Almaty city, 2025
Contents
1. General Provisions
2. Purposes of the Policy
3. Scope and responsibilities of Employees
4. Social principles of sustainable development
5. Principles of sustainable development in the field of corporate management
6. Environmental principles of sustainable development
7. Responsibility for non-compliance with the Policy
8. Final Provisions
1. GENERAL PROVISIONS
1.1. This Sustainability and Compliance Policy (hereinafter referred to as the "Policy") of "Manpower Kaz" Limited Liability Partnership (hereinafter referred to as the "Company") has been developed for the purpose of implementing and using in the Company's activities the principles of sustainable development and ESG factor management, as well as compliance requirements.
Sustainable development principles (ESG principles) are social, environmental and management principles of the Company's activities based on environmental protection, creation of favorable social conditions, fair treatment of employees and clients and proper corporate governance.
Compliance is a set of measures and procedures applied in the Company's activities to ensure its compliance with applicable legislative and regulatory requirements, as well as ethical standards and rules of professional conduct.
1.2. The Policy has been developed in accordance with the legislation of the Republic of Kazakhstan, local regulations of the Company (including the Code of Business Conduct and Ethics, Anti-Corruption Policy), and also taking into account international best practices in the field of sustainable development.
2. PURPOSES OF THE POLICY
2.1. The Policy reflects the Company's strict commitment to the UN Global Compact Sustainable Development Principles, which are an integral part of the Company's goal-setting and corporate culture. The approach based on sustainable development is integrated into all aspects of the Company's business and reflects the Company's core values - Caring for People, Implementation of Innovations, Safety, Transparency, Responsibility.
2.2. The Policy aims to consolidate the main directions and requirements in the field of sustainable development to ensure that the Company complies with the highest ethical, environmental and social standards in its activities, conducts sensible and honest business based on the best practices of corporate governance, provides clients with the highest quality services, creates favorable living and working conditions for its employees, and makes a positive contribution to the development of the environment and society.
2.3. The Company strictly adheres to the principles specified in this Policy and regularly monitors international experience in this area, consistently improving its own approach and introducing new mechanisms and tools in order to increase the efficiency of its activities.
3. SCOPE AND RESPONSIBILITIES OF THE EMPLOYEES
3.1. The provisions of this Policy apply to all employees of the Company, as well as to counterparties and other persons in cases where the relevant obligations are set out in contracts with them, in their internal documents or directly follow from the legislation of the Republic of Kazakhstan.
3.2. The Director of the Company is responsible for organizing all activities aimed at implementing the principles and requirements of the Policy; for developing relevant procedures, their implementation and control.
4. SOCIAL PRINCIPLES OF SUSTAINABLE DEVELOPMENT
4.1. One of the most priority areas of the Company's development is the improvement of social policy and expansion of social responsibility. Caring for the life and health of the Company's employees, ensuring equal opportunities, a safe and comfortable working environment, developing human capital and promoting the professional and personal growth of employees reflects one of the main missions and values of our company.
4.2. The key social principles of the Company's activities are as follows:
4.2.1. Freedom of labor and prevention of child and forced labor
A fundamental requirement within the framework of the Company's activities and the organization of the employment process is ensuring the principle of freedom of labor, meaning the voluntary expression of the employee's will to enter into labor relations with the Company and the possibility of their termination at the reasonable and free will of the employee. The Company does not accept any forms of forced, child labor and modern slavery, in which a person is forced to work through threats, punishments, restrictions of freedom, charging additional fees, etc.
4.2.2. Strict compliance with labor and other applicable legislation
In all aspects of its activities, the Company ensures compliance with labor and other applicable legislation, in particular, regarding the age of employment, ensuring the payment of fair and just wages and the provision of all other applicable benefits, guarantees and compensation, working hours, protection of personal data, etc. The Company continuously monitors working conditions in the organization, strictly monitors compliance with the rights of employees at all levels, regularly organizes personnel training, during which it explains the need for unconditional compliance with the requirements of labor and other legislation in the framework of its work.
4.2.3. Respect and protection of human and employee rights, prevention of violence
The Company recognizes the inviolability of the rights of every person, their dignity and freedom, and strives to ensure their respect and protection. The company ensures the creation and maintenance of a safe and respectful working environment free from unprofessional, offensive or hostile behavior of any type (verbal, non-verbal, psychological or physical). The Company shows zero tolerance for any forms of violence, discrimination, bullying, harassment and strictly controls the prevention of such situations in the workplace. The Company encourages self-expression of employees and provides them with the opportunity to freely express their opinions, suggestions or doubts on any issues related to their work activities.
The Company provides continuous comprehensive legal audit in the area of human rights compliance, aimed at identifying and preventing cases of human rights violations, as well as developing new practices in this area.
4.2.4. Ensuring equality, diversity and inclusion
During the recruitment process and within the framework of existing employment relationships, the Company shows the highest degree of loyalty to candidates and employees, providing fair and equal employment and career development opportunities to everyone without exception, regardless of differences in race, national origin, religion, cultural background, sex, age, marital status, union membership, political affiliation, health status, gender identity or other characteristics that are not related to professional performance. We encourage cultural diversity and individual differences in a spirit of inclusion that welcomes all people and strives to provide people with the maximum opportunity to achieve their potential.
4.2.5. Ensuring safe working conditions
The Company considers human life and health to be the highest value. The Company's activities are based on the strictest compliance with all requirements in the field of labor protection and safety engineering and are aimed at continuously improving the working conditions of its employees, reducing the level of industrial injuries and occupational diseases.
4.2.6. Right to freedom of association and collective bargaining
The Company respects the right of employees to create and join organizations of their choice, as well as to participate in collective bargaining, guaranteeing the freedom of activity of representative employee organizations, as well as the good faith cooperation of the Company with them.
5. PRINCIPLES OF SUSTAINABLE DEVELOPMENT IN THE FIELD OF CORPORATE MANAGEMENT
5.1. The Company pays considerable attention to the implementation and maintenance of best practices in the field of corporate culture and uses a thorough and comprehensive approach to corporate management in order to ensure the success and continuity of business, economic efficiency, and maintaining a high business reputation as a reliable and conscientious partner.
5.2. Within the framework of the management aspect, the Company ensures unconditional compliance with the following principles and requirements:
5.2.1. Transparency of Activities and Disclosure of Information
The Company ensures openness of key information on the organization of its activities at all levels, including transparency regarding issues of management structure, financial reporting, procurement process and supply chain. At the request of interested Parties, in particular, the Company's clients, the Company is ready to provide any confirmation of compliance with the requirements of compliance and legal norms in the course of its activities.
5.2.2. Financial Stability
As part of its activities, the Company strives to ensure financial prosperity and economic stability, which is achieved, in particular, through competent and responsible financial planning, ensuring the profitability of activities, timely payment of all taxes and fees stipulated by law, the absence of debt to third parties and government agencies.
All financial transactions of the Company are properly, accurately and with sufficient detail reflected in the accounting records, documented and available for verification. Distortion or falsification of the accounting statements of the Company is strictly prohibited and is regarded as fraud.
5.2.3. Strict compliance with anti-corruption and anti-monopoly legislation
The Company enshrines the principle of non-acceptance of corruption and violation of anti-monopoly legislation in any form (the principle of "zero tolerance") in conducting business and carrying out any transactions, including in interaction with counterparties, representatives of government bodies, local governments, political parties, employees and other persons. The Company makes every possible effort to prevent any cases of such violations and implements a set of measures that are described in more detail in the Anti-Corruption Policy of the Company.
5.2.4. Independence and accountability of management bodies and officials
The Company adheres to the principle of good faith management, which is implemented through a multi-stage structure and accountability of management bodies, their effective relationships with each other, high professionalism, qualifications and impartiality of all officials.
5.2.5. High standards of procurement activities
As part of procurement activities, the Company strives to order supplies of goods and services only from reliable, law-abiding and competent suppliers and for this purpose carefully selects them for cooperation. In particular, all suppliers undergo a detailed comprehensive verification procedure, during which the Company studies the business reputation of the supplier, the history of its litigation, cases of persecution by government agencies, and requests a large package of documents for verification, including financial statements. Preference is given only to those suppliers who have not been noticed in any violations and can confirm their commitment to the principles of sustainable development, have a set of internal regulations in this area. In addition, at the beginning of cooperation with each supplier, the Company imposes on them obligations to comply with the provisions and requirements in the field of compliance set out in the Code of Business Conduct and Ethics, the Anti-Corruption Policy and the Sustainable Development Policy of the Company.
5.2.6. Active cooperation and maintaining a balance of interests of the parties
As part of its activities, the Company strives to interact honestly, actively and constructively with all interested parties on an equal basis, including clients, suppliers, partners, employees, public organizations, state and municipal institutions and authorities with the aim of building an effective dialogue and long-term successful partnership.
6. ENVIRONMENTAL PRINCIPLES OF SUSTAINABLE DEVELOPMENT
6.1. The Company is aware of its responsibility for the impact of its activities on the environment and makes environmental protection one of the priorities of its corporate culture. In order to contribute to improving the environmental situation and protecting natural resources, the Company adheres to the following strategies:
6.1.1. Striving to minimize harmful impact on the environment, introducing the best available technologies;
6.1.2. Rational use of energy resources and waste reduction;
6.1.3. Improving operational efficiency in order to reduce production costs;
6.1.4. Reuse, recycling and disposal of materials and resources.
7. RESPONSIBILITY FOR NON-COMPLIANCE WITH THE POLICY
7.1. All Employees, regardless of the position they hold, bear responsibility, as provided for by the current legislation of the Republic of Kazakhstan, for compliance with the principles and requirements of this Policy, as well as for the actions (inactions) of their subordinates that violate these principles and requirements.
7.2. Persons guilty of violating the requirements of this Policy may be subject to disciplinary, administrative, civil or criminal liability at the initiative of the Company, law enforcement agencies or other persons in the manner and on the grounds provided for by the legislation of the Republic of Kazakhstan, the Charter of the Company and other acts.
8. FINAL PROVISIONS
8.1. Issues not regulated by the Policy are governed by the legislation of the Republic of Kazakhstan.
8.2. This Policy comes into effect from the moment of its signing.
