Business Ethics
Annual Declaration of Compliance 2025
IMBC has complied with its principal documents and compliance policies (Antitrust, Conflict of Interest, Anti-Bribery, Corruption, Anti-Money Laundering and other compliance related documents) in 2025.
No violations of compliance policies have been detected in 2025.
In 2025, the Ethics and Compliance Hotline did not receive any information regarding suspected compliance violations.
Internal policies prohibit certain activities that are considered illegal and unethical.
To increase compliance awareness among employees IMBC periodically conducts compliance training.
IMBC reminds its employees about early declaration of conflicts of interest.
Values, Ethics and Compliance
IMBC in its activities is guided by core ethical values – honesty, integrity and fairness.
By making commitment to these values and implementing them into practice, each employee of IMBC significantly contributes in protecting and enhancing IMBC reputation.
The activities and behavior of IMBC employees must always and under any circumstances comply with high international ethical standards since the perception of the ultimate result of IMBC activities has a certain dependence on ethical constituents.
In order to anchor the ethical norms of professional conduct, in line with international standards and aimed at the proper performance of functional duties, the Code of Conduct, the Anti-Bribery and Corruption and Anti-Money Laundering Manual, the Conflict of Interest Policy, and the Compliance Investigation Procedure have been approved.
Internal ethics and compliance requirements are not only the regulation of ethical standards of behavior in relationships both inside and outside of IMBC, but also demonstrate our social responsibility to society and the desire to strengthen the reputation of IMBC.
IMBC complies and requires to act strictly in accordance with the intentions and the explicit wording of approved policies and high ethical standards.
In addition, IMBC pays special attention to the fact that all who interacts with IMBC are called upon to be fully aware of the responsibility for maintaining a high level of international ethical standards and strive to exclude the possibility of violating them.
Before entering into a formal relationship with IMBC , each potential counterparty of IMBC must confirm familiarization with and agreement with the approved Code of Conduct (download) of IMBC, which provides the basic requirements for ethical behavior in the field of human rights, safety, anti- bribery and corruption, and anti-money laundering, gifts/hospitality, etc.
In order to coordinate at IMBC activities related to adherence to international ethical conduct, an Ethics and Compliance Officer has been appointed, and there is also an Ethics and Compliance Hotline.
Ethical Due Diligence
Ethical Due Diligence Procedure was approved to regulate the mechanism for conducting verification of potential suppliers of goods, works and services.
In addition, Ethical Due Diligence of Manufacturers Procedure has been adopted to collect, process and verify information on their ethical integrity.
The purposes of these Procedures are to reduce the risks of material and non-material damage to IMBC, to limit relationships with unreliable manufacturers, as well as to avoid financial, corruption, reputational and other risks for IMBC.
During conducting EDD, IMBC uses various tools, such as receiving a completed questionnaire and necessary documents from a potential counterparty, using information and reference systems, etc.
IMBC refrains from dealing with individuals who have not successfully passed ethical due diligence.
Hotline
Compliance investigation is the activity of collecting and verifying materials and information about an alleged violation in order to fully, comprehensively and objectively clarify the circumstances.
One of the tools for obtaining information/materials about possible violations in the field of ethics and compliance is the hotline.
Information will be considered by the Ethics and Compliance Officer in a confidential, impartial and timely manner.
You can share relevant information by e-mail hotline@imbc.kz or by phone +7 7172 39 99 66 (ext. 205).
If you have information about possible violations by the Ethics and Compliance Officer, you can contact by phone +7 7172 39 99 66 (ext. 200).
The information will be reviewed by the Ethics and Compliance Officer in a confidential, impartial and timely manner.
If there is information about possible violations by the Ethics and Compliance Officer:
