Anti-Corruption and Bribery Policy

1.Objective of the Anti-Corruption and Bribery Policy:

The company's policy is rooted in the fight against corruption and bribery. It aims to conduct business with clients in accordance with moral standards and honest practices. The company has zero tolerance for bribery and corruption, and is committed to conducting its affairs honestly, openly, and with full responsibility.
The primary goal of our policy is to actively support all laws aimed at countering bribery and corruption. We firmly adhere to and comply with the laws of the United Kingdom, including the Bribery Act of 2010, both within the country and abroad. We fully understand and strictly adhere to anti-corruption laws, such as the U.S. Foreign Corrupt Practices Act, the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions, as well as other local laws aimed at combating corruption and bribery.
The company collaborates only with verified and reliable individuals and organizations. Before establishing business relationships with partners, a comprehensive legal check of counterparties is conducted, and measures are taken to ensure adequate protection for the company.
Abuse of position and corruption are crimes that carry penalties for individuals, including up to ten years of imprisonment. In case of a breach of this policy, individuals may face fines without limitation. Additionally, we reserve the right to terminate further collaboration with business partners in the event of a violation or non-compliance with the terms of this policy. We take the issue of legal responsibility seriously and insist on a similar commitment to legal responsibility from our partners.
In this policy, a third party refers to any individual or organization with whom we interact in the course of our work. This includes both actual and potential clients, buyers, suppliers, distributors, business partners, agents, consultants, representatives of government and public bodies, their advisors, officials, politicians, and political parties.

2.Bribery:

Bribery refers to rewards, promises, guarantees, or benefits provided to obtain any commercial, contractual, regulatory, or personal advantage.
Company employees are prohibited from accepting such offers. Accepting an offer is a violation of the law, as it constitutes personal gain.

3.Gifts and Hospitality:

The policy does not restrict normal and appropriate hospitality (given and received) to or from third parties.
The giving or receiving of gifts is not prohibited, provided the following conditions are met:
It is not done to influence a third party for the purpose of obtaining or retaining business or commercial advantages, including rewards for maintaining business relationships, and as an explicit or implicit exchange for benefits.
It complies with local legislation.
It is addressed to the company.
It does not involve cash or cash equivalents (e.g., gift certificates or vouchers).
It is appropriate given the circumstances. For example, in the UK, small gifts are customary during Christmas.
Consideration is given to the reasons for the gift, its value, and the timing of its presentation.
It is openly given, not secretly.
The company understands that the practice of corporate gifts varies depending on the country and region and what may be acceptable in one region may be unacceptable in another. Verification should be conducted in all cases, even if the gift or hospitality is reasonable and justified. The purpose of the gift should always be taken into account.

4.What is Unacceptable:

This is unacceptable for the Company, as well as for partners (or individuals representing the company or on behalf of partners):
to give, promise, or offer any payments, gifts, or hospitality with the expectation or hope of obtaining commercial benefit, or to reward someone with benefits that have already been provided;
to give, promise, or offer any payments, gifts, or hospitality to government officials, agents, or representatives with the aim to "facilitate" or expedite routine procedures;
to accept payments from third parties if the Company knows or suspects that the amount is provided with the intent of obtaining commercial benefit;
to accept a gift or hospitality from a third party if it is known or suspected that it is offered or provided with the expectation that business advantages will be granted in return;
to threaten or take retaliatory measures against another employee who refused to bribe or expressed concern within the scope of this policy;
to engage in any activity that may violate this policy.

5.Rewards for Facilitating Payments and Kickbacks:

The company does not make or accept "facilitating payments" or "kickbacks" of any kind. Facilitating payments typically consist of small unofficial payments made to ensure or expedite routine actions.
"Kickbacks" are usually payments exchanged for profit or business advantages. All employees must avoid any activity that could lead to facilitation payment or kickback being made or accepted by us.

6. Donations:

The company does not make donations to political parties. The company may make charitable donations in accordance with local laws and practices. No donations are offered or organized without prior approval from the head of the oversight department.

7.Responsibilities:

Prevention, detection, and reporting of bribery and other forms of corruption are the responsibility of everyone working for the Company or under its control. All employees are obligated to avoid any actions that may lead to a violation of this policy.
In the event of such a circumstance, if there is a fact or suspicion that a conflict with this policy has occurred or may occur in the future, it must be reported immediately. For example, if a partner or potential partner offers a deal involving a gift or money to secure future collaboration with the Company for a business advantage.

8.Protection:

The company's management ensures that no employee will suffer as a result of refusing to participate in bribery or corruption, or due to their suspicions that actual or potential corrupt offenses have occurred or may occur in the future. Corrective measures include dismissal, disciplinary actions, reprimands, or other unfavorable actions.

9.Potential Risk Scenario: "Warning Signs"

Below is a list of possible "warning signs" to be attentive to during work or partnerships, which may raise concerns under various anti-corruption laws. The list is not exhaustive and is provided solely for informational purposes:
You become aware that a third party is engaged in or has been accused of involvement in illegal business activities.
You learn that a third party is suspected of giving or receiving a bribe, or that it enjoys a "special relationship" with foreign officials.
The third party insists on payment of commissions or fees before signing a contract for contracting or performing government functions for us.
The third party demands cash payment and/or refuses to sign an official commission agreement or agreement, or requires an invoice or payment receipt.
The third party demands payment to be made to a country or geographic region different from its residence or business operation.
The third party demands an unexpected additional payment or commission for the "facilitation" of services.
The third party demands entertainment or gifts before the conclusion or continuation of contract negotiations or service provision.
The third party demands payment for "ignoring" potential legal violations.
The third party demands that you secure a position or other benefits for a friend or relative.
You receive an invoice from a third party that looks non-standard or individually made.
The third party insists on using additional agreements, or the party refuses to accept terms previously agreed upon in writing.
You notice that we have been invoiced for commissions or fees, and the payment exceeds the amount for the provided service.
The third party insists on involving an agent, intermediary, consultant, distributor, or supplier with whom we have not collaborated before.
You are offered an unusually generous gift or generous hospitality by third parties.
If you discover or encounter any warning signs or policy violations when working with us, you should immediately report it to any employee or associated person who may be concerned about such issues. You do not need to conduct an investigation on your own, but it is important that your concern is sincere, truthful, and free of malicious intent.
The company provides various ways for expressing concerns and reporting from employees and other associated individuals. An independent third party may be involved in this process. Associated individuals can send messages via email to compliance.officer@nscom.kz, ensuring confidentiality and security. Additionally, information and reminders about the opportunity to express concerns are provided through various communication channels. This includes the corporate website, where associated individuals can find all necessary contact information and guides for the reporting process. The company also conducts compliance training, educating employees and other associated individuals about the whistleblowing process and how they can safely and effectively use this tool. All these measures help build trust in the whistleblowing line and ensure that reports will be appropriately reviewed, and necessary actions will be taken in response.