Corporate Code of Ethics

COMPANY MISSION

By supplying modern, high-quality workwear, safety footwear and PPE to enterprises, we:

• create highly safe and comfortable working conditions for employees at any enterprise;
• protect people's health and lives from the harmful effects of adverse production and environmental factors;
• preserve the labor potential and health of the nation.

GENERAL PROVISIONS

• The Corporate Code of Ethics of the Vostok-Service Group of Companies (hereinafter — the Company) has been developed to strengthen business reputation, promote honest and ethical business conduct, prevent abuses and violations of the law, and to establish professional, respectful and responsible relationships between employees, clients and partners of the Company.
• The Code contains the Company's standards and requirements in the field of compliance with ethical and business principles and norms and is not exhaustive. Where applicable, current legislation and legal principles take precedence.
• The Code defines the rules for the Company's relations with clients, partners, government authorities, and individuals and legal entities.
• The purpose of the Code is to form a unified behavioral and moral-ethical concept for employees and other persons acting on behalf of the Company in the course of business.
• The provisions of the Code must be observed by employees not only at work, but also during various events outside working hours, if they affect the Company's interests or if the employee is perceived by third parties as a representative of the Company.

OUR VALUES

1. People

Our Company brings together people who are passionate about their work, experts in various fields. We value experience, support initiative, and strive to create a comfortable working environment for every employee. Working with professionals in the creation of clothing, footwear and protective equipment enables the Company to achieve stable results and confidently move forward.

People are the Company's most important asset. Thanks to the talents of employees, their knowledge, professional competencies, and desire to discover new things, create useful products and develop dynamically, the Company remains a market leader.

2. Innovation

Innovation has always been a top priority for the Company. The most advanced and progressive ideas, trends, developments and technologies inspire our employees to create new products, relevant digital solutions and in-demand services. This allows the Company to respond quickly to market demands, be at the forefront and stay one step ahead of its time.

3. Development

Continuous and ongoing development is one of the main principles of our Company's work. In a rapidly changing world, continuous learning and development are essential. By developing, the Company maintains competitiveness, attracts top clients and talent, and increases efficiency and profitability. Innovation and adaptation to change are part of its DNA.

For personnel, continuous learning and growth are key to resilience. Professions transform and new skills are required. By mastering new competencies, employees increase their value, open up paths for career advancement, increase income and maintain motivation to act.

4. Healthy lifestyle

An active lifestyle, participation in sports and strong health enable us to live and work productively. This is one of the Company's significant values.

Employees who engage in sports and lead an active lifestyle are organized, goal-oriented and responsible, ready to work individually and as part of a team; they know firsthand about the will to win and achieve goals. Their physical and mental health provide energy and productivity, high concentration and creativity, leading to excellent results and innovation.

Healthy employees are an important component of success, therefore a healthy lifestyle is a principle embedded in the culture of the Vostok-Service Group.

5. Creativity

Creativity is the engine of innovation and a key company value. Real progress is born not from routine but from the desire to create something new. By encouraging bold ideas and experiments, the Company turns hypotheses into breakthrough products and services, and our employees, seeing the results of their efforts, work with enthusiasm and engagement.

For us, creativity is a conscious choice. By creating products, processes, culture and knowledge, we build a foundation for long-term growth, do not wait for change but initiate it, turning the team's energy into value for clients and sustainable success for our Company.

CORE PRINCIPLES OF BUSINESS CONDUCT

The most important principles and values of honest and ethical business conduct that our Company follows and strictly adheres to are:

1. Social responsibility:

• the pursuit of legality and accountability in business activities;
• conducting open and transparent operations.

2. General business responsibility:

• a ban on giving and receiving bribes in any form and under any circumstances;
• honest dealings with clients, suppliers and competitors;
• compliance with the provisions of this Code, competition protection laws, antimonopoly legislation, laws on countering money laundering and corruption;
• careful selection of business partners, clients and suppliers;
• a ban on the use of child or forced labor in production activities;
• disclosure of truthful information in marketing and advertising campaigns.

3. Responsibility to clients:

• observance of professional standards in business conduct;
• protection of clients' confidential information;
• fulfillment of legal obligations;
• avoidance of abuse of rights;
• avoidance of granting clients unjustified privileges not provided by law;
• avoidance of disseminating information that damages clients' reputation.

4. Responsibility to employees:

• respect for all Company employees;
• prohibition of insults and harassment of Company employees;
• creation and maintenance of a safe workplace;
• respecting the confidentiality of employees' personal data;
• social responsibility expressed in professional management of employees' health protection, timely payment of wages and contributions to the relevant budgets;
• improvement of the employee training and motivation system;
• ensuring accounting for individual employee performance;
• use of voluntary labor;
• use of voluntary overtime, compensated in accordance with laws and regulations.

5. Employees' responsibility to the Company:

• to look after the Company's good name and not harm its activities or reputation;
• to conscientiously perform their job duties;
• to comply with the Company's internal standards;
• not to use internal information for personal, including selfish, purposes;
• not to compete with the Company for personal gain;
• to protect the Company's intellectual property;
• to use the Company's resources carefully and efficiently.

RELATIONSHIPS WITHIN THE COMPANY

1. Corporate principles

Hiring and promotion in our Company are based on employees' competencies, abilities and work achievements without discrimination, regardless of gender, origin, religion or other circumstances unrelated to employees' professional qualities.

The Company values and rewards employees whose activities are the foundation of success, and expects high standards of business conduct and professional achievements from them.

The Company promotes the professional development of employees to ensure high productivity and quality performance of their duties.

The Company respects the confidentiality of employees' personal data. Only information necessary for effective work and required in accordance with the legislation in the Company's operating territories may be collected and stored.

All our divisions are open to each other to consolidate efforts to achieve a common result.

2. General principles and rules of internal corporate conduct

For effective work and stable development of the Company, our employees adhere to the following principles and rules of internal corporate conduct:

• professional performance of duties, compliance with legal requirements and internal labor regulations, responsibility for the results of collective work;
• maintaining impartiality when preparing and making decisions, guided solely by the Company's interests;
• competent, efficient and honest use and management of the Company's property and funds, exclusively for official purposes;
• observance of subordination when resolving issues, submitting well-considered decisions to the immediate supervisor for review, and executing adopted decisions responsibly and within established deadlines;
• respect for the qualifications, views and achievements of colleagues;
• maintaining a healthy, efficient, creative and development-friendly working environment; in conflict situations — acting in accordance with one's job responsibilities and this Code;
• maintaining proper health, timely disease prevention, and annual use of vacation according to the vacation schedule: a healthy lifestyle is encouraged in our Company;
• striving to share knowledge and work experience within the Company;
• absence of prejudice and discrimination (verbal or behavioral) towards anyone based on race, religion, nationality, gender or political affiliation, social origin, property or job status, language of communication and other circumstances;
• upon dismissal — refraining from public statements and critical remarks about Company management, and not using information, developments, inventions and technologies acquired during employment that constitute commercial secrets.

3. Principles of managerial function execution

A manager of any level sets an example of behavior, prevents unacceptable conduct by subordinates, conducts explanatory work on the Company's behavioral rules, and acts as a mediator in conflicts and disputes.

In their work a manager follows corporate principles:

• objectivity, goodwill, attentiveness, impartiality and fairness in relations with subordinates and in evaluating their performance;
• rational delegation of authority, building and maintaining a stable favorable climate in the team that ensures open exchange of opinions and enables subordinates to realize their potential, contributing to effective task resolution;
• selection and promotion of competent, promising employees who contribute to achieving the Company's strategic goals, and creating conditions for their training and professional development.

ANTI-CORRUPTION POLICY

1. General provisions

Our Company adheres to the "zero tolerance" principle, i.e., rejection of corruption in any of its forms and manifestations, including in interactions with its counterparties (clients and business partners), as well as with state and municipal officials, representatives of public organizations and political parties.

The "zero tolerance" principle means a strict prohibition for employees acting on behalf of or in the interests of the Company in any country, personally or through third parties, to engage in any activity or take any actions that may be qualified as corruption.

When interacting with clients, state and municipal authorities, other organizations and individuals, our Company's employees do not allow actions that contradict the legislation of the Russian Federation and the norms established by this Code, as well as the regulatory legal acts of the countries where the Company operates.

Respecting the ethical principles of our clients and partners, including cultural and other differences, the Company gives preference to clients and partners who adhere to the standards and rules of corporate ethics adopted in our Company.

If the Company has information about a client or partner, including potential ones, violating fundamental principles of human rights protection or anti-corruption norms established by international and other applicable law, the Company has the right to refuse cooperation with such client or partner.

2. Measures to prevent corruption

When forming anti-corruption measures and implementing anti-corruption activities, the Company adheres to the principle of the rule of law over its own commercial interests.

Giving gifts and other material and non-material benefits, as well as representative expenses, are carried out in accordance with the Company's local regulatory acts. Gifts to employees, clients, business partners and persons associated with the state must in no way affect their ability to make unbiased and fair business decisions.

Company employees may give gifts of reasonable value to clients and business partners or receive such gifts from them if the gift cannot be considered an inducement to make a decision in favor of the giver.

All expenses for gifts must be correctly and accurately recorded in expense reports and reflected in the Company's accounting documents.

In our Company the exchange of gifts and representative events are permitted only if they meet the following criteria:

• business breakfasts, lunches, dinners and representative events for the purpose of a business meeting;
• corporate gifts with the Company's logo, gifts for annual, professional and other holidays (for example, New Year, Christmas, anniversary);
• promotional materials provided voluntarily, excluding the possibility of influencing an employee's decision;
• gifts and awards from the Company, public or charitable organizations for achievements or contributions to development within the value limits established by the law.

The decision to provide gifts and other material benefits is made in accordance with the Company's local regulatory acts and the principles set out in this Code.

3. Refraining from political activity

Our Company does not participate directly or indirectly in political parties, organizations and funds associated with them, and does not provide sponsorships or other payments in their support.

Company employees, as private individuals, may participate in political activities in their free time at their discretion, provided such participation does not harm the Company's interests or create a conflict of interest.

4. Interaction with state representatives and public organizations

The Company's interaction with law enforcement, regulatory and other state authorities, municipal bodies and their representatives, as well as with public organizations and their representatives, is conducted strictly within the framework of applicable law.

The Company does not make illegal payments to the aforementioned bodies, organizations, their representatives or other persons, including through intermediaries, including payment for recreation, entertainment, transport and other expenses, with the aim of obtaining or maintaining a business advantage.

5. Avoiding conflicts of interest

Company employees and persons acting on behalf of the Company must:

• avoid conflicts of interest that could negatively affect their judgment, objectivity and loyalty to the Company;
• obtain permission from their immediate supervisor for activities outside work at the Company, and for holding any concurrent position in a commercial organization to avoid conflicts of interest;
• periodically inform their immediate supervisors about participation in outside activities and confirm permission for such activities;
• avoid actions and relationships that may conflict with their official duties or the Company's interests, including employment or consulting activities in organizations that compete with the Company;
• avoid participating in any business decision of the Company related to organizations where their relatives are employed;
• avoid direct or indirect participation in the profits of an organization that is a competitor, partner or client of the Company, or financial relations with such an organization.

6. Relations with partners, clients and competitors

Our Company adheres to the principle that long-term, mutually beneficial relationships with clients and suppliers who have a strong business reputation are an important condition for commercial efficiency.

We support fair competition and compliance with all applicable competition laws.

Our Company does not collude with competitors and does not enter into agreements on fixed prices or trade restrictions.

We do not disseminate defamatory or false information about competitors' products and services.

Our Company values relationships with its business partners. While defending our interests, we respect the fair and lawful interests of counterparties.

We consistently ensure the guaranteed fulfillment of our contractual obligations and act as a reliable business partner.

Our Company establishes and maintains mutually beneficial relationships with any partner who follows the principles of mutual respect and mutual benefit, honesty and integrity, and strict mutual accountability.

SAFE WORKING CONDITIONS AND OCCUPATIONAL SAFETY

Creating safe working conditions at the workplace for employees is one of the Company's key tasks.

The Company strives to ensure compliance with all occupational safety and industrial safety rules and standards provided by the legislation of the Russian Federation.

The Company has developed and applies internal rules and regulations regarding occupational safety and workplace safety procedures.

The maximum level of safety can be guaranteed only if employees follow all the specified rules and instructions.

All issues related to occupational safety can be addressed to the HR Directorate or the Administrative and Economic Directorate.

ENVIRONMENTAL PROTECTION

The Company pays special attention to environmental protection, and to human health and safety at the workplace and beyond.

We welcome and support employees' actions aimed at a conscious attitude toward the environment.

Our Company consistently implements new zero-waste and low-waste production technologies that minimize environmental impact and ensure the most efficient use of material and raw resources.

Our Company initiates a number of environmental projects, such as:

• transition to electronic information carriers;
• planting the "Vostok-Service" alleys;
• collection and transfer of waste paper, plastic and batteries for recycling;
• preservation of rare species of plants, animals and birds;
• cleaning of coastal areas of water bodies;
• support for scientific research in the Arctic and Antarctic.

We appreciate activities that contribute to preserving a livable environment and make every effort to expand the circle of like-minded people in this direction.

WHERE TO DIRECT INQUIRIES

If questions arise about the application of the Code or if there is information about its violation, it is recommended to contact your immediate supervisor.

If an employee believes that such an approach is inappropriate or ineffective, the question/report of a violation can be submitted to the HR Director and/or the General Director of the branch/company.

Suppliers and other interested parties may also report Code violations by email via the "Write a letter" service on the official website vostok.kz

We expect that employees reporting violations will be guided by the best intentions, and we assure that the person reporting the violation will not be directly or indirectly subjected to any punishment or retaliation.

We understand that circumstances may force an employee to remain anonymous, and we will take all possible measures to preserve anonymity, except in cases where anonymity would prevent clarification of necessary details of the violation for the purposes of complying with the law and the norms of the Code.

DIRECT LINE

If questions arise about the application of the Code or the anti-corruption policy, or if there is information about their violation, you can contact the "Direct Line" through the channels listed below:

1. Our website vostok.kz
2. Central office in Kazakhstan:
   Almaty, 157/2 Turar Ryskulov Ave
3. Phone: +7 777 001 8913