Compliance Service

The Compliance Service is the structural subdivision of the Fund that ensures compliance with the anti-corruption legislation of the Republic of Kazakhstan, defines anti-corruption policy, monitors the implementation of anti-corruption measures, as well as forms the internal corporate culture based on transparency and honesty, conducts business in compliance with the legislation of the Republic of Kazakhstan, best international practices and internal documents of the Fund.

The Service generally coordinates and interacts with Compliance Services of Portfolio Companies, including providing recommendations on the development of centralized compliance controls, reviewing periodic reports of Compliance Services of the Fund group of companies, preparing consolidated reports on existing compliance risks, training in order to form an anti-corruption culture and other relevant issues in the field of compliance.

In its activities, the Compliance Service is guided by the Law of the Republic of Kazakhstan “On Combating Corruption”, the Anti-Corruption Policy, the Code of Conduct and other internal documents of the Fund.

According to the results of 2022 the Compliance Service:

• Considered 855 appeals received by the Hotline;
• conclusions were issued on the materials reviewed, including on the materials submitted to the Management Board and the Board of Directors of the Fund;
• The reliability of 380 candidates was verified, including:
  • 128 audits on candidates to the Board of Directors/Supervisory Board of Portfolio Companies in terms of compliance or non-compliance with their requirements, for election as directors;
  • 252 audits on candidates for vacant positions in the Fund for the circumstances preventing the admission of a candidate for a job.

As part of the methodology development in 2022:

• development and approval of the Corporate Compliance Function Standard in Portfolio Companies of Samruk-Kazyna JSC, which defines the methodological basis for the development and implementation of effective compliance systems and programs in Portfolio Companies of the Fund, by the decision of the Management Board of the Fund;
• approval of documents regulating the procedure for verifying counterparties before establishing business relations.

In the reporting period, the Compliance Service assessed the existing anti-corruption processes for compliance with the requirements of ISO 37001 “Anti-bribery Management Systems”. The Action Plan has been developed for the subsequent certification of the Fund based on the results of the evaluation.

As part of the processes automation, the information system for comprehensive verification of the reliability of third parties, including for affiliation with employees of the Fund and the group of companies, has been developed and implemented.

A model for assessing the maturity of the compliance function was developed in 2022 and a pilot project was implemented to assess the maturity of anti-corruption compliance systems in individual Portfolio Companies of Samruk-Kazyna JSC.

The strategic directions of compliance development for 2023 in the framework of combating corruption and increasing transparency of activities in the companies of the Fund Group are:

1. The development of the compliance function according to best international practice, including such areas as sanctions, listing, ESG and other types of compliance.
2. Certification of anti-corruption compliance systems for compliance with the requirements of international standards ISO 37001:2016 “Anti-bribery Management Systems” and ISO 37301:2021 “Compliance Management System”.
3. Automation of individual elements of the compliance program at the level of a group of companies.

According to the approved plans, work is underway to create an information system for automating individual elements of the compliance program, such as third-party trustworthiness verification, proactive information, identification and resolution of conflicts of interest, etc. This system will allow specialists in the field of compliance of the Fund group of companies to more effectively implement their tasks, as well as to carry out centralized control and collect the necessary information.