Anti-Corruption Policy
QANSAT ENERGY LLC
QANSAT ENERGY LLC
1. Purpose of the document
1.1. This Anti—Corruption Policy (hereinafter referred to as the "Policy") is a document of QANSAT ENERGY LLP (hereinafter referred to as the Company) that defines key principles and requirements aimed at preventing corruption and complying with applicable anti—corruption legislation by the Company, members of management bodies, employees and other persons who may act on behalf of the Company.
1.2. The Policy has been developed in accordance with the legislation of the Republic of Kazakhstan, the Charter and other internal documents of the Company, taking into account the requirements of generally recognized principles and norms of international law and international treaties.
1.3. The policy is formulated taking into account the fact that in Kazakhstan and other countries of the world, "corruption", "corrupt actions", "corrupt activities", as a rule, will be considered giving or receiving bribes, mediation in giving or receiving bribes, abuse of official position or authority, commercial bribery, payments to simplify formalities, illegal the use of an official's position to obtain benefits in the form of money, valuables, other property, services, any rights for oneself or for other persons, or the illegal granting of benefits or rights to this person by other persons.
2. Policy objectives
2.1. The Policy reflects the commitment of the Company and its management to high ethical standards and principles of open and honest business conduct, as well as the Company's commitment to maintaining its business reputation at an appropriate level.
2.2. The Company sets goals for itself:
• To minimize the risk of involvement of the Company, the CEO and employees of the Company, regardless of their position (hereinafter collectively referred to as "Employees") in corrupt activities.
• To form a uniform understanding of the Company's anti-corruption policy in all forms and manifestations among counterparties, employees, employees and others.
• Establish the obligation of the Company's employees to know and comply with the principles and requirements of this Policy, the key norms of applicable anti-corruption legislation, as well as adequate procedures to prevent corruption.
3. Scope and responsibilities
3.1. All employees of the Company must be guided by this Policy and strictly adhere to its principles and requirements.
3.2. The principles and requirements of this Policy apply to contractors and representatives of the Company, employees, as well as other persons, in cases where the relevant obligations are stipulated in contracts with them, in their internal documents, or directly follow from the law.
4. Applicable anti-corruption legislation
4.1. Kazakhstan's anti-corruption legislation: employees must comply with the norms of Kazakhstan's anti-corruption legislation, established, inter alia, by the Criminal Code of the Republic of Kazakhstan, the Code of Administrative Offenses of the Republic of Kazakhstan, the Law of the Republic of Kazakhstan "On Combating Corruption" and other regulatory acts.
4.2. Generally recognized principles and norms of international law, the main requirements of which are formulated as:
4.2.1. prohibition of giving bribes, i.e. providing or promising to provide any financial or other benefit/advantage with the intent to induce any person to perform his official duties improperly;
4.2.2. prohibition of receiving bribes, i.e. obtaining or agreeing to receive any financial or other benefit/advantage for performing their official duties improperly;
4.2.3. prohibition of bribing government employees, i.e. providing or promising to provide (directly or through third parties) any financial or other benefits/advantages to a government employee in order to influence the performance of his official duties in order to obtain/retain business or provide competitive or other advantages for a commercial organization;
4.2.4. the inability of a commercial organization to prevent a person associated with it from giving a bribe to another person on behalf of such a commercial organization, i.e. if the commercial organization does not prove that it has adequate procedures in place to prevent bribery, such an organization is responsible for giving a bribe to a person providing services in the interests of a commercial organization or on its behalf (for example, an agent, a subsidiary, an employee) in order to acquire or maintain a business, to provide commercial and competitive advantages.
4.3. Taking into account the above, all employees of the Company are strictly prohibited, directly or indirectly, personally or through the mediation of third parties, from participating in corrupt activities, offering, giving, promising, asking for and receiving bribes or making payments to simplify administrative, bureaucratic and other formalities in any form, including in the form of cash, values, services or other benefits, to any persons or from any persons or organizations, including commercial organizations, government and local government bodies, government employees, private companies and their representatives.
4.4. The Company and its employees must comply with the generally recognized principles and norms of international law and international treaties of the Republic of Kazakhstan, the anti-corruption laws of the Republic of Kazakhstan, as well as the principles and requirements of the Policy in any country of the world.
5. Key principles
5.1. The mission of the top management
The General Director of the Company and his deputies in the areas of activity should form an ethical standard of uncompromising attitude towards any forms and manifestations of corruption at all levels, setting an example by their behavior and familiarizing all employees and contractors with the anti-corruption policy.
5.2. Adequate anti-corruption procedures
The Company develops and implements adequate corruption prevention procedures that are reasonably responsive to the identified risks, and monitors their compliance.
5.3. Verification of counterparties
The Company makes reasonable efforts to minimize the risk of business relationships with counterparties that may be involved in corrupt activities, for which the counterparties' tolerance for bribery is checked, including checking whether they have their own anti-corruption procedures or policies, their willingness to comply with the requirements of this Policy and include anti-corruption conditions (clauses) in contracts, and also provide mutual assistance for ethical business conduct and prevention of corruption.
5.4. Information and training
The Company makes this Policy freely available on the corporate website on the Internet, openly declares its rejection of corruption, welcomes and encourages compliance with the principles and requirements of this Policy by all counterparties, its employees, employees and others.
The Company promotes the improvement of the anti-corruption culture by informing and systematically training employees in order to maintain their awareness of the company's anti-corruption policy and to master the ways and techniques of applying anti-corruption policy in practice.
6. Gifts and representation expenses
6.1. Gifts 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 at the Company, as well as representation expenses, including business hospitality and Company promotion expenses, which employees may bear on behalf of the Company, must simultaneously meet the five criteria listed below:
• be directly related to the legitimate goals of the Company's activities, such as the presentation or completion of business projects, the successful execution of contracts, or national holidays, commemorations, anniversaries;
• be reasonably reasonable, proportionate, and not considered luxury items;
• do not represent a hidden reward for a service, action, omission, connivance, patronage, granting rights, making a specific decision on a transaction, agreement, license, permit, etc., or an attempt to influence the recipient for another illegal or unethical purpose;
• not to create reputational risk for the Company, employees and others in case of disclosure of information about gifts or representative expenses;
• do not contradict the principles and requirements of this Policy, the Code of Business Ethics, other internal documents of the Company and the norms of applicable legislation.
6.2. Gifts on behalf of the Company, its employees and representatives to third parties in the form of cash, both cash and non-cash, regardless of the currency, are not allowed.
7. Participation in charity activities and sponsorship
7.1. The Company implements a unified regional charity policy aimed at creating the image of the organization as a socially responsible business. The Company does not finance charitable or sponsorship projects in order to gain commercial advantages in specific projects.
8. Participation in political activities
8.1. The Company does not finance political parties, organizations, or movements in order to gain commercial advantages in specific projects.
9. Interaction with government employees
9.1. The Company refrains from paying any expenses for government employees and their close relatives (or in their interests) in order to obtain commercial advantages in specific Company projects, including transportation, accommodation, meals, entertainment, PR campaigns, etc., or to receive other benefits at the expense of the Company.
10. Interaction with employees
10.1. The Company requires its employees to comply with this Policy by informing them of the key principles, requirements and sanctions for violations and including them in the official duties of the Company's employees.
11. Counterparties
11.1. The Company makes reasonable efforts to ensure that the fundamental principles and requirements of this Policy are respected by its counterparties.
12. Interaction with intermediaries and other persons
12.1. The Company and its employees are prohibited from engaging or using intermediaries, partners, agents or other persons, counterparties to commit any actions that contradict the principles and requirements of this Policy or the norms of applicable anti-corruption legislation.
12.2. The Company ensures that procedures are in place to verify intermediaries, partners, agents, joint ventures and other persons in order to prevent and/or identify the violations described above in order to minimize and suppress the risks of the Company's involvement in corrupt activities.
12.3. In order to comply with the principles and requirements stipulated in the Policy, the Company includes anti-corruption conditions (clauses) in contracts with intermediaries, partners, agents, counterparties and other persons. The anti-corruption terms (clauses) should contain information about the Policy and system of anti-corruption procedures in force in the Company, if necessary, provide for the Policy as an annex to contracts, and determine the responsibility of counterparties for non-compliance with the principles and requirements of the Policy.
13. Maintaining accounting books and records
13.1. All financial transactions must be accurately, correctly and with a sufficient level of detail reflected in the accounting records of the Company, documented and available for verification.
13.2. The Company has appointed employees who are responsible, in accordance with the current legislation of the Republic of Kazakhstan, for the preparation and provision of complete and reliable accounting statements within the time limits established by applicable law.
13.3. Misrepresentation or falsification of the Company's accounting statements is strictly prohibited and is considered fraud.
14. Notification of deficiencies
14.1. Any employee or other person, in case of doubts about the legality or in accordance with the goals, principles and requirements of the Policy of their actions, as well as actions, omissions or proposals of other employees, contractors or other persons who interact with the Company, may inform their immediate supervisor and/or the authorized body (authorized to a person), who, if necessary, will provide recommendations and clarifications regarding the current situation.
15. Refusal of retaliatory measures and sanctions
15.1. The Company declares that no employee will be sanctioned (including dismissed, demoted, or stripped of his bonus) if he reported an alleged fact of corruption, or if he refused to give or receive a bribe, commit commercial bribery, or mediate bribery, including if as a result of this refusal, the Company lost profits or did not gain commercial and competitive advantages.
16.Audit and control
16.1. The Company regularly conducts an internal audit of financial and business activities, monitoring the completeness and correctness of accounting records and compliance with the requirements of applicable legislation and internal regulatory documents of the Company, including the principles and requirements established by this Policy.
17. Reporting
17.1. The Authorized Person periodically reviews reports from the heads of the Company's structural divisions on the results of work to ensure that the activities of the Company and its employees comply with the principles and requirements of this Policy and the applicable anti-corruption legislation.
18. Responsibility for non-fulfillment (improper fulfillment) of this Policy
18.1. Employees of all structural divisions of the Company, regardless of their position, are responsible, in accordance with the current legislation of the Republic of Kazakhstan, for compliance with the principles and requirements of this Policy, as well as for actions (inaction) of their subordinates that violate these principles and requirements.
18.2. Since the Company may be held criminally liable in accordance with the legislation of the Republic of Kazakhstan for the involvement of Company employees, counterparties and other persons in corrupt activities, official investigations will be initiated for each reasonably substantiated suspicion or established fact of corruption within the framework permitted by applicable law.
18.3. Persons guilty of violating the requirements of this Policy may be brought to disciplinary, administrative, civil or criminal liability on the initiative of the Company, law enforcement agencies or other persons in accordance with the procedure and on the grounds provided for by the legislation of the Republic of Kazakhstan, the Company's Charter, local regulations and employment contracts.
1.1. This Anti—Corruption Policy (hereinafter referred to as the "Policy") is a document of QANSAT ENERGY LLP (hereinafter referred to as the Company) that defines key principles and requirements aimed at preventing corruption and complying with applicable anti—corruption legislation by the Company, members of management bodies, employees and other persons who may act on behalf of the Company.
1.2. The Policy has been developed in accordance with the legislation of the Republic of Kazakhstan, the Charter and other internal documents of the Company, taking into account the requirements of generally recognized principles and norms of international law and international treaties.
1.3. The policy is formulated taking into account the fact that in Kazakhstan and other countries of the world, "corruption", "corrupt actions", "corrupt activities", as a rule, will be considered giving or receiving bribes, mediation in giving or receiving bribes, abuse of official position or authority, commercial bribery, payments to simplify formalities, illegal the use of an official's position to obtain benefits in the form of money, valuables, other property, services, any rights for oneself or for other persons, or the illegal granting of benefits or rights to this person by other persons.
2. Policy objectives
2.1. The Policy reflects the commitment of the Company and its management to high ethical standards and principles of open and honest business conduct, as well as the Company's commitment to maintaining its business reputation at an appropriate level.
2.2. The Company sets goals for itself:
• To minimize the risk of involvement of the Company, the CEO and employees of the Company, regardless of their position (hereinafter collectively referred to as "Employees") in corrupt activities.
• To form a uniform understanding of the Company's anti-corruption policy in all forms and manifestations among counterparties, employees, employees and others.
• Establish the obligation of the Company's employees to know and comply with the principles and requirements of this Policy, the key norms of applicable anti-corruption legislation, as well as adequate procedures to prevent corruption.
3. Scope and responsibilities
3.1. All employees of the Company must be guided by this Policy and strictly adhere to its principles and requirements.
3.2. The principles and requirements of this Policy apply to contractors and representatives of the Company, employees, as well as other persons, in cases where the relevant obligations are stipulated in contracts with them, in their internal documents, or directly follow from the law.
4. Applicable anti-corruption legislation
4.1. Kazakhstan's anti-corruption legislation: employees must comply with the norms of Kazakhstan's anti-corruption legislation, established, inter alia, by the Criminal Code of the Republic of Kazakhstan, the Code of Administrative Offenses of the Republic of Kazakhstan, the Law of the Republic of Kazakhstan "On Combating Corruption" and other regulatory acts.
4.2. Generally recognized principles and norms of international law, the main requirements of which are formulated as:
4.2.1. prohibition of giving bribes, i.e. providing or promising to provide any financial or other benefit/advantage with the intent to induce any person to perform his official duties improperly;
4.2.2. prohibition of receiving bribes, i.e. obtaining or agreeing to receive any financial or other benefit/advantage for performing their official duties improperly;
4.2.3. prohibition of bribing government employees, i.e. providing or promising to provide (directly or through third parties) any financial or other benefits/advantages to a government employee in order to influence the performance of his official duties in order to obtain/retain business or provide competitive or other advantages for a commercial organization;
4.2.4. the inability of a commercial organization to prevent a person associated with it from giving a bribe to another person on behalf of such a commercial organization, i.e. if the commercial organization does not prove that it has adequate procedures in place to prevent bribery, such an organization is responsible for giving a bribe to a person providing services in the interests of a commercial organization or on its behalf (for example, an agent, a subsidiary, an employee) in order to acquire or maintain a business, to provide commercial and competitive advantages.
4.3. Taking into account the above, all employees of the Company are strictly prohibited, directly or indirectly, personally or through the mediation of third parties, from participating in corrupt activities, offering, giving, promising, asking for and receiving bribes or making payments to simplify administrative, bureaucratic and other formalities in any form, including in the form of cash, values, services or other benefits, to any persons or from any persons or organizations, including commercial organizations, government and local government bodies, government employees, private companies and their representatives.
4.4. The Company and its employees must comply with the generally recognized principles and norms of international law and international treaties of the Republic of Kazakhstan, the anti-corruption laws of the Republic of Kazakhstan, as well as the principles and requirements of the Policy in any country of the world.
5. Key principles
5.1. The mission of the top management
The General Director of the Company and his deputies in the areas of activity should form an ethical standard of uncompromising attitude towards any forms and manifestations of corruption at all levels, setting an example by their behavior and familiarizing all employees and contractors with the anti-corruption policy.
5.2. Adequate anti-corruption procedures
The Company develops and implements adequate corruption prevention procedures that are reasonably responsive to the identified risks, and monitors their compliance.
5.3. Verification of counterparties
The Company makes reasonable efforts to minimize the risk of business relationships with counterparties that may be involved in corrupt activities, for which the counterparties' tolerance for bribery is checked, including checking whether they have their own anti-corruption procedures or policies, their willingness to comply with the requirements of this Policy and include anti-corruption conditions (clauses) in contracts, and also provide mutual assistance for ethical business conduct and prevention of corruption.
5.4. Information and training
The Company makes this Policy freely available on the corporate website on the Internet, openly declares its rejection of corruption, welcomes and encourages compliance with the principles and requirements of this Policy by all counterparties, its employees, employees and others.
The Company promotes the improvement of the anti-corruption culture by informing and systematically training employees in order to maintain their awareness of the company's anti-corruption policy and to master the ways and techniques of applying anti-corruption policy in practice.
6. Gifts and representation expenses
6.1. Gifts 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 at the Company, as well as representation expenses, including business hospitality and Company promotion expenses, which employees may bear on behalf of the Company, must simultaneously meet the five criteria listed below:
• be directly related to the legitimate goals of the Company's activities, such as the presentation or completion of business projects, the successful execution of contracts, or national holidays, commemorations, anniversaries;
• be reasonably reasonable, proportionate, and not considered luxury items;
• do not represent a hidden reward for a service, action, omission, connivance, patronage, granting rights, making a specific decision on a transaction, agreement, license, permit, etc., or an attempt to influence the recipient for another illegal or unethical purpose;
• not to create reputational risk for the Company, employees and others in case of disclosure of information about gifts or representative expenses;
• do not contradict the principles and requirements of this Policy, the Code of Business Ethics, other internal documents of the Company and the norms of applicable legislation.
6.2. Gifts on behalf of the Company, its employees and representatives to third parties in the form of cash, both cash and non-cash, regardless of the currency, are not allowed.
7. Participation in charity activities and sponsorship
7.1. The Company implements a unified regional charity policy aimed at creating the image of the organization as a socially responsible business. The Company does not finance charitable or sponsorship projects in order to gain commercial advantages in specific projects.
8. Participation in political activities
8.1. The Company does not finance political parties, organizations, or movements in order to gain commercial advantages in specific projects.
9. Interaction with government employees
9.1. The Company refrains from paying any expenses for government employees and their close relatives (or in their interests) in order to obtain commercial advantages in specific Company projects, including transportation, accommodation, meals, entertainment, PR campaigns, etc., or to receive other benefits at the expense of the Company.
10. Interaction with employees
10.1. The Company requires its employees to comply with this Policy by informing them of the key principles, requirements and sanctions for violations and including them in the official duties of the Company's employees.
11. Counterparties
11.1. The Company makes reasonable efforts to ensure that the fundamental principles and requirements of this Policy are respected by its counterparties.
12. Interaction with intermediaries and other persons
12.1. The Company and its employees are prohibited from engaging or using intermediaries, partners, agents or other persons, counterparties to commit any actions that contradict the principles and requirements of this Policy or the norms of applicable anti-corruption legislation.
12.2. The Company ensures that procedures are in place to verify intermediaries, partners, agents, joint ventures and other persons in order to prevent and/or identify the violations described above in order to minimize and suppress the risks of the Company's involvement in corrupt activities.
12.3. In order to comply with the principles and requirements stipulated in the Policy, the Company includes anti-corruption conditions (clauses) in contracts with intermediaries, partners, agents, counterparties and other persons. The anti-corruption terms (clauses) should contain information about the Policy and system of anti-corruption procedures in force in the Company, if necessary, provide for the Policy as an annex to contracts, and determine the responsibility of counterparties for non-compliance with the principles and requirements of the Policy.
13. Maintaining accounting books and records
13.1. All financial transactions must be accurately, correctly and with a sufficient level of detail reflected in the accounting records of the Company, documented and available for verification.
13.2. The Company has appointed employees who are responsible, in accordance with the current legislation of the Republic of Kazakhstan, for the preparation and provision of complete and reliable accounting statements within the time limits established by applicable law.
13.3. Misrepresentation or falsification of the Company's accounting statements is strictly prohibited and is considered fraud.
14. Notification of deficiencies
14.1. Any employee or other person, in case of doubts about the legality or in accordance with the goals, principles and requirements of the Policy of their actions, as well as actions, omissions or proposals of other employees, contractors or other persons who interact with the Company, may inform their immediate supervisor and/or the authorized body (authorized to a person), who, if necessary, will provide recommendations and clarifications regarding the current situation.
15. Refusal of retaliatory measures and sanctions
15.1. The Company declares that no employee will be sanctioned (including dismissed, demoted, or stripped of his bonus) if he reported an alleged fact of corruption, or if he refused to give or receive a bribe, commit commercial bribery, or mediate bribery, including if as a result of this refusal, the Company lost profits or did not gain commercial and competitive advantages.
16.Audit and control
16.1. The Company regularly conducts an internal audit of financial and business activities, monitoring the completeness and correctness of accounting records and compliance with the requirements of applicable legislation and internal regulatory documents of the Company, including the principles and requirements established by this Policy.
17. Reporting
17.1. The Authorized Person periodically reviews reports from the heads of the Company's structural divisions on the results of work to ensure that the activities of the Company and its employees comply with the principles and requirements of this Policy and the applicable anti-corruption legislation.
18. Responsibility for non-fulfillment (improper fulfillment) of this Policy
18.1. Employees of all structural divisions of the Company, regardless of their position, are responsible, in accordance with the current legislation of the Republic of Kazakhstan, for compliance with the principles and requirements of this Policy, as well as for actions (inaction) of their subordinates that violate these principles and requirements.
18.2. Since the Company may be held criminally liable in accordance with the legislation of the Republic of Kazakhstan for the involvement of Company employees, counterparties and other persons in corrupt activities, official investigations will be initiated for each reasonably substantiated suspicion or established fact of corruption within the framework permitted by applicable law.
18.3. Persons guilty of violating the requirements of this Policy may be brought to disciplinary, administrative, civil or criminal liability on the initiative of the Company, law enforcement agencies or other persons in accordance with the procedure and on the grounds provided for by the legislation of the Republic of Kazakhstan, the Company's Charter, local regulations and employment contracts.
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