Business conduct

KPO BUSINESS PRINCIPLES

KPO conducts its business based on KPO Business Principles introduced in 2019.

Our Business Principles govern how we conduct our business and set high standards of performance and ethical behaviour. We also expect all of our stakeholders, including contractors and suppliers, to respect and adhere to these Business Principles.

Fig. 7. KPO Business Principles cover seven categories:

The full text of the KPO Business Principles and a short video are available on our website in Business Ethics section.

HUMAN RIGHTS

We are committed to complying with applicable laws and regulations, including the United Nations Universal Declaration of Human Rights and the core conventions of the International Labor Organization.

The observance of human rights is a prerequisite of our 'license to operate'. Our activities are based on respect for human rights of our stakeholders starting from our employees, contractors, local communities and authorities.

For this reason, human rights requirements are embedded in the Code of Conduct and in KPO existing framework, manuals and policies. These include:

• Social performance – we have social performance plans and address the social impacts of our operations on local communities.
• Security – company-wide security requirements help keep staff, contractors and facilities safe in a way that respects human rights and the security of local communities.
• Human resources – our policies and standards help us establish fair labour practices and a positive work environment.
• Contracting and procurement – we seek to work with contractors and suppliers, who contribute to sustainable development and are economically, environmentally and socially responsible.

As part of the overall KPO Compliance Framework, KPO has adopted and successfully implemented the new Ethics and Compliance Training Programme which addresses major points of the principles and commitments listed above.

CODE OF CONDUCT

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

The copy of Code of Conduct is available on our website.

Our Code of Conduct is read in conjunction with our Business Principles and gives KPO staff more detailed guidance on how to apply Business Principles and the standards and behaviours required of our staff. It covers areas including international trade, health and safety, communications and gifts and hospitality.

2021 was a particularly challenging year for the Company and the consistent application of the Code of Conduct was of an immense importance in the middle of the COVID-19 pandemic. KPO Legal Compliance department helped the leadership in developing a view on the COVID-19 related matters to ensure our staff keep behaving ethically and making right choices when dealing with potential conflicts of interest and other breaches of business ethics in relation to sponsorship. KPO provided medical equipment, materials and medicines to the local hospitals in Aksai and Uralsk. This has enabled the local communities’ to alleviate the consequences of the pandemic.

These challenges have impacted KPO’s approach to working with suppliers and contractors amid the COVID-19 uncertainties. KPO Legal Compliance Department stepped up in providing ethical due diligence assessments to ensure our suppliers do not compromise ethical conduct of business.

Awareness trainings on Anti-Corruption

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

All KPO employees receive regular trainings on various compliance topics. In 2021, we introduced the annual anti-bribery and corruption prevention online training course which was completed by 98 % of the KPO staff, including secondees and agency staff. Besides, 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 ethics and compliance policies and procedures are available on the KPO intranet for each employee.

All KPO employees receive regular trainings on various compliance topics.

In 2021, despite the Covid-19 restrictions, the Legal Compliance Department continued conducting virtual trainings for staff at “higher risk” that are normally conducted in a regular classroom environment. In total, six sessions were organized.

Hotline and other compliance measures

To support the Company’s Ethics and Compliance Programme, KPO has a toll-free, anonymous and confidential Hotline in place since 2012

The Hotline provides an important tool for KPO’s employees, contractors and stakeholders to ensure a fair and safe working environment. The topics may include discrimination, sexual harassment, conflicts of interest, safety or environmental violations and/or improper financial practices or bribery. The caller can report on the alleged misconduct either by telephone or by completing an online report form. The report is then sent to the Legal Compliance Department for review and to determine the appropriate actions. KPO employees can also report concerns directly to the Legal Compliance Department, HR or their respective line managers.

In 2021, Legal Compliance Department received 169 new reports. All of the reports were duly considered and the appropriate actions taken. Most of the complaints were related to the workplace relationship matters, whereby 150 complaints were addressed and closed in accordance with the KPO’s Compliance Investigation Procedure and/or Discipline Handling Procedure, depending on the nature of report.

The compliance investigation team duly investigates the received reports and, in case the allegations are substantiated, consequence management actions are identified and carried out. In 2021, KPO adopted a new investigation procedure to enhance its internal investigation capability and consistent application of the consequence management actions throughout the organization.