ER SAI Caspian Contractor LLC (hereinafter – ERSAI) in compliance with the Model stated in Saipem S.p.A.’s group organization, adopts the following Organization, Management and Control Model (“OM&C Model” hereafter). OM&C Model is aimed to prevent illegal behaviors in terms of corruption, extortion, money laundering, frauds and, in general, any offence that may be committed or attempted to be committed in the interests or to the advantage of a company, setting forth disciplinary measures to be enforced in case of illegal behaviors in breach of laws, regulations and/or internal policies.

OM&C Model is inspired by the most updated laws and the best practices for the prevention of “white collar” crimes, and specifically by protocols and precautionary measures ruled within the following regulations: United Nations Convention against Corruption dated 31 October 2003, ratified by Republic of Kazakhstan on 08 May 2008, No 31-IV with exceptions;

Republic of Kazakhstan Law On Combating Corruption No.267-1 dated 2 July 1998.