The Bank has approved a Policy on the Settlement of Corporate Conflicts and Conflicts of Interest, which defines a set of measures aimed at preventing conflicts of interest within the Bank. At its core, a conflict of interest represents a clash of opposing interests, opinions, goals, and differing perceptions of how to achieve them.

The Policy clearly establishes the obligation of officials (members of the Board of Directors and the Management Board of the Bank) and employees of the Bank to act in the interests of the Bank and its Sole Shareholder, and defines their corresponding liability.

According to the requirements of the Policy, officials and employees of the Bank are obliged to avoid any actions or relationships that could potentially cause a conflict of interest. Any conflict of interest between personal interests and professional duties in the Bank must be disclosed and resolved in accordance with the legislation of the Republic of Kazakhstan and the Policy. To exclude conflicts of interest, the Bank's employees sign a commitment to comply with actions that limit the risk of a conflict of interest arising.

Transactions with persons related to the Bank by special relations can only be executed by decision of the Bank's Board of Directors in accordance with the requirements of the legislation of the Republic of Kazakhstan and the internal documents of the Bank. The restrictions and requirements provided by the Bank's credit policy regarding transactions with persons related to the Bank by special relations apply to all types of transactions with such entities.

Furthermore, the Regulation on the Bank's Board of Directors provides that, in the event of corporate conflicts, the Chair of the Board of Directors takes measures to resolve them, minimize their negative impact on the Bank's activities, and promptly informs the Sole Shareholder if it is impossible to resolve such situations independently. The Bank confirms that there were no appeals from the Sole Shareholder in connection with corporate conflicts involving the Bank and its officials in 2025.

With the aim of fostering an anti-corruption culture, clarifying the requirements of the Bank's internal documents, and preventing conflicts of interest, the Compliance Control Department conducted a training course for all Bank employees on the topic: "Policy on the Settlement of Corporate Conflicts and Conflicts of Interest at JSC "Otbasy Bank"". This course included both a theoretical part and a final test to evaluate the level of material absorption and reinforce the acquired knowledge.