Anti-corruption
The Company follows the principles of integrity, transparency and responsibility. Kazakhtelecom and its subsidiaries and affiliates, as well as all their employees are obliged to comply with the requirements of the anti-corruption legislation of the Republic of Kazakhstan and the principles of ethical business conduct.
Management approach
The Company’s Compliance Service continues to function effectively. The main task of the Compliance Unit is to prevent and detect violations of anti-corruption legislation and Kazakhtelecom’s internal documents.
The Compliance Service also pays great attention to issues of ethics and behaviour and does not tolerate cases of humiliation and discrimination of employees by management both in Kazakhtelecom itself and in its subsidiaries. Where such breaches are identified, compliance takes steps to hold unscrupulous managers to account. In this matter, the compliance department has the support of both the Chairman of the Company’s Management Board and the senior management of the subsidiaries.
The Company has introduced the following internal documents regulating anti-corruption compliance procedures:
- Anti-Corruption Policy (updated in 2023)
- Whistleblowing Policy
- Conflict of Interest Policy
- Business Ethics Code
- Corporate Governance Code
The documents are available on the Company’s website telecom.kz in the Sustainable Development section, Anti-Corruption subsection.
The Company bases its anti-corruption efforts on the following key principles:
- legality of the Company’s activities;
- publicity and openness of the Company’s activities;
- anti-corruption propaganda among the Company’s employees, partners and customers;
- co-operation in the field of anti-corruption activities with state bodies, as well as partners and customers of the Company;
- mandatory internal audits of violations of anti-corruption legislation and Company’s internal policies;
- protection and encouragement of persons assisting in anti-corruption activities;
- adherence of Officials to the principles of anti-corruption stipulated in this Policy and setting the “tone from above”;
- inevitability of punishment for committing corruption offences.
Main areas of anti-corruption efforts in 2023
In 2023, the main areas of compliance work in anti-corruption were as follows:
- updating the Anti-Corruption Policy;
- internal analysis of corruption risks;
- training of employees;
- feedback channels;
- co-operation with subsidiaries and affiliates.
In 2023, we updated the Anti-Corruption Policy, which establishes the types of corruption offences, anti-corruption goals, objectives and principles, as well as the responsibility of employees and managers at all levels for corruption offences.
The Company has also defined and approved by Orders (Central Administration and branches) lists of positions with a high risk of committing corruption offences, with special, increased requirements for acceptance/appointment to these positions, including acceptance of consent to anti-corruption restrictions. Kazakhtelecom developed a remote online training course on the Anti-Corruption Policy and posted it on the internal portal learning.telecom.kz for the Company’s employees.
In 2023, Kazakhtelecom JSC carried out an internal analysis of corruption risks for 2022.
The internal analysis of corruption risks was conducted in the following areas:
- procurement activities;
- HR management;
- business processes in the Company.
Subdivisions and business processes, in respect of which corruption risks were assessed
The results of the internal analysis of corruption risks with recommendations on their elimination were sent to the Chairman of the Management Board of Kazakhtelecom JSC.
Based on the results of the analysis, we prepared and approved the Action Plan to eliminate causes and conditions that contribute to corruption offences.
At the end of the reporting period, we recorded no confirmed cases of corruption and bribery in Kazakhtelecom JSC and subsidiaries and affiliates.
Awareness of anti-corruption policies and practices, 2021-2023
Training on anti-corruption issues
The Company regularly conducts anti-corruption training for employees. All new employees undergo a mandatory online introduction course on the basic principles of the Code of Business Ethics and Anti-Corruption Policy.
In 2023, all managers of branches and subsidiaries and affiliates held communication training sessions aimed at combating corruption, fraud and other compliance risks.
In connection with the updating of the Anti-Corruption Policy of Kazakhtelecom JSC and introduction of additional norms of anti-corruption restrictions in accordance with the amendments to the anti-corruption legislation, we organised technical training covering 100% of employees of all branches and Central Administration.
In 2023, the Company held a training session for members of the governing bodies and executive body of Kazakhtelecom JSC and subsidiaries and affiliates on anti-corruption issues, where we demonstrated the latest trends in compliance and corporate culture.
In 2023, the Head of the Compliance Service conducted review interviews on the information platforms zakon.kz and kursiv.media to disclose the main goals, objectives and results of the Compliance Service’s activity.
Number of employees by category who received anti-corruption training in 2023
Feedback channels
The Company’s mechanisms for reporting unethical or illegal behaviour are governed by the Whistleblowing Policy.
The Company operates a hotline, an independent, confidential and anonymous channel for reporting actual or potential violations of the law, including fraud, corruption, discrimination, unethical behaviour and other violations. The hotline operates through the parent company Samruk-Kazyna JSC and is maintained by an independent operator (KPMG).
The hotline guarantees confidentiality and anonymity (at the request of the contacted person), as well as registration and processing of 100 per cent of requests with subsequent submission of reports to responsible persons.
The Company guarantees confidentiality for employees, business partners and other stakeholders who have reported wrongdoing to the Company, as well as the absence of harassment and/or discrimination.
In 2023, the hotline received 105 appeals (51 were confirmed).
The main topics of appeals:
- violations of procedures for connecting services;
- unequal employment and labour conditions;
- abuse;
- unethical behaviour;
- unfair labour remuneration.
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 on financial and economic discipline of Kazakhtelecom JSC under the guidance of the Chairman of the Management Board. Members of the Management Committee decide on transferring materials to law enforcement bodies.
Each fact recorded in the Compliance Service is reflected in the quarterly report for reporting to the Board of Directors. There were no critical issues in 2023.
The Company’s internal and corporate websites contain contacts of the hotline and the Compliance Service, for reporting any facts of labour, corruption and other types of offences.
Feedback channels for reporting violations of the Anti-Corruption Policy:
Hotline
Plans for 2024 and the medium term
- Organising and conducting training events on compliance issues.
- Ensuring timely detection and settlement of conflicts of interest.
- Dealing with 100 % of requests submitted through the confidential information line.
- Visiting the regions to popularise the Compliance Service among the Company’s employees (Mobile Office of the Compliance Service).
- Carrying out the initial certification audit of the Company and subsidiaries and affiliates in accordance with ISO 37001 Anti-Bribery Management System. Requirements and guidelines for use.