G – Governance

Ethics and Integrity

Values, Principles, Standards of Conduct

The most important principle of the Company’s operations is ensuring high corporate responsibility. The corporate responsibility includes transparent and ethical behaviour that contributes to sustainable development and corresponds to the legislation and international norms of behaviour. The Company’s activities in this area have a systemic nature, that is why KMG conducted the work for update of the current document on ethical issues – the new revision of Business Ethics Code was approved in order to comply with ethical behaviour standards and fair business conduct.

Pursuant to the approved Code, KMG’s operations are based on the following corporate values:

  • Justice
  • Loyalty
  • Development
  • Safety
  • Responsibility

The Company strictly follows the provisions of the Code as the basis of the KMG’s relations with its shareholders, employees, subsidiaries and associated companies, governmental authorities, partners, other stakeholders, when making business decisions and in everyday operations is the balance of interests, mutual respect, trust, responsibility and observance of rights and duties of each party.

The Code is an open document and is freely available to KMG’s business partners and to any other stakeholders. It is also available on the Company’s website in the Corporate Documents section.

Mechanisms of Applying for Consultations on Unethical Conduct

To ensure observation of employee rights, confidential and accessible means have been made available for real-time reporting of any wrongful actions on the part of employees or third parties.

Any employee of the Group or any other person who has any doubts regarding the legality of actions taken by other employees, counterparties, or any other persons interacting with KMG and its SDEs, may inform their management, supervisor or the Compliance Service.

Such information can be transmitted by the following confidential channels and means of communication:

  • to the KMG’s helpline system by e-mail doverie@kmg.kz, by helpline 8-(7172)-78-65-65;
  • to the Ombudsman (for business ethics, discrimination, labour disputes and other labour matters, etc.) by e-mail ombudsman@kmg.kz, or by phone 8-(7172)-78-65-60, 78-65-61;
  • to the Compliance Service (in case of any suspected or available information regarding corruption, fraud, or unethical conduct) through a single centralised hotline administered by Samruk-Kazyna JSC, which is serviced by an independent operator, KPMG:
  • toll-free call: 8 (800) 080 47 47;
  • WhatsApp: 8 (771) 191 88 16;
  • via web portal: mail@sk-hotline.kz
  • via web portal: www.sk-hotline.kz

The contact details of the Hotline are available on the KMG’s corporate website in the state, Russian and English languages. Similar information is available on the websites of SDEs.

All messages, including anonymous, will be received and processed by the operators and forwarded to KMG’s Compliance Service, which is in charge of their professional and confidential review. The Compliance Service will communicate the results of such review to the Audit Committee and KMG’s Board of Directors on a quarterly basis. In 2021, the Hotline received 76 complaints and applications; the number of applications decreased by 36% compared to 2020, which is due to the change of the Hotline operator, withdrawal of some SDEs from KMG, and rejection of irrelevant applications by the Hotline operator.

The issues that did not directly relate to corruption and fraud control were also resolved owing to the applications sent to the Hotline. For example, the Hotline received reports about violations of business conduct and abuse of power. All the received applications were considered in accordance with the established timeframes and procedures with taking of relevant measures to decrease the possibility of repeat of similar situations in future and notifying the applicants about their consideration results.

Hot line

You may inform on any violations of the Code of conduct, including cases of corruption, discrimination, unethical behavior and other violations

We guarantee

  • Confidentiality and anonymity
  • Review of 100% of requests

Hotline telephone number: 8 800 080 47 47

WhatsApp messenger via number: 8 771 191 88 16

Internet portal: www.sk-hotline.kz

E-mail: mail@sk-hotline.kz

The hotline is operated by an independent operator, KPMG

Hotline Nysana

Hotline telephone number: 8 800 080 30 30

WhatsApp messenger via number: 8 702 075 30 30

Internet portal: nysana.cscc.kz

E-mail: nysana@cscc.kz

Call center “Nysana” accepts free calls for all social and labor violations 24/7.

No Success Without Trust

Strict and comprehensive observance and protection of human rights is a fundamental principle of JSC NC “KazMunayGas” activities based on trust, honesty and transparency. At that, these rules apply not only to employees, but also to relations with partners, suppliers, contractors and other stakeholders.

The regulatory framework for protection of rights of the Company’s employees is reflected in KMG Confidential Reporting Policy approved by the Resolution of the Board of Directors dated 13.02.2020, Minutes No.1/2020 (hereinafter, the Policy) and KMG’s Economic Security Regulations approved by Resolution of KMG’s Management Board dated 30.07.2020, Minutes No.31 (hereinafter, the Regulations).

According to these documents, KMG and SDEs have available and round-the-clock (24/7) communication channels and means ensuring confidentiality in order to increase efficiency of preventive measures and offences prevention, to improve interaction and provide feedback from the Company’s employees, stakeholders (private and legal entities) and in order to protect legal rights and interests. Hotline, telephone and email Helpline.

The procedure for acceptance, registration and consideration of reports about violation of the Republic of Kazakhstan laws and the Company’s internal regulatory documents is also regulated by the Work Instruction for Operation of KMG Helpline Information System approved by Order No. 129 of KMG Chairman dated 18.04.2018 (hereinafter, HIS).

Similar documents were approved by the SDEs. 

These tools also contribute to the Company’s openness, accessibility of report submission, efficiency and quality of their consideration, identification and elimination of causes that create conditions for corruption, violations of the rights and legitimate interests of employees and third parties.

Reporting also helps to resolve issues related not only to combating the corruption and fraud, but also to business misconduct, abuse of office, and social and general issues, among others.

In 2021, KMG Group received 6518 reports and applications (210 in 2020, 185 in 2019). The applications were related to labour rights of employees, remuneration, labour safety conditions, violations during tenders and other procurement procedures, abuse of power and unethical behaviour of company managers.

Applications are received by e-mail, telephone or as postal items.

All inquiries received from various communication channels are recorded and analysed in depth.

Applications and reports, including anonymous, are considered in accordance with the established procedure and timeframes, with actions being taken and with further notice being given to the applicants.

18 Information without KTG data

Turysbek Akiaskarov, Director of KMG Corporate Security Department

The important and fundamental principles of our Company are: trust, honesty and transparency, which are Our Company is governed by the principles of trustworthiness, honesty and transparency

Employees and other stakeholders to freely to seek protection of their rights and interests without hindrance. rights and interests. At the same time to receive the necessary assistance and support.

Given its effectiveness, development of the Hotline, telephone and email helpline will continue.

In 2021, as in previous years, there were no complaints of discrimination on the grounds of nationality, gender, religion or political views. There are no recorded instances of forced and compulsory labour and no prosecutions or criminal proceedings relating to such violations.

KMG Group’s corporate security departments take comprehensive efforts to ensure that the rights of employees and others are respected. In doing so, they are strictly guided by the laws of the Republic of Kazakhstan and international regulations, as well as general corporate and internal documents of the Fund, KMG and SDEs.

In 2021, 5.1% of employees in the Group’s corporate security departments were trained in compliance with the company’s policies and procedures (in 2020, 7.5% were trained).

In general, the management of KMG and its SDEs pays serious attention to human rights and is continuously working to improve this area of activities.

Anti-Corruption

JSC NC “KazMunayGas” (hereinafter, the Company) builds its business on the principles of legality, good faith and ethics. The Company strictly observes the human rights, takes all possible steps to prevent corruption, takes care to maintain an impeccable reputation and strives to implement high international standards of conduct.

KMG has a Compliance Service (hereinafter, the Service). It is the responsibility of the Service to ensure that there is no risk of employees committing a corruption offence during their employment. While remaining an independent activity area of the company, the Service is integrated with all of the Company’s business units.

In order to meet the standards of ethical and fair business conduct, KMG has taken steps to update existing and develop new internal compliance documents. The Anti-Corruption Policy and the Confidential Reporting Policy were amended in 2021. The changes concerned amendments to Kazakhstan’s laws regarding prohibition of receiving gifts, close relatives working together, and changing the Hotline operator. In addition, KMG Group’s Counterparty Due Diligence Policy has been approved. Similar policies have been approved in 35 SDEs of the company.

Following the best global practices in corporate governance, the Company continually strives to improve existing corporate standards. Thus, the Internal Control Rules of JSC NC “KazMunayGas” were approved to delimit the rights of access to insider information and to prevent misuse of such information by insiders.

Regarding its ongoing work with SDEs, the Company seeks to accelerate integration of companies into the corporate culture by introducing functions locally and shaping compliance programmes tailored to the company specifics. Compliance risk assessments were conducted at 14 companies (KMG, Ozenmunaygas, Embamunaygas, Pavlodar Oil Chemistry Refinery, Atyrau Refinery, KazTransOil, Kazmortransflot, KMG Engineering, OzenMunayService, Oil Service Company, KLPE, KPI, Kazakhoil Aktobe, KMG – Kumkol). Based on the risk analysis and assessment, the measures to minimise the risks have been developed. In addition, testing of accounting transactions, kinship analysis, and monitoring of compliance with the Anti-Corruption Law of the RoK and compliance policies were carried out.

Universal declaration of conflicts of interest for all employees of KMG group has been carried out in the Company since 2020 to create an effective system for managing the conflicts of interest, and define requirements for conduct of employees, which observance minimises the risks of decisions being influenced by personal interests and connections.

A universal tax declaration procedure was introduced in 2021 to support the government’s goal of establishing a system of effective control over personal income and assets to combat the shadow economy and corrupt practices. At the first stage of the universal tax declaration, tax returns were submitted by 303 employees of KMG and its SDEs.

Meetings were held jointly with Samruk-Kazyna JSC with representatives of Mangystau Region Akimat and contractors in Aktau to promote the Hotline. Compliance meetings were held with the administrative and management personnel of Mangistaumunaigas JSC, Karazhanbasmunay JSC, Oil Services Company LLP and Isatay Operating LLP.

In order to introduce best global compliance practices, a workshop with Tengizchevroil was held for the compliance officers of SDEs.

Commitment to high ethical standards is the foundation of good corporate governance and a guarantee of upholding and ensuring that the Company’s interests take precedence over personal interests. Three-day online compliance training for KMG employees was held in 2021 to promote high ethical standards of doing business and intolerance of corruption in any form.

In order to improve the effectiveness of the Compliance Service of KMG and its SDEs, as well as to strengthen the Company’s controls and combat the corruption and fraud, training was conducted in 2021 for the compliance officers of KMG Group in the following areas:

  • due diligence with regard to counterparties;
  • identifying and managing the conflicts of interest;
  • interviewing;
  • checking the Company’s employees;
  • investigation planning and execution;
  • preparing reports on investigation results.

This training was conducted with involvement of forensic experts from an international audit company.

The Compliance Service supports development of professional competencies and advanced training of KMG Group’s compliance officers. Today the compliance teams include experts with international prestigious certifications from the Association of Certified Fraud Examiners (ACFE) and the International Compliance Association (ICA), and their numbers are growing.

In 2022, the Company will continue to further improve its compliance system. Key work areas will include:

  • risk-based check of counterparties;
  • development of compliance system in the companies;
  • automation of the compliance procedure for declaring the conflicts of interest based on the own IT solutions;
  • developing compliance training and communication materials.