The Bank has a Code of Business Ethics in place, which was developed in accordance with the legislation of the Republic of Kazakhstan, the Charter and internal documents of the Bank, and the Code of Business Ethics of JSC "Baiterek" NIH". It incorporates recognized international standards of business conduct and corporate governance, serving as a collection of rules that establish the foundational values and principles of corporate (business) ethics to guide the Bank's employees.

The Code applies to the members of the Bank's Board of Directors and to all employees of the Bank, regardless of their position, and is implemented alongside other internal documents of the Bank. Employees are guided by the requirements of the Code in their relations with the Sole Shareholder, members of the Board of Directors, the Management Board, colleagues, clients, partners, and suppliers.

Ethical Principles.

1.    The Bank provides equal opportunities and, under no circumstances, tolerates discrimination based on gender, age, race, political views, religious beliefs, or other similar grounds.

2.    The recruitment and career advancement of personnel are carried out solely on the basis of professional knowledge, experience, and competencies in accordance with the internal documents of the Bank, excluding any manifestations of discrimination. Career advancement is based on an objective evaluation of performance results, qualifications, and competence.

3.    The Bank provides all employees with equal opportunities for development, which depend on achieved results, competence, and qualifications. In turn, the Bank expects initiative from all team members, a desire to acquire new knowledge, and a readiness to share this knowledge with colleagues.

4.    The granting of any privileges or benefits to individual workers/employees of the Bank is prohibited.

5. In the area of establishing fair remuneration, the Bank relies on the recognition of labor results, the achievement of key performance indicators, the level of qualifications and competencies, as well as the complexity and quality of the performed work.

The Bank operates an ombudsman institution to collect information regarding non-compliance with the Code of Business Ethics, conduct employee consultations on the provisions of the Code, initiate the review of disputes regarding violations of the Code's provisions, and participate in their settlement.

In 2025, as part of the execution of the Action Plan to Ensure Diversity and Inclusion at JSC "Otbasy Bank", an online meeting with the Bank's Ombudsman, Aidapkelov Nurbolat Sergalievich, was organized for the Bank's employees via the ZOOM platform. During the meeting, employees were introduced to the Ombudsman, discussed matters falling within the Ombudsman's competence, outlined the procedure for interacting with the Ombudsman, and reviewed key aspects of the Code of Business Ethics.