Compliance with Legal Requirements

Kcell JSC was involved in two antitrust investigations initiated during the reporting period.:

1. On 15 June 2022, the Almaty Department of the Agency for the Protection and Development of Competition of the Republic of Kazakhstan initiated an investigation (Order No. 42-OD) under Part 1, Article 174 of the Entrepreneurial Code. The purpose of the investigation is to determine whether Kcell JSC engaged in conduct resulting in the maintenance of a monopolistically high price.
2. A second investigation was launched on 21 December 2023 (Order No. 38-OD) to assess whether Kcell JSC participated in coordinated actions with competitors to establish and maintain pricing for telecommunications services during the period from May to July 2023.

If these violations are confirmed, Kcell JSC may face administrative liability in accordance with Part 3, Article 159 of the Code of Administrative Offences, which provides for a fine amounting to 5 % of the revenue generated from monopolistic activity, as well as confiscation of the resulting unlawful income.