Compliance Service

The Compliance Service of Samruk-Kazyna JSC in its activities is guided by the Regulations on the Compliance Service of the Fund, the new version of which was approved by the decision of the Board of Directors of Samruk-Kazyna JSC dated 20 May 2024 No. 235, anti-corruption legislation of the Republic of Kazakhstan and best international practices in the field of compliance and anti-corruption.

The main purpose of the Compliance Service of the Fund is to ensure compliance with the anti-corruption legislation of the Republic of Kazakhstan, development of the compliance programme, including coordination of activities of the compliance services of portfolio companies, communications and training, support of the proactive information line (hotline), inspections and investigations, interaction with third parties, identification and settlement of conflicts of interest, development of other areas of compliance in the group of companies of the Fund.

In 2024, the Compliance Service of the Fund continued the development of the compliance function in the Group of Companies of the Fund, automation of individual elements of the compliance programme at the level of the Group of Companies of the Fund and development of interaction with the regulator, increasing the transparency of the activities of the Group of Companies of the Fund.

The Fund's management carries out systematic work aimed at promoting the ideology of integrity and strengthening public control in the corporate governance of the Fund. The Fund's management also sets the right "tone from the top", emphasises the need to comply with legal requirements and compliance policies.

The Head of the Compliance Service of the Fund takes an active part in standard-setting work on the compliance function in the quasi-public and private sectors, meetings with government agencies and the business community.

RESULTS OF THE COMPLIANCE SERVICE IN 2024:

• In connection with the amendments made to the Law of the Republic of Kazakhstan On Combating Corruption, as well as the approval in December 2023 of the Corporate Standard on Compliance Function of the Fund (hereinafter – the Corporate Standard), a new version of the Anti-Corruption Policy of Samruk-Kazyna JSC was approved on 20 May 2024.
• By the decision of the Board of Directors of the Fund dated 20 May 2024, restated Regulations on Compliance Service of Samruk-Kazyna JSC were approved.
• On 11 March 2024, the Instruction on combating corruption in Samruk-Kazyna JSC, developed by the Compliance Service in accordance with the provisions of the Law of the Republic of Kazakhstan "On Combating Corruption".
• By the decision of the Management Board of the Fund dated 26 December 2024, amendments and additions to the Corporate Standard on the Compliance Function of the Samruk-Kazyna JSC Group were approved, taking into account the analysis of the work of the Compliance Services of the Fund Group.
• In order to develop proposals to improve the methodology and reporting, to discuss problematic issues arising in practice, a Working Group was formed consisting of the Heads of Compliance Services of the Compliance Group of the Fund under the chairmanship of the Head of the Compliance Service of the Fund.
• The Organisation for Economic Co-operation and Development (OECD) has completed the 5th round of monitoring of Kazakhstan legislation under the Istanbul Action Plan against Corruption. The monitoring includes critical areas such as procurement transparency and combating corruption in the quasi-public sector.
• All companies have adopted anti-corruption standards and implemented comprehensive measures to ensure integrity and prevent corruption. The issues of transparency and openness were separately noted. All assessed companies of the Fund publicly disclose information on financial and operational results, significant transactions with third parties, implementation of anti-corruption compliance programmes, as well as provide channels for whistleblowers and reporting violations of anti-corruption rules.
• The Fund's Compliance Service continues to automate the compliance function. The E-Compliance system has been put into operation, the main purpose of which is to automate compliance processes in terms of full and comprehensive review of appeals received by the Hotline, verification of counterparties, including access to information on counterparties contained in state databases, determination of risk level, formation of standard conclusions and storage of verification results through a single interface with access for all companies of the Fund's group.
• In terms of training activities, in 2024, the Fund's Compliance Service developed and launched an online course "Business Ethics and the Role of Senior Management in the Corporate Compliance System".
• To improve the competences of the employees of the Compliance services of the Fund's Group, a training programme "Compliance Expert" was launched on the basis of Samruk Business Academy.

PLANS FOR 2025:

In 2025, the Compliance Service will continue further development of the compliance function in the Group of Companies, including improvement of the methodological framework and formation of anti-corruption culture, further digitalisation of the compliance function, identification of compliance risks in the Fund's activities and development of a methodology for assessing the efficiency of the compliance function of the Fund's portfolio companies.