Ethics and compliance system of fair business conduct
Approach and principles
GRI 2-23, 3-3, GRI 12: Coal Sector: 12.20.1
“Samruk-Energy” JSC adheres to high standards of business ethics and principles of fair business conduct, being aware of its responsibility to the shareholder, partners and society. The Company considers compliance with the norms of corporate ethics and an effective system for preventing corruption as key conditions for sustainable development, increasing transparency of activities and building trust on the part of stakeholders.
The zero-tolerance policy on corruption applies to all levels of management and all stages of operations across the Samruk-Energy JSC Group.
The principles and norms of business ethics in “Samruk-Energy” JSC are formed on the basis of the legislation of the Republic of Kazakhstan, international standards and best practices in the field of compliance and sustainable development. The Company adheres to the principle of zero tolerance for corruption, actively implements preventive measures to prevent corruption risks and manage conflicts of interest. These requirements apply to both the Company’s employees and business partners.
In 2025, “Samruk-Energy” JSC continued to develop the compliance and corporate ethics system in accordance with the best international corporate governance practices. The main attention was paid to strengthening the culture of integrity, improving compliance risk management mechanisms and increasing the transparency of business processes.
Compliance system regulatory documents
Compliance activities are carried out on the basis of key corporate documents regulating ethics and anti-corruption issues
- Code of Conduct of "Samruk-Energy" JSC (approved in 2023)
- Anti-Corruption Policy of "Samruk-Energy" JSC (updated in 2024)
- Compliance Risk Management Policy of "Samruk-Energy" JSC (updated in 2025)
- Policy of initiative informing of "Samruk-Energy" JSC
- Policy for Settlement of Corporate Conflicts and Conflicts of Interest of "Samruk-Energy" JSC
- Corporate Standard for Compliance Functions of Samruk-Kazyna Group (implemented in 2025)
- Regulation on the "Compliance" Service of "Samruk-Energy" JSC
- Regulations for consideration of appeals and internal investigations registered in the information system of the compliance function, compliance functions of the group of Samruk-Kazyna JSC to the Corporate Standard for the compliance function of the group of Samruk-Kazyna JSC.
Corporate culture and business ethics
Code of Conduct
GRI 2-26
The Code of Conduct of "Samruk-Energy" JSC is the main document of the corporate ethics and compliance system, which defines the values, principles and standards of business conduct of employees and officials of the Company. The Code is aimed at forming a high corporate culture, ensuring transparency of activities and strengthening trust on the part of the shareholder and other stakeholders.
The Code establishes uniform requirements for compliance with business ethics and responsible business conduct, including human rights issues, prevention of conflicts of interest, anti-corruption, compliance with antitrust laws, transparency of financial reporting and protection of confidential and insider information. It is based on the Company's corporate values of mentorship, reliability, fairness and professionalism.
The provisions of the Code apply to all employees, officers and directors of the Company. Subsidiaries and affiliates apply it taking into account the specifics of their activities and the level of compliance risks. Business partners and suppliers are recommended to adhere to similar standards of business ethics.
Compliance with the Code of Conduct is monitored by the Board of Directors. The Compliance Service and the Ombudsman provide monitoring, advice and internal investigations. All employees of the group of companies ensure the implementation of the norms and provisions of the Code. Information on compliance with the Code is regularly reviewed by the Audit Committee and the Board of Directors. The Company provides confidential channels for reporting violations and protecting those who report them in good faith.
At the end of 2025, no violations of the Code of Conduct by members of the Board of Directors and the executive body were revealed.
The Company places the Code of Conduct of "Samruk-Energy" JSC on the corporate website in the public domain, providing an opportunity for its familiarisation by potential suppliers and contractors. This promotes transparency and interaction and compliance with uniform standards of business ethics and compliance
The Code of Conduct can be found at: https://samruk-energy.kz/images/AAINTRO/11.pdf
Management structure and distribution of roles
GRI 2-24
"Samruk-Energy" JSC has an anti-corruption management system aimed at ensuring compliance with anti-corruption standards and reducing the risks of corruption in its activities.
| Organ | Responsibility |
|---|---|
| Board of Directors |
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| Management Board |
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| Compliance Service |
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| Heads of structural divisions |
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| Employees and Officers |
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| Counterparties and third parties |
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Corruption Risk Management and Countermeasures
Monitoring and Assessment of Corruption Risks
"Samruk-Energy" JSC applies a risk-based approach to compliance risk management. Regularly monitors and analyzes corruption risks in accordance with the legislation of the Republic of Kazakhstan and the Company's internal regulatory documents.
The purpose of this work is to identify the factors that contribute to the emergence of corruption offenses, as well as to develop measures to eliminate and prevent them.
In 2025, the Board of Directors of the Company approved the Compliance Risk Management Policy of "Samruk-Energy" JSC, which establishes a systematic approach to identifying, assessing and minimizing compliance and corruption risks, preventing corruption offenses.
According to the Compliance Risk Management Policy of "Samruk-Energy" JSC, the identification of corruption risks in "Samruk-Energy" JSC is carried out within the framework of the compliance risk management system. The key tools are anti-corruption monitoring, internal analysis of corruption risks, compliance investigations (internal investigations), as well as other tools established by the legislation of the Republic of Kazakhstan and internal regulatory documents of Samruk-Kazyna JSC, Samruk-Energy JSC. The results of the analysis are formalised in the form of a register of compliance risks, which are reflected in the Plan for minimizing corruption risks of "Samruk-Energy" JSC and in the consolidated Risk Register of "Samruk-Energy" JSC.
GRI 205-1
| Indicator | 2025 | |
|---|---|---|
| pcs. | % | |
| "Samruk-Energy" JSC Group of Companies | 19 A | 100 A |
Subsidiaries and affiliates with significant corruption risks identified
| Organisation | 2025 |
|---|---|
| "Samruk-Energy" JSC Group of Companies | 0 |
Anti-corruption measures
GRI 205-1, 205-3, GRI 12: Coal Sector: 12.20.2, 12.20.4
To prevent corruption, a set of systemic measures is being implemented in the group of companies of "Samruk-Energy" JSC, including
- Internal analysis of corruption risks
- Anti-corruption monitoring
- Internal (Compliance) Investigations
- Third Party Compliance Verification
- Measures to improve the anti-corruption culture
- Adoption of anti-corruption restrictions
- Prevention and detection of conflicts of interest
- Verification of the reliability of counterparties and candidates
- Functioning of the "Hotline" initiative information channels
- Other measures in accordance with the laws of the Republic of Kazakhstan and the Company's internal regulations.
Implementation of the compliance system in 2025
"Samruk-Energy" JSC has an independent "Compliance" Service, which is organisationally and functionally subordinate to the Board of Directors of the Company. The main goal of the "Compliance" Service is to develop and implement a compliance programme, determine an anti-corruption policy, as well as monitor the implementation of anti-corruption measures, including the assessment of corruption risks in "Samruk-Energy" JSC and its subsidiaries and affiliates.
In 2025, we focused on the detailed study of a number of aspects and implemented the following activities
- Adopted and implemented by the decision of the Board of Directors of the Company dated 28 March 2025 (Minutes No. 05/25) the Corporate Standard for the Compliance Function of the Group of Samruk-Kazyna JSC
- Developed and approved by the decision of the Board of Directors of the Company dated 28 March 2025 (Minutes No. 05/25) Compliance Risk Management Policy of "Samruk-Energy" JSC
- Continuous monitoring of compliance with anti-corruption requirements is ensured
- Work was carried out to update internal regulatory documents for compliance with the requirements of international standards in the field of compliance and the legislation of the Republic of Kazakhstan
- Thematic anti-corruption monitoring was carried out, recommendations were made to minimise corruption risks
- Based on the results of anti-corruption monitoring, internal analyses of corruption risks were carried out in the Company and in a number of subsidiaries and affiliates, and recommendations were made to minimise corruption risks
- More than 3,713 due diligence procedures for third parties of the Company and subsidiaries and affiliates were carried out
- About 275 training events were held on the anti-corruption legislation of the Republic of Kazakhstan, corporate culture and ethics
- 75 Appeals were considered, of which 4 were confirmed, 11 were partially confirmed
- Internal audits of the corporate management system were carried out for compliance with the requirements of ISO 37001:2016 "Anti-bribery Management Systems" in "Samruk-Energy" JSC group of companies.
In 2025, "Samruk-Energy" JSC group of companies successfully passed the recertification of the corporate management system for compliance with the requirements of the international standard ISO 37001:2016 "Anti-bribery management systems. Requirements and Guidelines for Their Use".
In addition, "Samruk-Energy" JSC confirmed compliance with the requirements of the international standard ISO 37301:2021 "Compliance Management Systems. Requirements and Guidelines for Their Application", becoming one of the first holders of this certification in the group of companies of Samruk-Kazyna JSC.
Obtaining and confirming international certification demonstrates the compliance of the Company's corporate management system with the best international practices in the field of compliance, anti-corruption and risk management.
As part of the development of the compliance function in the group of companies of "Samruk-Energy" JSC, the Compliance Service during 2025 conducted training and methodological sessions for compliance officers of subsidiaries and affiliates.
The main purpose of these events was to improve the professional competence of compliance officers, develop a unified approach, as well as exchange practical experience in the field of compliance risk management and anti-corruption.
This practice helps ensure the effective implementation of the principles of fair business conduct, improve the quality of compliance risk management and strengthen the anti-corruption culture in "Samruk-Energy" JSC group of companies.
Training and awareness raising
GRI 2-24, 205-2, GRI 12: Coal Sector: 12.20.3
In order to form an anti-corruption culture and maintain the principle of zero tolerance for any forms of bribery and corruption, "Samruk-Energy" JSC Group of Companies regularly conducts training and information events for employees and business partners.
The training is aimed at raising the level of awareness of employees about the requirements of the anti-corruption legislation of the Republic of Kazakhstan, the Company's internal regulatory documents and the principles of business ethics, as well as developing skills for timely identification and prevention of corruption risks.
In 2025, as part of anti-corruption efforts, training seminars, mailings and information meetings were organised for employees of the Company and its subsidiaries and affiliates, including meetings with representatives of the authorised bodies to explain changes in anti-corruption legislation.
In 2025, about 275 training events were held in the group of companies of "Samruk-Energy" JSC, within the framework of which anti-corruption issues, compliance requirements, changes in the legislation of the Republic of Kazakhstan and the procedure for using feedback mechanisms, including the work of initiative information channels "hotline" were considered. Additional specialised trainings are held for the Company's top management.
Main training programmes
- Introduction to compliance (for newly hired employees)
- Code of Conduct of "Samruk-Energy" JSC: features of application in the Company's activities
- Formation of an anti-corruption culture
- Anti-corruption legislation of the Republic of Kazakhstan, taking into account the changes
- Key international organisations and their anti-corruption standards
- Business ethics and the role of top management in the corporate compliance system
- Declaration issues
- Popularisation of the "hotline", procedures for reporting violations.
19,272 employees of "Samruk-Energy" JSC group of companies were familiarised with the requirements of the Anti-Corruption Policy of "Samruk-Energy" JSC, the Code of Conduct of "Samruk-Energy" JSC, industry regulations and internal regulatory documents.
2,983 business partners were informed about the requirements of the Company's anti-corruption policy, the provisions of the Code of Conduct and the operation of the Hotline.
Informing business partners is an important element of the compliance system and is aimed at ensuring transparency of interaction with counterparties, as well as preventing corruption and reputational risks.
Informing employees and business partners about the anti-corruption policy of "Samruk-Energy" JSC
| Indicator | 2023 | 2024 | 2025 | |||
|---|---|---|---|---|---|---|
| people | % | people | % | people | % | |
| management board | 65 | 100% | 29 | 100% | 29 A | 100% A |
| Employees | 11,541 | 100% | 12,247 | 100% | 12,743 A | 100% A |
| Business partners | 2,360 | 100% | 9,235 | 100% | 2,983 A | 100% A |
Number of employees trained in anti-corruption
| Indicator | 2023 | 2024 | 2025 | |||
|---|---|---|---|---|---|---|
| people | % | people | % | people | % | |
| management board | 65 | 100 | 29 | 100% | 29 A | 100% A |
| Employees | 11,541 | 100% | 12,247 | 100% | 12,743 A | 100% A |
Whistleblower feedback and protection mechanism
GRI 2-26
"Samruk-Energy" JSC has a feedback system that provides an opportunity for employees, business partners, investors and other stakeholders to report on possible violations of the legislation of the Republic of Kazakhstan, internal regulatory documents and principles of business ethics.
The Company guarantees the confidentiality of appeals and the protection of persons who report possible violations in good faith from any form of pressure, discrimination or harassment.
To ensure the availability of whistleblowing mechanisms, the Company has the following feedback channels.
Feedback channels
| Hotline (24/7) | https://www.samruk-energy.kz/ru/navigation-and-support/hotline E-mail: mail@sk-hotline.kz Internet portal: www.sk-hotline.kz WhatsApp number: +7 771 191 88 16 Hotline: 8 800 080 47 47 The hotline is operated by an independent operator KPMG |
| Call centre "Nysana" Around the clock, he receives free calls for all social and labour violations, without holidays. | https://nysana.cscc.kz/website E-mail: nysana@cscc.kz Multi-channel phone: 8 800 080 30 30 WhatsApp number: +7 778 120 99 11 |
| Feedback form on the corporate website | https://www.samruk-energy.kz/ru/feedback-all |
| Feedback form for participants in investment projects and local communities. | https://www.samruk-energy.kz/ru/obrat |
| Feedback for shareholders and investors. Investor questionnaire | https://www.samruk-energy.kz/ru/shareholder/ independent-registrar |
| Appeals on emerging issues with contact details on the website | https://www.samrukenergy.kz/ru/company/contact |
| Ombudsman | Email akylov@samruk-energy.kz 8 (7172) 55-30-15, +7-701-788-8416 |
| Blog of the Chairman of the Board | https://www.samrukenergykz/ru/navigation-and-support/chairmans-blog |
The Company has a Unified Database of Complaints and Appeals for the group of companies of "Samruk-Energy" JSC. The Company annually monitors interaction with stakeholders through all feedback channels and analyzes all received appeals (complaints and suggestions) on the group of companies of "Samruk-Energy" JSC. The results of the analysis of the received appeals and complaints are reported to the Board of Directors of the Company on an annual basis.
The results of the analysis contribute to the implementation of the following tasks
- Involvement of managers of the appropriate level in solving the issues and problems raised, taking into account proposals for improving work
- Analysing and taking precautionary action on the concerns of external stakeholders, the public and individuals
- Strengthening the Company's reputation and maintaining confidence in it as a socially responsible energy holding
- Exercise of the Shareholder's rights to receive information on the activities of "Samruk-Energy" JSC.
Hotline operation
"Samruk-Energy" JSC has a system of initiative informing, which is an important element of the corporate compliance and anti-corruption system. One of the key tools of this system is the Hotline, designed for the timely detection and prevention of violations of the legislation of the Republic of Kazakhstan, internal regulatory documents and standards of business ethics.
The hotline is available to the Company's employees, business partners, contractors and other interested parties. Through this mechanism, it is possible to report facts of corruption and fraud, abuse of power, violations of employees' rights, as well as other actions that may damage the Company and its reputation.
The Hotline operates in accordance with the Policy of Initiative Informing of "Samruk-Energy" JSC, aimed at developing a culture of open reporting of possible violations and ensuring the transparency of the Company's activities.
The Hotline is administered by an independent external operator, which ensures the confidentiality of information and the ability to send messages on an anonymous basis. This approach helps to increase confidence in the whistleblowing system and reduce the risk of pressure or prosecution of whistleblowers who report violations in good faith. All appeals received through the Hotline are registered and sent to the Compliance Service, which ensures their professional and confidential consideration.
Every year, the Compliance Service conducts explanatory events and training sessions for employees of the Company and its subsidiaries and affiliates aimed at raising awareness of the Hotline. Information about the Hotline is posted in public places on the territory of all companies of "Samruk-Energy" JSC group.
In 2025, the Hotline received 75 calls.
Confidentiality and anonymity of appeals are guaranteed. Checks were carried out on all appeals and answers were provided.
Specifics of calls to the hotline
- Labour relations
- Misconduct risks
- Procurement complaints
- Occupational safety
- Other
Results and performance indicators
As part of improving the efficiency of interaction with stakeholders, the Company annually monitors the work of Feedback Channels, as well as analyzes the concerns of stakeholders.
The results of monitoring stakeholder engagement are reported to the Board of Directors on an annual basis.
Statistics of appeals and complaints
| Indicator | Quantity | ||
|---|---|---|---|
| 2023 | 2024 | 2025 | |
| Hotline (incl. personal appeals to compliance officers) | 95 | 100 | 75 |
| Office of "Samruk-Energy" JSC, including | 9,339 | 9,999 | 10,677 |
| from the State Authorities | 315 | 1,096 | 760 |
| from the Shareholder | 802 | 793 | 896 |
| Appeals, including those of the offices of subsidiaries and affiliates | 112 | 35 | 213 |
| E-otinish | 92 | 37 | |
| Web portal https//zakup.sk.kz/ | 47 | 38 | |
| Security Service | 0 (11) 12 | 1 (6) | 3 (19) 13 |
| Feedback form on the website | 0 | 0 | 0 |
| Budsmen and trade unions | 41 | 30 (33) 14 | 35 |
| Courts and supervisory authorities | 4 | 20 | 25 |
| Written appeals to the manager (incl. Blog of the manager by company) | 4 | 13 | 42 |
| Conciliation Commissions | 34 | 91 | 40 |
| Total | 290 | 429 | 508 |
- Appeals and complaints considered by the Security Service came from various sources of feedback. The number of appeals and complaints considered by the Security Department is indicated in parentheses.
- Repeat Appeals
- data including the Hotline
Statistics of complaints
- 2024
- 2024
- 2025
Statistics by category
- Appeals
- Complaints
- Proposals/invitations
- Statements of claim
Statistics on the subject of appeals
- Corruption and misappropriation of assets
- Information requests
- Proposals and Cooperation
- Unethical conduct and Harassment
- Against other employees
- Discrimination
- Violations of workplace conditions and OS requirements
- Revocation of disciplinary action and Recalculations
- Procurement
- Charity
- Regarding improper actions and inactions
- Regarding management actions
- Salaries, remuneration and other payments
- Reinstatement and unlawful dismissal
- Other
In the reporting period, we received many different requests related to cooperation in the activities of the group of companies, as well as invitations to various seminars, round tables and other events. The category of "other" includes appeals that were of a one-time nature, including internships, requests for advice within the framework of a graduation project at the university, making an appointment, conducting excursions for schoolchildren, etc.
In the reporting period, stakeholders were interested in issues related to the cancellation of orders on bringing to disciplinary responsibility, labour organisation, violation of working conditions, safety and labour legislation.
In 2025, most of the complaints were received about activities related to procurement procedures, unethical behaviour and abuse of authority of officials, as well as actions/inactions of organisations.
According to the results of 2025, no confirmed cases of discrimination were recorded.
According to the results of 2025, no confirmed facts of corruption were recorded.
Appropriate measures have been taken on confirmed inconsistencies/violations. Confidentiality and anonymity of appeals are guaranteed.
Antitrust Conduct and Fair Competition
GRI 206-1
"Samruk-Energy" JSC carries out its activities in accordance with the principles of fair competition, ensuring compliance with the requirements of antimonopoly legislation in accordance with the Law of the Republic of Kazakhstan "On Natural Monopolies", as well as the Code of Conduct of "Samruk-Energy" JSC and focusing on the best international practices of corporate governance.
Compliance with antitrust requirements is considered by the Company as an integral part of the internal control, risk management and business ethics system. The Company adheres to zero tolerance for anti-competitive practices, including price fixing, abuse of dominant position and other forms of restriction of competition.
The Company has implemented antitrust management within the framework of the risk management and compliance control system in accordance with the Code of Conduct of the Company, the Compliance Risk Management Policy of "Samruk-Energy" JSC and the Risk Management Policy of the Company.
Key areas of management include
Regulatory and legal risk management
Cross-functional risk of non-compliance (48-P-SE) covers
- Integration of antitrust requirements into internal regulations and operational processes
- Mandatory legal and compliance due diligence of transactions, investment projects and initiatives for compliance with competition requirements
- Regular monitoring of changes in legislation and law enforcement practice
- Systematic interaction with authorised state bodies.
The Company takes into account compliance risks (33-P-SE)
As one of the tools aimed at preventing violations of the requirements of the legislation of the Republic of Kazakhstan, internal regulatory documents and business ethics, as well as minimizing the likelihood of litigation and sanctions. Key factors include interaction with unscrupulous or sanctioned counterparties, the risks of involvement by third parties in illegal practices, the use of sanctions and other regulatory restrictions, unscrupulous actions of employees, insufficient maturity of the compliance culture, violations of anti-corruption requirements, untimely consideration of appeals, insufficient control procedures and due diligence of counterparties.
Procurement Risk Management (28-O-SE)
Procurement procedures implement mechanisms aimed at ensuring transparency and competitiveness, including
- standardised procedures for selecting suppliers in accordance with the approved rules
- control over the prevention of restrictions on competition and conflicts of interest
- assessment of the potential impact of procurement solutions on the competitive environment.
Tariff Risk Management for Natural Monopolies (24/1-FSE)
With respect to subsidiaries operating under a natural monopoly, the Company provides
- Monitoring compliance with the requirements of regulatory authorities in the formation of tariffs
- Monitoring the validity of the tariff policy
- Compliance with the principles of non-discriminatory access to infrastructure and services.
Reputational Risk Management (1-C-SE)
The Company takes into account the potential impact of antitrust violations on the business reputation and trust of stakeholders, ensuring
- Functioning of internal control and violation detection mechanisms
- Consideration of appeals and signals through feedback channels
- Prompt response to potential incidents.
Particular attention is paid to activities in regulated electricity markets, where the Company ensures a balance between the fulfillment of social obligations and compliance with the principles of market competition.
In order to prevent antitrust risks, the Company has
- Code of Conduct, which establishes the principles of ethical behaviour, including the inadmissibility of anticompetitive agreements and other violations of the legislation of the Republic of Kazakhstan
- Internal control mechanisms that ensure the identification, prevention and response to violations of the legislation of the Republic of Kazakhstan, internal regulatory documents and business ethics standards
- Procedures for the approval of transactions and partnerships, including a legal assessment of the potential impact on the competitive environment
- Regulated procurement procedures of the Samruk-Kazyna group aimed at ensuring transparency, competitiveness and equal access of suppliers.
In 2025, there were 2 casesA of related to antitrust behaviour, in which group companies were recognised as participants.
In 2025-2026, “AlES” JSC challenged in court the order and order of the Department of the Agency for the Protection and Development of Competition of the Republic of Kazakhstan in Almaty, related to the qualification of the actions of “AlES” JSC as a violation of antimonopoly legislation, expressed in the imposition on the counterparty of the purchase of electricity in a certain proportion from various stations, which, in the opinion of the Department of the Agency for the Protection and Development of Competition of the Republic of Kazakhstan, led to economically unjustified costs. The courts of the first and appellate instances dismissed the claims of "AlES" JSC.
In addition, in 2025, the Department of the Agency for the Protection and Development of Competition of the Republic of Kazakhstan in the Pavlodar region recognised the price of Bogatyr Komir LLP as monopolistically high. Bogatyr Komir LLP appealed to the judicial authorities with an appeal against the order of the state body, by the decision of the Pavlodar Regional Court dated 31.03.2026, the claims of Bogatyr Komir LLP were satisfied.
Based on the results of consideration of these cases, the Company intends to implement systemic measures aimed at preventing similar situations in the future, including updating internal procedures and strengthening internal control over compliance with the requirements of the legislation of the Republic of Kazakhstan and business ethics standards.
Ombudsman and protection of workers' rights
GRI 2-26
In order to protect the rights of employees, the Company has the position of the Ombudsman, designed to assist in the prevention/settlement of corporate conflicts, conflicts of interest and reports of illegal actions, as well as to promote the establishment and development of corporate values and culture, high standards of professional conduct and business ethics in the Company. The Ombudsman is an independent high-level manager who reports only to the Board of Directors.
By the decision of the Board of Directors, from 1 April 2021, Nariman Akylov was appointed as the Ombudsman of "Samruk-Energy" JSC, as well as nine Subsidiary Dependent Organisations.
Main tasks of the Ombudsman
- Resolution of labour disputes and social issues of employees
- Compliance with business ethics
- Assistance in improving the Company's image
- Conflict prevention and resolution
- Ensuring an open dialogue between management and employees
- Making suggestions for improving corporate policies and procedures
- Informing the Board of Directors about systemic problems and proposals for their solution.
Appeals to the Ombudsperson and response measures
GRI 2-26, 406-1, GRI 12: Coal Sector: 12.19.8
The Ombudsman is obliged to guarantee the anonymity of employees and officials who reported violations of the Code of Business Ethics, the legislation of the Republic of Kazakhstan and internal documents of the Company.
You can report violations on the part of officials and employees by calling the helplines
- +7 (7172) 55-30-15
- +7 (7017) 88-84-16 (WhatsApp)
- akylov@samruk-energy.kz, ombudsman@samruk-energy.kz
In 2025, the Ombudsman received 27 official appeals through various communication channels (group electronic document management, Nysana hotline, e-otynish, cell phone, WhatsApp messenger, e-mail, written and oral appeals).
Main topics of appeals
- labour law issues,
- complaints about illegal actions of management,
- conflicts in the team,
- illegal dismissal,
- unfair punishment and deprivation of bonuses,
- dissatisfaction with wages and bonuses.
In addition, more than 120 people sought advice by phone.
The Ombudsman reviewed all appeals, provided advice and recommendations, and ensured confidentiality and anonymity. He provided moral and psychological support, acting as a psychologist, and in some cases as a motivator and mentor. In a number of cases, personal meetings were held with employees and recommendations were given to managers.
There are no confirmed cases of discrimination on the basis of nationality, sex, race or religion. All the rights of employees are respected, excluding the possibility of a hostile or humiliating atmosphere. Work of the Ombudsman in subsidiaries and affiliates
Work of the Ombudsman in subsidiaries and affiliates
In 2025, the Ombudsman visited all subsidiaries and affiliates of the Company. During the visit:
- The "Ombudsperson's Report on the Work Done for 2024" was presented;
- The most frequent appeals and ways of their pre-trial settlement are considered;
- Information and advisory sessions were held on the topics "Harassment at work, how to avoid it", as well as "Conflict prevention".
In order to prevent and prevent potential conflicts and resolve problematic issues, an information and explanatory conversation was held with employees of subsidiaries and affiliates aimed at a common understanding and resolution of social and labour disputes, problems and conflicts, and direct work was carried out to explain the Company's internal regulatory documents and procedures. The Ombudsman held a personal reception (including confidential) with those who wished. Clarifications and recommendations were given to all questions to the applicants.
In direct communication with the management of subsidiaries and affiliates of the top and middle levels, the principle of "Hearing Middle Management" is constantly communicated - systematic interaction with the team, fixation and solution of problems. Thanks to this principle, many social, social, sanitary and hygienic and seasonal issues have been resolved.
Anonymous employee survey
The Ombudsman regularly conducts surveys of employees of CCs and subsidiaries and affiliates to identify systemic problems and assess the atmosphere in the team. Main topics of the survey:
- Psychological climate in the unit;
- Ability to make decisions independently and use an innovative approach;
- Relationships in the team;
- Trust in the Company's management and strategic development;
- Satisfaction with wages, bonuses and social packages;
- Awareness of the mechanisms for filing complaints and appeals.
All proposals received and identified problems are under consideration by the Ombudsman and, if necessary, are submitted for discussion with the management of subsidiaries and affiliates and the Management Board of "Samruk-Energy" JSC.
Advanced training
In 2025, the Ombudsman of "Samruk-Energy" JSC was trained in key areas in the field of human rights, ethics and modern competencies. During the year, the UN programme on international competencies in the field of human rights was completed with the receipt of an international certificate. The programme covered bullying, the role of the corporate ombudsman in the face of social tension, the basics of artificial intelligence, as well as mediation and negotiations for corporate ombudsmen.
Interaction and communication
The Ombudsman of "Samruk-Energy" JSC actively participates in the work of the Council of Ombudsmen of portfolio companies of "Samruk-Kazyna" JSC, ensuring the exchange of experience and the development of solutions on topical social and labour issues. In 2025, meetings of the Council were held in Astana, Almaty and Almaty region with visits to the enterprises of "Samruk-Kazyna" JSC", KEGOC JSC, NAC KazAtomProm JSC and Kazakhstan Temir Zholy JSC. In April 2025, the Council was held at the sites of Samruk-Energy JSC and KEGOC JSC with a visit to the facilities of Alatau Zharyk Company JSC and Moynak HPP JSC.
During the year, the Ombudsman carried out systematic interaction with trade unions and public organisations, including working meetings with employers and trade unions, discussion of collective agreements, measures to prevent labour conflicts and minimise the risks of strikes, as well as participation in a dialogue on legislative initiatives in the energy sector.
In addition, interaction was carried out with local executive bodies in the regions where the Company operates, aimed at developing social, welfare, sports and cultural infrastructure and increasing the involvement of employees in the development of the regions.
Recommendations and proposals of the Ombudsman based on the results of 2025
As part of the tour of subsidiaries and affiliates, employees very often turn to the Ombudsman with a request to increase wages, referring to the constant increase in prices for food products, rent, medical services and services for children's education. According to the official data of the Bureau of National Statistics of the Agency for Strategic Planning and Reforms of the Republic of Kazakhstan, at the end of 20 December 25, inflation in the country was 12.6%.
Prices rose according to the following schedule by 8.9% in January to 12.6% in December.
As a result, food products by 13.5%, non-food products by 11%, paid services by 12.9%, rent increased by 13.5%, education by 18%, medical and dental services from 13.4% to 19%.
Recommendations of the Ombudsman
On social support and motivation of personnel
- Consider raising wages in line with inflation and rising costs of living
- Consider the possibility of paying bonuses for all national and corporate holidays
- Develop a programme of financial assistance to employees who find themselves in a difficult life situation (treatment, loss of breadwinner and/or property, etc.)
To reduce the risks of labour conflicts and develop human resources
- Regularly train Managers in the basics of mediation and conflict prevention.
- Adhere to the Company's Talent Pool and Young Talent Pool lists.
Corporate Culture and Communications
- Strengthen internal communications - hold regular meetings of the Management with labour collectives and trade unions
- Encourage employees for special merits (remuneration, certificates, letters of gratitude, vouchers to a sanatorium, etc.)
Development priorities and vectors for improving the Compliance system
In 2026, the activities of the Compliance Service will be aimed at
- Development of a compliance risk management system
- Improvement of the Company's internal regulatory documents
- Expansion of employee training programmes
- Development of mechanisms for detecting violations.