Compliance with human rights

Samruk-Energy JSC strives to actively implement human rights principles in all its activities. Our comprehensive approach is based on the current legislation of the Republic of Kazakhstan, as well as internationally recognised standards and commitments that we uphold and implement, including:

• UN Guiding Principles on Business and Human Rights (UNGPs);
• UN Sustainable Development Goals;
• Ten Principles of the UN Global Compact;
• Universal Declaration of Human Rights;
• International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work;
• International Covenant on Civil and Political Rights;
• International Covenant on Economic, Social and Cultural Rights;
• United Nations Guiding Principles on Business and Human Rights.

The Company takes a holistic approach to respecting human rights throughout the value chain and endeavours to ensure compliance with relevant laws and regulations through a robust risk management framework. We continuously assess actual and potential adverse impacts on people and the environment and integrate our findings into the Company's due diligence policies, procedures and processes.

Our politicies

Samruk-Energy JSC expresses its commitment to human rights and approach to their protection, and sets expectations in this area through relevant policies and regulations:

• The Code of Conduct of Samruk-Energy JSC describes expectations with regard to employees and sets standards of corporate behaviour that apply to the entire Group. All employees and persons acting on behalf of Samruk-Energy JSC are obliged to comply with the Code, regardless of location and nature of their work.
• The Human Rights Policy of Samruk-Energy JSC describes the Company's approach to human rights protection.
• The Samruk-Energy JSC Non-Discrimination Policy affirms the Company’s commitment to the principles of equality, inclusivity, and respect for human rights, establishing a prohibition on all forms of discrimination and outlining mechanisms for employee protection.
• The Samruk-Energy JSC Sustainability Guidance outlines the Company’s commitments to respecting and protecting human rights across all areas of activity, including the prohibition of discrimination, the provision of safe and decent working conditions, freedom of association, and a responsible approach to engagement with communities and other stakeholders.
• The Personnel Policy of Samruk-Energy JSC regulates labour practices within the Company, defining obligations to employees and expectations from them.

Governance and accountability

Our priority human rights areas

We respect the basic human rights of all people by complying with all legal requirements. We have rigorous policies, procedures and other actions to mitigate potential risks in the following five human rights categories:

• Forced labour and child labour We have zero tolerance for any type of forced and/or child labour in our operations and supply chain.
• Occupational health and safety Health and safety is our top priority and we are committed to continuous improvement to achieve zero injuries. We are committed to the safety of our products and operations, and this extends to contractors and visitors to our sites.
• Wages and working hours We do not employ people whose wages are below the minimum wage permitted by local law for the type of work involved. We are committed to monitoring and taking steps to reduce excessive working hours and support flexible working conditions where possible.
• Freedom of association It is a fundamental right for employees to have freedom of association and collective bargaining. We recognise and respect the rights of employees under local law, including, where applicable, the right to collective representation and bargaining, without any negative consequences for engaging in legitimate trade union activities.
• Discrimination We are committed to promoting equal opportunity and are proud to build a culture with zero tolerance for discrimination, harassment and bullying.

Grievance mechanism and channels

For availability of feedback of complaints and appeals in the field of human rights, the Company has a hotline of Samruk-Energy JSC. All appeals about possible violations of human rights and freedoms are thoroughly analysed, after which the assessment results are sent to the Board of Directors.

The Company's managers were consulted on all appeals in the reporting period and provided with recommendations. Also in 2024, work was carried out with labour collectives to explain the norms of the Codes of Ethics and Conduct and Compliance Policy.

Political activities and contributions

The Company interacts with government-related persons in accordance with the requirements of applicable law. The Company does not finance or otherwise support political parties and non-profit organisations engaged in political activities. It also does not allow sponsorship/ charity/lobbying activities with the direct or indirect purpose of obtaining illegal benefits for providing such assistance.

The Company's principles in this area:

• You may not use Company accounts for contributions for political purposes;
• It is prohibited to use Company resources (including email) for political activities;
• You may not make charitable donations in lieu of contributions for political purposes;
• It is prohibited to allow the Company's funds or assets to be used through industry organisations or otherwise to make contributions to political parties.

According to the results of 2024, the Company has not recorded any facts of sponsoring events or holidays held solely for political propaganda purposes, and there are no facts of direct or indirect pressure on political parties.