APPROACHES TO ENSURING HUMAN RIGHTS
GRI 2-23, GRI 2-24, GRI 2-25, GRI 2-26, GRI 3-3, GRI 406-1, GRI 408-1
Ethics and Integrity
The Company has a Code of Business Ethics (Code), updated in early 2025. The Code’s provisions are mandatory for all Company employees, including management, and apply to subsidiaries, affiliates, and affiliates, as well as business partners and contractors. The Code establishes the fundamental principles of ethical conduct that form the foundation of the Company’s corporate culture:
- Ethical conduct – adherence to high moral standards, respect for traditions, cultural differences, and applicable laws.
- Professionalism – continuous development of competencies, responsible job performance, and striving for excellence.
- Fairness and meritocracy – equal opportunities for all employees, transparent recruitment and promotion procedures.
- Respect – appropriate interaction with colleagues, partners, shareholders, government agencies, and other stakeholders.
- Openness – honesty and transparency in business processes, open information sharing, and constructive dialogue.
- Environmental responsibility – compliance with environmental standards and rational use of resources.
- Occupational health and safety – ensuring safe working conditions and minimizing the risk of accidents.
- Sustainable development principles – taking into account the long-term interests of the Company, society, and future generations.
- Prohibition of discrimination and harassment – zero tolerance for coercion, intimidation, or unethical behavior.
Compliance with the Code is monitored by the Company’s Compliance Service and Ombudsman’s Office. All employees are required to read the Code and confirm their agreement with its provisions. Violations of the Code may result in disciplinary action in accordance with internal policies and the laws of the Republic of Kazakhstan.
The Company ensures the availability of confidential and accessible mechanisms for reporting potential violations of the Code and guarantees protection from retaliation for good faith reporting, fostering an open and ethical corporate environment. The KMG Ombudsman actively works to clarify the Code’s provisions and addresses employee complaints regarding social and labor issues and ethical violations.
Mechanisms for submitting appeals and complaints
The company ensures accessible and transparent mechanisms for filing appeals and complaints, providing multiple channels for reporting violations, consultations, and tracking the status of considerations.
Main channels for submitting appeals
Compliance and Ethics Hotline
The KMG Compliance Hotline is independently administered by the international firm KPMG, ensuring impartiality in handling inquiries and protecting complainants. This channel is designed for reporting corruption risks, fraud, conflicts of interest, and other violations of corporate standards.
How to submit an appeal:
- Hotline: 8 (800) 080-47-47
- WhatsApp: 8 (771) 191-88-16
- Email: mail@sk-hotline.kz
- Internet portal: www.sk-hotline.kz
This channel accepts inquiries on the following issues:
- Suspicions of corruption, fraud and abuse
- Conflicts of interest of KMG employees and partners
- Violations of corporate ethics and anti-corruption policies
- Suspected of violating the law
The company guarantees confidentiality and protection of applicants from retaliation. Appeals are processed in strict accordance with international business ethics standards.
The process of registering and processing requests is fully automated: all messages from the hotline operator are forwarded in real time to KMG Group compliance officers for review.
On a quarterly basis, the Compliance Service informs the Audit Committee and the Board of Directors of KMG on the results of the review of requests received.
Unified centralized hotline “Nysana”
The Nysana hotline was created to receive inquiries on social and labor issues. The channel is accessible to both Company employees and third-party stakeholders who encounter potential violations.
How to contact:
- Hotline: 8 (800) 080-30-30
- WhatsApp: 8 (778) 120 99 11
- Email: nysana@cscc.kz
- Internet portal: nysana.cscc.kz
- Access via KMG’s internal corporate portal
You can use this channel to report:
- Violations in the field of labor protection and industrial safety
- Labor conflicts
- Other issues related to social and labor relations
The centralized hotline ensures prompt response, transparent review of complaints, and strengthening mechanisms for protecting employee rights within the KMG Group of Companies.
The hotline operates 24/7 and allows anonymous reporting. All reports are handled with due regard for confidentiality and the protection of the complainants.
Unified information system for citizen appeals E-Otinish
E-Otinish platform is a state digital system of the Republic of Kazakhstan designed for the submission of applications by individuals and legal entities. It provides a structured, transparent, and legally regulated process for reviewing applications and appeals.
Methods of submitting an application:
- Official website: https://eotinish.gov.kz
- E-Otinish mobile app (available in App Store and Google Play)
- Public Service Centers (PSCs) operating throughout the Republic of Kazakhstan
Key features of the system:
- Automatic registration of requests with assignment of a unique identification number
- Online tracking of the review status
- Receiving an official response within the timeframes established by law
E-Otinish platform helps increase the transparency of the application processing processes and ensure compliance with the regulated deadlines for consideration.
Statistics of requests
Compliance and Ethics Hotline
In 2025, the compliance hotline received 136 calls. The main topics of these calls related to corruption, labor disputes, and procurement procedures.
Incoming reports were reviewed, including the necessary investigations and factual analysis. Based on these findings, applicants were provided with feedback, and where warranted, corrective measures were taken.
Unified centralized hotline “Nysana”
During the reporting period, 87 inquiries were received through the Nysana communication channel regarding issues related to compliance with employee’s labor rights, working and living conditions, remuneration, relations with management, and other aspects of social and labor relations.
All appeals were reviewed, with the necessary checks conducted and official explanations provided within the established timeframes.
Unified information system for citizen’s appeals E-Otinish
In 2025, the Company received 1,115 requests from individuals and legal entities through the E-Otinish platform.
Regulations for handling appeals
The review of appeals received by KMG is carried out in accordance with the Regulations for the Review of Appeals, approved by the Board of Directors in 2024. This document establishes uniform requirements for the registration, analysis, and action taken based on the review of appeals.
Within the framework of the established procedure the following is ensured:
- mandatory registration of all requests, including messages received through the E-Compliance system;
- classification of appeals depending on their content (issues of corruption, business ethics, labor relations and other violations);
- identification of responsible people and formation of working groups if necessary;
- compliance with established review deadlines;
- application of the principles of objectivity, completeness of analysis, confidentiality and protection of applicants from persecution;
- providing feedback - informing applicants about the progress and results of the consideration of applications.
This procedure is aimed at creating a transparent and fair system for responding to requests, as well as strengthening trust on the part of employees and other stakeholders.
Protection of human rights
KMG recognizes the importance of respecting and protecting human rights, guided by international standards and national legislation. The Company undertakes commitments to ensure respect for human rights throughout its value chain and expects the same approach from its partners, suppliers, and contractors.
KMG bases its activities on the principles set out in the following international standards and instruments:
- the Universal Declaration of Human Rights;
- the International Covenant on Civil and Political Rights;
- the International Covenant on Economic, Social and Cultural Rights;
- the UN Guiding Principles on Business and Human Rights;
- the International Labour Organization Declaration on Fundamental Principles and Rights at Work;
- the UN Declaration on the Rights of Indigenous Peoples;
- the UN Voluntary Principles on Security and Human Rights;
- the UN Global Compact.
The Company recognizes the right to freedom of association and the right to safe working conditions, does not tolerate any forms of discrimination or exploitative practices, and respects the cultural characteristics of local communities in the regions of its operations.
The Company does not use child labor, does not practice forced labor, and ensures equal rights for all employees regardless of race, religion, or gender.
No cases of discrimination were recorded during the reporting period A.
KMG conducts assessments and monitoring of the potential and actual impact of its activities on human rights. The Company also ensures the availability of accessible channels for submitting complaints and reporting potential violations, including anonymous reporting mechanisms.
Diversity and inclusion
KMG adheres to the principles of equal opportunities, inclusiveness, and the creation of a working environment free from discrimination and bias. The Company recognizes that workforce diversity and an inclusive corporate culture contribute to improved performance and sustainable development.
Gender equality
- KMG supports equal opportunities for women and men at all management levels and seeks to ensure the full involvement of women across all areas of activity.
- The Company ensures equal pay for equal work.
- Initiatives are implemented to increase the representation of women in management positions, including by expanding the share of women in succession planning pools.
- Considering the specifics of the oil and gas industry, KMG applies measures to minimize health risks for women working in production environments.
Support for local personnel and socially vulnerable groups
- KMG actively engages local personnel in regions of operation, creating conditions for their professional development.
- The Company supports the employment of migrants and kandas (ethnic kazakhs who have returned to their historical homeland).
Inclusion of people with disabilities
- KMG strives to create comfortable working conditions for people with disabilities.
- The Company ensures workplace adaptation and provides information on assistive technologies and other tools aimed at improving employee mobility and creating a supportive working environment.
Fostering an inclusive corporate culture
- KMG promotes a workplace environment in which every employee feels accepted and respected.
- The Company develops internal training and awareness programs aimed at fostering respect for diversity and preventing discrimination.
KMG acknowledges that diversity and inclusion are not only elements of social responsibility but also key factors in enhancing competitiveness, operational efficiency, and innovation.
Occupational health and protection of employee’s rights
KMG ensures safe and healthy working conditions for all employees, which is an integral part of respecting and protecting human rights. The following measures have been implemented within the Company:
- Occupational health and safety policies aligned with international standards;
- Regular safety training programs;
- Monitoring systems to ensure compliance with safety regulations and mitigate workplace risks.
The Company respects employees’ rights to freedom of association and collective bargaining in accordance with the legislation of the Republic of Kazakhstan.
Prohibition of forced and child labor
KMG strictly adheres to a zero-tolerance policy regarding forced and child labor. The Company:
- Eliminates all forms of work performed under threat of punishment or against the will of the worker, in line with ILO Convention No. 29 on Forced Labor.
- Monitors compliance with labor standards both within the Company and among its suppliers and contractors
- Ensures that all employees work under voluntarily signed employment contracts and have the right to terminate their employment in accordance with applicable legislation.
Consideration of appeals and human rights monitoring
KMG has implemented a multi-level appeals and complaints submission mechanism, which includes:
- hotlines and anonymous reporting channels;
- the Ombudsman and Compliance Service, ensuring impartial and independent review of complaints.
Implementation of the human rights policy
To ensure effective implementation of its human rights policy, KMG undertakes the following measures:
Training and raising awareness
- KMG regularly provides training to employees on human rights compliance, including the principles of diversity and inclusion;
- Conducts awareness initiatives for employees, suppliers, and contractors.
Risk assessment and management
KMG conducts periodic assessments of risks related to potential human rights violations and develops response measures. The Company applies the principle of human rights due diligence in its operations and value chain.
Transparency and reporting
- KMG discloses information on the implementation of its human rights policy in non financial reports, following international reporting standards;
- The effectiveness of human rights compliance measures is monitored, and corrective actions are taken when violations are identified.
Stakeholder engagement
- the Company actively engages with public authorities, non governmental organizations, and international organizations on human rights matters;
- Conducts public hearings and consultations with local communities when implementing projects.
- KMG views the implementation of its human rights policy as a dynamic process that requires continuous improvement in line with leading international practices.