Approved

by Order of the Director of “Akhmedsafin Institute of Hydrogeology and Geoecology” LLP

No. 04-03/30-OD

dated December 01, 2022

Anti-Corruption Standard of

“Akhmedsafin Institute of Hydrogeology and Geoecology”

Limited Liability Partnership

General Provisions

This Anti-Corruption Standard of “Akhmedsafin Institute of Hydrogeology and Geoecology” Limited Liability Partnership (hereinafter – the “Company”) (hereinafter – the “Anti-Corruption Standard”) was developed in accordance with Article 10 of the Law of the Republic of Kazakhstan “On Combating Corruption” dated November 18, 2015, the Methodological Recommendations for the Development of Anti-Corruption Standards approved by the Agency for Civil Service Affairs and Anti-Corruption of the Republic of Kazakhstan, and the Anti-Corruption Policy of “Akhmedsafin Institute of Hydrogeology and Geoecology” LLP, and is aimed at preventing corruption in the Company’s activities.

The developer of the Anti-Corruption Standard is the Legal and Human Resources Department.

The Anti-Corruption Standard is aimed at establishing, for a specific sphere of public relations, a system of recommendations aimed at preventing corruption.

The objectives of the Anti-Corruption Standard are:

  • to develop sustainable anti-corruption behavior in the relevant sphere of public relations;
  • to timely identify manifestations of corruption and prevent their negative consequences.

The principles of the anti-corruption standards are:

  • legality;
  • transparency;
  • ethical conduct;
  • respect for and protection of the rights and legitimate interests of individuals and legal entities from manifestations of corruption;
  • prevention of conflicts of interest.

Compliance with the Anti-Corruption Standard is mandatory for Company employees.

Anti-Corruption Standard

Officials and employees of the Company are obliged to:

  • accept the anti-corruption restrictions established by the legislation of the Republic of Kazakhstan and the Company’s internal acts;
  • when exercising the rights and legitimate interests of individuals and legal entities within the Company’s scope of activity, oppose any manifestations of corruption, prevent offenses that create conditions for corruption, and suppress any facts of corruption-related offenses;
  • upon receiving information about a corruption-related offense, take all measures to prevent and stop such an offense;
  • develop an anti-corruption culture in the performance of their official duties;

when preparing and making managerial and other decisions within their competence:

  • through their actions and decisions, avoid creating administrative or other obstacles that hinder individuals and legal entities from exercising their rights and legitimate interests. If such facts exist, take measures to eliminate them;
  • not use their official powers and related opportunities to obtain proprietary or non-proprietary benefits;
  • avoid conflicts of interest. If a conflict of interest arises, take measures to prevent and resolve it;

when preparing draft internal documents:

  • conduct analysis and expert review of adopted internal documents to identify corruption-related provisions that create preconditions for Company employees to commit corruption-related or other unlawful acts, and reflect appropriate preventive measures therein;
  • conduct anti-corruption monitoring and analysis of corruption risks in the Company’s adopted internal documents. If corruption-related provisions are identified, take measures to eliminate them;

7.7. in other relationships arising in the course of performing their duties:

  • by their conduct, serve as an example of impartiality, honesty, and integrity;
  • not engage in activities incompatible with the performance of their functional duties;
  • not permit joint activity (work) of close relatives, spouses, and in-laws in cases of direct subordination;
  • not use official or other information not subject to official disclosure for the purpose of obtaining or deriving proprietary or non-proprietary benefits and advantages;
  • not accept gifts in connection with the performance of official duties;
  • not use their official position to resolve matters unrelated to their official duties;
  • not coerce others into committing unlawful acts or acts inconsistent with generally accepted moral and ethical standards;
  • when performing their official duties, provide only objective and reliable information, and promptly inform management of any known instances of corruption in the actions of other employees, counterparties, or other persons;
  • not display personal loyalty toward management, or seek to obtain benefits and advantages through management’s official capabilities.

Anti-Corruption Restrictions and Prohibitions

Officials and employees of the Company are obliged to comply with the restrictions and prohibitions established by the applicable legislation of the Republic of Kazakhstan, and the restrictions established by the legislation of the Republic of… (the source text is cut off at this point)