KZT billion
total amount of dividends paid in 2025
4.4. Sustainability Report: G Aspect
293.4
Key indicators for 2025
99.7%
share of procurement from local suppliers in 2025
~9
thousand DDoS attacks repelled
75%
of employees
completed anti-corruption training
>7
million fraudulent calls
blocked
0
incidents
in the area of information security
Key events of 2025
The first inspection audit for compliance with the requirements of the national standard ST RK ISO 37001 was conducted.
4.4.1. Anti-corruption
According to the results of the materiality analysis disclosed in section “Materiality analysis”, anti-corruption is regarded as part of a single material topic “Corporate ethics and anti-corruption”. Upon the determination of materiality, the Company took into account the results of interaction with stakeholders, questioning, internal expertise, and also the potential impact of the topic on the sustainability of business, corporate governance and long-term value creation.
For Kazakhtelecom JSC, anti-corruption is of material significance with account for the scale of activities, the significant volume of procurement and contractual relations, interaction with state bodies, suppliers, contractors, clients, shareholders and partners. Insufficient control of corruption risks may affect the trust of stakeholders, the transparency of procurement, the Company’s reputation, legal sustainability and the effectiveness of implementation of strategic projects. Therefore, the Company regards the anti-corruption system as one of the key elements of reliable corporate governance and the protection of long-term value.
The Company follows the principles of integrity, transparency and responsibility. Kazakhtelecom JSC and Subsidiaries, as well as all their employees are obliged to comply with the requirements of anti-corruption legislation of the Republic of Kazakhstan and the principles of ethical conduct of business.
4.4.1.1. Management approach
GRI 3-3
At the Company, the Compliance Service continues to function effectively. The main task of the compliance subdivision is the prevention and identification of violations of anti-corruption legislation and internal documents of Kazakhtelecom JSC.
The Compliance Service pays particular attention to issues of ethics, corporate behaviour and the prevention of cases of humiliation or discrimination of employees by managers both at the Company itself and at its subsidiary organizations. Upon the identification of such violations, the Compliance Service takes necessary measures to bring unfair managers to responsibility. In this work, the compliance subdivision interacts with the Board of Directors, the Chairman of the Management Board of the Company and the senior management of subsidiary organizations.
GRI 2-23
At the Company, the following internal documents regulating anti-corruption compliance procedures have been introduced:
- Anti-corruption Policy (updated in December 2024).
- Policy of notification of alleged unethical/unlawful actions.
- Policy on the settlement of conflicts of interest.
- Code of Business Ethics.
- Corporate Governance Code.
The documents can be reviewed on the Company’s website telecom.kz in the “Compliance” section.
GRI 205-1, 205-2
Anti-corruption at the Company is based on the following main principles:
- legality of the Company’s activities;
- publicity and openness of the Company’s activities;
- cooperation in the area of anti-corruption activity with state bodies, as well as partners and clients of the Company;
- protection and encouragement of persons providing assistance in anti-corruption;
- adherence of Officials and Managers to the principles of anti-corruption envisaged by this Policy, and the establishment of the “tone from the top”;
- inevitability of punishment for the commission of corruption offences.
4.4.1.2. Anti-corruption activities in 2025
The main directions of compliance work in the sphere of anti-corruption in 2025 were:
- conducting the first inspection audit at Kazakhtelecom JSC on compliance with the standard ST RK ISO 37001 “Anti-bribery management system. Requirements and guidance for use”;
- conducting an internal audit of the anti-bribery management system (ABMS);
- internal analysis of corruption risks;
- training of employees;
- feedback channels;
- interaction with Subsidiaries.
In October 2025, at Kazakhtelecom JSC, the first inspection audit on the compliance of the ABMS with the requirements of the national standard ST RK ISO 37001 “Anti-bribery management system. Requirements and guidance for use” was conducted, based on the results of which Kazakhtelecom JSC confirmed compliance with the indicated standard.
The current “Anti-corruption Policy” at Kazakhtelecom JSC establishes and includes:
- goals and objectives of the Company in the area of anti-corruption;
- main principles of anti-corruption by the Company;
- requirements of the Legislation and obligations on its fulfilment by the Company;
- context of the Company;
- complex of measures on the prevention and counteraction of corruption at the Company;
- responsibility of officials and employees of the Company for violation of the provisions of this Policy;
- obligation of the Company on the constant improvement of the anti-corruption management system.
Also in 2025, at the Company, the lists of positions with a high risk of commission of corruption offences were determined and approved by Orders (CO and branches), with the establishment of special, enhanced requirements for hiring/appointing to these positions, including with the acceptance of consent to anti-corruption restrictions.
In 2025, an internal analysis of corruption risks at Kazakhtelecom JSC was conducted for the period of 2024 and the first half of 2025.
The internal analysis of corruption risks was conducted in the directions:
- procurement activities;
- personnel management;
- business processes at the Company.
The Compliance Service, in interaction with relevant subdivisions, conducted an internal audit of the anti-bribery management system (ABMS) at Kazakhtelecom JSC.
The aim of the audit was the confirmation of compliance of the introduced anti-bribery management system with ST RK ISO 37001, the identification of areas for improvement, the confirmation of the functioning of policies, procedures and processes in the area of anti-corruption. Within the framework of the audit, activities of 14 subdivisions of the Company were conducted.
Based on the results of the internal audit, the Report and Plan of corrective actions (order No. 156 of 09.10.2025) on the elimination of identified findings with the indication of recommendations and deadlines for the execution of measures by responsible subdivisions of the Company were prepared and approved. The implementation of the indicated measures will make it possible to enhance the level of maturity of the anti-corruption system and to ensure further compliance with international standards and best practices of corporate governance.
Table 66. Indicators of effectiveness of the anti-corruption system in 2025
| Indicator | Description | 2025 |
|---|---|---|
| Assessment of corruption risks | Number of structural divisions covered by risk assessment | 8 |
| Verification of business partners (Due Diligence) | Number of counterparties that have passed compliance verification | 736 |
| Compliance training | Share of employees who have completed anti-corruption training | 75% |
| Appeals through reporting channels | Number of appeals received | 81 |
| Confirmed violations | Number of confirmed cases | 35 |
| Internal investigations | Number of checks conducted | 15 |
| Response measures | Number of disciplinary measures applied | 23 |
| Compliance monitoring | Number of monitoring measures conducted | 14 |
GRI 302-3
Table 67. Subdivisions and business processes in respect of which the assessment of risks related to corruption was conducted A
| Name | 2023 | 2024 | 2025 |
|---|---|---|---|
| Total number of structural divisions in respect of which corruption-related risk assessment was conducted, units | 7 | 9 | 9 А |
| Share of structural divisions in respect of which corruption-related risk assessment was conducted, % | 58 | 75 | 100% А |
GRI 205-2
Table 68. Informing about anti-corruption policies and methods, 2023–2025
| Employee category | 2023 | 2024 | 2025 | |||
|---|---|---|---|---|---|---|
| persons | % | persons | % | persons | % | |
| Total number of informed members of key corporate governance bodies (General Meeting of Shareholders, Board of Directors, Management Board) | 12 | 100 | 14 | 100 | 4 А | 100 |
| Total number of informed employees | 18,662 | 93.4 | 12,651 | 69 | 13,623 А | 75 |
| Total number of informed business partners | 0 | 0 | 2 022 | 100 | 5,730 | 100 |
GRI 3-3, GRI 205-3
Based on the results of the reporting period, confirmed cases of corruption and bribery at Kazakhtelecom JSC and Subsidiaries have not been registered.
Table 69. Cases of corruption and bribery А
| Indicator | 2025 |
|---|---|
| Total number and nature of confirmed cases of corruption | 0 |
| Total number of confirmed cases resulting in employees being dismissed or subjected to disciplinary measures for corruption | 0 |
| Total number of confirmed cases when contracts with business partners were terminated or not renewed due to corruption-related violations | 0 |
| Total number of public legal cases related to corruption brought against the organization or its employees in the reporting period | 0 |
4.4.1.3. Training on issues of anti-corruption
The Company regularly conducts anti-corruption trainings for employees. All new employees undergo an obligatory introductory online course on the main principles of the “Code of Business Ethics” and “Anti-corruption Policy”.
In 2025, training of 23 employees from among the Company’s management (including 4 members of the Management Board) was organized on the topic “The future of corporate governance, compliance and AI technologies for the quasi-state sector of Kazakhstan”.
Also, 4 training sessions with managers and employees of the Company on issues of compliance and anti-corruption were conducted:
>75%
coverage13,630
employees
In Q1 — ”Anti-Corruption Policy”
12,212
employees
In Q2 — ”Conflict of Interest Policy”
13,194
employees
In Q3 — ”Whistleblowing Policy on Alleged Unethical/Wrongful Actions”
11,191
employees
In Q4 — ”Code of Business Ethics”
GRI 205-2
Table 70. Number of employees by categories who underwent training on issues of anti-corruption in 2025 A
| Employee category | Persons | Share, % |
|---|---|---|
| Total number of members of key corporate governance bodies (Board of Directors, Management Board) who completed training | 4 | 57 |
| Total number of employees who completed training (by category): | 13,627 | 75 |
| - In managerial positions | 1,002 | 7.4 |
| - Specialists | 6,054 | 44.4 |
| - Workers | 6,567 | 48.2 |
4.4.1.4. Feedback channels
GRI 2-16, 2-25, 2-27, GRI 205-3
The mechanisms of reporting facts of unethical or unlawful behaviour at the Company are regulated by the “Policy of notification of alleged unethical/unlawful actions”.
At the Company, a hotline is operating — an independent, confidential and anonymous channel of communication, designed for reporting in connection with actual or potential cases of violations of legislation, including in the case of fraud, corruption, discrimination, unethical behaviour and other violations. The hotline functions through the parent company Sovereign Wealth Fund Samruk-Kazyna JSC and is serviced by an independent operator (KPMG company).
81
requests
were received through the hotline in 2025
The hotline guarantees confidentiality and anonymity (at the wish of the person making the request), as well as registration and processing of 100% of requests with the subsequent provision of reports to responsible persons.
In accordance with the “Policy of notification of alleged unethical/unlawful actions”, the Company guarantees the observance of confidentiality in respect of employees, business partners and other stakeholders who reported violations at the Company, as well as the absence of prosecution and/or discrimination.
In 2025, the hotline received 81 requests (34 were confirmed).
Main topics of requests:
- violations of established procedures and legislation;
- abuse;
- labour conflicts.
GRI 302-3
Table 71. Total number and amount of fines for cases of non-compliance with legislation and regulatory requirements, KZT million
| Indicator | 2023 | 2024 | 2025 |
|---|---|---|---|
| Total number of cases of non-compliance with legislation and regulatory requirements, including: | - | - | - |
| Cases in which fines were imposed | - | - | - |
| Cases in which non-monetary sanctions were applied | - | - | - |
| Total number of fines for non-compliance with legislation and regulatory requirements paid in the reporting period, broken down: | 17 | 22 | 23 А |
| Fines for cases of non-compliance that occurred in the current reporting period | - | - | - |
| Fines for cases of non-compliance that occurred in previous reporting periods | - | - | - |
| Total amount of fines for non-compliance with legislation and regulatory requirements paid in the reporting period, broken down: | 12.32 | 16.98 | 18.25 А |
| Fines for cases of non-compliance that occurred in the current reporting period | 12.32 | 16.98 | 18.25 А |
| Fines for cases of non-compliance that occurred in previous reporting periods | - | - | - |
GRI 3-3, 2-16
The Compliance Service studies the requests and materials received through the hotline. In the presence of signs of a criminal offence, the Compliance Service forwards them for consideration to the Steering Committee on financial and economic discipline of Kazakhtelecom JSC under the leadership of the Chairman of the Management Board. The members of the steering committee make a decision on the transfer of the materials to law enforcement bodies.
Each fact registered at the Compliance Service is reflected in a quarterly report for reporting to the Board of Directors. In 2025, no critical problems arose.
On the internal and corporate websites of the Company, the contacts of the hotline and the Compliance Service are placed, through which one can report any facts of labour, corruption and other types of offences.
Feedback channels for reporting violations of the Anti-corruption Policy:
-
Hotline of Samruk-Kazyna JSC
8 800 080 47 47 (Call within the RK is free of charge)
8 771 191 88 16 (WhatsApp) - Internet portal: www.sk-hotline.kz
- Email: mail@sk-hotline.kz
- Compliance Service: 8 701 941-1001
- E-mail: Isakov.T@telecom.kz
4.4.1.5. Indicators on the material topic
Table 72. Indicators on the material topic affecting the long-term value creation of the Company
Indicator
Target for 2025
Result 2025
Conducting an internal analysis of corruption risks in the area of procurement, hiring, assessment, promotion and dismissal of employees, and other business processes
Annually
100%
Verification of distributors and service providers
Annually
736
Conducting thematic training sessions for members of governing bodies and the executive body on compliance and anti-corruption matters (including with the involvement of an external training provider)
Annual conduct
Conducted in December 2025
Passing of certification under the ISO 37001 standard (Anti-Bribery Management System).
Conducted in 2025
Certification successfully passed
The above-indicated indicators on the topic “Corporate ethics and anti-corruption” are included in the KPIs of the Head of the Compliance Service. The fulfilment of KPIs is taken into account in the variable part of his remuneration in the order established by the internal documents of the Company.
Plans for 2026 and the medium term
- Organization and conducting of training events on issues in the area of compliance.
- Ensuring the timely identification and settlement of conflict of interest.
- Ensuring the consideration of 100% of requests transmitted through the line of confidential informing.
- Conducting the second inspection audit of the Company under the standard ST RK ISO 37001 “Anti-bribery management system. Requirements and guidance for use”.
- Conducting an internal audit of the anti-bribery management system (ABMS).
- Conducting an internal analysis of corruption risks.
