OUR OFFICES

1. THE PURPOSE OF THE DOCUMENT

1.1. The present Anti-Corruption Policy (hereafter - Policy) is a core document of WPK Company (hereafter - Company), defining the key principles and requirements aimed at the prevention of corruption and the observance of the standards of the effective anti-corruption legislation by the Company, its divisions, employees and other persons who may act on behalf of the Company.

1.2. The Policy was prepared in accordance with the legislation of the Republic of Kazakhstan, the Charter and other internal documents of WPK Astana LLP, taking into account the requirements of the RoK Law "On Anti-Corruption Efforts" (No.267-I dated 02.07.1998).

2. THE PURPOSE OF THE POLICY

2.1. The Policy reflects the commitment of the Company and its management to the high standards of transparent and fair business conduction for improving the corporate culture, following the best practices of corporate management and sustaining the business reputation of the Company at the appropriate level.

2.2. The Company sets the following goals:

• to minimize the risk of the Company and its employees', notwithstanding the position in the Company (hereafter referred to as the Employees), being involved in corrupt activity.
• to form the uniform understanding of contracting parties, the Employees and other persons of the Company's policy on the non-acceptance of any form and display of corruption.
• to generalize and explain the main requirements of the anti-corruption legislation of the Republic of Kazakhstan that can be applied to the Company and the Employees.
• to set the obligation for the Employees of the Company to know and observe the principles and the requirements of the present Policy, the key norms of the applied anti-corruption legislation, as well as the adequate procedures for preventing corruption.

3. APPLICATION AND OBLIGATIONS

3.1. All Employees of the Company shall follow the present Policy and strictly observe its principles and requirements.

3.2. The top executive of the Company shall be responsible for the organization of all measures aimed at the realization of the principles and requirements of the present Policy, including the appointment of persons responsible for the development of anti-corruption procedures, their implementation and control.

3.3. The principles and requirements of the present Policy are applied to the contracting parties and the representatives of the Company, as well as other persons, when such obligations are stipulated in the contracts with them, in their internal documents or resulting directly from the law.

4. THE APPLIED ANTI-CORRUPTION LEGISLATION

4.1. The Anti-Corruption Legislation of Kazakhstan: the Company and all Employees shall observe the norms of the RoK Law "On Anti-Corruption Efforts" (No.267-I dated 02.07.1998), the main requirements of which are:

• bribery prohibition, i.e. a provision or promise to provide any financial or another benefit/advantage with the intention of making any person fulfill his/her job duties improperly;
• prohibition of bribe acceptance, i.e. accepting or agreeing to accept any financial or other benefit/advantage for the improper fulfillment of job duties;
• prohibition of corrupt payments to state officials, i.e. a provision or a promise to provide (directly or through any third parties) to a state employee any financial or other benefit/advantage with the purpose of influencing his/her performance of official duties for receiving/ensuring competitive or other advantages for a commercial organization;
• prohibition of connivance in bribery, i.e. non-availability in the commercial organizations of the adequate procedures for the prevention of the giving or accepting bribes by persons connected with such organization for the acquisition or sustenance of a business, for ensuring any commercial and competitive advantages.

Taking into account the abovementioned, all Company Employees are strictly forbidden to participate directly or indirectly, personally or through any third parties, in any corrupt activities, to offer, give, promise, ask and accept bribes or make payments for facilitating any administrative, bureaucratic and other formalities in any form, including, in the form of cash, valuables, services or other benefits to any persons and from any persons and organizations, including commercial organizations, government and public authorities, state employees, private companies and their representatives.

5. KEY PRINCIPLES

5.1. The Mission for the Top Management: The directors, managers and top executives of the Company shall form the ethical standard of intolerance to any forms or displays of corruption at all levels, thus, setting an example through their own conduct. The principle of intolerance to any forms and displays of corruption ("zero tolerance" principle) is set in the Company for all routine operations and strategic projects, including interactions with shareholders, investors, contracting parties, and representatives of the state authorities.

5.2. Adequate Anti-Corruption Procedures: The Company develops and implements adequate procedures for the prevention of corruption that are reasonable for the detected risks and controls their observance.

5.3. Inspection of Contracting Parties: The Company applies all reasonable efforts for minimizing the risk of business relations with contracting parties that can be involved in corruption activities. For this, the assessment of the contracting party's tolerance towards bribery is conducted, including the inspection of the availability of their own anti-corruption policies and procedures, their readiness to observe the requirements of the present Policy and include anti-corruption clauses in their contracts, as well as to render mutual assistance for ethical business conduction and prevention of corruption.

5.4. Informing and Trainings: The Company publishes the present Policy on its corporate website with free access, openly declaring its intolerance towards corruption, welcoming and encouraging the observance of the principles and requirements of the present Policy by all contracting parties, its Employees, and assists in improving the level of anti-corruption culture by way of information provision and training.

6. GIFTS AND REPRESENTATION EXPENSES

6.1. The gifts and representation expenses, including expenses on business hospitality, that Employees may give on behalf of the Company to other persons or organizations, or that Employees may receive in connection with their job in the Company from other persons and organizations, shall correspond to the following criteria:

• shall be directly connected with the legal purposes of the Company's operations, for example, with the presentation or conclusion of a business project, arranging conferences, successful fulfillment of contracts, or with such public holidays as Christmas, New Year, International Women's Day, memorable dates, anniversaries;
• shall be reasonably justified, ratable and shall be luxury;
• shall not be a disguised compensation for services, an action, failure to act, connivance, protection, provision of rights, making a particular decision on a transaction, agreement, permit, etc. and shall not be an effort for influencing a receiving part with other illegal or unethical purpose;
• shall not create any reputation risk for the Company, the Employees and other persons, in case of disclosing information on gifts or representation expenses;
• shall not contradict to the principles and requirements of the present Policy, the Code of Ethical Conduct, other internal documents of the Company and the standards of applicable legislation.

6.2. Gifts in the form of souvenirs (inexpensive goods) with the symbols of the Company presented at exhibitions, open presentations, forums and other representation and marketing events, in which the Company participates officially, are allowed and are considered as image materials.

6.3. Gifts on behalf of the Company, its Employees and representatives of third parties in the form of monetary funds, cash or non-cash, in any currency are not allowed.

7. INTERACTIONS WITH THE STATE EMPLOYEES

7.1. The Company refrains from payment of any expenses for state employees and their close relatives (or in their interests) for obtaining any commercial advantages in particular projects of the Company, including expenses for transportation, accommodation, meals, entertainment, PR campaigns, etc., or any other benefits received at the Company's expense.

8. INTERACTIONS WITH THE EMPLOYEES

8.1. The Company requests that all its Employees to comply with the present Policy by informing them of the key principles, requirements and sanctions, in cases of violations.

8.2. The observance by the Employees of the Company of the principles and requirements of the present Policy is taken into account when forming the staff reserve for promotions and for imposing disciplinary penalties.

9. RESPONSIBILITY FOR FAILURE TO OBSERVE (IMPROPER OBSERVANCE) THE PRESENT POLICY

9.1. The Directors, Managers and Employees of the Company, notwithstanding their position in the Company, shall be personally responsible for observing the principles and requirements of the present Policy, as well as for acts (failure to act) of their subordinates violating such principles and requirements.

9.2. Due to the fact that the sanctions can be applied to the Company for the participation of its Employees or contracting parties in corruption activities, official investigations within the limits permitted by the applicable legislation shall be initiated on the basis of any reasonably justified suspicion or a detected fact of corruption.

Introduction

The present Code of Business Conduct and Ethics of WPK Company (hereafter - Company) embodies the general rules and effective provisions that shall be observed by all Company employees continuously, consciously and accurately.

The purpose of the present Code is to demonstrate the importance of responsible conduct by the employees to the Company. By constantly complying with the requirements of the present Code, the managers shall set an honorable example for other Company employees.

The management made a decision to apply this Code to the full extent and undertakes to make it an important part of the Company's business practice.

The rules and standards described in the present Code shall be used as a guide in all operations of the Company, as well as in all interactions with our clients and business partners.

The observance of the present Code and other key valuables, such as honesty, fairness, transparency and responsibility, corresponds, not only to our requirements, but to the international standards as well.

Each employee of the Company shall know the Code, shall understand it and shall observe it. The Code is not only a part of the job description, the observance of which is the primary responsibility of all Company employees with no exceptions.

Each of us is responsible for the correspondence of our own actions and decisions to the requirements of the present Code, and also shall put the interests of the clients and partners, as well as the interests of the Company above their own interests. This is fundamentally important for maintaining the impeccable reputation of our Company.


THE PRINCIPLES OF THE POLICY

Observance of the Effective Legislation

The Company expects its employees to strictly comply with the effective legislation and regulatory legal acts. Each employee bears personal responsibility for the observance of the laws applicable to their operations. Notwithstanding the sanctions stipulated by the law, any violation results in disciplinary sanctions within the Company, regardless of the position of an employee in the Company. The managers shall also eliminate the possibility of the violation of the legislation or the present Code within the area of their responsibility.

Fair Competition

Each employee uses his/her best efforts to carry out interactions with clients, business partners, competitors, and colleagues on the basis of fairness, honesty, transparency and openness.

At that time, the Company acknowledges the main principles of economy, observes the corresponding laws, rules and regulations and does not allow any unethical or dishonest acts towards its competitors.

Bribes, Corruption, Gifts

The Company employees are strictly forbidden to participate directly or indirectly, personally or through any third parties, in any corrupt activities, to offer, give, promise, ask and accept bribes or make payments for facilitating any administrative, bureaucratic and other formalities in any form, including, in the form of cash, valuables, services or other benefits to any persons and from any persons and organizations, including commercial organizations, government and public authorities, state employees, private companies and their representatives.

Conflicts of Interests

We realize that conflicts of interests can arise in the process of work. We undertake to take effective organizational and administrative measures for recognizing and settling such conflicts. Our purpose is to recognize, at the early stage, conflicts that can arise in the course of our operations, their settling or prevention. In case of possible or actual conflicts, the employees shall inform their line managers of such circumstances in time.

Confidentiality

The Company complies with the high standards on ensuring informational security, and we undertake to maintain in secret and protect data of our clients. We take particular care in the processing of personal information collection, processing and storing and observe the standards of information protection.

Attitude to Employees

We strive to raise the level of information available to the employees with regard to human rights. We respect and protect the personal dignity of each employee and we do not allow any impairment of rights with regard to our employees.

Relations with Clients

The Company acts in the interests of a client, not favoring one client over another. The operations in the company are conducted in such way that prevents the arising of a conflict of interest with clients and makes it possible to determine the ethical and legal responsibility to a client and ensure it to the fullest. We are flawlessly honest to our clients, and we strive to fully satisfy their demands. We build our relationships with clients on a trust basis. Such trust-based relations are considered by us as the highest value.

Relations with Suppliers

Agreements with suppliers shall be concluded and recorded in documents to the full extent and in unmistakable terms. Suppliers shall be chosen on a competitive basis only, after comparing the prices, quality, deadlines and effectiveness of the offered services.

Asset Protection and Their Use

The Company strives to protect its assets and to use with care the equipment and inventory belonging to the Company or transferred for its use. The Company takes measures for preventing loss, damage, theft or improper use of its property.

It is forbidden to use equipment and infrastructure for purposes other than work. We follow the highest standards of maintaining intellectual property, confidential information and information that is a commercial secret for observing the interests of the Company and the requirements of the legislation.

HSE

The Company realizes its responsibility for ensuring for all its employees safety at workplace and observes all effective standards on labor safety and protection of its employees' health. It is forbidden to damage the special equipment installed at the workplace for the protection of the health of employees and ensuring their well-being. All employees shall make efforts for preventing possible dangers for humans and the environment, preventing a possible negative impact on the environment and for using natural resources wisely.

Investments to Public Benefit

The Company strives to make a contribution to the social and environmental public benefit and motivates its employees to participate in charity projects.

Information provision and training

Information will be regularly provided to the employees on current issues related to the Code of Business Conduction and Ethics. The present policy of the Company is implemented and maintained by regular training, where the corresponding issues are discussed.

Each employee has a right to inform his/her manager on the circumstances pointing to a violation of the provisions stipulated in the Code of Business Conduction and Ethics. All information on possible violations shall be checked and the appropriate measures shall be taken.