ҚАЗРУСENG

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 2025, the Compliance Service of the Fund continued the development of the compliance function in the Group of Companies of the Fund. The work was aimed at 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 Fund’s Compliance Service actively participated in the development of regulatory initiatives related to the advancement of the compliance function in both the quasi‑public and private sectors, as well as in working meetings with government authorities and representatives of the business community, thereby contributing to the development of modern approaches to strengthening the compliance institution at the national level.

Results of the Compliance Service in 2025:

  • In order to establish a robust and effective evaluation framework, developed and approved the Methodology for Assessing the Effectiveness of the Compliance Function of the Group of Companies of Samruk-Kazyna JSC (approved by Resolution of the Fund’s Management Board No. 30/25 dated 26 June 2025). The Methodology sets out unified approaches, criteria, and procedures for assessing compliance functions across the Fund’s group companies with respect to adherence to the Corporate Standard on the Compliance Function of Samruk-Kazyna JSC Group (approved by Resolution of the Management Board dated 21 December 2023, Minutes No. 60/23), as well as compliance with anti-corruption legislation and leading international practices, including ISO 37001:2025 Anti-Bribery Management Systems and ISO 37301:2021 Compliance Management Systems.
  • To further strengthen the compliance risk management framework across the Fund Group, the Corporate Standard on the Compliance Function was supplemented with Appendix No. 9: Rules for Screening Potential Suppliers for Affiliation, Suspended Operations, and Restrictions Provisioned by the Procurement Procedures of the Samruk-Kazyna Group. In addition, a Roadmap for the implementation of a pilot project and the phased rollout of a system for screening potential suppliers for affiliation and suspended operations within the portfolio companies of Samruk-Kazyna JSC for 2025–2026 was approved to ensure the effective and structured introduction of these procedures.
  • Work continued on the development and support of the E‑Compliance information system. The system provides centralised automation of key compliance processes of the Fund and its portfolio companies, including compliance risk management, analytics generation and management reporting. E‑Compliance consolidates all reporting on the activities of the compliance function, including data on requests, incidents, identified violations, corrective actions and assessments of the effectiveness of compliance units. During the reporting period, the integration of E‑Compliance with the Fund’s digital platform Qsamruk.kz was completed, enabling automated integrity checks of candidates and ensuring end‑to‑end integration of HR and compliance procedures.
  • With respect to training initiatives, in 2025 the Fund’s Compliance Service developed and delivered the online courses Business Ethics and Anti‑Corruption Policy and Requirements of Anti‑Corruption Legislation of the Republic of Kazakhstan, followed by testing, including the resolution of practical case‑based scenarios.

Plans for 2026

In 2026, the Compliance Service will focus on further strengthening the compliance function across the Group of Companies by improving the methodological framework, fostering an anti‑corruption culture, advancing the digitalisation of compliance processes, and enhancing the identification and management of compliance risks in the Fund’s operations.