Compliance Control Activities

The Compliance Control function is focused on preventing business risks, resolving critical issues, and ensuring adherence to legal and ethical standards. Globally, the presence of a robust compliance system is regarded as an indicator of a company’s responsible and transparent business conduct.

In the reporting year, the Compliance Control Service carried out the following activities:

• 60 compliance reviews of single-source procurement contracts to assess the reliability of counterparties. No compliance risks were identified.
• 17 compliance reviews of special-procedure procurements. No compliance risks were identified.
• 15 compliance checks of potential partners for Mobile Financial Services (MFS) product/service launches. No compliance risks were identified.
• 19 background checks of candidates for vacant positions at the CEO-1 and CEO-2 levels to assess affiliation risks and potential conflicts of interest.
• Monthly screening and monitoring of counterparties from the Russian Federation against international sanctions lists – 61 counterparties were reviewed.
• Expert opinions were provided on materials submitted for review, including those presented to the Management Board and the Board of Directors.
• As part of the 2024 Compliance Work Plan, a company-wide anonymous employee survey was conducted via Forms.Office on compliance-related topics, including anti-corruption, conflict of interest prevention, ethics, and integrity standards.

Kcell JSC’s ultimate controlling shareholder, Samruk-Kazyna JSC, operates a dedicated whistleblowing hotline through which any individual may report violations of law within Samruk-Kazyna or its subsidiaries. The hotline ensures confidentiality and anonymity (at the request of the reporting party) and guarantees that all reports are recorded, reviewed, and forwarded to the appropriate personnel for further action. Contact information for the Samruk-Kazyna hotline and Kcell’s Compliance Service is published on both the internal and corporate websites. Individuals can use these channels to report suspected labour violations, corruption, or other misconduct.

The process for receiving and handling reports of unethical or unlawful behaviour is governed by Kcell JSC’s Internal Misconduct Reporting Procedure. Under this policy, the Company guarantees full confidentiality to employees, business partners, and other stakeholders who raise serious concerns. The policy also ensures protection from retaliation or discrimination for whistleblowers.

In 2024, 15 reports were submitted through the hotline, of which 6 were confirmed.

The main issues raised included:

• Violations of procurement procedures;
• Breaches of corporate ethics;
• Abuse of official authority;
• Infringement of employee labour rights.

Each report received by the Compliance Service is documented in a quarterly report submitted to the Board of Directors. No critical issues were identified in 2024.