- PURPOSE OF THE DOCUMENT
1.1. This Anti-Corruption Policy (hereinafter referred to as the “Policy”) is a baseline document of RBC Group LLP (hereinafter referred to as the “Company”), defining key principles and requirements aimed at preventing corruption and ensuring compliance with applicable anti-corruption legislation by the Company, employees, and other persons acting on behalf of the Company.
- OBJECTIVES OF THE POLICY
2.1. The Policy reflects the commitment of the Company and its management to high ethical standards in conducting open and honest business to improve corporate culture, follow best corporate governance practices, and maintain the Company’s business reputation at a proper level.
2.2. The Company sets the following objectives:
- Minimize the risk of involving Company Employees, regardless of their position, in corruption activities.
- Establish a uniform understanding among Employees and other persons of the Company’s policy of zero tolerance for corruption in any forms and manifestations.
- Summarize and clarify the main requirements of the anti-corruption legislation of the Republic of Kazakhstan that may apply to the Company and its Employees.
- Establish the obligation of Company Employees to know and comply with the principles and requirements of this Policy, key norms of applicable anti-corruption legislation, and adequate anti-corruption procedures.
- Summarize and clarify the main requirements of the anti-corruption legislation of the Republic of Kazakhstan that may apply to the Company.
- SCOPE AND RESPONSIBILITIES
3.1. All Company Employees must be guided by this Policy and strictly comply with its principles and requirements.
3.2. The Director of the Company is responsible for organizing all measures aimed at implementing the principles and requirements of this Policy, including appointing persons responsible for developing anti-corruption procedures, their implementation, and control.
3.3. The principles and requirements of this Policy apply to counterparties and representatives of the Company, Employees, and other persons in cases where corresponding obligations are stipulated in contracts with them, in their internal documents, or directly follow from the law.
- APPLICABLE ANTI-CORRUPTION LEGISLATION
- 1. In Kazakhstan, “corruption acts” generally include giving or receiving bribes, intermediation in giving or receiving bribes, abuse of office or authority, commercial bribery, facilitation payments, illegal use of official position to obtain advantages in the form of money, valuables, other property, services, or any rights for oneself or other persons, or the illegal provision of benefits or rights to such a person by other persons.
- 2. In view of the above, all Company Employees are strictly prohibited, directly or indirectly, personally or through third parties, from participating in corrupt activities, offering, giving, promising, requesting, and receiving bribes, or making facilitation payments in any form, including cash, valuables, services, or other benefits, to or from any persons or organizations, including commercial entities, government authorities and self-government bodies, public servants, private companies, and their representatives.
- 3. The Company and its Employees must comply with the anti-corruption laws of the Republic of Kazakhstan, as well as the principles and requirements of the Policy, in any country worldwide.
- KEY PRINCIPLES
5.1. Counterparty Due Diligence
The Company makes reasonable efforts to minimize the risk of business relationships with counterparties that may be involved in corrupt activities by assessing counterparties’ tolerance to bribery, including checking for their own anti-corruption procedures or policies, their readiness to comply with the requirements of this Policy and include anti-corruption clauses in contracts, and providing mutual assistance for ethical business conduct and corruption prevention.
5.2. Information and Training
The Company makes this Policy freely available via informational notices in the Company’s offices, openly declares zero tolerance for corruption, welcomes and encourages compliance with the principles and requirements of this Policy by all counterparties, Employees, and other persons, and promotes higher anti-corruption culture through information and training.
- GIFTS AND HOSPITALITY EXPENSES
6.1. Gifts and hospitality expenses, including business entertainment, that Employees may provide to other persons and organizations on behalf of the Company, or that Employees may receive from other persons and organizations in connection with their work in the Company, must meet all five criteria listed below:
- be directly related to the legitimate business objectives of the Company, such as presentations or completion of business projects, conferences, successful execution of contracts, or generally recognized holidays such as Christmas and New Year, International Women’s Day, memorable dates, anniversaries;
- be reasonably justified, proportionate, and not constitute luxury items;
- not represent a concealed reward for a service, action, inaction, connivance, patronage, granting of rights, making a specific transaction, agreement, license, permission decision, etc., or an attempt to influence the recipient for another unlawful or unethical purpose;
- not create reputational risks for the Company, Employees, and other persons in the event of disclosure of information regarding gifts or hospitality expenses;
- not contradict the principles and requirements of this Policy, other internal documents of the Company, and the norms of applicable legislation.
6.2. Gifts in the form of promotional merchandise (low-cost items) bearing the Company’s logo, provided at exhibitions, open presentations, forums, and other representative and marketing events in which the Company officially participates, are permitted and considered branding materials.
6.3. Gifts on behalf of the Company, its Employees, and representatives to third parties in the form of cash, in cash or non-cash form, in any currency, are not permitted.
- PARTICIPATION IN CHARITABLE ACTIVITIES AND SPONSORSHIP
7.1. The Company does not finance charitable and sponsorship projects for the purpose of obtaining commercial advantages in specific projects of the Company.
- PARTICIPATION IN POLITICAL ACTIVITIES
8.1. The Company does not finance political parties, organizations, and movements for the purpose of obtaining commercial advantages in specific projects of the Company.
- INTERACTION WITH PUBLIC SERVANTS
9.1. The Company refrains from paying any expenses for public servants and their close relatives (or in their interests) for the purpose of obtaining commercial advantages in specific projects of the Company, including expenses for transport, accommodation, meals, entertainment, etc., or obtaining any other benefits at the expense of the Company.
- INTERACTION WITH EMPLOYEES
10.1. The Company requires its Employees to comply with this Policy by informing them of key principles, requirements, and penalties for violations.
10.2. As part of fostering an appropriate anti-corruption culture within the Company, periodic informational seminars in in-person and/or remote formats are held for Employees, along with introductory training sessions on the provisions of this Policy and related documents for all new Company Employees.
10.3. Compliance by Company Employees with the principles and requirements of this Policy is taken into account when forming the talent pool for promotion to higher positions, as well as when applying disciplinary penalties.
- PAYMENTS THROUGH INTERMEDIARIES OR FOR THE BENEFIT OF THIRD PARTIES
11.1. The Company and its Employees are prohibited from engaging or using intermediaries, partners, agents, joint ventures, or other persons to commit any actions that contradict the principles and requirements of this Policy or applicable anti-corruption legislation.
11.2. The Company ensures the presence of procedures for vetting intermediaries, partners, agents, joint ventures, and other persons to prevent and/or detect the violations described above in order to minimize and suppress risks of involving the Company in corrupt activities.
- MAINTENANCE OF ACCOUNTING BOOKS AND RECORDS
12.1. All financial transactions must be accurately, properly, and with a sufficient level of detail reflected in the Company’s accounting records, documented, and available for audit.
12.2. The Company has appointed employees who bear personal responsibility for preparing and submitting complete and reliable financial reporting within the deadlines established by applicable legislation.
12.3. Distortion or falsification of the Company’s financial reporting is strictly prohibited and regarded as fraud.
- NON-RETALIATION AND PROTECTION FROM SANCTIONS
13.1. The Company declares that no Employee will be subjected to sanctions (including dismissal, demotion, loss of bonus) if they reported a suspected act of corruption, or if they refused to give or receive a bribe, engage in commercial bribery, or mediate in bribery, including if such refusal resulted in missed profit or failure to obtain commercial and competitive advantages for the Company.
- AMENDMENTS
14.1. If insufficiently effective provisions of this Policy or related business processes of the Company are identified, or if the requirements of applicable RK legislation change, the Director of the Company organizes the development and implementation of an action plan to update this Policy and/or business processes.
- LIABILITY FOR NON-COMPLIANCE (IMPROPER COMPLIANCE) WITH THIS POLICY
15.1. Employees of all structural units of the Company, regardless of their position, bear personal responsibility for compliance with the principles and requirements of this Policy, as well as for the actions (inaction) of subordinate persons violating these principles and requirements.
15.2. Since the Company may be subject to sanctions for the participation of its Employees, counterparties, and other persons in corrupt activities, internal investigations will be initiated for each reasonably substantiated suspicion or established fact of corruption within the limits permitted by applicable legislation.
15.3. Persons guilty of violating the requirements of this Policy may be brought to disciplinary, administrative, civil, or criminal liability upon the initiative of the Company, law enforcement agencies, or other persons in the manner and on the grounds provided for by the legislation of the Republic of Kazakhstan, regulatory acts, and employment contracts.
General Director
RBC Group LLP
Oleg Bibik