Anti-Bribery and Anti-Corruption Policy

Approved 11.04.2025 by decision №4 of the Board of Directorsof the Non-Profit Joint Stock Company "M. Kozybayev North Kazakhstan University" 

ANTI-CORRUPTION POLICY
of the Non-Profit Joint Stock Company
"M. Kozybayev North Kazakhstan University"

1. GENERAL PROVISIONS

1. This Anti-Corruption Policy (hereinafter – the Policy) defines the principles, goals, and objectives of the Non-profit Joint Stock Company "M. Kozybayev North Kazakhstan University" (hereinafter – the Organization) in the field of preventing and combating corruption, and also establishes the basic requirements aimed at preventing corruption offenses in the Organization.

2. The Policy is a fundamental document regulating the Organization's activities in ensuring anti-corruption compliance, and is aimed at implementing the anti-corruption policy in accordance with the legislation of the Republic of Kazakhstan.

3. The Policy applies to all employees, students, as well as members of the Organization's governing bodies, regardless of their position, length of service, or other conditions.

4. The Organization declares zero tolerance for any manifestations of corruption and expresses its determination to form an organizational anti-corruption culture.

2. BASIC TERMS AND DEFINITIONS

5. For the purposes of this Policy, the following terms are used:

– Corruption – illegal use by persons of their official position, status, or authority to obtain personal gain in the form of money, valuables, other property or property-related services, other property rights for themselves or third parties, as well as bribery by providing benefits or advantages.

– Anti-corruption compliance – the internal system of the Organization aimed at ensuring compliance with anti-corruption laws, preventing and suppressing corruption offenses.

– Corruption risk – the probability of occurrence of causes and conditions conducive to the commission of corruption offenses.

– Conflict of interest – a situation in which personal interest (direct or indirect) affects or may affect the proper and objective performance of job duties by an employee, official, or member of the governing body, and in which there is or may arise a conflict between personal interest and the rights and legitimate interests of the Organization, which may cause harm to the rights and legitimate interests of the Organization.

– Corporate conflict – a conflict between the Organization and its shareholders (participant), between shareholders (participants) of the Organization regarding matters of the Organization's activities, or between the governing bodies of the Organization.

– Gift – cash or in-kind benefit provided free of charge in the form of money, securities, other property, including property services, other property rights, which is or may be perceived as related to job performance, decision-making, and is or may be intended as remuneration or incentive.

3. PRINCIPLES OF ANTI-CORRUPTION POLICY

6. The Organization adheres to the following basic principles of anti-corruption policy:

– Legality – compliance with the Constitution and laws of the Republic of Kazakhstan, other regulatory legal acts and internal documents of the Organization.

– Public awareness and transparency – availability of information on anti-corruption activities of the Organization to employees, students, and other interested parties.

– Personal example – the obligation of managers and officials to demonstrate ethical behavior and set a personal example of integrity and intolerance of corruption.

– Intolerance of corruption – any corruption manifestations are unacceptable and punishable regardless of the position, seniority, or other characteristics of the employee or official.

– Risk orientation – identification and analysis of corruption risks, their assessment, and implementation of measures to minimize them.

– Involvement of stakeholders – engaging employees, students, and other stakeholders in the development and implementation of anti-corruption measures.

3. GOALS AND OBJECTIVES OF THE UNIVERSITY IN THE FIELD OF ANTI-CORRUPTION

30. The goal of this Policy is to establish an effective anti-corruption system and zero tolerance for corruption among students, the teaching staff, and employees of the Organization.

31. To achieve the stated goal, this Policy provides for the implementation of the following objectives:
– Summarizing and explaining the main requirements of the legislation of the Republic of Kazakhstan in the field of anti-corruption;
– Forming a culture of ethical behavior and anti-corruption culture among employees of the Organization regardless of their position, students, and counterparties;
– Developing and implementing effective mechanisms and procedures aimed at preventing and combating corruption, eliminating, minimizing, and eliminating corruption risks;
– Monitoring corruption factors and the effectiveness of measures for the implementation of this Policy;
– Identifying the list of persons subject to anti-corruption restrictions;
– Integrating anti-corruption principles into strategic and operational management at all levels of the Organization’s activities;
– Ensuring openness and transparency of the Organization's business processes;
– Informing the Board of Directors about corruption-related actions and measures taken within the framework of corruption prevention;
– Determining responsibility for compliance with this Policy;
– Applying disciplinary measures to persons involved in corruption offenses.

4. BASIC PRINCIPLES OF ANTI-CORRUPTION

32. The basic principles of anti-corruption are:
– Zero tolerance for any manifestation of corruption – the Organization adheres to the principle of total rejection of corruption in any form and manifestation in its activities;
– Personal example of leadership – the Board of Directors and the Management Board must set an ethical standard of uncompromising attitude toward all forms and manifestations of corruption;
– Openness – informing the Organization’s employees about the ongoing Anti-Corruption Policy;
– Responsibility and inevitability of punishment – the Organization declares the inevitability of punishment for employees regardless of their position, work experience, or other circumstances in case of committing corruption offenses during the performance of their official duties. Liability for other subjects of anti-corruption policy shall be applied as provided by the current legislation of the Republic of Kazakhstan;
– Periodic assessment of corruption risks – the Organization regularly identifies and assesses corruption risks specific to its general activities and those of its individual structural units;
– Due diligence – the Organization conducts checks of counterparties and employment candidates before deciding to begin or continue business/employment relationships, ensuring their reliability and the absence of conflicts of interest;
– Interaction and coordination – the Organization ensures interaction and coordination in the field of anti-corruption with government bodies, as well as with interested public organizations and individuals;
– Control and monitoring – the Organization regularly monitors and observes the effectiveness of the implementation of anti-corruption measures and their execution;
– Avoidance of conflict of interest – the Organization believes that its employees must not directly or indirectly influence decisions made by the Board of Directors, the Management Board, or other heads of structural units.

5. REQUIREMENTS OF ANTI-CORRUPTION LEGISLATION OF THE REPUBLIC OF KAZAKHSTAN AND OBLIGATIONS FOR ITS IMPLEMENTATION

33. Corruption crimes/offenses subject to criminal liability under the anti-corruption legislation of the Republic of Kazakhstan include:
– Abuse of official powers, exceeding authority or official powers;
– Usurpation of official powers;
– Illegal participation in entrepreneurial activity;
– Receiving or giving bribes, and mediation in bribery;
– Official forgery;
– Inaction in office;
– Negligence.
34. Corruption crimes/offenses subject to administrative liability under the anti-corruption legislation of the Republic of Kazakhstan include:
– Providing unlawful material benefits to individuals and legal entities;
– Receiving unlawful material benefits from individuals and legal entities;
– Failure of managers to take anti-corruption measures;
– Hiring individuals who have previously committed corruption offenses.
35. Corruption-related situations and the procedure for action by officials, employees, and students of the Organization in such cases are defined by the Anti-Corruption Instruction.
36. In implementing this Policy, the Organization proceeds from the assumption that its officials and employees are prohibited, either directly or indirectly, personally or through third parties, from participating in corrupt actions:
– Offering, promising, or transferring money, gifts, or providing free services that are subject to payment with the intent to induce any person to improperly perform their official duties;
– Demanding, agreeing to receive, or accepting money, gifts, or free services subject to payment in exchange for the improper performance of their official duties;
– Offering, promising, or making payments (except as provided by applicable law), presenting gifts, or providing free services subject to payment to persons authorized to perform government functions or those equated with them in order to expedite or simplify established procedures;
– Offering, promising, or making payments to third parties when there is a suspicion that such payments may be used to expedite or simplify established procedures;
– Offering, promising, or providing employment at the Organization (including temporary employment) in exchange for personal gain;
– Facilitating or accepting excessive or fictitious payments from third parties;
– Giving or receiving gifts that contradict the anti-corruption legislation of the Republic of Kazakhstan and internal documents of the Organization.
37. In their professional activities, employees of the Organization must:
– Familiarize themselves with the Policy, confirmed by a mark in the electronic acknowledgment journal, according to Appendix 1;
– Comply with the requirements of the legislation of the Republic of Kazakhstan and this Policy;
– Strictly follow the restrictions and requirements provided by the Policy, including those related to giving and receiving gifts, representation expenses, charitable and sponsorship activities;
– Not perform official duties in the presence of a conflict of interest;
– Be honest and ethical in business relations, refrain from any dishonest methods of performing official duties, and observe the Code of Corporate Ethics;
– Not use their official position, confidential information, or the Organization’s material and non-material assets for personal purposes;
– Uphold and encourage colleagues to adhere to and promote anti-corruption culture and the Rules of Academic Integrity.
38. In their educational and scientific activities, students of the Organization must strictly:
– Familiarize themselves with the Policy, confirmed by a mark in the electronic acknowledgment journal, according to Appendix 1;
– Comply with the requirements of the legislation of the Republic of Kazakhstan and this Policy;
– Strictly follow the restrictions and requirements provided by the Policy, including those related to giving gifts to teachers and employees of the Organization;
– Be honest and ethical in academic relations, refrain from any dishonest methods of achieving academic and scientific results;
– Support and encourage other students to adhere to and promote anti-corruption culture and the Rules of Academic Integrity.
39. If employees or students of the Organization have doubts about the appropriateness of their actions or other standards of conduct, they may contact the Head of the Anti-Corruption Compliance Service (full confidentiality is guaranteed).

6. MAIN DIRECTIONS OF ANTI-CORRUPTION ACTIVITIES

40. The main directions of the Organization's anti-corruption activities are:
– Implementation of a unified Policy of the Organization in the field of anti-corruption;
– Development of internal regulatory documents;
– Anti-corruption education and upbringing of the younger generation;
– Promotion of anti-corruption culture among the academic and administrative staff of the University;
– Promotion of the institution of anti-corruption compliance;
– Implementation of the Anti-Corruption Concept;
– Development of anti-corruption materials;
– Anti-corruption monitoring.
41. The Organization's anti-corruption activities are carried out in accordance with the Anti-Corruption Standard and the Anti-Corruption Action Plan, which is approved annually by the Board of Directors.
42. Employees of the Organization, in accordance with the established rules, have the right to submit proposals for additional measures to combat and prevent corruption.

7. REGULATION OF GIFTS AND REPRESENTATION EXPENSES

43. The Organization promotes an atmosphere of honesty and transparency regarding business gifts and hospitality expenses.
44. The exchange of gifts with third parties must meet the following criteria:
– Fully comply with the current legislation of the Republic of Kazakhstan;
– Be reasonably justified, proportionate, not constitute cash or non-cash funds, securities, precious metals or other monetary equivalents, and not be luxury items;
– Not constitute a hidden reward for a service, action (or inaction), favoritism, patronage, granting of rights, adoption of a certain decision, or an attempt to influence the recipient for any unlawful or unethical purpose;
– Not create a risk that could lead to a loss of business reputation for the Organization or its officials.
45. It is prohibited to accept gifts or hospitality from any potential participant in procurements conducted by the Organization. If there are doubts regarding the compliance of a business gift or hospitality event with the requirements of this Policy, the official must consult the Head of the Anti-Corruption Compliance Service and their immediate supervisor.
46. The procedure and form of written notification upon identifying a given/received/planned gift/representation expense/hospitality are defined in Appendix 2.

8. PREVENTION AND RESOLUTION OF CORPORATE CONFLICTS AND CONFLICTS OF INTEREST

47. Management of corporate conflicts and conflicts of interest is one of the key anti-corruption mechanisms. The Organization pays close attention to the prevention and resolution of risks related to conflicts of interest.
48. Officials and employees of the Organization must act in the interests of the Organization and avoid situations or circumstances where their personal interests may conflict with the interests of the Organization.
49. In the event of a conflict of interest (or a potential conflict), officials and employees of the Organization must inform their immediate supervisor or the Board of Directors in writing.
50. The resolution of conflicts of interest is carried out in accordance with the Regulation on Identification and Resolution of Corporate Conflicts and Conflicts of Interest of the Non-profit Joint Stock Company "M. Kozybayev North Kazakhstan University".

9. MONITORING AND ANALYSIS OF CORRUPTION RISKS

51. The Organization evaluates corruption risks and develops measures to minimize them in accordance with the anti-corruption legislation of the Republic of Kazakhstan and internal documents.
52. The purpose of corruption risk monitoring and analysis is to identify high-risk areas and business processes of the Organization that are susceptible to non-compliance with anti-corruption laws and where there is a high probability of committing corruption offenses, whether for personal gain or for the benefit of the Organization.
53. Identification and assessment of corruption risks are carried out on the basis of anti-corruption monitoring and internal analysis, in accordance with the Plan approved by the Board of Directors.

10. REPORTING CORRUPTION OFFENSES AND INTERNAL INVESTIGATION

54. Employees of the Organization must report to their immediate supervisors and the Anti-Corruption Compliance Service any attempts by individuals to induce them to engage in corrupt actions or any information or suspicion about possible corrupt actions (or inaction) by other employees or third parties associated with the Organization. Confidentiality of reports is guaranteed.
55. All reports of corruption offenses in the Organization are subject to verification or internal investigation conducted by the Head of the Anti-Corruption Compliance Service. The time frame for such verification or investigation is determined by order of the Chairperson of the Management Board – Rector.
56. If a corruption offense is confirmed as a result of the internal investigation, the case is considered closed upon implementation of corrective measures, following the principle of zero tolerance to any manifestation of corruption, including termination of employment and referral of materials to the authorized state bodies.

11. MUTUAL COOPERATION

57. The Organization cooperates with authorized government bodies and organizations, as well as third parties in the field of anti-corruption, on the basis of reciprocity, for the purpose of:
– Receiving methodological and informational support;
– Reporting violations with signs of corruption;
– Providing information/participating in meetings upon request of authorized government bodies and organizations related to anti-corruption legislation.

12. LIABILITY OF EMPLOYEES AND STUDENTS FOR NON-COMPLIANCE WITH THE POLICY

58. Officials, employees, and students of the Organization bear liability, as established by the legislation of the Republic of Kazakhstan, for committing corruption offenses.
59. Responsibility for ensuring compliance with this Policy lies with the employees of the Organization within the scope of their competence.
60. Violation of the requirements of this Policy is considered incompatible with the status of an employee or student of the Organization and constitutes grounds for disciplinary action, up to and including dismissal or expulsion.

13. AMENDMENTS TO THE ANTI-CORRUPTION POLICY

61. This Policy enters into force upon its approval by the decision of the Board of Directors.
62. Amendments, additions, or adoption of a new version of this Policy are approved by the decision of the Board of Directors.
63. The revision of the adopted Policy may be carried out in case of amendments to the current legislation of the Republic of Kazakhstan or in the event that the provisions of the Policy are found to be insufficiently effective.