Khanguud Group

We draw conclusions based on research and data, plan for the long term, and make sound decisions.

Research and Data — Every decision is grounded in facts, figures, and research.

Strategy and Planning — Every task has a clear objective, timeline, and owner, and is aligned with the Group’s long-term strategy.

Innovation and Continuous Improvement — We seek out and test advanced technologies and methods and implement effective solutions.

We turn ideas into real results and deliver quality that meets global standards.

Execution and Discipline — We fulfill our commitments on time and to a high standard and take responsibility for our results.

Quality and Standards — We align the quality of our products and services with international standards and pay close attention to every detail.

Sustainable, Green Solutions — We conserve resources and adopt sustainable solutions that reduce our environmental impact.

We put people first and build trust.

Engagement and Commitment — We take ownership of our work and show initiative.

Internal Culture and Participation — We support one another, share our views openly, and value team success.

Ethics and Trust — We deal honestly and fairly with employees, customers, and investors. We admit our mistakes and keep our promises.

We build a responsible business that balances environmental, social and economic impact.

Resource efficiency — We use resources, energy and materials efficiently and minimize waste.

Nature-friendly solutions — We assess the environmental impact of our activities and adopt nature-friendly practices to reduce it.

Responsibility for the future — We put long-term value and the needs of future generations ahead of short-term gains.

1.1 This Code of Ethics (the “Code”) applies to the shareholders of Khanguud LLC (the “Company”), the members of its Board of Directors (the “Board”), its executive management and its employees (permanent, contract and part-time staff, and interns).

1.2 The purpose of the Code is to set the legal and ethical standards and conduct requirements to be observed in the Company’s business activities, and to establish a mechanism for assessing and monitoring compliance with them.

3.1 Respect for the law. The Company and its employees strictly comply with the laws of Mongolia, the Company’s internal regulations and the laws of the other countries in which the Company operates. Where laws and standards conflict, the highest requirement applies.

3.2 Honesty and transparency. Negotiations, decision-making, and financial and other reporting are carried out accurately and transparently, without distorting information.

3.3 Preventing conflicts of interest. Where a personal interest conflicts with the Company’s interests, this must be reported to management immediately and the person concerned must abstain from the decision.

3.4 Freedom from corruption and bribery. Offering, accepting or brokering a bribe in any form is prohibited. When giving or accepting gifts and hospitality, the limits set under the Khanguud Group Corporate Governance Code must be observed.

3.5 Fair competition. We do not engage in unfair competition such as price-fixing, market sharing or bid-rigging.

3.6 Protecting the trust of clients, customers and suppliers. We provide accurate information about our products, services and partnerships, and fulfill our contractual obligations on time.

3.7 Confidentiality. Disclosing confidential information of the Company, its clients or its employees without authorization, or using it for personal purposes, is prohibited. We comply with the Khanguud Group Privacy Policy.

3.8 Proper use of Company assets. Company assets, equipment, working time and reputation are used solely for Company purposes.

3.9 A respectful and safe workplace. We do not tolerate discrimination, harassment or violence, and we ensure occupational health and safety.

3.10 Environmental and social responsibility. We reduce our negative environmental impact and respect the interests of the countries and local communities where we operate.

3.11 Combating money laundering. We do not take part in any transaction connected with money laundering or terrorist financing, and we report suspicious transactions in accordance with the applicable procedures.

3.12 Reporting. We prepare and report the Company’s financial statements and other information accurately, truthfully and in a timely manner.

4.1 The Human Resources Department is responsible for making all employees, shareholders, the Board, business partners and other relevant parties aware of this Code by publishing it on the Company’s website and providing training.

4.2 The Human Resources Department reports to the Board on the implementation of the Code at least once a year.

4.3 Anyone who becomes aware of a breach of the Code may report it to their line manager, to the Human Resources Department or through an anonymous channel. Retaliation against anyone who makes a report is prohibited.

4.4 The Human Resources Department investigates reported breaches and presents its findings to executive management. Breaches involving executive management or a Board member are received and investigated directly by the Board.

5.1 Employees who breach the Code are subject to disciplinary action under the Labor Law and the Company’s internal labor regulations, taking into account the nature and extent of the breach and whether it was intentional. Serious or repeated breaches are grounds for terminating the employment contract.

5.2 Board members and executive management who breach the Code are held accountable under the Company Law and the Company’s Charter.

5.3 Any loss caused to the Company by a breach of the Code, including where a supplier contract is terminated, shall be recovered from the party at fault in accordance with the relevant contract. Breaches of a criminal nature are referred to the relevant law enforcement authorities.

6.1 This Code is approved by the Board and takes effect from the date of its approval.

6.2 Proposed amendments to the Code are prepared by the Human Resources Department and submitted to the Board for approval.