Compliance
The unified compliance function, covering the Fund and portfolio companies, sets the anti-corruption policy, oversees the delivery of the relevant measures, shapes a corporate culture based on the principles of transparency and integrity, and ensures that activities are conducted in accordance with the legislation of the Republic of Kazakhstan and international best practice.
The activities of compliance services are governed by the Code of Conduct, the Anti-Corruption Policy, the Conflict of Interest Resolution Policy, the Whistleblowing Policy, the Rules on Third-Party Due Diligence and other internal documents supporting the compliance programme.
The Fund's Compliance Service is an independent structural unit, organizationally subordinate to and functionally accountable to the Fund's Board of Directors. The Service coordinates the activities of the compliance services of portfolio companies, communications and training, supports the whistleblowing channel (Hotline), conducts checks and investigations, and identifies and resolves conflicts of interest. Violations are considered material if they involve major financial or non-monetary sanctions, are upheld by a court, or cause damage to reputation, the environment, and human rights.
To automate and centralise third-party due-diligence procedures and assessment of counterparty affiliation, a digital tool – E-Compliance – is used. To improve user accessibility and responsiveness, a digital compliance assistant based on artificial intelligence has been integrated into the system.
As part of further development, in 2026 it is planned to expand the system's functionality with new modules, including a compliance-risk register and tools for anti-corruption monitoring and internal corruption-risk analysis.
In 2025, we carried out a systematic update of our methodological framework. The Methodology for Evaluating the Effectiveness of the Group's Compliance Function has been approved, setting out unified criteria for compliance with corporate requirements, anti-corruption legislation and the international standards ISO 37001 and ISO 37301.
The Corporate Standard on the Compliance Function has been updated in relation to handling enquiries, conducting internal investigations and checking suppliers. The Whistleblowing Policy has been refreshed: the categories of violations, the procedure for reviewing reports and the protection measures for good-faith whistleblowers have been clarified.