Code of ethics

1. General Provisions

The Code explains rules that employee to know and to observe.
The Code is designed to enhance coordination of actions for all employees and to create conditions for financial viability of the Company.

The Code of Corporate Ethics (hereinafter referred to as “the Code”) of KAMAZ Publicly Traded Company (hereinafter referred to as “KAMAZ PTC”, the Company ) shall identify principal ethical standards and create conditions for financial viability of the Company.

The Code shall cover activities of the Company and its employess regardless of their occupied position (hereinafter referred to as “the Employee”). Specific features of KAMAZ PTC business divisions may necessitate for stricter rules than the ones stipulated herein, and to be coved by individual policies and local policies and procedures.

Within the context of corporate ethical principles special priority to be given to:

Employess should take all necessary measures to comply with the provisions hereof both during working hours and non-working events if they affect the interests of the Company or an Employee is treated by third Parties as a representative of the Company.

2. Company Commitments

Product quality is a major priority of the Company.
Harmonious unity in profit-making, human rights protection and environmental protection is built up within the framework of Company operations
The Company respects human rights and abides by applicable norms
Compliance with antitrust regulations and Fair competition protect the Company from illegal agreements and unreasonable prices.
The Company supports fight against corruption, money laundering and terrorism.

The Company is committed to the principles of sustainable development and consciously manages internal factors that have an impact on environment, society and business community. In pursuance of ethical principles the Company accepts the following obligations and expects a similar commitment from business partners:

3. Safe labor, life and health of Employees

We are held liable for own life and health as well as for lives and health of wider public.
We support corporate culture of labor safety.
We strive to harmoniously connect such aspects as making profit and protecting people.

Life and health of Employees and safety of their labor is the key priority of the Company.

The Company uses its best endeavours to protect lives and health of Employees in the course of their labor activities through continuous manufacturing modernization, improvement of working conditions, decrease of occupational hazards, prevention of work-related injuries and occupational diseases.

The Company is aware of the necessity to implement programs of corporate social responsibility in terms of environmental protection, social development, economics and occupational stability and engagement with community and suppliers in the period of unfavourable epidemiological situation in the world.

The Company is aware of social responsibility for prevention of pandemics and necessity for new behavior pattern for Employees.

Managers at all management levels should provide safe labor conditions to Employees. Company Employees shall bear personal responsibility for safety behavior and observance of occupational safety and health protection on the job.

Each Employee of the Company shall be obliged to:

4. Environmental protection

The main goal of the Company in the course of development and manufacturing is to provide environmentally-friendly and energy efficient products.
Company Employees abide by laws, internal corporate rules and are aware of their responsibility.

The Company’s policy is aimed at the most careful use of energy, water, land and other natural resources in the course of production process, proper handling of industrial waste, careful и restrained use of hazardous materials and technologies.

The Company consistently introduces new waste-free and low-waste technologies into production that reduce maximally the level of negative impact on the environment and ensure minimal consumption of material and raw materials. Rational use of natural resources, preservation of biological diversity and reduction of negative impacts on the environment allow the Company to adhere to the principles of dynamic economic growth in its activities.

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

Professional integrity is the key pillar in the operations of the Company.
Meaningful cooperation regardless of management level.
Ensuring security of information is of great value.

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

Selection and appointment of Employees is carried out taking into account professional competencies
Careful and responsible handling of Company resources is carries out solely for business purposes.
Ethical principles are:
- to work conscientiously;
- to perceive oneself as a part of the whole;
- to be proud to be an Employee of the Company;
- to strive for something new
Employees may not represent the Company in business relations with entities in performance of which an Employee has a significant personal interest that is different from the interests of the Company.
Managers at all management levels are a model of ethical behavior and maintain a high level of Company’s corporate culture by personal example.

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:

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

Managers/heads at all management levels:

7. Corporate image and style

There is a traditional business style in clothes of the Company employees.

The company pays great attention to its corporate 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:

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

Conflict of interests is a situation when the outside interests of one or more employees, regardless of their position held or their family members, run contrary to the interests of the Company.
Information about a potential conflict of interests is provided by the employees of the Company, regardless of their position held, in the form of a notification to the Compliance Service.

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 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 Company welcomes labor dynasties.

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

In case of any questions about the possibility of receiving / giving gifts, submit a request to the Compliance Service.
It is unacceptable:
- to take, offer, promise or give bribes;
- to abuse the authority;
- to carry out commercial bribery;
- to accept gifts in the form of cash, cash vouchers, lottery tickets that can be exchanged for money or other financial services.

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

Only authorized employees can provide information and comments on the Company's activities.

If media representatives address any employee of the Company, he should immediately inform the head of KAMAZ PTC Press Center.

When communicating on Internet resources, disseminate information related to the Company's activities only with the agreement of KAMAZ PTC Press Center.

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

Honesty, openness and transparency are the foundation of our activities with shareholders, external partners and other individuals and legal entities.
The Company complies with laws and regulations, and aware of its responsibility.
The Company fulfills its obligations to counterparties in good faith and expects counterparties to do the same.
Fair competition is the pledge of the effective financial and economic activity.
In relations with representatives of States, we avoid even the semblance of undue influence.
The Copmany does not provide financing for political parties and non-profit organizations that are engaged in political activities.

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:

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

This Code is posted on the official website of KAMAZ PTC
https://kamaz.ru.
Questions with regard to the application of this Code rules can be sent to the email address
sk@kamaz.ru.
Compliance hotline on violations of anti-corruption legislation
+7 (8552) 37-18-37
+7 (960) 070-61-11
compliance@kamaz.org

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:

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.

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.