Social and Environmental Policy Version 2.3 of September, 2025 Public
document. Level A.

Contents

Social and Environmental Policy Version 2.3 of September, 2025

2

Revision
History.......................................................................................
3
Purpose....................................................................................................
3
Scope.......................................................................................................
3
Introduction.............................................................................................
3 Sustainability
Vision...........................................................................
3 Sustainability
Compliance.................................................................
3 Goals and objectives / Sustainability
targets.................................. 4
Policy.......................................................................................................
4 DataArt
People...................................................................................
4 Value-Based Communications and Management...................... 4
Equal Opportunities and
Diversity................................................ 4 No
Discrimination, Harassment or Bullying.................................
4 No Child or Forced
Labor............................................................. 5
Comfortable and Safe Working
Place......................................... 5 Professional
Development / Talent Management....................... 5 Society and
Communities..................................................................
5 Knowledge
Sharing.......................................................................
6 Public Health and
Wellbeing........................................................ 6
People Empowerment and
Inclusion............................................ 6 Data Privacy
Measures..................................................................
6
Transparency..................................................................................
6 Dialogue and Support of Local
Communities.............................. 7 Helping War-Torn
Societies.......................................................... 7
Environment.........................................................................................
7 Carbon
Footprint............................................................................
7 Reduction of Energy
Consumption................................................ 8 Shift to
Low Carbon
Energy.......................................................... 8 Green
Travel and
Commute.......................................................... 8
Promoting Sustainable Hotel
Services.......................................... 8 Green IT
hardware........................................................................
8
Recycling........................................................................................
8 Buy
Local........................................................................................
8 Supply
Chain..................................................................................
9 Environmental and Climate-Related Partnership.........................
9
Responsibilities....................................................................................
9

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Revision History Purpose Scope Introduction

Date 07/2020 08/2021 09/2022 09/2023 09/2024 09/2025

Version Comments

Approved By

1.0 Initial version

Andrey Shklyarov

1.1 Annual review

Andrey Shklyarov

2.0 Responsibilities are updates. Paragraphs Andrey Shklyarov about
privacy, support of local communities, climate partnership and helping
war-torn societies added

2.1 Annual review. Minor changes.

Andrey Shklyarov

2.2 Environmental part rework.

Andrey Shklyarov

2.3 Responsibilities section is amended. Minor Andrey Shklyarov changes.

The purpose of this document is to -- define the primary goals and the
focus areas for DataArt regarding environmental and social issues, and
-- establish and maintain the framework to efficiently manage
sustainability activities. The policy applies to DataArt staff in all
locations, DataArt supply chain, and DataArt processes that affect
social or environmental aspects of DataArt's business. Sustainability
Vision DataArt promotes the integration of sustainability into business
processes and throughout the value chain, based on creating a shared
value concept defined in DataArt Sustainability Manifesto.
Sustainability Compliance In accordance with DataArt Compliance Policy,
DataArt is committed to compliance with legislation in all geographies
where we operate. We also accept the following groups of standards as a
guidance for sustainability management at DataArt: -- IFC Performance
Standards on Environmental and Social Sustainability;

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Policy

Social and Environmental Policy Version 2.3 of September, 2025

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-- The Sustainable Development Goals (SDGs) of the 2030 Agenda; -- UN
Conventions on environment and labor; -- International Labor
Organization (ILO) documents. Goals and objectives / Sustainability
targets DataArt accepts the risks and impacts mitigation hierarchy
covering environmental and social issues with special focus to DataArt
People, professional society and local communities company operates in,
surrounding environment and global climate.

DataArt People

UN Goals -- Goal 5: Gender equality; -- Goal 8: Decent work and economic
growth.

DataArt uses a systemic approach to how work, human resource management,
and staff wellbeing are organized and provided in the company. The
approach covers areas as follow below.

Value-based communications and management DataArt maintains high
standards for ethics, personal and professional behavior that are based
on company's values and ensure comfortable and productive work
relationship between DataArt people.

Equal Opportunities and Diversity We are committed to promoting equal
opportunities and diversity in employment. Any job applicant will
receive equal treatment regardless of age, disability, gender
reassignment, marital or civil partner status, pregnancy or maternity,
race, color, nationality, ethnic or national origin, religion or belief,
sex or sexual orientation. For more details, please turn to Our
Commitment to Diversity and Inclusion.

No discrimination, harassment or bullying The Company is committed to
creating a workplace that is free of harassment and discrimination,
where co-workers, candidates and

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Social and Environmental Policy Version 2.3 of September, 2025

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other stakeholders are respected, and which provides an appropriate
environment to encourage good performance and conduct at all its working
locations, at all times. No Child or Forced Labor DataArt is committed
to compliance with local and international anti-slavery, human
trafficking and child labor laws, following all international guidelines
and national labor legislative requirements. Comfortable and Safe
Working Place DataArt has established and maintains high standards to
office environment in terms of comfort and safety. Corporate Business
Continuity and Disaster Recovery program has staff wellbeing and safety
as its key components. We provide extensive medical insurance and have
mental help programs. Professional Development / Talent Management
DataArt consistently invests in professional development of employees
and has a state-of-art education approach coordinated by a
cross-function group at corporate level. That includes, but not limited
to, an internal EDU platform, language courses, professional development
programs and certifications.

Society and Communities

UN Goals -- Goal 3: Good health and wellbeing; -- Goal 4: Quality
education; -- Goal 11: Sustainable cities and communities

DataArt actively manages relationships with both internal and external
communities, extending capacities and creating new opportunities.
Company develops and implements educational initiatives and measures for
improvement in health and wellbeing of communities and society.

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Knowledge Sharing DataArt is a community of highly educated in science,
technology, engineering and math people and is uniquely positioned to
share their knowledge and experience with other people around the world
as well as promote free mechanisms for self-education. Public Health and
Wellbeing DataArt recognizes the importance of Public Health and
Wellbeing and provides inputs through health and safety initiatives,
anti-epidemic measures, conducting respective public awareness seminars,
and supporting local industry sport events. People Empowerment and
Inclusion Being 20+ years on the market, DataArt aims to empower people
who work or want to work in IT industry with long-term and shortterm
programs and events. We help them to grab a better knowledge of the
industry and its history, get a better understanding of how it helps
communities and people around the world, and what people can do to move
the industry forward to the bright future. Data Privacy Measures We
treat data privacy as one of the core tasks so our clients, partners,
candidates and staff members can rely on us during cooperation. DataArt
has established Personal Data Protection Policy which ensure that
DataArt collects and processes personal data about employees, customers,
suppliers and other third parties in compliance with international and
local data protection procedures to provide confidentiality, integrity
and availability of personal data. Transparency DataArt has a wide range
of processes and tools to collect, analyze and take actions based on the
feedback of DataArt people and external stakeholders. The processes
include Grievance mechanism, internal communication with company
management, surveys, forums, and whistleblowing mechanism.

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Dialogue and Support of Local Communities DataArt on its way to become
an international company has learned how important it is to understand
the problems of local communities and is determined to help our staff
members who try to make life in the regions better by leveraging DataArt
global IT expertise. Helping War-Torn Societies DataArt has realized
that war in the XXI century remains an eminent threat with several
locations such as Ukraine and Armenia finding themselves in the
environment of an active armed conflict. DataArt management and its
staff members are committed in helping these societies in their efforts
to overcome the destructive consequences of a modern-day armed conflicts
through such initiatives as Support Ukraine described in Support Ukraine
Policy.

Environment

UN Goals -- Goal 12: Responsible consumption and production; -- Goal 13:
Climate action

DataArt knows that man-made climate change is real and that it poses a
great threat to the planet and its inhabitants. DataArt takes
responsibility for climate, waste, energy, water and other natural
resources. That is why DataArt is committed to aligning its
sustainability efforts with the Science Based Targets initiative (SBTi)
to limit global warming to 1.5°C above pre-industrial levels. DataArt
set science-based greenhouse gas emission reduction targets across our
entire value chain. This commitment reflects DataArt's dedication to
being accountable, transparent, and proactive in our approach to
environmental stewardship. For this purpose, DataArt is determined to
take the following measures adopted in its Climate Action Plan:

Carbon Footprint DataArt cares about carbon footprints we leave and is
determined to build capabilities in assessing Scope 1, Scope 2 and Scope
3 carbon emissions associated with all of the DataArt operational
activities.

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Reduction of Energy Consumption DataArt is determined to reduce its
actual energy consumption by 50 % through the reduction and optimization
of office space and expansion of work from home scheme. Shift to Low
Carbon Energy DataArt is committed to a transition to renewable energy
for its offices and other facilities by purchasing renewable energy
certificates (RECs) and urge stakeholders to concluded power purchase
agreements with the renewable or low carbon energy providers. Green
Travel and Commute DataArt is committed to reducing business travel CO2
emissions by such measures as promoting video-conferencing, prioritizing
trains and EV over planes and internal combustions vehicles, as well as
through carbon offsetting. DataArt is also committed to calculate and
improve the climate impact of all business trips. Promoting Sustainable
Hotel Services DataArt is committed to reduce CO2 emissions from hotel
services by such measures as prioritizing low carbon footprint hotels or
hotels with carbon offsets. Green IT hardware DataArt is committed to
reduce CO2 emissions from IT hardware purchases by such measures as
prioritizing low carbon footprint and high energy-efficient IT hardware.
Recycling DataArt is committed to adoption of waste separation,
increasing share of equipment that can be recycled and be compliant with
requirements on recycling wastes such as batteries and electrical and
electronic equipment. Buy Local DataArt is committed to adopting "buy
local" principle for certain goods and materials to ensure the reduction
of climate impact that

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DataArt's supply chain produces within goods and materials
transportation. Supply Chain DataArt is committed to encourage own
Supply Chain to implement and follow sustainable practices as described
in our Code of Sustainable Supplier. Environmental and Climate-Related
Partnership DataArt desires to form the culture of respect for
environment and our planet by promoting and supporting such local
environmental and climate-related initiatives of its staff members or
communities. Responsibilities DataArt Social and Environmental
Responsibility function is responsible for the implementation of this
policy. More detailed information about policy implementation and
corporate programs is included into DataArt annual Sustainability Report
which can be found on the corporate website.

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