Caring for our planet

In 2026, the Company will continue to implement the Industrial Environmental Control Programme in accordance with the principles of sustainable development and the requirements of environmental legislation. Minimizing the impact of power plants on water resources in the regions of operation will remain a key area.

Environmental control will be carried out with the involvement of licensed and accredited specialised laboratories and is aimed at ensuring a transparent and objective assessment of the state of surface and groundwater.

As part of the monitoring of water resources in the area of influence of the enterprise, the following types of observations are planned

• Control of water quality
• Control of the quantitative and qualitative composition of water from the cooling system of turbine condensers and water for transporting ash and slag waste to the ash dump
• Monthly observations of the impact on water bodies, according to the monitoring schedule presented in the programme.

Groundwater quality will be monitored through a network of observation wells located in the direction of groundwater flow. The wells are equipped with metal heads and have serial numbers.

Responsible waste management is an important component of the environmental strategy of "Samruk-Energy" JSC. We are committed to the efficient use of resources and minimising the impact of waste on the environment at all stages of our operations, from power generation to facility operations.

The Company carries out waste management activities in accordance with the requirements of the legislation of the Republic of Kazakhstan, including keeping records of generated, treated, disposed of, neutralised, transferred to other persons or received from other persons, as well as disposed of waste. The data are summarised quarterly and annually.

Waste management is organised in strict accordance with established standards and procedures, including

• Corporate Environmental Standard
• Waste Management Programs
• Waste management action plan. ^A

The enterprises carry out careful control over contractors working with waste. During the procurement process, the contractors are checked whether they have the necessary licences and the compliance of material and technical support for safe waste management. Contractors are required to sign contracts confirming compliance with environmental standards and legislation of the Republic of Kazakhstan. Environmental services regularly inspect their activities.

• We actively interact with stakeholders, providing channels for submitting environmental comments through "Samruk-Energy" JSC, all appeals are recorded and carefully considered.
• Waste inventory has been carried out in subsidiaries and affiliates, and for each type of waste, methods for their accumulation have been developed, taking into account the hazard class, toxicity, physical condition and other characteristics.
• Hazardous waste requires specialised disposal, while non-hazardous waste is subject to separate collection and recycling. For separate waste collection, special points and areas are equipped with containers and metal containers marked for ease of identification.

• Bogatyr Komir LLP is actively working to reduce the impact on the environment by reducing the volume of overburden placed on external dumps. The company is developing plans to adapt the mined-out spaces of the Severny and Bogatyr quarries for their use as internal dumps. To prevent oxidation and spontaneous combustion of coal-bearing rocks, inert materials are used to isolate and compact the surface layer of dumps.
• The development of HPPs and renewable energy facilities in "Samruk-Energy" JSC contributes to reducing the amount of ash and slag waste per unit of production.

In "Samruk-Energy" JSC, waste management is carried out in accordance with the Corporate Standard for Environmental Management in the Group of Companies, which defines uniform requirements for accounting, identification, inventory and control of waste at all stages of its life cycle.

The main processes used to collect and monitor waste data include

• Primary accounting of waste is carried out at the places of its generation on the basis of the actual volume of waste, including its quantity, types and further movement (disposal, transfer, placement, reuse).
• Identification and certification – the type, composition, properties and hazard class of hazardous waste are determined, hazardous waste is accompanied by passports in accordance with the legislation.
• Waste inventory is carried out annually by the enterprises themselves or by licensed third-party organisations to check the completeness of data and assess the condition of waste accumulation and disposal sites.
• Consolidation and reporting – primary data from departments are aggregated in environmental protection services to prepare monthly and annual reports used for planning activities, controlling limits and preparing permits.
• Monitoring and control – includes visual inspection of waste storage and disposal sites, verification of compliance with regulatory requirements, control of waste sorting, labeling, transportation and transfer conditions, as well as corrective actions in case of non-conformities.
• Confirmation of data accuracy – reconciliation with documents (certificates of completion, invoices, coupons, balances in warehouses) and verification of reports by responsible persons and management of subsidiaries and affiliates.
• Measures to reduce the impact and prevent waste generation are aimed at reducing waste volumes, reuse and recycling, optimizing production processes, as well as improving the skills of personnel involved in waste management.

These processes ensure the completeness, continuity and reliability of waste accounting, make it possible to control their impact on the environment and improve the efficiency of waste management at the level of the entire Group of Companies.

The enterprises organise the collection of used batteries containing toxic substances, such as lead, mercury and cadmium, which can harm human health and the environment. Used batteries are sent for recycling to prevent them from ending up in landfills. In the period from 2022 to 2025, 278.2 kg of batteries were collected and handed over for disposal at “AlES” JSC.

In the course of their work, Energy Solutions Center LLP (Ekibastuz CHPP), EGRES-1 LLP, EKIBASTUZ GRES-2 JSC, AlES JSC and Bogatyr-Komir LLP do not generate radioactive waste. Radiation monitoring is carried out every quarter, and the results show that radiation levels remain within the safe standard of 2.5 μSv/h, confirming the effectiveness of existing radiation safety measures.

In 2025, 115.8 million tons of waste were generated, which meets environmental requirements. The main types of waste are overburden and ash and slag waste. The volume of waste increased by 6.3% compared to 2024, which is due to an increase in stripping at Bogatyr Komir LLP.

In 2026 and in the medium term, it is planned to implement a set of measures aimed at improving the production waste management system and reducing its negative impact on the environment and the health of employees. The main areas of work include

• Development and implementation of measures aimed at minimizing the impact of waste on the environment and the health of employees.
• Monthly accounting of waste generation, delivery, regeneration and disposal.
• Transfer of waste to third parties for recycling or disposal.
• Development of technologies for effective handling of ash and slag waste using dust suppression.
• Compliance with the standards for temporary storage of waste (no more than 6 months) until their further disposal or processing.

"Samruk-Energy" JSC Group of Companies recognises the importance of biodiversity conservation and rational use of natural resources in the implementation of energy projects.

Our Company prioritises biodiversity conservation and systematically assesses the effectiveness of measures aimed at reducing the impact on natural ecosystems.

The activities of the Company's subsidiaries and affiliates completely exclude the use of specially protected natural areas, protected areas and areas with high biodiversity value.

We are actively working to protect and improve the state of natural ecosystems at all stages of our activities, from power generation to decommissioning.

As part of this work, wildlife conservation projects are being implemented, cooperation is being established with scientific and research institutes, as well as with government agencies. One of the examples of interaction with international environmental organisations is the project of Moynak HPP JSC to preserve the relict ash grove on the Charyn River, implemented with UNDP experts in Kazakhstan.

The Company has in place the Corporate Standard for Environmental Management, which establishes commitment to the principles of environmental responsibility. The document is aimed at preventing and minimizing the impact of operating activities on biodiversity and provides for the implementation of measures to preserve natural complexes, manage environmental risks and control aspects of activities that may affect the state of biological diversity.

Disclosure 101-1. Policies to halt and restore biodiversity

When implementing new projects, we comply with the requirements and principles aimed at preserving biodiversity and reducing the impact on the environment. In particular, the projects provide for

These measures ensure that projects are implemented with minimal impact on natural ecosystems and are in line with the 2030 targets and long-term 2050 goals set out in the Kunming Montreal Global Biodiversity Framework.

In accordance with the requirements of the Environmental Code of the Republic of Kazakhstan, environmental monitoring is carried out quarterly at facilities of hazard categories I and II of facilities that have a negative impact on the environment with the involvement of accredited organisations with the necessary qualifications and licences. The results of monitoring are quarterly documented in the Industrial Environmental Control Report and sent to the authorised state bodies in the field of environmental protection in accordance with the current legislation.

Industrial environmental control (IEC) is a system of measures carried out by a natural resource user to monitor the state of the environment and its changes under the influence of economic and other activities, to check the implementation of plans and measures for the protection and improvement of the environment, the reproduction and rational use of natural resources, compliance with legislation on environmental protection, standards of its quality and environmental requirements, including production monitoring, accounting, reporting, documenting the results, as well as measures to eliminate the identified non-conformities in the field of environmental protection.

Environmental control is the most important legal measure to ensure the rational use of natural resources and environmental protection from harmful effects, a function of state administration and a legal institution of environmental law.

Based on the role of environmental control in the mechanism of environmental protection, it can be assessed as a key legal measure aimed at preventing the degradation of ecosystems, preserving biological diversity and maintaining ecological balance. Through the systematic monitoring and management of anthropogenic pressures, environmental control contributes to the protection of natural habitats, the prevention of species loss, the maintenance of ecosystem resilience and the preservation of ecological functions vital to both nature and humans.

According to Article 193 of the Environmental Code of the Republic of Kazakhstan, environmental education in organisations is carried out through the integration of environmental technology topics, taking into account regional landscape features and climate change, taking into account the Sustainable Development Goals, as well as through the introduction of specialised and interdisciplinary educational programmes and the inclusion of environmental aspects in academic disciplines. As part of the company's production activities, environmental training and employee education are carried out in order to preserve ecosystems and maintain biodiversity. Employees participate in training programmes, seminars and practical classes on environmental technologies and rational use of natural resources, which increases their environmental competence and helps to reduce their impact on the environment.

Thus, we took part in a seminar held on 23 May 2025 in Astana, on the topic "Education for the conservation and sustainable financing of biodiversity". The event brought together representatives of government agencies, organisations, universities, specially protected natural areas (PAs), as well as students and young professionals. During the workshop, key topics were discussed, basic concepts in the field of biodiversity and sustainable development were highlighted. In the era of global climate change and biodiversity loss, it is especially important to train specialists who are able to combine professional knowledge with environmental thinking and act in the interests of a sustainable future.

Disclosure 101-2. Biodiversity Impact Management

The company coordinates and controls the environmental safety of all subsidiaries and affiliates of the group of companies. We comply with corporate standards for environmental impact assessment, biodiversity conservation and restoration, as well as monitoring the effectiveness of measures taken. All our organisations are guided by the same principles of minimizing the negative impact on ecosystems, including the prevention, mitigation, restoration and compensation of the environmental consequences of their activities.

In the course of the planned activity, an environmental impact assessment is carried out with the receipt of up-to-date and reliable (background) information on the species, sizes and places of distribution of flora and fauna in the territory of the planned activity (including valuable and specially protected ones), on the presence and proximity to the territory of the planned activity of the protected area. Also, the information obtained is taken into account when choosing a site for the placement of various production and auxiliary facilities and alternatives for the implementation of the planned activity, as well as the possible impacts of the planned economic and other activities on the conservation of biodiversity, taking into account the alternatives for the location of production and auxiliary facilities and the implementation of the planned activity. During the EIA procedure, the significance of the impacts on the conservation of biodiversity of the proposed economic and other activities is assessed (the probability of risk occurrence, the degree, nature, scale, zone of distribution, as well as the forecast of environmental and related social and economic consequences).

Measures are determined to reduce, mitigate or prevent negative impacts, including planning of actions to prevent and promptly eliminate possible emergencies, measures to preserve and compensate for aquatic biological resources, assessment of their effectiveness and the possibility of implementation.

For example, every two years in the reservoir of the Kapshagay hydroelectric power station on the Ili River, measures are taken to restore the number of fish populations. The work is carried out in the Ili River (43°55′22" N, 77°05′52" E) in compliance with the requirements of the legislation of the Republic of Kazakhstan, using methods to minimise damage to fish. The effectiveness and the fact of compensation are confirmed by the act of stocking water bodies, signed by the authorised body.

On the territory of the combined ash and slag removal system of CHPP-2 of “AlES” JSC, 1,200 seedlings of deciduous species were planted on an area of 0.335 hectares, on the territory of the sanitary protection zone of CHPP-3 of “AlES” JSC - 1,590 seedlings of deciduous species on an area of 0.444 hectares. To restore green spaces in the sanitary protection zone of GRES-2, 2,000 seedlings were planted over an area of 0.7 ha.

In addition, Bogatyr-Komir LLP implemented additional measures to preserve the ecosystem on the territory of the sanitary protection zone, including an increase in the area of landscaping, 2,655 seedlings were planted, in the warm period, maintenance work was carried out for plantings in 2023-2024, sanitary pruning of the crowns of 1,182 trees and removal of 367 dead trees were carried out.

Also, Bogatyr-Komir LLP carried out landscaping work on the dump No. 1, within the framework of which 725 seedlings (0.6 hectares) were planted.

Landscaping of the territory of the SPZ of category I facilities in accordance with the approved plans for the end of 2025 was completed in full. The total area of landscaping was 27.905 hectares, 17,467 seedlings of green spaces were planted

18 October 2025 - On the territory of school No. 107 of the city of Astana, Samruk-Energy, together with first-grade students, planted spruces, pines and apple trees and contributed to landscaping and the ecological future of the capital.

20 October 2025 - In support of the initiative of the Head of State to develop environmental culture and form a caring attitude to nature, "Samruk-Energy" JSC group of companies held an environmental campaign in Ekibastuz to green the city within the framework of the republican campaign "Aza Kazakhstan". Over 4,000 trees were planted by "Samruk-Energy" power engineers in Ekibastuz

Disclosure 101-3. Access and benefit-sharing

The Company ensures the openness and transparency of environmental information. The Company regularly interacts with government agencies, the expert community and local residents when implementing new projects and conducting environmental impact assessments.

The Environmental Report is regularly submitted to the Company's management and the Health, Safety and Environment Committee, as well as annually to the Board of Directors.

The Company's activities are related to the production of electricity and heat energy based on fuel (coal, etc.) and do not provide for access to genetic resources, their use or commercialisation. The Organisation does not carry out research, development or other activities subject to Access and Benefit-Sharing (ABS) regulation.

In this regard, the norms and measures (Access and Benefit-Sharing, ABS) provided for by international and national legislation do not apply to the activities of the Society.

There are no significant cases of non-compliance with ABS legislation.

The production facilities of "Samruk-Energy" JSC are located in anthropogenically modified areas of the urban environment or in an industrial zone and have a minimal impact on biodiversity.

The Kapshagay HPP and the Cascade of HPPs of "AlES" JSC are located in the areas of cultivation of cultivated plants and the location of freshwater reservoirs and have an insignificant impact on biodiversity. Their activities are planned taking into account the ecological features of the territories and have an insignificant local impact on biodiversity. Measures to minimise impacts include monitoring the hydrological regime and maintaining the habitat of aquatic and coastal species.

Disclosure 101-4. Identification of impacts on biodiversity

The main potential impacts on biodiversity in the Group's activities are related to

• Use of land plots for the placement of energy infrastructure
• Operation of Hydropower Facilities
• Disposal of ash and slag waste
• The use of water resources for production needs.

When implementing renewable energy projects, the state of ecosystems in the territory where the facilities are located is analysed.

For solar power plants, the most significant potential impact on biodiversity is related to land conversion during the construction phase.

For wind farms - with a potential impact on the avifauna, as well as local soil disturbance during construction.

The operational activities of renewable energy facilities are characterised by a low level of direct impact, provided that environmental requirements are met

For example, on the territory of the solar power plant with a capacity of 1 MW of Samruk-Green Energy LLP in Almaty, the formation of man-made soil cover was revealed, while the Red Book species of plants and animals were not found in this area.

In accordance with the Action Plan for Environmental Protection Management in "Samruk-Energy" JSC Group of Companies for 2025, "Shardarinsk HPP" JSC, "Moynak HPP" JSC, "Ust-Kamenogorsk HPP" AES LLP, "Shulbinsk HPP" AES LLP, "AZhK" JSC and " FWPS" LLP have developed and approved Monitoring Plans for the impact of economic activities on flora and fauna.

The personnel of "AlES" JSC (Kapshagay HPP and Cascade of HPPs), "ShHPP" JSC, "SHPP" JSC, "UKHES" LLP and "ShulHPP" LLP conduct weekly monitoring of the state of biodiversity during the vegetation period (inspection of the river surface for the death of fish resources). During the reporting period, no cases of fish death were recorded, the results of monitoring the state of the river surface are reflected in the logs of the hydroelectric power plant.

UKHPP LLP and ShulHPP LLP carry out stocking annually, and AlES JSC (Kapshagay HPP) once every two years. At the end of 2025, stocking had been completed at 2 out of 3 HPPs (66.7%).

On 23.09.2025, “AlES” JSC stocked the Kapshagai reservoir, released 3,500 yearlings of carp.

On 08.10.2025, UKHPP LLP stocked the Shulba reservoir, released 78,710 carp fingerlings.

The annual research work "Calculation of the level of contamination of environmental components in the area of solid industrial waste storage facilities - overburden dumps of Bogatyr Komir LLP" is carried out. The main goal is to determine the degree of degradation of environmental components under the influence of man-made load due to the placement of production waste - overburden - on the external rock heaps.

According to the scientific work, the state of the environment (ecosystem) in the area of waste storage facilities produced by Bogatyr Komir LLP is classified as permissible, at which the content of individual pollutants does not exceed the MPC in the components of the environment. There are no rare and endangered plants in the zone of influence of waste accumulators. There are no natural food and medicinal plants. Rare or endangered species of animals listed in the Red Book of Kazakhstan are not found in the area of work.

101-5 Areas impacted by biodiversity

The company's main production facilities are located in areas with varying degrees of anthropogenic impact. The biodiversity impact assessment took into account the nature of the sites' activities, their location and their interaction with the surrounding natural ecosystems.

Ekibastuz GRES-1 named after B. Nurzhanov LLP and Ekibastuz GRES-2 Station SO are located in the industrial zone of the Ekibastuz energy hub, which has been used for electricity production for a long time. These facilities are located in previously disturbed and technologically transformed areas formed as a result of many years of industrial activity (placement of ash dumps, energy infrastructure).

In this regard, the direct impact of the stations on natural ecosystems and biodiversity is limited, since the adjacent territories are already characterised by a high degree of anthropogenic transformation and do not belong to areas with high ecosystem integrity. The main environmental aspects of the activities of these facilities are mainly related to the management of emissions, water use and ash and slag waste management.

Ust-Kamenogorsk HPP, Kapshagay HPP, Shardara HPP and Moynak HPP named after U.D. Kantayev JSC operate on water bodies and, as hydraulic structures, can affect the state of aquatic and coastal ecosystems.

Key potential impacts include

• Changes in the hydrological regime of rivers associated with flow regulation and reservoir operation
• Changes in the habitat of aquatic biological resources, including migration and reproduction of fish
• Transformation of coastal and wetland ecosystems in the reservoir zone
• Changes in the seasonal dynamics of water levels, which can affect ecosystem processes in the tailrace.

At the same time, the operation of hydroelectric power plants is carried out in accordance with the requirements of environmental legislation and water use regimes established by authorised state bodies. As part of its operations, measures are taken to minimise the environmental impact, including monitoring the state of aquatic ecosystems.

"Moynak HPP named after U.D. Kantayev" JSC is located on the Sharyn River in the Almaty region of the Republic of Kazakhstan and is a hydropower facility that generates electricity by regulating the flow of the river and the use of water resources of the Moynak reservoir.

In relative proximity to the area where the station is located, there is a specially protected natural area - the Charyn National Park, located at a distance of about 40-50 km from the Moynak hydroelectric power station. The national park is an area important for the conservation of biodiversity and natural landscapes of the region.

The potential impact of the Moynak HPP on biodiversity may be related to the peculiarities of the functioning of hydraulic structures, including

• Regulation of the hydrological regime of the Sharyn River
• Changes in the natural dynamics of water flow
• Possible impacts on aquatic and coastal ecosystems in the reservoir area and downstream.

At the same time, the Moynak HPP is not located directly on the territory of a specially protected natural area, but is located at a considerable distance from the borders of the Charyn National Park. The plant is operated in accordance with the requirements of the environmental legislation of the Republic of Kazakhstan and the established water use regimes, which is aimed at minimizing the possible impact on the environment and natural ecosystems.

Samruk-Green Energy LLP implements projects in the field of renewable energy sources, including solar and wind power plants in the Republic of Kazakhstan.

Renewable energy facilities, as a rule, are located in previously developed or intact areas that do not belong to specially protected natural areas. Compared to traditional generation, such projects are characterised by a significantly lower level of impact on biodiversity, since there are no emissions of pollutants, the formation of ash and slag waste and significant consumption of water resources during operation.

Potential impacts of renewable energy facilities on ecosystems can include

• Change in the structure of land use in the territory of the location of facilities
• Local impact on vegetation cover during construction
• The possible impact of wind farms on the migratory routes of birds and bats.

Previously, during the implementation and operation of projects of Samruk-Green Energy LLP, the requirements of environmental legislation were taken into account and environmental expertise was carried out during the environmental impact assessment, which minimises the possible impact on biodiversity and natural ecosystems.

Disclosure 101-6. Direct drivers of biodiversity loss

Production processes can have potential impacts on components of natural ecosystems, including water resources, soil cover, vegetation and wildlife.

The main sources of potential impact are

• Use of water resources for technological processes and equipment cooling
• Emissions of pollutants into the atmosphere
• Disposal and transportation of industrial waste
• Operation of hydraulic structures and energy infrastructure
• Changes in landscapes and lands in the location of production facilities.

In order to prevent a negative impact on biodiversity, the Company has introduced a corporate standard for environmental management aimed at minimizing environmental risks, including risks to natural ecosystems and biological diversity.

Disclosure 101-7 Changes in Biodiversity

"Samruk-Energy" JSC carries out systematic environmental monitoring in the areas where its production assets are located. Monitoring is carried out as part of industrial environmental control programmes and is aimed at assessing the state of natural components of the environment.

As part of the monitoring, the following parameters are monitored

• Ambient air quality
• Condition of surface and groundwater
• Soil cover condition
• State of flora and fauna
• State of aquatic biological resources.

At hydropower facilities, regular visual inspections of the water surfaces of reservoirs for fish mortality are carried out, as well as measures for the reproduction of fish resources (stocking of water bodies).

At the Company's industrial facilities of category I, wastewater is not discharged into natural objects. Artificial structures or drainless water bodies that meet all the requirements of building codes to prevent negative impact on groundwater are used as wastewater reservoirs.

According to the results of industrial environmental control for 2025, no exceedances of permissible concentrations of pollutants in wastewater were recorded.

As part of the implementation of the Environmental Safety Program of "Samruk-Energy" JSC Group of Companies for 2025, the following were carried out at the facilities of "FWPS" LLP and "SGE" LLP:

• Monitoring the routes of power lines and the territories of wind farms to identify the possible death of birds
• Measures for environmental information and training of personnel.

At the end of 2025, no cases of bird collisions with wind turbines were recorded. The monitoring results are recorded in the relevant logs of the wind farm.

Disclosure 101-8. Ecosystem services

Conservation of biodiversity is one of the key directions of the environmental policy of "Samruk-Energy" JSC. The Company implements a set of measures aimed at preventing, minimising and compensating for the impact of production activities on natural ecosystems.

Key measures include

• Environmental Planning and Management
• Implementation of corporate environmental management standards
• Conducting an environmental impact assessment during the implementation of projects
• Development and implementation of plans for monitoring the impact of economic activities on flora and fauna.

We strictly adhere to our commitment to land reclamation, which allows us to significantly reduce negative environmental impacts and at the same time increase environmental and social benefits. To ensure the sustainability of the closure and rehabilitation of depleted quarries, we allocate significant funds to cover all related costs.

A key element of reclamation is the active participation of local communities, which increases the transparency of our actions and takes into account the interests of residents. This collaboration helps to better understand the needs of the community and provides a basis for the development of effective ecosystem restoration plans.

We pay special attention to the development and implementation of measures aimed at reducing the impact of our activities on the environment. In this context, special attention is paid not only to the restoration of the ecological value of reclaimed areas, but also to the support of biological diversity and the protection of unique ecosystems.

In accordance with the Environmental Code, we have a legal obligation to dispose of ash dumps, which are specialised areas for the disposal of waste generated in the course of our operations.

In 2025, the estimated value of the fund for the liquidation of ash dumps amounted to 3,345.2 million KZT, which is 10.5% lower than the previous year. The decrease is due to the use of the reserve, as well as the revision of inflation rates and discount rates as of the reporting date. Book value of the provision for the liquidation of ash dumps, million KZT

The assessment of the current reserve for the elimination of ash dumps is based on the current environmental legislation of the Republic of Kazakhstan and is supported by technical and economic calculations and engineering studies that meet modern standards and methods of reclamation. The assessment may be adjusted depending on the results of future environmental studies and updates to reclamation and restoration programmes.

Plans for 2026 and the medium term

• Landscaping and increasing the area of green spaces
• Regular laboratory tests as part of industrial environmental control to monitor and assess the environmental impact of the Company's activities
• Reclamation of exhausted areas of ash dumps, including their restoration and transformation into environmentally safe and functional zones.