The Bank pays special attention to anti-corruption issues. Activities in this direction are carried out on an ongoing basis, in strict accordance with the requirements of the legislation of the Republic of Kazakhstan and internal documents of the Bank.

To prevent corruption offenses, a complex of measures is carried out in the Bank, the ultimate result of which is the elimination of corrupt activities.

The Anti-Corruption Policy and the Anti-Corruption Instruction have been developed and approved by the Bank. Separate procedures and controls are integrated into the Bank's internal documents, including those related to personnel management issues.

The Bank regularly conducts internal training for Bank employees on anti-corruption issues with mandatory testing of the acquired knowledge.

In 2025, anti-corruption training with testing of the acquired 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 unit that performs the functions of anti-corruption compliance in the Bank, is independent of any activities of the Bank's structural units and is accountable through the Chief Compliance Officer to the Bank's Board of Directors.

All Bank employees and individuals providing services to the Bank based on civil law contracts, regardless of the position held, are warned of the obligation to report known facts of corruption in the Bank to their immediate supervisors, to the security unit, or confidentially via the Hotline. At the same time, each employee of the Bank bears personal responsibility for concealing facts of the involvement of any of the Bank's employees in corrupt activities.

The Bank operates a Hotline, which is a means of confidential receipt of information about corruption-related violations on the part of the Bank's employees and consultants. The analysis of requests received in the current year showed that all of them were of an advisory and informational nature and did not contain information indicating the involvement of Bank employees in corrupt actions.

On a quarterly basis, the Bank informs the Anti-Corruption Agency of the Republic of Kazakhstan about the presence/absence of facts of holding the Bank's managers liable for corruption crimes committed by subordinates.

As a result of staff training, the awareness of the Bank's personnel about the Bank's activities on anti-corruption issues, existing restrictions and obligations, and feedback channels have been raised. It is expected that the ongoing measures will minimize the risk of corruption in the Bank's activities.

In the 2nd quarter of 2025, a 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 Bank's Management Board and sent on May 27, 2025, to the Anti-Corruption Agency of the Republic of Kazakhstan (Anti-Corruption Service).

In the 3rd quarter of 2025, an internal analysis of corruption risks was conducted in the activities of the Center for Providing the First Housing of JSC "Otbasy Bank" regarding the formation, maintenance, updating, administration, inventory, technical, and methodological support of the Unified Republican Electronic Database of Waiting List Individuals 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 conducive to the commission of corruption offenses identified as a result of the internal analysis of corruption risks.

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

No facts of commission of corruption offenses by the Bank's employees were identified during the reporting year.