CODE OF BUSINESS BEHAVIOR AND ETHICS

This Code of Business Behavior and Ethics (hereinafter - the Code) has been developed in accordance with the Charter of Caspian Engineering & Research LLP (hereinafter referred to as CE&R or the Company) and the requirements of the legislation of the Republic of Kazakhstan.

This Code contains general guidelines for the conduct of business by the Company, consistent with the highest standards of business ethics. This Code should be regarded as the minimum standard intended to withhold from offenses and to stimulate honest and ethical behavior. To the extent that the Code requires a higher standard than that provided business practice or applicable laws, rules or regulations, the Company will adhere to these higher standards.

The implementation of the provisions of this document is aimed at the solution of the following main tasks:

• maintaining high reputation of CE&R LLP in relations with the customers and partners;
• acquirement of the rules of business behavior, responsibility for the conscientious performance of their official duties by the employees of CE&R LLP;
• integrity, honesty, politeness and correctness in the relationship between colleagues, creating an atmosphere of mutual understanding, trust and cooperation, as well as creating a favorable socio-psychological atmosphere in the team;
• exchange of experience and information between colleagues, helping each other to achieve the best results, the ability to work in a team;
• punctual, precise and timely fulfillment of its obligations to the Company and colleagues at work, self-discipline, organization and the ability to work on the result;
• rational use of own working time and time of their colleagues, as well as the Company's assets;
• aspiration of the employees to a healthy lifestyle and respect for family values;
• improving the efficiency of business interaction between employees of CE&R LLP.

This Code applies to all officers and employees of the Company, including the General Director, Deputy of General Director, Director of Finance, Director of Business Development, (hereinafter referred to as the Top Management).

Implementation and compliance with the requirements of this Code are possible only with the assistance of all employees of CE&R LLP and their proper conduct. Each employee is obliged to adhere to the rules of behavior that contribute to the implementation of these rules.

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