Anti-corruption action plan

Anti-corruption action plan in
JSC «Regional football club «Aktobe» for 2023.

No. i/oAction contentTerms of executionCompletion FormResponsible for the enforcement
1. Anti-corruption culture formation

Provision of information on prevention and counteracting of corruption for the staff of the Company on prevention and suppression of corruption (including public procurement, administrative offences, labour relations)QuarterlySeminar-meetingCompliance officer

Ensuring the functioning of the Company’s HelplineRegularlyHelplineCompliance officer

Ensuring transparency and openness of the Company’s Internet resource by timely posting information on its activitiesRegularlyPublicationsMedia officer  

Monitoring of compliance with the Company’s Code of Business EthicsAnnually till December 20Information for the Chairman of the BoardCorporate secretary
2. Measures to conduct anti-corruption monitoring

Monitoring of existing normative legal acts for corruption risksAnnuallyInformation for the Chairman of the BoardCompliance officer

Internal analysis of corruption risks
AnnuallyAnalytical review to the Chairman of the BoardCompliance officer
3. Measures to prevent conflict of interests
3.1Informing in written form the immediate supervisor or management of the Company about the conflict of interests or about the possibility of its occurrenceIf neededInformation for the immediate supervisor or the Chairman of the BoardCompany employees
3.2Acceptance of one of the following measures by the management of the Company on appeals or upon receipt of information from other sources on prevention and settlement of conflicts of interests: Suspension of persons from their duties and assignment of duties to another person in respect of a matter where a conflict of interest has arisen or may arise;.  Changes in job duties;. Take other measures to eliminate conflict of interestsIf neededAppropriate decisions acceptanceCorporate secretary, НR-manager
4. Measures for corruption offences
4.1Timely information of the Company’s management on the facts of corruption offencesIf corruption violations occurInformation for the Chairman of the BoardCompliance officer
4.2Analysis of corruption offences committed by employees of the CompanyOnce a year to December 15Information for the Chairman of the BoardCompliance officer
4.3Monitoring and control of terms of consideration of appeals submitted to the Company by individuals and legal entities in accordance with the Law of the Republic of Kazakhstan of January 12, 2007 «On procedure of consideration of appeals of individuals and legal entities»QuarterlyInformation for the Chairman of the BoardCompliance officer
4.4Analysis of incoming appeals for violations of ethics and anti-corruption legislation in order to develop recommendations to address the causes that create conditions for violations of ethics and corruption offencesHalf-yearlyInformation for the Chairman of the BoardCompliance officer 
5. Measures in financial and economic activities in the field of public procurement
5.1Timely action on violations of the legislation in the field of public procurement (in terms of unfair participants in public procurement)If neededLawsuitsFinancial department,  lawyer
5.2Monitoring and analysis of public procurementQuarterlyInformation for the Chairman of the BoardCompliance officer, Financial department