Anti-corruption measures
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The Kazakhmys Group is particularly focused on issues concerning introduction of anti-corruption policies and procedures, internal corporate system capable of combating bribery and corruption.
To this end, the company approved and enacted the Anti-Corruption Code, which is a summary of general principles of professional business ethics and primary rules of conduct for company employees, both in external relationships with partners, counterparties and other interested parties, and in internal relationships between personnel.
The Company from time to time conducts effectiveness appraisal of anti-corruption policies and procedures in terms of timely identifying breaches.
Speak Up service is one of the tools of such appraisal and its activities are aimed at reporting breaches of legislation.
It enables company employees, partners, counterparties and other interested parties not only to report their suspicions, but also to receive explanations on issues related to application of local regulations of the company.
Three options are available for legal entities and individuals to report wrongdoing: - to call to the free-of-charge hotline at 8-800-080-8089; - to send message to WhatsApp of Speak Up Service at +7 708 436 2058; - to send message to e-mail: speakup@kazakhmys.kz or to the office of Kazakhmys Corporation LLC.
Work is underway with regard to counterparties who refuse to comply with the anti-corruption provisions of Kazakhmys Group (refusal to fill out the questionnaire and include an anti-corruption clause in the contract).
Within reporting period, 42 appeals (against 57) were received on counterparties refusal to comply with the company's anti-corruption policies in respect of 67 contracts (against 105).
Of these, 32 appeals (against 28) concerned counterparties refusal to fill out the Questionnaire, 3 appeals (against 8) - refusal to include an anti-corruption clause in the text of the contract as approved for Kazakhmys Group companies, 7 appeals (against 21) - refusal to fill out the Questionnaire and include an anti-corruption clause in the text of the contract.
Seven counterparties (against 21) have been added to the Register of counterparties refusing to comply with Kazakhmys Group's Anti-Corruption Policy, due to their affiliation to: The state-owned enterprises and institutions, legal entities with state participation in the authorised capital or state-controlled joint stock companies and limited liability companies, as well as state-owned legal entities (clause 5.1.2 item “e” of the Regulations).
One–time approval was granted for 27 appeals (against 33) concerning counterparties that declined to comply with Kazakhmys Group's Anti-Corruption Policy: to ensure proper operation of structural divisions of Kazakhmys Group companies in absence of counterparties offering similar goods, works and services in a particular market segment and/or region (clause 6.5.3 of the Regulations); due to Management instructions (Clause 6.5.1. of the Regulations); due to amendments and additions made by the counterparty to the model regulations of the Anti-Corruption Clause, provided that the purpose and interpretation of these regulations are not materially changed (clause 6.3.3 of the Regulations).
In respect of 5 appeals (against 3) a response was given on the previously issued approval on the basis of clause 5.1.3 of the Regulations.
2 appeals (against 0) were left without consideration due to removal of remarks by the counterparty and submission of the Anti-Bribery and Corruption Compliance Questionnaire, containing all the necessary information.
1 appeal (against 0) was refused for approval.
List of approved counterparties with a breakdown by approval criterion are communicated to structural subdivisions by sending them via the electronic document management system.
Enhancement of the Group employees' awareness of implemented anti-bribery and corruption policies and procedures is in progress with focus on newly hired employees.
Within the reporting period, 2507 employees (against 4788) gained familiarity with Anti-Corruption Code and the Regulations for Conflict of Interest Management, including newly hired employees.
In total 551 Additional Anti-Corruption Agreements (against 1635) to the Employment Contracts were concluded, including those for newly hired employees. Conclusion of such agreements is mandatory for newly hired employees pursuant to their position.
Conflict of Interest Management has been assigned a special role. In the pursuit of implementing the Regulations for Conflict of Interest Management, an in-depth analysis was conducted to verify the credibility and completeness of the disclosure of conflicts of interests, as well as the quality of their resolution.
963 employees (against 1703) of Kazakhmys Group companies (newly hired inclusive) submitted Forms A and B of Disclosure of Potential and Actual Conflicts of Interests Questionnaire. Consequently, 12 conflicts of interests (against 7) were identified and settled.
One of the core elements of efficient anticorruption system is training and instructing employees on main requirements of local Anti-Bribery and Anti-Corruption regulations.
Anti-corruption Knowledge Database software is the key source of corruption counteracting information for the Group employees.
The software is available at computer desks of the Group employees, so that every computer user/ account holder of a corporate network is provided with an access.
Anti-corruption Knowledge Database registered 64 548 impressions/views (against 59 038) as of date of current reporting formulation.
The practice of conducting training sessions on Anti-Corruption Policies and Procedures to enhance awareness among Group employees on Anti-Corruption issues continues.
The training covered 410 specialists (against 512), including 120 specialists through on-site seminars (no on-site trainings were held during the 12 months of 2022 due CVID-19 pandemic restrictions) and 290 specialists (against 512) through e -learning.
