Environmental protection

The Company has an Environmental Management System (EMS), which is an integral part of the corporate governance system and the main component of the non-financial risk management system. Kazakhtelecom JSC conducts activities for continuous improvement of the EMS in accordance with the requirements of the international standard ISO 14001. As part of these activities, internal and external audits are conducted.

In 2022, the organizational structure in the field of Environmental Protection (EP) remained unchanged. Environmental issues are managed at two levels. The Health and Safety Department coordinates these activities at both head office and branch level. All planning, coordination, assessment of the company’s environmental risks and identification of hazards are the responsibility of the Chief Strategic Officer.

The Company has the following internal regulatory documents governing environmental activities, which are binding on each employee of the Company:

• Environmental policy (Approved by resolution of the Board of Directors) (https://telecom.kz/ru/pages/13687/172367);
• Kazakhtelecom JSC policy in quality, environment, professional health and labor protection (approved by the Company’s Order) (https://telecom.kz/ru/pages/13687/172367);
• Low-carbon development program of Kazakhtelecom JSC for 2022-2032 (hereinafter referred to as “LCDP”) (approved by the decision of the Board of Directors) (https://telecom.kz/ru/pages/13683/172516);
• Plan of Kazakhtelecom JSC’s environmental protection measures for 2022-2023 (approved by the Company’s Order);
• Program of internal environmental audits of Kazakhtelecom JSC (approved by the Order of the Company);
• Documented procedure for identifying hazards, environmental aspects and risk assessment (approved by Order of the Company);
• Documented procedure for identifying legislative and other requirements in the area of occupational safety, health and environmental protection;
• Documented procedure for monitoring occupational health, safety and environmental indicators (approved by Order of the Company);
• Documented procedure for management of production and consumption waste (approved by Order of the Company);
• Documented emergency readiness and response procedure (approved by Order of the Company).

In accordance with the Environmental Policy and Low-Carbon Development Program, the Company has identified the following priority development areas in the environmental sphere:

• minimizing the negative impact on the environment;
• Awareness of the extreme importance of the climate change problem;
• complying with legislation and national and international environmental standards;
• adhering to the principles of sustainable development in the design and implementation of the Company’s activities;
• responsibility of the Company’s management at all levels for the effective functioning of the environmental management system;
• disclosure of accessible and transparent environmental information to all stakeholders.

At the end of the year, a number of regulatory documents were approved with a view to achieving the set objectives in the field of environmental protection:

• Plan of Kazakhtelecom JSC’s environmental protection activities for 2022-2023. The Plan reflects 30 main activities on rational use of natural resources, monitoring and promotion of environmental initiatives to protect the environment among the Company’s employees;
• LCDP of Kazakhtelecom JSC for 2022-2032. The Program was developed within the framework of implementation of the strategic objective to reduce the carbon footprint in accordance with the legislation of the Republic of Kazakhstan and the Charter of Kazakhtelecom JSC.

Within the Plan of Kazakhtelecom JSC’s environmental protection measures for 2022-2023, the Company implemented measures to minimize environmental impact in terms of air emissions, waste generation and biodiversity. Within the framework of preparation for obtaining the international ESG-rating, the Company held a few seminars on the topics “Sustainable development and priorities, timeframe and possible in integration of ESG-principles into the Company’s business processes” and “Low-carbon development” in the face-to-face format. According to the results of the seminars from the Corporate University Samruk-Kazyna, eight employees of the Company were given certificates of training.

In 2022, the Program of internal environmental inspections of Kazakhtelecom JSC was approved. Within the framework of this program, 8 affiliated branches in 18 cities of Kazakhstan were checked for compliance with the environmental legislation:

• Merger Division “Network”;
• Corporate Business Directory;
• Retail Business Directory;
• TelecomComplect Directory;
• IT Division;
• Telecommunications and Infrastructure Construction Directory;
• Information and Communication Technologies Academy Directory;
• Service factory.

Based on the results of the inspection, the Company’s branches developed corrective action plans for the identified environmental inconsistencies, which were eliminated by the responsible employees.

The Company plans to carry out the following measures to effectively manage environmental protection:

1. Participation in obtaining an ESG rating;
2. Independent assurance of non-financial reporting;
3. Development of a procedure for investigating environmental incidents.

Thus, at all facilities of the Company’s branches, maintenance and operation of generators, gasoline generators and motor vehicles is carried out in accordance with the manufacturer’s recommendations. During periods of low activity, equipment engines are turned off and stationary generators are used in the event of a power outage. A report on pollutant emissions is performed on a quarterly basis in accordance with the deadlines established by the legislation of the Republic of Kazakhstan.

In 2022, in accordance with Montreal Protocol methodology on substances that deplete the ozone layer, the Company carried out calculations on the following ozone-depleting substances used in refrigeration installations at the Company facilities: refrigerants R-407C, R-410A, chlordifluoromethane (R-22), difluoromethane (R-32). The main producer of ozone-depleting substances emissions is refrigerant R-22 with the share of 100%.

The Company accounts for refrigerants in cylinders and kilograms. When calculating ODS, the ozone-depleting potential coefficient of 0.055 was applied.

⁷ Trichlorofluoromethane (CFC -11- equivalent).

⁸ Emissions for 2020 are not given due to changes in the calculation methodology — for the current methodology, the base year is 2021.

In 2022, the total volume of air emissions (AE) was 294 tons. Calculation of AE was based on the approved Methodology for determining the standards of emissions into the environment. The main sources of air pollutants are carbon monoxide (CO) and nitrogen oxides (NOx) — they account for 37.1% and 24.8%, respectively. The total volume of pollutants increased by 4.4% compared to the previous year. The growth of pollutant emissions is due to the long heating season in North-Kazakhstan and East-Kazakhstan regions, which caused an increase in the volume of fuel combustion.

For operation of autonomous heating systems and diesel generator units, projects of maximum permissible emissions are being developed in accordance with the requirements of environmental legislation. Currently, Kazakhtelecom JSC has one valid environmental emission permit for the facility of the 2nd category in Zhambyl region.

In 2023, the following measures are planned to reduce air pollutant emissions:

1. Monitoring of pollutants and recording of emissions;
2. Introduction of quantitative targets for the reduction of emissions of pollutants into the atmosphere.

Efficient use of water resources at all the Company’s facilities is a priority objective of the Environmental Policy. The Company has adopted documents regulating water resource management:

• The Plan for achieving long-term objectives of Kazakhtelecom JSC in the field of environmental management for 2020-2030 approved by the Order of the Company;
• The Action Plan of Kazakhtelecom JSC for environmental protection for 2022-2023 approved by the Order of the Company.

The main sources of water supply are water from water supply organizations (water utilities). The Company does not withdraw water from surface and underground sources in regions with water deficit. In 2022, there was decrease of water intake by 34.36% due to implementation of measures of the Plan on achieving long-term targets of Kazakhtelecom JSC in the field of environmental management for 2020-2030. The Company uses water exclusively for sanitary and household needs. All wastewater of the Company is discharged into the centralized sewerage network in accordance with the contract, except for wastewater at the Company’s facilities in Zhambyl region. Wastewater at these facilities is discharged into screened septic tanks with subsequent disposal under the contract.

The Company plans to carry out the following water resource management measures:

1. Conduct monitoring of water bodies describing the impact of the Company’s activities on them once a year (monitoring of water bodies at the intersections of the main networks of water bodies to determine the degree of cable impact on water bodies, on underwater wildlife, etc.). The monitoring results will allow developing measures to eliminate the impact or preserve water quality in water bodies;
2. Installation of water saving devices (water flow regulators, sensor faucets).

Kazakhtelecom JSC strives to minimize waste generation. The Company has a Documented procedure for management of production and consumption waste approved by the Order of the Company, which reflects the procedure for management of production and consumption waste, including collection, temporary storage, disposal, removal, and monitoring of generated waste in accordance with the legislation of the Republic of Kazakhstan on EP. The Company records waste volumes in registers, as well as based on acts of waste movement (acts of write-off, acceptance and transfer, disposal, etc.).

The Company implements projects to improve and optimize business processes in the field of waste management by the branch “Service Factory”. Every year the Service Factory enters into an agreement with organizations to dispose of the following types of waste of the Company:

• electronic and electrical equipment (climate control equipment, household electrical appliances, power metering devices, backup power supplies (DGS, DGU, mini-electric power plants), uninterruptible power supplies, EPP equipment, transformer substations, power tools, etc.);
• chemical sources of current (batteries of various types);
• mercury-containing waste (fluorescent lamps);
• waste oils (waste oil from gas processing plants, vehicles, transformer substations, etc.);
• waste paper (paper);
• packaging (all kinds of packaging material).

⁹ In 2020-2021 there was no breakdown by hazard class.

¹⁰ The entire volume of waste is disposed of by a third party.

In 2022, the total volume of waste generated was 41.7 tons (excluding municipal solid waste).

Every year the Company transfers telecommunication equipment to specialized organizations for storage and disposal of non-ferrous and ferrous metals. When in proper condition, telecommunications equipment is used as spare parts based on the organization’s Standard “Rules for Dismantling and Recycling of Written Off Telecommunications Equipment” approved by the Company’s Order.

The Company plans to implement the following measures for effective waste management:

1. Conducting an inventory of production and consumption waste.
2. Developing waste passports.
3. Expansion of separate waste collection.
4. Introduction of accounting by waste hazard classes.

The Company does not carry out activities in protected and other areas of high biodiversity value. Pursuant to the Environmental Policy, Kazakhtelecom JSC undertakes to promote the level of biodiversity and prevent production activities in protected areas.

Within the framework of preservation of flora and fauna in the areas of construction and installation works (including cable laying), mechanical and biological reclamation were carried out, which minimize the risks of soil erosion and contribute to restoration of vegetation layer on the disturbed land plot.

In 2023, the Company plans to implement the following biodiversity conservation measures:

1. Development and approval of guidelines for biodiversity management and conservation, as well as land management.
2. Monitoring the impact of the Company’s operations on biodiversity, land, and water resources to develop measures to manage and improve the quality of biodiversity, water, and land resources.