новое положение об информационной политике

Approved

by decree of the Board

“KazAgroInnovation” JSC

Dated on August «29» 2012

Protocol № 13

Confirmed by

Decree of the Committee of directors

of “KazAgroInnovation” JSC dated on

September «18» 2012

Protocol № 15

STATUTE ABOUT INFORMATION POLICY OF JOINT-STOCK

COMPANY “KAZAGROINNOVATION”

Content:

1. General conditions 3

2. Principles of information policy 3

3. Mechanism of realization of information policy 5

4. Order of information disclosure 6

5. Order of information disclosure by representatives of the Company 9

6. Order of information disclosure for Unique stockholder 10

7. Order of information representation of information to Committee

of directors

10

8. Information, which compose commercial or official secret 11

9. Competence and responsibility of stuff of the Company 11

10. Concluding statutes 12

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Положение об информационной политикеАО «КазАгроИнновация»

1. GENERAL PROVISIONS

1. Current Statute about information politics (further - Company) joint-stock

company «KazAgroInnovation» (further - Company) worked out in accordance with

the law of Kazakhstan Republic dated on May 13 2003 «About joint-stock

companies» (further - Law) and other normative legal acts of Republic of

Kazakhstan, Statute of the Company and Code of corporative management of the

Company.

2. Information policy defines basic principles and general requests to

information disclosure about activity of the Company to Unique stockholder –

Ministry of agriculture of Kazakhstan Republic (further – Unique stockholder),

interested in activity of the Company to persons, potential investors and other

persons (further – concerned parties), and also to protection of information, which

composes official, commercial and other secret of Company protected by Law of

Kazakhstan Republic.

3. Information policy – is policy of the Company in sphere of disclosure and

information protection about Company with purpose of promulgation to Unique

stockholder, Committee of directors and their representatives, potential investors and

other concerned parties in capacity, which necessary to taking balanced decision

about participation in Company or to executed other actions, which are able to

influence on financial and economical activity of the Company.

4. The purpose of information policy of the Company is more complete

satisfaction of information requests of Unique stockholder, Committee of directors

and concerned parties in exact information about the Company and it activity, and

also protection of confidential information, which release can be deleterious to the

Company and Unique stockholder.

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5. Information policy must provide improvement of the effectiveness of

Company activity, increasing of active assets’ cost, attraction of investments and

creation of auspicious image.

2. THE PRINCIPLES OF INFORMATION POLICY

6. Basic principles at realization of information policy are:

1) frequency and promptness;

1) demonstrativeness and accessibility;

2) authenticity and completeness;

3) promptitude;

4) observation of confidential treatment;

5) balance;

6) equality of rights.

Principle of frequency and promptness of information disclosure means

responsibility of the Company concerning terms and consistency of information

supply, provided by legislation of Kazakhstan Republic, Company’s Statute, Code of

corporative management present Statute and other inner regulatory documents of

Company (further – documents of the Company). Company realizes the meaning of

frequent providing of information to concerned parties, as a factor which has direct

relationship of taking well-founded decisions and\or affirmative performance.

Information provides in accordance with terms, established by legislation of

Kazakhstan Republic, inner documents of the Company, and also by measure of as

far as event arrival by degree of it significance and with account of it modernity and

general publication.

Principle of demonstrativeness and information accessibility means choice

by Company of such methods of information distribution, using of which will be

possible for concerned parties, free and easy, and also intention of Company to

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provide maximal visibility of information about it activity with account of

observation of confidential treatment concerning information, which composes

official, commercial and other secret protected by law of Kazakhstan Republic.

Principle of authenticity and completeness means responsibility of the

Company in providing information, which corresponds to reality and which

sufficient for understanding in full scale disclosure fact or event. Company takes

care to ensure that providing information wasn’t corrupted by third parties and in

case of finding out this fact takes measures on errors and corruption correction.

Company doesn’t evade of disclosure of negative information about itself, if

such information is not confidential one and it can influence to taking of investment

and other decisions of Unique stockholder, Committee of directors and Company.

Besides information, disclosed by Company obligatorily in accordance with

legislation of Kazakhstan Republic, Company by own initiative discloses to

concerned parties on it own initiative discloses to concerned parties additional

information with purpose of full and exact understanding of Company activity.

List and order of disclosure of such information establishes in all inner

documents of the Company, such as Code of corporative management, Rules of

disclosure and providing of safety of commercial and official secrets of the

Company and etc.

Principle of promptitude means responsibility of Company at supplying of

information about activity of Company, concerned with facts and events, which

affects interests of Unique of stockholder and Committee of directors, in maximally

tight deadlines, including at necessity of accepting according decisions.

Principle of observation of confidential treatment means responsibility of

Company concerning safety and information protection, composing official,

commercial, and other secret protected by law of Kazakhstan Republic, means and

methods, defined by legislation of Kazakhstan Republic and inner documents of the

Company.

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Principle of balance state means providing by Company reasonable balance of

demonstrativeness and visibility, on one side, and confidentiality on another side with

purpose of maximal realization of rights for concerned parties, but in conditions of

severe observation of interests of Company and Unique stockholder, in part of limit in

access to information, composing official, commercial, or other secret of Company,

protected by law of Kazakhstan Republic.

Principle of equality of rights means that Company observes rights of all

concerned parties concerning access to information of Company and it activity,

affects the interests, in severe accordance with norms and requests, established by

legislation of Kazakhstan Republic and inner documents of the Company.

3. INTERVENTION MECHANISM OF INFORMATION POLICY

7. For realization of Information policy of the Company:

1) Keeps count of information (data), which disclosure is obligatory in

accordance with requests of legislation of Kazakhstan Republic and inner documents

of the Company;

2) defines list of information (data) disclosing by Company additionally with

purpose of improvement of it information visibility and demonstrativeness;

3) establishes order of information disclosure to recipients, disclosed by

Company obligatorily and by own initiative;

4) defines list of data, which composes official, commercial or other secret

protected by law of Kazakhstan Republic, public disclosure (delivery, leakage) of

which can be deleterious to interests of the Company and Unique stockholder, and

establishes necessary measures on provision of safety of established information;

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5) establishes system of control over distribution and using of information of

the Company through:

Defining of methods, forms and order of information distribution;

Defining of parties, responsible for preparing and information distributing, it is

able to dislosure;

6) defines competence and responsibility of agencies, officials and employees

of the Company for providing of appropriate information disclosure of the Company

and for safety of information, which comprises official, commercial or other protected

secret by law of Republic of Kazakhstan.

4. ORDER OF INFORMATION DISCLOSURE

8. Information disclosure regards as providing of it accessibility to all

concerned parties notwithstanding purposes of getting this information on procedure,

which guarantees finding and receiving. Information disclosure, in respect to which

there were conducted actions on it disclosure.

9. Responsibility for information sharing about activity of the Company bears

it executive agency. The order of information sharing of concerned by it decision

establishes by it decree.

Executive agency of the Company controls execution of such decisions and

well-timed measures on development and improvement of such work.

10. Company must inform Unique stockholder about activity of the Company,

which affects it interests.

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Information affected interests of Unique stockholder of the Company

confesses:

1) decisions, accepted by Unique stockholder and Soviet of directors, and

information about execution of accepted decisions;

2) output of shares and other capital assets by Company and confirmation by

authorised authority (National Bank of Kazakhstan), reports about results of primary

distribution of the Company, reports about results of redemption of securities of the

Company, annulment by this authorised authority of capital assets in Company;

3) execution by Company of big bargain and bargains, in which execution

Company has proprietary interest;

4) creation of a mortgage (surcharge) of the property of the Company for sum,

comprising five and more percents of assets in Company;

5) receiving in Company of loan in size, comprising twenty five and more

percents of own capital of the Company;

6) receiving by Company the license for realization of some varieties of

activity, discontinuance or stop of action of early received licenses by Company on

realization of some varieties of activity;

7) participation of the Company in establishment of legal entity;

8) arrest of property of the Company;

9) offence of circumstances, which brings exceeding character, in result of

which there was destroyed property of the Company, which balance cost comprised

10 and more percents from total size of assets of the Company;

10) attraction of the Company and it officials to administrative responsibility;

11) to institute court proceedings on corporative dispute;

12) decrees about compulsory readjustment of the Company;

13) another information, affecting interests of Unique stockholder, in

accordance with Decree of the Company.

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Company provides obligatory control of list of employees in Company, which

have information, comprising commercial or official secret.

11. In keeping with acting legislation of Kazakhstan republic the Company

realizes public disclosure of this information:

1) statute and other inner documents of the Company, which regulates

activity, if it agencies: Unique stockholder, Soviet of directors and executive agency;

2) current information about manufacture, financially economical activity and

inner-corporative activity of Company;

3) about important events, results of work and activity of Company;

4) about speeches of the leaders of Company in mass media, press-releases of

Company;

5) about social and personal policy of Company;

6) lists of affiliated persons of Company;

7) about changing of priority directions of activity of Company;

8) depository of finance accounting, defined according to legislation of

Kazakhstan Republic about business accounting and finance accounting,

information about corporative events, annual finance accounting of Company and

audit reports in order and terms, established by regulatory legal act of executive

agency;

9) about dividend policy;

10) report about results or redemption of securities of Company;

11) about accepting of decree on increasing (decreasing) of registered capital

of Company;

12) about principles and methods of corporative management, accepted by

Company;

13) about available license to the right of realization of some varieties of

activity;

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14) about purchasing function and valuation activities, including message of

government public purchasing;

15) about results of proceedings of agencies of management of Company,

Company management and about accepted significant decisions, except information,

comprising commercial or official secret;

16) about changing of name of Company;

17) structure and content of agencies of Company;

18) other documents (materials), provided by legislation of Kazakhstan

Republic, Statute and inner documents of the Company.

12. Right to make public announces of person of the Company:

1) Chairman of Soviet of directors;

2) members of Soviet of directors;

3) Chairman of the Board;

4) members of the Board;

5) managing directors;

6) officials authorized by the Chairman of the Board.

13. Information about Company and it activity realizes by distribution of information

by next methods:

1) publishing of information in mass media information;

2) publishing of information at internet –resource, including at corporative web-

site of Company;

3) information publishing in official printing publication;

4) information publishing in brochures and booklets;

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5) by conduction of press-conferences and meetings with Unique stockholder

and other concerned parties, and also public speeches of representatives of the

Company.

14. Information disclosure realizes in next forms:

1) messages about existent facts;

2) annual report about activity of Company;

3) list of affiliated parties and changes to the list of affiliated parties;

4) annual finance and accounting report;

5) data about auditors;

6) organizational and inner regulatory documents of the Company;

7) messages about increasing (decreasing) of capital stock of the Company,

reorganization and liquidation;

8) statutory press-releases;

9) publications in mass media;

10) publications at corporative web-site of the Company;

11) oral and written answers to requests of concerned parties, who entered, the

Company.

Information, provided to Unique stockholder, discloses in following forms:

1) information (materials), subject to performance of stockholder according to

point 10 of this Statement;

2) answers on questions of Unique stockholder about information providing.

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5. ORDER OF INFORMATION DISCLOSURE

TO REPRESENTATIVES OF THE COMPANY

15. Company adheres to Information policy, which will provide timely and

full-scale disclosure of essential information about activity of the Company.

Information discloses according to demands of legislation of Kazakhstan

Republic and inner regulatory documents of the Company, and can be generally

accessible, so performed to Unique stockholder, so and presented to Unique

stockholder and Committee of directors.

Company provides operative and full access of members of Committee of

directors to information, necessary to it work and decision taking.

16. Information disclosure by members of the Committee of directors and

officials of the Company realizes according to demands of present Statement and

order of suing of confidential information, defined by inner regulatory documents,

confirmed by Committee of directors.

17. Chairman of Committee of directors formally comments and expounds

decisions, which taken by Committee of directors and also states an opinion of

Committee of directors (in the context of conferences, interview and etc.) on

questions, considered at sessions of order, established by legislation of Kazakhstan

Republic.

18. Members of Committee of directors have right to state in public it own

opinion on questions considered at sessions of Committee of directors, and also on

decisions accepted at session of Committee of directors, except information,

comprising commercial or official secret.

19. Executive agency, authorized representative of the Company on

communications with mass media, other authorized parties of the Company on errand

of Chairman of the Board have inclusive right of execution of public speeches on

questions, connected with activity of Company, except information, comprising

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commercial or official secret, at conducted conferences in country and abroad,

meetings, seminars, at sessions of state agencies, agencies of judicial and legislative

authority of Kazakhstan Republic and subjects of Kazakhstan Republic, other social

measures, to take part in press-conferences, briefings, telephonic and video

conferences, to give interview, to speak with comments for Kazakhstan and foreign

mass media, finance, investment and other Companies.

6. ORDER OF ASSIGNMENT OF INFORMATION

FOR UNIQUE STOCKHOLDER

20. Representation of information to Unique stockholder provides by

structural subdivisions of the Company, in which competence doesn’t concerned

corresponding questions

21. Documents, inquired by Unique stockholder according to legislation of

KR and list contained in point 10 of the present Statement, offers in terms,

established by legislation of Kazakhstan Republic. In case, if legislation of

Kazakhstan Republic and/or inner regulatory documents of the Company provided

right of access for Unique stockholder and/or other person to inquired documents,

their copies performed in order and on conditions, defined by Law.

22. Decision about performing on written request, which wasn’t included by

legislation of Kazakhstan Republic and present Statement into list of disclosed

information, accepts by executive agency only in case, if such information:

1) concretizes publicly available about Company and it is of importance of

investment decision;

2) wasn’t referred to data of confidential character and etc.

23. term of consideration of written inquires required in point 21 of the

present Statement, can’t exceed the terms, established by Law of Kazakhstan

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Republic dated January 12 2007 «About consideration of appeals of physical and

juridic persons» from the moment of it acceptance into Company.

7. ORDER OF PROVIDING INFORMATION

TO COMMITTEE OF DIRECTORS

24. Members of Committee of directors provides with whole information,

necessary for realization of own duties.

25. Officials and employees of structural subdivisions of the Company must

timely perform authentic and complete information on questions of the agenda of

session of the Committee of directors and requests of any member of Committee of

directors.

Non-performance of this duty attracts responsibility of above-mentioned

persons according present legislation of Kazakhstan Republic.

8. INFORMATION, COMPRISING COMMERCIAL OR OFFICIAL

SECRET

26. Information, comprising commercial or official secret, must be protected.

27. Company, as person of Chairman of the Board provides all depleted

measures on protection of commercial and official information, establishes

confidentiality and operation mode with such information, establishes list of such

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information, keeping reasonable balance between openness of the Company and

aspiration not to inflict harm to it interests.

28. At employment agreement with officials and employees of the Company

in obligatory order including conditions about non-disclosure of confidential

information.

9. COMPETENCE AND RESPONSIBILITY OF EMPLOYEES OF THE

COMPANY

29. Committee confirms Statement about information policy of the Company,

and also defines order of information disclosure and protection, composing official,

commercial or other secret protected by legislation of Kazakhstan Republic.

30. Executive agency reconsiders and improves Information policy realizes

disclosure and protection of information about activity of the Company according

requirements of legislation of Kazakhstan Republic and inner regulatory

documents of the Company.

31. Company in established order provides timely providing of information,

and also support of high level of information transparency of the Company.

32. Service of inner audit in case of necessity conducts examination of

observation of requirements of legislation of Kazakhstan Republic and documents

of the Company in part of information disclosure, it safety and protection.

33. Responsibility for information sharing about activity of the Company

bears executive agency, by which decision there establishes order of information

sharing for Unique stockholder. Employees of the Company bear responsibility for

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disclosure, and also safety and protection of information about activity of the

Company in order, defined by laws of Kazakhstan Republic.

10. CONCLUDING STATEMENTS

34. Control for observation of present Statement realizes by executive agency

of the Company.

35. Present Statement comes into effect from the day of confirmation of it by

Committee of directors.

36. Committee of directors has right to charge information about observation of

present Statement and legislation of Kazakhstan Republic in part of information

disclosure by Company.

37. Statement about information policy and introduction of changes and

additions confirms by Committee directors.

38. Questions which are not regulated by present Statement were regulated by

Kazakhstan Republic, Statement of the Company and decisions of Committee of

directors.

39. If in result of changing legislation of Kazakhstan Republic some individual

norms of present Statement come into collision with them, these norms falls into

ground and to the moment of introduction changes in present Statement rules by

legislation of Kazakhstan Republic.

______________________________________

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