Regulation of insider information Almaty International Airport Joint Stock Company

1. General provisions

1. The Regulation of insider information of Almaty International Airport Joint Stock Company (the ‘Regulation’) is developed in accordance with the Law of the Republic of Kazakhstan ‘On joint stock companies’, Law of the Republic of Kazakhstan ‘On securities market’ (the ‘Law’), Charter, internal documents of Almaty International Airport Joint Stock Company (the ‘Company’), and current legislation of the Republic of Kazakhstan for further improvement of corporate management practice of the Company, and its adjustment to international standards.

2. The primary objectives of this Regulation are prevention and suppression of unlawful use of the insider information.

3. This Regulation establishes the procedure and the criteria of insider information, limitation on the use of the insider information, responsibility for unlawful use of the insider information.

2. Insider information

The insider information in this Regulation means any information on issuable securities of the Company and securities transactions, as well as any information on the Company and its activities unknown to third parties, which disclosure may have a significant influence on the market value of stocks and other securities of the Company.

4. The insider information includes:

1) information constituting a commercial secret until it is disclosed;

2) information, subject to disclosure in accordance with the laws on securities market, until it is disclosed, unless otherwise provided in the laws;

3) other information on the Company’s activity, securities of the Company and securities transactions, which is not public, and which disclosure may have a significant influence on the market value of securities of the Company.

3. Insiders

5. The insiders mean individual persons and legal entities having the right of access to the insider information of the Company as per the Law, other regulatory legal act, internal document of the Company, job description, or a contract concluded with the Company, including:

members of the Board of Directors, and the executive board of the Company;

employees of the Company having the access to the insider information due to their official duties;

auditors, independent appraisers, consultants, contractors to concluded and/or planned to be concluded contracts of the Company, and their authorized persons cooperating with the Company;

other persons for whom the insider information of the Company can be available.

6. Procedure for maintaining and keeping a list of persons having the access to the insider information in a current status shall be established according to the internal documents of the Company.

4. Limitations on the use of the insider information

7. Before the official disclosure of the insider information by the Company, the insiders are obliged to keep such information confidential in accordance with the Regulation, Charter, Code of corporate governance, and other internal acts of the Company.

8. The insiders do not have the right to disclose known to them insider information of the Company, except for cases of disclosure of such information provided for by the laws of the Republic of Kazakhstan and/or internal documents of the Company.

9. The insiders do not have the right to use the insider information of the Company for the purposes not related to their professional activity at the Company and/or purposes not stipulated by provisions of non-disclosure agreements and labor contracts concluded with the Company.

10. The insiders do not have the right to use the insider information, except for cases provided for by the laws of the Republic of Kazakhstan and/or internal documents of the Company, in the personal interests or in the interests of third parties, and do not have the right to use the insider information for transactions with the Company’s securities, transfer the insider information to third parties for transactions to be made by them with the Company’s securities, and transfer them any recommendation for making transactions with the Company’s securities based on the insider information.

11. For the purpose of prevention and suppression of unlawful use of the insider information when making the transactions with the Company’s securities, the insiders are obliged to notify the Company’s Board of Directors in writing (by Corporate Secretary) on the intention to make transactions with the Company’s securities in advance, unless otherwise provided in the internal documents of the Company.

12. After the official disclosure of the insider information of the Company, the limitations on its use and disclosure established by the Regulation shall become invalid, unless otherwise provided for by the laws of the Republic of Kazakhstan or internal documents of the Company.

5. Disclosure of the insider information

13. The official disclosure of the insider information by the Company means its publication in the order and form provided for by the laws and/or internal documents of the Company.

14. Unlawful disclosure of the insider information by the insiders and other persons does not relieve the Company from liabilities to disclose it in the cases provided for by the laws of the Republic of Kazakhstan and/or internal documents of the Company, and does not cancel limitations on its use established by the Regulation, until such information is officially disclosed by the Company.

15. In the cases when the applicable laws of the Republic of Kazakhstan do not establish special order and form of publication for certain types of the insider information, the official disclosure of such information is carried out in accordance with the order and form determined by the Customer.

6. Responsibility

16. The insiders are responsible for the unlawful disclosure and use of the insider information of the Company in accordance with the laws of the Republic of Kazakhstan, internal documents of the Company, and provisions of agreements concluded with the Company.