Code of ethics

The Company complies with the legislation, standards and requirements for environmental protection related to its activities and products and is aware of the full degree of responsibility to present and future generations for the impact that the Company activities may have.

5. Relations between Employees and the Company

The Company builds relationships with Employees on the basis of mutual understanding and trust.

The Company fulfills its obligations to Employees, Employees comply with their obligations to the Company and to each other.

The Company guarantees protection to Employees from any form of discrimination as defined by current legislation of the Russian Federation and international law. In the course of implementation of personnel policy, remuneration policy, social security policy the Company may not have any preferences nationality-wise, gender-wise, age-wise, etc.

The Company ensures transparency and openness in personnel management process providing Employees with favorable working conditions, opportunity to improve their skills and realization of their potential.

The Company respects confidentiality of personal data. Is it permitted to receive and store only information that is necessary for efficient performance of the Company and that is needed pursuant to the Law in the territory where the Company operates.

The Company guarantees that no penalties will be applied to Employees who refuses to perform an action that is pursuant to the law can be regarded as corrupt act even if it can сause losses of additional financial and intangible benefits that could be avoided exclusively in violation of legal requirements hereof.

The Company strives to promptly identify and restrain illegal counter-measures against Employees that in good faith reported of alleged act of corrupt practices.

The Company complies with thу Law on Trade Unions, supports joining of Employees into trade-union activities and does not interfere with it.

6. Corporate Ethics

Each Employee of the Company shall be obliged to comply with requirements of Russian Law and corporate by-laws of the Company, as well as regulations of those countries where the Company carries out financial and economic activities, and corporate rules of the Company.

The following is prohibited in the Company:

• physical violence;
• sexual harassment;
• smoking in non-smoking areas;
• presence at the workplace as well as in the territory of the Company under the influence of alcohol, drugs or other intoxicants;
• use of offensive language in written (electronic) and verbal form. Interaction between Employees is based on respect for the individual, respect for human rights;
• exercising of entrepreneurial or other commercial activities by Employees that have become available to them thanks to position they hold in the Company including business contacts and possibilities of the Company. This restriction does not apply to cases where such activities or participation is directly entrusted to Employee by the Company in the manner prescribed by local regulations;
• use of Company’s assets and resources for personal purposes.

Employees of the Company shall abide by the following principles and rules of inter-corporate conduct:

• conscientious compiance with terms of the signed employment agreement (contract) exercising their job duties, improving their professional knowledge and skills, showing responsibility and initiative, striving to find solutions that increase labor productivity and reduce costs;
• informing the immediate manager about occurrence of existing risks of the Company and formation of new ones including corruption risks, proposing elaborated and balanced decisions for consideration by the immediate manager, and taken decision shall be performed immediately. At the same time failure to comply with knowingly illegal decisions excludes any liability of Employee;
• using available resources of the Company as efficiently as possible and exclusively for business purposes; not carrying actions aimed at damaging assets, resources, business reputation of the Company, treating environment with due care;
• maintaining a healthy, efficient work environment that is open to creativity and changes, sharing experience and knowledge ensuring teamwork; showing courtesy, amiability, ethics, attentiveness and tolerance in dealing with associates, counterparties and other interested persons of the Company;
• not showing prejudice and discrimination (verbally or by actions) towards anyone on the basis of racial, religious, national, gender, age or political affiliation, social origin, property and official status, language of communication and other circumstances;
• complying with requirements of the current applicable legislation and by-laws of the Company, taking all necessary measures to prevent and resolve conflict of interests.

Managers/heads at all management levels:

• are a model of ethical behavior and maintain a high level of Company’s corporate culture by personal example; they carry out necessary introductory and explanatory work in their teams with subordinate employees in order to implement the provisionsof the Code and to prevent violation of the rules of conduct set forth herein;
• show neutrality, attentiveness, good will and impartiality in relations with subordinates and in assessing the results of their activities, support the culture of rejection of corruption; - provide a rational delegation of authorities, maintain a favorable climate in the team aimed at ensuring ann open exchange of views and developing an effective solution;
• ensure selection and promotion of competent, promising Employees that assist the Company in achieving strategic goals, create conditions for training and professional development of employees;
• exercise due diligence including participation of the Company in doubtful transactions that may cause material or reputational damage.

7. Corporate image and style

KAMAZ PTC is a large heavy duty truck manufacturer in the world and the largest heavy duty truck manufacturer in Russia and in the CIS.The wide product line of the output around the world sets the tone for the rules of conducting business.The trademark of KAMAZ PTC is well-known in the world market of heavy duty truck manufacturers.

The employees of the Company, dealership and service network representatives are obliged to:

• follow the rules of using the Company's trademark regulated by the brandbook;
• immediately inform the Company about possible illegal use of the Company's trademark.

The company pays great attention to its corporate image, the elements of which are the business conduct and appearance of the employees.

Traditional business style in the selection of clothes is compulsory for all employees. The only exceptions are those categories of the employees whose work standards involve wearing special clothes.

8. Conflict of interests

The Company respects the outside interests and private life of the employees, but the outside, social, property, financial or political interests of the employee should not run contrary to the interests of the Company.

The employee should refrain from a possible conflict of interests in the event of a situation in which the interests or actions of the employee run contrary to the interests of the Company, or may potentially come into conflict with them and, thereby, have or may have an impact on the objectivity of decisions or actions of the employee.

Conflict of interests may arise in the following cases:

• the employee or his next of kin are people associated with the State;
• the employee or his next of kin are individual executive body,or a member of organization collective executive body, established with the participation of KAMAZ PTC, a party/employee/beneficiary, intermediary or representative of a counterparty to the deals made with the participation of the Company;
• the employee or his next of kin hold or held shares in the Company's profit organizations or third-party profit organizations;
• the employee’s next of kin hold such positions in KAMAZ PTC or in the Company's profit organizations that are able to affect the performance of the employee's official duties or the evaluation of his work.

The work of the Company employee on a part-time basis or a civil law contract should not lead to a conflict of interests and reduce labor productivity of the employee.

The employees are prohibited from representing the Company in business relations with organizations in which the employee has a significant personal interest other than the interests of the Company, including (but not limited to) cases of dominant participation in the authorized capital or management bodies of such organizations of the employee himself, his next of kin or family members.

Provided there is a possible conflict of interests, as well as facts of own share participation or about the participation of next of kin or family members in the authorized capitals and (or) management bodies of third-party profit organizations-counterparties of the Company, the employee of the Company is obliged to provide notice on the existence of a possible conflict of interests to the KAMAZ PTC Compliance Service.

Potentially significant conflicts of interests are addressed by the Compliance Coordination Council of KAMAZ PTC in order to neutralize the influence of risk.

In a situation of a conflict of interests between the employee and the Company, if it is impossible to eliminate the specified conflict of interests, the Company's interests are the priority.

9. Collaborative work of relatives

The collaborative work of relatives in direct or indirect subordination creates reputational costs, spawns doubts about the objectivity of personnel evaluation and promotion procedures in the Company.

The Company restricts cases of relatives’ collaborative work.

The Company welcomes labor dynasties, but their representatives are not given additional rights or opportunities.

10. Gifts

Receiving/giving business gifts, as well as organizing or participating in representational activities is allowed only if it complies with accepted business practices, does not violate country legislation in which the activity is carried out, the requirements of local regulations of the Company and does not create the impression of illegal actions.

It is unacceptable for the Company employees to ask for/receive gifts, rewards, services and other benefits for themselves and others in exchange for fulfillment of obligations or failure to perform actions.

Gifts in the form of cash, cash vouchers, lottery tickets that can be exchanged for money or other financial services are not allowed.

Gifts received by an employee of the Company from business partners and persons associated with the State, the value of which knowingly exceeds 3,000 (three thousand) rubles, or he has doubts about the value of the gift, either are given back to the grantor, indicating to the business partner that the employee of the Company must comply with the requirements of this Code, or the information is transmitted to the Compliance Service in order to exclude the implementation of compliance risks.

For the purposes of this Code, by a gift is meant a gratuitous transfer to third parties or receipt of any property from third parties, including cash, implementation of works, rendering services, as well as the gratuitous granting of the right to receive property, works, services. For the purposes of the application of the Code gifts to family members, relatives or other persons close to the employee are considered as gifts to the employee.

11. Corporate information

Information is the Company’s main property value, and its protection is of significant importance for the stable development of the Company.

The Company employees are obliged to comply with the rules established by the current legislation, as well as the rules regulated by the Company for handling information obtained in the course of work, including insider information, commercial classified information and personal data.Each employee of the Company is held liable for protection of information which is at his disposal as part of the performance of work duties.

With the digital transformation, the Company guarantees the employees and business partners safety and protection of information obtained in the course of the Company's activities from unauthorized access. By the means of process automation and data digitalization management, the Company strives to make processes efficient using artificial intelligence tools.

Any interactions with media representatives on issues of cooperation or information exchange concerning the Company's activities are carried out or coordinated solely by the Press Center of KAMAZ PTC. All requests from mass media, including arrangement of the meeting with the Company's management are submitted to the Press Center of KAMAZ PTC.

12. The Company's relations with stakeholders

All employees, especially leaders, are aware that they represent the Company, and their conduct towards external partners and third parties has an impact on the reputation of the Company.

Shareholders

The Company guarantees its shareholders the enforcement of all rights established by the current legislation of the Russian Federation.

As a profit organization, one of the main goals of which is to make a profit, the Company strives to rise in profitability of its business activities within the framework of tasks and restrictions determined by shareholders and the legislation of the Russian Federation.

Investors

The Company strives to minimize the risks of investors acquiring the Company's securities or investing in the Company in another form by organizing and continuously improving the system of corporate governance, risk management and internal control.

In the best interests of investors, the Company ensures timely disclosure of reliable information about its state and activities to the extent established by legislation of the Russian Federation.

The Company ensures equal access of all representatives of the investment community to information about it.

Clients, contractors, customers

The company forms its relations on the basis of:

• mutual trust and respect;
• compliance with generally accepted standards of conduct and business ethics;
• refusal to participate in transactions that could damage reputation of the Company;
• unacceptability of bribery and commercial bribery;
• fulfillment of contractual obligations in good faith;
• timely prevention of conflict situations and maximum use of constructive negotiations with a view to resolving the contradictions that have arisen;
• refusal to take any actions that could be detrimental to the interests of the other party, mutual respect and trust.

The company strives to ensure high quality, economic attractiveness and competitiveness of its products.

Subsidiaries and affiliates

When making decisions regarding the Company's profit organizations, KAMAZ PTC is guided by the interests of its shareholders, while taking into account the interests of other shareholders (participants) of these companies, as well as the legislation requirements of the Russian Federation, the charter and local regulations of the Company.

The State and society

The Company interacts with persons associated with the State in accordance with the requirements of applicable law.

The company actively develops projects of industrial parks in certain regions, which contributes to their socio-economic development, the growth of industrial production and the improvement of population’s working conditions.

The Copmany does not provide financing and does not support by any other means political parties and non-profit organizations engaged in political activities. And also does not permit to carry out sponsorship / charitable activities with the direct or indirect purpose of obtaining unlawful advantage for providing such assistance.

When carrying out sponsorship/ charity activities, the Company puts emphasis on the prevention and protection of citizens' health, promotion of a healthy lifestyle, development of physical culture and sports, education, science, culture, art, enlightenment, improvement of the moral and psychological condition of citizens. The Company supports voluntary work of the Company employees.

13. The implementation mechanism of the Cod

Responsibility for labour organization on the implementation of requirements and provisions of the Code with regard to countering corruption lies with the Compliance Service.

In the event that certain provisions of the Code come into collision:

• provisions of the current legislation are applied with the current legislation;
• provisions of the Code are applied with traditions, customs or someone's ideas about the appropriate rules of conduct.

If the employee has questions regarding application of this Code rules, he may seek advice from his immediate supervisor or the Compliance Service.

The Company guarantees that the employee's provision of information about the Code violation will not be a subject matter of publicity and will not cause negative implications with regard to the employee's occupational status, who reported such information.

14. Responsibility

Compliance with the provisions of this Code by the Company employees is an essential element of the successful implementation of the Company strategic aims and an objective assessment of the personal, professional and business qualities of the employee himself.

In accordance with the labor legislation of the Russian Federation and local regulations disciplinary measures may be applied to the Company employees who violated the provisions of this Code. In case of minor misconduct detection, recommendations on conduct change may be given in accordance with the principles established by this Code.