Kazakhmys Group have vested interest in introduction of anti-bribery and anti-corruption policies and procedures, as well as building corporate system aimed at combating bribery and corruption.
In this regard Anti-Corruption Code was approved and implemented by the Company. This Code is a summary of general principles of professional business ethics and key rules of conduct for company employees to build lasting relationships with partners, counterparties and other interested parties, and healthy relationships among employees.
Company regularly estimates efficiency of anti-bribery and anti-corruption policies and procedures for timely identification of violations.
Senim Alert Service is one of the tools aimed at identification and reporting of violations.
It enables employees, partners, counterparts and other interested parties to report wrongdoing when suspected as well as request for clarifying information on issues concerning internal policies and procedures 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 Senim 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, 43 appeals (42 in 12 months 2023) were received regarding refusal of counterparties to comply with the company's anti-corruption policies in respect of 53 contracts (67 in 12 months 2023).
Of these, 20 appeals (32 in 12 months 2023) concerned refusal of counterparties to fill out the Questionnaire, 3 appeals (3 in 12 months 2023) – regarding refusal to include an anti-corruption clause in the text of the contract as approved for Kazakhmys Group companies, 20 appeals (7 in 12 months 2023 ) – regarding refusal to fill out the Questionnaire and include an anti-corruption clause in the text of the contract. 
- On 22 appeals regarding counterparties that declined to comply with Kazakhmys Group's Anti-Corruption Policy (27 in 12 months 2023) one –time approval was granted:
| Due to Management Instructions of the Company (clause 6.5.1 of the Regulations) | 6
| Kazakhmys Group acts as the sole provider of services and cannot refuse to provide them (clause 6.5.2 of the Regulations) | 3
| to ensure proper operation of structural divisions of Kazakhmys Group in the absence of counterparties offering similar goods, works and services in a particular market segment and/or region (clause 6.5.3 of the Regulations) | 13
- For 8 (7 in 12 months 2023) appeals the counterparties are included in the Register of Counterparties that refuse to comply with Kazakhmys Group's Anti-Corruption Provisions due to their attribution:
| 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) | 4
| state organisations (p.5.1.2 item “e” of the Regulations) | 4
Approval was denied in relation of 4 (1 in 12 months 2023) appeals, clarification of previously issued approval was given for 8 appeals (5 in 12 months 2023); 1 appeal (2 in 12 months 2023) was left without consideration due to elimination of comments from the counterparty and submission of the Questionnaire on compliance with Anti-Bribery and Corruption Law with all necessary information.
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 1,879 individuals (2,507 in 2023) gained familiarity with Anti-Corruption Code and the Regulations for Conflict of Interest Management, including newly hired employees.
In total 472 (551 in 2023) additional Anti-Corruption Agreements to the Labour Contracts were concluded, including those for newly hired employees. Conclusion of such agreements is mandatory for newly hired employees pursuant to their position. 
705 employees (963 in 2023) of Kazakhmys Group companies (newly hired inclusive) submitted Forms A and B of Disclosure of Potential and Actual Conflict of Interest Questionnaire. Consequently, 8 conflicts of interests (12 in 2023) were identified and settled.
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 69,141 impressions/views (64,548 in 2023) 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. 479 specialists (410 in 2023) were provided training, including 206 specialists (120 in 2023) through on-site seminars and 273 specialists (290 in 2023) through e - learning. 