Anti-corruption
Management of material topics
The Company has created a Compliance Service. The main task of the division is to ensure compliance with mandatory regulator y requirements and international practices on issues of combating corruption, compliance with ethics and the formation of the Kazakhtelecom JSC internal corporate culture.
The Company has the following internal documents22:
- Anti-Corruption Policy;
- Whistleblowing Policy;
- Conflict of Interest Policy;
- Code of Business Ethics;
- Corporate Governance Code.
22 Compliance policies are available in the Compliance section of the Company’s Internet resource telecom.kz.
Anti-corruption at the Company is based on the following main principles:
- the legality of the Company’s operations;
- the public and openness of the Company’s operations;
- anti-corruption promotion among employees, partners and clients;
- cooperation in the area of anti-corruption activity with the state authorities, as well as the Company’s partners and clients;
- mandatory performance of official audits of violations of anti-corruption laws and the Company’s internal policies.
With a view to combating corruption in the reporting period, the Company used the following tools and mechanisms:
- Kazakhtelecom JSC’s Order No. 184 dd. 18.08.2022 “On distribution of powers and responsibilities of Kazakhtelecom JSC’s management” was amended with additions on personal liability for non-performance or improper performance of official duties on preventing corruption offenses by subordinate employees;
- Approved amendments to the Rules for selection of employees of Kazakhtelecom JSC in terms of provision of a list of affiliated persons of a candidate, certificate of criminal record, conclusion of polygraph examination (only for CEO-1 and CEO-2 supervising procurement issues), before appointment of candidates to vacant positions of CEO-1 and CEO-2, for the Compliance Service to conduct a check on a candidate;
- Additions were made to the Regulations on the Compliance Service of Kazakhtelecom JSC to extend the powers of the Service in terms of consideration of issues adopted at the level of the Management Board and the Board of Directors;
- Kazakhtelecom JSC’s Risk Register for 2022 included and approved the expanded list of compliance risks. In 2021, it included two main risks: the presence of conflicts of interest in the performance of official duties and the presence of corrupt practices and non-compliance with the code of ethics. In 2022, the risk of corrupt practices and non-compliance with the code of ethics was split into two separate risks with separate measures and response plans.
The last internal analysis of corruption risks was conducted in 2021 for procurement, recruitment, and business
processes. The next analysis of corruption risks is planned for 2023.
In 2022, the Company’s activities were analyzed to identify spheres of influence, collusion and other violations
that lead to shortfalls in profits and losses of the Company.
The analysis revealed the facts of falsification of lease agreements for placed equipment of Kazakhtelecom JSC, the
facts of sale of property at underestimated cost, violations of procurement procedures, as well as the facts of
unreasonable granting discounts to certain companies, violating the existing regulations. Materials were submitted
to law enforcement bodies.
Operations assessed for risks related to corruption
| Name | 2020 | 2021 | 2022 |
|---|---|---|---|
| Total number of structural units in relation to which corruption-related risks were assessed, pcs. | 0 | 4 | 0 |
| Share of structural subdivisions for which corruption-related risks were assessed, % | 0 | 70 | 0 |
In the reporting period, to improve compliance culture in the Company, the Compliance Service organized and conducted 41 training events in Kazakhtelecom JSC and subsidiaries aimed at popularizing the compliance function and raising the level of knowledge on combating corruption with the coverage of more than 6 thousand employees of the Company and subsidiaries.
Communication and training about anti-corruption policies and procedures
| 2020 | 2021 | 2022 | ||||
|---|---|---|---|---|---|---|
| Category of employees | people | % | people | % | people | % |
| Total number of informed members of key corporate governance bodies (General Shareholders Meeting, Board of Directors, Management Board) | 15 | 100 | 15 | 100 | 12 | 100 |
| Total number of informed employees | 20,000 | 100 | 20,000 | 100 | 18,662 | 93.4 |
| Total number of informed business partners | 0 | 0 | 0 | 0 | 0 | 0 |
The Head of the Compliance Service conducted review interviews on the information sites zakon.kz and kursiv.media,
revealing the main goals, objectives and results of the Service.
Technical training was conducted, within the framework of which the employees of all affiliated branches and Central
Administration Office (coverage of 18,662 employees — 93.4%) were familiarized with amendments to the
anti-corruption legislation of the Republic of Kazakhstan and the Anti-Corruption Policy of Kazakhtelecom JSC in
terms of responsibility of managers for committing corruption offences by subordinate employees.
Number of employees by category who received anti-corruption training in 2022
| Category of employees | People | Share, % |
|---|---|---|
| Total number of members of key corporate governance bodies (Board of Directors, Management Board) who were trained | 12 | 100 |
| Total number of employees trained (by category): | 18,662 | 93.4 |
| – In managerial positions | 1,074 | 93.6 |
| – Specialists | 12,305 | 88.8 |
| – Employees | 5,283 | 99.6 |
The number of employees by category is different from the number of employees in the general list, because data as
of the date of training was taken.
The Company does not make payments to political parties, organizations or their representatives and does not
participate in political activities.
In 2022, the Compliance Service did not identify any instances of corruption.
Reporting mechanisms for unethical or illegal conduct are governed by the Whistle-Blowing/Reporting Policy, under
which the Company guarantees full confidentiality to employees, business partners and other interested parties who
have reported serious problems at the Company, as well as the absence of harassment and/or discrimination.
The Company operates a hotline through its parent company Samruk-Kazyna JSC, which is serviced by an independent
operator, KPMG, to ensure its efficiency. The hotline guarantees confidentiality and anonymity (at the request of
the contacted person), as well as registration and processing of 100% of appeals with subsequent submission to
responsible persons. The Company’s internal and corporate websites contain hotline and Compliance Service contacts
that can be used to report any facts of labor, corruption, and other types of offenses.
In 2022, 170 reports on the following topics were considered:
- non-performance of contractual obligations;
- unfair wages;
- unequal employment and working conditions;
- violations of procedures, abuse;
- Procurement violations.
The Compliance Service examines appeals and received materials. If there are signs of a criminal offence, the
Compliance Service sends them to the Management Committee for financial and economic discipline of Kazakhtelecom JSC
under the guidance of the Chairman of the Management Board. Members of the Management Committee take a decision on
transferring materials to law enforcement bodies.
Each fact recorded in the Compliance Service is reflected in the quarterly report for the report to the Board of
Directors. There were no critical problems in the reporting year.
Plans for 2023 and the medium term
- Conducting internal analysis of corruption risks in procurement, hiring, evaluation, promotion and dismissal of employees and other business processes.
- Organizing and conducting training sessions for members of the governing bodies and the executive body of the Company and the SAO on anti-corruption issues, demonstrating the latest trends in compliance and corporate culture.
- Holding training sessions for the heads of the Company’s branches and structural subdivisions (СЕО-1, СЕО-2 level) and the first heads of subsidiaries and affiliated organizations (SAO) for the organizations’ employees on anti-corruption issues.