кодекс корп этики ао каи

Approved by Confirmed
Decree of Government by Decree of Committee of directors
«KazAgroInnovation» JSC «KazAgroInnovation» JSC
dated on June «1» 2012 dated on July «2» 2012
Protocol № 6 Protocol № 11

CODE
of corporate governance for joint-stock company
«KazAgroInnovation»

Кодекс корпоративной этики
АО «КазАгроИнновация»

Content:

1. General statements 3
2. Assets and principles of corporative ethics 5
3. Norms of corporate governance 7
3.1. Ethics of relations for officials and employees of the Company 7
3.2. Ethics of relations with Unique stockholder 9
3.3. Ethics of relations with government agencies 10
3.4. Ethics of relations with branch organizations 10
3.5. Ethics of relations with business partners 10
3.6. Ethics of relations with society 11
3.7. Ethics of relations with Mass media 11
4. Rules of business behavior at Company 12
4.1. Relations with colleagues 12
4.2. Relations between guidance and employees 13
4.3. Corporate culture 13
4.3.1. Personal appearance of employees and ethics of conduct of 13
negotiations
4.3.2. Corporate parties 14
5. Confidentiality 15
6. Conflict of objectives 15
7. Responsibility 16
8. Rules and responsibilities of Ombudsman 16
9. Practical application 17
10. Explanation and studying with Code 18
11. Conclusion 18

1. GENERAL CONDITIONS

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1. Present Code of corporate governance of «KazAgroInnovation» JSC (further
– Code) was developed according to the conditions of acting legislation of legislation
of Kazakhstan Republic, inner regulatory documents of «KazAgroInnovation» JSC
(further - Society), including Code of corporate governance, and establishes centring
values and principles of corporatebusiness governance, standards of ethics of
corporate/business relations.
2. Purpose of present Code is:
1) Strengthening of key values, principles, rules and norms of business ethics
and behavior, by which officials and employees of the Company conforms in it
activity as at acceptance of strategically important decision so in daily situations;
2) development of one corporate culture, based on high ethic standards,
support in collective the atmosphere of confidence of mutual respect and
respectability;
3) uniform understanding and execution of norms of business ethics, accepted
in Company by all employees without distinction of development of position held;
4) extension and saving of confidentiality to Company on the part of business
community, reputation, strengthening of reputation for opened and honest participant
of the market;
5) Assistance of effective interaction with concerned parties.
3. Code uses together with other inner regulatory documents of the Company
and reflects activity of the officials and employees of the Company in terms of using
norms and principles of business ethics and business behavior.
4. List of pointed norms and principles are not irrefragable and can be
comprehensive specified, changed and added in case of appearance of some terms of
reference or liabilities.
5. Code provisions extend for officials and all employees of the Company
without distinction of hold position. Consecution of principles of corporate
management and transparency provides to more active participation of the Company

3


in realization of government policy in agricultural sector by provision of effective
development of agroindustrial complex through increasing of productivity of
scientific activity, and also assists to formation and development of positive corporate
culture, leads to consolidation of reputation and authority of the Company and are the
deposit of successful development of the Company in future.

6. Following definitions and abbreviations uses in Code:
1) Company – joint-stock company «KazAgroInnovation»;
2) Business ethics – it is composite of ethic principles and norms of business
communication, which conforms in it Company, it officials and employees; Official
– Chairman and deputies of Chairman of the Board, Chairman and members of
Committee of directors, managing directors of the Company;
3) One shareholder – Ministry of agriculture of Kazakhstan Republic, the
highest agency of the Company according to legislation of Kazakhstan Republic;

4) Concerned individual – physical and juridical persons, entrant in с
Обществом;
5) Code – present Code of business ethics of Code of business ethics of
joint-stock company «KazAgroInnovation»;
Conflict of objectives – situation, in which private interest for official or employee
of the Company influence or can influence to unprejudiced execution employment
duties;

6) Corporate culture – is a specific values for Общества values, principles,
norms of behavior and relations;

7) Corporate secretary – employee of the Company, which is Company, is
not a member of Committee of directors or Company, which assigned as Committee

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of directors and affiliated to the Committee of directors of the Company, and also in
the context of activity controls preparing and conduction of sessions of the
Committee of directors of the Company, provides formation of materials on
questions which were submitted for consideration of one stockholder and materials
for session of Committee of directors of the Company, leads control for providing
access for them;

8) Employee – physical person, composed in labor relations with Company
and immediately executing work on labor agreement.

9) Corporate social responsibility – execution of voluntary accepted
liabilities, which meets mutual interests of the Company, government and business;

10) Ombudsman – appointed by Committee of directors of the Company
person (supposedly from number of employees) encourages implementation and
observance in Company of business ethics principles.

7. Society accepts and follows statements of present Code in relations with
one stockholder, officials, employees, branch organizations, government agencies,
partners, other concerned parties, as for accepting of strategically important business
decisions, so in daily situations which meet officials and employees.

5


2. VALUES AND PRINCIPLES OF CORPORATE GOVERNANCE

8. Foundational corporate values on the base of which forms Company
activity, are:

1) Competence and professionalism
Primarily result of the work of the Company must be flawless in the context of
professionalism. Officials and employees of Company. Officials and employees of
the Company must have highest professional education, work experience, ability of
taking responsible decisions. Company not only sets missions, but creates conditions
for their employees, which allow increasing level of professional skills and
knowledge to realize it professional creative facilities, develop potential, to have
perspective of career growth.
Company estimates in it employees and it work:
Orientation on achievement of strategic purposes of the Company;
Professionalism in it activity and aspiration to increase it professional level;
Initiative and activity in the performance of official duties;
Discipline state and responsibility;
Mutual support of employees, making assistance to young specialists of the
Company and respect of it veterans.

2) Honesty and impartiality
Honesty and impartiality – «basis» of Company activity it business reputation.
Company prevents conflict between private interests and professional activity.
Deception, reticence and false announce are not compatible with status of official
party and employee of the Company.

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3) Responsibility
Responsibility – guarantee of the quality of Company activity. Company brings
responsibility on taken liabilities, established requirements of Kazakhstan Republic
legislation, contractual relationship, traditions of business rotation and moral and
ethic principles. Company realizes it social responsibility before state and society
(property).

4) Demonstrativeness
Company strives to maximal demonstrativeness and reliability of information,
about Company, services and gains, results of activity. Company activity directed on
honest and timely information of one stockholder and partners about state of affairs,
to increase transparence and accessibility on base of improvement of quality
accounting according to legislation of Kazakhstan Republic. At once Company see
after information and data, comprising commercial, service and other secret protected
by legislation of Kazakhstan Republic.

5) Respect of human personality
Employees and partners of the Company have a right to honest and fair attitude
irrespectively race, language, political and religious convictions, national and culture
and sex attribute.

6) Nationalism
Imposed on Company high confidence from the side of state and it social
responsibility generates feeling of nationalism and striving to make development of
national economics and provision of maximal profits for state.
9. At execution of it activity Company:

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1) Observe the regulations of legislation of Kazakhstan Republic, executes
decisions of the one stockholder Committee of directors and state agencies and other
documents, which refers to Company activity;
2) provides observance and rights respect, honor and dignities of human and
citizen notwithstanding origin, social, property and business position, gender, race,
nationality, language, religion attitude, convictions, habitation or other
circumstances;
3) To respect symbols of the state – Emblem, Flag, Anthem;
4) To respect corporate symbolics of the Company;
5) Observe generally accepted moral and ethic norms, respectively to state and
other languages, traditions of all nations;
6) Acts right and conscientiously doesn’t accept bribe and analogous vicious
business practice and also practice of giving gifts and receiving gifts except accepted
in business practice (herewith such presents can’t be significant and can’t be
giftedaccepted often);
7) To apply to officials and employees treat with justice, with respect and
observation of ethics norms;
8) Strives to make all his relations with interested parties are mutually
profitable;
9) Shows respect and carefully treats to property of the Company and
environment.
10. Effective organization of work was built on execution of mutual rights
between Company and all concerned parties. Observation of mutual rights –
necessary condition of constructive work.

8


3. NORMS OF CORPORATE ETHICS

3.1. ETHICS OF MUTUAL RELATIONS OF OFFICIALS AND
EMPLOYEES OF THE COMPANY

11. Officials and employees of the Company undertook responsibilities to
execute professional functions conscientiously and reasonably in interests of the
Company and one stockholder, avoiding conflict of interests.
12. Officials of the Company for achieving of strategic purposes of the
Company take business decisions taking into account of foundational values and
principles of business ethic, and bring provided acting legislation of Kazakhstan
Republic and inner regulatory documents of the Company responsibility for
realization of tasks, which set to them.
13. Officials and employees of the Company at execution of discharge duties
Общества must be based on interests of the Company, and not by personal
relationships or personal profit.
14. Every employee must be conscientiously to follow principles, providing in
present Code, to observe requirements of labor and collective agreements, rights of
inner labor order, official instructions and other inner regulatory documents of the
company and also to realize it personal responsibility for it breakdown or
nonobservance.
15. At process of hire for job of new employees the Company refers to
legislation of Kazakhstan Republic and requirements of inner regulatory documents
of the Company, gives preference which have more high qualification and
professional skill and doesn’t admits no discrimination, by some features. Selection

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and promoting of stuff realizes exceptionally on base of professional abilities,
knowledge and skills according to inner regulatory documents of the Company,
except some discrimination demonstrations on gender, race, political, religious and
other equal motives.
16. Company encourages employees, who are striving to self-education and
professional development, and creates equal and optimal conditions for extension of
qualification of employees from all levels according programs of education and
professional development of employees.
17. Politics in sphere of award bases on admitting of professional qualities of
employees, results of labor, and achievement of key indicators of activity and
suggesting of social package in purpose of motivation according to inner regulatory
documents of the Company.
18. Politics of the Company in sphere of safety and labor protection provides
supply and constant improvement of healthy and safe conditions of labor for
employees.
19. Officials and employees of the Company must provide creation of
sustainable and positive situation in collective by its attitudinal and behavior. In the
Company doesn’t admit providing of some privileges and facilities of legislation of
Kazakhstan Republic andor regulatory documents of the Company, at obligatory
providing of equal possibilities.
20. Officials and employees of the Company must exert every effort for high-
professional work, to treat with due care to property of Company, rationally and
effectively use it.
21. Company brings responsibility for accepting decisions, free from conflict
rise of interests at any stage of this process from official party to any employee,
taking decision.
22. Officials and employees of the Company must to carry themselves to not
admit the situation in which conflict rise not concerning itself (or connected with

10


itself parties) not concerning other.
23. Officials and employees timely perform to each other authentic
information, without breakdown without norms of confidentiality and with account of
decisions of one stockholder and Committee of directors and also inner regulatory
documents of the Company. Taking decisions by officials of the Company must be
based on principles of transparency and adequateness.
24.Officials must urgently inform about any commercial or other interest
(straight or circumstantial) at bargains, agreements, project, connected with Company,
or in the context of other questions in order, established by inner regulatory
25. Officials must urgently inform in written form structural subdivision of the
Company, which answer to supply of lists of affiliated parties into authorized state
agency, about execution of work andor taking positions in other organizations, about
changing of constant (basic) place of work service, entrepreneur activity and etc.)
26. Officials must timely inform immediate supervisor or line management and
can refuse from participation in discussion and voting on questions, in solving of
which there is an interest.
27. Officials and employees regardless from it status and position for
execution of it functional responsibilities have no rule to accept:
1) Reward in form of money, services and other forms from organizations and
physical parties, in which they doesn’t execute corresponding functions;
2) Gifts or services from parties, dependent by virtue of employment, except
symbolic courtesies and symbolic souvenirs according to generally accepted norms
of politeness and hospitality or at conduction of protocol and other official measures.
30. It is prohibited for officials and employees to compromise commercial,
official and other secret protected by legislation of Kazakhstan Republic, except
cases, when requirement about providing of this information was established by
legislation of Kazakhstan Republic, and also use information for personal advantage.

11


These norms regulates by inner statements about commercial and official secret and
other documents of the Company.
31. Officials and employees must observe rights, order and procedures
providing by inner regulatory documents of the Company and connected with mode
of safety and work with confidential information of the Company.
32. Every employee must not to admit in relationship with colleagues and
partners discrimination on gender, age, racial, political, and religious other such
motives.
33. Any situations which lead to rights breakdown must be considered
according to norms of legislation of Kazakhstan Republic and inner regulatory
34. Officials and employees of the Company must not to admit public
speaking, pronouncements or interview for any themes from name of Company
without direct errand of management or directly providing authorities.
35. Officials of the Company, management of structural subdivisions of all
levels must be accepted managing decisions which corresponds to requirements of
Code, moreover must be striving individual example to show adherence of statements
of Code, to pay attention for consultations and mentoring, cohesiveness of the
collective into team, united by one mission, corporate values and principles.

3.2. ETHICS OF MUTUAL RELATIONS
WITH ONE STOCKHOLDER

36. Vision of one stockholder is the core of strategy of Company development
strategy, for development and realization of which Committee and Governance of the
Company are responsible.
37. System of mutual relations between Governance, Committee of directors
and one stockholder was based on principles according to requirements of legislation

12


of Kazakhstan Republic, Statute and internal documents, and also statements of Code
of corporate management of the Company. Company establishes procedures in
respect to own mutual relations with one stockholder.
38. Order of information exchange between Government, Committee of
directors of the Company and one stockholder regulates by legislation of Kazakhstan
Republic, Statute and internal documents of the Company.

3.3. ETHICS OF MUTUAL RELATIONS WITH GOVERNMENT
AGENCIES

39. Company realizes mutual relations with government agencies according to
requirements of legislation of Kazakhstan Republic, Statute and internal regulatory
documents of the Company, and also statements of code of corporate management of
the Company, on the base of detachment of parties. Company doesn’t admit for
achievement of their purposes of lawless attempts to make influence on solution of
government agencies.
40. Company makes efforts for non-admission of corruption and other illegal
actions, as from the side of government agencies so from the side of officials and
employees of the Company.

3.4. ETHICS OF MUTUAL RELATIONS WITH BRANCH
ORGANIZATIONS

41. Company realizes mutual relations with branch organizations of the
Company according to requirements of legislation of Kazakhstan Republic, Statute
and internal regulatory documents of the Company, Statutes of branch organizations,
and also statements of Code of corporate management of Company.

13


3.5. ETHICS OF MUTUAL RELATIONS WITH BUSINESS PARTNERS

42. Company cooperates with business partners on principles of mutual profit,
transparency and full responsibility for accepted responsibilities according to
conditions of agreements.
43. Company observe conditions of agreementscontracts with business
partners and executes own responsibilities towards them.
44. Company guarantees timely and full consideration of all appeals desires
and claims of partners. In case of outbreak of differences and disputes, gives
preference to negotiations and search of compromises.
45. Company realizes selection of supplier of goods and services which
suggest minimum prices, the best quality, conditions of supply and services, which
has good reputation, according legislation of Kazakhstan Republic.
46. Company adheres to honest and free competition and condemns all
exertions of unfair competition, which can not only negatively affect on reputation,
but to shatter confidence of partners to Company.
47. Company doesn’t admit in own activity supply to business partners of
groundless facilities and privileges.

3.6. ETHICS OF MUTUAL RELATIONS WITH PUBLIC

48. Company realizes all social responsibility before public.
49. Company strives to make positive influence on solution of socially
significant questions.
50. Company strives to service for society, support programs, directed on
extension of knowledge level and education of population in region, and other social
programs.

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51. Company considers itself as inherent element of social sphere, in which he
works and with which he strives to establish relations, based on principles of respect,
trust, honesty and justice.
52. Company aspires to create new working places and to increase professional
qualification of employees.
53. Company strives to establish constructive relations with organizations
(social, non-governmental and other), with purpose of improvement of social relations,
decrease of impact of own manufacturing activity
on environment, health protection and providing of safety of employees labor of the
Company.
54. Company undertakes commitments to refuse from cooperation with
juridical and physical parties with doubtful reputation.
55. Social responsibility realizes in the context of legislation of Kazakhstan
Republic, Statute and internal regulatory documents of the Company, and also is
subject to statements of Code of corporate social responsibility of the Company.

3.7. ETHICS OF MUTUAL RELATIONS WITH MASS MEDIA

56. Information policy of the Company provides creation of possibility of
getting free and easy access to information about Company. At corporate web-site of
Company (http://www.agroinnovations.kz) at public mode there was placed
information about Company, it activity, corporate management, branch organizations,
and also about stuff policy, contacts data and etc.
57. Company enforces high standards with interaction with mass media.
58. Data concerning Company has right to provide management of the
Company to mass media.
59. Employees of the Company, providing data to mass media brings personal
responsibility for it authenticity and lack of data, comprising commercial andor

15


official secret and also data of confidential character.
60. Employees of the Company can provide information to mass media
concerning activity of the Company by errand or with permission of management of
the Company, with the approval of supervisory structure subdivisions, which brings
responsibility for cooperation with mass media.
61. Each employee must understand and always remember that any point if
view outspoken by him as employee of the Company or distributed information
immediately correlates with the Company, it image and influence on it reputation in
business community.

4. RULES OF BUSINESS BEHAVIOR IN SOCIETY

4.1. RELATIONS WITH COLLEAGUES

62. Relations between all employees of the Company are equal.
63. Relations in collective influence on mood of employees and their wish to
work, broadly defines results of Company work. Creating and supporting comfortable
working atmosphere, employees observe next norms and rules of business etiquette:
1) To respect each other;
2) Not to run errands which are not concerns to execution of service
responsibilities at working time;
3) Not to demonstrate to colleagues your bad mood;
4) Not to use obscenities, not to show intemperance and not to show
aggression;
5) Always to apologize for your incorrect behavior;
6) To help colleagues, to share your knowledge and skill;
7) Not to discuss personal or professional properties of colleagues;
8) To be polite and reasonable;

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9) To be attentive to somebody’s opinion and constructive criticism.

4.2. MANAGEMENT-STAFF RELATIONS

64. Creation of constructive professional relations of management and staff is
necessary for daily effective work of the Company and for future development.
65. Leaders recommended observing next norms and rules of business
etiquette:
1) To show employees the example of good possession of norms and rules of
ethics and business etiquette;
2) Not to criticize employees in the presence of other employees, to make it
confidentially;
3) Can recognize before staff your own mistakes and not to persecute them for
constructive criticism towards yourself.
66. Observing of next norms and rules of etiquette was recommended to
employees:
1) Instantaneously inform immediate supervisor about reasons of absence at
work seat;
2) Not to answer in the presence of the colleagues for incorrect behavior of the
chief. If there is assurance of your rightness, it is necessary to ask for face-to-face
contact;
3) To know by sight and by name the chiefs of the Company.
67. Present at labor activity out of Company employees must:
1) To notice immediate supervisor and chief of structural subdivision,
responsible for personnel policy of the Company about planning other payable
working practice in other organizations;

17


2) To formalize working relations combined duties according to legislation of
Kazakhstan Republic;
3) To realize other payable working practice in other organizations which
wouldn’t influence on execution of basic employment duties and to do damage for
image and interests of the Company;
4) To observe rules of saving commercial and other official information,
provided by legislation of Kazakhstan Republic сand internal regulatory documents
of the Company.

4.3. CORPORATE CULTURE

4.3.1. APPEARANCE OF EMPLOYEES AND ETHICS OF
NEGOTIATIONS

68. It is recommended for staff to adhere to norms of business style in choice
of clothes, shoes and hairdo, according to respectable and professional image of the
Company during execution of official responsibilities.
69. It is necessary for officials to adhere rules of negotiating including
telephone conversations. Business negotiations must be hold in low and polite
profile.
70. Skill of officials to speak on the telephone with colleagues and business
partners makes creation of prosperous impression about Company altogether. When

18


speaking on the telephone it is necessary to remember that colleagues can be seat in
one placement and it is necessary to treat with due care to their work and not to divert
them with loud conversations.
With participation in the meeting, it is necessary to switch off cellular or set
silent profile.

4.3.2. CORPORATE EVENTS

71. One of important elements in formation of corporate culture is holding of
festive measures in collective. Birthday of the Company, New Year, international
Women Day, Nauryz, Constitution Day, Independence Day, Defender of the
Motherland Day, Day of science official and Day of agriculture official devotes to
traditional corporate events.
Festive measures commemorates at conference-hall, management of the
Company and their representatives congratulate especially distinguished in work
officials with missive letters, gifts, according order of award and encouragement of
officials of the Company. In case of celebration out of office block of the Company,
collective drives to culture and entertainment complex or to the country, outside
where the collective makes musical events, dances, national games and etc. At
individual cases, by initiative of management members of families are invited.
72. Celebration of children of officials of the Company, is traditional for
members of work collective. Formally congratulates management (birthday card,
bunch of flowers, congratulation on internal mail of the Company). For the rest
categories of officials the celebrations conducts in structural subdivisions. During

19


celebration of birthdays of the officials some reception standing is admissible (soft
drinks, fruits, cakes) out of hours (dinner break). Responsible structural subdivision
directs congratulation for birthday person from collective of the Company by internal
mail in Company. Gifts to officials presents according to personal wish of collective
members.

5. CONFIDENTIALITY

73.Confidential information of the Company admits information concern such
according to legislation of Kazakhstan Republic and internal regulatory documents of
the Company.
74. Any data of confidential character which officials have including
officials, keeps in secret, if legislation of Kazakhstan Republic wasn’t provided
another.
75. Employees, who have access for confidential information of the
Company, can’t share to each other, which have no access of such information, and
also any third parties out of the Company. Present limitations uses also during time,
established by internal regulatory documents of the Company, after dismissal.
76. Within working day and after completion when employee leaves it place,
he must be assure that at his working table or other readily available place there is no
documents which have confidential information. All such documents must be locked
in closets or boxes, and computer must be switched off or blocked. During talk with
partners all confidential information, at desktop of employee all confidential
information including information on desk-top must be visually inaccessible for
interlocutor.
77. Confidential information (in electronic, written or other form) must not
be taken out to limits of the Company without according errand of management of

20


the Company. At dismissal employee must leave in the Company all belong to
Company documents, files, computer diskettes (memory sticks and etc.) reports and
records, which compose information about company or information which is not
meant to wide range of people, and also all copies of documents, which compose this
information.

6. CONFLICT OF INTERESTS

78. Officials, as employees of the Company make all professional functions
conscientiously and reasonably with due care and circumspection in interests of the
Company and one stockholder, avoiding conflicts. Company realizes significance of
effective work of non-executive directors in the structure of Committee of directors
and thoroughly select candidates, which have necessary professional skill, flawless
business reputation and high level of personal ethic;
79. Reveal of conflict of interests and it adequate regulating is important
condition of interests’ protection of one stockholder and partners.
80. officials and employee of the Company andor affiliated parties with
purpose of non-admission of interests:
1) Can’t use it in won interests or for deriving profit by possibilities, which
provided to him by corporate resources of the Company, management, employees of
the Company, it position andor information, received in consequence of execution of
employment duties;
2) Can’t be participated in consideration and solution of decisions on any
relations between Company and him, any affiliated party;
3) Can’t be participated in any activity, which can be potentially to the
conflicts of interest;

21


4) Must make efforts to make conflicts be solved in the context of present
legislation of Kazakhstan Republic with account of legal interests of parties, involved
into conflict;
5) Can’t accept any gifts or use profits connected with it activity in the
Company, from any third parties and also get some incomes or profits as execution of
functional duties, except incomes, received from Company. Company doesn’t admit
accepting of gifts or receiving profits, except symbolic souvenirs according to
generally accepted norms of politeness and hospitality, and also at conduction of
protocol and other official measures.
81. Settlement of conflict of interests in Company regimented by present Code
of corporate management and other internal regulatory documents of the Company.

7. RESPONSIBILITY

82. Observation of norms of present Code is obligatory for all officials and
employees of the Company. All facts of breakdown of ethic norms according to
present Code must be considered according to norms of legislation of Kazakhstan
Republic and internal regulatory documents.

8. RIGHTS AND DUTIES OF OMBUDSMAN

83. Ombudsman appoints by Committee of directors one time a year of
employees of the Company, who have length of service in state and educational
enterprises.

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Basic functions of Ombudsman are selection of data of nonobservance of
statement of Code, consultation of employees, consultation of officials on statements
of Code, initiation of consideration of disputes on breakdown of Code and
participation in it.
84. Ombudsman has a right:
1) Instigate conduction of procedures on execution of breakdowns of Code
statements, as on the base of appeals, so on own initiative;
2) To apply to employees and officials on questions of non-observance of Code;
3) To represent for employees and officials explanations and interpretation of
statements of Code.

85. Ombudsman must:
1) To provide jointly with Professional union of employees of Company
protection (in the context of established by labor legislation procedures) of
employees, for period of conduction of disputes on questions of Code breakdown, in
case of rise situation of it compulsory dismissal on cause of consideration of these
business initiation;
2) To take part at consideration of questions in respect to non-observance of
Code;
3) To conduct account of appeals of employees, officials, and also business
partners and interested parties on questions of non-observance of Code statements;
4) Within 5 (five) working days to provide explanations of Code statements to
employees of Company in case of appeal;
5) To observe independence and impartiality at participation of disputes
consideration on questions of non-observance of Code;
6) To provide anonymity of employee, official, who appealed on fact of
breakdown of Code statements (in case of desire of being anonymous).

23


9. PRACTICAL USING

86. Present Code is internal document of the Company, obligatory for
execution by officials and all employees without distinction of position.
87. Company encourages employees to open discussion of Code and
positively refers to any constructive suggestions on it improvement.
88. On questions concerning statements of Code andor appeared at work
process ethic questions, and also by facts of breakdown of Code statements,
corruption and other illegal actions officials and employees of the Company, and also
business partners and interested parties have right to appeal:
1) To immediate supervisor, or to the next level to direct chief;
2) Ombudsman;
3) On electronic information system of the Company, presenting itself or
anonymously, for taking corresponding measures.
Rights of appealed party can not be detrimental to any method of appeal.
89. In case of reveal of circumstances of breakdown by officials and employees
of the Company, confirmed norms of business ethics, materials for accepting decision
directs to consideration of Commission on consideration of questions of
encouragement and using to employees of disciplinary action of the Company
(further - Commission) with obligatory participation of Ombudsman. Results of
consideration and accepted decisions informs to appealed party within 3 (three)
working days from the day of accepting decision by Commission.
90. Members of the Commission guarantees confidentiality of data
consideration about breakdown of Code statements.

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10. EXPLANATION AND AWARENESS WITH CODE

94. Structural subdivision who responsible for development of Code provides in
respect to officials (at election of them into membership of according agency of the
Company) and chiefs of structural subdivisions of the Company – awareness with
code within 5 (five) working days from the day of it enactment.
In case of changing and adding of Code statements – awareness of structural
subdivisions and officials within 5 (five) working days from the day of it enactment.
Chiefs of structural subdivisions provide in respect to employees – awareness
with Code within 5 (five) working days from the day of it enactment.
Structural subdivision, responsible for personal policy of the Company provides
in respect to initiates – awareness with Code at employment.
95. Explanation of Code statements realizes by Ombudsman.
96. Code is open document and can be easily distributed by Company among
partners and other concerned parties.

11. CONCLUSION

97. Company realizes monitoring, conducts research, interrogations by theme
of corporate culture condition and business ethics level of officials and employees of
the Company.
98. Affirmation of Code falls within the ambit of Committee of directors of
Company. Committee of directors of Company only once in 2 years with purpose of
actualization and improvement reconsiders statements of present Code, analyzes in
which measure they uses at practice and also at necessity make changes and/or
additions.

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_____________________________________

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кодекс корп этики ао каи

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