Approach to Managing Environmental Responsibility Issues

Management approaches

GRI 3-3

Environmental responsibility is a key priority for KMG. The company is implementing a comprehensive set of measures aimed at improving environmental safety and gradually reducing its negative environmental impact.

KMG’s environmental policy is an integral part of the Company’s Development Strategy for 2022–2031 and is focused on achieving the long-term goal of preventing environmental damage (the “zero result” principle). This goal is achieved through the implementation of corporate standards, the use of modern technological solutions, the development of an environmental culture, and the continuous improvement of the environmental management system.

The key areas of the Company’s environmental activities are:

management of air pollutant emissions;
reduction of raw gas flaring volumes;
rational use and protection of water resources;
management of industrial waste and reclamation of disturbed lands;
biodiversity conservation.

KMG’s management and its subsidiaries and affiliates adhere to the principle of zero tolerance for environmental pollution. In its operations, the Company is guided by the requirements of the Environmental Code of the Republic of Kazakhstan and its own Environmental Policy, ensuring the systematic collection, analysis, and disclosure of environmental information.

Transition to the best available techniques

As environmental legislation in the Republic of Kazakhstan is being modernized, KMG is actively participating in the reform to transition to best available techniques (BAT). As part of this work, industry- specific BAT reference books have been developed for oil and gas production and processing. Companies classified as Category I facilities have begun obtaining integrated environmental permits (IEPs).

The KMG group, which falls under this regulation, includes the Atyrau and Pavlodar oil refineries, PetroKazakhstan Oil Products LLP, and KazakhOil Aktobe JSC. In April 2025, PetroKazakhstan Oil Products LLP received the IEP, the first oil and gas company to do so.

Environmental dialogue and stakeholder engagement

KMG actively participates in industry initiatives and maintains constructive dialogue with government authorities, industry associations, and the expert community.

On 30 May and 14 November 2025, two round table discussions were held in Astana. The events were attended by representatives of the Ministry of Ecology and Natural Resources of the Republic of Kazakhstan, the Ministry of Water Resources and Irrigation of the Republic of Kazakhstan, KMG subsidiaries, as well as international companies specializing in technologies aimed at minimizing negative environmental impacts.The participants discussed key environmental protection issues, including proposed amendments and additions to the Environmental Code and the Water Code of the Republic of Kazakhstan, advanced technologies for reducing pollutant emissions and discharges, and matters related to waste recovery and disposal. Attention was paid to KMG’s corporate and strategic objectives, the Company’s environmental policy, and greenhouse gas management.

Automated environmental monitoring system

In 2025, the Company continued its work on implementing the Automated Information System for Environmental Monitoring (AISEM), aimed at creating a unified digital environment for environmental protection. The project’s primary goal is to increase the transparency of environmental monitoring, minimize the impact of human error, and ensure prompt monitoring of compliance with environmental requirements.

The AISEM functionality includes automation of environmental reporting for government agencies, maintenance of permitting database, calculation of environmental payments, prompt identification of deviations from regulatory indicators, environmental monitoring as part of industrial environmental control, and the generation of corporate reports with integration into the HSE KMG system.

The implementation of the AISEM contributes to increased efficiency in managing environmental aspects of the Company’s activities and strengthens control over compliance with environmental legislation.

KMG applies a systematic approach to assessing the environmental impact of its business activities, ensuring the timely identification, analysis, and mitigation of potential environmental risks. As part of this approach, environmental assessments are conducted at all stages of new projects, with stakeholder input and an assessment of the potential impact on ecosystems.

Environmental assessment procedure and public participation

Environmental assessment involves a comprehensive analysis of the potential environmental impacts of planned projects and aims to identify and prevent potential negative consequences. A key element of this process is the consideration of stakeholder input, which is achieved through the following forms of engagement:

holding working meetings and consultations with representatives of interested parties;
collection of written and oral requests, suggestions and comments from the public;
organizing open meetings and public hearings.

All projects with a significant environmental impact are subject to mandatory public hearings with representatives of government agencies, non- governmental organizations, local communities, and other stakeholders. Public hearings are open, and their results must be recorded and published in open sources.

In 2025, KMG held 34 meetings with representatives of the public and organized 96 public hearings.

In November 2025, Atyrau Oil Refinery LLP was visited by deputies of the regional maslikhat, representatives of political parties, and members of the public. During the visit, the guests discussed with the refinery’s specialists the key areas of the enterprise’s environmental activities as well as its upcoming projects.

On 20 September 2025, Pavlodar Petrochemical Plant LLP hosted an off site meeting of the Mazhilis of the Parliament of the Republic of Kazakhstan Committee on Ecology and Natural Resource Management. The meeting addressed issues related to environmental safety in the Pavlodar Region. The visit served as an important platform for open dialogue on environmental safety matters, demonstrated the transparency of the enterprise’s operations, and confirmed the refinery’s commitment to responsible environmental management.

Updating internal corporate documents in 2025

In 2025, the following documents were approved in KMG’s internal regulatory documents:

List of identified environmental aspects, environmental risks and opportunities, and measures to reduce environmental impacts for 2025;
Roadmap for improving industrial safety, labor protection and the environment of the KMG Group of Companies for 2025–2027.
Standard for conducting environmental assessment in the KMG Group of Companies.

KMG is implementing “green office” principles aimed at the rational use of natural resources, reducing waste generation, and enhancing employee environmental responsibility. This approach includes a range of measures to reduce the environmental footprint of office activities and foster sustainable behavior patterns within the corporate environment. In 2025, efforts in this area were further strengthened through the “Taza Kazakhstan” environmental initiative.

Greening of office space

As part of the development of a separate waste collection system, a reverse vending machine for plastic bottles, aluminum cans, and glass containers is operating in the KMG building. Over 18,934 plastic bottles and approximately 3,548 aluminum cans were recycled during the reporting year. The total volume of containers collected in 2025 was 22,482 units.

The Company’s central office is equipped with eco- friendly bins and containers for the separate collection of paper, plastic, glass, metal, and used batteries. Additionally, special cabinets have been installed for the safe storage and recycling of fluorescent lamps.

In order to reduce resource consumption, a number of additional measures are being implemented, including:

automated reminders to employees to turn off office equipment at the end of the working day;
information materials aimed at reducing printing volumes and preserving forest resources;
development of electronic document management to minimize the use of paper;
greening of office spaces, including through a corporate initiative to give houseplants to colleagues on their birthdays instead of traditional bouquets.

To support environmentally friendly modes of transportation, KMG buildings are equipped with bicycle parking.

Environmental initiatives and employee engagement

KMG places special emphasis on engaging its employees in environmental initiatives. The Company runs a “Bring Your Own Tableware” campaign, offering discounts to employees who use reusable containers in coffee shops, cafeterias, and the office cafeteria.

In addition, starting in 2023, charging stations for electric vehicles have been operating in the KMG building on a pilot basis.

On June 5, 2025, as part of World Environment Day, KMG, with the support of the Earth Fund “Sustainable Development” and the Earth Ambassadors movement, held a master class for employees and their children, “The Future Starts Today”.

On December 11, 2025, with KMG’s support, a presentation of the environmental fairy tale series “Platon’s Magical Worlds”, created by 12-year-old author and creator Platon Nechayev, was held for employees’ children in Astana. The event’s goal was to promote environmental awareness among children and adolescents and support key environmental education initiatives within the KazMunayGas Group’s “Taza Kazakhstan” environmental campaign action plan. The event took place in a warm New Year’s atmosphere and brought together a wide range of participants: children, parents, representatives of government agencies, businesses, international organizations, and the creative community.

An eco-quiz was organized for the children, aimed at developing a caring attitude toward nature and practical knowledge about ecology. The program concluded with a creative workshop, PLATON 5D, during which the young participants created their own eco-heroes, defined their environmental missions, and presented their work.

KMG and its subsidiaries and affiliates traditionally support the international Earth Hour initiative, turning off lights and household appliances for one hour each year. In 2025, the Company again participated in the initiative, reaffirming its commitment to global efforts to reduce energy consumption and protect the environment.

KMG’s systematic activities in the area of landscaping and greening are aimed at improving the environmental situation and creating green zones in the regions where the Company operates.

Campaign “Taza Kazakhstan”

As part of the national environmental campaign “Taza Kazakhstan”, on March 26, 2025, an Action Plan for the implementation of the campaign in the KMG Group of Companies for 2025 was approved, including 13 events aimed at introducing environmental initiatives, developing an environmental culture among employees, and increasing the volume of greening.

In accordance with the approved schedule, in 2025, the KMG Group of Companies held 282 cleanup days with the participation of 9,287 people, during which more than 5,900 bags of waste were collected.

KMG continued its participation in a large- scale environmental greening initiative. The KMG Group’s tree planting plan for 2025 was 109,000 trees, with 113,700 trees planted by the end of the year. Additionally, in October 2025, 150,000 Scots pine seedlings were planted in the Kostanay region with KMG’s financial support. The total tree planting volume for the KMG Group in 2025 was 263,700 trees.

On October 18, 2025, the KMG Park in Astana officially opened, with 1,320 trees planted. Throughout the year, employees of the Company and its subsidiaries and affiliates actively participated in environmental campaigns, tree planting, and landscaping activities.

Environmental education and interaction activities with educational organizations

To enhance environmental awareness and awareness among its employees, KMG is consistently implementing a range of educational and awareness- raising initiatives. In 2025, the Company’s subsidiaries and affiliates implemented a series of events aimed at developing environmental education and engagement among employees, as well as schoolchildren and students:

open lessons and seminars for schools and universities on issues of air quality, waste management, water resources, carbon footprint and environmental aspects of industrial activities;
participation of representatives of KMG and its subsidiaries and affiliates in meetings and scientific and practical events dedicated to the implementation of innovative and environmental solutions in production;
conducting informational and educational seminars for students of specialized universities;
organizing environmental competitions and creative events among children of the Company’s employees;
holding thematic environmental events (such as Paper Free Day, Plastic Free Day, and the collection of used batteries and plastic caps for subsequent recycling);
implementation of internal communication activities on environmental and sustainable development issues, including newsletters and materials on the Green Office concept.

All events were covered through KMG’s internal and external communication channels.