Anti-Corruption and Compliance

The Bank places special emphasis on anti-corruption measures. This area of work is carried out continuously and in strict compliance with the laws of the Republic of Kazakhstan and the Bank’s internal regulations.

To prevent corruption, the Bank systematically implements a series of preventive actions designed to completely eliminate corrupt behavior.

The Bank has developed and approved an Anti-Corruption Policy and related Rules. Specific procedures and internal controls, including those related to HR management, have been incorporated into the Bank’s internal documents.

The Bank conducts regular internal training for employees on anti-corruption matters, including mandatory knowledge testing.

On 12 April 2024, with the aim of preventing and combating violations of anti-corruption law, Lyazzat Ibragimova, Chair of the Management Board, together with representatives of the Compliance Control and Security Departments, held a meeting with all Bank employees.

The employees were informed of a report received concerning the gifting of a present to a Bank official. During the meeting, employees were given explanations regarding the applicable laws and internal regulations on anti-corruption compliance, the consequences of breaches, and the sanctions that could be imposed. The Chair of the Management Board firmly emphasized that the giving or acceptance of gifts by Bank employees in any form is strictly prohibited.

The Chair of the Management Board emphasized the Bank’s zero-tolerance policy for breaches of anti-corruption laws and internal procedures.

In 2024, a total of 1,284 consultants from the Central Office and 20 regional branches, along with 1,440 employees from the Central Office and branches, completed anti-corruption training and passed the associated testing.

The Compliance Control Department is a division performing anti-corruption compliance functions in the Bank, is independent from any activities of the Bank’s structural units and reports through the Chief Compliance Officer to the Board of Directors of the Bank.

All employees of the Bank and individuals providing services to the Bank on the basis of civil law contracts, regardless of their position, are warned of the obligation to report facts of corruption known to them in the Bank to their immediate supervisors or to the Security Department or confidentially via the hotline. Each employee is personally liable for failing to report any known involvement of Bank personnel in corrupt practices.

To prevent corruption, the Bank systematically implements a series of preventive actions designed to completely eliminate corrupt behavior.

The Bank operates a confidential Hotline, which serves as a secure channel for reporting potential violations of anti-corruption policies by employees or consultants. Analysis of the reports received in 2024 showed that all of them were informational or advisory in nature and did not include evidence implicating Bank employees in corrupt practices.

On a quarterly basis, the Bank provides updates to the Anti-Corruption Agency of the Republic of Kazakhstan regarding the presence or absence of cases in which Bank executives have been held liable for corruption offenses committed by subordinates.

Based on the results of personnel training, the awareness of the Bank’s personnel of the Bank’s anti-corruption activities, restrictions and obligations, and feedback channels was increased. It is expected that the measures taken will minimize the risk of corruption manifestations in the Bank’s activities.

In Q2 2024, the Bank conducted a themed anti-corruption monitoring. The findings of the monitoring were reported to the Chair of the Management Board and submitted on 5 June 2024, to the Anti-Corruption Agency of the Republic of Kazakhstan.

In Q3 2024, the Bank carried out an internal corruption risk assessment focused on the operations of the HR and Organizational Activities Management Department of Otbasy Bank JSC, specifically in the areas of personnel administration and remuneration. Based on the results, a corrective Action Plan was developed to address the causes and conditions contributing to corruption risks identified during the internal analysis of the HR and Organizational Activities Management Department of Otbasy Bank JSC. The analytical report and the Action Plan were published on the Bank’s official website.

No incident of corrupt practices involving Bank employees were identified during the reporting year.