“SAMRUK-ENERGY” JSC | Integrated ANNUAL REPORT

“Compliance” service

Akshalov Dauren Esalyuly

Head of Compliance Service

ICA International Diploma in Governance, Risk & Compliance - Int.Dip. (GRC) Member of International Compliance Association (MICA) Маster of business administration  (MBA) Candidate of ICA Professional ICA Postgraduate Diploma in GRC – Prof.PGDip (GRC)

 Hot line
Email address: sk.hotline@deloitte.kz
Telephone: 8 800 080 19 94

In line with the best international practice, the “Compliance” Service was established in 2017 at “Samruk-Energy” JSC with aim to reduce and eliminate corruption risks. The Service implements the Compliance Program, determines the policy on anti-corruption issues, and controls over the execution of anti-corruption actions, including the assessment of corruption risks at “Samruk-Energy” JSC and its group of companies.

The Company’s compliance program is fully supported by the Board of Directors and the Management Board and is an integral part of the Company’s culture. In 2018, a Code of Conduct was approved, disclosing values and principles, goals, attitudes towards employees, asset protection, information management, compliance, interaction with the business community and communication with the Company.

As part of creating a corporate culture of "zero tolerance" to the facts of corruption and bribery at premises of the Head Office and at “Samruk-Energy” JSC group of companies, the Service included requirements of “Anti-corruption clauses” into employment contracts, as well as conducted compliance awareness training for employees which was attended by a representative of the Agency of the Republic of Kazakhstan on civil service and anti-corruption.

Information about the best international and national practice on compliance matters is sent to the Company’s employees on an ongoing basis, the “Compliance Service” information page with training material and videos on compliance with anti-corruption legislation is created on the Company’s internal Internet resource. The program of adaptation training includes a course on compliance requirements.

One of the key tools of the Company’s compliance program is to verify the reliability of third parties, partners, and counterparties entering into relations with the Company. The Service checks their reliability before entering into business relations with third parties. In order to extend the provisions of the Code of Conduct on business partners, suppliers and other third parties who work with the Company, rules of “Anti-corruption clauses” were included into the standard business agreements.

Moreover, as part of compliance program, all employees and stakeholders are provided with communication tools like the Initiative Informing Line (Hotline / Speak up) so that they can report their concerns regarding actual and suspected violations of legislation, regulatory requirements and internal ethics documents and compliance. Individuals reporting violations are given the opportunity to send a message on a confidential and anonymous basis, as well as guarantees that they will be prevented from harassment and their rights and interests will be protected. In line with the best international practices, and in order to protect the interests of informers. “Deloitte”, independent company, administers all complaints and appeals received through the hotline, which are recorded and reported to the Compliance Service that ensures anonymous and competent review. In order to review the message most effectively, an option of providing contact information is available; however, individuals may also leave an anonymous message. For anonymous complaints, answers are provided to an independent company for further sending them to those who filed a complaint/appeal.

The service provides the Board of Directors with a Report regarding Initiative Informing Line on a quarterly basis. At the end of 2018, the Company’s hot line received 31 calls, 8 of which were reported anonymously. All received appeals were reviewed / investigated, and applicants were provided with replies. For fair review and decision-making on appeals/complaints, the Company established the Committee for handling complaints / appeals received through initiative informing line.