While all Performance Standards are applicable to this investment, IFC’s environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards

PS 1 - Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and Working Conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 - Community Health, Safety and Security

This is Category A project according to IFC’s Policy on Environmental and Social Sustainability. The Project does not entail any additional footprint, however the augmentation works (as described in project description section) associated with the investment may unlock additional air traffic capacity. Key E&S risks associated with the project include: exacerbated noise impacts on communities living in airport vicinity from aircrafts and airport ground operations; health and safety risks at the airport’s fuel storage facility; potential legacy soil and groundwater contamination; designation of protection/safety zones around airport to limit additional construction; government-led resettlement related to the establishment of zones around the airport to minimize damage from potential accident during aircraft landing and take-off or to regulate environmental pollutants such as noise; project construction related impacts on air quality, noise, waste, wastewater, traffic, increase in emission of greenhouse gases; contractor management and implementation of PS2 requirements for third-party contracted workers.

IFC’s appraisal considered the environmental and social management planning process and documentation for the Project and gaps, if any, between these and IFC’s requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through implementation of these measures, the Project is expected to be designed and operated in accordance with Performance Standards objectives.

PS 1 - Assessment and Management of Environmental and Social Risks and Impacts

AIA has an existing environmental and social management system (ESMS) including policies, procedures, and tools for E&S risk management. The ESMS was designed, considering the nature and scale of the airport’s E&S risks and impacts, and to facilitate improved E&S outcomes. The ESMS is certified under ISO 14001 (Environmental Management System), ISO 45001 (Occupational Health and Safety) and ISO 9001 (Quality Management System). The ESMS is aligned with IFC requirements, and covers the following elements: (i) human resource (HR) and Environment, Health and Safety (EHS) policies; (ii) the process of identifying E&S risks and impacts; (iii) organizational capacity and management programs; (iv) emergency preparedness and response; (v) stakeholder engagement; and (vi) monitoring and review of EHS related matters. As per ESAP#1, AIA will update and implement the ESMS, in line with IFC Performance Standards, to minimize environmental and social risks associated with construction and operation of the proposed project as identified in the ESIA.

AIA has developed a policy on Quality, Occupational Health and Safety and Environmental and Social aspects as part of its Integrated Management System. The Policy expresses AIA’s commitments to protect the health and safety of its workers, contractors and surrounding communities, and comply with local regulatory requirements for environment, health and safety. The policy also includes a commitment to provide adequate resources and training to fulfil the commitment given in this policy.

To identify and manage risks associated with ongoing airport operations, AIA has a management plan for the identification and significance assessment of environmental aspects. There is also a hazard identification, risk assessment and risk management procedure incorporated in the Occupational Health and Safety (OHS) plan.

For the Project, the company commissioned an ESIA aligned with lenders’ requirements (attached to this ESRS) which identifies the main E&S risks and impacts associated with construction and operations. A public consultation meeting was held in September 2025 to share the results of the ESIA with stakeholder, and the ESIA was disclosed on AIA’s website at https://alaport.com/en-EN/passenger-guide/terminal-construction/page/environmental-and-social-impacts. AIA will prepare the Environmental Impact Assessment (EIA) in accordance with Kazakhstan’s Environmental Code and submit to relevant government authorities for approval.

As part of the Project, the fuel farm will be upgraded with addition of new tanks, refurbishment and replacement of older tanks, expansion of railway unloading rack, modification and expansion of pipeline network, as well as enhanced automation, fire protection, and expansion of staff facilities etc. A Quantitative Risk Assessment (QRA) is underway and expected to be completed by December 2025. This assessment focuses on the identification of hazards associated with both the existing fuel farm facilities as well as the planned expansion works. As per ESAP#2, AIA will incorporate the recommendations of the QRA in the fuel farm design and implement required measures during construction and operations to align the facility with good international industry practices (GIIP) in terms of spill prevention, atmospheric emissions, fire risk management and occupational health and safety.

Although the addition of new project components are expected to remain within AlA’s existing footprint of the previous project (#43007), potential land acquisition risks were identified with regard to the properties in the proximity of the Airport Complex covered by the potential Sanitary Protection Zones (for the purposes of regulating the level of noise or other environmental pollutants arising from aviation activities), Aerodrome Territory/Aviation Safety Zone (within which certain activities are subject to regulation on grounds of aviation safety pursuant to the Laws of the Republic of Kazakhstan) or potential Public Safety Zone (to control the number of people on the ground at risk in the event of an aircraft accident on take-off or landing). An Intergovernmental Working Group (IWG) was established in 2025 consisting of members from relevant government departments, local akimat, airport authorities, and the lenders, to coordinate any potential resettlement. Any land acquisition or resettlement risk related to airport operations will be managed in accordance with the Land Acquisition and Resettlement Framework (LARF) adopted as per the project #43007, accessible at: https://webcmsala.tav.aero/files/1651115489_Land%20Acquisition%20and%20Resettlement%20Framework.pdf. If any land acquisition and/or resettlement is triggered, AIA will notify lenders, and engage a qualified consultant to prepare a Supplemental Resettlement Action Plan in line with IFC requirements prior to the commencement of any displacement.

Management Programs:
An Environmental and Social Management and Monitoring Framework was prepared as part of the ESIA and it outlines the actions, requirements, frequency and responsibilities for E&S management and monitoring by the company. As per ESAP#3, AIA will require the EPC contractor to develop Construction phase Environmental and Social Management Plans (C-ESMPs) aligned with the Project’s ESIA to manage and minimize the impacts identified. These will include but not be limited to: (i) standard environmental controls; (ii) waste management plan; (iii) hazardous materials management plan; (iv) air quality management plan; noise and vibration management plan; (v) water management plan, vi) emergency preparedness and response plan; (vii) traffic and transport management plan; (viii) community health and safety plan; (ix) occupational health and safety plan; (x) contractor management plan; (xi) labor management plan; (xii) training plan; (xiii) security management plan; and (xiv) stakeholder engagement plan and grievance mechanism.

The company developed and is implementing operational management plans for AIA’s current operations. As per ESAP#4, AIA will develop and implement Operations phase Environmental and Social Management Plans (O-ESMPs) aligned with the risks and impacts from the Project. These will include but not be limited to: (i) air quality management plan; (ii) waste management plan; (iii) hazardous materials management plan; (iv) water management plan; (v) noise and vibration management plan; (vi) traffic and transport management plan; (vii) community health and safety plan; (viii) GHG Management Plan; (ix) occupational wellbeing health and safety plan; (x) emergency preparedness and response plan; (xi) contractor management plan; (xii) labor management plan; (xiii)security management plan; (xiv) stakeholders management plan; (xv) wildlife hazard management plan; (xvi) climate change adaptation and resilience plan.

Organizational Capacity & Competency
AIA has an Environmental, Health and Safety (EHS) Department that falls under the Vice President of Integrated Management System. The team includes two environmental specialists, one social specialist, two environmental and social specialist, five OHS engineers, one industrial safety engineer and one environmental engineer. The E&S organizational capacity at AIA is commensurate with risks associated with existing operations.

An Engineering, Procurement, and Construction (EPC) contractor has been appointed for the construction of certain components of the Project (primary EPC), including full depth reconstruction of main runway, new taxiway, new cargo apron, full depth reconstruction of existing VIP apron, new de-icing pad, and rehabilitation of parking stands. However, an EPC is yet to be appointed for construction of other components, such as fuel farm storage improvements and expansion. As per ESAP#5, AIA will require the EPC contractor to hire qualified EHS staff commensurate with project risks, including an EHS manager, EHS officers and EHS supervisors (one for 50 workers). The EPC will provide role-specific training to these staff members particularly to implement the project Construction Environmental and Social Management Plans (C-ESMP) and Environmental and Social Management and Monitoring Plan (ESMMP).

Emergency Preparedness and Response:
AIA has an Emergency Preparedness and Response Plan based on the identified health, safety and environmental risks associated with the Project. The plan covers potential emergency situations including storms, flooding, earthquakes, fires, explosions, bomb scares, terrorist attacks and civil unrest. The EPRP includes guidance on identifying potential emergencies; procedures to respond to emergency situations; protocols for the use of the emergency equipment and facilities; schedule of trainings and drills, including with local emergency response services (fire fighters); list and location of emergency response equipment (firefighting, spill response, first aid kits, personal protection equipment for emergency response teams); as well as a detailed emergency evacuation plan indicating the location of emergency response equipment, evacuation routes, and a list of relevant persons contact details.

As part of O-ESMP (ESAP#4), AIA will update the Emergency and Preparedness Response Plan (EPRP) to manage and monitor all operational-phase risks associated with the Project including those associated with the fuel farm storage facility, as well as risks to community safety and security risks. In addition, AIA will require the EPC to prepare and implement an EPRP for the construction phase of the project as part of the C-ESMPs (ESAP#3).

An assessment was undertaken to determine the impacts of climate change on the operation of the Project. Potential impacts relate to changes in temperature, increases in precipitation and flooding, high winds and storms, wildfires and ground stability. These impacts may negatively affect the airport infrastructure and systems, through overheating, deterioration, and damage. AIA will prepare a Climate Change Adaptation and Resilience Plan as part of the O-ESMP (ESAP#4).

Monitoring & Review:
AIA has established monitoring procedures, including an internal audit department, to monitor and measure the effectiveness of their E&S management systems. In line with these procedures, there are scheduled internal audits and spot audits conducted by AIA personnel which cover technical, environmental, health and safety issues. AIA management receives audit results and there is a formal process of reviewing, responding and closing the report’s findings through a corrective action system. According to AIA’s ESMS, the frequency and methods of monitoring is determined by i) compliance obligations and stakeholder requirements; ii) AIA policy commitments and set objectives; iii) level of risk and types of control measures; iv) performance and audit results; v) trends in non-conformities or corrective actions; and vi) outcome of stakeholder/community interviews and grievances. AIA has in place a monitoring plan, which includes quarterly and semi-annual monitoring. All monitoring outputs are documented and analyzed to determine the effectiveness of the ESMS.

A detailed Environmental and Social Management and Monitoring Plan (ESMMP) was prepared as part of the ESIA which outlines the monitoring requirements for construction and operation phases, including monitoring indicators, timelines, and responsibilities. Monitoring results will be shared with stakeholders through periodic disclosure mechanisms to promote transparency and accountability.

Training: AIA has a documented Training and Awareness procedure outlined in the ESMS to ensure that all employees within the organization are adequately trained in the company’s EHS policies and procedures. The Human Resources department maintains and reviews the training records to ensure completeness and identifies the need for future training. Induction training is provided for all new staff. In addition, job-specific training, as well as health and safety training are conducted on an ongoing basis. AIA’s Training, Retraining and Professional Development policy reiterates the company’s commitment to providing equal opportunities for professional growth and development irrespective of gender. As part of C-ESMPs (ESAP#3), the EPC will develop a Training Plan for project construction focusing on key risks associated with construction such as working at height, lifting & rigging, confined space training, excavation safety, heavy equipment movement etc.

PS 2 – Labor and Working Conditions

AIA employed 4,189 operational staff (2,936 men and 1,253 women) as of September 2025. Of these, 2,292 have term contracts and 1,897 have permanent contracts. About 1.9% of these staff members are people with disabilities. Responsibilities of operational staff include operation and maintenance of the ground facilities, airfield servicing, managing flight safety for international and domestic air traffic, handling of luggage, cargo and mail, managing payload of aircrafts, provision of ground service for passengers, etc. It is anticipated that 426 contracted workers will be hired for the construction phase by the primary EPC, while other construction contractors will hire additional workers.

Human Resources Policies and Procedures
AIA has a human resources (HR) Policy, applicable to all full-time employees and contracted staff. It outlines the company’s commitment to establish and maintain a strong relationship between workers and managers, and ensure fair treatment of workers, without discrimination. The policy includes a commitment to promote compliance with national labor and employment laws, and the fundamental standards embodied in the International Labor Inspection Convention https://normlex.ilo.org/dyn/nrmlx_en/f?p=NORMLEXPUB:12100:0::NO::P12100_INSTRUMENT_ID:312226). Overall, AIA’s HR policy is compliant with the requirements of PS2. It is available in key languages of the workforce, including English, Russian and Kazakh, and is communicated to workers at the time of employment. The company has developed a Code of Conduct for all employees. This document states the key values of the company (i.e. responsibility, integrity and respect). It also includes guidelines for managing conflicts of interest; compliance with laws and regulations; combating fraudulent behavior; intolerance of harassment and abuse of employees; non-discrimination etc.

As per ESAP#6a, AIA will update its HR Policy and Code of Conduct to comply with the requirements of IFC PS by including specific references to forced and child labor, freedom of association, occupational standards, as well as explicitly addressing discrimination, gender-based violence and harassment (GBVH), including human trafficking, as well as child protection and safeguarding (CPS). As per ESAP#6b, AIA will require the EPC and other contractors to develop their HR policies, worker accommodation plan and Code of Conduct compliant with IFC PS requirements. AIA will require the EPC to integrate IFC PS requirements into all employment contracts for sub-contractor staff and ensure training and awareness for all workers. As per ESAP#6c, AIA will develop and put in place an internal labor audit procedure and assign qualified staff to undertake these audits to effectively monitor project contractor and subcontractor compliance with PS and address any shortcomings.

Working Conditions and Terms of Employment
All direct workers at AIA receive a contract at time of employment that includes basic terms of employment such as contract duration, annual leave, wages, overtime, and benefits. All employees receive information about HR policies, procedures, and AIA’s code of conduct at the time of induction.

The project EPC does not intend on building an on-site camp for accommodating workers. Instead, they will rent accommodation in an area approximately 10km from the Project site for its international staff (approximately 15% of workers). This accommodation will comply with the Worker Accommodation Plan (prepared as part of C-ESMPs). The local workers will stay in their homes and commute daily to the site.

Workers’ Organization
AIA has signed a Collective Bargaining Agreement (CBA) with the Trade Union of Almaty International Airport. The CBA is in line with the applicable national legislation including the Labor Code and the Law on Trade Unions outlining rights and responsibilities of administration and union employees. Approximately 99% of employees are members of the Trade Union. The CBA establishes a grievance mechanism that is managed by the TU Committee. AIA reported that no labor disputes, including strikes, have occurred during the last two years. As per the ESAP#6b above, AIA or the EPC will not interfere with construction workers’ right to join or form unions or alternative representation mechanisms of their own choosing.

Non-discrimination and Equal Opportunity
AIA’s Human Resources Policy outlines that employees may not be subject to discrimination based on origin, gender, race, nationality, language, attitude to religion, belief, place of residence, age or physical disabilities. The policy further reiterates that AIA is committed to ensuring that women are not discriminated against, and that women are supported to take full advantage of opportunities in the workplace. In 2024, AIA signed a regulation to designate an Equality, Diversity and Inclusion Committee to create a work environment where all employees, regardless of gender or sexual orientation, feel valued, respected, and empowered.

Protecting the Workforce
Kazakhstan's labor regulations explicitly prohibit forced labor and define it as any work or service demanded under threat of punishment for which a person has not voluntarily offered themselves. These protections are enshrined in the country’s Labor Code and the country's broader human trafficking laws. Aligned with local regulatory requirements, AIA’s HR policy includes a commitment not to use any form of forced labor. The HR Policy to be adopted by the EPC and the sub-contractors as per ESAP#6b will include safeguards for avoidance of any unauthorized personal document retention or other compulsory practices related to overtime or restriction of mobility or access to salient labor rights as per local regulations and PS2. AIA’s HR policy reiterates its commitment not to employ children (persons less than 18 years of age), in any of its activities. The company also guarantees that its sub-contractors will not employ children. All employees of contracted companies must be of legal working age as defined by the Kazakhstan legislation and the International Labor Organization (ILO). As outlined in the ESIA, project construction will generate a temporary minor beneficial impact on employment generation. No retrenchment is expected as a result of the project. However, if required, AIA will carry out retrenchment in line with local labor regulations and PS requirements.

Workers Grievance Mechanism
AIA has established a workers grievance mechanism which is aligned with PS 2 requirements. It is available to both direct and contracted workers. Multiple channels for submitting grievances have been established: telephone, e-mail, face-to-face, as well as an online form that is accessible by scanning a QR code. Responsible persons (CLO and HR manager) have been nominated to receive and consider complaints. Complaint boxes have been installed, and complaint forms are available. Procedures for considering complaints and sending a response to the applicant are established.

As per ESAP#7, AIA will augment the grievance mechanism to include standalone, survivor-centered, and accelerated procedure for reporting and investigating “sensitive cases” – such as discrimination, child abuse and gender-based violence and harassment (GBVH), including human trafficking, multiple entry points to raise and address allegations (in person, in writing, via phone, email), and options to report anonymously without retaliation. The Company will appoint an adequately trained grievance officer, and establish referral pathways to provide free medical services, psychological support, and legal aid for all workers. All project workers (including those from contractors) will be trained and informed of the grievance mechanism at the time of recruitment and on an annual basis, and all staff from project company and EPC workers and subcontractor workers, will be trained in the workers grievance mechanism. The company will also provide training for managers, HR staff, and grievance officers on how to handle and investigate grievances.

Occupational Health and Safety
AIA operates a Health & Safety Management System certified to ISO-45001 (internationally recognized standard for occupational health and safety). The system includes risk assessments, management plans and mechanisms for reporting and managing incidents. AIA has developed an OHS Management Plan for operations which reiterates the company’s commitment to ensuring healthy and safe working conditions, prevention of work-related accidents and occupational diseases, as well as improvement of labor protection and working conditions. The plan includes a Risk Management procedure for hazard identification, as well as risk assessment and management. The objective of this procedure is to identify, quantify, and reduce the level of risk to an acceptable level.

During project construction and operations, workers may be exposed to a range of physical hazards (e.g. working at height, noise, vibration, manual handling, operation of heavy equipment), chemical hazards (e.g. dust, fumes, solvents, fuels), and biological hazards (e.g. exposure to wastewater, vector-borne diseases, or contaminated materials). As per ESAP#8, AIA will require the EPC contractor to develop and implement Occupational Health, Safety and Wellbeing Management Plan (OHSWMP) for construction phase including plans and procedures of a scale appropriate to the risks including hazard identification, risk assessment, provision of appropriate personal protective equipment (PPE), emergency preparedness, training, and monitoring. The requirements defined within these documents will apply to all workers, including sub-contractors. Similarly, as per ESAP#9, AIA will update and implement their OHSWMP for operations, taking into consideration risks associated with operations.

Workers Engaged by Third Parties:
AIA includes in all contracts an appendix on Health, Occupational, Environmental and Safety Protection. This appendix reiterates that all contractors will comply with AIA’s ESMS as well as all relevant local regulatory requirements for labor and working conditions, health and safety, environmental and social impact, fire safety etc. As per ESAP#10a, AIA will develop a Contractor Management Plan defining their approach to managing the Environment, Health, Safety and Social (EHSS) performance of their contractors, subcontractors, and other third parties during the various phases of the project. The contractor management approach will be consistent with the general principles described within IFC Good Practice Note: Managing Contractors' Environmental and Social Performance. (b) AIA will include legally binding obligations in the EPC contract to ensure compliance with the requirements of project ESMS, C-ESMPs, national EHS regulations, as well as IFC requirements. EPC will do the same for its sub-contractors (ESAP#10b). For effective monitoring and regular oversight, AIA will include in EPC contracts, a requirement to submit monthly workforce reports covering working hours, overtime, wage payments, training, grievances, union activity, accommodation details, health and safety statistics, and other relevant labor data (ESAP#10c).
As per ESAP#11, the company will hire a qualified consultant to undertake a labor audit at the peak of project construction to assess contractor and sub-contractor adherence to local labor laws and compliance with PS 2 requirements. The labor audit will also include an assessment of accommodation facilities provided by contractors/sub-contractors to ensure compliance with IFC/EBRD Good Practice Note on Workers’ Accommodation, internationally recognized life & fire safety standards, and to ensure adequate considerations have been made related to health, safety, and gender aspects.

PS 3 – Resources Efficiency and Pollution Prevention

Resource Efficiency:
The new international terminal of the airport, financed as part of the previous investment at AIA, received EDGE (Excellence in Design for Greater Efficiencies) certification from the World Bank in January 2025. The certification recognized AIA’s achievement in the following areas: 46% energy savings, 56% water savings, 33% less embodied energy and materials, as well as saving of 4317 tCO2 equivalent per year.

A number of sustainability and resource efficiency features will be incorporated in the design, construction and operations of the proposed Project. These include installation of smart LED lighting systems with motion and daylight sensors to reduce energy consumption; climate control systems with zoning and smart thermostats to improve energy performance and indoor air quality; enhanced wall and roof insulation to reduce heating and cooling loads; use of locally sourced and green building materials.

During project construction, dust will be generated from construction activities, which will impact air quality, as well as construction workers, and individuals residing in airport vicinity. As outlined in the ESIA, measures will be implemented to manage these impacts, such as minimizing dust from on-site sources, using dust suppression techniques, limiting dusty processes, etc. The C-ESMP (ESAP#3), will include dust and emissions control measures developed as part of the Air Quality Management Plan.

During the operation of the Project, there will be an increase in operational traffic (air and road), which will result in an increase in pollutant concentrations for nearby receptors. There will also be an increase in emissions from on-ground airport activities. As part of the O-ESMPs (ESAP#4), AIA will update and implement the operations Air Quality Management Plan to reflect current and future operational conditions. The plan shall include prevention and control measures for fugitive emissions from fuel farm operations.

Water
During project construction, there may be an increase in the risk of contamination to the surface water through accidental spills and dust generation. There may also be a temporary increase in flood risk due to construction activities altering the flow paths of the surface water or increasing the amount of surface water runoff in localized areas. During project operations, the increase in the number of aircraft and support vehicles is expected to result in higher levels of water pollution, particularly through routine surface runoff. Stormwater runoff may include pollutants associated with leaks and spills of oil, diesel, and jet fuels, as well aircraft de-icing / anti-icing fluids.

To minimize these impacts, appropriate measures outlined in the ESIA will be implemented during the construction and operations phase. In addition, as part of the C-ESMP (ESAP#3), AIA will require the EPC to develop a water management plan for the construction phase, while AIA will update and implement AIA’s water management plan to reflect current and future operational conditions as part of the O-ESMPs (ESAP#4). In addition, as per ESAP#12, AIA will develop and integrate a flood risk assessment, Stormwater Management Plan and hydraulic modelling to quantify fluvial and pluvial risks from the Malaya Almatinka and Kotur-Bulak Rivers. The findings of this assessment will be used to inform drainage design and overflow planning and reflected in updates to the Stormwater Management Plan.

Wastewater
All wastewater currently produced at the airport, including foul water from airport buildings and blue water from aircraft, is discharged to the sewer for treatment at the municipal wastewater treatment facility. Sludge produced from the cleaning of oil tanks at the fuel farm is retained in underground storage tanks which are emptied by a contractor who treats the waste offsite.

Rising passenger numbers are expected to result in an increased on-site wastewater production. This includes both domestic wastewater from terminal facilities and operational wastewater from cleaning, catering, and other support services. The volume of treated effluent discharged into the receiving watercourse will therefore increase with increased passenger numbers. It is assumed that the capacity of the existing treatment works is adequate for this increase in wastewater generated. Any discharges to municipal wastewater treatment systems must be compliant with national legislation. As outlined in the ESIA and ESMMP, AIA will implement a water quality monitoring regime of both surface water and groundwater during the construction phase, and continue this monitoring during the operational lifespan of the Project.

Waste:
An assessment was undertaken as part of the ESIA to determine the project impacts on waste and resources. During construction, a significant volume of waste is expected to be generated by the Project (construction waste, packing material, municipal solid waste). During operation, there will be additional capacity for passengers and cargo. Therefore, the volume of waste from the catering and hospitality of workers and passengers, packaging waste, as well as waste generated from maintenance and cleaning will be increased. The C-ESMP as outlined in ESAP#3 will include a Waste Management Plan (WMP) to minimize construction waste impacts. Moreover, as part of the O-ESMPs (ESAP#4), AIA will update and implement AIA’s operational Waste Management Plan.

Hazardous materials and waste
Within AIA, oil sludge from the fuel farms (both aviation and gasoline) and waste from the maintenance area is collected on site and stored in an underground storage tank. Hazardous waste is segregated and stored in a separate facility. These wastes are then removed from site via an authorized waste carrier, and transported to a municipal waste management facility.

The project ESIA outlines detailed mitigation measures for safe handling, storage, and emergency response, including bunding, spill containment, and PPE use. Improper handling and storage of hazardous materials can lead to soil and water contamination, fire hazards, and health risks for workers and nearby communities. As part of the C-ESMP, AIA will require the EPC to develop and implement the Hazardous Materials Management Plan (HMMP). As part of the O-ESMP update (ESAP#4), AIA will update the operation Hazardous Material Management Plan. In addition, the operations Spill Prevention Plan and Emergency Preparedness and Response Plan (EPRP) will be updated taking into consideration the hazardous material generated during project operations.

Soil and Groundwater
AIA is implementing a soil and groundwater monitoring program at the fuel farm (adjacent to the proposed new taxiway). The first monitoring visit was conducted in May 2025, and samples were analyzed for a range of metals, inorganics, polycyclic aromatic hydrocarbons (PAHs), polychlorinated biphenyls (PCBs), volatile organic compounds (VOCs), Perfluoroalkyl and Polyfluoroalkyl substances (PFAS), and de-icing complex (Glycol). Preliminary results indicate potential for limited legacy contamination, though further analysis is required to confirm the presence, type and extent of contamination. As per ESAP#13a, AIA will hire a competent consulting firm to conduct the soil and groundwater monitoring program, and prepare a comprehensive contamination assessment report, comparing sampling results with international recognized standards. In addition, as per ESAP#13b, AIA will prepare and submit a time-bound, costed, action plan, in form and substance aligned with IFC requirements for soil and groundwater remediation (if required).
In order to prevent oil and/or groundwater contamination due to accidental spillages from construction or operation vehicles, equipment maintenance, and storage of fuels/oils, AIA will require the EPC to integrate soil protection and emergency response into the C-ESMPs, including the Emergency Preparedness and Response Plan (EPRP), to help prevent incidents, ensure rapid response, and reduce environmental and regulatory risks.

GHG Emissions
During the construction of the Project, GHG emissions will result from the manufacturing and transportation of materials and fuel use for construction equipment. Ground-based emissions during airport operations are caused by gasoline and diesel fuel for airport vehicles and ground support equipment (GSE), as well as jet fuel for auxiliary power units (APUs). Indirect emissions are associated with the company’s purchase of electricity heat from generating companies and increase in flights. GHG emissions associated with the Project are expected to be 35,288 tCO2e per year by 2030.

PS4 – Community Health and Safety

Construction impacts on community
The proposed development areas are located within the boundary of the operational airport and, therefore impacts on community health and safety are expected to be typical of large construction sites including temporary and minor adverse impacts from increased noise, dust, road traffic, and waste generation. However, by implementing the construction Environmental and Social Management Plans (C-EMSPs), the impacts can be minimized and are not expected to be significant.

Noise
Project development will trigger an increase in air traffic movements with corresponding increase in noise impacts on the local communities. The areas of Turksib, Guldala, Almerek, and Panfilovo neighborhoods in airport vicinity will be most impacted as a result of noise from aircraft movements, ground support equipment, and increased road traffic. Noise modelling conducted as part of the ESIA evaluated the number of buildings impacted by different noise levels. According to this assessment, by 2030 approximately 2,119 buildings will be impacted by noise levels exceeding 60dBA(max) - the national regulatory limit for single noise events such as those caused by aircraft. By 2040, this figure is expected to increase to 3,292 buildings.

AIA is currently implementing a voluntary Noise Insulation Programme (NIP) for households impacted by night-time noise exceeding 60dBA(max). As per ESAP#14, AIA will: (a) continue outreach to affected people exposed to nighttime noise level exceeding 60dbA; (b) implement a noise insulation program building upon the ongoing program and prioritizing vulnerable people. As per ESAP#15, AIA will coordinate with governments authorities including the Civil Aviation Authorities to update and implement the Noise Management Plan (NMP) to mitigate noise impacts for all households exposed to night-time noise levels above 60 dBA, consistent with the International Civil Aviation Organization (ICAO) Resolution A33/7, Balanced Approach to Aircraft Noise Management (the “Balanced Approach”) and WBG EHS Guidelines for Airports.

Traffic
An increase in road traffic in and around the airport is expected during project construction and operation from movement of construction vehicles, passenger buses, shuttles and cars. Before start of construction, AIA will require the EPC to develop a Traffic Management Plan integrated to the C-ESMP. Moreover, before start of operations, AIA will develop the Operational Traffic Management Plan (as part of the O-ESMP) to monitor cargo and passenger movements, to avoid congestion, and minimize adverse impacts on public safety and the environment.

Zoning
Sanitary Protection Zone (SPZ) refers to any area around the airport complex declared (or to be declared) for the purposes of regulating the level of environmental pollutants arising from a developmental project pursuant to the laws of Kazakhstan. These pollutants may include noise, air emissions, electromagnetic or other radiation etc. AIA filed a preliminary SPZ application with regulatory authority, but the SPZ was not finalized due to the presence of historical buildings in airport vicinity, as well as an exceedance of noise above the national thresholds.

Public Safety Zone (PSZ) is the area of land at the ends of the runways of an airport complex, within which development should be restricted in order to control the number of people on the ground at risk of death or injury in the event of an aircraft accident during take-off or landing. The term ‘public safety zone’ does not appear in Kazakhstan’s legislation. However, a 2020 air safety study commissioned by AIA recommended enhancing control over land use near the airport by establishing a Public Safety Zone and using the British “Control of Development in Airport Public Safety Zones” to delineate the PSZ.

Aviation Safety Zone (ASZ) is a buffer zone from the runway within which certain activities, such as agricultural activities, industrial activities, and construction of building above a certain height, are subject to regulation on grounds of aviation safety, pursuant to the Laws of the Republic of Kazakhstan.

To minimize the number of individuals impacted by adverse impacts from airport operations, AIA will continue to proactively engage with governmental authorities for the establishment of a SPZ and PSZ (ESAP#16) which will prevent further influx of new residents in these zones.

Security
Security personnel are directly employed by AIA. It is anticipated that additional security staff will be required once the project becomes operational and air traffic increases. AIA has developed a Security Management Plan aligned with PS requirements. As per ESAP#17, AIA will carry out a Security Risk Assessment and update the SMP to incorporate additional risks associated with construction and operations. The plan will include training requirements, including on discrimination, GBVH, child abuse, and use of force in line with the Voluntary Principles on Security and Human Rights.

Life and Fire Safety: The new international terminal of the airport and other facilities are equipped with Fire Alarm Systems from leading industry vendors, fully aligned with US National Fire Protection Association (NFPA) standards. These systems are monitored from a centralized operators’ room in compliance with local regulations. As per ESAP#18, Life and Fire Safety requirements will be incorporated in the design of the project to meet internationally recognized LFS standards (NFPA 101), and the design will be certified by an accredited LFS professional. In addition, AIA will ensure the new terminal design will be in accordance with the relevant national and international structural/building standards, taking into account the potential for seismic activity and universal access principle.

Gender, Gender-based violence and harassment (GBVH), and child protection and safeguarding (CPS)
AIA will ensure that restrooms, breastfeeding rooms, and other airport facilities are safe, accessible, and supportive of women’s needs. This includes providing larger, well-equipped restrooms with sanitary product dispensers and disposal options, clearly marked breastfeeding rooms, and ensuring all facilities are accessible to people with disabilities and parents with children.

Given the high rates of GBVH, and particularly human trafficking and sexual harassment in Kazakhstan, AIA will augment the grievance mechanism for all airport users and employees for reporting and investigating “sensitive cases” – such as discrimination, child abuse, gender-based violence and harassment (GBVH), and human trafficking. This mechanism will feature a standalone and accelerated procedure, offer multiple accessible and confidential reporting avenues (in person, by phone, in writing, and anonymously), and appoint trained grievance officers to sensitively receive and handle complaints (ESAP#19). In addition, the company will conduct awareness campaigns for all airport users (through signage, hotline, etc.) and provide regular training to employees to help identify and respond to potential GBVH and child abuse cases. AIA will also develop partnerships with law enforcement agencies and NGOs to ensure a coordinated response to all GBVH and child abuse cases.

The ESIA for the project included detailed surveys and consultations with a representative sample of the affected community in Turksib, Guldala, Almerek, and Panfilovo, as well as interviews with key stakeholders during June and July 2025. A public consultation meeting was organized on September 7, 2025, which helped gather initial feedback on the ESIA. The ESIA has been disclosed at AIA’s website: https://alaport.com/en-EN/passenger-guide/terminal-construction/page/environmental-and-social-impacts.
AIA has developed a Stakeholder Engagement Plan (SEP) for the project aligned with IFC requirements (disclosed attached to this ESRS) which outlines the framework for ongoing stakeholder identification and analysis as well as the consultation methodology, frequency, and timelines. The SEP also includes a grievance mechanism to allow stakeholders to channel their grievances and facilitate mutually acceptable resolutions. AIA has a full-time Community Liaison Officer, who will be in charge of communication and outreach activities related to the project, manage grievance mechanism and oversee voluntary Noise Insulation Program (NIP) outreach and implementation. The grievance mechanism contacts can be accessed via the following email address: customer.service.ala@tav.aero. As outlined earlier, the grievance mechanism will be updated to include specialized channels and awareness-measures for reporting sensitive cases such as discrimination, harassment, child abuse and GBVH.

Broad Community Support is not applicable for this project.

S.no	Description	Anticipated Completion Date
1	AIA will update and implement the ESMS, in line with IFC Performance Standards, to minimize environmental and social risks associated with construction and operation of the proposed project as identified in the Environmental and Social Impact Assessment (ESIA).	03/31/2026
2	AIA will incorporate the recommendations of the QRA in the fuel farm design and implement required measures during construction and operations ensuring the facility complies with GIIP in terms of spill prevention, atmospheric emissions, fire risk management and OHS.	03/31/2026
3	AIA will require the EPC contractor to develop and implement Construction Environmental and Social Management Plan (C-ESMP) aligned with ESIA of the Project to manage and minimize the impacts identified. These will include, but not be restricted to: (i) standard environmental controls; (ii) waste management plan; (iii) hazardous materials management plan; (iv) air quality management plan; noise and vibration management plan; (v) water management plan, vi) emergency preparedness and response plan; (vii) traffic and transport management plan; (viii) community health and safety plan; (ix) occupational health and safety plan; (x) contractor management plan; (xi) labor management plan; (xii) training plan; (xiii) security management plan; and (xiv) stakeholder engagement plan and grievance mechanism.	03/31/2026
4	AIA will develop and implement Operations phase Environmental and Social Management Plans (O-ESMPs) aligned with the risks and impacts from the Project. These will include but not be limited to: (i) air quality management plan; (ii) waste management plan; (iii) hazardous materials management plan; (iv) water management plan; (v) noise and vibration management plan; (vi) traffic and transport management plan; (vii) community health and safety plan; (viii) GHG Management Plan; (ix) occupational wellbeing health and safety plan; (x) emergency preparedness and response plan; (xi) contractor management plan; (xii) labor management plan; (xiii)security management plan; (xiv) stakeholders management plan; (xv) wildlife hazard management plan; (xvi) climate change adaptation and resilience plan.	08/31/2026
5	AIA will require the EPC contractor to hire qualified EHS staff commensurate with project risks, including an EHS manager, EHS officers and EHS supervisors (one for 50 staff). The EPC will provide role-specific training to these staff members particularly to implement the project Construction Environmental and Social Management Plans (C-ESMP) and Environmental and Social Management and Monitoring Plan (ESMMP).	03/31/2026
6	a) AIA will update its HR Policy and Code of Conduct to comply with the requirements of IFC PS by including specific references to forced and child labor, freedom of association, occupational standards, as well as explicitly addressing discrimination, gender-based violence and harassment (GBVH), including human trafficking, as well as child protection and safeguarding (CPS)b) AIA will require the EPC and construction contractors to develop their HR policies, worker accommodation plan and Code of Conduct compliant with IFC PS requirements. AIA will require the EPC to integrate IFC PS requirements into all employment contracts for sub-contractor staff and ensure training and awareness for all workers. c) AIA will develop and put in place an internal labor audit procedure and assign qualified staff to undertake these audits to effectively monitor project contractor and subcontractor compliance with PS2 and address any shortcomings.	03/31/2026
7	AIA will augment the grievance mechanism to include standalone and accelerated procedure for reporting and investigating “sensitive cases” – such as discrimination, child abuse and gender-based violence and harassment (GBVH), including human trafficking, multiple entry points to raise and address allegations (in person, in writing, via phone, email), and options to report anonymously without retaliation. The Company will appoint an adequately trained grievance officer, and establish survivor-centered referral pathways to provide free medical services, psychological support, and legal aid for all workers.	03/31/2026
8	AIA will require the EPC contractor to develop and implement contractor Occupational Health, Safety and Wellbeing Management Plan (OHSWMP) for construction including plans and procedures of a scale appropriate to the risks. The requirements defined within these documents will apply to all workers, including sub-contractors.	03/31/2026
9	AIA will update and implement their Occupational Health, Safety and Wellbeing Management Plan (OHSWMP) for operations, taking into consideration risks associated with operations of the Project	08/31/2026
10	a) AIA will develop a Contractor Management Plan defining their approach to managing the EHS performance of their contractors, subcontractors, and other third parties during the various phases of the project. The contractor management approach will be consistent with the general principles described within IFC Good Practice Note: Managing Contractors' Environmental and Social Performance.b) AIA will include legally binding obligations in the EPC contract for compliance with the requirements of project ESMS, C-ESMPs, national EHS and labor regulations, as well as IFC requirements. EPC will do the same for its sub-contractors. c) AIA will include in EPC contracts, a requirement to submit monthly workforce reports covering working hours, overtime, wage payments, training, grievances, union activity, accommodation, health and safety statistics, and other relevant labor data	03/31/2026
11	The company will hire a qualified consultant to undertake a labor audit at the peak of project construction to assess contractor and sub-contractor adherence to local labor laws and compliance with PS 2 requirements. The labor audit will also include an assessment of accommodation facilities provided by contractors/sub-contractors to ensure compliance with IFC/EBRD Good Practice Note on Workers’ Accommodation, internationally recognized life & fire safety standards, and to ensure adequate considerations have been made related to health, safety, and gender aspects.	06/30/2027
12	AIA will develop and integrate a flood risk assessment, Stormwater Management Plan and hydraulic modelling to quantify fluvial and pluvial risks from the Malaya Almatinka and Kotur-Bulak Rivers. The findings of this assessment will be used to inform drainage design and overflow planning, and reflected in updates to the Stormwater Management Plan.	06/30/2026
13	a) AIA will hire a competent consulting firm to conduct the soil and groundwater monitoring program, and prepare a comprehensive contamination assessment report, comparing sampling results with international recognized standardsb) AIA will prepare and submit a time-bound, costed, action plan, in form and substance aligned with IFC requirements for soil and groundwater remediation (if required).	01/31/2026
14	AIA will: (a) continue outreach to affected people exposed to nighttime noise level exceeding 60dbA; (b) implement a noise insulation program building upon the ongoing program and prioritizing vulnerable people;	12/31/2030
15	AIA will coordinate with governments authorities including the Civil Aviation Authorities to update and implement the Noise Management Plan (NMP) to mitigate noise impacts for all households exposed to night-time noise levels above 60 dBA, consistent with the International Civil Aviation Organization (ICAO) Resolution A33/7, Balanced Approach to Aircraft Noise Management (the “Balanced Approach”) and WBG EHS Guidelines for Airports.	12/31/2035
16	AIA will continue to proactively engage with governmental authorities for establishment of a SPZ and PSZ which will prevent further influx of new residents in these zones.	12/31/2030
17	AIA will carry out a Security Risk Assessment and update the SMP to incorporate additional risks associated with construction and operations. The plan will include training requirements, including on discrimination, GBVH, child abuse, and use of force in line with the Voluntary Principles on Security and Human Rights.	03/31/2026
18	Life and Fire Safety requirements will be incorporated in the design of the project to meet internationally recognized LFS standards (NFPA 101), and the design will be certified by an accredited LFS professional.	06/30/2026
19	Given the high rates of GBVH, and particularly human trafficking and sexual harassment in Kazakhstan, AIA will augment the grievance mechanism for all airport users and employees for reporting and investigating “sensitive cases” – such as discrimination, child abuse, gender-based violence and harassment (GBVH), and human trafficking. This mechanism will feature a standalone and accelerated procedure, offer multiple accessible and confidential reporting avenues (in person, by phone, in writing, and anonymously), and appoint trained grievance officers to sensitively receive and handle complaints.	03/31/2026