Occupational health and safety

The Company intends to comply with the world’s best practices, as well as strictly follow the national and international requirements and continuously improve its Health and Safety Management System (HSE).

Kazakhtelecom’s OHS (occupational health and safety) priorities are:

• relevant compliance with and application of the Labour Code of the Republic of Kazakhstan;
• provision of safe working conditions and workplaces;
• use of modern technologies and best practices in occupational safety and safety;
• introduction of modern means and methods of preventing occupational injuries and occupational diseases.

Early prevention or mitigation of adverse health and safety impacts on employees, contractors’ employees and population plays an important role in Kazakhtelecom JSC’s activity in the field of occupational safety. The safety and labor protection management system functioning in the Company is aimed at providing methodological guidance, analysis and control over the state of OHS.

Kazakhtelecom JSC developed the Occupational Health and Safety Policy that applies to all employees and contractors of the Company.

The main internal documents regulating the issues of occupational health, safety and environment, industrial safety, within which Kazakhtelecom JSC’s health and safety management system operates, are:

• Occupational Health and Safety Policy;
• Collection of instructions on safety and labor protection by types of work;
• Collection of instructions on safety and labor protection by professions of the Center for maintenance of local networks of branches of Kazakhtelecom JSC;
• Technical requirements and specifications for special clothing and personal protective equipment;
• Health and Safety Card Program;
• Regulations on encouragement of employees in the field of occupational safety and health;
• Procedure for drawing up reports and collecting data on accidents and potentially dangerous situations related to the work activities of employees to be investigated by Kazakhtelecom JSC;
• Kazakhtelecom JSC’s policy on driving;
• Travel and Driving Standard;
• Approved forms of statistical reporting on OHS;
• Rules for periodic mandatory medical examinations;
• Rules to produce work in conditions of increased danger according to work permits;
• Standard Fire safety rules at Kazakhtelecom JSC;
• Documented procedure “Emergency Preparedness and Response.

The Company has the Occupational Safety and Health Service (OSHS), which is a special functional unit of the Central Administration of Kazakhtelecom JSC. The Service is responsible for day-to-day management and coordination of all organizational work on labor protection in the Company.

Responsibility for the implementation of the emergency management procedure is vested in the heads of structural subdivisions of the Company’s Central Administration Office and affiliated branches, as well as responsible employees for occupational health and fire safety.

At Kazakhtelecom JSC, we understand that employees play an important role in managing occupational safety issues. For this reason, we ensure active involvement of employees in the development, implementation, and evaluation of the occupational safety management system. All branches and central office of the Company have established industrial safety and labor protection councils. The production councils work on an ongoing basis to organize joint efforts by the Company and employees to ensure compliance with occupational safety requirements, prevent occupational injuries and diseases, and also organize inspections of working conditions and occupational safety at workplaces. In addition, in case of crisis situations, the Company forms a working group for investigation and elimination of crisis situations with the participation of the Occupational Safety and Health Service together with the Civil Defense Headquarters.

In 2022, Kazakhtelecom JSC developed a standard “OHS Card Program” aimed at increasing the level of involvement of the Company’s employees in the process of improving the OHS system, as well as enabling employees to observe and report on hazards, potentially dangerous cases, and good practices, and make proposals for improving the Company’s OHS.

In addition, with a view to involving the Company’s employees in creating safe working conditions at their workplaces to achieve zero injuries, Kazakhtelecom JSC approved the “Regulations on encouraging employees in the field of safety and labor protection”. The Regulation defines the categories of annual encouragement and the procedure for selection, as well as approves the amounts and types of encouragement.

Within the framework of the HSE Concept and the Roadmap the “Қауіпсіз еңбек” (Safety Work), measures were implemented to reduce accidents, achieve zero injuries and train managers of all levels.

¹⁹ the system has not undergone an internal audit procedure and/or an independent third-party audit/certification procedure.

The Company understands the importance of ensuring efficient operation of the health and safety management systems. Kazakhtelecom JSC has introduced health and safety management systems in accordance with international standards. Kazakhtelecom JSC has implemented an Integrated Management System in accordance with international standards ISO 9001, ISO 14001, and ISO 45001.

The Health and Safety Management System establishes uniform requirements for the organisation of occupational safety in accordance with the “Guidelines on Occupational Safety Management Systems of the International Labour Organisation of International Labour Standards ILO-OSH 2001” and the international standard ISO 45001:2018.

One of the main principles of the Company’s OHS policy is the constant improvement of the system of industrial and occupational safety in accordance with the requirements of international standard ILO-OSH and their national counterpart ST RK ISO 45001–2018 and an increase in its effectiveness.

The company reviewed documentation for compliance with ISO 45001:2018 and ISO 14001:2015 standards for documented information of occupational health, safety and environmental management systems.

In addition, as part of the Integrated Management System, the Company developed a Documented Procedure “Emergency Preparedness and Response”, prepared taking into account the ST RK ISO 9000-2015 “Quality Management Systems. Basic provisions and vocabulary”, ST RK ISO 14001-2016 “Environmental management systems. Requirements and guidelines for use”, ST RK ISO 45001-2019 “Occupational safety and health management systems. Requirements and guidelines for use”.

The requirements of the Documented procedure are mandatory for application in all affiliated branches of Kazakhtelecom JSC. The document applies to all areas of the Company’s activity.

Kazakhtelecom JSC treats with due responsibility the issues of managing occupational health and safety risks. The process of managing the key risks of OHS is an integral part of the corporate risk management system, as well as the Company’s health and safety management system. Assessment of unacceptable hazards and risks is carried out in accordance with the approved documented procedure “Hazard Identification, Environmental Aspects and Risk Assessment. Procedure for Determining Management Measures”.

The Company’s Risk Register identifies occupational injuries as one of the main risks. The Company has compiled a list of measures aimed at preventing the risk and mitigating its consequences.

To identify work-related hazards and assess risks, an action plan for a key risk event has been prepared, and the status of key risk indicators for key risk events, on the basis of information on injuries and accidents at work, and internal health and safety control, has been provided. The Company has approved the Register of significant hazards and unacceptable risks. The Company also analyzes and assesses the probability and impact of risks, and reviews measures to minimize risk taking into account the current situation.

In 2022, the Company approved and put into effect the standard “Procedure for reporting and collecting data on accidents and potentially hazardous situations related to labor activities to be investigated at Kazakhtelecom JSC, which is designed to facilitate the collection of data on accidents and potentially hazardous situations to be investigated. In addition, in 2022, the Chairman of the Management Board announced the “Right to Stop”, which enables the Company’s employees to stop work partially or fully at any time if they believe that working conditions are unsafe. In doing so, employees are guaranteed that there will be no adverse consequences for partially or completely stopping unsafe work.

Kazakhtelecom JSC regularly identifies and assesses project risks and adverse impacts on the health and safety of population groups in the areas where it operates, and develops protective, preventive measures. If necessary, the Company cooperates with relevant authorities and other stakeholders on mitigation measures and plans.

Hazard identification and risk assessment procedures consider the daily activities of all personnel, human behavior and abilities, hazards identified near or outside the work area, infrastructure, equipment and materials, and technological processes. The Company defines and implements risk management measures.

Kazakhtelecom JSC understands its responsibility for managing the issues of occupational injuries and ensures regular meetings to analyze all causes of accidents that have occurred in the Company and develop measures to prevent them.

The Company carries out analysis of occupational injuries and accidents, because of which information letters are prepared and sent to the branches, which contain a list of measures for prevention and avoidance of accidents. In addition, the Company discusses the circumstances and causes of accidents with employees in all subdivisions and conducts unscheduled safety briefings.

To ensure occupational health and safety, an annual Zero Injury Plan is implemented. A report on the implementation of the plan is reviewed by the Board of Directors on a quarterly basis.

The Company does not conduct statistical recording of injuries among employees of contractors with whom it has service contracts.

²⁰ This data covers 100% of the Company’s employees. No categories of employees have been excluded from these statistics.
²¹ The coefficients are based on 1,000,000 hours worked.

In 2022, the Company had two accidents with a severe degree of occupational severity.

Main causes of injuries:

• road traffic accident caused by the fault of a third party;
• inadequate organization of safe work by responsible managers, resulting in an explosion of faulty equipment in Aktobe.

Based on the results of the identified accidents, the management of Kazakhtelecom JSC took the following corrective measures:

• conducting a special investigation;
• full inspection of working equipment in the Company’s branches and divisions for compliance with the requirements of OHS;
• disciplinary reprimands to responsible managers;
• provision of compensation for material damage.

Compliance with occupational health and safety requirements in carrying out its activities is mandatorily ensured and monitored by the Company, and comprehensive measures to prevent accidents and incidents are taken on a regular basis. In addition, Kazakhtelecom JSC carries out systematic work on improving safety culture to raise the level of employees’ awareness of the relevant requirements, as well as to ensure compliance with the best international practices in this area.

The Company carries out annual training of employees in occupational safety, industrial safety, fire safety and minimum safety requirements for working at electrical installations, both in third-party training organizations and at workplaces. In 2022, Kazakhtelecom JSC held trainings and training programs in the field of occupational health and safety for the Company’s employees:

• providing first aid to injured people;
• fatigue control;
• a master class program on “Safety for Children”. 100 participants aged 8-10 years old were trained in the pilot mode;
• online injury prevention and response level 1 training — on injury prevention;
• online injury prevention and response level 2 training for technicians;
• online injury prevention and response level 3 injury prevention training for trainers;
• safe driving training. Drivers in the cities of Astana and Almaty participated;
• Health and Safety Facilitation” training; “Occupational Health and Safety Facilitation” training.

In 2022, the total amount of investment in industrial safety and labor protection was KZT 970 million.

Since care for people is the Company’s top priority, special attention in Kazakhtelecom JSC’s activity is paid to employees’ health. The social package of employees includes full medical insurance, in accordance with the terms of collective agreement there are health improvement and sanatorium-resort treatment programs. In addition, the Company regularly conducts preliminary, periodic, and unscheduled medical examinations. Based on their results, if necessary, employees are sent for in-depth preventive examinations. Employees who are production personnel and are subject to mandatory medical examinations but have not passed a medical examination are not allowed to work. In accordance with the requirements of the Labor Code of the Republic of Kazakhstan, employees of the Company’s contractors engaged in work associated with increased danger, machines, and mechanisms, also undergo mandatory pre- and post-shift medical examinations.

The company is continuously working to improve its practices in occupational safety and occupational injury risk management. Several corrective measures were taken to ensure the elimination of work-related hazards and to minimize the risks of injury:

• unscheduled briefing with an analysis of the causes and circumstances of the accident with employees of the Company’s branches;
• an unscheduled check of the knowledge of the injured persons for their knowledge of the Instructions on Occupational Safety and Safety for the electrical controller and during the performance of work at height;
• when working at a height of more than 1.8 meters, and if the distance is less than two meters from non-protected height, protective devices and PPE have been used;
• access to work with heightened danger was performed after the responsible manufacturer of the work provided confirmation of its readiness for safe work (availability of special clothing, special footwear, protective cask, security and retention tie, security rope, fixtures, etc.);
• to take disciplinary measures against managers and employees who allow work to be performed without the use of collective and personal protective equipment, up to and including termination of employment contracts.

To prevent employees falling into inspection pits, the Service Factory shall:

• to provide all repair boxes with protective billboards to cover the inspection pits, with a depth of at least 4 cm;
• develop instructions on occupational and occupational safety when performing work in the inspection pit, with subsequent familiarization of employees against signature;
• to provide repair boxes with sufficient portable lighting with a voltage of 12 volts.

In 2022, Kazakhtelecom JSC was awarded a certificate of honor for successful work in the field of industrial safety by Samruk-Kazyna JSC.

Contracting organizations carrying out work at the Company’s facilities are obliged to comply with the requirements, standards, and norms in the field of environmental protection and industrial safety.

Kazakhtelecom JSC responsibly interacts with suppliers of goods, works and services in terms of managing occupational health and safety aspects. Requirements to suppliers and contractors are imposed in accordance with the corporate standards in the field of occupational safety. At the same time, contractors independently monitor compliance with occupational health and safety requirements.

The Company has implemented a system for assessing contracting organizations on production safety issues. For employees of contractors, the Company organizes training in OHS aspects.

Kazakhtelecom JSC treats responsibly the issues of emergency response. According to the Occupational Health and Safety Policy, the Company applies the principle of “immediate notification, timely and objective investigation and accounting of all accidents, incidents and incidents in accordance with the legislation of the Republic of Kazakhstan and corporate documents”. The Company has a Civil Defense (CD) Headquarters, which forms teams in case of emergencies. The HQ reports directly to the Chairman of the Management Board. Kazakhtelecom JSC regularly conducts training alarms and emergency drills.

1. Implement procedures to motivate and reward employees for H&S achievement.
2. Implement the H&S Behavioral Surveillance Program (OHS Card).
3. Provide all employees with “Right to Stop” cards.
4. Organize an occupational safety audit.
5. To hold the second annual forum of Kazakhtelecom JSC on Health & Safety with the participation of subsidiaries and affiliated organizations (SAO).
6. Updating the health and safety management system.
7. Develop and implement a standard for investigating accident.
8. Continue the program for rewarding the Company’s employees for their commitment to occupational health and safety (motivation program).
9. Develop the possibility of using VR-technologies to practice skills for safe performance of hazardous types of work with the risk of severe and/or fatal injuries.
10. Acquire a frontal collision simulator to train as many employees as possible.
11. Make a register of risks of emergencies, accidents, and emergencies with a high probability of severe and/or fatal outcomes at the level of Kazakhtelecom JSC.
12. To automate everywhere the process of pre-shift and post-shift medical examinations to reduce the risks of deterioration of employees’ health.
13. Procure emergency medical equipment, including defibrillators for cardiopulmonary resuscitation.
14. To train 100% of employees in the methods of medical assistance.
15. To train 100% of the production personnel on the course “Culture of safe work”, including the involvement of internal trainers.