KEGOC JSC adheres to the policy of zero tolerance for corruption in any of its manifestations in cooperation with all stakeholders and to concealment of corruption offences. The Company excludes any form of bribery, including offering or receiving material remuneration, benefits, or services of property, physical or moral nature for performing work or rendering services for actions (inaction) in favour of the persons who provided them, if such actions (inaction) are within the authority of the Company’s employees. Employees of the Company do not provide and do not accept hospitality or gifts, which may further entail any obligations of the parties. Officials and employees involved in corruption cases are subject to dismissal and prosecution in accordance with the procedure stipulated by the legislation of the Republic of Kazakhstan.

As part of corruption risk management, the main factors of its occurrence have been identified:

• use of his official powers and related opportunities to obtain property benefits;
• abuse in procurement procedures of goods, works and services, as well as in relations with clients, suppliers, and contractors of KEGOC JSC;
• use of the Company’s material resources for personal benefit or enrichment;
• lack of comprehensive and targeted information work to form an anti-corruption model of behaviour among the Company’s employees and a public atmosphere of rejection of corruption;
• giving bribes or other remuneration to third parties;
• poor response to incidents of a corrupt nature.

In its day-to-day activities, KEGOC JSC complies with the requirements of anti-corruption legislation and takes maximum organisational and practical steps aimed at uncompromisingly combating corruption in any of its forms and manifestations and managing corruption risk. Contracts with the Company’s counterparties contain obligations of the parties and their employees to combat corruption — the parties undertake to ensure the implementation of procedures for conducting compliance audits to prevent risks of involvement in corrupt activities.

In 2023, a new version of the Code of Conduct (business ethics) of KEGOC JSC was approved due to changes in the administrative and criminal legislation of the Republic of Kazakhstan, as well as the implementation of the concluded framework agreement between KEGOC JSC and the European Bank for Reconstruction and Development dated 29 March 2023 in terms of ensuring prohibition of any form of harassment in the workplace, as reflected in the Social Environmental Action Plan under the bond programme.

On 30-31 March 2023, KEGOC JSC employees were tested for knowledge of the provisions of the Code of Conduct (business ethics). A total of 597 KEGOC JSC employees passed the test, scoring an average of 20.7 out of 25 points. This result indicates an excellent understanding by KEGOC JSC employees of the basic norms of the Code of Conduct (business ethics).

In 2023, work was carried out to implement the international standard ISO 37001:2016 ‘Anti-corruption management systems. Requirements and Recommendation for Application’: the Anti-Corruption Management System Manual was developed, which became the fundamental document of the anti-corruption management system and describes the anti-corruption management procedures at KEGOC JSC.

All Company employees (100%) are familiarised with anti-corruption documents. The Company’s officials accept anti-corruption restrictions by signing commitments to comply with anti-corruption legislation. Work is carried out to comply with the Action Algorithm for the implementation of the institute of resignation and prosecution of managers for corruption offences committed by their subordinates.

Within the framework of forming of KEGOC JSC anti-corruption culture and intolerance to corruption manifestations, special attention is paid to preventive and prophylactic work aimed at reducing corruption risks. Thus, in 2023, the Compliance Service conducted training on the topic ‘Formation of integrity and anti-corruption culture. Strengthening public control in corporate governance’. During the training, the main objective was to raise employees’ awareness of the compliance function, popularise the Hotline, the provisions of KEGOC JSC Anti-Corruption and Fraud Regulations, and build interaction with the management of territorial branches and substations.