Anti-Corruption Compliance

Kcell JSC has implemented a set of internal policies and procedures to support its anti-corruption compliance efforts. These include:

• Corporate Compliance Standard of the Samruk-Kazyna JSC Group;
• Regulation on the Compliance Control Service at Kcell JSC;
• Code of Ethics and Conduct of Kcell JSC;
• Anti-Corruption Policy of Kcell JSC;
• Conflict of Interest Management Policy of Kcell JSC;
• Internal Misconduct Reporting Procedure of Kcell JSC.

In 2024, as part of the regular update of compliance-related internal documents, the Internal Misconduct Reporting Procedure was revised to reflect the current requirements of both the Company and the Fund. Updates included the addition, consolidation, and clarification of guarantees provided to whistleblowers, as follows:

1. 1)   Full confidentiality for employees, business partners, and other stakeholders who report misconduct or violations;
2. 2)   Protection against retaliation or discrimination for individuals who report concerns;
3. 3)   Any act of retaliation or discrimination against whistleblowers will be treated as a disciplinary offense subject to appropriate action;
4. 4)   A zero-tolerance approach toward concealing evidence of misconduct;
5. 5)   Disciplinary measures will be taken against individuals who destroy or hide evidence of wrongdoing;
6. 6)   In some cases, anonymous reports may not be reviewed without additional information or follow-up from the reporting party. However, the Company will ensure the highest level of confidentiality possible;
7. 7)   Any employee who knowingly submits false or malicious reports for personal gain forfeits protection and may be subject to disciplinary action. All employees are expected to understand the consequences of violating this procedure.

The current numbers of the Fund’s hotline have also been added to the Instructions.

Requests can be provided through the following communication channels:

• by phone number 8 800 080 47. (within the RK territory a call is free);
• by e-mail mail@sk-hotline.kz;
• through an online-portal www.sk-hotline.kz;
• via WhatsApp Messenger by number: +7 771 191 8816.

The Job Descriptions of employees, developed in accordance with the Corporate Standard for the Compliance-function of Samruk-Kazyna JSC Group and other regulatory documents, were added in the form of appendix to the Regulations on the Compliance Control Service at Kcell JSC.

The main areas of work of the Compliance Service in the field of anti-corruption in 2024 were:

• Anti-corruption policy;
• Ethics and behavior in Company;
• Responsible purchases;
• Human rights;
• Conflict of interest management;
• Control in the field of compliance risk management.

The principles and procedures for combating corruption are outlined in Kcell JSC’s Anti-Corruption Policy. The purpose of the Policy is to minimise the risk of the Company’s officers and employees – regardless of their position – being involved in corrupt practices. The key objectives of the Policy include:

• Promoting a clear understanding among officers and employees of the Company’s zero-tolerance approach to all forms of corruption;
• Consolidating and clarifying the core requirements of Kazakhstan’s anti-corruption legislation as it applies to the Company and its staff;
• Establishing the obligation of all officers and employees to understand and comply with the principles and requirements of anti-corruption laws, the Anti-Corruption Policy itself, and to carry out appropriate preventative procedures;
• Developing and implementing effective anti-corruption measures aimed at preventing, detecting, and mitigating the consequences of corrupt activities.

Kcell JSC’s approach to anti-corruption is based on the following core principles:

• Compliance with the law in all Company activities;
• Transparency and openness in the Company’s operations;
• Raising awareness among employees, partners, and clients about anti-corruption practices;
• Cooperation with public authorities, business partners, and clients in preventing corruption;
• Mandatory internal investigations into any alleged violations of anti-corruption legislation or internal Company policies.

In line with the provisions of the Company’s Anti-Corruption Policy, Kcell JSC conducts annual identification and assessment of corruption risks, followed by the development of targeted mitigation measures. The objective is to detect business areas and processes most vulnerable to violations of anti-corruption laws, whether for personal gain or to benefit the Company.

In 2024, the Company conducted an internal analysis of corruption risks for the 2023 period, covering six departments and 14 business processes. As a result, nine corruption risks were identified, and 11 recommendations were developed to address and mitigate these risks.

Further to the internal corruption risk assessment, the Company developed and approved an Action Plan to eliminate the root causes and conditions contributing to potential corruption offences.

In November–December 2024, the Company underwent an independent certification audit and successfully confirmed the implementation of its Anti-Corruption Management System in accordance with the requirements of ST RK ISO 37001. In December 2024, the Company was awarded a state-recognised certificate of compliance with ST RK ISO 37001–2017 (ISO 37001:2016). The Compliance Service was responsible for the implementation of this system.

As of the end of the reporting period, no confirmed cases of corruption or bribery were recorded within the Company.

The Company conducts regular anti-corruption training for employees. All new hires are required to complete an introductory online course on the core principles of the Kcell Code of Ethics and Conduct and the Kcell Anti-Corruption Policy.

In 2024, the Company held nine anti-corruption training sessions, reaching 1,812 employees (83 % coverage), including 28 senior executives (6 members of the Management Board and 22 executives at the CEO-1 and CEO-2 levels), 511 mid-level managers, and 1,273 specialists.