Anti-corruption

The anti-corruption policy reflects the commitment of Subsidiary VTB Bank JSC (Kazakhstan), its employees and its Managers to high ethical standards of conducting open and honest business to improve corporate culture, follow best corporate governance practices and maintain the Bank's impeccable business reputation.

The main goals of counteracting corruption by Subsidiary VTB Bank JSC (Kazakhstan) are:

• minimizing the risk of involvement of the Bank and Bank employees in corruption activities;

• formation among shareholders, the investment community, counterparties, employees and other persons of a common understanding of the Bank’s policy on non-acceptance of corruption in all its forms and manifestations;

• establishing the obligations of Bank employees to know and comply with the principles and requirements of the Anti-Corruption Policy;

• identifying conditions and causes that contribute to the emergence of corruption risk, the commission of corruption offenses, and eliminating their consequences;

• strengthening interaction within the Bank in order to combat corruption.

Procedures to prevent corruption are carried out by Subsidiary VTB Bank JSC (Kazakhstan) in the following main areas:

1. Prevention of corruption

All employees of Subsidiary VTB Bank JSC (Kazakhstan) strictly adhere to the requirements of the Anti-Corruption Policy.

Subsidiary JSC VTB Bank (Kazakhstan), when carrying out its activities, takes measures to prevent corruption, including minimizing the causes and conditions conducive to the commission of corruption offenses, by: 

• establishing organizational and legal mechanisms that ensure accountability, control and transparency of decision-making procedures;

• compliance with the principles of fair competition;

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• taking measures to create an anti-corruption culture;

• interaction of anti-corruption entities, including with other bodies and organizations on issues of preventing corruption. 

2. Identification and assessment of risks of involvement in corruption activities

Subsidiary JSC VTB Bank (Kazakhstan) identifies and minimizes the risks of involvement in corruption activities by conducting an anti-corruption examination of developed internal administrative documents and when establishing internal business processes and procedures, while collecting information about risk events related to corruption offenses.

3. Verification of counterparties

Subsidiary JSC VTB Bank (Kazakhstan) does not attract or use counterparties or other persons to commit actions that contradict the principles and requirements of the Anti-Corruption Policy and the norms of the legislation of the Republic of Kazakhstan on anti-corruption.

4. Receiving and giving gifts

Gifts and entertainment expenses that Bank employees on behalf of the Bank may provide to other persons and organizations, or which employees, in connection with their official duties, may receive from other persons and organizations, must comply with existing business practices and the requirements of the legislation of the Republic of Kazakhstan.

Subsidiary JSC VTB Bank (Kazakhstan) refrains from paying any expenses for civil servants, government officials, persons holding responsible government positions, persons authorized to perform government functions, as well as persons equated to persons authorized to perform government functions, and their close relatives (or in their interests) who do not meet the criteria specified in the Anti-Corruption Policy and the legislation of the Republic of Kazakhstan.

5. Financial and technical control

Subsidiary JSC VTB Bank (Kazakhstan) regularly conducts internal and external audits of financial and economic activities, monitoring the completeness and correctness of data in accounting records and compliance with the requirements of the legislation of the Republic of Kazakhstan and internal documents of the Bank.

6. Interaction with employees

Bank employees are strictly prohibited, directly or indirectly, personally or through the mediation of third parties, close relatives, from participating in corrupt practices, offering, giving bribes, abusing authority, carrying out commercial bribery in order to simplify administrative and other formalities, or in order to obtain benefits in the form of money, valuables, other property or services/benefits of a property/non-property nature, other property rights for themselves and/or for close relatives, third parties.

The Bank requires its employees to comply with the Anti-Corruption Policy and the Code of Ethics.

If you become aware of facts of corruption offenses involving Bank employees, unlawful acts of Bank employees and third parties, or fraud, you can send a message to the Chief Compliance Controller. on the page of the Chief Compliance Controller.