
Kazakhtelecom JSC’s Approach to Human Rights Risk Management
Kazakhtelecom JSC adheres to the principles of respect for and protection of human rights in accordance with the legislation of the Republic of Kazakhstan and international standards, including the Universal Declaration of Human Rights, the UN Global Compact, and the ILO Declaration on Fundamental Principles and Rights at Work. These principles are embedded in the Human Rights Policy, approved by the Company’s Board of Directors.
The Policy applies to all employees of the Company and is recommended for implementation across its subsidiaries. As part of contractual procedures, Kazakhtelecom JSC informs its suppliers and partners about the principles of the Human Rights Policy and ensures they sign a confirmation of acknowledgment.
Monitoring and Evaluation of Human Rights Risk
Kazakhtelecom JSC conducts systematic monitoring of Risk P-30: Human Rights Violation Risk.
Current risk assessment:
- Likelihood: 2
- Impact: 1
- Risk map position: Green zone
Since Q2 2024, a positive trend has been observed. The risk remains within acceptable thresholds of the key risk indicator: number of reported violations of the Human Rights Policy.
Key Risk Factors
The following potential risk factors are included in the risk register:
• Violation of national legislation and international human rights standards
• Discrimination, violation of human dignity, and physical or psychological violence in the workplace
• Forced labor, child labor, and human trafficking (including by partners or other stakeholders)
• Corrupt practices
• Breach of personal data confidentiality
• Non-compliance with the Code of Business Ethics
Mitigation Measures
Kazakhtelecom JSC implements a range of measures to prevent human rights violations across the Head Office, branches, and subsidiaries:
• The Human Rights Policy is made accessible to all employees and partners
• Regular training is conducted on human rights issues
• Risks are monitored on an ongoing basis, with oversight by the Risk and Internal Controls Department
• Contractual provisions require suppliers and contractors to comply with human rights standards
• Zero tolerance is maintained for discrimination, violence, child labor, and forced labor
• Personal data and privacy are fully protected
• Anonymous reporting channels are available
- Hotline: 8 800 080 47 47
- Compliance service: tlek.issakov@telecom.kz
- Website: www.sk-hotline.kz
• Internal monitoring is conducted to ensure compliance with the Human Rights Policy
• Human rights principles are integrated into other corporate documents, including the Code of Business Ethics, the Sustainable Development Policy, and the Equal Opportunity, Inclusion, and Diversity Policy.
The Company complies with the requirements of the labor legislation of the Republic of Kazakhstan in this area, under which no one can be subject to any discrimination in exercising labor rights based on religion, gender, language, age, national origin, disability, family status, social origin or other individual characteristics that are not related to the business qualities of an employee.
Kazakhtelecom JSC is continuously improving its practices in the field of human rights and equal opportunities. Thus, the Company participates in negotiations with employees
on conclusion, amendment, and supplementation of the collective agreement, observes terms of negotiations and ensures work of relevant joint commissions, provides information necessary for negotiations, strictly complies with provisions of the collective agreement. According to labor legislation, any employee has the right to participate through his/her representatives in collective bargaining and drafting of the collective agreement, as well as to get acquainted with the signed collective agreement.
Employee Social Support at Kazakhtelecom JSC
Kazakhtelecom JSC is committed to maintaining a strong social support system that ensures safe, fair, and comfortable working conditions for all employees. The Company's Collective Agreement, which currently covers 92% of the workforce, serves as a key framework for delivering this support and promoting employee well-being.
In accordance with the Collective Agreement, the Company continued to provide the following social benefits in 2024, regardless of the type of employment (permanent or temporary):
• Life insurance
• Medical care
• Parental leave
• Pension programs
Kazakhtelecom JSC also provides the option for remote work. The terms and procedures for the implementation of remote work are determined in accordance with the Labor Code of the Republic of Kazakhstan and the Company’s internal regulations.
In addition to these core benefits, the Collective Agreement also establishes a wide range of additional social support measures, including:
Support in Case of Downsizing and Retirement
The Collective Agreement includes specific provisions for employees affected by organizational changes such as downsizing or retirement. These include:
• Reassignment to available internal vacancies
• Early retirement based on length of service
• Paid time off for job searching
• One-time severance or retirement payments
Annual Leave Entitlements
Kazakhtelecom JSC provides paid annual leave in line with employee categories:
• 30 calendar days – for employees in managerial, specialist, and administrative roles
• 27 calendar days – for employees in working-class positions
In addition, extra paid annual leave may be granted in accordance with the terms set out in the Collective Agreement.
Compensatory Payments
As outlined in Appendix 3 of the Collective Agreement, "Employee Compensation System of Kazakhtelecom JSC", employees are entitled to various additional payments and allowances, including:
• Overtime pay
• Night shift pay
• Compensation for work on public holidays and weekends
• On-call duty pay (home standby)
• Additional pay for physically demanding work or work involving hazardous and/or dangerous conditions
• Other compensation-related supplements, as defined by internal regulations.
Additional details regarding the employee social support system are available in the 2024 Integrated Annual Report of Kazakhtelecom JSC.
- Management by objectives - assessing the degree and quality of corporate and individual goal achievement by employees.
- Competency assessment - evaluating employees' work behavior based on specific indicators for achieving individual goals.
Management by objectives involves two types of performance evaluation:
- Annual performance indicators aimed at achieving strategic goals.
- Quarterly tasks to facilitate project implementation.
The corporate key performance indicators (KPIs) approved by the Board of Directors of JSC “Kazakhtelecom” include:
- EBITDA Margin
- Consolidated Net profit
- Free cash flow
- Zone Credit risk
- NAV
- and Labor Productivity within the Group
The developed performance evaluation system enables the transformation of business goals into team goals. It is relatively simple and understandable in application and administration, facilitating the company's pursuit of maximum efficiency and business development stability.The evaluation of employees' performance is conducted with the following objectives:
The competency model of the employees at JSC “Kazakhtelecom’' comprises 11 competencies reflecting the Company's values.Each branch of the Company conducts an assessment of employee performance considering production processes, based on which a performance rating system is formed, serving as the basis for applying motivational tools
Corporate KPIs / KPIs for the CEO
The corporate KPIs of Kazakhtelecom JSC / KPI of the Chairman of the Management Board of Kazakhtelecom JSC are approved by the Board of Directors. The key performance indicators (KPIs) reflect Company's strategic goals and priorities. These KPIs encompass a range of indicators, such as financial performance, enhancement of safety culture, domestic value share in purchases of goods, works and services, shareholder return, Net Promoter Score loyalty index and major investment projects.
Corporate KPIs / KPIs for the CEO:
Performance period applied to evaluate variable compensation – 1 year
• Achieving EBITDA Margin
• Lost Time Injury Frequency Rate (LTIF)
• Share of domestic value in purchases of goods, works and services
• Achieving TSR (Total Shareholder Return)
• Achieving NPS (Net Promoter Score) loyalty index
Specific guidances are developed for long-term KPIs.
Performance period applied to evaluate variable compensation – 5 years
• Implementation of major investment projects:
• «Development of 5G network» project. Implementation period: 2022-2025
• «Construction of fiber-optic communication lines across the Caspian Sea» project. Implementation period: 2022-2026
The Company does not engage in the practice of deferring any portion of the CEO's short-term incentive bonuses. Short-term compensation is paid out in full and in a timely manner, without any delay or conversion into shares or stock options.
The following KPIs relate to achieving goals associated with risk management:
• Achieving EBITDA Margin
• Lost Time Injury Frequency Rate (LTIF)
• Achieving NPS (Net Promoter Score) loyalty index
Kazakhtelecom’s OHS (occupational health and safety) priorities are:
- relevant compliance with and application of the Labour Code of the Republic of Kazakhstan;
- provision of safe working conditions and workplaces;
- use of modern technologies and best practices in occupational safety and safety;
- introduction of modern means and methods of preventing occupational injuries and occupational diseases.
Early prevention or mitigation of adverse health and safety impacts on employees, contractors’ employees and population plays an important role in Kazakhtelecom JSC’s activity in the field of occupational safety. The safety and labor protection management system functioning in the Company is aimed at providing methodological guidance, analysis and control over the state of OHS.
Kazakhtelecom JSC developed the Occupational Health and Safety Policy that applies to all employees and contractors of the Company.
The main internal documents regulating the issues of occupational health, safety and environment, industrial safety, within which Kazakhtelecom JSC’s health and safety management system operates, are: