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.
Individuals and legal entities submit their applications to the free hotline via 8-800-080-8089 telephone number, the email address at firstname.lastname@example.org, a mail to the registered office of the company (Bldg.12, Abai Str., Karaganda 100012).
The company informs employees and third parties of Speak Up Service activities by placing posters on premises of the Group’s production units, as well as contact information on social networks.
The company is particularly focused on interaction with counterparties and compliance by counterparties with anti-corruption provisions of the Kazakhmys Group.
These activities are implemented in accordance with requirements of Counterparties preliminary verification program on compliance with anti-bribery and corruption legislation, Regulations on verification of counterparties, draft contracts, procedure for recording an identified threat and level of its feasibility, as well as Regulations on approval of counterparties refusing to comply with anti-corruption provisions of the Kazakhmys Group.
In 2020, 12 (47) applications were accepted on refusal of counterparties to comply with the company's anti-corruption policies. At the same time, 6 (28) counterparties refused to fill out the Questionnaire, 2 (8) counterparties refused to include in a contract the Anti-Corruption clause, 4 (11) counterparties refused to fill out the Questionnaire and include the Anti-Corruption clause.
Approval of Counterparties Refusing to Comply With Anti-Corruption Provisions of the Kazakhmys Group
Based on results of analysis of above-mentioned applications, 4 (22) counterparties were included in the Register of counterparties which are eligible to conclude and subsequently execute contracts in the absence of anti-corruption provisions.
Concerning the remaining 8 (25) applications related to counterparties refusing to comply with anti-corruption provisions of the Kazakhmys Group, approval was given on a one-off basis to ensure appropriate operation of the Kazakhmys Group structural units.
The company continues efforts to raise the Kazakhmys Group employees awareness of implemented policies and procedures in the field of combating bribery and corruption. A strong focus is put on rehired employees.
In the reporting period, the total number of those who reviewed the Anti-Corruption Code, including rehired employees, amounted to 2,577 (2,812) persons.
576 (673) additional anti-corruption agreements to labor contracts were concluded, including with rehired employees, with whom conclusion of such agreements is mandatory due to their position.
A special function is assigned to activities on conflicts of interest management. As part of implementation of Regulations on conflicts of interest management, an analysis on authenticity and completeness of conflicts of interest disclosure and quality of their settlement is constantly being conducted. In accordance with requirements of this Regulation 973 (981), employees of the Kazakhmys Group, including those rehired, submitted Forms A and B, Disclosure of Information on Potential, Arisen Conflicts of Interest. When filling out the Questionnaires, 47 (28) conflicts of interest were disclosed and settled.
Conflict of Interest Management
One of the most important elements of an effective anti-corruption system is personnel training in basic requirements of local anti-corruption acts. Anti-Corruption Knowledge Base software is in operation in the company. It is the primary source of information related to anti-corruption measures for employees of the Kazakhmys Group.
The software product is available on personal computers desktops of Kazakhmys Group employees. All employees, who have a personal computer and a corporate network user account, are eligible for a permanent access to it.
Required environment was established for conducting mandatory testing of employees knowledge of anti-corruption policies and procedures. In 2020, 385 (370) employees (including rehired) passed digital testing.
The practice of conducting trainings on anti-corruption policies and procedures aimed at raising the Kazakhmys Group employees awareness of combating corruption is ongoing. E-learning covered 385 (370) persons.
The company conducts anti-corruption examination of projects, contracts (agreements) and local acts on a permanent basis to identify norms contradicting anti-corruption policies and procedures that facilitates risks prevention in this area.