Code of Conduct

Message from Chief Executive

Referring to the best examples of global companies, I have decided to share with my team and communicate the importance of complying with the Code Conduct.

Considering principles of the Codes of Conduct of Hitachi Construction Machinery Group,

Eurasian Machinery establishes own principles of the corporate ethics, mutual statements and expectations from employees.

The Code of Conduct is based on recognition of the rule of law, human rights and his dignity, business ethics.

I hereby call each of us for active participation in establishing corporate culture, ensuring the best conditions in the daily work of the Company, colleagues, counteragents and compliance with the laws.

Mehmet Kemal Cetinelli
CEO

Our vision

Eurasian Machinery LLP is the largest company supplying specialized machinery and equipment for mining, construction and oil and gas enterprises in Kazakhstan and Central Asia.

Our goal is to become part of global solutions, adequately represent products of the international producers and constantly improve conditions for clients in the acquisition of specialized machinery.

Our values

Competence.
Human resource is the most important value of Eurasian Machinery. We constantly invest in development and advanced training of our employees, including both universal skills and specialized knowledge for high-qualified engineers.

Mutual respect.
We acknowledge that a team unity gets success. Eurasian Machinery encourages teamwork, trust, goodwill and cooperation in solving assigned tasks.

Efficiency.
Eurasian Machinery strives for effective solutions, balancing risk management.

Stability.
We acknowledge stability as a primary factor in team building and ensuring long-term projects. The Company’s stable position is a necessity caused, inter alia, by the importance of specialized machinery in the continuous production of mining, construction and oil and gas enterprises.

Fairness.
Fairness as a universal requirement in all Eurasian Machinery business processes is recognized as a value. Officials aim to ensure fairness in decisions.

Zero tolerance for corruption.
The Company has a zero tolerance for corruption and any it’s form: giving and receiving a bribe, bribery, rent-seeking behavior, and other actions containing corruption component.

Rules and principles of Business Conduct

The Eurasian Machinery Code of Conduct consist of rules and principles intended to assist officers and employees in making decisions and taking actions in accord with the Eurasian Machinery values. All officers and employees of Eurasian Machinery shall understand and follow the Code of Conduct and act with sincerity and fairness in a highly ethical manner.

1. Toward a Sustainable Society

(1) We will contribute to resolving social issues by promoting the results of innovative solutions.
(2) We will strive to offer the best conditions for our customers in the selection and maintenance of specialized machinery and equipment, contributing to the fulfillment of the mission of world brands.

2. Sincere and Fair Business Activities

2.1. Fair Trading

(1) To ensure fair and open competition, we will observe the fundamental rules of trade, including domestic and overseas competition laws and regulations, and act in compliance with legislation and sound corporate ethics.
(2) We will have no relationship whatsoever with antisocial forces anywhere in the world, and resolutely reject involvement in improper or antisocial transactions.
(3) We strictly prohibit and will have no involvement in bribery and other corrupt business practices. We will neither give or receive gifts nor extend or accept invitations to business entertainment beyond socially accepted limits, as we recognize that such practices can foster corruption. When working with political entities, we will build and maintain sound and transparent relationships.
(4) We will help maintain international peace and security through compliance with all applicable laws and regulations concerning import & export and will operate appropriately according to our internal rules and policies.
(5) We are committed to full compliance with relevant laws and external and Company reporting requirements, including those concerning disclosure to tax authorities and reporting on the tax payments that we make.
(6) We will comply with applicable laws. Furthermore, we will do so guided by international norms and standards even in areas where legislation is not adequately enforced.

2.2. Relationships with Suppliers

(1) With a mindful of the long-term perspective, we will find qualified suppliers and build fair and equal partnerships with them, working together to build mutual understanding and trust.
(2) In selecting suppliers, we will thoroughly review the quality, reliability, delivery time, and price of the materials they provide as well as their business stability and technological capability. We will give due consideration to their adoption of social responsibility practices, including areas such as the abolition of unfair discrimination, the elimination of child labor and forced labor, and environmental conservation.
(3) We will not accept any personal benefits from suppliers in procurement transactions.

2.3. Relationships with Customers

(1) We will provide products and services that meet the needs and requirements of our customers, complying with relevant laws and standards and ensuring quality and safety.
(2) We will communicate with customers sincerely, address defects and customer complaints quickly and in good faith and strive to determine causes in order to eliminate them and prevent recurrence.

3. Respect for Human Rights

(1) We will promote our understanding of internationally recognized human rights and will respect and not infringe on the human rights of all those involved in our business activities.
(2) We will assess and prevent potential violations of human rights. In the event of such a violation, we will promptly take internal and external actions to correct and remedy the situation.
(3) We will respect individual human rights in the recruitment and treatment of employees and during all other company activities. We will not engage in any acts that may impair individual dignity or discriminate on bases such as sex, sexual orientation, age, nationality, race, ethnicity, ideology, belief, religion, social status, family origin, disease, disability.
(4) We will hire employees in compliance with the relevant laws and regulations in each country and region, and in accordance with international norms and standards. We will not use child labor that employs children below the minimum working age or forced labor that is against the will of employees.
(5) We will strive to resolve issues through sincere and constructive discussion between management and employees, in compliance with the laws, regulations, and labor practices.

4. Building a Work Environment That Brings Out Employee Strengths

(1) Prioritizing health and safety above all else, we will strive to ensure the safety of employees and the workplace. In addition, we will promote the physical and mental health of employees and their families.
(2) We will support flexible work styles and respect diverse values, creating workplaces that provide employees with a sense of accomplishment and personal growth, and we will promote the sustainable growth of the organization and individuals.
(3) We will invest in educational programs to help employees expand their capabilities and exercise their strengths. Supervisors will fairly and appropriately support, guide, and educate their employees to develop their abilities.

5. Information Management and Communication

(1) We will promote the ethical handling of information, so as to ensure respect for human rights and security, through the proper management of personal information based on our Personal Data and their Protection Policy.
(2) We will properly manage and protect confidential information related to our business activities in compliance with domestic and international laws and regulations as well as our internal rules and policies.
(3) In order to maintain and expand our trusting relationship with the Eurasian Machinery’s diverse stakeholders, we will disclose information openly and transparently, and respond to stakeholders responsibly through dialogue and other means of communication.

6. Protection of Intellectual Property and Brand

(1) We will protect our own intellectual property, respect third-party intellectual property, and use both effectively for smooth business operations.
(2) We will manage our own and third-party confidential information by importance and manage and handle it appropriately based on this ranking.

7. Securing Corporate Assets

We will use all our corporate assets only for business activities and other appropriate purposes and manage them properly to protect their value.

8. Crisis Management

We will make concerted efforts throughout the Eurasian Machinery secure employee safety and business continuity in case of disasters and threats such as earthquakes, floods, cyberattacks, and terrorism.

9. Responsibilities of Employees

Employees shall pledge to comply with the Codes of Conduct. If they become aware of any non-compliant activity, they shall immediately report to their manager or Legal Department.

10. Responsibilities of officers

All officers shall take the initiative in complying with the Codes of Conduct and make their best efforts to conduct business based on corporate ethics and the law. In the event of violation of the Codes of Conduct, officers shall swiftly take corrective measures and actions to prevent the recurrence of similar incidents, while at the same time strictly disciplining themselves as well as those involved in the violation.

Identifying and solving ethical dilemma

At work you may be faced with situations where there is no obvious right answer and you are unsure which course of action to take. This section will help you to identify instance where there may be ethical dilemma and to find your way through these to make sound ethical decisions.

How to identify unethical behavior or an ethical dilemma.

Ask some of the following questions:

• Are these actions legal, fair and honest?
• How would I feel about myself afterwards?
• How would this issue look if it was reported in the media?
• Would I be comfortable explaining this in court?
• How would I feel if my family and friends knew about my actions?

Listen to the conversations around you. If you find yourself hearing or saying phrases like ones below, you may well be facing an ethical dilemma:

• «No one will ever know»
• «it doesn’t matter how it gets done as long as it gets done»
• «Everyone else does it, so it must be OK»
• «Don’t worry, it’s the way we do things around here»
• «I don’t want to know»

Take advantage of the trust model.

(1) THINK about the ethical dilemma:

• What is the dilemma?
• Do you know all the relevant facts?
• Who does it affect?

(2) READ the relevant policy or procedure:

• Is there a principle in the policy to guide you?
• What are the relevant policies, procedures and/or laws?

(3) UNDERSTAND the implications of the decision for all concerned:

• What is the potential risk to you, our business or other stakeholders (e.g. customers, suppliers, community)?
• What is the likely impact on the business (e.g. reputation, cost, quality, delivery)?

(4) SPEAK to others for guidance:

• Talk to your manager, colleagues, or an expert (e.g. HR Department, Legal Department, Health Safety and Environment) as necessary.

(5) Take action to solve the ethical dilemma:

• Make an informed decision – this may be a simple choice between a ‘right’ and a ‘wrong’ alternative, or more difficult judgement between two ‘rights’.
• Evaluate the results of your decision. What was the outcome, and what did you learn from the situation?

Adoption of Code of Conduct

The Eurasian Machinery Code of Conduct shall apply to all officers and employees of Eurasian Machinery and its subsidiaries. The subsidiaries shall establish their own codes of conduct by adopting or revising the Eurasian Machinery Code of Conduct at a policymaking meeting, ensuring that all their officers and employees fully understand the provisions of the codes.

All employees of the Company are expected to familiarize themselves with the Code of Conduct. HR Department ensures that newly hired employees familiarize themselves with the Code of Conduct and sign an acknowledgement from as a part of hiring procedure.

Any person employed by the Company must notify his or her manager of any breach of Code.

Breaches of this Code are not acceptable and will result in the Company taking action which may include disciplinary action up to and including dismissal.