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In today’s environment, the sustainable development of any organization is impossible without the trust of the state, society, employees, partners, and other stakeholders. For quasi-public sector companies, achieving operational and financial targets is important, but equally essential is adherence to the principles of legality, integrity, transparency, and business ethics. These principles form the foundation of the Compliance Service of Zhasyl Damu JSC.
In its broadest sense, compliance is a system of organizational, legal, and ethical measures designed to ensure that an organization operates in accordance with the legislation of the Republic of Kazakhstan, internal regulations, corporate values, business ethics standards, and the principles of good faith conduct.
In other words, compliance means adhering to established rules and preventing actions that may expose an organization to legal, financial, reputational, corruption-related, or other risks. Compliance goes beyond formal monitoring of legal requirements; its primary objective is to create a corporate environment in which employees understand their responsibilities, act with integrity, and promptly report potential violations or risks.
In practice, compliance includes identifying and assessing compliance risks, preventing corruption and fraud, managing conflicts of interest, conducting due diligence on counterparties and candidates, providing guidance and awareness activities, monitoring legislative changes, and promoting a culture of openness, accountability, and zero tolerance for misconduct.
For quasi-public sector entities, compliance is particularly important because their activities are subject to heightened expectations regarding legality, transparency, efficient use of resources, and public trust. In this context, compliance serves not only as a control function but also as a preventive mechanism that contributes to sustainable development, protects the organization’s reputation, and strengthens its corporate culture.
The evolution of compliance culture in Kazakhstan is closely linked to the country's anti-corruption policy.
One of the first significant milestones was the adoption of the Law of the Republic of Kazakhstan "On Combating Corruption" on 2 July 1998, aimed at protecting citizens' rights and freedoms, ensuring national security, and preventing, detecting, and suppressing corruption offenses.
The next major step was the adoption of the Law "On Counteracting Corruption" on 18 November 2015. This legislation introduced a modern approach focused not only on detecting corruption offenses but also on preventing corruption risks, fostering an anti-corruption culture, and eliminating the causes and conditions that facilitate corruption. In particular, the law requires quasi-public sector entities to establish either a dedicated structural unit or appoint a responsible officer to perform anti-corruption compliance functions.
A further milestone was the Concept of the Anti-Corruption Policy of the Republic of Kazakhstan for 2022–2026, approved by Presidential Decree No. 802 dated 2 February 2022. The Concept sets objectives for strengthening anti-corruption culture, eliminating corruption risks, and ensuring the inevitability of liability for corruption offenses. Its implementation is entrusted to government agencies, subordinate organizations, and quasi-public sector entities.
An additional institutional framework for compliance was established through the Model Regulation on Anti-Corruption Compliance Services in Quasi-Public Sector Entities, approved by the Order of the Chairman of the Anti-Corruption Agency of the Republic of Kazakhstan No. 112 dated 31 March 2023. The Regulation defines anti-corruption compliance as a function aimed at ensuring compliance by quasi-public sector entities and their employees with Kazakhstan’s anti-corruption legislation.
Compliance is an integral component of the corporate governance system. Its primary purpose is to ensure that the organization’s activities comply with applicable legislation, internal regulations, ethical standards, and principles of good faith conduct.
For a joint-stock company, compliance is particularly significant because corporate governance requires transparent relationships among the shareholder, the Board of Directors, the executive body, employees, and other stakeholders. The Law of the Republic of Kazakhstan "On Joint Stock Companies" emphasizes the importance of internal corporate documents and the Corporate Governance Code in regulating relations among corporate bodies, shareholders, and stakeholders.
Accordingly, the Compliance Service serves as both a preventive and advisory function aimed at preventing violations, reducing compliance risks, strengthening business ethics, and protecting the Company’s reputation.
The Compliance Service of Zhasyl Damu JSC was established by a decision of the Board of Directors in July 2022 to organize and oversee the Company’s anti-fraud and anti-corruption framework.
Its primary mission is to ensure transparency, ethical conduct, and compliance with high standards in preventing corruption, fraud, and conflicts of interest.
Zhasyl Damu JSC aligns its operations with recognized compliance best practices because investors, business partners, and the public expect the Company to operate honestly, transparently, and lawfully. In this regard, compliance is not merely a formal procedure but a key element in building and maintaining trust.
The Company has established a comprehensive internal regulatory framework aimed at preventing corruption, ethical, reputational, and other compliance risks. The following internal documents have been developed and implemented:
In addition, the Compliance Service, together with the Human Resources Department, has developed the Code of Business Ethics, which establishes standards of conduct based on the Company's mission and values and promotes honest, fair, and lawful relationships among employees and business partners.
One of the Compliance Service’s key responsibilities is the continuous monitoring of legislative developments in the field of anti-corruption. This enables the Company to promptly update internal policies and ensure compliance with the laws of the Republic of Kazakhstan.
Another important function is conducting integrity checks on candidates for vacant positions and individuals engaged under civil law contracts. These checks help reduce the likelihood of recruiting individuals who may pose legal, financial, or reputational risks.
Equally important is due diligence on counterparties. Every new business relationship or agreement may involve potential risks. Therefore, the Compliance Service conducts comprehensive reviews of prospective and existing counterparties to assess their integrity, identify affiliations, and verify compliance with legal requirements.
Between 2022 and 2026, no cases of corruption offenses involving officials or employees of Zhasyl Damu JSC were recorded. Furthermore, all planned activities of the Compliance Service were completed on time and in full.
These results demonstrate the value of systematic preventive efforts. Effective compliance is not limited to responding to violations after they occur. Its greatest value lies in preventing risks, fostering a culture of integrity, increasing employee accountability, and strengthening trust in the Company’s operations.
The Compliance Service of Zhasyl Damu JSC is an essential element of the Company’s corporate governance and anti-corruption framework. Its activities are focused on ensuring legality, transparency, business ethics, and the prevention of corruption, fraud, conflicts of interest, and other compliance risks.
Considering the requirements of the legislation of the Republic of Kazakhstan and modern expectations for quasi-public sector organizations, the compliance function has become an indispensable condition for sustainable organizational development. For Zhasyl Damu JSC, compliance is not only a mechanism of control but also a strategic instrument for building trust, protecting the Company's reputation, and fostering a culture of honesty, responsibility, and ethical conduct.
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