Code of Ethical Principles and Conduct of Octobank JSC

 Code of Ethical Principles and Conduct of Octobank.

To achieve Octobank's goal of entering the international market and strengthening its position as a global financial hub, it is essential not only to provide innovative solutions, but also to demonstrate strict adherence to international standards of corporate ethics and transparency.

The Code of Conduct will be a key tool for:

1. Maintaining the trust of customers and international partners;

2. Minimizing reputational and legal risks;

3. Strengthening the bank's position as a responsible player in the international arena.

This document not only forms the basis of the corporate culture, but also confirms Octobank's willingness to work in accordance with the best international practices, which is crucial for attracting new partners and expanding its presence in the global market.

I.Introduction

Why is this document important?

Octobank is more than just a financial institution. We are creating an ecosystem where innovation, professionalism and responsibility build the trust of our customers, partners and society. This Code is not just a set of rules. This is a guide that helps each employee act in the interests of the bank, customers and society, make informed decisions and be part of a team that strives for the best.

For Octobank employees, the Code is a guide that helps:

1. Navigate difficult situations;

2. Make decisions that meet ethical standards;

3. Work effectively, maintaining the values and reputation of the bank.

This document covers key aspects of your professional life at Octobank and explains how each of us can contribute to the success of the company.

II.  Mission, values and principles

Company's mission.

"We provide innovative financial solutions that help clients and partners achieve their goals. Our mission is to become a global financial hub, providing a high level of service and support for sustainable economic growth."

Octobank's mission combines two key objectives: providing customers and partners with convenient, high-tech financial solutions and making a strategic contribution to the development of the regional and global economy.

Innovative Financial Solutions: We focus on developing fintech products, cryptocurrency solutions, and services that simplify complex processes.

Customer and partner support: We help our clients and partners succeed by creating a platform for long-term success.

Global Hub: Our goal is to connect markets and regions through cross-border financial instruments and partnerships, becoming an important link for the economies of Central Asia and the world.

Company values.

Adaptability:

"We offer solutions that use cutting-edge technology for customer convenience and safety."

The introduction of new technologies allows us to offer our clients a unique experience, from user-friendly mobile applications to automated analytical tools;

We strive to use artificial intelligence, blockchain and other modern technologies to provide products that make finance accessible to everyone;

Data and transaction security is our top priority, which we achieve through technological innovation.

Transparency:

"We work honestly and openly, complying with the law and internal standards."

We build trust through honest communication with customers, partners and employees;

Transparency means there are no hidden conditions, manipulations or misinformation in our work;

All information about Octobank's products, services, and processes is open for understanding and study.

Client orientation:

"Each of our actions is aimed at meeting the needs of out clients."

We start by understanding the needs of each client and offer solutions that meet their individual needs;

Our customer support is proactive, helping to resolve any issues quickly and efficiently;

We strive to create long-term relationships by providing a high level of service and ensuring the ease of use of our products.

Stability:

"We take into account the long-term consequences of our decisions for business and society."

We strive to contribute to the development of the region's economy by supporting local and international initiatives;

For us, sustainability is a balance between economic efficiency and responsibility to society;

We are implementing eco-friendly and socially relevant practices that help create a sustainable future.

Teamwork:

"We value the contribution of each employee and create a culture based on support and collaboration."

We recognize the importance of teamwork, where each employee feels like a significant part of the team;

Training and sharing of experience within the company help us to develop and achieve success;

Supporting each other is not just a principle, but the foundation of Octobank's corporate culture.

Company principles.

Simplicity and accessibility:

We strive to simplify complex processes so that financial services are intuitive and convenient for all customers.

Honesty and openness:

We work within strict ethical standards, fulfilling our obligations to all stakeholders.

Speed and flexibility:

Octobank adapts quickly to changes in the market, offering relevant and effective solutions.

Effective cooperation:

We actively interact with clients, partners and colleagues in order to achieve outstanding results together.

Customer and partner support:

Each of our actions is aimed at creating value for customers and partners, helping them develop and succeed in the modern world.

Why it's important to us.

These values and principles are not just words — they are how we act on a daily basis. We are proud to work in a bank that combines professionalism, technology and humanity. Thanks to this, we grow, inspire each other and make the financial world more accessible.

III.   Employee responsibilities

Each of us is a face of Octobank.

Our employees are our main strength. We respect the rights and dignity of everyone, and we believe that diversity is part of our competitive advantage. Octobank JSC consistently maintains an atmosphere of respect, mutual trust, cooperation and open communication.

Working at Octobank is more than just completing tasks. Each of us is responsible for the reputation and success of the company. Our daily actions and decisions affect the trust of our customers, partners, and society. In this section, we have collected the key responsibilities of employees that help us all work together and efficiently.

Compliance with the company's values and standards.

Each employee is required to share and follow the values and principles of Octobank, which are described in this Code. This concerns:

Trust: Work transparently, honestly, and professionally. Never violate your obligations to clients or colleagues;

Innovation: Take the initiative, propose new ideas and help implement them in the bank's work;

Respect: Treat colleagues, clients, and partners with respect, regardless of their position, background, or views.

Responsibility for one's own actions.

Your decisions and behavior are a reflection of Octobank. Remember:

Comply with the law. You must know and comply with the rules and laws regarding your work;

Take responsibility for yourself. If you've made a mistake, admit it and come up with a plan to fix it;

Improve your skills. Continuous development and training make you stronger as a professional.

Customer orientation.

Clients are the center of our work, and each of us is responsible for their experience of interacting with the bank:

Act in the best interests of the client. Recommend only those products and services that meet their needs;

Respect confidentiality. Any customer information must be protected and used only for its intended purpose;

Be professional. Politeness and attentiveness are the basic elements of any communication with a client.

We comply with all applicable laws in the field of labor relations in the Republic of Uzbekistan. All hiring, selection, professional development, and career growth decisions are based solely on the merits, qualifications, skills, achievements, and potential of employees. We respect fundamental human rights and ensure that factors such as race, religion, gender, age, nationality, marital status or disability do not influence our decisions.

IV.  Client interaction

Clients are our main inspiration.
Understanding clients: we listen, analyze, and act.

Listen carefully. Understanding a client's needs begins with an active and thoughtful dialogue;

Study the details. Find out what is important to the client and suggest solutions that will really benefit;

Offer more. We don't just solve problems, but create value by offering innovation and convenience.

Honesty and transparency: we don't make empty promises.

Explain it clearly. Each product, service, or tariff should be clear to the client. Avoid complicated formulations and "small font" tricks;

Promise only what you can fulfill. If difficulties arise, be honest and offer solutions;

Follow the rules. All our interactions comply with the legislation and internal standards.

Confidentiality and security: the client must be calm.

Take care of your personal information. Never disclose client data to third parties without their consent;

Be vigilant. If you see suspicious activity, report it to the security service immediately.

Professionalism in every contact.

Be polite and considerate. Even in difficult situations, stay calm and respectful;

Solve problems. If the client is facing difficulties, offer a solution quickly and efficiently;

Do more. Think about what you can do to make the client leave not just satisfied, but inspired.

Feedback: Clients help us grow.

Listen up. Positive and negative reviews are equally important;

Learn. Analyze the reviews and use them to improve our products and services;

Give your gratitude. Show the clients that their opinion is appreciated.

V.  Interaction with colleagues

We are the team that moves Octobank forward.

At Octobank, each employee is an important element of a unified team. Our strength lies in our ability to work together, respect each other, and join forces to achieve common goals. The bank's success begins with how we interact with each other.

Respect for each other: the basis of our cooperation.

Respect the opinion of your colleagues. A variety of points of view makes us stronger. Even if you disagree, stay correct;

Be polite. A simple "thank you" or "please" makes communication more human;

Avoid conflicts. If there are disagreements, resolve them through constructive dialogue, not arguments.

Support and assistance: we are working for the overall result.

Share your knowledge. If you have any experience or information that can help your colleagues, please offer it;

Don't be afraid to ask. Ask for help if you need it, and be ready to support your colleagues in return;

Acknowledge achievements. Celebrate the successes of the team and individual employees — it motivates everyone.

Effective communication: the key to cooperation.

Speak to the point. Try to express your thoughts clearly and clearly, avoiding unnecessary information;

Be open to feedback. Take criticism as an opportunity to get better, not as a rebuke;

Use the appropriate channels. For work issues, choose corporate communication tools to maintain order in communication.

Creating a safe and comfortable working environment.

Follow the ethics. It is important to respect personal boundaries and avoid behavior that could be perceived as discrimination or harassment;

Maintain order. The workspace should be clean and organized;

Take care of your health. Respect the physical and emotional state of your colleagues, and follow safety rules.

Unacceptable behavior.

Octobank JSC does not allow actions or behavior that degrade dignity, create a threat or hostile atmosphere, as well as unreasonable obstacles to the performance of professional duties. We expect employees to treat others with respect and avoid situations that may be perceived as inappropriate.

In particular, Octobank JSC prohibits the following forms of behavior:

insults or rudeness;

comments or images of sexual or degrading content;

unwanted attentions;

obscene or offensive gestures and jokes;

intimidation or threats;

dangerous, rude, or violent actions or threats of their use.

If something is bothering you, you can always contact the HR Department or use the hotline to report violations. We guarantee confidentiality and no negative consequences for conscientious treatment.

VI.  Interaction with partners and competitors

Our partners and competitors are part of the Octobank success ecosystem.

Partnerships and fair competition are the foundation for Octobank's sustainable growth. We operate in a dynamic and competitive environment where trust and professionalism determine our place in the market. Each Octobank employee plays a key role in shaping these relationships.

We build partnerships on trust.

Transparency in relationships. Act honestly and openly, providing partners with accurate and complete information;

Respect for obligations. Fulfill agreements on time and with proper quality is the foundation of trust;

Proactive approach. Look for opportunities to improve cooperation with partners, and propose initiatives that will benefit both sides.

Fair competition: we act ethically.

Follow the rules. Respect competition law and never engage in anti-competitive agreements or manipulation;

Do not use questionable methods. Never resort to slander, misinformation, or unethical tactics to gain an advantage;

Analyze with respect. While studying the actions of competitors, focus on their strengths in order to develop your own.

Octobank JSC adheres to a strict policy of compliance with anti-corruption legislation and intolerance to any manifestations of bribery and corruption. We expect all our employees, partners, and competitors to demonstrate the same principles. None of the bank's representatives or third parties acting on our behalf has the right to offer, promise or provide funds or other valuables for personal gain, as well as in exchange for obtaining commercial advantages or maintaining business. Refusing bribes, even if it is associated with missed business opportunities, cannot have negative consequences for our employees.

We build our business on the principles of honesty and transparency, respecting the rights of our partners and competitors. Octobank JSC excludes any actions that may breach the rules of fair business conduct, including manipulation, concealment of information or abuse of trust. We strictly comply with competition law, avoiding any form of anti-competitive agreements such as price collusion or market sharing. In addition, the bank guarantees the responsible use of intellectual property, using only those materials that are obtained legally.

VII.  Conflicts of interest

What is a conflict of interest and why is it important?

A conflict of interest arises when an employee's personal interests (financial, family, or otherwise) may influence their professional decisions at Octobank. Such situations are not always obvious, but they can damage the bank's reputation, undermine customer trust, or hinder objective decision-making. Your honesty and transparency are key factors in preventing such risks.

1. How to recognize a conflict of interest:

   1. Financial interest: You or your family members have financial interests in a company that cooperates with Octobank;

   2. Personal relationships: You participate in decisions regarding the hiring, promotion, or work of people with whom you have a close relationship;

   3. Gifts and rewards: Receiving gifts or bonuses from a partner that may influence your decisions.

2. What to do in case of a conflict of interest:

1. Acknowledge the problem. Don't try to hide a potential conflict, even if it seems insignificant to you;

2. Inform the management. Contact your line manager, HR department, or compliance department to clarify the situation;

3. Avoid participating in the decision. If the conflict is obvious, refrain from making decisions related to this situation until you receive clarification from management.

3. How to prevent conflicts of interest:

   1. Be transparent. Regularly report any external interests that may overlap with your work at the bank;

   2. Follow the gift policy. If you receive a gift or reward from a client or partner, consult with management about whether this is acceptable;

   3. Plan your employment. Before starting any side activity, make sure that it does not contradict the Octobank policy.

Octobank JSC adheres to a strict policy of preventing and resolving conflicts of interest, guided by high standards of ethics and transparency. We expect every employee to act in good faith, excluding any situations that may put personal interests above the interests of the bank. Disclosure of potential or actual conflicts of interest is a mandatory requirement that helps maintain the trust of customers, partners, and shareholders.

VIII.      Handling information

Information is a key asset of Octobank.

Information is the basis of our work, and proper handling of it plays a key role in ensuring the success of the bank. We are committed to protecting the data of our customers, partners, and companies in order to maintain a high level of trust.

Types of information:

Customer information: Personal and financial data of clients;

Corporate data: Internal documents, strategies and business plans;

Confidential information of the partners: Any information provided to the Bank as part of the partnership.

Working with information:

Respect confidentiality and access only when necessary;

Do not copy documents unnecessarily and do not create duplicates;

Protect your electronic data with corporate security systems.

Electronic security:

Use only corporate devices and secure communication channels;

Update passwords regularly and use two-factor authentication;

Report suspicious activity to the IT department.

Communication:

Never discuss confidential information outside of a work context;

Coordinate any publications related to the bank's activities with the PR department.

Octobank JSC pays special attention to the protection of confidential information, personal data and ensuring the accuracy of internal and external communication. Each employee is required to maintain confidentiality in their professional activities, excluding unauthorized use, dissemination or disclosure of information related to the activities of the bank, its customers, partners and colleagues. Only authorized persons have the right to interact with external parties, including the media, analysts and investors, and any requests regarding financial or business information are forwarded to the relevant departments. We recommend that employees exercise caution when using social media, avoiding mentioning business partners or colleagues without their permission.

Octobank JSC strictly adheres to personal data protection standards and applicable laws in the field of information security. Access to personal information is provided exclusively to authorized employees and only within the scope of their professional duties. We take measures to prevent data loss, theft, or unauthorized access, and require the use of confidentiality agreements when exchanging information with external partners. These measures guarantee reliable information protection, help maintain the trust of our customers and partners, and ensure that the bank meets high standards of professional ethics.

IX. Risk accounting and responsibility management

Risks are a part of any activity, and our task is to minimize them.

Octobank implements advanced risk management practices to ensure security and stability. Each employee is required to participate in identifying, analyzing, and eliminating potential threats.

1. Types of risks:

   1. Financial risks: Losses due to market fluctuations or non-compliance of products with customer needs;

   2. Operational risks: Failures in IT systems or errors in processes;

   3. Reputational risks: Negative reaction from customers or partners;

   4. Corporate risks: Conflicts of interest, inefficient asset and project management, and weak corporate culture;

   5. Legal risks: Non-compliance with legal requirements.

2. How to manage risks:

   1. Follow internal policies and instructions;

   2. Report potential threats or violations;

   3. Take part in the trainings and get acquainted with the recommendations on risk prevention.

X.  Code compliance procedures

How to apply the Code in practice.

This Code works only when employees clearly understand its requirements and act in accordance with them. We have created tools and processes that help us follow its provisions.

1. Training.

   1. Each employee is familiarized with the Code on the first work day;

   2. Regular trainings are conducted to improve awareness and understanding of ethical standards.

2. Reporting violations.

   1. Report the violation through your supervisor, HR department, or an anonymous channel;

   2. Your message will be reviewed with confidentiality and without negative consequences for you.

3. Review of violations.

   1. Each message is analyzed by competent specialists;

   2. Decisions are made objectively, taking into account all factors.

XI. Final provisions

This Code is not just a set of rules, but a tool that helps us grow and maintain a high standard of work. By following it, we strengthen the bank's reputation and the trust of our customers and colleagues.

Apply the provisions of the Code daily;

Support initiatives aimed at developing corporate culture;

Share suggestions and comments to improve the document.

Octobank thanks you for your commitment to high standards of ethics and professionalism!