OUR POLICIES:

General provisions
The Shield Group of Companies (hereinafter referred to as GC) strives for a systematic solution to the challenges it faces. Sustainable development is an integral part of the Company's goal setting. In its activities, the Company applies an integrated approach to solving its tasks, striving for a long-term balance between business continuity, creating favorable living and working conditions for its employees, and effective interaction with partners.

1. Scope of application
1) This Policy of the Shield Group of Companies (hereinafter referred to as – The Policy) was developed in accordance with the legislation and regulatory legal acts of the Republic of Kazakhstan, the consortium agreement, the Corporate Governance Code of the Group of Companies and other internal documents regulating the Group's activities, as well as taking into account the requirements of the UN Global Compact, the UN Principles of Responsible Investment, the AA1000 Series of Standards, the International Standard ISO 26000:2010 "Guidelines on Social Responsibility", The Global Reporting Initiative's Sustainability Reporting Standards (GRI Standards).
2) The purpose of this Policy is to define the fundamental norms, principles, rules and approaches that the Civil Code should adhere to in building a management system in the field of sustainable development.
3) Objectives of this Policy:
• define the principles and directions of the Group's activities in the field of sustainable development, including the creation of an effective and transparent system of interaction with stakeholders;
• consolidate the roles, competencies, and responsibilities of each body and all employees of the GC for the implementation of the principles of sustainable development;
• Identify the relationship between sustainable development and key GC processes.
4) When solving tasks in the field of sustainable development, the GC relies on its mission, the provisions of the GC Development Strategy, and also uses international norms of behavior and principles enshrined in international standards in the field of sustainable development.
5) The GC considers the use of international standards in the field of sustainable development as a necessary condition for ensuring that its activities comply with the best international practices and achieve goals and objectives in the field of sustainable development.
6) The provisions of this Policy must be observed by all employees of the Group of Companies in terms of interaction with stakeholders, when planning and carrying out their activities, developing internal regulatory documents, distributing information and other types of communication.
7) The following basic terms and definitions are used in this document:
• The UN Global Compact is the largest international initiative in the field of sustainable development, which aims to introduce ten basic principles in the field of human rights, labor relations, environmental protection and anti–corruption into the business community.;
• interested party (stakeholder) – individuals and legal entities or groups of persons who influence the GC and its activities and/or are influenced by the GC (for example, employees, clients, counterparties, etc.);
• The Development Index is a tool for prioritizing potential projects when deciding whether to provide financial support in accordance with the Group's Development Strategy, state development programs and the goals of the Group's investment activities, calculated in accordance with the adopted Investment Policy of the Group;
• The Stakeholder map is a tool that allows you to systematize and visualize information about the company's environment in order to develop a strategy for working with each of the stakeholders;
• competitors – individuals or legal entities whose field of activity, interests and goals are identical in the field of activity, interests and goals of the Group of Companies;
• counterparties – individuals or legal entities who have assumed certain obligations under the agreement (for example, suppliers, partners);
• The concept of a "green office" is an integrated approach that includes both technical and motivational and educational activities aimed at increasing the level of environmental awareness of employees;
• The international standard ISO 26000:2010 "Guidelines on Social Responsibility" is a standard that defines the principles of social responsibility, the main topics and issues related to social responsibility, and ways to integrate socially responsible behavior into organizational strategies, systems, practices, and processes.;
• UN Principles of Responsible Investment (UN PRI Principles) – a set of principles based on consideration of environmental and social factors, as well as factors of good corporate governance (ESG factors) at all stages of investment activity;
• the precautionary principle – the principle implies the adoption of effective measures to prevent environmental degradation, preventive actions to prevent environmental disasters, even in the absence of their full scientific justification;
• a project is a potential or concluded transaction involving the provision of security services to the Group:
• The AA1000 Series of Standards is a set of tools and standards for managing non–financial reporting and ensuring its quality, developed by the Institute for Account Ability (Institute for Social and Ethical Reporting). The AA1000 series of standards includes:
• The AA1000 Accountability Principles Standard (AA1000APS);
• AA1000 Verification Standard (AA1000AS);
• The AA1000 Stakeholder Engagement Standard (AA1000SES);
• The Global Reporting Initiative's Sustainability Reporting Standards (GRI Standards) are a set of standards that include 3 universal standards applicable to all organizations and include principles and requirements for reporting, general disclosure elements and information about the management approach, and 33 thematic standards containing a series of standards on economic, environmental, and social disclosure. topics;
• Strategy 2050 is a strategy for the development of the Republic of Kazakhstan until 2050, the main goal of which is to create a welfare society based on a strong state, a developed economy and opportunities for universal labor, Kazakhstan's entry into the top thirty most developed countries in the world;
• the structural unit responsible for the direction of activities in the field of sustainable development of the Group of Companies is the structural unit responsible for the development, coordination, monitoring and updating of the development strategy of the Group of Companies;
• Sustainable development – development in which an organization manages the impact of its activities on the environment, economy, and society and makes decisions based on the interests of stakeholders. Sustainable development must meet the needs of the current generation without depriving future generations of the opportunity to meet their needs.;
• ESG factors – a set of principles of environmental efficiency and environmental protection, social orientation and good corporate governance, based on standards recognized by the international community;
• The UN Sustainable Development Goals – 17 goals and 169 targets adopted within the framework of the 2030 Agenda for Sustainable Development and aimed at eradicating poverty, conserving the planet's resources and ensuring well-being for all;

2. Goals and objectives of the GC in the field of sustainable development

1) The sustainable development of the Group of Companies is a set of principles and obligations that guide the Group of Companies in carrying out its activities, in terms of:
• Managing relationships with stakeholders;
• Assessment and management of the impact on the national economy, social sphere and environment.
2) The Group of Companies ensures consistency of its economic, environmental and social goals for sustainable development in the long term.
3) The economic component of the sustainable development of the GK contains the following objectives:
• Break-even performance of the Group of Companies;
• ensuring the interests of the Sole Shareholder and investors;
• Improving process efficiency;
4) increase labor productivity;
5) The environmental component of the sustainable development of the GC contains the following objectives:
• minimizing the impact on biological and physical natural systems;
• optimal use of limited resources;
• application of environmental, energy- and material-saving technologies.
6) The social component of the sustainable development of the GC contains the following objectives:
• Ensuring transparent competitive procedures and equal employment opportunities;
• Fair remuneration and respect for the rights of employees;
• Ensuring occupational safety and preserving the health of employees;
• training and professional development of employees;
• Implementation of internal and external social programs.
7) The objectives of the GC in the field of sustainable development are:
• Integration of the principles of sustainable development into the activities of HC;
• conducting an analysis of activities and risk control in the context of the three components of sustainable development;
• improving the quality of sustainable development management through the organization of systematic work;
• Creation of mechanisms for effective interaction of Society with stakeholders, including regular information on the results of activities in the field of sustainable development.

3. Principles of sustainable development of the Group of Companies

1) The Group of Companies, within the framework of its activities, is guided by the following principles of sustainable development, enshrined in the Code of Corporate Governance (hereinafter CCG) of the Group of Companies, openness, accountability, transparency, ethical behavior, respect for the interests of stakeholders, legality, respect for human rights, intolerance to corruption, inadmissibility of conflicts of interest.
2) The GC also declares its commitment to the principles of the UN Global Compact in its activities:
• In the field of human rights protection:
− The Civil Code ensures and respects the protection of human rights proclaimed at the international level;
− The Civil Code ensures non-involvement in human rights violations.
• in the field of labor relations:
− The Civil Code supports and recognizes the right to conclude collective agreements;
− The Civil Code promotes the elimination of forced and child labor, discrimination in labor and employment.
• In the field of environmental protection:
− GC supports a precautionary approach to environmental issues;
− GC undertakes initiatives aimed at increasing responsibility for the state of the environment;
− GC promotes the development and dissemination of environmentally sound technologies.
• in the field of anti-corruption:
− The Civil Code declares intolerance to all forms of corruption and other illegal actions, including extortion and bribery.

4. Interaction with stakeholders

1) In order to implement a successful and effective sustainable development policy in the Civil Code, due attention is paid to interaction with stakeholders.
2) In order to determine the list of stakeholders, the degree of their influence and spheres of influence on the interests of the Group of Companies, the structural division in charge of activities in the field of sustainable development of the Group of Companies is developing a Map of stakeholders of the Group of Companies.
3) The Civil Code defines three groups of stakeholders depending on the area of impact:
• Area of authority and responsibility (Sole Participant, management body, management and staff);
• area of direct impact (government agencies, suppliers, partners, customers, consumers, auditors and consulting organizations);
• the area of indirect impact (population, public organizations, mass media and competitors).
4) When assessing the importance of the stakeholders of the GC, the stakeholders are ranked according to two factors: the degree of support / opposition of the stakeholder, the assessment of the strength of his influence on the GC.
5) Based on the assessment of the significance of the interested parties, the structural divisions of the State Committee determine the areas of interaction with interested parties, depending on the specifics of the activity.
6) The main forms of interaction with stakeholders are: joint programs and projects, memorandums of cooperation, joint working groups, activity reporting, meetings, publications, interviews, etc.
7) The main areas of interaction with interested parties: strategic planning, financial activities, project management, supply of goods, works and services, lawmaking, operational activities, interaction with the media.
8) GC annually sends questionnaire forms to the main stakeholders, determined by the structural unit in charge of activities in the field of sustainable development, in order to determine the degree of stakeholders' interest, including in issues of sustainable development.
9) The process of organizing the interaction of the GC with stakeholders is based on the principle of engagement, which implies taking into account the interests of stakeholders at all stages of the GC management process and involving stakeholders in discussing significant topics and important issues, potential risks and boundaries of responsibility.
10) In turn, engagement is achieved by following the following three principles:
• Materiality. The GC clearly defines its stakeholders and is aware of which stakeholders' interests are essential.
• completeness. In the course of its activities, the GC pays attention to the concerns of stakeholders, as well as understands their views, needs and expected results, as well as opinions on significant issues.
• Response. The GC consistently responds to the all-important issues of stakeholders.
11) In order to organize the management of relations with interested parties, the Group focuses its activities on the following basic principles:
• Respects and takes into account the interests of all interested parties;
• strives to actively inform target audiences about their activities;
• ensures objectivity, reliability, independence, and a high level of information transparency regarding the implementation of government programs, certain internal procedures (procurement, competitive selection among external candidates for employment, provision of financial and non-financial services), as well as the use of financial resources;
• Ensures open and productive collaboration between all stakeholders;
• fulfills its obligations to interested parties;
• Receives feedback from stakeholders on a regular basis.
12) When formalizing approaches to managing the impact on stakeholders, the Company proceeds from the need to comply with the requirements defined below.
13) When interacting with the Sole Participant and government agencies:
• The Civil Code provides reliable information on the results of financial and economic activities in accordance with the requirements of the legislation of the Republic of Kazakhstan, the Charter and internal documents of the Civil Code;
• The Group of Companies ensures the implementation of the rights of the Sole Shareholder within the framework of corporate governance principles aimed at effective key decision-making;
• The GC provides additional information about plans, achievements, business challenges, as well as research by other organizations on the GC's activities, with the exception of confidential information received from other organizations under contracts and/or agreements on information disclosure and/or confidentiality;
• GC participates in international ratings in the field of sustainable development and credit ratings.
14) When interacting with investors and counterparties:
• The Group of Companies sufficiently discloses up-to-date information about its financial condition, as well as its development prospects;
• The financial and management reports of the Group are prepared and provided in a timely manner in accordance with legislative and regulatory requirements, while the financial statements are reviewed by independent auditors;
• information about the influence of the Sole Participant and other stakeholders (national and local authorities), as well as the procedure for monitoring and approving transactions with interested parties is known, transparent and accessible;
• GC proactively communicates approaches to making investment and strategic decisions;
• GC faithfully fulfills its contractual obligations to business partners;
• The Civil Code ensures information transparency, openness, equality, fairness, non-discrimination and unjustified restrictions on competition, in accordance with the legislation of the Republic of Kazakhstan;
• The Group adheres to the principles of corporate governance and improvement of the corporate governance system in accordance with world-leading practice.
15) When interacting with customers and consumers:
• GC services are accessible to consumers;
• The GC ensures the security of consumer data and commercial information in order to protect their leakage and misuse;
• GC provides services of the same quality and the same level of service without discrimination to all consumer groups;
• GC promotes the improvement of the quality of service and customer service, which is reflected in the improvement of customer service standards;
• GC provides customers with information about new tools and operating principles on a regular basis;
• GK promotes the improvement of financial literacy of consumers and its clients to the best of their abilities and in accessible forms.
16) When interacting with employees:
• The Group of Companies ensures an open, transparent, personnel policy aimed at the formation of qualified and motivated personnel;
• The Civil Code provides all employees with equal opportunities to realize their potential in the course of their work, and an impartial and fair assessment of their activities;
• the selection and career development of employees in the Group is carried out solely on the basis of professional abilities, knowledge and skills;
• Effective communication and employee interaction is ensured through the organization of internal corporate sources for regular employee information and communication channels, regular study of employee opinions and suggestions, and organization of workgroup activities.
17) When interacting with the public:
• The GC effectively and promptly interacts with its own;
• GC actively participates in the implementation of socially significant projects;
• Responses to inquiries sent to the GC are provided in a timely and complete manner;
• The GC organizes regular meetings with the public (round tables, briefings, public access information) to discuss the progress of program implementation, exchange of views;
• The GK's sponsorship and charitable activities are aimed at helping vulnerable segments of the population and low-income citizens, reviving national values, and supporting culture, science, and education.
18) Due to the GC's commitment to the principles of sustainable development, it considers environmental protection and the prevention of negative impacts on it to be one of the main priorities of its activities.
19) The Civil Code follows the principle of zero tolerance for losses and damages related to environmental pollution. It is important for each employee to understand their area of responsibility in the field of ecology in order to minimize negative impacts and improve environmental policy.
20) The GC strives to carry out its activities taking into account the balance of environmental and economic interests. It also strives steadily to improve its performance in the field of environmental protection.
21) Caring for the environment is an integral part of the corporate culture and ensures its sustainable development. To prevent possible negative impacts, GC undertakes obligations and takes all necessary actions to ensure environmental protection, conservation and restoration of natural resources, including constantly improving processes and working conditions for its employees and partners.

5. Activities of the Group of Companies in the field of sustainable development

1) GC's activities in the field of sustainable development cover seven areas, including twenty ESG objectives:
2) Minimizing environmental impact:
• promote the dissemination of high environmental standards among customers and partners;
• ensure that the GC office complies with environmental standards.
3) Creating conditions for effective work and human potential development:
• promote a healthy lifestyle, promote the health and longevity of employees;
• Ensure decent working conditions, professional and personal growth of employees, and gender equality.
4) Ensuring the observance and protection of human rights, an inclusive environment and equal access to products and services:
• to develop a barrier-free environment in the GC office and the client area of the branches, including the development of online insurance;
• Increase the availability of financial products and services, including socially significant products and services for vulnerable groups of the population;
• contribute to improving financial literacy of the population;
• Ensure the observance and protection of human rights, inclusivity and equal opportunities, including gender equality, for all employees.
5) Support local communities and promote social development:
• develop corporate volunteerism;
• Promote a healthy lifestyle, promote the health and longevity of the population.
6) Improving corporate governance, security and ESG risk management practices, including in the supply chain:
• ensure compliance with the requirements and best practices in the field of corporate governance and business ethics of all GC branches;
• Improve the integrated risk management system;
• ensure the cybersecurity of the Group and guarantee the protection of personal data of customers;
• Ensure the prevention of financial crimes/fraud and compliance with anti-corruption legislation.
7) Development of responsible financing practices:
• provide high-demand ESG products and services in all business segments;
• Manage constraints and limits for a positive impact on the environment, social society and the quality of corporate governance.
8) Promoting economic well-being and prosperity for all:
• maintain jobs, develop internal mobility;
• improve the economic efficiency of the company through the introduction of digital and technological solutions;
• promote the development of small and medium-sized businesses and expand their economic opportunities.

6. ESG and Sustainable Development Management System

1) As an organizational mechanism for the implementation of this policy in the GC, an ESG and sustainable development management system has been created, including strategic and operational planning processes, as well as a system of goals and key performance indicators (hereinafter referred to as KPIs), monitoring, the process of making changes, adjustments and reporting.
2) The successful functioning of the ESG and sustainable development management system also presupposes constant activity in three main campaigns:
• Constant interaction with all interested parties;
• Providing communication support and conducting information campaigns;
• Conducting educational and awareness-raising programs in the field of ESG and sustainable development.
3) To implement this policy, the GC develops and will annually update an action plan in the field of ESG and sustainable development. The action plan includes specific initiatives, programs and projects, as well as targets aimed at meeting the challenges of ESG and sustainable development. The implementation of the plan will be regularly evaluated and reflected in the company's non-financial statements.
4) The Company has an effective corporate governance system covering all activities of the Group. The management functions of ESG transformation and sustainable development are integrated into the corporate governance architecture.
5) ESG and Sustainable Development management structure:
• The CEO of GK oversees the implementation of this policy in the field of sustainable development. The SC has identified the person responsible for the ESG agenda;
• Divisions in the Group's business blocks participating in the ESG agenda are responsible divisions in the Group's business areas that implement specific ESG initiatives and provide support to their target audiences.

7. Monitoring and reporting

1) The GC recognizes the importance of monitoring and preparing reports describing the aspects and results of the GC's activities in the field of ESG transformation and sustainability. The reports will be compiled in accordance with internationally recognized guidelines and recommendations.
2) Information on the implementation of this policy, as well as the annual report on the sustainable development of the Group of Companies, will be regularly published on the Internet resourcehttps://shieldgroup.company/
3) Legislative, regulatory and international requirements, as well as recommendations, may change over time, therefore, the GC will monitor such changes and adjust certain tasks and aspects in the field of ESG and sustainable development, as well as make changes to this policy and internal regulatory documentation.

8. Final provisions

1) This Policy comes into force from the date of its approval.
2) The Civil Code strives to implement the provisions of this Policy in its activities.
3) The GC will improve this Policy, taking into account changes in the legislation of the Republic of Kazakhstan and the emergence of new standards in the field of sustainable development in international and national practice, guided by the interests of the Sole Participation of the GC and other stakeholders.

The SHIELD Group of Companies (hereinafter referred to as the Group) is committed to the principles of sustainable development and places environmental protection and the prevention of negative environmental impacts among the main priorities of its activities. We follow the principle of zero tolerance in relation to losses and damages related to environmental pollution.It is important for us to understand our area of responsibility in the field of ecology in order to minimize negative impacts and improve environmental policy.

1. Purpose of the Policy:
This Policy expresses the Company's position in the field of environmental protection. The policy has been developed taking into account the requirements of applicable legislation, including the Environmental Code of the Republic of Kazakhstan dated January 02, 2021 No. 400-VI, as well as the ISO 14001 standard and the best international practices in the field of environmental protection.

2. Scope of application:
The Policy is binding on all employees of the Group, as well as its partners. Administrative, local regulatory and other internal documents should not contradict this Policy.

3. The main provisions:
The Group strives to carry out its activities taking into account the balance of environmental and economic interests. It also strives steadily to improve its performance in the field of environmental protection.

Caring for the environment is an integral part of the Group's corporate culture and ensures its sustainable development. To prevent possible negative impacts, the Group undertakes obligations and takes all necessary actions to ensure environmental protection, conservation and restoration of natural resources, including constantly improving processes and working conditions for its employees and partners.

4. The Group's objectives in the field of environmental protection:
The Group's mission is to effectively manage the impact of the Group's production operations on the environment, ensuring its preservation for the benefit of current and future generations.

The goal is to achieve high performance in the field of environmental safety.

5. The Group's principles in the field of environmental protection:
All the activities carried out by the SHIELD Group of Companies in the field of environmental protection are based on the following principles:

1) compliance with the requirements of the legislation and other requirements applicable to the Company's activities in the field of environmental protection, including the norms of international law by each employee of the Group and his management;

2) preservation of a favorable environment and biological diversity;

3) balancing the interests of the Group and Society in the use of natural resources;

4) intolerance to environmental risks;

5) priority of preventive measures over measures aimed at localization and elimination of consequences of dangerous events;

6) openness and reliability of the Group's reporting in the field of environmental protection;

7) transparency and accessibility of environmental information for all stakeholders in order to respect everyone's right to receive reliable information about the state of the environment;

8) continuity and consistency in achieving goals and objectives in the field of environmental protection.

6. The Group's tasks in the field of environmental protection:

In order to achieve its stated mission and goal, the Group prioritizes the following tasks:

1) ensuring the competence of the Group's employees through information and systematic improvement of the level of environmental education and culture;

2) cooperation with government agencies, partners and other stakeholders aimed at developing relations in the field of nature management and environmental protection;

3) promoting digitalization in the course of activities, ensuring a reduction in the use of paper media and the transition to electronic digital media;

4) reducing the overall level of waste generation by analyzing the sources of its formation, developing and implementing ways to prevent the formation of excess waste where possible, including through sorting and recycling of garbage;

5) carrying out landscaping activities on the adjacent territory of the Group, as well as participation in mass events aimed at cleaning the territories from waste and garbage;

6) active participation in the support and implementation of projects and activities aimed at preserving the environment and renewing natural resources

7) promotion of Environmental Protection Policy using ESG principles among the stakeholders of the external and internal environment of the Group through direct dialogue and also using the information resources of the Group:

8) carrying out an appropriate analysis and evaluation of the work carried out to determine the results achieved and ensure compliance with the principles set out in this Policy;

9) improving the efficiency of the Group's activities through the use of the best international practices for environmental protection.

7. Validity period and procedure for making changes:

This Policy is a local regulatory document of permanent validity.

This Policy and changes to it are approved in the Group by the decision of the Group Director and put into effect by order.

The implementation of this Policy is carried out by the Director of the Group.

Compliance with the requirements of this Policy is monitored using a target indicator monitoring system. The responsibility for keeping this Policy up to date lies with the Group's Director.

The SHIELD Group of Companies (hereinafter referred to as the Group) categorically prohibits the commission of corruption offenses or bribery in any form, carried out directly or through the involvement of third parties (mediation). The Group openly declares its rejection of corruption and voluntarily undertakes additional obligations in the field of preventing corruption offenses.

1. Terms and definitions:

The following terms and definitions are used in this Policy:

1) Anti-corruption legislation of the Republic of Kazakhstan - the Law of the Republic of Kazakhstan "On Combating Corruption" and other regulatory legal acts on anti-corruption issues;

2) Anti-corruption monitoring - the Group's activities to collect, analyze and evaluate information related to the effectiveness of measures taken by the Anti-Corruption Group;

3) Anti-corruption standards - a system of recommendations established for a separate area of activity of the Group aimed at preventing corruption;

4) A bribe - receipt by an employee personally or through an intermediary of a bribe in the form of money, securities, other property, or in the form of illegal provision of property-related services to him, granting other property rights (including when the bribe is transferred to another individual or legal entity on the instructions of an official) for committing actions (inaction) in favor of the bribe giver or represented by him persons if the specified actions (inaction) fall within the official powers of the employee or if, by virtue of his official position, he may contribute to the specified actions (inaction), as well as for general patronage or connivance in the service.

5) Internal analysis of corruption risks - the Group's activities to identify and study the causes and conditions contributing to the commission of corruption offenses;

6) Conflict of interests - a contradiction between the personal interests of employees and their official powers, in which the personal interests of these persons may lead to improper performance of their official powers.

7) Corruption is the illegal use by persons of the Group of their official powers and related opportunities in order to obtain or extract personally or through intermediaries property (non-property) benefits and advantages for themselves or third parties, as well as bribery of these persons by providing benefits and advantages;

8) A corruption offense is an unlawful culpable act (action or omission) that has signs of corruption, for which responsibility is established by the legislation of the Republic of Kazakhstan.;

9) Corruption risk - the possibility of causes and conditions contributing to the commission of corruption offenses;

10) Anti-corruption - the Group's activities within its powers to prevent corruption, including the formation of an anti-corruption culture in the Group, the identification and elimination of causes and conditions conducive to the commission of corruption offenses, as well as the identification, suppression, disclosure and investigation of corruption offenses, and elimination of their consequences;

11) Prevention of corruption - the Group's activities to study, identify, limit and eliminate the causes and conditions conducive to the commission of corruption offenses by developing and implementing a system of preventive measures;

12) An employee is an individual who is in an employment relationship with a Group on the basis of an employment contract.;

The definitions applied but not disclosed in this Policy correspond to those used in the legislation of the Republic of Kazakhstan, the Charter and other internal documents of the Group.

2. General provisions:

1. This Policy of the Group is an internal regulatory document defining the key principles and requirements aimed at combating corruption and minimizing corruption risk, as well as ensuring compliance by the head of the Group and its employees with the norms of applicable anti-corruption legislation.

2. The Policy has been developed in accordance with the legislation of the Republic of Kazakhstan, the Group's Charters, as well as other internal documents of the Group.

3. The provisions of this Policy apply to all employees of the Group, regardless of their position, status and duration of their work in the Group, All employees of the Group must be guided by this Policy and strictly adhere to its principles and requirements.

4. The Group declares its rejection of corruption and intolerance of corrupt behavior in any form and manifestations, monitors compliance with the principles and requirements of the Policy by the head of the Group and its employees.

3. The purpose and objectives in the field of anti-corruption:

5. The purpose of combating corruption in the Group is to minimize the risk of involvement of the Group's management and employees, regardless of their position, in corrupt activities.

6. To achieve this goal, this Policy provides for the following tasks::

1) formation of an understanding of zero tolerance for any corruption among the management and employees of the Company;

2) summarizing and explaining the basic requirements of the anti-corruption legislation of the Republic of Kazakhstan that can be applied to the Group, management and employees;

3) establishing the obligation of the management and employees of the Group to know and comply with the principles and requirements of the anti-corruption legislation of the Republic of Kazakhstan, this Policy, as well as to implement adequate procedures to prevent and prevent corruption;

4) development and implementation of anti-corruption measures aimed at preventing and combating corruption, minimizing and (or) eliminating the consequences of corruption offenses.

4. Basic principles of anti-corruption:

7. The main principles of anti-corruption in the Group are:

1) zero tolerance for any form of corruption - The Group adheres to the principle of complete rejection of corruption in any form and manifestations in the conduct of its activities.

The principle of zero tolerance for any form of corruption means a strict prohibition for the management and employees of the Group acting on behalf of the Group or in its interests, directly or indirectly, personally or through any kind of mediation, to participate in corrupt activities.;

2) the commitment of the leadership to an uncompromising attitude towards corruption.

The Director plays a key role in fostering a culture of intolerance to corruption and creating a corruption prevention and counteraction system in the Group. The Director must declare an irreconcilable attitude towards any form of corruption and at all levels, demonstrate, observe and implement this principle by personal example.;

3) Employee engagement – The Group informs its employees about the provisions of the anti-corruption legislation of the Republic of Kazakhstan and welcomes their active participation in the formation and implementation of anti-corruption standards and procedures;

4) the inevitability of punishment - The Group declares the inevitability of punishment of the group's employees, regardless of their position, work experience and other conditions, if they commit corruption offenses in the performance of their official duties.;

5) Effectiveness of anti-corruption procedures - The Group strives to make procedures as transparent, clear, and feasible as possible, which ensure their easy implementation and meaningful results.;

6) Due diligence - The Group checks third parties and candidates for employment before deciding whether to start or continue a business/employment relationship for their trustworthiness, rejection of corruption and lack of conflict of interest;

7) Interaction and coordination - The Group ensures interaction and cooperation in the field of anti-corruption activities with government agencies, as well as coordination of actions in the process of combating corruption.

5. Requirements of the anti-corruption legislation of the Republic of Kazakhstan and obligations to comply with it:

8. The Group, its management and employees are required to comply with anti-corruption legislation, as well as the principles and requirements of this Policy. In implementing this Policy, the Group assumes that its management and employees are prohibited from engaging in corrupt practices, directly or indirectly, personally or through third parties, and:

1) to offer, promise or perform a bribe, i.e. the provision or promise to provide any financial or other benefit /advantage with the intent to induce any person to perform his official duties improperly;

2) to demand, agree to accept or accept bribes, that is, receiving or agreeing to receive any financial or other benefit/advantage for performing their official duties improperly;

3) offer, promise or make payments, except as provided for by applicable law, to present gifts to persons authorized to perform government functions, as well as to persons equated to them for speeding up or simplifying established procedures;

4) offer, promise, or make payments to third parties if there is a suspicion that payments may be used to speed up or simplify established procedures.;

5) offer, promise, or provide employment to the Group (including on a temporary basis) in exchange for personal gain;

6) facilitate the acceptance or acceptance of inflated or fictitious payments from third parties;

7) to give or receive gifts or hospitality tokens that contradict the requirements of the anti-corruption legislation of the Republic of Kazakhstan and internal documents of the Company.

9. The management and employees of the Group must strictly observe the following standards of conduct in their professional activities:

1) comply with the requirements of the legislation of the Republic of Kazakhstan and this Policy;

2) to be honest and decent in business relations, to refrain from any unfair methods of conducting official duties;

3) to prevent the commission of actions capable of discrediting the Group;

4) not to use for personal purposes the official position and confidential information, tangible and intangible assets of the Group;

5) to prevent illegal actions, or actions that may raise suspicions about their legality and ethics;

6) to support and require colleagues to adhere to a high legal anti-corruption culture;

7) not to incite other employees to commit corruption offenses and not to encourage such actions;

8) not to perform official duties in the presence of a conflict of interests.

10. The Group's employees are required to:

1) refrain from committing and/or participating in the commission of corruption offenses in the interests of or on behalf of the Group;

2) refrain from behavior that may be interpreted by others as willingness to commit or participate in the commission of a corruption offense in the interests of or on behalf of the Group;

3) inform management about the possibility of an employee's conflict of interest.

If they have doubts about the correctness of their actions or about any other standards of behavior, the Group's employees can contact the management.

6. A set of measures to prevent and combat corruption:

11. Corruption risks may arise in some areas of the Group's activities. Such areas include, but are not limited to, the following:

1) involvement of third parties and making payments to third parties;

2) gifts and representation expenses;

3) participation in political activities;

4) payments to persons holding a responsible government position, persons authorized to perform government functions, as well as persons equated to them, including foreign officials;

5) Personnel management.

6.1 Involvement of third parties and making payments to third parties:

12. The Group refrains from involving third parties and from participating in joint projects with partners that violate the principles and requirements of the anti-corruption legislation of the Republic of Kazakhstan, this Policy or create a risk of loss of business reputation for the Group.

13. Before making a decision on starting or continuing business cooperation with third parties or participating in a joint project, the relevant structural units of the Group initiating the involvement of third parties are required to:

1) monitor third parties and joint project partners for any manifestations of corruption by carrying out the following procedures (including, but not limited to):

- verification of the availability of their own anti-corruption policies and procedures, willingness to comply with the requirements of this Policy and to carry out mutual cooperation in the field of anti-corruption;

- verification of business reputation and absence of conflict of interests;

- checking for false entrepreneurship, reliability, tax and other debts, the source of funds, as well as the bank, the jurisdiction from which the funds obtained through criminal means are sent, by sending requests to the relevant authorized state bodies and organizations (the Ministry of Finance of the Republic of Kazakhstan, the National Bank of the Republic of Kazakhstan and others);

2) include an anti-corruption clause in the concluded transactions, the form and content of which is given in Appendix No. 1 to this Policy. The Group reserves the right to terminate transactions with third parties and joint venture partners in the event of corruption on their part.;

3) inform third parties and joint project partners about the principles and requirements of this Policy.

14. The Company welcomes the adoption by third parties and joint project partners of anti-corruption policies and procedures, as well as standards of conduct.

6.2 Gifts and representation expenses:

15. The Group recognizes the exchange of business gifts and the implementation of representative expenses, including business hospitality, as a necessary part of the implementation of activities and generally accepted business practices.

16. The Group promotes an atmosphere of honesty and transparency regarding business gifts and business hospitality expenses.

17. The exchange of business gifts and the implementation of representative expenses, including for the Group's business hospitality with third parties, must meet the following criteria:

1) fully comply with the norms of the current legislation of the Republic of Kazakhstan, internal documents of the Company on representation expenses;

2) be reasonably justified, proportionate, not to be cash or non-cash monetary funds, securities, precious metals and not to represent other types or equivalents of funds, as well as not to be a luxury item;

3) not to represent a hidden reward for a service, action, omission, connivance, patronage, granting rights, making a specific decision on a transaction, agreement, license, permit, etc., or an attempt to influence the recipient for another illegal or unethical purpose;

4) not to create a risk that could lead to a loss of business reputation for the Group, its management and employees.

18. If there are doubts about the compliance of a business gift or event with the requirements of this Policy, an employee of the Group should consult with the management of the Group.

6.3 Participation in political activities:

19. The Group does not participate in political activities for the direct or indirect purpose of influencing the decision-making by public officials or other persons affecting the preservation or expansion of the Group's activities, or if such participation may be perceived as an attempt to exert such influence.

20. The Group does not independently or through its employees finance political parties or public associations in order to gain or maintain an advantage in its activities.

21. The management and employees of the Group have the right to participate in public associations established in accordance with the current legislation of the Republic of Kazakhstan, as well as in international public associations whose purpose is not to obtain or maintain an advantage for the Group in their activities.

22. The management and employees of the Group, when participating in public associations, are prohibited from offering, giving, promising, or making payments, depositing property, giving gifts, etc. on behalf of the Group in order to obtain or maintain an advantage for the Group in its activities.

23. The management and employees of the Group are independently responsible in accordance with the current legislation of the Republic of Kazakhstan for participation in public associations.

6.4 Payments to persons holding responsible government positions, persons authorized to perform government functions, as well as persons equated to them, including foreign officials:

24. The Group does not independently or through its employees pay any expenses for persons holding a responsible government position, persons authorized to perform government functions, as well as persons equated to them, including foreign officials, to their close relatives in order to obtain commercial advantages for the Group, including expenses for transportation, accommodation, food, entertainment, PR campaigns, etc., or for them to receive other benefits at the expense of the Group.

25. The Group does not pay fees for simplification of formalities directly or through its agents, with the exception of official fees for public services, the information and amount of which are publicly available.

6.5 Personnel management:

26. The Group adheres to the principles of objectivity and honesty when making personnel decisions. In order to eliminate corruption risks in the recruitment, evaluation, promotion and dismissal of employees, the Group:

1) develops and approves, in accordance with the established procedure, transparent procedures for the selection and hiring of employees and the relevant qualification requirements for the position;

2) checks candidates for employment before making a decision on the beginning or continuation of an employment relationship for their trustworthiness and absence of a conflict of interests;

3) evaluates the activities of employees and pays remuneration based on the effectiveness of their key performance indicators and professional achievements;

4) decides on the promotion to a higher position based on the business qualities and qualifications of the employee;

5) carries out the procedure for termination of employment relations with an employee on the grounds provided for by the legislation of the Republic of Kazakhstan and internal documents of the Group.

27. When applying for a job or continuing an employment relationship with the Company, employees assume anti-corruption restrictions in the form of consent to adopt anti-corruption restrictions in accordance with Appendix No. 2 to this Policy, which are recorded in writing by the structural unit of the Personnel Management Group.

28. Failure to comply with anti-corruption restrictions by the group's employees entails refusal to be hired or dismissed from office, and failure to comply with them in cases where there are no signs of a criminal offense or an administrative offense is the basis for termination of authority.

7. Prevention and resolution of conflicts of interest:

29. Conflict of interest management is one of the most important anti-corruption mechanisms. The Group pays great attention to preventing and resolving the risks associated with conflicts of interest.

30. The management and employees of the Group, when performing their official duties, are obliged to be guided by the interests of the Group and avoid situations or circumstances in which their personal interests would conflict with the interests of the Group. In the event of a conflict of interest (or the possibility of one), the Group's employees are required to bring this information to the attention of the Group's management in writing.

31. The management of the Group, upon requests from the Group's employees or upon receiving information from other sources, is obliged to take timely appropriate response measures in accordance with the Policy on Preventing and Resolving Conflicts of Interest in the Group.

32. The Company must keep records of affiliated companies, as well as maintain a list of insiders of the Group in accordance with the requirements of the legislation of the Republic of Kazakhstan and internal documents of the Group.

7.1 Identification and assessment of corruption risks:

33. The Group annually identifies and evaluates corruption risks and develops measures to minimize them.

34. The purpose of identifying and assessing corruption risks is to identify those areas of the Group's activities that are at risk of non-compliance with anti-corruption legislation, and where there is a high probability that the Group's management and employees will commit corruption offenses, both for personal gain and for the benefit of the Group.

35. Identification and assessment of corruption risks is based on anti-corruption monitoring and internal analysis of corruption risks.

36. Anti-corruption monitoring includes the following measures, but is not limited to the following:

1) conducting a compliance examination of the Group's key internal documents and their drafts submitted for approval for the presence of provisions in them that contribute to the creation of causes and conditions for the manifestation of corruption (corruption-causing factors), and developing proposals to eliminate them;

2) monitoring the anti-corruption legislation of the Republic of Kazakhstan, as well as the anti-corruption legislation of foreign countries that influence the Group's activities in order to promptly bring its internal documents into line with the changing requirements of anti-corruption legislation;

3) study of statistics of appeals from individuals and legal entities on the facts of corruption on the part of the management and employees of the Group;

4) monitoring of publications in the mass media.

37. The object of the internal analysis of corruption risks is the activity of the Group's structural unit and includes:

1) identification of "critical points" of activity, during the implementation of which corruption offenses are most likely to occur;

2) a description of corruption schemes that contain:

a) a description of the benefits or advantages that can be obtained by the Group or its individual employees when committing a corruption offense;

b) positions in the Group that are "key" to the commission of a corruption offense;

c) probable forms of corrupt payments;

3) determining the presence or absence of internal control procedures, evaluating the effectiveness of existing control procedures.

38. For any corruption scheme, a zero level of risk tolerance has been adopted, and in each case, the Group develops measures to minimize the risks of corruption identified by internal analysis.

39. The procedure for identifying and assessing corruption risks and developing measures to minimize them is regulated by the Group's internal documents.

7.2 Development of anti-corruption standards, formation of an anti-corruption culture:

40. The Group is developing anti-corruption standards, the purpose of which is to establish a system of recommendations aimed at preventing corruption in a separate field of activity.

41. Anti-corruption standards are taken into account when developing the Group's internal documents.

42. The objectives of developing anti-corruption standards are:

1) formation of sustainable anti-corruption behavior among persons working in the Group;

2) timely detection of corruption and prevention of its negative consequences.

43. The formation of an anti-corruption culture in the Group is carried out through a set of educational, informational and organizational measures.

44. The Group carries out activities to inform and clarify the principles and norms of applicable anti-corruption legislation, this Policy and other internal documents in the field of anti-corruption, including training and testing of the Group's employees.

45. The Group welcomes the active participation of all its staff in shaping anti-corruption policies and procedures.

7.3 Reports of corruption offenses:

46. If there is any evidence that a corruption offense committed by an employee of the Group has taken place in the Group, this should be immediately reported to the hotline, information about which is posted on the Group's corporate website, or to the Group's management.

7.4 Official investigations of corruption offenses:

47. For all reports of corruption offenses in the Group, an audit or internal investigation is conducted with the participation of the relevant structural units of the Group within a reasonable time.

48. If, as a result of an internal investigation, the fact of corruption is established, the completion of the investigation is considered to be the adoption of corrective measures based on the principle of zero tolerance for any manifestations of corruption, up to the termination of employment relations and the transfer of materials to the relevant authorized state bodies, as well as the improvement of control procedures.

7.5 Mutual cooperation:

49. The Group cooperates with authorized government agencies and organizations, associates and third parties in the field of anti-corruption on the basis of the principle of reciprocity, in order to:

1) informing about cases of violations with signs of corruption;

2) assistance in conducting investigations of violations with signs of corruption;

3) coordination during inspections of the Group's activities on compliance with anti-corruption legislation and the development of joint measures to prevent and combat corruption;

4) providing comments/participating in meetings (meetings) at the request of authorized government agencies and organizations related to anti-corruption legislation.

8. Responsibility:

50. The management and employees of the Group bear the responsibility established by the legislation of the Republic of Kazakhstan for committing corruption offenses.

57. The management and employees of the Group, to whom appropriate measures have been applied for committing corruption offenses, are not exempt from liability and compensation for material damage to the Group, except by a court decision of the Republic of Kazakhstan that has entered into force.

58. The management, employees and structural divisions of Group A are responsible for the implementation of the requirements of this Policy within their competence.

Appendix No. 1

Use this form to confirm that you are committed to faithfully follow and strictly comply with the anti-corruption legislation of the Republic of Kazakhstan and the Anti-Corruption Policy of the SHIELD Group of Companies.

The completed and signed confirmation form is stored in the personal file of the Group's employees from the moment they perform their work and/or official duties in the Group.

CONFIRMATION

* Please mark
the appropriate boxes. I confirm that I have studied the Anti-Corruption Policy of the SHIELD Group of Companies;
I undertake to strictly follow the requirements established by the anti-corruption legislation of the Republic of Kazakhstan, the Anti-Corruption Policy in the SHIELD Group of Companies;
I have been notified that if I violate the anti-corruption legislation of the Republic of Kazakhstan and the Anti-Corruption Policy in the SHIELD Group of Companies, I may be held accountable, including dismissed from my position, in accordance with the procedure established by the legislation of the Republic of Kazakhstan.

(Full name, position)

(date, signature)

Appendix No. 2

Use this form to confirm that you accept the anti-corruption restrictions provided for by the anti-corruption legislation of the Republic of Kazakhstan and the Anti-Corruption Policy of the SHIELD Group of Companies.

A completed and signed confirmation form from the date of performance of employment and/or official duties in the SHIELD Group of Companies. it is stored in the personal file of employees.

The form of consent on the adoption of anti-corruption restrictions

I, __________________________________________________________________

(last name, first name, patronymic)

___________________________________________________________________

(specify position)

in order to comply with the requirements of the anti-corruption legislation of the Republic of Kazakhstan, the Anti-Corruption Policy in the SHIELD Group of Companies, and to prevent the commission of actions that may lead to the use of my powers in personal, group and other non-official interests, I assume anti-corruption restrictions on:

1) carrying out activities incompatible with the performance of their functions;

2) the inadmissibility of joint service (work) of close relatives, spouses and relatives;

3) the use of official and other information that is not subject to official dissemination in order to obtain or extract property and non-property benefits and advantages;

4) acceptance by me and my family members of material remuneration, gifts or services for actions (inaction) in favor of the persons who provided them, if such actions fall within my official powers or I, by virtue of my official position, can contribute to such actions (inaction).

_________________________________

(date, signature)

Appendix No. 3

Form and content of the anti-corruption clause

1. The SHIELD Group of Companies (hereinafter referred to as the Group) informs the other Party to the Agreement about the principles and requirements of the Group's Anti-Corruption Policy (hereinafter referred to as the Policy).

By signing the Agreement, the other Party confirms familiarization with the Group's Policy. When fulfilling their obligations under the Agreement, the Parties undertake to comply with and ensure that their employees comply with the requirements of the anti-corruption legislation of the Republic of Kazakhstan, as well as not to commit corruption offenses provided for in international acts and anti-corruption laws of foreign states applicable for the purposes of the Agreement.

2. Corruption offenses for the purposes of the Contract include intentional acts committed when giving or receiving bribes, commercial bribery or other illegal use by an employee of the Parties of his official position contrary to the legitimate interests of the Parties in order to obtain benefits in the form of money, valuables, gifts and other property or services of a property, physical or moral nature, obtaining other property rights for for themselves or for third parties, or the illegal provision of such benefits to the specified person by other individuals, and obtaining other property benefits and advantages, in accordance with the anti-corruption legislation of the Republic of Kazakhstan or the host country and/or the Party's activities (hereinafter referred to as corruption offenses).

3. If a Party has a reasonable assumption that a corruption offense has occurred or may occur (upon receiving information about the initiation of criminal proceedings against an employee(s) of the other Party in connection with the commission of a corruption offense or other reliable information about a corruption offense), such Party undertakes to notify the other Party in writing, indicating relevant facts (more - notification) and has the right not to fulfill obligations under the Agreement until receiving confirmation from the other Party that a corruption offense has not occurred or cannot occur.

The specified confirmation must be provided by the other Party within 10 (ten) calendar days from the date of receipt of the notification.

4. Upon receiving reliable information about the commission of a corruption offense and subject to the provisions of this Article, the Company has the right to unilaterally cancel the Contract in whole or in part by sending a corresponding written notification to the other Party, as well as to demand compensation from the other Party for damages caused by the termination of the Contract.

5. If the other Party to the Agreement suspects that any provisions of the Agreement have been violated or may be violated, the other Party to the Agreement undertakes to immediately notify the Group in any convenient way, including through the hotline, the contact information of which is posted on the Group's corporate website.

1. Introduction:
The Shield Group of Companies (the SHIELD Group or GC) maintains relationships with many different organizations in its service chain. In light of the General Employment and Human Rights Act and, in particular, the laws against modern slavery and human trafficking, the Group has developed policies and procedures aimed at identifying, preventing and reducing the risk of modern slavery and human trafficking, and encourages employees and contractors to report any alleged or actual violations of the principles set out in the policy of the Group, or the management of the GC "SHIELD".

We are one of the largest and fastest growing companies in the Republic of Kazakhstan. The Group is present in 7 countries around the world, and since 2018 it has been a permanent provider of UN security services. This economic potential implies a corporate responsibility to protect and respect our employees and related organizations, their families, and the local environment. The remuneration of all employees exceeds the minimum wage, and in Kazakhstan, wages are higher than the subsistence minimum set by the Government of Kazakhstan. We conduct a dialogue with our employees, as well as consult with them on changing working conditions and conducting our business activities.

We have adopted a statement of our corporate values to prevent modern slavery and human trafficking. This statement of values governs all of our business relationships and the behavior of all individuals or organizations with whom we work directly. We expect that everyone who has or aspires to have a business relationship with the Shield Group of Companies will become familiar with our anti-slavery values and will always act in accordance with them.

2. Fundamental values:

As part of our management culture for good business practices, at SHIELD Group we are guided by a set of fundamental values that characterize our relationships with customers and our employees. We accept a behavioral value that reflects our attitude towards human exploitation in any form and, in particular, to offenses provided for by laws against modern slavery and human trafficking. We strive to counteract modern slavery in all its forms and prevent it by any means possible. We demand the same approach from everyone who works for us and expect it from those with whom we have business relationships.

The Group has also established standards, where the basic provisions are: prohibition of any forced, compulsory, bonded or child labor, seizure of passports or identity documents, receipt of deposits, restriction of freedom of movement and levying fees for hiring staff. All employees of the SHIELD Group of Companies have employment contracts indicating their rights and obligations, receive salaries above the minimum wage established by law, and have an equal position with respect to working hours, which fully complies with the restrictions established by law. Cruel or inhuman treatment is strictly prohibited, and employees have the legal right to terminate their employment contract and leave their workplace at any time.

The objectives of the Human Rights Group's Policy are to ensure respect for human rights for all, in all aspects of the Group's activities, as well as in the society in which it operates. We have adopted the United Nations Guiding Principles on Business and Human Rights.

Our policy reflects our commitment to act in good faith with respect to all our business relationships in order to ensure that there is no slavery or human trafficking in our service chains.

3. Purpose:

Modern slavery is a criminal offense under the laws on combating modern slavery and human trafficking. Modern slavery can manifest itself in various forms, including servitude, forced or compulsory labor, and human trafficking, all of which deprive a person of freedom while others exploit him for personal or commercial gain. This document sets out the Group's policy, which aims to prevent the possibility of modern slavery within the framework of its activities and the provision of services to clients.

The term "modern slavery" used in this Policy has the meaning specified in the applicable laws on combating modern slavery and human trafficking. The group uses a zero tolerance approach towards modern slavery. We strive to act ethically and in good faith in all of our business operations and relationships, and to implement and enforce effective systems and controls to ensure that modern slavery does not occur in any part of our operations or those of our clients.

4. Prevention:

We strive to ensure transparency of our own activities and our approach to combating modern slavery in all our service delivery chains, consistent with our disclosure obligations under anti-modern slavery and human trafficking laws. We expect all our business partners to adhere to the same high standards, and we are also developing and updating our contract processes to include specific prohibitions on the use of forced, compulsory, or trafficked labor, as well as the labor of any person in slavery or servitude, whether adults or children.

We expect our clients to set the same high standards for their partners. Compliance with this Policy is part of the obligations of all employees of the Group under the employment contract with them. While acknowledging our statutory obligation to outline the steps we have taken to prevent modern-day slavery and human trafficking in our service chains, we admit that we do not fully control the behavior of individuals and organizations in our service chains.

In order to back up our compliance with actual actions, we intend to implement the following four measures:

1) conduct a risk assessment to determine which areas of our business and which of our partners' activities are most at risk of modern slavery, in order to focus efforts on these areas;

2) Interact with our clients to communicate our Policies to them and gain insight into the measures they are taking to ensure that modern slavery does not take place in their operations.;

3) where appropriate, in accordance with our risk assessment, strive to introduce pre-selection of partners and self-provision of information for our clients to monitor the measures taken;

4) introduce contractual provisions for our suppliers to confirm their commitment to this Policy and accept our right to review their activities and (where possible) relationships, both as a matter of routine and in the case of reasonable suspicion.

5. Responsibility:

The ultimate responsibility for the prevention and self-prevention of modern slavery rests with the Group's top management. The Group's Director is fully responsible for ensuring that this Policy and its implementation comply with our legal and ethical obligations. Managers at all levels are responsible for ensuring that their subordinates understand and act in accordance with this Policy, as well as receive appropriate regular training, both on it and on the issue of modern slavery itself.

6. Informing:

6.1 Procedure for reporting violations:
The Group has a Procedure for Reporting violations aimed at providing recommendations on how to inform the Group about what is causing concern. Employees can report their concerns about suspected modern–day slavery associated with the Group or its partners as follows: the Group employee should contact the Group Director and outline the complaint, who, in turn, will determine the Group's future course of action.

6.2 Confidential feedback line:
Those who have gained access to this Policy because they want to be in business relations with us/our fields of activity or already have business relations with us/our fields of activity are also advised to familiarize themselves with the main features of our measures to combat modern slavery.:

A confidential line for reporting suspicious activity + 7 ***********.

This line can be used by employees or any other person who wishes to express concern. You should call this line under one of the following circumstances:

1) You suspect that a person acting on behalf of a Group is trying to exploit another person in a way that could amount to modern-day slavery;

2) Do you suspect that a person acting on behalf of one of our partners is trying to exploit another person in a way that could amount to modern-day slavery;

3) You were contacted by a person acting on behalf of the Group, who invited you to participate in actions that could lead to the commission of an offense in accordance with the laws on combating modern slavery and human trafficking;

4) You have information from which it can be reasonably concluded that a person acting on behalf of the Group or its partners is preparing to commit, is committing, or has committed an act that violates laws against modern slavery and human trafficking.

Information received on a Confidential Line for reporting suspicious activity (hereinafter referred to as the "Line") They are kept secret, taking into account that the Group must act responsibly and within the framework of the law. The source of the information transmitted to the Line will be kept secret, except in cases where maintaining this secrecy or anonymity of the source is not permitted by law or is incompatible with our compliance with appropriate procedures to prevent modern slavery committed on our behalf or in some element of our service activities.

6.3 Direct communication:
The Shield Group of Companies calls on members of the public or people who do not work with us to send us an email on a confidential basis if they have any concerns or suspicions about modern slavery in any area of our business or related to us.

6.4 Guarantees:
We strive to encourage openness and will support anyone who well-intentioned expresses concern by reporting the issues identified under this Policy, even if it turns out that they are mistaken. We strive to ensure that no one suffers any negative impact as a result of conscientiously reporting suspicions that modern slavery exists in any form. Such a negative impact includes dismissal, threats, or other adverse effects related to something that may cause concern. The Group will accept and take seriously the concerns expressed anonymously. However, maintaining anonymity significantly complicates the investigation and verification and may make the process less effective. Thus, individuals are encouraged to provide their names in their statements of accusations. If any statements or accusations are considered malicious or unfair, disciplinary measures will be applied against the person who provided them.

7. Informing and informing about this Policy:
Our zero tolerance approach to modern slavery should be communicated to all our business partners at the very beginning of our business relations with them and further consolidated accordingly.

8. Review:
This policy was approved by the Director in 202... and is subject to annual review.