Current ESG Profile of the Company

Strengths

Weaknesses

Opportunities

Threats

• Low greenhouse gas emissions
• Separate energy consumption accounting in data centers

• No established system for managing climate-related impacts or defining GHG emission reduction pathways
• No defined targets for waste utilization or disposal (e.g., recycling, landfill, incineration)
• No Environmental Policy currently in place
• No products or services currently classified as low-carbon offerings
• No procedure in place to monitor the Company’s impact on biodiversity

• Introduction of quantitative targets for environmental performance (e.g., waste reduction, GHG emissions reduction)
• Identification of products, activities, and services aligned with the UN Sustainable Development Goals (SDGs)
• Assessment of current biodiversity levels in the Company’s operational areas
• Consideration and evaluation of transitional climate risks (in line with TCFD recommendations)
• Attraction of green investments to finance GHG reduction initiatives

• High cost of low-carbon technologies
• Stricter environmental regulations, including those targeting the telecom sector
• Extreme weather events potentially damaging infrastructure and harming the Company’s reputation
• Reduced investment appeal due to insufficient disclosure of climate-related risks
• Missed opportunities resulting from the absence of an institutional and regulatory framework for climate-related projects

• Industry policy on freedom of expression in the telecommunications sector
• Well-developed occupational health and safety management system
• Robust employee feedback mechanisms
• Comprehensive employee social support system
• Risk register for workforce management with mitigation measures
• Extensive employee training and professional development programs
• Broad accessibility of ICT services across coverage zones
• Established system for individual and team-based performance management
• Company privacy policies ensuring data protectionх

• No formal process for assessing and managing human rights risks
• Absence of a collective bargaining agreement
• Lack of policies or mechanisms to manage diversity and prevent discrimination
• No initiatives to ensure gender pay equity
• No established policy for engagement with local communities
• Lack of long-term employee incentive programs
• Limited freedom of association
• Insufficient communication on personal data protection and privacy rights

• Advancing digital literacy through ICT
• Strengthening investment in human capital
• Increasing revenue through expanded online service offerings
• Implementing structured human rights risk management
• Deploying new applications and platforms to optimize resource use
• Addressing stakeholder demand with human rights–focused digital tools
• Introducing a human rights risk mapping framework
• Enhancing health and safety outcomes for employees and contractors
• Increasing the proportion of highly qualified personnel
• Supporting employee well-being and improving quality of life

• Macroeconomic factors leading to a decline in real household income
• Operational dependence on a single central communications hub in Almaty
• Tightening regulatory and legal requirements for ICT services

• High proportion of independent directors on the Board of Directors
• Existence of an Audit and Sustainability Committee under the Board
• Active participation in projects promoting the digital economy and access to information resources
• Diversified portfolio of products and services
• Sustainability principles are integrated into both operational and strategic activities through various corporate documents, including policies, codes, charters, the development strategy, and ESG roadmaps
• Clearly defined priorities in achieving the Sustainable Development Goals (SDGs)
• Established ESG goals and defined key performance indicators (KPIs)
• The Board of Directors and senior management are actively involved in sustainability matters

• Limited transparency in ESG disclosures
• Low representation of women on the Management Board and Board of Directors
• Dependence on government regulation and oversight
• Absence of a diversity policy for the Board of Directors specifying how diversity factors are considered in appointments
• Lack of disclosure regarding the CEO’s remuneration, the median employee remuneration, and the ratio between them
• Insufficient transparency in senior management compensation
• No disclosure of breaches of the company’s codes of conduct or ethics (e.g. corruption, discrimination)
• Absence of a formal ESG risk management system
• Employee performance evaluations do not include incentives linked to compliance with codes of conduct or reporting corruption

• Rapid technological change and innovation being successfully adopted by the Company
• Local economic growth creating a more favorable operating environment
• Attraction of investment through deeper ESG integration into operations
• Opportunity to expand market share by growing the customer base and strengthening market position
• Value creation through the design of new products and services incorporating sustainability principles
• Potential to achieve a high ESG rating by applying international standards such as GRI, IFRS S1/S2, and disclosing carbon footprint data via CDP
• Strengthening corporate social responsibility
• Leveraging international expertise and partnerships to enhance ESG practices and integrate them into business processes
• Leading by example in implementing an ESG supplier program that identifies and mitigates material ESG risks while offering development opportunities to suppliers

• Data security breaches due to unauthorized access or leakage of confidential information
• Geopolitical conflict, political instability, or structural changes in governance that could disrupt operations
• Increasing ESG-related regulatory pressure and investor scrutiny requiring significant attention and resources
• Potential international sanctions and trade restrictions
• Risk of reduced financial stability due to global economic slowdown, inflationary pressures, or liquidity challenges
• Legal disputes or litigation, particularly related to antitrust issues and data privacy, that may demand significant time and resources