This Ethical Code (hereinafter referred to as the Code) is an adapted version of the ETI code, a unified and consolidated document binding on the Association of Eye Clinics «ASTANA VISION» (hereinafter referred to as «ASTANA VISION») with all affiliated structures and subsidiaries.

All employees of «ASTANA VISION» undertake to use this Code in audits for compliance with SMETA requirements, SA 8000 standards, national accreditation standards, and in their day‑to‑day activities.

The Ethical Code establishes high standards of business conduct that management and all employees of the Association must follow in their work. The Ethical Code is based on the Company’s core corporate values – professionalism, responsibility, fairness, democracy, customer orientation, partnership, and solidarity.

The Code supplements the «ASTANA VISION» Charter, Internal Labour Regulations, Confidentiality Policy, and the Company’s QMS documents.

Managers and all employees of the Company, regardless of their status or position, are required to strictly comply with the norms and requirements of the Code. All employees and managers of the Company, as well as representatives of all interested parties, must be familiarised with the provisions of the Code. Failure to comply with the Code may result in disciplinary action, up to and including termination of the employment contract.

«I HAVE A PROBLEM»

ASTANA VISION promotes a spirit of openness in which any employee can raise concerns about any issue.

We encourage employees to express their opinions, defend their points of view, and report unacceptable behaviour or demands from other employees, regardless of their position or title.

We understand that employees may have questions about certain rules and may need advice or guidance to make decisions. According to our policy, all reports of misconduct by the Company, its employees, or even third parties with whom the Company cooperates are subject to thorough investigation. All necessary measures must be taken, regardless of who is involved in the conflict.

The usual way to raise an issue is through the immediate line or functional manager. In exceptional cases, when certain issues cannot be resolved through normal channels, you may contact the Executive Director of the Association directly via the form at: https://forms.gle/NA17avWdMhVsQGgs6 (Press CTRL and click the link) or by email at lawyer@vision.kz.

Any employee who reports a problem in good faith is protected from harassment and retaliation. If an employee believes they are being subjected to harassment, they must report it immediately through the channels mentioned above.

«In good faith» means that you must be confident in the completeness, authenticity, and accuracy of the information you provide at the time of submission, even if it later turns out that you were mistaken. It is desirable, but not essential, to have some evidence supporting this information.

If an investigation is conducted, it will be conducted fairly and in good faith, with respect for confidentiality and the presumption of innocence. In addition, applicable local legislation will be observed, including due legal process.

During the ethics investigation, all involved parties must provide full cooperation and immediately provide all information and documentation upon request to the authorised committee.

The involved person will also be informed of the allegations against them. In certain cases, there may be a delay in providing information, for example, to verify facts, preserve evidence, or communicate with competent authorities.

Access to all information provided will be restricted exclusively to those persons who have a legitimate basis for it – those authorised to monitor the process or to take necessary measures.

The person who reported the issue will receive a response regarding the results of the investigation to the extent that such a response is appropriate and within the framework of legal requirements and other confidentiality obligations.

If the allegations are proven to be defamatory or made in bad faith, this may result in disciplinary proceedings.

«WORKING TOGETHER»

We strive to ensure that all employees interact in an atmosphere of openness and mutual respect.

Teamwork is strongly encouraged; employees share both the successes and failures of their colleagues.

We should all strive to listen to the ideas of other employees and respect their contributions to the common cause. We must listen carefully and, if necessary, share information, while respecting the confidentiality rules established within the Group.

Disrespect, including offensive language, obscene gestures, racist, discriminatory remarks, and statements concerning gender, religious, age, political issues, as well as those concerning sexual orientation or having a direct or indirect sexual connotation, are unacceptable. Disdainful treatment of colleagues also contradicts the ethical principles of ASTANA VISION.

Only in this way can we maintain qualities such as dedication, trust, cohesion, and respect for other cultures throughout all divisions of our company.

FUNDAMENTAL PRINCIPLES OF THE COMPANY’S ETHICAL CODE

– Any form of discrimination, including racial, ethnic, religious, political, as well as discrimination on the grounds of sex, age, orientation, etc., is prohibited;

– The use of forced labour in any form, including the use of labour or services without remuneration or under threat of sanctions, is prohibited;

– Freedom of association is encouraged: all forms of representation and expression of employee opinions permitted by applicable law are observed;

– Any encroachment on the life, health, honour, and dignity of employees is prohibited;

– In matters of remuneration and working hours, all relevant legislation is fully complied with;

– Any form of harassment, including sexual and/or psychological harassment, is prohibited;

– Employees must ensure the safety and protection of any information, the use of which could harm the Company, including trade secrets;

– The Company «ASTANA VISION» strives to benefit society by actively supporting organisations engaged in social and educational programmes, as well as long‑term social programmes supporting vulnerable groups in Kazakhstan.

ETHICAL STANDARDS FOR COMPANY EMPLOYEES

– Responsibility. Each employee is responsible for their actions and decisions.

– Professionalism. All business relationships of the Company’s employees must comply with business practice and not contradict the law.

– Honesty. All actions of the Company’s employees must be honest.

– Integrity. Employees must strive to prevent any situations of abuse of official authority for personal gain, for the benefit of third parties, or to the detriment of the Company.

– Strengthening the Company’s image and reputation. Employees must strive to prevent situations where their actions could harm the Company’s reputation.

– Respect. Every employee, regardless of position, must treat their colleagues with understanding and respect.

– Transparency. Employee activities must be open and transparent. All interested parties should have access to reliable and objective information, subject to the principle of confidentiality.

– Anti‑corruption. Employees of «ASTANA VISION» are prohibited, while acting on behalf of and/or in the interests of the Company, from offering, transferring, or accepting any means of encouragement or gifts, remuneration, loans, guarantees, sureties, material assistance in the form of cash and its equivalents, regardless of the amount, securities (including deposit or savings certificates), regardless of their market value, precious metals, precious stones, and jewellery made from them, if this may cause a conflict of interest in the performance of their duties, or if such actions violate the law or could damage the Company’s business reputation.

Interaction with Stakeholders

All stakeholders interacting with the Company undertake to comply with the Code and promote compliance with this Code, to familiarise their employees with it, and to inform the Association of any difficulties in complying with the Code.

Final Provisions

A culture of ethical relationships is equally a priority and a responsibility of every employee of «ASTANA VISION».

The text of the Code may be amended and supplemented through practical use and may serve as a basis for creating local acts.