Environmental management approach (Раздел 1)

As Kazakhstan’s leading energy company Samrurk-Energy JSC places environmental protection at the core of its corporate responsibility. We are committed to aligning our operations with national environmental legislation, the ISO 14001 international standard, and recognised best practices in sustainable development, with the overarching goal of minimising our environmental footprint.

Our environmental management activities are focused on the following priority areas:

● preventing and reducing environmental impact, including improving air quality, responsible waste management, and sustainable water resource use;

● contributing to climate change mitigation efforts;

● conserving and efficiently utilising energy resources;

● implementing effective environmental monitoring and impact assessments;

● preserving natural landscapes and biodiversity.

To ensure systematic and transparent environmental governance, the Company has adopted a number of key internal documents:

● Corporate Management System Policy;

● Corporate Environmental Protection Management Standard for the Samruk-Energy Group of Companies;

● Emergency Environmental Response and Management Guidelines;

● Environmental Safety Programme of Samruk-Energy Group of Companies.

Environmental protection is fully embedded in the Company’s corporate governance structure. The senior executive team is accountable for the implementation of the Company’s environmental commitments, targets, and performance indicators. The Board of Directors is responsible for approving the environmental strategy and associated policies. Day-to-day oversight of environmental initiatives is carried out by the Department for Energy Efficiency, Innovation Development and Environmental Safety of Samruk-Energy JSC. Within the Group’s subsidiaries, dedicated environmental units are in place to implement corporate policies and strategies, and to ensure that contractors and business partners comply with the Company’s environmental standards.

Environmental safety programme of Samruk-Energy group of companies

To support the achievement of its strategic objectives through to 2033, Samruk-Energy’s Board of Directors approved the Group’s Environmental Safety Programme in 2024. This Programme serves as the core planning tool for the Group’s environmental activities, setting out clear goals and measures aimed at achieving environmental sustainability and enhancing corporate social responsibility.

The Programme is long-term and target-oriented, providing a framework for integrating planned initiatives into the Group’s long-term, medium-term, and operational planning documents. The implementation period spans from 2024 to 2033.

Precautionary principles

When planning and executing projects, Samruk-Energy JSC applies a precautionary approach, placing strong emphasis on the assessment of potential environmental impacts and associated risks. In line with the Company’s internal standards, each project undergoes a rigorous risk assessment process, including the analysis of environmental impact and potential long-term consequences. These assessments are carried out with the involvement of qualified experts, in accordance with internal regulations governing risk management for investment projects.

The Company implements both routine and capital-intensive environmental measures aimed at mitigating environmental risks. Continuous monitoring of effectiveness is conducted, along with ongoing improvement of tools for environmental risk assessment and management.

To strengthen accountability and employee motivation in reducing environmental risks, Samruk-Energy JSC has introduced environmental Key Performance Indicators (KPIs), enabling more effective management of environmental safety and the achievement of strategic targets.

Monitoring and transparency

To maintain a high standard of environmental accountability, the Company regularly discloses detailed reports on its environmental activities. Quarterly reports are submitted to the Management Board and the dedicated Committee for Safety, Occupational Health, and Environmental Protection. An annual report, the “Environmental Protection Performance Report”, is also submitted to the Board of Directors of Samruk-Energy JSC.

In 2024, the Samruk-Energy Group successfully passed an external surveillance audit confirming the compliance of its corporate management system with the requirements of international standards ISO 9001, ISO 14001, ISO 45001, ISO 50001, and ISO 37001.

In the same year, the Group successfully implemented 94% of its planned environmental protection activities, which covered air, water and land protection, as well as the conservation of flora, fauna, and biodiversity.

A key achievement was the implementation of an automated emissions monitoring system at ESDPP-2 JSC and APP JSC (CHP-1 and the Western Thermal Complex), as well as at Bogatyr Komir LLP (for the discharge of drainage and wastewater into the Akbidaik storage lake), with data transmitted every 20 minutes in real time to the National Database on the State of the Environment and Natural Resources of the Republic of Kazakhstan (NDSENR RK).

As part of the implementation of the 2024 Action Plan for Environmental Management within the Samruk-Energy Group of Companies, a number of cultural, educational, and environmental activities were carried out among employees of subsidiaries to mark World Environment Day, celebrated annually on June 5. Key initiatives included:

● Employees of SDPP-2 JSC organised an environmental event — plogging — aimed at preserving the environment and fostering a responsible attitude towards nature;

● Environmental specialists from the production departments and the head office of APP JSC conducted the “#Together – Clean Mountains” campaign in the Butakovka Gorge, which resulted in the collection of 18 bags (160 litres each) of waste;

● At ESDPP-1 LLP, a team-building event entitled “Green Unity” was held for power plant staff to promote environmental awareness and responsibility for nature conservation;

● At Bogatyr Komir LLP, a video and children’s drawing contest was held on the theme of “World Environment Day”;

● A range of thematic events and awareness campaigns were conducted at the enterprises of AZhC JSC, Shardarinsk HPP JSC, Moynak HPP JSC, Ust-Kamenogorsk HPP LLP, Shulbinsk HPP LLP, and First Wind Power Plant LLP, aimed at promoting environmentally conscious behavior and fostering aimed at promoting environmentally responsible behavior and fostering a culture of environmental awareness among employees.

Participation of Samruk-Energy employees in the citywide cleanup campaign

As part of the national environmental campaign Taza Kazakhstan, held in Astana in April 2024, the team of Samruk-Energy JSC actively participated in a citywide cleanup initiative. The primary objective of the event was to raise environmental awareness and promote the importance of environmental protection.

Company employees cleaned up the Energy Workers’ Alley, which had been planted by Samruk-Energy JSC to mark the 15th anniversary of the Samruk-Kazyna Fund. This event served as a meaningful contribution to improving the city’s environmental condition and once again underscored the Company’s commitment to sustainable development and environmental stewardship.

We maintain an ongoing dialogue with stakeholders on environmental issues. This helps us track the effectiveness of decisions and initiatives implemented, as well as identify and reassess environmental risks.

In 2024, the Company conducted public hearings on four projects, all of which received positive expert opinions.

In line with the principles of transparency and accountability, Samruk-Energy JSC organizes meetings, press conferences, and roundtable discussions to address environmental topics with representatives of the public, media, volunteer groups, and non-profit organizations. These initiatives involve the Company’s senior executives as well as the leadership of its subsidiaries.

Environmental protection expenditures

Under the 2024 Environmental Management Action Plan for the Samruk-Energy Group of Companies, as well as the Environmental Action Plans of its subsidiaries coordinated with the national environmental authority, 94% of the planned environmental protection measures were completed. A total of KZT 14.416 billion was utilized out of the allocated KZT 16.192 billion. Key measures aimed at reducing environmental impact and improving ecological performance included:

● Equipment modernization – overhaul of boiler burners and reconstruction of electrostatic precipitators to reduce dust emissions;

● Industrial process optimization – repair of the closed-loop production water system (dredge system), and maintenance of dust and gas cleaning units;

● Systemic pollution control measures – introduction of automated pollutant emissions monitoring systems and dust suppression measures at ash disposal sites;

● Sustainable waste management – waste disposal and the placement of overburden materials in temporary internal dumps, which will reduce the volume of external dumps by 69.511 million tons;

● Water conservation and wastewater treatment – maintenance of systems for the collection and treatment of stormwater and meltwater;

● Landscaping and greening – expansion of green spaces across production sites;

● Improved equipment reliability – repair of components and optimization of equipment operation modes in accordance with technical specifications.

Samruk-Energy JSC’s investments in environmental protection initiatives, KZT billion

We also paid over KZT 9 billion in regulatory emission charges (environmental tax).

Environmental benchmarking

Environmental benchmarking is a key tool for assessing and managing the environmental performance of Samruk-Energy JSC by comparing the company’s indicators with those of leading industry players. This approach supports the adoption of best international practices in environmental management and sustainable development.

The current analysis is based on publicly available data for the years 2021–2023. Following the publication of Samruk-Energy’s environmental performance indicators for 2024, the benchmarking analysis will be updated and the results will be made available on the Company’s official website.

The following indicators have been selected for benchmarking:

● freshwater use for industrial and domestic purposes;

● direct (Scope 1) and indirect (Scope 2) greenhouse gas emissions.

To identify environmental performance trends, an analysis was conducted using data from major energy companies in Kazakhstan and globally, including:

● Enel

● ERG

● RusHydro PJSC

Operating indicators 

Greenhouse gas emissions (Scope 1,2)

* The companies did not disclose Scope 2 data.
** Enel and RusHydro PJSC primarily generate electricity from renewable energy sources, resulting in minimal greenhouse gas emissions.
*** In addition to power generation assets, ERG also operates mining and processing facilities; Scope 1 emissions include all types of operations.

Freshwater withdrawal, mln m³

Intensity indicators 

The companies differ in terms of installed capacity and electricity generation output; therefore, the comparative analysis of greenhouse gas emission intensity and freshwater withdrawal intensity is indicative in nature.

According to the results, Samruk-Energy JSC demonstrates the following trends:

● Greenhouse gas emission intensity in 2023 remained at the same level as in 2022, with no significant changes, similar to ERG and RusHydro PJSC. Meanwhile, Enel has shown a consistent annual decrease in this indicator: by 3.6% in 2022 and 25.9% in 2023;

● The average freshwater withdrawal intensity for 2021–2023 was 6.22 m³ per thousand kWh, which is:

– 20 times higher than Enel (0.31 m³ per thousand kWh);

– 26.4% higher than RusHydro PJSC (4.92 m³ per thousand kWh);

– 16.6 times lower than ERG (103 m³ per thousand kWh).

Based on the results of the analysis, Samruk-Energy JSC reaffirms its commitment to sustainable development. The Company will continue its systematic efforts to reduce its carbon footprint, adopt modern technologies and solutions aimed at reducing greenhouse gas emissions. A key priority remains the modernization of core and auxiliary equipment, which will improve resource efficiency and reduce water consumption for technological needs across our subsidiaries.

Air pollutant emissions (Раздел 2)

We are committed to reducing atmospheric emissions and are implementing measures aimed at minimizing pollutants. Particular attention is given to reducing air pollution at facilities such as ESDPP-1 LLP, SDPP-2 JSC, APP JSC, and Bogatyr Komir LLP, which operate on fossil fuels and have a significant impact on emission levels.

The Company ensures compliance with maximum permissible emission standards, with mandatory reporting to supervisory authorities. Regular air quality monitoring is carried out under the Industrial Environmental Monitoring Program to ensure compliance with environmental standards.

Air emissions are strictly regulated by the environmental legislation of the Republic of Kazakhstan. Emissions of pollutants occur in volumes determined by production processes and in accordance with project documentation and standards approved by authorized government agencies, as stipulated in specific environmental permits.

To minimize air emissions, we regularly assess the performance of equipment and, when necessary, take appropriate measures and implement new technological solutions. At ESDPP-1 LLP, SDPP-2 JSC, APP JSC, and Bogatyr Komir LLP, continuous monitoring is carried out as part of production control over technical and technological parameters that affect emissions, discharges, and waste.

The main sources of air pollutant emissions within the Company include boiler units, oil facilities, fuel oil systems, ash disposal sites, and other pollutant emission sources located at power plants and boiler houses (ESDPP-1 LLP, SDPP-2 JSC, APP JSC, Bogatyr Komir LLP). The primary pollutants generated by these enterprises as a result of fuel combustion and coal mining include nitrogen oxides, sulfur dioxide, particulate matter, carbon monoxide, volatile organic compounds, and other gaseous substance

In 2024, atmospheric pollutant emissions across the Samruk-Energy JSC Group of Companies did not exceed the established maximum permissible limits and amounted to 345,373 tons, compared to the approved limit of 420,010 tons.

Trend in specific air pollutant emissions per unit of output, g/kWh

According to 2024 data, specific air pollutant emissions decreased by 13.8% compared to the 2023 level.

This positive trend is attributed to:

● a reduction in unit consumption of conventional fuel (UCCF) at SDPP-2 JSC from 381.3 g/kWh to 374.7 g/kWh;

● a 2.6-fold increase in electricity generation from renewable energy sources, from 2.849 bn. kWh to 7.460 bn. kWh, resulting from the contribution of assets of Ust-Kamenogorsk HPP LLP and Shulbinsk HPP LLP to the Company’s charter capital.

Air pollutant emissions, tons 

Plans for 2025 and the medium-term outlook

1. 1)Study of advanced flue gas cleaning technologies at EGRES-1 LLP, SDPP-2 JSC, and APP JSC, with a focus on the removal of ash, dust, nitrogen oxides (NOx), and sulfur oxides (SOx).
2. 2)Determination of final costs for the implementation of Best Available Techniques (BAT) following a comprehensive analysis of available technological solutions.
3. 3)Construction of a return pumping station for clarified water as part of the design and estimate documentation (Stage «P») for the project «Expansion and Modernization of Ekibastuz SDPP-2 with Installation of Power Units No. 3 and 4».

Responsible water use (Раздел 3)

Samruk-Energy JSC is actively working to identify and prevent potential impacts of its operations on water resources. The Company exercises strict control over the abstraction and use of water at its production facilities to ensure compliance with environmental regulations.

Although our subsidiaries — including ESDPP-1 LLP, SDPP-2 JSC, APP JSC, Bogatyr Komir LLP, Moynak HPP JSC, Shardara HPP JSC, Shulbinsk HPP LLP, Ust-Kamenogorsk HPP LLP, and AZhC JSC — do not operate in water-stressed regions, we place particular emphasis on sustainable water management. Our approach includes assessing water-related risks, implementing strategies to minimize freshwater consumption, and ensuring efficient treatment of wastewater to guarantee its safe return to the natural environment.

Water resource management within the Company complies with the Water Code of the Republic of Kazakhstan and all applicable permits, ensuring the proper protection of water resources.

Key principles of our water resource management approach include:

● Responsible water use and maintenance of a sustainable water balance;

● Identification and accounting of all water intake points, including those involving intermediaries;

● Continuous improvement of strategies to optimize water use;

● Minimization of potable water use for industrial purposes;

● Annual inspection of water intake and discharge metering devices to verify their presence, operability, and timely calibration and sealing by regulatory authorities;

● Avoidance of operations in water-scarce regions, underscoring our environmental responsibility.

The Company’s main water sources include:

– Bestyubinsk Reservoir (Moynak HPP),

– Shardara Reservoir (Shardara HPP),

– Shulbinsk Reservoir (Shulbinsk HPP),

– Ust-Kamenogorsk Reservoir (Ust-Kamenogorsk HPP),

– Satpayev Canal (ESDPP-1 LLP, SDPP-2 JSC),

– Shiderty Canal (SDPP-2 JSC),

– Big Almaty Lake and Bolshaya Almatinka River basin (Hydropower Cascade),

– Kapshagay Reservoir (Kapshagay HPP).

In 2024, the volume of water withdrawn by Samruk-Energy’s subsidiaries for production and household-drinking needs amounted to 80,188,759 megaliters. Of this volume, 99% was used for electricity generation, specifically for the steam-water cycle at thermal power plants (SDPPs and CHPs) and for driving hydro turbines at hydropower plants (HPPs).

Trends in freshwater use for electricity generation, megaliters

The total water consumption in 2024 amounted to 145,368 megaliters.

As part of our water conservation strategy, we actively utilized closed-loop water supply systems, including cooling reservoirs and once-through ash removal systems at the Ekibastuz thermal power plants. At the Almaty CHP plants, recirculating cooling systems with cooling towers were used, along with water from ash disposal sites, which contributed to improved water use efficiency and environmental protection.

Volume of reused and recirculated water, megaliters

Wastewater management

We adhere to high standards for wastewater handling to minimize its negative impact on aquatic ecosystems. Samruk-Energy JSC is committed to staying within established discharge limits and complying with regulatory requirements, which helps protect biodiversity and natural habitats.

In 2023, the Company discharged a total of 80,043,391 megaliters of wastewater.

The Group’s production and operational activities generate two main categories of wastewater:

● More than 99% of the total volume consists of wastewater from ash hydraulic removal systems, water used for cooling technical units at CHPs, and water used in electricity generation at HPPs.

● Less than 1% comprises domestic wastewater from administrative buildings, canteens, and service facilities.

Wastewater is treated using modern physical-chemical and biological technologies. Discharge limits are set based on the methodology approved by the Ministry of Ecology, Geology, and Natural Resources of the Republic of Kazakhstan in March 2021. The quality of treated wastewater is monitored by a certified laboratory to ensure compliance with environmental standards.

Surface water quality is assessed using both general and specific indicators. General indicators include mineralization, pH, hardness, and others. Specific indicators include chemical and biochemical oxygen demand, concentrations of petroleum products, ammonium salts, nitrates, phosphates, and other pollutants.

In 2024, no cases of exceeding the maximum allowable concentrations of pollutants in domestic wastewater discharges were recorded.

Waste management (Раздел 4)

Responsible waste management is a key component of Samruk-Energy JSC’s environmental strategy. We are committed to efficient resource use and minimizing the environmental impact of waste across all stages of our operations — from electricity generation to asset operation.

The Company conducts its waste management activities in full compliance with the legislation of the Republic of Kazakhstan. This includes tracking the quantities of waste generated, treated, recycled, disposed of, transferred to or received from third parties, and stored. Data are compiled quarterly and annually.

Waste management is implemented in strict accordance with established standards and procedures, including:

● The Corporate Standard on Environmental Management;

● Waste Management Programs;

● The Waste Management Action Plan.

In line with the classification criteria established by the authorized environmental agency, all waste is categorized as either hazardous or non-hazardous.

Hazardous waste requires specialized disposal methods, while non-hazardous waste is subject to separate collection and recycling. Designated collection points and areas are equipped with labeled containers and metal bins to facilitate proper segregation. Standards are also in place for identifying waste that may not be landfilled and materials that are suitable for processing into secondary raw materials.

Given the operational specifics of ESDPP-1 LLP, SDPP-2 JSC, and APP JSC, the majority of the Company’s total waste volume consists of high-tonnage non-hazardous waste — specifically, ash and slag waste and overburden from coal mining at Bogatyr Komir LLP.

Bogatyr Komir LLP is actively working to reduce its environmental footprint by minimizing the volume of overburden deposited in external dumps. As part of this initiative, the Company is developing plans to repurpose exhausted areas of the Northern and Bogatyr coal pits for use as internal dumps. In addition, to prevent oxidation and spontaneous combustion of coal-containing rock, inert materials are used for isolation, and surface layers are compacted.

Ash and slag waste generated by ESDPP-1 LLP, SDPP-2 JSC, and APP JSC is stored at ash disposal sites. Dust suppression measures are in place — at the Ekibastuz SDPPs, this includes submerging waste under the waterline, while APP JSC employs a unique combined technology involving soil covering and planting of perennial grasses and shrubs. We conduct annual land reclamation of the used portions of ash disposal sites. In addition to disposal, ash and slag are also recycled for use in road construction and building material production.

The expansion of HPPs and renewable energy facilities within Samruk-Energy JSC contributes to reducing the volume of ash and slag waste per unit of electricity produced.

Hazardous waste includes industrial and operational waste such as batteries, used mercury-containing lamps, waste oils and technical fluids, fuels and lubricants, dyes, resins, varnishes, and paints.

Between 2020 and 2024, 285 kilograms of used batteries were collected and sent for recycling.

During operations, ESDPP-1 LLP, SDPP-2 JSC, APP JSC, and Bogatyr Komir LLP do not generate radioactive waste. Quarterly radiation monitoring is carried out, and results consistently show radiation levels remain within the safe standard of 2.5 µSv/h, confirming the effectiveness of existing radiation safety measures.

Samruk-Energy JSC also monitors the performance of contractors involved in waste management. During procurement procedures, bidders are required to present valid licenses for handling each type of waste, as well as evidence of sufficient infrastructure and equipment. Contractors sign agreements obligating them to comply with the environmental laws of the Republic of Kazakhstan.

Samruk-Energy JSC maintains ongoing dialogue with stakeholders. Any individual can express concerns related to the environmental aspects of our operations through designated feedback channels. All submissions are officially logged and reviewed.

Total waste volume generated by Samruk-Energy JSC enterprises, tons

Biodiversity conservation (Раздел 5)

Samruk-Energy JSC fully recognizes its responsibility for the conservation of biodiversity. We are committed not only to achieving “no net loss”, but also striving for a “net positive impact” on biodiversity across all our operations. This applies to the construction of new facilities, modernization and operation of existing assets, as well as their decommissioning.

Key areas of focus for preserving and protecting biodiversity include:

• ●Deployment of advanced technologies that reduce environmental impact during production.
• ●Development and implementation of biodiversity protection and conservation programs in areas adjacent to production sites.
• ●Regular environmental monitoring to identify and address ecosystem threats in a timely manner.

In accordance with the environmental legislation of the Republic of Kazakhstan, any expansion or modernization of production activities is preceded by an assessment of potential impacts on the ecological system and the biodiversity of the region where our facilities are located. To ensure public participation in decision-making, public hearings are held with open access to all project documentation.

Across all aspects of our operations—from power generation to decommissioning—we actively work to protect and enhance the condition of natural ecosystems.

This work includes wildlife conservation projects, collaboration with research institutions and scientific organizations, as well as engagement with government authorities. A notable example of cooperation with international environmental organizations is the project implemented by Moynak HPP JSC in partnership with UNDP Kazakhstan, aimed at preserving the relict ash forest along the Charyn River.

In 2024, the activities of our subsidiaries did not have any significant direct or indirect impact on vulnerable ecosystems or biodiversity.

In 2024, KZT 224,100 was invested in landscaping and greening of the sanitary protection zones of the Company’s subsidiaries, which represents a 95.4% increase compared to the previous year.

Investments in biodiversity conservation, million KZT

Biodiversity conservation initiatives:

• ●To minimize fish mortality, hydro turbines at our hydropower plants are equipped with fish protection devices. Additionally, as a preventive measure, searchlights are used near the water intake in front of turbine pipelines during nighttime hours to deter fish from approaching.
• ●To reduce bird fatalities caused by using overhead power line towers as perching sites, AZhC JSC is implementing projects to retrofit poles with insulated wires and install special bird deterrent devices to prevent birds from landing on crossarms.
• ●At the pre-design and design stages of wind power plants (WPPs), measures are taken to reduce their environmental impact. In particular, to mitigate light pollution that can disrupt the natural biorhythms of living organisms and to preserve and restore biodiversity, lighting at WPPs is kept to a minimum, limited to mandatory obstruction lights only.
• ●Greening of industrial areas and expansion of green space coverage.
• ●As part of the industrial environmental monitoring program, regular laboratory testing is planned to monitor and assess the environmental impact of the Company’s operations.
• ●Reclamation of decommissioned ash disposal sites is being designed. These efforts aim to restore and convert the sites into environmentally safe and functional areas.

Restoration of Fish Populations in the Irtysh River

The Ust-Kamenogorsk and Shulbinsk hydropower plants continue to contribute to maintaining the region’s ecological balance by regularly implementing fish stocking programs. In 2024, as part of an environmental initiative, 130,111 juvenile carp were released into the Irtysh River. The release location was carefully selected in coordination with a scientific organization, which identified the optimal site — the village of Azovoye, located along the Irtysh River. This area was chosen due to its favorable natural conditions for the survival and reproduction of juvenile fish, helping to strengthen the population of this species.

Such initiatives have a positive impact on maintaining the fish population in the reservoir and contribute to preserving the region’s ecosystem as a whole.

We place particular emphasis on the development and implementation of measures aimed at minimizing the environmental impact of our operations. This includes not only restoring the ecological value of reclaimed land but also supporting biodiversity and protecting unique ecosystems.

In accordance with the Environmental Code, we are legally obligated to decommission ash disposal sites, which are designated areas for the storage of operational waste.

In 2024, the estimated decommissioning fund for ash disposal sites amounted to KZT 3,739.3 million, representing an 18.96% increase compared to the previous year. This growth is primarily due to higher costs of reclamation works and materials.

Carrying amount of the ash dump decommissioning reserve, million KZT

In the regions where it operates, Samruk-Energy is committed to active and inclusive cooperation with local communities, regional authorities, public organizations, and other stakeholders from the early stages of facility decommissioning. The Company employs a variety of engagement formats, including thematic conferences, one-on-one meetings, press briefings, phone consultations, public hearings, as well as perception surveys and stakeholder research.