Speak up

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.

Legal entities, as well as individuals, can report wrongdoing via free-of-charge hotline, with three options available: • Phone call 8-800-080-8089; • Email: speakup@kazakhmys.kz • Regular mail to the company’s legal address: 12, Abai Street, Karaganda, 100012.

In 2021, 59 reports/appeals (against 51 compared to the same period of 2020) were registered by Speak Up Alert Reporting Service of which:

51 (against 49) – analyzed, 5 – dismissed, 1 (against 0) – forwarded to the competent subdivisions, and 2 (against 2) – pending.

Following verifications, 7 official notes were issued to eliminate violations and resolve conflict of interest, the lump-sum bonuses were paid to employees on maternity leave, as well as additional payments were made for concurrent service, service area expansion and weekend work.

At the same time, not all appeals corresponded to facts and could be verified. It is noted that 18 (against 25) out of 51(against 49) appeals/reports analyzed were declined.

15 (against 11) out of 51 (against 49) appeals analyzed provided with clarifications, such as: • Employment legislation • Payment of bonuses • 2 weeks sick pay (self-isolation due-to COVID-19) • Preventative measures of COVID-19 • Vaccination • Compensation for damage to health caused by occupational disease or occupational accident • Land plots condemnation • Reasons for tender bids rejection

Speak Up Alert Report Examination Results

In 2021, 5 anonymous appeals were dismissed based on Clause 6.4. of the Instruction (the heart of the matter is not stated, an employee name whose actions are being appealed is not indicated, and it is not possible to ascertain this information).

33 or 56% (against 29 or 57%) – related to employment relationships, occupational health and safety; 8 or 13.6% (against 7 or 14%) – related to actions of the Structural Units Managers; 4 or 6.8% (against 5 or 10%) – related to procurement arrangement (goods, works and services); 3 or 5% (against 2 or 4%) – related to compliance with Anti-Bribery and Anti-Corruption policies and procedures regarding Conflict of Interests. 3 or 5% (against 0) – non –compliance of regulations against COVID-19, 8 or 13.6% (against 8 or 15%) – other issues.

Speak Up Alert Report Examination Results

Breakdown of 59 (against 51) appeals by enterprises were as follows: • Kazakhmys Corporation LLC – 41, or 69.4% • Kazakhmys Smelting LLC – 7; • Dank LLC – 1; • Ulytau Nan LLC – 1; • Zhezkazgan Medical Center LLC – 1; • other enterprises – 8.

Breakdown of Appeals by Enterprises

The following groups contacted Speak Up Alert Service were as follows: • Company employees – 35 or 59.3%; • Company employees’ relatives – 3 or 5.1%; • Counterparties – 5 or 8.5%; • Other enterprise employees – 16 or 27.1%;

Groups Contacting Speak Up Alert Service

It is noted that out of 59 appeals 25 or 42.3% appeals were anonymous; appealers refused to give their full names and residence addresses.

In the meantime out of 25 anonymous appeals analyzed: 7 appeals – verified during inspection; 7 appeals – false; 6 appeals – clarifications provided 5 appeals – dismissed

Anonimous Reports

Company employees and third parties are informed about Speak Up Alert Service via Kazakhmys Group official websites and Instagram messenger.