SENIM

Kazakhmys Group focuses efforts on supporting corporate culture demonstrating commitment to principles of good faith, transparency and integrity.

Since 2012, Speak Up Alert Reporting Service has been launched to sustain positive corporate image. This service aimed at identification and prevention of violations including fraud, corruption, discrimination, unethical behavior and etc.

It enables employees, partners, counterparts and other interested parties to report wrongdoing when suspected as well as request for clarifying information on issues concerned.

To ensure confidentiality and anonymity, all reports/appeals are collected and processed by a hotline operator who reporting on a daily basis and submitting reports/appeals for consideration to the Section on Legal Support of Anti-Corruption Policies, Legal Services Department.

At the same time, the hotline is not designed for the purposes of putting pressure on employees and counterparties and/or enforce them to commit/avoid some actions, as well as taking revenge/settling a score either.

Three options are available for legal entities and individuals to report wrongdoing: - to call to the free-of-charge hotline at 8-800-080-8089; - to send message to WhatsApp of Speak Up Service at +7 708 436 2058; - to send message to e-mail: speakup@kazakhmys.kz or to the office of Kazakhmys Corporation LLC.

Totally 159 appeals were registered in 12 months, 2024 by Speak Up Service (181 appeals in 12 months of 2023, a decrease of – 12.5%).

Out of 159 appeals (181 in 2023) - 153 (174 in 2023) were considered, 2 appeals (4 in 2023) are under consideration, 1 appeal was left without consideration (0 in 2023) on the basis of paragraph 6.1.4 of the Instruction (the essence of the issue is not stated, the full name of the employee of the Kazakhmys Group Company, whose actions are being appealed is not indicated and it is not possible to establish this information), 2 appeals (2 in 2023) were directed to jurisdiction, and for 1 appeal (1 in 2023)- the proceeding was terminated on the basis of paragraph 6.5.2 of the Instruction (written substantive answers have already been given on this appeal in connection with previously sent appeals, this appeal does not provide new arguments or circumstances).

Out of 153 considered appeals (174 in 2023) - 32 appeals (against 43) were satisfied.

The complainants reported violations related to occupational health and safety, labour discipline and internal regulations. They also raised concerns about bureaucratic delays in approving light-duty work transfers, breaches of professional ethics and conduct, bribery for employment, non-payment of funeral allowances, illegal storage of spare parts, shortages and embezzlement of copper products, unfair bonus distribution, and disputes over bonus amounts, challenging the validity of rejection of bids on the official website of “Kazakhmys Carrier” and competitive bids in tenders for procurement of goods, works and services.

According to the results of inspections 1 instruction on observance of safety and labour protection requirements was sent, 4 instructions on elimination of violations were made, shortage and embezzlement of used copper products in the amount of 6215.14 kg for the total amount of KZT 518,964.19 was revealed. 4 officials were brought to disciplinary responsibility, in respect of 8 persons the materials are under consideration, 4 persons were brought to material responsibility, labour contract with 2 persons was terminated, 1 letter on termination of labour contract is under consideration, 1 employee was transferred to light- duty work, one-time cash payment for funeral services in the amount of KZT 50,000 was made, assistance was provided in returning KZT 1.4 million received fraudulently for employment.

However, the arguments set out in the appeal do not always correspond to the actual circumstances, and are confirmed in the course of the inspection.

Thus, out of 153 appeals (174 in 2023) reviewed - 66 appeals (64 in 2023) were declined on disagreement with refusal of employment; suspension from work; concealment of an industrial injury; violations in the calculation of wage; assistance in taking tests for a financial reward; transfer of confidential information on price offers of suppliers to ‘selected’ companies; performance of functions not stipulated by job descriptions; disagreement with the decision to refuse to pay targeted social assistance.

For 55 appeals out of 153 considered appeals (67 out of 174 in 12 months 2023) clarifications were given on employment procedures, the work of the Kazakhmys Career website, professional examinations, remuneration for combining positions, withholding from wage for several writs of execution, transfer of alimony, payment of dividends, payment of penalties, issuance of archival certificates, reimbursement of expenses for inpatient treatment, provision of an individual rehabilitation programme for disabled people.

Out of 159 appeals received (181 in 12 months 2023): 67 appeals or 42, 1% (65 or 35,9% in 2023) - related to labor relations, occupational safety and health; 35 appeals or 22, 1% (45 or 24,9% in 2023) - concerning incorrect operation of the Kazakhmys Career website; 15 appeals or 9, 4% (11 or 6, 1% in 2023) - related to the actions of executives; 14 appeals or 8,8% (14 or 7,7% in 2023) - concerning non–compliance with Anti-Corruption Code (breach of business ethics standards and rules of conduct, non-compliance with the requirements of the Regulations for Conflicts of Interest Management, assistance in securing employment for monetary remuneration); 7 appeals or 4, 4% (9 or 5% in 2023) - related to organization of purchases of goods, works and services; 21 appeals or 13,2% (37 or 20,4%) related to other matters.

Across enterprises: Statistics of 159 (181 in 12 months 2023) appeals received by enterprises is as follows: Kazakhmys Corporation LLC – 91 appeals or 57,2% (133 or 73,5% in 12 months 2023); Kazakhmys Smelting LLC – 17 appeals or 10, 7% (20 or 11 % in 12 months 2023); Kazakhmys Distribution LLC – 16 or 10,1% (4 or 2,2% in 12 months 2023) Kazakhmys Energy LLC – 10 or 6,3% (3 or 1,7% in 2023) Kazakhmys Maintenance Services LLC – 5 or 3,1% (0 in 12 months 2023) Kazakhmys Coal LLC – 4 or 2,5% (1 or 0,6% in 12 months 2023) Zhanashyr Project LLC – 3 or 1,9% (5 or 2,7% in 12 months 2023) Maker LLC – 3 or 1,9% (1 or 0,6% in 12 months 2023) Qazaq Geophysics LLC - 2 or 1,3% (0 in 12 months 2023) Medical Center Zhezkazgan – 1 or 0,6% (2 or 1,1% in 12 months 2023) Other – 7 or 4,4% (12 or 6,6% in 12 months 2023)

Out of 159 appeals (181 in 12 months 2023) came to the hotline of Speak Up Service, the following groups are presented: Employees of Kazakhmys Group companies – 92 or 57,8% (81 or 44,8% in 12 months 2023); Candidates for vacant positions through “Kazakhmys Carrier” website – 35 or 22% (50 or 27,6% in 12 months 2023) Relatives of the employees and of candidates for vacant positions – 6 or 3,8% (22 or 12,2% in 12 months 2023); Counterparties – 9 or 5,7% (15 or 8,3% in 12 months 2023); Representatives of state authorities – 1 or 0,6% (3 or 1,6% in 12 months 2023) Others – 16 or 10,1% (10 or 5,5% in 12 months 2023).

33 appeals out of 159 appeals or 20,7% (35 out of 181 or 19,3% in 12 months 2023) are anonymous, among them 9 (11 in 12 months 2023) were confirmed. 20 appeals (13 in 12 months 2023) were not confirmed, for 2 appeals (8 in 12 months 2023) clarification was provided in corporate teams, 1 appeal (2 in 12 months 2023) is under consideration; 1 appeal (1 in 12 months 2023) – was sent within jurisdiction.

However, it should be noted that disclosure of appealer’s personal details significantly increased efficiency of settling the claims. On the contrary, it was less likely to examine all evidence due to anonymity. Timeliness, quality and completeness of their consideration are ensured for all appeals received by the Speak Up Service, and continuous monitoring is carried out in order to identify the facts of application of repressive measures to persons who have applied to the Speak Up Service.