In the Bank, special attention is paid to anti-corruption issues. Activity in this direction is carried out on a constant basis, in strict accordance with the requirements of the legislation of the Republic of Kazakhstan and internal documents of the Bank.

With the aim of preventing corruption offenses, a complex of measures is conducted in the Bank, the ultimate result of which is the exclusion of corruption activity. In 2025, a number of corruption manifestations were identified, committed by Bank employees who received illegal remunerations for lobbying the interests of clients, realtors, private bailiffs, and notaries, and promoting the housing queue. Also, facts of fabrication by an employee of one of the branches of forged income documents confirming the creditworthiness of clients and attaching them to credit applications were identified. The employment contracts with the specified employees were terminated at the initiative of the employer due to loss of trust. Based on the identified facts, statements were sent to bring these Bank employees to criminal responsibility, under which pre-trial investigations are being carried out by law enforcement agencies in a number of criminal cases.

The Anti-Corruption Policy and Rules have been developed and approved in the Bank. Specific procedures and controls have been implemented into the internal documents of the Bank, including on personnel management issues.

The Bank regularly conducts internal training of the Bank's employees on anti-corruption issues with mandatory testing of the obtained knowledge.

In 2025, training on anti-corruption issues with testing of the obtained knowledge was completed by 1,183 consultants of the Central Office and 20 branches of the Bank, and 1,506 employees of the Central Office and branches of the Bank.

The Compliance Control Department is the division exercising the functions of anti-corruption compliance in the Bank, is independent of any activity of the structural divisions of the Bank, and is accountable through the Chief Compliance Controller to the Board of Directors of the Bank.

All employees of the Bank, regardless of the position held, are warned of the obligation to report known facts of corruption in the Bank to their immediate supervisors or to the security unit or confidentially via the Hotline. At the same time, every employee of the Bank bears personal responsibility for concealing the facts of involvement of any of the Bank's employees in corruption activity.

To prevent corruption offenses, a complex of measures is conducted in the Bank, the purpose of which is the exclusion of corruption risks.

A Hotline operates in the Bank, which is a means of confidentially receiving information about violations of a corrupt nature on the part of employees and consultants of the Bank. The analysis of received appeals in the current year showed that all of them were of a reference and consultative nature and did not contain information indicating the involvement of Bank employees in corrupt actions.

The Bank on a quarterly basis informs the Anti-Corruption Agency of the Republic of Kazakhstan about the presence/absence of facts of bringing the Bank's managers to responsibility for corruption crimes of subordinates.

In 2025, thematic anti-corruption monitoring was conducted in the Bank. The results of the conducted monitoring in the form of a report were brought to the attention of the Chairman of the Management Board of the Bank and sent to the Anti-Corruption Agency of the Republic of Kazakhstan (Anti-Corruption Service).

An internal analysis of corruption risks in the activities of the Center for Providing First Housing of JSC "Otbasy Bank" was also conducted on the issues of formation, maintenance, actualization, administration, inventory, technical and methodological support of the Unified Republican Electronic Database of Queue Applicants and the electronic database "Housing Provision Center".

Based on the results of the conducted analysis, an Action Plan was drawn up to eliminate the causes and conditions contributing to the commission of corruption offenses identified through the results of the internal analysis of corruption risks.

The analytical report and the Action Plan based on the results of the conducted analysis are posted on the internet resource of the Bank.

Facts of commission of corruption offenses by the Bank's employees during the reporting year were not identified.

Facts of disciplinary punishments of managers whose subordinates committed corruption crimes are absent in 2025.