In accordance with the Code of Business Ethics and Conflict of Interest Policy KEGOC JSC, one of the necessary conditions for an employee to perform his/her job duties effectively is the absence of contradictions between the private interests of an employee or an official and the interests of the Company, and, if any, their timely disclosure and settlement. All employees and officials of KEGOC JSC shall behave in such a way as to avoid a situation in which a conflict of interest may arise either in respect of themselves (or persons related to themselves) or others.

In 2023, the Company’s officials and employees did not report any cases of conflict of interest:

• There were no situations in which personal interest could influence the proper fulfilment of their duties;
• There were no situations with conflicts of interest that affect or could potentially affect impartial decision-making;
• Officials with an interest did not participate in the discussion and adoption of such decisions.

As a preventive measure (warning), an addition was made to the Policy on Settlement of Conflict of Interest of KEGOC JSC officials and employees in 2023 and a form of declaration on disclosure of potential conflict of interest was approved. In 2023, only independent directors took part in the discussion and voting on the issues of entering into related-party transactions within the competence of the Board of Directors, which was recorded in the minutes of the Board of Directors’ meetings. In the reporting year, the Board of Directors of KEGOC JSC made decisions to enter into related-party transactions by signing three (3) contracts for organization of works on the operational and maintenance of equipment between branches of KEGOC JSC and Batys Transit JSC for the total amount of KZT 335.9 million.

No major transactions were entered into in 2023.