ESG and sustainability

This Policy sets out the principles and commitments of ROI GROUP LLP (the "Company") on sustainable development and reflects the Company's approach to responsible business conduct, care for employees, reducing environmental impact and responsible engagement with business partners.

The Policy applies to all employees of the Company, including the Director, regardless of position or work format, and covers all areas of activity and all projects of ROI GROUP. Where applicable, the Company expects contractors, freelancers, suppliers and other business partners to follow comparable principles.

ROI GROUP is an advertising agency that develops and delivers advertising, communication and event projects. The nature of its business defines its main areas of responsibility: working conditions and employee development, use of resources, business practices, and the choice of solutions, suppliers and contractors for its projects.

The Company's direct environmental impact comes mainly from the use of electricity and office resources, waste generation and employee travel. Projects may create additional impacts through printed materials, advertising and packaging materials, temporary structures, transport arrangements and the involvement of suppliers and contractors.

The Company aims to take these aspects into account in its decisions and to reduce negative impacts where it can influence them, including through the rational use of resources, waste reduction, reuse of materials and responsible selection of suppliers and contractors.

The Company is guided by the following principles:

• compliance with the legislation of the Republic of Kazakhstan and with the commitments the Company has made;
• responsible business conduct in good faith;
• risk prevention and continuous improvement;
• respect for human rights, dignity and equal opportunities;
• safe and decent working conditions and support for employees' professional development;
• careful use of resources and waste reduction;
• zero tolerance of corruption, fraud and retaliation against anyone who reports a violation in good faith;
• responsible engagement with clients, suppliers, contractors and other business partners;
• openness in assessing results and regular improvement of the measures taken.

The Director has overall responsibility for implementing this Policy: approves goals, assigns responsibilities, reviews results and decides on matters that require additional measures or changes to existing approaches.

Responsibility for specific areas is assigned within the Company's existing structure, in line with employees' job duties:

• employee matters, including working conditions, working hours, occupational health and safety, training and professional development, equal opportunities and well-being, are coordinated by the Director or an employee appointed by the Director;
• when delivering advertising and event projects, the responsible employees take into account safety, the rational use of materials and resources, waste generation and engagement with suppliers and contractors;
• the quantitative data needed to assess the set indicators is collected and recorded by the responsible employees, with the accounting department contributing the information it holds;
• every employee is responsible for complying with this Policy and related internal documents, taking part in the required training and promptly reporting identified risks and violations.

At least once a year, the Director reviews the implementation of the Policy and progress towards the set goals. Based on this review, additional measures, responsible persons and next steps are defined where necessary.

4.1. Working conditions, working hours and pay

The Company provides working conditions no less favourable than those required by the legislation of the Republic of Kazakhstan. A hybrid format applies: as a rule, at least 3 days a week in the office and up to 2 days remotely, unless a project or client requires otherwise. Flexible start and finish times are allowed and, by agreement, fully remote work.

Overtime and work on weekends, public holidays and at night are permitted only as provided by law, are recorded and are always compensated. Employees receive the monetary compensation provided for by law and internal documents, or another permitted form of compensation. Leave and temporary incapacity for work are formalised in accordance with the law and the employment contract.

Pay and bonuses are determined by the Regulations on Employee Remuneration and Bonuses. Decisions on pay, bonuses and development are made on work-related criteria, without discrimination.

4.2. Health, safety and well-being

The Company strives to provide safe and comfortable working conditions in the office, when working remotely and during on-site projects. Particular attention is paid to injury prevention, the safe organisation of work at events, a reasonable workload and factors that may affect employees' physical and mental health.

The Company has identified the occupational health and safety risks specific to its activities and working conditions. Identified risks and the measures to prevent and reduce them are regularly monitored and reviewed when working conditions change, after incidents, when new risk factors are identified, and as part of an annual review.

To ensure safe working conditions, the Company:

• provides mandatory insurance against work-related accidents for 100% of employees;
• defines measures to prevent and reduce identified occupational health and safety risks and monitors their implementation;
• provides safety briefings to employees, taking into account the risks and safety requirements relevant to their work;
• ensures preparedness for fire, injury, evacuation and other emergencies;
• records and reviews accidents, incidents and identified near-misses to prevent their recurrence;
• arranges medical examinations where required by law or by the nature of the work.

Flexible work arrangements, a reasonable distribution of workload and the ability to contact the Director directly are also part of the Company's approach to employee well-being.

4.3. Equal opportunities, non-discrimination and unacceptable behaviour

The Company ensures equal opportunities in hiring, pay, evaluation, training and professional development. Discrimination, harassment, bullying, humiliation, and physical, psychological or verbal abuse on grounds unrelated to professional qualities and job requirements are not tolerated.

The Company supports an inclusive approach to employment, including the employment of people with disabilities, and takes reasonable measures to adapt working conditions and workplaces where necessary. The rules on non-discrimination and unacceptable behaviour are set out in more detail in the Code of Conduct.

4.4. Human rights

The Company does not allow child or forced labour, human trafficking, the withholding of identity documents, threats or any other form of coercion to work. These principles are also taken into account when selecting contractors and suppliers.

4.5. Training, development and performance review

The Company supports employees' professional development and, depending on their work tasks, pays for specialised training, participation in professional events and the development of the skills needed for their work.

At least once a year, each employee discusses their results and further development with the Director or a project manager. The outcome is briefly recorded: results achieved, strengths, development areas and agreed next steps.

The Company keeps a training register and uses review results to identify professional development needs.

4.6. Family responsibilities and work–life balance

The flexible and hybrid work format allows employees, where needed, to agree an individual schedule that takes into account family circumstances and work tasks. The Company complies with the statutory guarantees related to pregnancy, childbirth and childcare and, where possible, takes family circumstances into account when allocating workload and business trips.

To understand how comfortable employees are with their working conditions, the Company conducts a short internal survey at least once a year and takes the results into account when planning improvements.

5.1. Energy and climate impact

For an advertising agency, the main direct environmental impact comes from the use of electricity and office resources, waste generation and employee travel. The Company strives to use resources wisely, choose energy-efficient office equipment and monitor available electricity consumption data every year.

Based on electricity consumption data, the Company plans to estimate the related greenhouse gas emissions and use the results to define further measures to reduce them. The Company also encourages the use of public transport, shared travel and remote work where this is convenient and does not interfere with project delivery.

5.2. Waste and resources

The Company aims first of all to reduce waste, reuse suitable materials, organise separate collection and send suitable waste for recycling. Document management is mainly electronic, and unnecessary printing and the use of single-use materials are being reduced.

Plastic, used batteries and other waste for which separate collection is available are collected separately where possible and handed over to the appropriate collection points or specialised organisations. The Company keeps the available confirmations of such handovers and monitors paper use.

5.3. Environmental aspects of projects

When preparing advertising and event projects, the Company, where possible, chooses solutions that reduce unnecessary printing, packaging and single-use materials, reuse structures and materials, and send suitable waste for recycling. Specific solutions depend on the nature of the project, the client's requirements and the contractors' capabilities.

6.1. Anti-corruption and conflicts of interest

The Company does not tolerate bribery, corruption, fraud, improper payments or any other form of unlawful influence on business decisions. Employees must report conflicts of interest promptly and follow the established rules on gifts, business hospitality and dealings with clients, suppliers and government bodies.

Detailed rules of conduct and the procedure for reporting violations are set out in the Code of Conduct and other applicable internal documents.

6.2. Protection of information and personal data

The Company handles client, commercial, personnel and other confidential information with care. Access is granted only to employees who need it for their work and is revoked when the relevant authority ends.

Employees must comply with confidentiality requirements, never share passwords, use the available account protection tools and immediately report a lost device, data sent in error, a suspicious message or any other incident that may lead to the disclosure or loss of information.

When selecting suppliers and contractors, the Company strives to consider not only price, quality and timing, but also the issues relevant to the specific purchase: business integrity, working conditions, safety, information protection and the environmental impact of the materials used. For advertising and event work, the key factors are materials for printing and production, packaging, temporary structures, transport, and the possibility of reuse and recycling.

Employees and business partners may report in good faith violations of labour rights, safety requirements, discrimination, corruption, conflicts of interest, breaches of information protection or other requirements of this Policy directly to the Director or through the confidential channel provided for in the Code of Conduct.

The Company handles such reports confidentially to the extent permitted by law, does not allow retaliation against anyone who reports in good faith, and takes the necessary action based on the outcome of the review.

The Company sets measurable goals in the areas most relevant to its business. Results are reviewed annually, and goals are updated where necessary based on accumulated data and changes in the Company's work.

At least once a year, the Director or an employee appointed by the Director reviews the implementation of this Policy and progress towards the set goals. Evidence comes from documents and records produced in the Company's normal course of business: contracts and orders, data on working hours, employee training and performance reviews, survey results, energy consumption data, waste handover confirmations, and records of briefings, incidents, reports and work with suppliers.

Where data on a particular indicator is insufficient, the Company improves its collection and recording. The results of the annual review are used to define next steps and, where necessary, to adjust the goals.

The Policy is communicated to all employees. It is reviewed at least once every three years and whenever there are significant changes in legislation, the Company's activities or identified risks. The Policy takes effect on the date of its approval by the Director.