Code of Ethics

I. General Provisions

This Code establishes the moral and ethical norms, principles and standards of conduct for employees of Asarel-Medet JSC in conformity with the company’s core values set out in the Corporate Policy and the UN Global Compact principles serving as a foundation for the well-being of the company and every person working within it.

The purpose of the Code of Ethics is to encourage and cultivate the ideal of service to society by promoting high ethical standards in business, recognizing the importance of all socially useful work, and supporting each employee’s commitment to protect their own good name, the reputation of their profession and the name of Asarel-Medet JSC.

The Code of Ethics is a system of moral and ethical norms and rules that all employees of the company, including temporary staff, voluntarily commit to observe and comply with.

II. Rules of Conduct

General Rules of Conduct
In performing their official duties, employees of the company shall observe the following rules of conduct:

1. Unconditional compliance with and respect for the rule of law, and protection of the indivisible and universal values of human dignity, freedom, equality, and solidarity.
2. Actions that contradict legal provisions or good business practice are unacceptable, regardless of the reasons given. Good intentions do not justify illegal actions.
3. The employees must avoid any action that is or could potentially be regarded as damaging the good name of Asarel-Medet JSC.
4. Compliance with legal requirements is the foundation of ethical business conduct. While employees are not expected to know every applicable law in detail, they must be familiar with the basic rules relevant to their area of work and, in case of uncertainty, seek assistance from the company’s legal counsel.
5. Contractual agreements are considered fully binding. It is unacceptable to use authority over a subcontractor or supplier to prevent a contractual obligation from being fulfilled or to compel an action that is not part of the subcontractor’s or supplier’s contractual duties.
6. In their personal and professional lives, employees of Asarel-Medet JSC should ask themselves the following four questions that guide personal ethical standards about everything they think, say, or do:

• Is it true?
• Is it fair to everyone concerned?
• Will it build goodwill and better friendships?
• Will it be beneficial to everyone concerned?

Internal Conduct

1. In their relations, employees of Asarel-Medet JSC shall be guided solely by the interests of the company and shall apply established rules of positive attitude, integrity, and respect for the honor and dignity of others.
2. In communication with one another, employees are equal. Relationships are based on trust, tolerance, ethical conduct, and mutual assistance. Professional and personal disagreements shall not become the subject of public dispute.
3. Conduct that undermines the personal dignity and honor of any employee is not permitted.
4. Employees of Asarel-Medet JSC:

• Observe hierarchy in their  official relations or in connection with them
• Strive for unbiased mindset and impartiality in decision-making
• Assume responsibility for their actions
• Encourage feedback in every activity and workplace; seek and accept positions and opinions expressed by others; actively participate in solving company issues
• Support open communication between managers and employees. Build and maintain collegial relations within teams.
• Do not use their official position to obtain any advantage or benefit for themselves or their close relatives;
• Strive for order and consistency in their thoughts and actions.

It is unethical to submit unfounded complaints or to make defamatory statements about employees of the company. Public statements shall be guided by objectivity and truth.

Personal Conduct

In carrying out their official duties and in public life, employees of Asarel-Medet JSC shall follow conduct that does not undermine the company’s prestige, by:

1. Performing their duties and commitments to the company responsibly and accurately.
2. Developing themselves and those around them, discerning what is important, decisive and inappropriate in the process; not endangering or violating the rights of colleagues and business partners.
3. Condemning all forms of direct and indirect discrimination.
4. Not receiving personal benefits (other than remuneration from the company) from any activity or service undertaken on behalf and at the expense of the company; not accepting money or gifts except where such gifts constitute promotional materials.
5. Acting with integrity in relations with partners and competitors.
6. Using internal company information only for the performance of work related to Asarel-Medet JSC; protecting the company’s and its partners’ intellectual property; ensuring confidentiality of both our business and our partners’ business.
7. Excluding any personal interest in relation to business partners or companies competing with the company, and not participating in transactions incompatible with their position, functions, and duties.
8. Complying with the Labor Code and occupational health and safety requirements, the laws regulating the company’s activities, and the internal rules adopted within the company.

Relations with Business Partners

1. This Code ensures the implementation of a transparent and open policy in the company’s operations.
2. Competition is protected and encouraged, and trust is built among shareholders, business partners, and the public.
3. The fight against all forms of corruption and personal gain is promoted.
4. The employees participate in and conduct negotiations with business partners in a courteous manner, in accordance with generally accepted principles and standards of integrity, showing due respect for the partner without displaying unacceptable aggressiveness. They act positively in their conduct and relations.

III. Management Commitment

1. The management commits to apply to the highest degree and competently organize the implementation of these shared corporate values under conditions of transparency, dialogue and free exchange of opinions, ideas, and proposals, in accordance with the requirements for a good employee, specialist, and manager at Asarel-Medet JSC.
2. The management undertakes all necessary actions to ensure the highest standards of quality, occupational health and safety, environmental protection, human capital development and transparent cooperation with all stakeholders inside and outside the company.
3. The management complies with the principle of transparency and disclosure of commitments as a component of ISO standards for quality, environmental protection and occupational health and safety management systems.
4. The management acknowledges its responsibility to ensure that employees feel respected by honoring personal dignity, encouraging strengths and creating a sense of security at the workplace.
5. The management provides all employees equal opportunities for professional achievement , performance, and development, while assessing achieved results objectively and fairly.
6. The management develops leadership qualities: leadership means learning how to motivate, influence and guide others.
7. The management stimulates personal initiative, supports individuality and works to increase staff motivation, including through fair and adequate remuneration.
8. The management encourages a sense of collegial respect, trust, and integrity toward the company, without tolerating actions that contradict the shared policy and values.
9. The management applies zero tolerance to all forms of irresponsibility, duplicity, envy, gossip, lies, laziness, negligence, malice, servility by adhering to the motto:
   “It is good to be an important person, but it is even more important to be a good colleague in the position you hold within the company.”
10. The management ensures personal data protection and any confidential personal information about the  employees that becomes known during or in connection with the performance of official duties, preventing privacy violation.
11. The management ensures the observance of all human rights and individual freedoms in the performance of official duties.
12. The management pursues a policy of open communication with a view to future improvement and development of this Code and the company’s overall policy and culture.

IV. Additional Provisions

The provisions of this Code are a voluntary moral and ethical commitment to conduct for employees of Asarel-Medet JSC. Upon initial appointment, the immediate supervisor shall introduce to the the employee with the provisions of this Code by providing the following declaration for signature:

“Guided by the moral and ethical principles of conduct in my work, I understand and accept that I will comply with this Code of Ethics.”

The employees have the oblligation to comply with the provisions of this Code and therefore to stay informed—through management—about any amendments or updates to its provisions.

The provisions of this Code shall apply insofar as they do not contradict the Labor Code and other applicable legislation.