Annual Report / 2023
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Corporate governance
Management structure of the Company General Meeting of Shareholders Dividend Policy Rights of Minority Shareholders Report on the Activities of the Board of Directors
Professional development Compliance with the Corporate Governance Code Executive Body Management appraisal and remuneration Conflict of interest
Corporate ethics Anti-Corruption Risk management and internal control systems Internal Audit Service Information policy and security

Corporate ethics

Corporate ethics is a key element that unites our employees.

The purpose of corporate ethics is to regulate relations between employees within the framework of a single team and is formed on the basis of generally accepted human values:

  • competence and professionalism (the Company’s employees have quality education, work experience, decision-making skills, and aspiration to improve their professional level);
  • honesty and impartiality (an important aspect of the organization’s activities, preserving its business reputation and avoiding conflicts between personal interests and professional activities);
  • responsibility as a guarantee of the quality of our Company’s activities;
  • respect for human personality (every employee of KEGOC JSC has the right to be treated fairly and honestly regardless of race, language, political and religious beliefs, gender, nationality and culture);
  • safety, which is characterized by striving to preserve trade secrets and ensuring non-harmful and non-hazardous working conditions.

The Code of Conduct (business ethics), which is a set of practical rules to be followed by each employee in his or her daily activities, is binding on all employees of the Company, including senior managers. The Code of Conduct has been developed on the basis of generally accepted norms of corporate ethics and business behavior and documents defining the best practices of corporate governance. The Code of Conduct applies to all structural subdivisions, branches of the Company and subsidiaries. Familiarization with the provisions of the Code of Conduct for all employees of the Company, including officials, is carried out on a regular basis upon hiring and when changes are made to the Code of Conduct.

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The Company continues to employ an Ombudsman reporting to the Board of Directors, one of whose tasks is to ensure compliance by employees and officers with the Code of Conduct and to explain its provisions. The main principles of the Ombudsman’s work are independence, neutrality and impartiality, confidentiality and informality.

To monitor the moral and psychological climate in the Company’s labor collectives and employees’ awareness of the norms and requirements of the Code of Conduct (business ethics), an anonymous survey was organized during the reporting year.

The employee survey showed the following (the survey coverage was over 1,900 people from all branches or over 50% of employees):

  • the opinion of employees (97.7%) about the moral and psychological climate and the situation in the team is generally positive, employees can count on help and support from the management, and there is mutual trust;
  • direct supervisors are objective in their relations with subordinates, and there is no pressure;
  • employees are recognized as having the right to participate in making decisions that are important for their work; there are no requirements to perform tasks outside the scope of their job responsibilities;
  • employees are informed where they can turn in case of conflicts.

In the areas identified for improvement in labour relations and human rights, the Ombudsman developed and implemented a plan in 2023, under which the following activities were carried out:

  • The Ombudsman visited 9 branches, including their territorial subdivisions.
  • Meetings were held with the staff of the branches, including substations of Yuzhnye MES, Almatinskiye MES, Akmolinskiye MES, Tsentralnye MES and branches of Energoinform JSC. Employees were explained the necessity of observing of ethical norms and rules of behavior by KEGOC employees. The goals and objectives of the Code of Conduct (business ethics) were explained, communication channels (telephone numbers of the Ombudsman, HRMD, hotline operated by an independent company KPMG Tax & Advisory LLP, Nysana Call Centre) were provided, and information and explanatory work on the resolution of social and labour disputes was carried out — the provisions of ‘Basic Rights and Obligations of Employees’ and ‘Basic Rights and Obligations of Employer’ of the Labour Code of the Republic of Kazakhstan were explained, as well as the Company’s internal regulatory documents and procedures on prevention and mitigation of social and labour disputes were explained.

The work was carried out in order to assist in the formation of a corporate culture of relations that would comply with generally accepted moral and ethical norms in the team, as set out in the Code of Conduct (business ethics) among the Company’s employees and officials. In addition, workplaces were inspected in terms of labour conditions, and employee re­creation areas, during visits to the above-mentioned branches with employees.

In 2023, the Ombudsman:

  • took part in the Forum of trade union leaders and corporate ombudsmen on the topic ‘Social partnership and assistance in ensuring social stability and social harmony on the basis of objective consideration of the interests of the Employee and Employer’ organized by the Centre for Social Interaction and Communications of Samruk-Kazyna JSC.
  • took part in the Forum on Social and Labour Communications in the Group of Companies of Samruk-Kazyna JSC ombudsmen of portfolio companies, chairmen of trade unions of PCs and affiliated subsidiaries, heads of IR PCs and subsidiaries and affiliates, and internal mediators of the Group of Companies of Samruk-Kazyna JSC;
  • trained Ombudsmen of PCs and subsidiaries and affiliates of Samruk-Kazyna JSC on the topic ‘Methods and organization of negotiations in managing labour conflicts’.

The procedure for consideration of employee appeals is regulated by the Regulations on the Ombudsman of KEGOC JSC, according to which the Ombudsman has the right to request and receive information, materials and explanations from employees, officials, Head of the Internal Audit Service and Compliance Service necessary for consideration of the appeal in accordance with the established procedure. Having accepted the appeal for consideration, within 5 (five) working days, the Ombudsman shall explain the ways and means that the applicant may use to protect his/her rights and/or eliminate violations of the norms of conduct and/or decisions or actions (inaction) taken in violation of the norms of conduct. The Ombudsman is also obliged to transfer the appeal to the Company’s bodies, whose competence includes the resolution of such appeals.

In 2023, the Ombudsman of KEGOC JSC received 12 appeals, including 8 appeals via the Nysana Call Centre and in person during visits to branches. For each appeal the applicants were provided with answers in accordance with the procedure established by the Company’s internal documents and the legislation of the Republic of Kazakhstan.

At the same time, no violations of human rights were detected, and in 2023, no cases of filing lawsuits by the Company’s employees for non-compliance with labour legislation were recorded.

The Ombudsman submits a quarterly report to the Board of Directors on all appeals and measures taken on appeals of the Company’s employees and officials.

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