate governance system and is responsible for compliance risk management – the risk of loss (material and reputational) as a result of non-compliance of Baiterek NMH JSC and its employees with the requirements of the legislation of the Republic of Kazakhstan.

The main functions of the Anti-corruption compliance service are coordination of compliance risk management, counteraction to corruption, prevention of conflicts of interest, consideration of applications of individuals and legal entities on violations of the requirements of the Code of Business Ethics, corruption and other unlawful actions.

2. Anti-Corruption policy

Baiterek NMH JSC, being the main financial agent of the Government of the Republic of Kazakhstan, is actively working to counteract corruption through the introduction of control functions to prevent and detect corruption, and the formation of an atmosphere of tough rejection of corruption in Baiterek NMH JSC in any of its manifestations.

For this purposes, Baiterek NMH JSC adopted an Anti-Corruption Policy, which includes a set of measures to combat corruption, as well as the formation of an anti-corruption culture of Baiterek NMH JSC employees, which ensures the observance of the principles of honesty and transparency in the performance of job duties.

The Holding Company's employees annually participate in training seminars on anti-corruption and anti-fraud issues, and are also tested on their knowledge of current anti-corruption legislation and internal documents of the Holding Company.

See the information on counteracting    corruption    in    the    Republic    of Kazakhstanon the following links: https://www.gov.kz/memleket/entities/qyzmet?lang=en and https://www.gov.kz/memleket/entities/anticorruption?lang=en

Analytical reference for corruption risks internal review.docx

3. Code of Business Ethics

Baiterek NMH JSC adopted the Code of Business Ethics, which provides a set of rules that establish the fundamental values and principles of corporate (business) ethics, which are guided by officials and employees of Baiterek NMH JSC.

Code of Business Ethics