Conflict of Interest

The Bank has approved the Corporate Conflicts and Conflicts of Interest Policy, which defines a list of measures aimed at preventing conflicts of interest in the Bank, which is based on the collision of opposite interests, opinions, goals, and different ideas about 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, as well as defines their responsibility.

In accordance with the requirements of the Policy, in order to prevent a conflict of interest, officials and employees of the Bank are obliged to avoid any actions and relations that could potentially cause a conflict of interest. Any conflict of interest between personal interests and professional responsibilities in the Bank must be disclosed and settled as required by the laws of the Republic of Kazakhstan and the Policy. To exclude a conflict of interest, the Bank’s employees sign an undertaking to comply with the actions limiting the risk of a conflict of interest.

The Regulations on the Bank’s Board of Directors also provide that the Chair of the Board shall take measures to resolve corporate conflicts and minimize their negative impact on the Bank’s operations. In cases where such conflicts cannot be resolved independently, the Chair shall promptly inform the Sole Shareholder. The Bank confirms there are no appeals of the Sole Shareholder in connection with corporate conflict with the Bank and its officials in 2024.

Additionally, no instances of conflict of interest, including those involving the Bank’s officers, were identified in 2024.