Since anticorruption regulations in Kazakhstan are still under development and subject to regular amendments we highly recommend developing and implementing a reasonably detailed anticorruption corporate policy with the assistance of qualified legal practitioners acquainted with local practice or adjusting existing Compliance Policies concerning Kazakhstan in accordance with the above information.

• We recommend indicating in the section of the Compliance Policy concerning Kazakhstan that no gift can be given by employees to any representatives of the public sector until a practice is formed with regard to the conflict between the norm of the Civil Code (regarding gifts of limited value) and the norm of the Law on Combating Corruption prohibiting gifts altogether, or until this issue is resolved otherwise.
• Corporate anticorruption policy should specify that the company and its employees are not allowed to finance representatives of the public sector, grant them whatsoever material and/or intangible assistance, perform works free of charge, or render services free of charge.

It is highly recommended at all times to avoid creating the perception that the purpose of any amenity giving might be connected with exercise of an Official’s authority and/or duty for the benefit of the amenity-giver and/or of the company.