Anti-corruption

The Anti-Corruption Policy reflects the commitment of Subsidiary JSC VTB Bank (Kazakhstan), its employees, and its Management Team to high ethical standards of doing open and honest business to improve corporate culture, and adhere to best corporate governance practices, and maintain an impeccable business reputation of the Bank.

The main objectives of Subsidiary JSC VTB Bank (Kazakhstan) in combating corruption are as follows:

• minimizing the risk of involving the Bank and its employees in corrupt activities;

• formation of a common understanding of the Bank's policy on the rejection of corruption in any forms and manifestations among shareholders, investment community, counterparties, employees, and other persons;

• establishing the obligations of the Bank's employees to know and comply with the principles and requirements of the Anti-Corruption Policy;

• identifying conditions and causes contributing to corruption risk, committing corruption offenses, and eliminating their consequences;

• strengthening cooperation within the Bank to combat corruption.

Subsidiary JSC VTB Bank (Kazakhstan) implements corruption prevention procedures in the following main areas:

1. Corruption prevention

All employees of Subsidiary JSC VTB Bank (Kazakhstan) adhere to the requirements of the Anti-Corruption Policy. For all employees of the Bank, the principle of zero tolerance for corruption in all its forms and manifestations in the implementation of current and project activities is established.

In carrying out its activities, Subsidiary JSC VTB Bank (Kazakhstan) takes measures to prevent corruption, including minimization of causes and conditions contributing to corruption offenses, by:

• establishing organizational and legal mechanisms to ensure accountability, controllability, and transparency of decision-making procedures;

• compliance with the principles of fair competition; prevention of conflicts of interest;

• adoption of and adherence to the standards of business ethics;

• taking measures to develop an anti-corruption culture;

• interaction of anti-corruption actors, inter alia with other bodies and organizations on the prevention of corruption.

2. Identifying and assessing the risks of involvement in corrupt activities

Subsidiary JSC VTB Bank (Kazakhstan) identifies and minimizes the risks of involvement in corruption activities by conducting the anticorruption examination of developed internal, regulatory documents and in the establishment of internal business processes and procedures during the collection of information on the risk events associated with corruption offenses.

3. Checking counterparties

Subsidiary JSC VTB Bank (Kazakhstan) does not attract or use counterparties or other persons to commit actions, contrary to the principles and requirements of the Anti-Corruption Policy and the provisions of the legislation of the Republic of Kazakhstan on combating corruption.

4. Receiving and giving gifts

Gifts and entertainment expenses that the Bank's employees may provide to other persons and organizations on behalf of the Bank or that employees may receive from other persons and organizations in connection with their official duties shall comply with the existing business customs and requirements of the legislation of the Republic of Kazakhstan.

Subsidiary JSC VTB Bank (Kazakhstan) refrains from paying any expenses for civil servants, public officials, persons holding responsible public positions, persons authorized to perform public functions, as well as persons equated to persons authorized to perform public functions and their close relatives (or in their interests) who do not meet the criteria specified in the Anti-Corruption Policy and the legislation of the Republic of Kazakhstan.

5. Financial and technical control

Subsidiary JSC VTB Bank (Kazakhstan) regularly carry out an internal and external audit of financial and economic activities, control over the completeness and accuracy of data reflected in the accounting, and compliance with the legislation of the Republic of Kazakhstan and internal documents of the Bank.

6. Interaction with employees

The Bank's employees are strictly prohibited to directly or indirectly, personally or through the mediation of third parties, close relatives, participate in corrupt practices, offer, give bribes, abuse authority, perform commercial bribery to simplify administrative and other formalities or to obtain benefits in the form of money, valuables, other property or services/ property or non-property benefits, other property rights for themselves and/or for close relatives, third parties.

The Bank requires its employees to comply with the Anti-Corruption Policy and the Code of Ethics. The Bank develops among its employees an attitude of zero tolerance to corruption in all its forms and manifestations, as well as an understanding of the need to prevent conflicts of interest and resolve them on time.

In case you become aware of any facts of corruption offenses involving the Bank's employees, unlawful acts of the Bank's employees and third parties, or fraud, you may send a message to the Chief Compliance Controller. The forms of "Authorized message" and/or "Anonymous message" are available on page of the Chief Compliance Controller.