Anti-corruption action plan in
JSC «Regional football club «Aktobe» for 2023.
No. i/o | Action content | Terms of execution | Completion Form | Responsible for the enforcement |
1 | 2 | 3 | 4 | 5 |
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) | Quarterly | Seminar-meeting | Compliance officer | |
Ensuring the functioning of the Company’s Helpline | Regularly | Helpline | Compliance officer | |
Ensuring transparency and openness of the Company’s Internet resource by timely posting information on its activities | Regularly | Publications | Media officer | |
Monitoring of compliance with the Company’s Code of Business Ethics | Annually till December 20 | Information for the Chairman of the Board | Corporate secretary | |
2. Measures to conduct anti-corruption monitoring | ||||
Monitoring of existing normative legal acts for corruption risks | Annually | Information for the Chairman of the Board | Compliance officer | |
Internal analysis of corruption risks | Annually | Analytical review to the Chairman of the Board | Compliance officer | |
3. Measures to prevent conflict of interests | ||||
3.1 | Informing in written form the immediate supervisor or management of the Company about the conflict of interests or about the possibility of its occurrence | If needed | Information for the immediate supervisor or the Chairman of the Board | Company employees |
3.2 | Acceptance 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 interests | If needed | Appropriate decisions acceptance | Corporate secretary, НR-manager |
4. Measures for corruption offences | ||||
4.1 | Timely information of the Company’s management on the facts of corruption offences | If corruption violations occur | Information for the Chairman of the Board | Compliance officer |
4.2 | Analysis of corruption offences committed by employees of the Company | Once a year to December 15 | Information for the Chairman of the Board | Compliance officer |
4.3 | Monitoring 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» | Quarterly | Information for the Chairman of the Board | Compliance officer |
4.4 | Analysis 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 offences | Half-yearly | Information for the Chairman of the Board | Compliance officer |
5. Measures in financial and economic activities in the field of public procurement | ||||
5.1 | Timely action on violations of the legislation in the field of public procurement (in terms of unfair participants in public procurement) | If needed | Lawsuits | Financial department, lawyer |
5.2 | Monitoring and analysis of public procurement | Quarterly | Information for the Chairman of the Board | Compliance officer, Financial department |