Environmental management approach

Environmental Management System / GRI 2-23, 2-24, 3-1, 3-3 /

KPO has certified to use the Integrated HSE Management System certified to comply with

international standards ISO 14001:2015, ISO 45001:2018 and ISO 50001:2018, as well as HSE Policy targeted to continuous improvement.

In 2024, KPO successfully passed the ISO 14001 audit that confirmed compliance with the requirements of the standard.

The key environmental commitments of the Company’s HSE Policy include the following significant impacts:

• prevention of the environmental pollution,
• reduction of greenhouse gas emissions,
• biodiversity and ecosystems conservation,
• conservation of resources,
• continuous improvement in environmental performance.

In 2023, the KPO Environmental Concept has been developed, – the Company’s strategic vision for achieving the environmental goals until 2037. The Concept has outlined the Company’s activities in minimizing its environmental impact.

To achieve the set environmental targets within the established time frame, the KPO Environmental Work Programme was developed, where the activities and specific tasks for further ensuring the maximum possible environmental impact mitigation and sustainable development of the Company were defined.

As part of maintaining an effective environmental management system and to comply with the requirements of the new Environmental Code, KPO environmental procedures are regularly reviewed.

As required by the international standard ISO 14001: 2015, KPO continues to work on improving the environmental aspects identification process and environmental risks assessment.

Environmental aspects electronic management system

Environmental Aspects Register is developed and used by KPO to manage environmental aspects EnvAR.

Environmental Aspects Register of the Company’s divisions are annually reviewed and updated in line with the actual status. Based on the Company’s divisions registers, the Consolidated register of the most significant environmental aspects is developed to devise additional activities/control measures to reduce risks and improve the environmental condition. In 2024, the Consolidated Register of Significant Environmental Aspects of KPO covered the following aspects:

1. Pollutant emissions into the atmosphere and greenhouse gases,
2. Waste formation and management,
3. Detection of unauthorized waste disposal,
4. Treatment and discharge of domestic wastewater,
5. Generation and disposal of industrial wastewater,
6. Spills / leaks (hydrocarbons and/or chemicals),
7. Water resources consumption.

Environmental compliance

KPO runs its business in accordance with the environmental legislation of the Republic of Kazakhstan (RoK). KPO annually requests and obtains an Environmental Impact Permit (EEP) from the RoK Ministry of Environmental Protection. This permit sets the limits for contaminants emissions, discharges and limits for accumulation and burial of waste.

Two environmental administrative fines were filed in relation to the events of 2022–2023 for a total amount of KZT 908.62 mln following the unscheduled inspection carried out in the 2024. In 2024, the Company is appealing in court the decisions on imposing an administrative penalty for exceeding emissions limits in the amount of KZT 849.34 mln. and discharge limits in the amount of KZT 59.28 mln. The process of partial appealing the court decision that imposed an administrative penalty for exceeding pollutant discharge limits in the amount of KZT 50 mln is also ongoing. / GRI 2-27 /

Implementation of the Environmental Code

The 2025 Environmental Impact Permit for KOGCF facilities was obtained in 2024 as part of the Rok Environmental Code (EC) requirements. In 2024, the Plan for implementation of the Rok Environmental Code’s requirements was 94 % completed.

During the year 2024, as member of the working groups under the Foreign Investors’ Council, Rok Ministry of Ecology and Natural Resources, Ministry of Energy, National Chamber of Entrepreneurs “Atameken” and the KAZENERGY Association, the Company took part in 147 meetings and commented and introduced proposals for 74 projects of the Rok laws and regulations in environment protection, as a result the following changes been made to corresponding Rok regulatory legal acts:

1. The Rok EC in accordance with the Law No. 121-VIII dated 08/07/2024. The deadline for providing financial support has been extended for 5 years, meaning that existing facilities shall provide financial support for the fulfillment of obligations to eliminate the consequences of its operation starting from July 1, 2029. In October, the Methodology for Determining the Amount of Financial Support was amended in accordance with the Rok Environmental Code.
2. The Working Group for review of the Sour Gas Processing Development Program (SGDGP) and its Guidance was approved by the Order of the Rok Minister of Energy dated June 29, 2024, approval process was systematized.
3. A Working Group has been created to develop structural solutions and ensure a smooth transition to the Integrated Environmental Permit (IEP), as well as to address issues related to the suspension of environmental permits. The draft Orders for development of Process Emissions and Discharge Limits have been coordinated with other state authorities and anti-corruption expert review panel. In November, a round table was arranged for KazEnergy, operators and the MENR. As a result, ‘NIT’ JSC and the Committee for Environmental Regulation and Control of the RoK MENR were advised to work on eliminating the technical shortcomings of the e-Licensing System to ensure the IEP smooth issuance.
4. “The MENR supported the business in cancellation of amendments to the RoK Environmental Code, initiated by the deputies of the Mazhilis of the Rok Parliament, to return to damage calculation using the indirect method for category 1 and 2 Operators for compensating environmental damage from environmental pollution by excessive and unauthorized emissions.
5. In April 2025, the Head of State signed the new Water Code of the Republic of Kazakhstan, which aims to introduce new mechanisms for water conservation and water sources protection, the water resources management approaches with the priority on its protection, measures to prevent and eliminate harmful water effects, such as flood control measures, as well as stricter state regulation and control of water funds use and protection.
6. Discussion of the draft new Rok Tax Code. The draft law proposes to exclude retrospective fees/penalties in case of IEP revocation or suspension and not to apply increasing coefficients (2, 4, 8) to emissions from construction and installation works and reclamation and (or) liquidation works. Some amendments to the list of pollutants have also been proposed.

Environmental Public Hearings / GRI 2-29 /

In 2024, the Company held public hearings on application materials for obtaining the 2025 Environmental Impact Permit for KPO facilities located within the KOGCF. According to the Rok Environmental Code, the public hearings were held on 15-18 October 2024 by means of open meetings in 4 rural districts of the Burlin region (Uspenovskiy, Priuralnyi, Zharsuatsky, Pugachevsky). 84 construction projects, 3 Emission Limits Projects, Waste Management Program, Production Environmental Control Program and Environmental Protective Measures Plan were presented for public consideration.

Information about the planned public hearings was brought for attention of the state authorities and the public through announcements at the Unified Environmental Portal, in a periodical printed publication (newspaper), TV channel and on bulletin boards of local executive authorities of administrative-territorial units.

All projects submitted for discussion at the public hearings in 2024 were endorsed by the state authorities and the public. The results of public hearings were reflected in the protocols of public hearings. A package of documents submitted for the public hearings, including the discussion results, are available on the website https://ecoportal.kz/.

All projects submitted for discussion at the public hearings in 2024 were endorsed by the state authorities and the public.

Supplier environmental assessment / GRI 308-1, 308-2 /

Based on the Rok Environmental Code, KPO as an operator of the KOGCF and condensate export pipeline KPC Bolshoi Chagan-Atyrau facilities is obliged to obtain an Environmental Impact Permit, which also includes Business Partner-organizations engaged to perform works and to provide services on the territory of KPO facilities. Business Partners shall comply with the terms of the Environmental Permit conditions and bear responsibility for their non-compliance under the laws of the Republic of Kazakhstan.

Thus, since 2021, KPO has been continuously working to improve its engagement with suppliers. In the 2021–2022 period, the Business Partners’ control system has been implemented and further developed in 2023 and 2024.

In 2023, the Company’s HSE requirements reflected in Schedule D of contracts were revised. This has allowed proceeding with amendments to existing contracts upon which a number of suppliers are required to manage their own wastes generated within the KPO facilities area. Subsequently, all suppliers performing works at KPO facilities shall handle safe storage of waste at workplaces. While KPO will handle further collection and transportation of waste involving a specialized contractor.

In 2023, KPO has implemented a practice of limited-scope audits of Business Partners by means of the KPO Environmental Controllership to check their compliance with terms of the KPO Environmental Permit. As a result of the audits, accounting systems for fuel consumption at stationary emission sources and Business Partners waste flows were improved. In 2024, internal environmental control system during works or operational environmental control is subject to the audits.

On 22nd December 2023, as part of raising the environmental awareness, improving the Environment Management System and fulfilling requirements of the contracts’ Schedule D, KPO held a workshop on familiarization with the new Rok Environmental Code’s requirements for the Environmental Engineers. The workshop was attended by representatives of the 57 Business Partners. The workshop provided attendees with detailed requirements of the new Rok Environmental Code, as well with better understanding of the Operator and Business Partners’ responsibilities on the environmental protection.

In 2024, the Company implemented procedural and organizational measures to upgrade the Waste Management System to handle waste generated from services provided by Business Partners under the contracts at the KPO facilities. This includes centralized collection of all waste by a single specialized waste management organization to ensure compliance with the Environmental Code, and to improve transparency and efficiency in waste management.

2024 Environmental Protective Measures Plan / GRI 3-3, SDG 9.4 /

To achieve the set environmental goals, KPO annually develops Environmental Protective Measures Plans (hereinafter referred as the EPMP). EPMP focuses on ensuring environmental safety, improving environmental protection methods and technologies, ensuring rational use of nature and maintaining compliance with the ISO 14001 and ISO 50001 international standards.

In 2024 KPO operated the business based on the issued environmental permits. The EPMPs were developed and approved for each of the Permits obtained.

The environmental effect from the implementation of environmental protection measures is presented in Table 28

Environmental monitoring / GRI 3-3, 413-1, SDG 3.9 /

KPO implements a number of environmental programs that cover all aspects of operational activities. One of the key programs is a Production Environmental Control (PEC) Program developed in line with the Rok Environmental Code to meet the following objectives:

• obtaining reliable data about the Company’s emissions and impact of production activities on the environment;
• rapid and proactive response to emergencies;
• minimizing the impact on the environment and human health;
• communication to stakeholders (local communities, state regulatory authorities, partner companies) about the environmental activities of the Company and risks for population health.

As part of the PEC program, the environmental emissions such as air emissions, wastewater discharge, waste treatment, waste accumulation and disposal, and the quality of environmental components such as air, surface and ground water, and soil are monitored.

In 2024, the PEC monitoring of the environment components has demonstrated that concentrations of target substances were on a par with those observed in previous years. No negative impact on the environment from the KOGCF operations was identified.

KPO regularly keeps the production environmental control over the environmental condition at the Field’s waste disposal facilities. In 2024, no direct negative impact on the environmental components has been revealed as a result of monitoring of the ground water and soil at the Eco Centre’s Solid Industrial Waste Burial Landfill and the Temporary Liquid Drilling Waste Storage Site, as well as in сells 35A and 35B. Quantitative control over the movement of waste is carried out to account for the volume of burial, as well as the volumes and time of waste accumulation.

Air quality monitoring is carried out through the collection and analysis of samples by the accredited laboratory as well as by 18 stationary automatic EMS’s. To assess the quality of atmospheric air, sanitary and hygienic limits are used – maximum permissible concentrations (MPC). To determine the level of atmospheric pollution, the registered concentrations of monitored components are compared against the MPC and demonstrated in fractions.

In 2024, over 100 thous. samples were taken by the laboratory, about 115 thous. laboratory sample analyses and 28 thous. measurements were conducted as part of the PEC.

The Company pays special attention to protection of atmospheric air in the Field area, at the SPZ boundaries and in settlements adjacent to the Karachaganak Field.

Sanitary Protection Zone / SDG 11.4, 15.2 /

The current estimated Sanitary Protection Zone (SPZ) at the KOGCF is valid from January 1, 2018. In 2021, KPO successfully completed the relocation of environmental air monitoring stations commenced in 2018. The relocation of these stations was performed due to the change of the Sanitary Protection Zone to ensure correct performance of the continuous air monitoring and to comply with the Rok legal requirements. The plot map of the KOGCF with SPZ marked, as of end 2023 is available for viewing on the KPO website in the section Sustainability/Environmental monitoring/ Sanitary protection zone.

In 2024, KPO has continued the implementation of the Project “Organization and improvement of the estimated KOGCF Sanitary Protection Zone”, having completed “The first phase of planting the KOGCF SPZ and extending the SPZ boundaries”. The aim of the Project is to take care of existing forest stands and to plant new trees, as well as to install information signs at the SPZ boundaries. In order to protect historical and cultural heritage sites from potential negative impact, the Project also provides for the installation of relevant signages at the boundaries of the protected heritage sites. Earlier in 2019, KPO organized the large-scale archaeological research on this topic (see the details in the KPO Sustainability Report 2019, pp. 85-88). / SDG 11.4 /

In 2024, the boundaries of the Sanitary Protection Zone were expanded. According to the project the total number of information signposts is 62. In 2023, 42 signposts and 8 boards were installed. The remaining 20 information signposts are expected to be installed during the project implementation (2025–2028). In 2024, no work was carried out, 2025 budget for installation of historical and cultural heritage site signs has not yet been approved by the PSA Authority.

In 2024, the Project on KOGCF ESPZ Development and Upgrade was updated due to changes in land use within the KOGCF ESPZ area and plans for construction of a new facility (Aksai STP water line – Konchubai pump station). In the period from 2025 to 2028, the planned forest belt locations will be corrected by relocating them to the reserve lands.

A consolidated layout plan of the SPZ development and landscaping facilities will be agreed with the stakeholders.

The total area of ​​the sites planned for green construction for the entire project period will be 249.1 ha, of which 151.9 ha are new plants, and 97.2 ha – reconstruction of the existing ones.

The overall timeline of the entire Project implementation includes the period from spring 2023 down to 2028:

• 2022 – surveys, fieldwork and development of the Project’s work documentation.
• 2023 – demarcation of the SPZ.
• 2024 – Installation of guide posts at the boundaries of the protected cultural and historical heritage sites.
• 2023 – 2026 – forest belts reconstruction.
• 2025 – 2028 – establishment of new forest belts.

Construction of capital facilities in the process of project implementation is not foreseen. The work is being carried out by the contractor. The plot map “Key design solutions of the development and upgrade of the KOGCF ESPZ for 2023–2028” is available for viewing on the KPO website in the section Sustainable development/Environmental protection/ Sanitary protection zone. Consolidated layout plans of the SPZ development and landscaping facilities were agreed with the stakeholders, economic organizations and agricultural producers.

Atmospheric Air Monitoring by automatic Environmental Monitoring Stations / GRI 413-1 /

18 stationary automatic Environmental Monitoring Stations are installed along the perimeter of the KOGCF and the SPZ (EMSs 001 – 018) integrated into a single automatic environmental monitoring system.

Four out of 18 EMSs are located in the Field and within the SPZ. As of the end of 2023, 13 EMSs are located at the ESPZ boundary: 006 – 018 EMSs; EMS 005 is located near the Aksai town.

Annual average concentrations of the monitored components recorded by the EMS in 2024 at the KOGCF SPZ boundary are shown in the table 30. The column ‘Actual annual average concentration’ shows the minimum and maximum average concentrations of the monitored air components recorded by each EMS.

All the EMSs take measurement of the four main pollutants (H₂S, SO₂, NO₂, CO) on a continuous basis, i.e. 24/7.

According to the data received from EMSs at the SPZ boundary in 2024, the actual daily, monthly, quarterly and annual average concentrations of the monitored components did not exceed the established sanitary and hygienic limits.

Meanwhile, 8 cases of 20-minute exceedance in H₂S concentration were recorded during the year.

Pursuant to the requirement of the Rok Environmental Code (Sub-it. 8, It. 2, Article 184), KPO delivered notices regarding the exceedance recorded at the EMS-013, EMS-009 and EMS-006 to the WKO Environmental Department.

It should be noted that no connection has been found between the exceedances recorded at the EMS-009, EMS-07 and EMS-006 and KPO field operations. At the time of the exceedances all KPO facilities were functioning in normal operation mode, no well flaring/clean-ups were performed. No malfunctions of process equipment, leaks or unauthorized emissions, emergency or scheduled shutdowns of the process were recorded. No direct H₂S sources were revealed at the KPO facilities. It is assumed that three cases of 20-minute exceedances, recorded by the EMS –013 on 27 August, could be related to a gas leak from the RBVS, pipeline No. 508.

Moreover, one case of H₂S exceedance was recorded by the EMS-005 located at the entrance to the Aksai town with MPC one time exceeded by a factor of 1.625 times.

No gas odour complaints from the local communities adjacent to the KOGCF were raised on the date the MPC exceedances were recorded.

Air quality data from all 18 KPO automatic EMSs are transmitted online to the West Kazakhstan Oblast Environmental Department via the Ecomonitor portal.

Atmospheric air monitoring at the Karachaganak Field’s SPZ boundary

Along with the continuous monitoring of atmospheric air quality run by the automatic EMS, the accredited Contractor laboratory conducts air sampling at at the KOGCF SPZ boundary, at 8 compass points (rhumbs). Sampling at the SPZ boundary is performed daily at the route monitoring posts¹⁰ with the following frequency:

• 4 times a day at the N, E, S, W sampling points;
• once a day at the sampling points of NE, SE, SW, NW.

In 2024, over 44,000 air samples were collected and analysed for the content of the same components measured at the EMSs: hydrogen sulphide (H₂S); sulphur dioxide (SO₂); nitrogen dioxide (NO₂); carbon monoxide (CO). Additionally, air samples are analyzed for methane (СН₄) and methylmercaptan (СH₃SH).

In 2024, according to the results of air monitoring at eight route monitoring posts at the KOGCF SPZ no exceedance of MPC of the monitored components was recorded.

Annual average concentrations of the monitored air components at the SPZ boundary in 2024 are shown in the table below. The column ‘Actual annual average concentration’ shows the minimum and maximum average concentrations of the controlled air components per 8 points.

Atmospheric air monitoring in the villages adjacent to the Karachaganak Field / GRI 413-1 /

In six villages located along the perimeter of the field: Zharsuat, Zhanatalap, Dimitrovo, Karachaganak, Priuralnoye, Uspenovka, and in Aksai town, stationary air monitoring posts have been installed. Air sampling is carried out four (4) times a day (at 1, 7, 13 and 19 hours according to the State Standard) by the permanent personnel of the contracted laboratory, who reside in the villages. Approximately 52,000 air samples were collected and analyzed at the stationary posts in 2024.

Air samples are chemically tested in the Aksai laboratory for the content of five main components in accordance with the State Standard and ruling documents: hydrogen sulphide (H₂S), sulphur dioxide (SO₂), nitrogen dioxide (NO₂), carbon monoxide (CO), and methylmercaptan (СH₃SH). In addition, every 10 days the air is monitored for concentration of volatile organic components: benzene (C₆H₆), toluene (C7H), xylene (C₈H₁₀).

Monthly air monitoring results are distributed to the villages for posting on the information boards and monthly published on the KPO web-site and local print media (Burlinskie Vesti, Borli Jarsysy, Budni Aksaya). If any gas odour complaint is raised by someone of the community, an unscheduled air sampling is performed at the stationary posts.

In 2024, no MPC exceedances were recorded for the daily average concentrations of the monitored air components in the villages.

In 2024, 3 complaints with respect to gas odour were raised by the villagers living in proximity of the Karachaganak Field and in Aksai. The unscheduled air sampling was carried out in the villages, the analysis results of which showed that the concentrations of the monitored components did not exceed the established MPCone time. Each complaint from an initiator with respect to gas odour was addressed.

2024 annual average concentrations of air components monitored in the seven villages are shown in table 32. The column ‘Actual annual average concentration’ shows the minimum and maximum values of annual average concentrations of the controlled air components. Criterion for assessing air quality in settlements is MPC daily average.