Code of business ethics

Code of Business Ethics of "BRK-Leasing" JSC

Chapter 1. General terms

1. This Code of Business Ethics of "DBK-Leasing" JSC (hereinafter referred to as the Code and the Company respectively) was developed in accordance with the provisions of the current legislation of the Republic of Kazakhstan, the Charter and other internal acts of the Company, taking into account recognized international standards of business conduct and corporate governance, and establishes fundamental values and principles of business ethics, ethical norms of business relationships.

2. The following concepts and terms are used in this Code:

• Bank - Development Bank of Kazakhstan JSC
• business ethics - a set of ethical principles and norms of business conduct that guide all the officials and employees of the Company in their activities;
• official - member of the Board of Directors, member of the Management Board of the Company;
• employee - a person who has an employment relationship with the Company and directly performs work under an employment contract;
• Conflict of interests - a situation in which the personal interest of an employee and / or officer of the Company affects or may affect his impartial performance of his professional / work duties and conflicts with the interests of the Company;
• corporate culture - values, ethical norms of business relationships, norms of behavior peculiar to the Company;
• interested party - individuals and legal entities entering into legal relations with the Company;
• Ombudsman - a person who, by decision of the Board of Directors of the Company, is entrusted with the functions of introducing and adhering to the principles of business ethics in the Company, in accordance with this Code.

Chapter 2. Purpose of the Code and Company Values

3. The Code is a document that regulates the ethical side of the Company's interactions with all interested parties, the ethical norms of corporate relations, and the mechanisms by which ethical norms influence the daily activities of the Company and its employees.

The Code is an integral part of corporate governance and is designed to help improve the efficiency of the Company's corporate governance mechanisms.

4. The purpose of this Code is:

• creating a corporate culture and value system;
• Uniform understanding and implementation of business ethics accepted by the Company by all employees regardless of their position;
• developing a unified corporate culture based on high ethical standards, maintaining in the team an atmosphere of trust, mutual respect and decency. The provisions of the Code apply to officials and all employees of the Company, regardless of their position.

5. The fundamental values of the Company are:

• professionalism;
• transparency;
• a responsibility;
• decency;
• justice;
• good faith;
• patriotism.

6. The company, recognizing its responsibility to employees, assumes the following obligations:

• seeks to provide jobs with a competitive level of wages and social guarantees;
• provides employees with the opportunity to realize their potential, and also encourages their professional development;
• takes all measures to ensure the safety and health of workers in accordance with applicable law, and also creates safe working conditions for workers;
• creates conditions for an open and trusting dialogue between officials and employees of the Company in cases of conflict;
• seeks to comply with the norms in the sphere of social and labor relations;
• promotes the development of corporate culture and corporate values;
• ensures respect for and respect for human rights;
• evaluates and encourages initiative ideas and proposals from employees whose implementation has a positive effect on the Company;
• refrains from any form of discrimination based on religious, national, racial, sexual, political or other grounds when hiring or being appointed to posts;
• ensures non-disclosure of confidential information relating to employees, within the limits established by applicable law and the Company's internal acts.

Chapter 3. Ethical standards of business relationships with third parties

7. Ethics of relations with the Bank.

Relations with the Bank are based on the principles of transparency, accountability and responsibility in accordance with the requirements of the legislation of the Republic of Kazakhstan, the Charter, the Corporate Governance Code and other internal acts of the Company.

The procedure for the exchange of information between the Company and the Bank is governed by the laws of the Republic of Kazakhstan, the Charter, the Corporate Governance Code and other internal acts of the Company.

8. Government agencies

The company is committed to building and maintaining stable, constructive relationships with government authorities. The Company builds its activities in accordance with the requirements of the legislation of the Republic of Kazakhstan, the Charter and other internal acts of the Company, on the basis of the independence of the parties, with observance of the principle of preventing corruption and other unlawful actions, both from government bodies and from officials and employees of the Company. Adhering to the principle of good business. The Company strives to strictly observe and respect the current legislation of the Republic of Kazakhstan, as well as the national legislation in the countries where the Company operates. The company and its employees express solidarity in the fight against corruption, the legalization of illegally gained income and any actions that violate the laws of the Republic of Kazakhstan.

9. Society, non-governmental organizations.

1) The company, recognizing its social responsibility to society:

• forms its development strategy taking into account the interests of society as a whole;
• promotes the creation of new jobs in the regions where investment projects are implemented, export leasing operations financed by the Company;
• strives to respect the principles of maximum respect for the environment and the rational use of natural resources;
• seeks to comply with generally accepted moral and ethical standards;
• The company supports programs in the field of sponsorship and charity, providing financial and organizational support for social and cultural projects in accordance with the Company's internal acts and acts of the Sole Shareholder;
• The company encourages employee participation in charitable and sponsorship activities on a voluntary basis.

2) The company allows for the participation of its employees in public organizations and trade unions, when it is not contrary to the laws of the Republic of Kazakhstan.

3) Employee participation and public organizations are possible only outside working hours and without using the Company's resources, so that this participation is not regarded as the political or public position of the Company.

10. Business partners

• The Company interacts with business partners on the basis of mutual benefit, transparency and full responsibility for the obligations assumed in accordance with the terms of contracts on the principles of legality, fairness and efficiency.
• The company complies with the terms of contracts with business partners and fulfills its obligations towards them.
• The company does not allow the provision of unreasonable benefits and privileges to business partners in its activities.
• The selection of suppliers of goods, works, services is carried out by the Company on a transparent basis in accordance with the requirements of the current legislation of the Republic of Kazakhstan, the Bank and internal acts, based on preference for the best price, quality and conditions of supply of goods, works and services, as well as good business reputation counterparty.

11. Media

• Aware of the social significance of the results of its activities, the Company adheres to the principle of openness of information about its work.
• The company monitors compliance with high ethical standards in relations with the public and the media. The company does not allow the dissemination of inaccurate information, concealment and / or distortion of facts in public speeches of executives, its promotional materials or other public relations activities.
• The right to speak publicly, comment on the Company's events or make any statements on behalf of the Company in the media, only authorized officials and employees of the Company have the right.
• When performing on behalf of the Company, authorized persons must comply with generally accepted standards of professional conduct and business ethics, distribute only reliable information, and not allow disclosure of confidential information and information protected by law.

Chapter 4. Rules of business conduct for officials and employees of the Company

12. Responsibilities of officials and employees of the Company:

• Respect state symbols - National Flag, National Emblem, National Anthem;
• respectful of corporate symbolism;
• comply with generally accepted moral and ethical standards, respect the state language and other languages, traditions and customs of peoples;
• be polite and correct;
• be intolerant of indifference and rudeness;
• provide support and assistance to colleagues, if this is within the competence of the employee;
• be attentive to the opinions of others;
• ensure the unity of word and deed, keep promises;
• Do not hide / admit your mistakes.

13. Company officials and employees assume the following obligations with respect to the Code:

• Carefully study, understand and faithfully follow the requirements of business ethics and the rules of conduct established by this Code. In the case of consent, the officers and employees of the Company must complete the appropriate form (Appendix No. 1);
• conscientiously, professionally, efficiently and impartially perform their work duties and responsibilities;
• be responsible for the obligations assumed, regardless of status and position;
• assist with investigations into violations of business ethics and rules of conduct;
• comply with the information security requirements and procedures specified in clause 17;
• make management decisions that meet the requirements of the Code;
• show by your own example adherence to Code requirements;
• to devote time to creating a corporate spirit among subordinates, consolidating the team into a team united by a common mission, values ​​and principles of the Company;
• counsel and mentor subordinates.

14. Duties of officials:

• make decisions based on the principles of transparency and impartiality;
• carry out the selection and appointment of workers with regard to professional (qualifications, work experience in the specialty, etc.) and personal qualities, treat all employees impartially and fairly;
• providing each other with reliable information in a timely manner, without violating the confidentiality norms and taking into account the decisions of the Bank and the Company's internal acts;

15. Officials are not allowed to allow in relation to other employees:

• any form of discrimination: racial, religious, national, sexual, age, political and other grounds;
• any types of privileges and benefits to individual employees, except on the basis of the company's remuneration systems and social measures, with the Company ensuring that the Company enjoys equal opportunities to receive these privileges and benefits.

  16. Company employees must:

  • be active and achieve high performance;
  • be responsible for the result of their actions;
  • assist and advise colleagues, adhere to partner-style relationships with colleagues;
  • support self-development and self-improvement through advanced training in accordance with the Company's internal acts;
  • be attentive to the opinions of others;
  • be consistent and keep promises;
  • observe labor discipline in accordance with the Company's internal labor regulations;
  • Take care of the Company's property.

  17. Confidentiality of information.

  1) The list of information constituting commercial, confidential information, the conditions for access to such information, and the possibility of its use are determined by the Company, taking into account the need to observe a reasonable balance between the openness of the Company and the desire not to harm its interests.

  2) When applying for a job, employees of the Company must sign an Agreement on the protection and non-disclosure of confidential information. In the performance of their duties, officials and employees must follow these rules and procedures.

  3) Any confidential information held by officers and employees of the Company must be kept confidential and processed with special responsibility, unless otherwise expressly provided by the legislation of the Republic of Kazakhstan.

  4) Company employees must take care to prevent unauthorized access and disclosure of commercial, confidential information to other employees who do not have access to such information, as well as to any third parties outside the Company, and to prevent loss or destruction of data.

  5) When you receive information about a violation of the rules of confidentiality of information or a violation of the security of systems or devices, the employee must immediately report this fact to the supervisor.

  18. Corruption and other illegal actions.

  1) The Company is making every effort to prevent corruption and other illegal actions in order to obtain or retain unjustified benefits and advantages, both from stakeholders and from officials and employees of the Company.

  2) The direct duty to combat corruption rests with officials in senior positions in the Company.

  3) Company employees are obliged to bring to the attention of the management of cases of corruption offenses that have become known to them. For such reports, employees of the Company will not be subject to sanctions (including dismissed, demoted, deprived of bonuses, etc.). It is forbidden to take:

  • for the performance of their functional duties remuneration, in the form of money, services and other forms of individuals and organizations in which they do not perform the relevant functions;
  • gifts and services in connection with the use of their functions or from persons dependent on their work, with the exception of symbolic attentions, symbolic souvenirs in accordance with public standards of courtesy and hospitality or during protocol and official events.

  Any act of receiving remuneration in the form of money, services and in other forms will be considered as acts of a corrupt nature.

  The Board of Directors and the Management Board of the Company form an ethical standard of irreconcilable attitude to any forms and manifestations of corruption at all levels, setting an example for the Company's employees and within their authority determine the main activities of the Company in the field of combating corruption and other illegal actions provided for by the Company's internal acts .

  19. Corporate culture.

  1) Officials and employees should contribute to the development of the Company's corporate culture, observing and understanding the requirements of the Code and prevent violations of the Code.

  2) Officials and employees must form the corporate spirit and support compliance with the requirements of the Code in the following ways:

  • personal explanatory meetings with subordinates;
  • own example, use of the behavior as a sample for workers.

  3) All employees can take part in corporate entertainment or sporting events. They can also make suggestions for holding events, the purpose of which will be to increase the corporate spirit among employees.

  4) Officials and employees are obliged to follow the Company's rules on document flow and keep in order all the necessary documentation. All employees must keep their workplace in a neat and presentable form.

  5) Officials and employees must adhere to the business style of clothing during the performance of their duties.

  20. Appearance.

  1) Officials and employees must strictly adhere to the rules of business style in the selection of clothing, shoes, hair, during the performance of their official duties.

  2) The main characteristics of business style:

  • restraint, elegance, lack of bright, eye-catching accessories;
  • The central element of the business style is the suit.

  21. Ethics of conducting business negotiations.

  1) The ability of officials and employees to negotiate with other employees and business partners, including by telephone, helps create a favorable impression of the Company as a whole. In many ways, the success of the activity as a whole depends on business negotiations.

  2) Confidence, well-organized speech, completeness of phrases, persuasiveness of the employee’s arguments convince the client that he is a professional.

  3) Officials and employees should speak correctly and respectfully during business negotiations.

  4) When participating in a meeting, you must turn off your cell phones or set them to silent.

  22. Ethics of conducting telephone conversations.

  1) When talking on the phone, you must remember that colleagues may be in the same room and should be careful about their work, not distract with a loud conversation.

  2) The basis of a successful business telephone conversation is competence, tact, goodwill, possession of conversation techniques, the desire to quickly and effectively solve the problem. It is important that the business telephone conversation be conducted in a calm, polite tone and evoke positive emotions.

  3) Workers, when answering an internal call, should say hello, then introduce themselves, say an external call, call the organization.

  23. Ethics of greetings.

  The Company generally uses international etiquette of greetings: in a different form to wish each other good morning, afternoon or evening, health, labor success, goodness and well-being. A greeting in any situation should show disposition and benevolence.

  Chapter 5. Personal safety, labor protection, environment

  24. The company seeks to provide workers with safe working conditions in accordance with the requirements of the legislation in this area. In order to ensure occupational health and safety, the Company takes the following measures:

  • adherence to the principle of priority of preserving the life and health of an employee relative to the results of production activities;
  • ensuring all safety and labor protection measures provided for by current legislation;
  • preventive measures to ensure industrial safety.

  Officials and employees of the Company are required to:

  • strictly follow the standards and rules in the field of occupational safety and health at work;
  • inform the employer about the situation that poses a threat to the life and health of people, the safety of the employer's property and employees.

  25. The company follows the principles of environmental protection and itself stimulates other companies to introduce energy-saving technologies, waste-free production, and recycling of waste. To this end, the Company may consider these factors when making investment decisions or entering into agreements with suppliers.

  26. Company officials and employees should evaluate their actions in terms of environmental impact and minimize the impact on everything, for example, save energy, minimize the use of paper.

  Chapter 6. Control measures

  27. Officials and employees of the Company undertake to adhere to the business ethics and rules of conduct established by this Code, to perform professional functions in good faith and reasonably in the interests of the Company and the Bank, avoiding conflicts of interest, sign Appendix No. 1 to the Code. In addition, officials and employees on an annual basis are tested for knowledge and understanding of the basic principles of the Code through testing and / or other tools to test knowledge of the norms of the Code.

  28. The company negatively assesses any actions, including instructions from managers, which knowingly contribute to the violation of the Code, as well as the concealment of violations.

  29. Officials to achieve the strategic goals of the Company make business decisions based on fundamental values ​​and principles of business ethics, and are fully responsible for the implementation of the tasks assigned to them.

  30. Relevant employees of the Company, according to their competence, are obliged to respond to problems related to the violation of business ethics requirements by:

  • taking timely measures to remedy the situation and eliminate deficiencies;
  • adopting / proposing effective disciplinary measures in the manner prescribed by law;
  • consulting with the relevant structural units / bodies of the Company, providing them with the necessary information.

  31. The company encourages employees who are ready for an open discussion of the Code, and has a positive attitude to any constructive proposals for its improvement.

  32. For questions about the requirements of the Code and / or arising during the work, ethical issues, as well as violations of the requirements of the Code, corruption and other unlawful actions, officials and employees of the Company, as well as business partners and stakeholders have the right to contact the direct head of the Company's business unit , to the Ombudsman, as well as via the “Helpline” posted on the Company's official website. In this case, violations of the conditions and requirements of the Code by officials, managers and employees of the Internal Audit Service and the Corporate Secretary are considered by the Board of Directors of the Company.

  33. In case of revealing the circumstances of the violation by employees of the Company, the requirements of the Code, the materials for decision-making are sent to the authorized body of the Company with the mandatory participation of the Ombudsman. The results of the review and the decisions taken are communicated to the applicant within 5 (five) working days from the date of the decision.

  In the case of providing false information discrediting the honor and dignity of an official, an employee of the Company, the applicant may be brought to responsibility established by the legislation of the Republic of Kazakhstan.

  34. The authorized body does not consider violations, the consideration of which is within the competence of the Board of Directors of the Company, as well as if the employee acknowledges the fact of the violation.

  Chapter 7. ombudsman institution

  35. The Ombudsman’s Institute was created to strengthen the internal control system by ensuring that the Company's employees and officers comply with the requirements and provisions of the Code.

  The Ombudsman conducts its activities in accordance with the laws of the Republic of Kazakhstan, the Charter of the Company, the Code and other internal acts of the Company.

  36. The main functions of the Ombudsman are to collect information on violations of the provisions of the Code, to advise employees, officials of the Company, business partners and stakeholders on the provisions of the Code, as well as to initiate disputes regarding violations of the provisions of the Code and other issues according to the Code.

  Officials and employees of the Company have no right to interfere in the activities of the Ombudsman.

  37. The assignment of the functions of the Ombudsman to an employee or an officer of the Company is carried out by decision of the Board of Directors of the Company The term of functional duties of the Ombudsman is 2 (two) years.

  The members of the Company's Management Board, members of the Board of Directors, as well as the Bank are entitled to make proposals on the nomination of the Ombudsman, and the issue of early termination of the powers of the Ombudsman is made by a decision of the Board of Directors.

  The Ombudsman must meet the following requirements:

  1) the presence of higher education;

  2) experience of at least 5 (five) years in financial institutions, at least 2 (two) years in a management position;

  3) no criminal record;

  4) organizational and analytical skills;

  5) knowledge of corporate governance;

  6) impeccable business reputation.

  38. In the event that the Ombudsman is assigned to another employee or another person, the person from whom the functions of the Ombudsman are removed must hand over the cases and all relevant documents (on paper / electronic media), and also if there is an electronic database of appeals to the new person entrusted with Ombudsman functions. The transfer of documents is carried out registration of the act of acceptance and transfer.

  39. Early withdrawal of the Ombudsman’s functions is carried out in accordance with the decision of the Board of Directors of the Company on the basis of one of the following cases:

  1) performing actions related to the failure to fulfill the functional duties of the Ombudsman;

  2) termination of the employment contract at the initiative of the employee / at the initiative of the employer / by agreement of the parties / for health reasons;

  3) on the initiative of a member of the Board of Directors, who is the Ombudsman, or in connection with the termination of his powers as a member of the Board of Directors.

  40. The Ombudsman has the right to:

  • initiate procedures for identifying violations of the provisions of the Code, both on the basis of received appeals and on their own initiative;
  • apply personally to employees, officials of the Company regarding non-compliance with the Code;
  • provide employees, officials with clarifications and interpretations of the provisions of the Code.

  41. The Ombudsman must:

  • to ensure protection (within the framework established by the labor law procedures) of employees for the period of the procedures for the consideration of disputes concerning violations of the Code in case of situations of their forced dismissal;
  • participate in reviewing issues regarding non-compliance with the Code;
  • keep records of appeals of employees, officials of the Company, as well as business partners and interested parties regarding non-compliance with the provisions of the Code;
  • within 5 (five) working days, provide explanations of the provisions of the Code to employees, officials of the Company, business partners and interested persons if they are addressed);
  • transfer appeals to the appropriate bodies of the Company, the competence of which is to allow such appeals on the merits;
  • respect the independence and impartiality in handling disputes regarding non-compliance with the Code;
  • Ensure the anonymity of the employee, the official who applied for violation of the provisions of the Code (if he wishes to remain anonymous).

  42. In case of violations by employees and officials of the Company of the provisions of the Code, employees, officials, business partners and stakeholders have the right to appeal to the Ombudsman, both in written and oral form.

  Anonymous appeals are not subject to review, except for cases when such an appeal contains information about criminal offenses that are being prepared or committed, or about a threat to state or public security and which should be immediately redirected to the competent state bodies of the Republic of Kazakhstan.

  When applying to the Ombudsman in any form, the applicant must indicate his surname, name, patronymic, structural unit in which he works, the subject of the application and other information necessary for the Ombudsman to perform the tasks and functions assigned to him.

  43. In the event of violations by officials and employees of approved norms of business ethics, norms of legislation and internal acts of the Company, the Ombudsman will form materials for further referral to the Company's disciplinary commission.