Business ethics and anti-corruption

Uzbektelecom JSC implements a comprehensive approach to anti-corruption management aimed at preventing, identifying, and minimizing corruption risks in all areas of its activities. This approach is based on compliance with the national legislation of the Republic of Uzbekistan, international standards, and best practices in the field of anti-corruption, including ISO 37001:2016 «Anti-bribery management systems”.

The anti-corruption activities of Uzbektelecom JSC are regulated by the following legal documents:

Uzbektelcom JSC’s anti-corruption activities are coordinated by the Compliance Department, which ensures the development and implementation of anti-corruption measures.

The main functions of the department include:

• developing and updating internal regulations in accordance with ISO 37001:2016 and legislation;

All new employees undergo an anti-corruption screening procedure upon hiring. All structural divisions of the Company are required to comply with anti-corruption requirements, and management is responsible for their implementation and effectiveness.

Uzbektelecom JSC regularly reviews and improves its anti-corruption policy, taking into account changes in legislation and international standards. The assessment of the effectiveness of the measures implemented allows for the timely adaptation of internal processes to minimize corruption risks and increase the level of corporate responsibility.

As part of the risk management system at Uzbektelecom JSC regular assessments of corruption risks are carried out in departments and key business processes. This work is aimed at identifying potential threats, implementing preventive measures, and increasing the transparency of the Company’s activities.

In 2023, 41 business processes in 31 divisions of the Company were analyzed. According to the assessment results:

• 5 processes were classified as high risk,
• 21 processes had a medium risk level,
• 15 processes were classified as low risk.

After the implementation of anti-corruption measures:

• 0 processes remained in the high-risk category,
• 5 processes were moved to the medium level,
• 36 processes were classified as low risk.

Uzbektelecom JSC pays special attention to raising employee awareness of anti-corruption policy principles and implementing training programs aimed at fostering a culture of ethical business conduct. as part of its anti-corruption measures in 2024, information and training events were held for various categories of employees.

During the reporting period, 100% of administrative and management personnel, production personnel, and members of the management board were familiarized with the Company’s anti-corruption policy and internal procedures.

In particular:

• 725 administrative and management personnel,
• 16,095 production personnel,
• 5 members of the executive body.

As part of corporate educational initiatives in 2024, 979 employees underwent specialized anti-corruption training, including:

• 975 employees in the Republic of Uzbekistan,
• 4 employees outside the country.

The training programs covered the main provisions of the Company’s anti-corruption policy, legislative norms, mechanisms for identifying and preventing corruption risks, as well as rules of ethical conduct when interacting with partners and government agencies.

Uzbektelecom JSC continues to improve its anti-corruption training system and plans to expand its coverage among employees and business partners by introducing new interactive training and testing formats.

In 2024, no confirmed cases of corruption were identified within Uzbektelecom JSC as part of corporate monitoring and internal control systems. During the reporting period, there were no cases of employees being dismissed or disciplinary measures being taken against them for corruption offences. There were also no cases of termination or refusal to renew contracts with business partners for reasons related to corruption. During the year, there were no public court proceedings related to corruption against the Company or its employees. This situation remained unchanged in the two previous reporting periods.

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Furthermore, no violations of legislation or regulatory requirements were recorded in 2024. No penalties or other measures of liability, whether financial or administrative, were imposed on the Company during the reporting period or in the last two years.

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As of the end of 2024, there were no court proceedings related to the regulation of anti-competitive behavior.

In accordance with the Decree of the President of the Republic of Uzbekistan «On measures to introduce a rating system for the effectiveness of anti-corruption work» № PP-81 dated January 12, 2022, the Anti-Corruption Agency (hereinafter referred to as the Agency) conducts an annual rating assessment of organizations. Monitoring is carried out using the electronic platform «E-Anticor.uz», which ensures the objectivity and transparency of the assessment of anti-corruption activities.

Uzbektelecom JSC actively participates in this rating, confirming its commitment to high standards of transparency and corporate ethics. at the end of the last reporting period, the Company scored 82 points out of 100, which demonstrates the effectiveness of the anti-corruption measures implemented.

This result reflects:

• Compliance with legislation. The measures implemented fully comply with the requirements of the legislation of the Republic of Uzbekistan and international standards in the field of anti-corruption policy.
• A systematic approach to anti-corruption management. The Company has implemented effective anti-corruption mechanisms that comply with the requirements of the international standard ISO 37001:2016.

The company pays special attention to transparency and anti-corruption issues by implementing effective mechanisms to identify and prevent corruption risks. These tools include a hotline that allows employees, partners, and customers to report incidents of corruption and misconduct.

Channels for submitting complaints:

• Virtual reception office of the President of the Republic of Uzbekistan (https://pm.gov.uz);
• The Company’s official website and email: antikorrupsiya@uztelecom.uz ;
• The Company’s official social media accounts and Telegram bot;
• Special hotline: +998 55 501 77 87;
• Personal or written appeal to the relevant authorities of the Company.