4.1. Sustainable development management

51/100

ESG rating S&P Global CSA Score

Key indicators for 2025

measures

implemented under the Roadmap for ESG practices development during 2025

83%

Net Promoter Score (NPS) index

high level of client loyalty

thousand trees

were planted as part of participation in an eco-campaign

Key events of 2025

The Company entered the top-6 of the PwC Kazakhstan ESG disclosure rating with an “A” grade and was recognized as the best company in the telecommunications industry for the level of ESG disclosure;

Official accession to the UN Global Compact;

In September 2025, the Company participated in UN Global Compact events as part of the 80th session of the UN General Assembly in New York.

4.1.1. Management approach

Kazakhtelecom JSC strives for long-term sustainable development, regarding ESG aspects — environmental protection, social responsibility and the improvement of corporate governance — as fundamental elements of its strategy. Sustainable development goals are integrated into the business processes of the Company, defining the approach to management and the formation of initiatives aimed at the creation of long-term value for society, the economy and future generations.

In 2025, the international independent rating agency S&P Global assigned Kazakhtelecom JSC an ESG rating S&P Global CSA Score at the level of 51/100, which is higher than the average industry indicator among international telecom companies (40/100) and confirms the strong positions of the company in the management of sustainable development.

At the Company, a Roadmap on the development of ESG practices of Kazakhtelecom JSC is annually formed and updated. In total during 2025, within the framework of the Roadmap, more than 49 measures aimed at the improvement of corporate governance, the reduction of environmental impact, the development of social responsibility and the enhancement of the transparency of activities were implemented.

Key documents in the area of sustainable development

GRI 2-23

ESG strategy (approved by Decision of the Board of Directors No. 15 of 19 September 2024).
Sustainable Development Policy (updated and approved by Decision of the Board of Directors No. 5 of 21 April 2023).
Environmental Policy (updated and approved by Decision of the Board of Directors No. 5 of 21 April 2023).
Policy in the area of human rights (approved by Decision of the Board of Directors No. 6 of 30 May 2023).
Policy in the area of equal opportunities, inclusivity and diversity (approved by Decision of the Board of Directors No. 6 of 30 May 2023).
Policy on interaction with local communities (approved by Decision of the Board of Directors No. 6 of 30 May 2023).
Policy in the area of ensuring safety and occupational health (approved by Decision of the Management Board No. 2/7 of 27 January 2020).
Anti-corruption Policy (updated and approved by decision of the Board of Directors No. 20 of 11 December 2024).
Policy of notification of alleged unethical/unlawful actions (approved by Decision of the Board of Directors of 8 December 2023).
Policy on the protection of personal data of Kazakhtelecom JSC (approved by Order No. 313 of 6 October 2023).
Information security Policy of Kazakhtelecom JSC (approved by Order No. 93 of 17 June 2025).
Information Policy of Kazakhtelecom JSC (approved by Order No. 153 of 19 July 2023).

Code of Business Ethics (approved by Decision of the Board of Directors No. 14 of 28 May 2019).
Policy of absolute non-admission of violence at Kazakhtelecom JSC (Zero Tolerance Policy) (approved by Order No. 61 of 12 March 2024).
Corporate Governance Code in a new version (approved by Decision of the Extraordinary General Meeting of Shareholders No. 85 of 10 December 2025).
Procurement Procedure of Samruk-Kazyna JSC.
Supplier Code (approved by Decision of the Board of Directors No. 2 of 11 February 2022).
International standards ISO 9001, ISO 14001, ISO 45001, ISO 50001, ISO 37001 (the validity of certificates of the quality management system, the environmental management system, the occupational health and safety management system, the energy management system, and also the anti-bribery management system on compliance with established requirements has been confirmed). A

All stakeholders of the Company can read the documents on the website of the Company telecom.kz.

In addition, the Company informs employees about the approval of new documents, including in the area of sustainable development, by means of an internal mailout.

51/100

ESG rating S&P Global CSA Score

measures

implemented under the Roadmap for ESG practices development during 2025

ESG Strategy of Kazakhtelecom JSC for 2024–2032

In 2024, Kazakhtelecom JSC approved the ESG Strategy for 2024–2032, fixing sustainable development as an integral component of strategic management.

The document was developed based on a comprehensive ESG diagnostic assessment, within the framework of which the key risks, opportunities and priority directions in the area of ecology, social policy and corporate governance were determined. The ESG Strategy is organically integrated into the corporate development strategy JRun, strengthening its implementation through the systemic approach to the management of ESG factors and the sustainable creation of long-term value.

The Strategy represents a clear and structured action plan, reflecting the ambitions of the Company in the area of sustainable development. Its implementation underlines the aspiration of Kazakhtelecom JSC to responsible conduct of business and the readiness to make a contribution to the resolution of global challenges, including climate change, the ensuring of social justice and the improvement of management practices.

In the ESG Strategy, the key measures for each direction, which the Company has already begun to consistently introduce into its operational activities, are determined in detail. The implementation of these initiatives forms the basis for the long-term growth and enhancement of the resilience of the business.

Principles of Kazakhtelecom JSC in the area of sustainable development

Openness

We are open to dialogue with all stakeholders to build long-term cooperation based on the consideration of mutual interests, respect for rights and the balance between our interests and the interests of stakeholders.

Accountability

We are aware of our responsibility for the impact on the economy, the environment and society, and our accountability to shareholders and investors for the growth of long-term value and the sustainable development of the Company on a long-term basis.

Transparency

All our decisions and actions are built on transparency and the timely disclosure of information to stakeholders.

Ethical behaviour

At the heart of our decisions and actions are our values, such as respect, honesty, openness, team spirit and trust, integrity and fairness.

Respect

We respect the rights and interests of stakeholders.

Legality

We make decisions and act in compliance with the legislation of the Republic of Kazakhstan.

Personal example

Each of us daily, in our actions, behaviour and decision-making, contributes to the implementation of sustainable development principles.

Observance of human rights

We observe and promote the observance of human rights provided for by the Constitution of the Republic of Kazakhstan and international documents, such as the Universal Declaration of Human Rights. We categorically do not accept and prohibit the use of child labour. Our employees are our main value and core resource, and the results of our activities and the value created for investors directly depend on the level of their professionalism and safety.

Inadmissibility of conflicts of interest

All violations related to conflicts of interest may cause damage to the reputation of the Company and undermine the trust placed in them by shareholders and other stakeholders; also, the personal interests of an official or employee must not influence the impartial performance of their official and functional duties.

Zero tolerance to corruption

We show zero tolerance to corruption in any of its manifestations in our interaction with all stakeholders. Officials and employees involved in corruption cases are subject to dismissal and prosecution in the manner provided for by the laws of the Republic of Kazakhstan.

Mission of Kazakhtelecom JSC

The formation of a long-term ESG agenda at the level of a leading telecommunications company exerting minimal impact on the environment. The Company’s activities are focused primarily on improving social security while supporting economic growth.