Compliance competence center

The implementation of business processes of the compliance function in accordance with requirements of the current anti-corruption legislation of the Republic of Kazakhstan and the Corporate Standard for the Compliance Function in Portfolio Companies of Samruk-Kazyna JSC.

The Anti-corruption Compliance Service has been fully functioning in the Partnership according to requirements of the Law “On Combating Corruption” and the Corporate Standard for the Compliance Function in Portfolio Companies of Samruk-Kazyna JSC since early 2019.

The main activities in the field of compliance are as follows:

Advising and providing methodological support to the structural subdivisions and officials of the company in the performance of the assigned functions in the field of compliance and anti-corruption, including in terms of:

• development and implementation of compliance policies and procedures in company processes;
• compliance with established standards of business ethics within the company and in relations with third parties;
• continuous monitoring of external requirements, assessment of the impact of regulatory changes on the functioning of the company and taking the necessary measures;
• analysis and assessment of compliance risks in processes;
• identifying and resolving situations of potential conflict of interest;
• interactions with third parties;
• inspections and investigations of information received within the framework of the proactive information system and so on.
• functioning of the proactive information system and verification of incoming messages;
• monitoring the effectiveness of established compliance systems;
• communications on compliance issues within the company, as well as, if necessary, interaction with customers, partners, government agencies and other stakeholders within the competence;
• organizing and conducting training of the company employees on compliance and anti-corruption issues;
• functioning of the effective corruption risk management system;
• iImplementation of centralized compliance processes and systems in the company;
• implementation of functions of the processes owner according to the decision of the management body;
• monitoring and providing the management body with information on the functioning of compliance systems, as well as recommendations for their improvement.

Functions of the Compliance Competence Center include:

• Methodological support and maintenance of the compliance function in Portfolio Companies of the Fund;
• Automation of individual elements of the compliance program;
• Assessment of maturity of compliance functions in Portfolio Companies;
• Creation and maintenance of centralized controls over the formation of lists of affiliates and declaration of conflicts of interest at the level of the Fund group of companies;
• Introduction of requirements of ISO 37001 “Anti-Bribery Management System” and ISO 37301 “Compliance Management System” in the processes of the Fund group of companies.

In addition, as part of the development of the compliance institute, the group is implementing a project on outsourcing compliance functions for the Fund group of companies, the main purpose of which is to ensure the implementation of compliance function business processes according to requirements of the current legislation on anti-corruption of the Republic of Kazakhstan and the Corporate Standard for the compliance function in portfolio companies of Samruk-Kazyna JSC.