Code of Conduct

The KPO Compliance Framework regulates and provides guidance on all aspects of сompliance throughout the Company. The fundamental document within the Compliance Framework is the Code of Conduct, which establishes the core ethical principles, values and behaviours in the process of working inside and outside of the Company and when contracting with vendors, suppliers or other counterparties. The Code of Conduct can be viewed here.

KPO FUNDAMENTAL VALUES

Behaviour

We act with integrity and have consistently high ethical standards.

We conduct our business in compliance with legal, regulatory and license requirements applicable to KPO and its Parent Companies.

Our relationships are based on fairness, cooperation, loyalty and mutual respect.

People

We treat each other with fairness, respect and decency.

We trust, respect and support each other and the different cultures of our colleagues.

HSE

We are concerned for the health and safety of one another and will ensure that we work in a healthy, safe and secure environment.

We will act to minimize any adverse effects our actions may have on the environment.

Partnership

We are focused on maintaining productive, collaborative and trusting relationships with the Republic of Kazakhstan, our Parent Companies, and the local communities where we work.

We work with and seek to provide benefits to the local communities.

KPO has a Compliance Committee, which is chaired by the Legal Director and attended by the General Director and other members of the KPO senior management. The Committee meets quarterly and oversees all matters relating to Legal Compliance in KPO.

Code of conduct and anti-corruption awareness training

KPO insists on creating a fair and equitable business environment where the ethical business principles in the KPO Code of Conduct are the foundation for all its relationships.

All new starters in KPO receive an introductory training course on the Code of Conduct. Each KPO employee is required, on an annual basis, to make a Compliance Declaration acknowledging their familiarisation with their personal compliance obligations.  The Code of Conduct and other ethical compliance policies and practical tests are available on the KPO intranet for each employee.  By the end of December 2018, 95% of KPO employees had completed their Compliance Declaration.

As part of raising awareness on ethical compliance and engagement amongst the contractor companies, KPO held its annual Contractor Ethical Compliance Workshop in October 2018.  The workshop was attended by 34 delegates from 29 contractor organisations, together with Operator representatives from Shell and Eni.