− Why did the Company implement the Hotline?

Air Astana’s Hotline is an independent, confidential and anonymous communication channel operated by an independent Operator, KPMG, and designed to report actual or potential cases of violation of the law and / or Code of Conduct, including cases of fraud, corruption, discrimination, unethical behavior and other violations related to the activities of the Company.

− Who can use the Hotline?

The Hotline is available both for employees of the Company and third parties interacting with the Company (customers, contractors, government agencies, financial institutions and other stakeholders).

− What types of violations can I report?

You can report the following alleged or actual violations (the list includes, but is not limited to, the following):

• Bribery, commercial bribery, extortion and other corruption offenses;
• Corporate fraud, including (but not limited to):

- fraud in the field of finance and reporting (intentional errors in the preparation and evaluation of the financial statements of the Company, preparation and storage of financial documents);

- misappropriation, theft, misuse of the assets and other resources of the Company;

- income or assets obtained as a result of fraudulent and / or other illegal actions;

- expenses or obligations incurred or increased as a result of fraudulent and / or other illegal actions;

- falsification or alteration of documents;

- use of the Company's internal information for personal gain.

• Interference into the Company’s operational activities;
• Violation of legislative and regulatory requirements, internal regulations and policies of the Company;
• Illegal distribution of confidential and proprietary information to third parties;
• Unethical business practices and conduct, including abuse of power;
• Conflicts of interest, including (but not limited to) social and labor, in accordance with the Policy for the Prevention and Resolution of Conflicts of Interest;
• Discrimination, harassment, threats to health, safety and the environment;
• Other violations of the Company Code of Conduct, as well as applicable law and / or any other illegal or dishonest actions.

You can find more examples in the Anti Corruption Policy, Corporate Fraud Prevention Policy, as well as in the Conflict of Interest Prevention and Resolution Policy. The Code of Conduct for the Company will also be helpful in determining whether an action is a violation.

− How can I report violations?

Messages can be reported by all the parties through the following communication channels:

• by phone number 8-800-080-5353 (a call in the territory of the Republic of Kazakhstan is free); or
• by email airastana@hotlinekpmg.kz; or
• through the Internet portal www.airastana.hotlinekpmg.kz.

The Hotline operates around the clock seven days a week in 24/7 mode. Moreover, telephone calls are received by the Operator from 09.00 to 18.00 from Monday to Friday. The rest of the time (including holidays / weekends), telephone calls are received on voicemail with the ability to record messages. Processing of messages received after working hours is carried out on the first business day after receipt of the message.

− In what language can I report violations on the Hotline?

Messages are received by an external Operator in Russian, Kazakh or English (at the choice of the Applicant).

− How is my information processed and where?

In order to ensure confidentiality and anonymity, the information received through the Hotline communication channels is processed by an external independent Operator, who daily draws up a report on the received applications and sends it to Compliance and Sustainability Department of the Company (hereinafter the “Department”).

Responsible employees of the Department take follow up actions to consider all received messages in accordance with the internal policies and procedures of the Company.

− What principles does the hotline work on?

The hotline is serviced by an independent Operator on the principles of:

• confidentiality and anonymity (if the Applicant has chosen not to disclose his personal data); as well as
• registration, processing and objective examination of 100% of messages.

− I do not want to leave my contact details, is this not anonymous?

1. If you do not wish to disclose your identity, you can remain anonymous. In this case, it will be difficult to conduct a quick and thorough investigation into the fact of the anonymous message received from you, since it will be impossible to contact you to clarify the details and further interaction. It will be valuable for the Company if you leave your contact details.
2. The company will not disclose your identity, except for persons authorized to investigate your appeal. The company will act carefully to protect your identity.
3. In accordance with the policy of the Company, no measures of influence can be applied to the person making contact with the Hotline. We maintain the confidentiality of the data on the identity of the caller on the Hotline within the limits established by applicable law.

Herewith, by contacting the Hotline, you agree to the processing of your personal data by employees of an external independent Operator, and transfer of the received data to the Company’s responsible employees, who will ensure professional and confidential consideration of your message.

− How can I be sure of maintaining the confidentiality and anonymity of my information if I wish not to disclose my identity?

If you wish not to disclose your personal data when submitting a message, they will not be registered and will not be transferred to the Company.

− Can I be sure that there is no harassment or retaliation against myself after the provision of information?

In accordance with the Speak-Up policy of the Company, no measures of influence can be applied to a person who makes contact with the Hotline.

Any Employee, Counterparty or other third party who has made good faith statements should not be afraid of termination of employment, demotion, refusal of business cooperation, harassment or other forms of discrimination. Moreover, the Applicant is not entitled to abuse the protection granted to him. The protection afforded to the Applicant does not constitute protection against disciplinary or other liability for submitting a knowingly false message.

− What information should be provided when contacting the Hotline?

Any information provided will be taken into account. However, consideration of the appeal will be more efficient and faster in providing detailed information and supporting documents (if any). Therefore, the appeal is recommended to reflect the following information:

• The essence of the situation / violation;
• The time and place of the situation / violation;
• The circle of persons involved;
• Under what circumstances did you become aware of the situation / violation?
• Do you have supporting documents?
• Other information that you would also like to provide.

At the same time, it is worth remembering that the submission of a deliberately false message is considered as a serious violation that could entail the application of liability measures in accordance with the Criminal Code of the Republic of Kazakhstan. Such facts, if they contain false information and if there are grounds in accordance with the legislation of the Republic of Kazakhstan, will be transferred to law enforcement agencies.

− What is NOT included in the range of messages on the Hotline?

The hotline is only intended to receive messages regarding violations, legislation and / or the Code of Conduct, including cases of fraud, corruption, discrimination, unethical behavior and other violations related to the activities of the Company (see Answer to the question “What types of violations do can I report?”).

• Questions regarding the creation / modification / cancellation of reservations, refunds, special and other requests related to your trip should be sent to Call Centre.
• For questions related to cargo sales, you must contact the appropriate Sales Offices.
• If you have questions about the operation of the Nomad Club programme or complaints / opinions about the Company's service level, you can send them to the contacts indicated on the official website of the Company.

Important! The hotline should not be used to pressure employees and counterparties and / or force them to commit / abstain from certain actions, and should not be considered as a revenge tool for personal reasons.

− What are the deadlines for considering messages?

The time period for consideration of received messages depends on many factors, including the completeness and accuracy of the information provided, on the availability of supporting documents, as well as on the type of violation.

In general, the Department conducts a preliminary audit within no more than 2 business days. If the received information is not confirmed by the results of this check, the message may be rejected at this stage. And if the results of the preliminary audit indicate that further consideration is necessary, then an internal investigation is initiated.

− Will I get feedback on my appeal?

For all messages (both accepted for consideration and rejected), the Department within 2 working days provides updates on the status of the appeal (through the Internet portal of the Company’s Hotline, in accordance with the individual number of the appeal), informing of the decision on acceptance (or not acceptance) Applications for consideration. At the same time, reasons are indicated for which the Application cannot be accepted. The applicant will be able to check the status of his appeal through the Internet portal of the Company Hotline, after entering the individual number of his appeal.

Within 15 business days after the initiation of the investigation, the Department must update the status of the appeal (through the Internet portal of the Company’s Hotline, in accordance with the individual number of the appeal), reporting the results or status (if ongoing) of the investigation, but within the limits of legal norms and internal privacy policies. The applicant will be able to check the status of his appeal through the Internet portal of the Company Hotline, after entering the individual number of his appeal.

− Who should I contact if I have questions about the Hotline?

More detailed information on the Hotline is available on the official website of Air Astana JSC. Additionally, you can contact Senior Compliance and Sustainability Officer via message.