See information on compliance and business ethics on the Company’s website.

MTS PJSC Code of Business Conduct and Ethics

The MTS Group Code of Business Conduct and Ethics contains the key principles, the set of standards and requirements adopted in the Company to promote the fair and ethical business practices of the MTS Group and prevention of abuse. The Code provisions were updated in 2024. In 2024, the updated electronic training “Code of Business Conduct and Compliance” was completed by more than 96%. of MTS PJSC employees hired in 2024.

MTS PJSC Contractor’s Code of Business Conduct

In accordance with the best global practices, the Company approved the MTS PJSC Contractor’s Code of Business Conduct, which contains basic requirements and ethical norms, the compliance with which is expected from the MTS contractors. The Code provisions cover all MTS contractors, and also any third parties employed by the contractor to act on behalf of and/or for the MTS Group. The mandatory review of the Code and acceptance of its obligations are an integral part of the contractual relations with the Company, and electronic training is integrated into the procurement process (https://education.mts.ru) and is conducted in accordance with the risk-oriented approach to working with the counterparties as specified in the company. Taking into account the mass training of counterparties in the previous years when electronic format of training was launched, the number of the trainees dropped in 2024.

Unified compliance system that supports the ESG-strategy

Since 2016, the Company has been actively developing the Unified Compliance System (UCS), relying on the norms of applicable laws, recommendations of the regulatory bodies, specific nature of the industry and best practices in this sphere.

The Company’s compliance programs that support the ESG-strategy make it possible to develop the MTS ecosystem on the basis of the business ethics principles, strictly comply with the requirements of the regulators, contribute to the sustainability of the society, observing the balance of stakeholders’ interests.

MTS makes a significant contribution to the processes of digitization and improvement in transparency of the information flows. Therefore, it is especially important for the Company at all levels, in all businesses and in all territories of presence to build an effective system of compliance risk management. UCS for the entire digital holding of MTS relies on the general principles of sustainability and ethical conduct, forms the foundation for its responsible management (G-part of the ESG-strategy).

Key areas of the MTS Unified Compliance System

Functional subdivisions, each implementing its compliance program and risk mitigation system are assigned to each area of compliance. Coordination of the UCS introduction and operation is assigned to the Department of Business Ethics and Compliance at MTS PJSC.

Within the annual (on a rotation basis) supervision over the implementation of the compliance program in subsidiaries of MTS PJSC aimed at uniform introduction of the compliance program and application of compliance controls in the MTS Group, in 2024, seven subsidiaries were inspected. Also, an annual self-assessment of the operating efficiency of the corporate anti-corruption compliance program was made on the basis of more than 40 specially developed metrics. The procedure was aimed at ensuring program resilience and at creating conditions for its continuous development.

In 2024, MTS successfully confirmed its compliance with the following standards:

• ISO 37001:2016 “Anti-bribery management system”.
• ISO 37301:2021 “Compliance management system”.

Great attention was paid to the events aimed at improving the level of employees’ compliance culture. The corporate portal of the UCS blog regularly posted publications on the most significant events of the program.

Day of Ethics and Compliance

In 2024, the Day of Ethics was held under the slogan “Ethics begins with each of us”. A message was published from the Vice President for Business Ethics and Compliance on the role of every employee in building the compliance culture. Also, interactive events were held: a quiz game “Compliance Cup” among the MTS Group employees, creative competitions, video messages-lifehacks of employees and managers, communication on the role of everyone in creating an ethical work environment, and other events prepared by the supervisors of the compliance programs in the MTS Unified Compliance System.

Results of investigating MTS Group compliance culture in 2024

Unified Hot Line

Information on the failure to comply with the business ethics codes and compliance by the MTS employees may be sent to the Unified Hot Line (UHL).

The Company ensures independent and comprehensive review of all reports. The investigations on all reports to the UHL are made in accordance with the local regulation that defines the procedure for reviewing such reports.

UHL receives proposals to improve the anti-corruption procedures and other internal control procedures.

A person who provided relevant information is protected from any forms of pressure (including dismissal, retaliation or any forms of discrimination). MTS PJSC supports the policy against retaliation and prohibits any forms of adverse impact regarding the report authors. In addition, the Company has developed and uses compliance KPIs and compliance triggers, which support the commitment of all employees to the norms of business ethics and compliance.

Releases on the UHL operation are published on a quarterly basis on the MTS corporate information portal to brief the MTS Group employees on the results of its work.

In April 2024, the UHL management and administration process was transferred to the Department of Business Ethics and Compliance.

All situations of the conflict of interest, failure to comply with the provisions of the Code of Business Conduct and Ethics, risks of failure to comply with the anti-corruption laws are settled in accordance with the Company-approved Code of Business Conduct and Ethics, Policies on Management of the Conflict of Interest and Compliance with Anti-Corruption Laws with participation by the Department of Business Ethics and Compliance.

Unified Hot Line is a critical aspect in preventing failures to comply with the Code of Business Conduct and Ethics and other local regulations of the Company. Additionally, the Unified Hot Line is one of the bridges in the communication of the employees, which stimulates development of a trusting and comfortable internal atmosphere. The culture of open dialog in MTS is an important element in the system of values and principles of ethical business.

Vice President for Business Ethics and Compliance

Number of reports received by MTS Group UHL

MTS Group Companies	2022	Share, %	2023	Share, %	2024	Share, %
RTC JSC	462	51%.	439	48%.	389	42%.
MTS PJSC	307	34%.	324	35%.	373	40%.
MGTS PJSC	34	4%.	43	5%.	22	2%.
MTS Digital LLC	31	3%.	36	4%.	32	3%.
MTS-Bank PJSC	17	2%.	18	2%.	39	4%.
MTS Armenia CJSC	15	2%.	11	1%.	0	0%.
Mobile TeleSystems JLLC	14	2%.	8	1%.	26	3%.
Other	27	3%.	39	4%.	51	5%.
Total	907	100%.	918	100%.	932	100%.

Discipline Committee

MTS operates the MTS Discipline Committee constantly, which considers cases of failures to comply with the compliance requirements and other substantial violations, ensuring compliance with the principles of legality, justice, uniformity and substantiation when making the decisions to apply disciplinary sanctions to employees, and develops sustainable corrective actions.

Employees who allowed violations of internal Company regulations were briefed on the elimination of violations and prevention of such situations in the future in accordance with the laws.

Anti-corruption compliance

The anti-corruption compliance program in MTS PJSC specifies measures aimed at managing regulatory risks, protecting the Company from any manifestations of corruption (both inside the Company and the attempts to involve the Company in corruption activities from outside), improving the corporate culture, introducing and developing the best corporate governance practices in the Company, as well as the standards of responsible and ethical conduct.

Results of investigating MTS Group compliance culture in 2024

The annual investigation of the compliance culture was made using an updated method, the overall level of the compliance culture was 85.2 points. The highest level was demonstrated by the parameter “Culture of Compliance with Norms and Rules in the Company” – 94.2 points.

Projects and initiatives within development of anti-corruption compliance program and compliance culture strengthening in 2024

In 2024, several initiatives were implemented to improve the compliance culture:

• All local regulations that contained compliance controls were revised and updated with account for the detected risks. The Code of Business Conduct and Ethics and Policy “Compliance with Anti-Corruption Laws” were unified and transferred to ecosystem format for uniform use in the entire MTS Group.
• The methodology base for the MTS Group was updated to solve the operational problems in accordance with the best anti-corruption practices.
• The successful use was continued of the existing and development of new tools for automation and digitization of the compliance controls to ensure transparency, cut the time and costs to perform the control procedures, and to improve the quality of ecosystem business processes as a whole.
• The chat bot was updated with respect to the scripts it uses.
• Within the digitization of the compliance function, the unification of the existing program and procedural solutions continued for management of risks on the basis of a single technological platform. During 2024, the incident management system development was supported – the program complex for effective management of the risks of corruption and corporate fraud in the group of companies. The system united several information systems, including the UHL base, developed on the same technological basis, using automation and new technology. The development of the above system helps to maintain unified standards for incident investigation, evidence recording, development of mitigating measures in the entire MTS group of companies.
• The process of anti-corruption inspection of counterparties using Big Data was updated to detect and respond on a timely basis to the risks in the transactions with counterparties.
• The process of anti-corruption covenants analysis in contracts was partially automated.
• An automated service was introduced to approve and record the signs of business hospitality.
• Most developed IT-solutions on compliance have the potential to be scaled to the MTS Group, which makes it possible to spread the useful effects from automation to the entire MTS ecosystem.
• The regional development directors and branch directors demonstrated their “ethical leadership” to the employees, explaining the principles of ethics, compliance controls etc. In 2024, more than 300 “tone in the middle” events were held.
• More than 60 managers saw the video lesson on the subject “Ethical Conflict Management” under the Manager’s Skill Factor program for development of the managers.
• A mandatory training program was developed for the new employees “MTS Security and Protection”, which includes “Code of Business Conduct and Compliance” courses. More than 96%. employees of MTS PJSC employed in 2024 completed the course.
• Interaction with the external partners was strengthened: participation in conferences, membership in associations and unions, partnership with universities (Higher School of Economics, Moscow State Law Academy) and organizations (MDTO)
• Communications are of an interactive nature: memos, quiz, game, use of associations etc.

Inside compliance

MTS PJSC as a company whose financial instruments trade on the Moscow Stock Exchange pays great attention to maintaining an efficient system to prevent illegal use of insider information and market manipulation.

The system for preventing breaches of legislation on use of insider information that is built considering the best Russian and international practices and based
on the two underlying documents: Regulation on Principles and Procedures for Preventing Transactions using MTS Insider Information, Policy “On Countering the Misuse of Insider Information and Market Manipulation”, and “Conditions for Transactions with Financial Instruments of the MTS Group Companies by Individuals Specified in clauses 7 and 13 of Article 4 of the Law on Insider Information¹, who are included in the list of MTS insiders, and persons associated with them.”

¹ Federal Law dated 07.27.2010 No. 224-FZ “On Countering the Misuse of Insider Information and Market Manipulation and on Amending Certain Legislative Acts of the Russian Federation.”

MTS PJSC local regulatory acts define the procedure for using insider information, rules for protecting its confidentiality and control over compliance with the legal requirements on the use of insider information. Control procedures ensure fair price setting of financial instruments, protection of the rights and property interests of all MTS shareholders and equality of other investors in terms of the timing and volume of information received, strengthening investor confidence, and curbing abuse in the form of misuse of insider information and market manipulation.

The Company maintains a list of its insiders. It includes individuals and legal entities. Since 2014, the Company has operated a training system for all insiders who are the Company’s employees. Upon hiring, each employee reads the Company’s regulations aimed at preventing violations of insider laws. An interactive course dedicated to the basics of insider law is held for all employees of the Company.

Risks related to the violation of insider legislation are recorded in a specialized automated system and reassessed every six months.

Pursuant to the requirements of the Law on Insider Information, MTS approved Internal Control Rules to prevent, identify and suppress the misuse of insider information and/or market manipulation. The Internal Control Rules establish the goals, objectives and methods for internal control over compliance by MTS with the requirements of the insider information law, the procedure and timing of disclosure of MTS insider information, the procedure for access to insider information and the rules for protecting its confidentiality. Control over MTS compliance with the requirements of insider information law is part of the official duties of the Vice President for Corporate and Legal Affairs of the MTS Group CC (Management Board Member), who is accountable to the President of MTS¹.

¹ On February 26, 2025, an entry was made about the change in information about the legal entity to the Unified State Register of Legal Entities: Inesa Galaktionova – CEO of MTS PJSC.

In order to maintain an effective insider compliance program, the Company audits the program controls as necessary (using the risk-based approach) – by the internal audit unit headed by an individual accountable to the Board of Directors.

Personal data processing organization

In 2024, the Information Security Department continued its activities within the pre-defined areas – Customer-Oriented Approach (Customer Centricity), Continuous Involvement, Assistance to Product Teams, Simplicity and Speed, Interaction with Product Teams at All Stages of Product Life Cycle.

As part of adhering to the principles of transparency and accountability when processing personal data, a new version of the MTS PJSC Personal Data Processing Policy was developed and approved (PT-010-8), which is subject to mandatory publication and takes into account the relevant legal requirements. To reduce the deviations that are not breaches of the mandatory legal requirements, but are taken into account by the supervisory authorities when making a decision to hold unplanned inspections (risk indicators), the information contained in the “Register of Personal Data Processing Operators” is maintained in up-to-date condition. The issue of notifying the authority that protects the personal data subjects’ rights on transborder transfer of personal data is controlled separately.

Risks associated with violating personal data legislation are taken into account in the Company’s risk management system and are reassessed on a regular basis.

In order to increase the level of awareness by the Company’s employees on the issues of organizing personal data processing and data privacy, an updated course “Confidential Information and Personal Data Handling Rules” was prepared, under which in 2024 MTS PJSC trained more than 30,000 employees of the Company.

Anti-monopoly compliance

In 2024, during the anti-monopoly training of MTS PJSC and subsidiaries’ employees the focus was on preventing trading collusion. The main purpose of the training was to provide for timely detection and suppression of anti-competitive agreements in connection with stiffening of criminal liability and special attention of regulators to such breaches.

In addition, a method was finalized for assessing anti-monopoly risks in subsidiaries: the markets of presence were defined, risks were ranged by the degree of significance of the consequences for the companies and the probability of their occurrence.

Occupational safety and health management system¹

¹ Detailed information on the program is presented in the “Our Employees” section.

The Company operates a two-tier OSH management system focused on creating a safe working environment, preventing occupational injuries and personnel training in occupational safety rules.

In 2024, as part of the compliance program, the following activities were carried out:

• special assessment of working conditions and production control;
• procedures for identification, assessment, and management of professional risks;
• medical examinations;
• training of employees and experts in occupational health and safety;
• provision of the employees with safety clothing, safety shoes, and other personal protective equipment;
• various events and communications in order to increase employee awareness of occupational health and safety;
• control procedures of various levels;
• interaction with regulatory authorities.

Human rights at the workplace¹

¹ Detailed information is provided in the “ESG and Sustainability” section, and in the MTS Sustainability Report.

MTS recognizes that a person, their life and health are the highest value. MTS services assist in providing equal opportunities for education, development, and self-realization of each stakeholder, regardless of individual features and needs.

MTS does not accept discrimination in any form or manifestation, it creates an inclusive and diverse environment and adheres to the best global practices (diversity, equity, and inclusion).

Therefore, in 2024:

• During the year, the ESG Committee regularly discussed issues related to the development of the corporate inclusion culture and its significance for the Company’s future;
• Educational programs on diversity, equity, inclusion, including in observance of human rights, were held. Educational programs were attended by 1,050 MTS managers and HR;
• On the Pulse portal, an educational campaign on various aspects of inclusive culture and human rights was arranged for the MTS ecosystem employees, reaching 20,000 employees;
• Research and surveys on diversity and inclusion were conducted among the ecosystem employees;
• Tools were developed that enable growth of the inclusive culture within the ecosystem: “Inclusion – A Trend in Fashion or New Business Ethics” test makes it possible to define the level of a tolerant attitude towards the representatives of inclusive groups, and “Bullying at the Workplace” test makes it possible to define the presence of bullying in the corporate environment.
• In the opinion of the National Championship for Professional Skills among Disabled People and People with Disabilities “Abilymptics”, MTS was one of the leaders in employing people with disabilities – 50 graduates of the championship have become a part of the ecosystem team as of 2024.

In 2024, the MTS Group Unified Hot Line received 202 messages containing signs of violating the Code of Business Conduct and Ethics. However, only one message concerned discrimination. A check was made of message that confirmed the fact of discrimination. The requisite corrective measures were taken for the detected case.

Risks in inclusive culture and observance of human rights are digitized regularly according to the recommendations from the external annual audit of compliance programs and assessment of compliance risks at the level of business processes.

MTS adopted local regulations governing the main issues of observance of human rights regarding diversity, equity, and inclusion. The documents consolidate key principles of respect for human rights and conduct of the Company’s employees.

Environmental Studies¹

¹  Detailed information about the Company’s approaches to managing its own environmental impact is provided in the “Caring for the Environment” section of this report, as well as in the MTS Sustainability Report.

The MTS approach is based on efficient management of regulatory environmental and climate risks. In 2023, the Company continued implementing the program to ensure environmental safety at MTS facilities, strategic projects on environmental responsibility aimed at the widespread introduction of cyclic economy principles into the MTS Group business processes. ESG Strategy of the MTS Group was approved.

Employees are notified regularly about legal requirements in environmental safety and protection on the MTS Blog platform.

Anti-money legalization (laundering) regarding proceeds from crime, countering financing of terrorism and financing the proliferation of weapons of mass destruction (AML/CFT/FPWMD)

The AML/CFT/FPWMD program has been developed pursuant to the requirements of applicable law, with its changes monitored on a regular basis. The Center for Comprehensive Security Development conducts a daily audit of all MTS subscribers to check whether all the subscribers are included in the list of Rosfinmonitoring (Federal Financial Monitoring Service of the Russian Federation). When the Company’s subscribers carry out high-risk transactions on personal accounts, an additional check is initiated against the database of invalid passports. The Company also makes a daily check of contract termination for providing communication services with the return of the advance balance, as well as other transactions of subscribers.

In 2024, in the Company:

• the signs of unusual transactions were updated;
• top-management scheduled training in the form of targeted briefing/raising the level of knowledge for the purpose of AML/FT/FPWMD was conducted.

Intellectual property risk management system

In 2024, in order to manage and assess risks related to intellectual property, jointly with the Risk Management Department, an improved model was developed for assessing IP-risks in MTS Group of Companies, which revised the approach to high quality and financial assessment of the IP-risks in the entire IP risk map, implemented the relevant criteria for assessing IP risks, their value and probability of occurrence from the point of view of the processes in the MTS Group of Companies and judicial practice in Russia, adjusted the financial model of risk assessment, improved the formulas for calculating the IP risk assessment.

To mitigate risks in terms of violating third parties’ rights and protecting their trademarks, the module “Monitoring of Infringement of Exclusive Rights to Trademarks” was put into operation, which automatically finds, sends claims and controls elimination of the breach of exclusive rights to trademarks, and the “Naming” module interface was improved using user feedback.

To simplify paperwork and accounting of trademarks of the MTS Group of Companies, the “Register of Trademarks” module was improved, where an option appeared to record using international trademarks of the MTS Group of Companies.

To manage risks in terms of infringing third parties’ rights to computer software, a survey was developed for inspecting the software license components with an open code (OSS licenses).

In 2024, the mandatory remote course “Intellectual Property Usage Rules” was updated.

A training event was held on the issues of patenting the developments in MTS Group, under which the need for testing the technologies for patent purity was considered, as well as the patentability and technology patenting procedure, and a webinar was also held, dedicated to the International Day of Intellectual Property, where the intellectual property items were considered, which are produced when the MTS Group products are designed.

Compliance training of MTS PJSC Board of Directors members

In 2024, training was held on the anti-corruption compliance system for the members of the MTS Board of Directors, the Management Board and members of the Committees of the Board of Directors. The training was attended by 100%. members of the Board of Directors, the Management Board and members of the Committees of the Board of Directors.

Comprehensive security system

In 2024, activities to ensure corporate security and access control were conducted in accordance with the Security Block Development Strategy for 2024–2026.

Within the implementation of the requirements of Federal Law No. 115-FZ dated August 07, 2001, “On Combating the Legalization (Laundering) of Criminal Proceeds and Financing of Terrorism”, the Security Block employees set up and are operating a system for detecting and blocking personal accounts registered in the names of persons on the List of Terrorists/Extremists. Dozens of such personal accounts are detected and blocked weekly.

Information Security

The architecture of the corporate information security system was developed considering the recommendations of regulators and best global practices, based on national and applicable international standards. The continuity of functioning of all corporate processes and information security tools is ensured. The level of maturity of the information security management and assurance system complies with the target and guarantees sustainable operation and development of the business and product ecosystem, as well as the achievement of the MTS Group strategic goals.

The work was continued on improving all processes for managing and providing information security and implementing the policy for import substitution of the information security tools from unfriendly countries, which required reengineering certain elements in the corporate architecture of the system of critical information infrastructure protection.

Projects were implemented to introduce and improve the information protection systems, in particular, for monitoring/managing events and incidents of information security, mirroring and managing network traffic copy, collecting and analyzing configurations/log files of firewalls and others, the cluster of servers for “KZKS Continent TLS” information system was expanded. Technical support and continuity of functioning of all information security tools were provided.

Compliance with licensing requirements regarding the operation of CIPF, technical protection for confidential information and monitoring the state of information security of information technology tools and computer systems was ensured. There were no comments from regulatory authorities.

Conflict of interest management

The Policy “Conflict of Interest Management”, as well as the memo on the conflict of interest management in the Company was updated in 2024 and posted on the MTS external website, the corporate portal, and also in the My MTS mobile app. All new employees familiarize themselves with this Policy, and fill out the form “Disclosure of Information about Conflict of Interests”. A survey is conducted twice a year for members of MTS PJSC management bodies. In 2024, data were checked on 1,239 situations for the presence of a conflict of interest, where: 749 – potential conflicts of interest that do not require settlement, 19 – settled conflicts of interest, 471 – conflicts of interest, the information on which was not confirmed.

LESS (Law Enforcement Support System)

In order to ensure the failure-proof operation of special complexes installed on the MTS PJSC network, events were organized and held on a permanent basis to maintain and support the equipment and software.

Special complexes were installed on the MTS PJSC communication networks, the presence of which makes it possible to provide communication services using 2G/3G/4G/5G, IMS (VoLTE, Wi-Fi Calling, “My MTS”), eSIM, RCS, NB IoT technologies, M2M, Wi-Fi, BBA, as well as convergent services “Virtual PBX”, “Membrane”, “Single Number” and MVNO services (“Tinkoff Mobile”). Work on modernizing special complexes supporting the activities of authorized state bodies was done on a scheduled basis, in accordance with the approved investment program and the requirements of L&R (laws and regulations). Scheduled events were held in full.

Economic security and anti-corruption

Primary attention was paid to mitigating financial and economic risks and preventing substantive damage to the Company. In 2024, 69 internal inspections/investigations were carried out, more than 14.4 thousand procurement procedures were reviewed, more than 44.5 thousand inspections of counterparties, as well as inspections of 67 thousand candidates and employees of the MTS Group of Companies, were made. Based on annual results, the economic effect from the activities of the Economic Security and Anti-Corruption Department, including reimbursed and prevented damage, amounted to RUB 1.8 billion. HR issues were addressed systematically. Within the framework of performing primary functions and authorities, the system of counterparties’ inspection using BigData tools was further improved:

• the functionality of automatic inspection of counterparties – individuals was implemented;
• the method to estimate credit limits for the customers was automated for selling equipment with deferred payment in the B2B segment;
• the functionality of annual inspection of counterparties under the existing technological lease contracts was automated;
• the service of preliminary inspection of counterparties using INN (Taxpayer ID) available on the Pulse internal corporate portal was updated.

Security of personnel and facilities

Anti-terrorist protection and facility security was provided in accordance with the MTS Group Strategy for the integrated security support for 2023–2024.

In 2024, fire-fighting and anti-terrorist training were conducted on a regular basis. In order to increase the level of anti-terrorist security, persons who are admitted to critical information infrastructure facilities are checked.

During the preparation and holding of significant socio-political events and public holidays, enhanced measures were taken to protect the Company’s facilities, ensure intra-facility and access control. No incidents or violations at facilities were allowed.

During the preparation and holding of significant socio-political events and public holidays, enhanced measures were taken to protect the Company’s facilities, ensure intra-facility and access control. No incidents or violations at facilities were allowed. In order to fulfill the requirements of the Decree of the Government of the Russian Federation dated June 08, 2023, No. 944 “On Approval of Requirements for Anti-Terrorist Protection of Objects (Territories) of the Ministry for Digital Development, Communications and Mass Media of the Russian Federation, the Federal Service for Supervision of Communications, Information Technology, and Mass Media and Its Territorial Bodies, as well as Subordinate Entities and Entities Related to Their Area of Activity”, systematic work to categorize and certify the MTS PJSC facilities was carried out.

Antifraud

The Antifraud Department¹ carried out work to connect to the Unified Call Verification System, operated by the Main Radio-Frequency Center, in accordance with current technical conditions, verification is performed in real time with all participants connected to the System. In 2024, MTS PJSC reached 100%. parameter of call verification for mobile and fixed communication subscribers. Calls of 1,163 communication providers are verified, including 103 transit operators. In 2024, the verification hub of MTS PJSC blocked 134.7 million calls.

¹ Under the Decree of the Government of the Russian Federation dated November 3, 2022 No. 1978, No. 1979

In 2024, 3.06 million facts of fraud were detected; the amount of prevented losses was RUB 817.5 million. In 2024, 104.1 billion calls were processed by antifraud systems on the MTS PJSC network, of which 2.7 billion were blocked.

Regional management

In 2024, regional security units continuously ensured the implementation of measures in terms of security of personnel and facilities, information and economic security in accordance with the Security Block Development Strategy.

In order to comply with Russian Federation Legislation, MTS PJSC duly organized and carries out interaction with law enforcement agencies, courts, and supervisory authorities.

In order to ensure the Company’s assets safety, as well as considering the current geopolitical situation and the position of vendors regarding equipment supply to the territory of the Russian Federation, regional security services on a regular basis monitor the safety and return of MTS PJSC equipment dismantled by contractors.

In order to identify and prevent economic risks for MTS PJSC, employees of the security unit centrally inspected in 2024 the reliability of 16 thousand new counterparties, with which MTS PJSC entered into agreements within its operating activities, as well as 32 thousand counterparties under existing contracts.

Responsible supply chain

The Company’s purchases are made in accordance with the MTS Procurement Rules developed in accordance with legal requirements. The MTS PJSC Counterparty’s Code of Business Conduct contains recommended standards, compliance with which is expected from counterparties, and applies in all subsidiaries and affiliates of MTS PJSC. In addition to good faith and honesty, the Code notes the importance of compliance by vendors with environmental laws and human rights. Equal access to procurement procedures is ensured by establishing equal competitive opportunities and uniform rules for all participants of the procurement procedure prior to its implementation.

In 2024, procedures aimed at increasing the transparency of procurement activities were maintained, namely:

• mandatory anti-corruption verification of counterparties and third parties is carried out within the procurement procedure;
• anti-corruption training for counterparties on a risk-oriented basis was conducted;
• controls were established to interact with sub-counterparties, including with anti-corruption inspection;
• a set of measures was implemented to consolidate purchasing procedures for companies included in the MTS Group, and also the process of intragroup transactions was structured.

In 2024, the Procurement Management Block strategy was successfully defended for 2024–2025. The key initiative of the strategy was introducing a single corporate procurement management system (SRM-system), which will ensure centralized management of procurement procedures and interaction with the vendors and internal customers.

The SRM-system covers the entire Source-to-Contract process and is aimed at increasing the transparency of the procurement process, automating key stages, improving quality and detail of the digital footprint – from assessment and selection of contractors to contract award, and further monitoring of their performance. The solution will help to change to state-of-the-art technologies and reduce dependence on the Oracle platform.

Increasing the transparency of procurement procedures

In 2024, anti-corruption inspection of sub-counterparties was made.

В 2024 году проведена антикоррупционная проверка субконтрагентов.

¹ MTS procurement procedures are performed in electronic form in ERP-system Oracle Sourcing using EDF (electronic document flow) module.