This chapter analyses Kazakhstan’s framework to ensure transparency and integrity in decision-making processes and assesses its resilience to the risks of capture of public policies and undue influence by special interest groups.
OECD Integrity Review of Kazakhstan
Advancing Integrity for Economic Development
Abstract
Public policies are the main ‘product’ people receive, observe, and evaluate from their governments. When designing and implementing these policies, governments need to acknowledge the existence of diverse interest groups and consider the costs and benefits for these groups. By sharing their expertise, legitimate needs and evidence about policy problems and how to address them, interest groups and their representatives can provide governments with valuable information on which to base their decisions. It is this variety of interests that allows policy makers to learn about options and trade-offs, better understand citizens and stakeholders’ evolving needs, and ultimately decide on the best course of action on any given policy issue (OECD, 2021[1]).
The consequences of this influence on the decision-making process, economy and society are widespread. While influence exerted by interest groups on public policies can bring about positive change, studies increasingly show that without the necessary guardrails, it can lead to the misallocation of public resources, reduced productivity, perpetuated social inequalities and sometimes led to deadly policy outcomes (OECD, 2017[2]). They may also negatively affect the appetite of (foreign) investors and lower a country's trustworthiness at the international level. Public policies that are misinformed and respond only to the needs of a specific interest group can also negatively affect trust to the government, possibly resulting in the dissatisfaction of the public towards public institutions and democratic processes.
This chapter looks at Kazakhstan’s existing framework to ensure transparency and integrity in decision-making processes and assesses its resilience to the risks of capture of public policies and undue influence by special interest groups. It identifies measures Kazakhstan could adopt to strengthen the legislative framework with respect to lobbying and political finance and identifies measures to raise awareness about integrity standards on lobbying for government officials and lobbyists more broadly. This chapter also explores how to strengthen access to information for all stakeholders, as well as promote stakeholder engagement in policymaking.
In recent years, the Government of Kazakhstan has taken important steps towards creating a space within which stakeholders can provide input into the policymaking process. In July 2019, the Government launched the National Council on Public Trust, with the aim of including civil society in policymaking processes. In August 2020, Kazakhstan released a new Civil Society Development Concept for 2020-2025 with the official aim to strengthen the partnership between the state, businesses and civil society. Participatory mechanisms have also been implemented, such as online consultations on draft laws, as well as Public Councils and Expert Councils (Chapter 4).
However, Kazakhstan faces significant challenges in this area. While there have been changes in policy, concerns remain on the impact of new participatory mechanisms and the degree of involvement of civil society in real decision-making (OECD, 2017[3]). Political reforms and policy co-ordination are generally top-down, initiated by the centre of government and translated into law by the Majilis, and representative bodies (maslikhats), which are dominated by the ruling party Amanat (formerly Nur Otan) (Bertelsmann Stiftung, 2022[4]; OECD, 2017[5]). Despite public commitment to reform, Kazakhstan’s elections are still not entirely open and free. Regular reports from the Office for Democratic Institutions and Human Rights (ODIHR) Election Observation Mission point to violations of fundamental freedoms as well as pressure on critical voices (Bertelsmann Stiftung, 2022[4]; OSCE, 2022[6]; GRECO, 2022[7]). According to the World Gallup Survey 2022, only 33 % of Kazakhstanis had confidence in the honesty of their elections in 2021 (Figure 6.1).
Some sources suggest that government responses to the protests of January 2022 have led to the re-emergence of negative trends affecting fundamental democratic rights, such as freedom of expression and assembly, despite the enactment of new legislation on peaceful assemblies (Freedom House, 2022[8]; Human Rights Watch, 2023[9]). Interest groups and political parties that are viewed as a threat have been traditionally excluded from key decision-making processes via administrative and judicial means, for example a registration denied to a political party, independent organisations being listed as extremist organisations, and harassment of activists by law enforcement (Bertelsmann Stiftung, 2022[4]). As such, the actions of most civil society organisations (CSOs) are usually limited to apolitical, social aid projects in areas where the government is not significantly involved (Bertelsmann Stiftung, 2022[4]).
Trust in the honesty of elections (2006-21), in per cent
Note: Respondents were asked the following question: “In this country, do you have confidence in the honesty of elections?”.
Source: Gallup (2022[10]), “Inside Kazakhstan: Record low confidence in government”, https://news.gallup.com/poll/388658/inside-kazakhstan-record-low-confidence-government.aspx.
Political corruption and nepotism continue to be major challenges, which undermine the country’s efforts to professionalise the public service and ensure resources are not wasted due to corruption, fraud, or misuse. Access to political leaders and to financial resources are skewed towards major actors of the quasi-public sector and various interest groups organised for and on behalf of Kazakh clans and oligarchs, who also exert considerable political influence, often at the expense of evidence-based policy-making, which limits economic competition and brings to the foreground additional lobbying and integrity concerns in Kazakhstan (Bertelsmann Stiftung, 2022[4]; GRECO, 2022[7]; IREX, 2022[11]; OECD, 2017[5]).
These governance concerns show that integrity, transparency, openness, and equity in public decision-making are necessary for both the creation of optimal policies, and for citizens’ trust in government. This has been recognised in the 2022- 2026 Anti-corruption Policy Concept, and its corresponding Action Plan. The Policy Concept highlights the need for additional mechanisms for the implementation of public control over government decision-making process, and policies that clarify the rules of interaction between the public and private sectors. Without ambitious reforms in these areas, overcoming the concentration of economic resources in the hands of the few will be difficult and the risk of policy capture in Kazakhstan will remain high. In the aftermath of the January 2022 protests and after his recent re-election, President Tokayev recognised in an opinion piece the “frustration among our people with the status quo and a sense that radical, lasting change had to be undertaken with urgency” and the need for major political reforms (Kassym-Jomart Tokayev, 2022[12]).
To advance the President’s objectives in this area, and in addition to strengthening public integrity as emphasised throughout the previous chapters, Kazakhstan could ensure transparent, objective, evidence informed decision-making independent of undue influence by reinforcing its policies in both the executive and legislative branches, along the following main priorities:
providing an adequate level of transparency on activities aimed at or capable of influencing government decision-making processes
establishing transparency and integrity frameworks for all persons and bodies providing advice to government
reinforcing competition, transparency and integrity in election processes
establishing a public integrity framework adapted to the risks of lobbying and influence activities for public officials
assisting businesses and CSOs in reinforcing their frameworks for transparency and integrity in policymaking.
These policies also need to be supported by awareness-raising and capacity-building efforts, as well as appropriate resources and enforcement capacities.
When undertaken transparently and in accordance with clear and objective rules, lobbying is a legitimate activity that enables public officials to better understand and respond to citizens and stakeholders’ evolving needs, to leverage knowledge and resources from beyond the public administration, develop innovative solutions to policy problems and their implementation, as well as achieve greater acceptance and better compliance with decisions reached (OECD, 2010[13]; 2021[1]).
Yet, lobbying remains unregulated in Kazakhstan. As such, there is currently no definition of “lobbying activities”, “lobbyist”, or “special interest groups”. Interviews conducted with various stakeholders for this review confirmed that the term “lobbying” is associated with opaque activities and corruption in Kazakhstan. The lobbying landscape is dominated by two powerful interest groups whose influence activities have a real impact on decision-making processes: the Kazenergy Association, representing large energy companies, and the Atakemen Business Chamber of Entrepreneurs (Bertelsmann Stiftung, 2022[4]).
To address lobbying-related risks, the Government of Kazakhstan could provide an adequate level of transparency on lobbying activities by: i) adopting a dedicated regulation that clarifies the terms “lobbying” and “lobbyist” and assigning the burden of disclosure of lobbying activities on certain on public officials; ii) assigning clear responsibilities for enforcing disclosure requirements; iii) disclosing the normative and legislative footprint; and iv) ensuring equitable access to decision-making processes and the protection of fundamental rights.
To provide transparency over lobbying activities taking place, Kazakhstan could establish open agenda initiatives for certain public officials with key decision-making capacities
A critical element for enhancing transparency in public decision-making is establishing mechanisms that allow public officials, businesses and society to access sufficient information on who has been involved and on what issues (OECD, 2010[13]). Such mechanisms should ensure that sufficient, pertinent information on critical aspects of lobbying activities is disclosed in a timely manner, with the ultimate aim of enabling public scrutiny (OECD, 2010[13]).
In recent years, there has been growing recognition of the importance of regulating lobbying through the development of national integrity frameworks. Seventeen OECD Members currently define lobbying in their regulatory framework, specifying which actors are considered as lobbyists. In these countries, the adoption of lobbying laws and regulations has helped legitimising lobbying activities and for increasing openness and transparency in public-private interaction (OECD, 2021[1]). In Kazakhstan, there is no specific framework that defines lobbying and lobbying activities that could provide for transparency in lobbying. However, several legislative sources do touch upon the principles of integrity and transparency in decision-making processes, including:
The Law on Combating Corruption (adopted in 2015, entered into force as of January 1, 2016) includes provisions on conflict-of-interest management (Article 15).
The Law on Civil Service (2016) covers a number of integrity elements, including asset declarations (Article 16), conflict of interest management (Article 51) and the expected anti-corruption behaviour of public officials (Article 52).
The Code of Ethics for Civil Servants (2015) defines the public service's values and expectations for ethical behaviour.
The Law "on Public Control", adopted in October 2023, aims to create legal conditions for strengthening public control over the activities of state bodies and quasi-public sector entities to increase their openness and efficiency and, thus, citizens' participation in the management of state affairs.
In 2009, the Ministry of Justice submitted a draft law on lobbying to Parliament. The draft law aimed to formalise the engagement of businesses with the government when promoting their interests. In 2012, the Ministry withdrew the draft law from Parliament. The draft law has been discussed in various public fora since then, but this has not brought any substantial results (Lexology, 2021[14]). The OECD Integrity Scan recommended establishing rules on the interaction between public and private and not-for-profit sectors through the Code of Conduct and Regulations of the Republic of Kazakhstan (OECD, 2017[15]).
To reduce the chilling effect on civil society, Kazakh authorities could pursue an “open agenda” policy in line with the criteria set out by the OECD Public Integrity Indicators (OECD, n.d.[16]). This means that Ministers’ agendas – among other selected public officials’ agendas with key decision-making powers, as suggested in the paragraph below – could be made publicly available online, specifying who was met by the minister, in which capacity and the topic that was discussed during the meeting, as is the case in OECD countries including Iceland, Korea, Latvia, Lithuania, Luxembourg, the Netherlands, Norway, Sweden, Spain and the United Kingdom (see examples from the UK and Spain in Box 6.1).
In Kazakhstan, the proposed policy could apply to elected officials, political appointees, and certain senior civil servants: members of the government, members of Cabinet, members of Parliament and their advisors, members of the Office of the Prosecutor General, members of the Constitutional Council, regional governments as well as senior leaders of quasi-public bodies. The information could be published on the Open Data Portal of Kazakhstan. The lobbying activities disclosed would be any meeting (whether in person, by phone, or online) with lobbyists, written communications from lobbyists in which they attempt to influence a decision, and specific inputs and documents received from lobbyists.
To facilitate disclosures and enhance transparency, the online portals where public officials would have to disclose their meetings could be directly connected to Kazakhstan's “Open LRA” platform, which contains information on draft laws and draft standards of public services and permits. When disclosing the type of decision that was the target of lobbying activities, public officials could choose from a drop-down menu the decisions currently being discussed in Parliament and on the Open LRA platform. In Quebec, for example, the Lobbying Register – Carrefour Lobby Quebec – is directly connected to the database of draft laws. As such, when disclosing information, lobbyists can easily select the decision they are influencing from a drop‑down menu, which limits the need to enter the information manually and ensures a decision-making footprint (OECD, 2022[17]).
Diaries available in the United Kingdom
In the UK, the Ministerial Code requires cabinet ministers to make their ministerial diaries available to the public. The relevant Department publishes them on a quarterly basis. The information details ministers’ external meetings and any meeting with newspaper and other media proprietors, editors and senior executives, regardless of the purpose of the meeting. The Code of Conduct for Special Advisors also requires special advisors to disclose meetings with newspaper and other media proprietors, editors and senior executives, on a quarterly basis.
Open agendas initiatives in Spain
In Spain, the agendas of elected members of the government have been published online since 2012, on the government website. The agenda lists daily the visits and meetings in which members of the government participate. Each item discloses at least:
the minister in charge, and other minister(s) assisting
the time of the meeting
the organisation met or visited.
In October 2020, the Boards of both Houses of the Spanish Parliament adopted a Code of Conduct for members of the Congress and the Senate, which requires the publication of the senators’ and deputies' agendas, including their meetings with lobbyists. An agenda section is available on the webpage dedicated to each deputy.
Source: OECD (2021[1]), Lobbying in the 21st Century: Transparency, Integrity and Access, https://doi.org/10.1787/c6d8eff8-en.
Civil servants in Kazakhstan could be covered by distinct disclosure requirements and specific regulations. In Latvia, for example, a Cabinet Regulation entitled “Values of the State Administration and Fundamental Principles of Ethics” (Chapter 3 on “Open Communication with Lobbyists”) provides that civil servants and employees of public administration bodies must disclose their meetings with lobbyists to their direct superior or the head of the institution (Government of Latvia, 2018[18]). This includes any anticipated meeting with lobbyists. They must disclose the information received from lobbyists, including what interests they represent, what proposals were expressed, and how they have been considered. In Lithuania, civil servants who participate in the preparation, consideration and adoption of draft legal acts must declare lobbying activities targeting them to their managers within seven days from the commencement of the activities for a specific draft legal act, in accordance with Law No. VIII-1749 on Lobbying Activities (Government of Lithuania, 2020[19]).
Rules for reporting by corporate or for-profit entities could complement this. This compromise would ensure the significant risks associated with the influence of powerful interest groups in Kazakhstan are still addressed and allow citizens to see who has access to decision-makers, as well as possibly the inequities in access between business interests and CSOs.
Kazakhstan could clarify institutional responsibilities for overseeing and enforcing any future lobbying and open agenda policies
While clear and enforceable rules and guidelines on transparency and integrity in lobbying are necessary, they are not sufficient to ensure effective regulation. Transparency requirements can only achieve their objective if the actors covered by the regulation comply with them and the supervisory bodies effectively enforce them. It is, therefore, crucial that any proposed law regulating lobbying first clarifies responsibilities for compliance and enforcement activities. It is also necessary to allocate appropriate resources to monitoring and control operations, for example, by designating an institution or a department responsible for enforcement and the implementation of possible sanctions.
As mentioned above, the information about the open agenda requirements in Kazakhstan could be made available on the existing online platform or website of each public organisation where a public official covered by the policy is employed. The website could also include a list of public officials who are bound by transparency requirements. The list could also serve as a resource for lobbyists, who would know which public officials they are meeting are bound by transparency requirements on lobbying activities. In Ireland, for example, each public body is required to publish and maintain a list of designated public officers under the Lobbying Act 2015; the Standards in Public Office Commission also publishes a list of public bodies with designated public officers on the lobbying website (Box 6.2).
In Ireland, Section 6(4) of the Lobbying Act 2015 requires each public body to publish a list showing the name, rank and brief details of the role and responsibilities of each 'designated public official' of the body. This list must be kept up to date. The purpose of the list is two-fold:
to enable members of the public to identify individuals who are designated public officials
to serve as a resource for lobbyists filing a return with the registry who may need to find contact information for a designated official.
The list of designated public officials should be prominently displayed and easily found on the home page of each organisation's website. This page should also contain a link to the lobbying register (www.lobbying.ie).
Source: Register of Lobbying (n.d.[20]), Requirements for Public Bodies, https://www.lobbying.ie/help-resources/information-for-public-bodies/requirements-for-public-bodies/.
The information from all the open agendas could then be compiled on the Open Data Portal of Kazakhstan. The enforcement of the regulation (and any future regulations on interactions between lobbyists and public officials), as well as investigations on potential breaches of transparency requirements, could be entrusted to an institution with the necessary powers to carry-out verifications and apply administrative sanctions as needed. If this role falls with the Anti-Corruption Service, it should be clear in consultation and outreach on the draft regulation that lobbying is not a criminal activity and does not equate to corruption but that these reforms are necessary to prevent potential corruption and are part of the preventative function of the Anti‑Corruption Service.
All OECD countries with a transparency register on lobbying activities have an institution or function responsible for monitoring compliance. Most of these bodies monitor compliance with disclosure obligations and whether the information submitted is accurate, presented in a timely fashion and complete. These functions are usually specified in the relevant lobbying law (Table 6.1).
The regulation should also clarify the types of verification activities conducted and the investigative powers entrusted to the responsible authority. Verification activities include, for example, verifying compliance with disclosure obligations (existence of disclosures, delays, unregistered meetings), as well as verifying the accuracy and completeness of the information declared. Investigative powers and tools include:
random review of disclosures or review of all disclosures
verification of public complaints and reports of misconduct
inspections (off-site and/or on-site controls)
inquiries (requests for further information)
hearings with other stakeholders.
Source: OECD (2021[1]), Lobbying in the 21st Century: Transparency, Integrity and Access, https://doi.org/10.1787/c6d8eff8-en.
Cross-checking available information also makes it possible to assess the consistency between data provided from various sources. For example, information within lobbying registries and open agendas can be cross-checked with political finance contributions. Several OECD countries have set up such mechanisms. In Slovenia, for example, public officials, civil servants and lobbyists are required to report each occurrence of lobbying, including gifts received or offered, to the Commission for the Prevention of Corruption. The Commission publishes the reports and gifts disclosure in the public sector transactions record, in an open online database named ERAR. This allows for the processing and cross-checking of available public financial data (OECD, 2021[1]).
In terms of sanctions, the practice has shown that a graduated system of administrative sanctions appears to be preferable, as countries that have established lobbying rules and guidelines provide for a range of graduated disciplinary or administrative sanctions (OECD, 2021[1]). For the responsible authority to carry out an oversight and enforcement role of the proposed lobbying regulation, it will require sufficient financial and human resources. Considering this, it is fundamental to ensure that the responsible authority will have the appropriate human and financial resources to carry out these functions effectively.
Governments across the OECD use advisory and expert groups to inform the design and implementation of public policy. An advisory or expert group refers to any committee, board, commission, council, conference, panel, task force or similar group, or any subcommittee or other subgroup thereof that provides advice, expertise, or recommendations to governments. Such groups are composed of public and private sector members and/or representatives from civil society and may be set up by the executive, legislative or judicial branches of government (OECD, 2010[13]). These groups can be permanent or set up on an ad hoc basis to respond to specific needs in a specific period. During the COVID-19 crisis, for example, many governments have established ad hoc institutional arrangements to provide scientific advice and technical expertise to guide their immediate responses and recovery plans.
Chairpersons and members of advisory or expert groups can help strengthen evidence-based decision-making. However, without sufficient transparency and safeguards against conflict of interest, they may risk undermining the legitimacy of their advice by allowing individual representatives participating in these groups to favour private interests, whether done unconsciously or not (e.g. by serving biased evidence to the decision makers on behalf of companies or industries or by allowing corporate executives or lobbyists advise governments as members of an advisory group).
In Kazakhstan, there are several types of advisory and expert groups (Table 6.2). However, there is no general rule on the establishment and functioning of government advisory and expert groups and committees, meaning that there is no general provision indicating their functioning and optimal composition despite various legal texts establishing these groups. Moreover, the composition of the Public Councils, as well as their ability to influence policies, remains unclear, and a risk of undue influence over the selection of CSOs arises, limiting the legitimacy of the role of civil society. To instil more transparency and integrity over the composition and functioning of advisory and expert groups, Kazakhstan could adopt the following measures: i) adopt rules and guidelines for the selection process of advisory and expert groups to mitigate conflict of interest and encourage inclusion; ii) strengthen transparency for government advisory or expert groups, including on what the outcomes are, how inputs have been dealt with and how they are incorporated in the resulting decision.
Kazakhstan could adopt clearer rules for the selection process of advisory and expert groups and extend transparency requirements
The Government of Kazakhstan relies on several advisory and expert groups to inform decision-making processes. The membership, objectives, and missions of key consultative and advisory groups is summarised in Table 6.2. The participation of civil society in these groups shows a willingness on the part of the government to open the door for stakeholder engagement in decision-making processes. For example, according to data provided by the Government of Kazakhstan, there are 260 Public Councils operating across the country as of September 2024, of which 36 at the national (“republican”) level and 224 at the local level. Civil society representatives currently make up 86 % of the total number of Public Councils, and 63 Public Councils are constituted of members of civil society only.
Source: Information provided by Kazakhstan in responses to the OECD questionnaire.
In addition to these main groups, other advisory and expert groups can be established under the Government Decree No. 247 dated 16 March 1999, “Instruction on the order of creation, activities and liquidation of advisory and consultative bodies under the Government of the Republic of Kazakhstan and working groups”. Task forces established under the “preparation of an advisory regulatory policy document” procedure can also be considered as advisory groups.
According to the Law on Public Councils, the composition of Public Councils is determined by “working groups on the formation of the Public Councils”, which are themselves formed from among representatives of state bodies, quasi-public sector entities and on a competitive basis from among representatives of non‑profit organisations and citizens. The procedure for selecting members of working groups and Public Councils is described in Box 6.3.
Members of working groups on the formation of the Public Councils
The procedure for selecting members of the working group from civil society, the timing of meetings, the list of documents, powers and other issues of the working group's activities shall be determined in the manner prescribed by the Model regulations on Public Councils, adopted in February 2021.
Within these working groups, representatives from states bodies must not exceed one third of the total number of members of the working group and are chosen by the head of the public body initiating the creation of the Public Council; representatives from civil society must make up at least two thirds of the total number of members of the working group. The public body initiating the creation of a Public Council must organise an online competitive process (with a duration of 10 working days) for the selection of civil society members of the working group. Members of the working group are then selected by a majority of votes of candidates for members of the working group from non-profit organisations and civil society (these candidates cannot vote for their own candidacy).
Decisions of working groups that oversee forming Public Councils are published online on the official website of the institution. Each group also adopts its own protocols. The working group determines the number of members of Public Councils. The working group conducts the procedure for electing members of Public Councils and develops draft regulations for Public Councils.
Members of Public Councils
Candidates for members of Public Councils are nominated by non-profit organisations, citizens, including through self-nomination. The term of office of the Public Council is three years. The working group oversees organising a competitive online process for the selection of candidates from civil society, who are then selected based on a vote among all candidates similar to that organised for working groups.
Candidates must provide information on their professional and/or public activities, a certificate of criminal convictions (or lack thereof), a certificate on the presence or absence of mental or behavioural disorders, including those related to the use of psychoactive substances. They must also consent to the collection, processing, distribution and publication of the information they provide.
The working group develops a draft regulation on the Public Council based on the Model regulations on the Public Councils.
Sources: Government of Kazakhstan (2015[21]), Law on Public Councils, https://adilet.zan.kz/rus/docs/Z1500000383; Government of Kazakhstan (2021[22]), On Approval of the Model Regulations on the Public Council, https://adilet.zan.kz/rus/docs/V2100022264.
While the Model regulations on Public Councils adopted in 2021 brought some level of clarity on the selection process, the criteria to guide the establishment of Public Councils and the selection of Public Council members could be improved and further clarified to ensure a balanced representation of interests in terms of private sector and civil society representatives (when relevant), as well as expertise from a variety of backgrounds. For Public Councils, the selection criteria to consider candidates could include, for example, candidate’s experience in a relevant field, and a clear connection to constituents in the community whose interests the candidate is representing (OECD, 2017[3]). Furthermore, the requirement to provide personal information such as the presence or absence of mental/behavioural disorders could also act as a disincentive to apply.
In addition, Public Councils are themselves allowed to establish permanent or temporary working bodies (committees, expert groups) within the Public Council – the composition of which is determined by the Public Council and may involve representatives from not-for-profit organisations, scientific organisations, trade unions, the media, and other experts. These expert groups can prepare expert opinions on which the decisions of the Public Council are made. However, there are no rules on the selection of these additional expert members, which increases the risks of policy capture, if some interests are not sufficiently represented, or risks of selecting members that are in favour of solutions or policies selected by the Government leading to just “rubber-stamping” government decisions (OECD, 2017[15]).
Moreover, considering that members of advisory groups come from different backgrounds and may have different interests, it is fundamental to provide a common framework that allows all members to carry out their duties in the general interest. It is therefore necessary to adopt specific rules of procedures for such groups that include procedures for preventing and managing conflict of interest that should be adhered to by all those participating in providing advice to government. Such measures would provide reasonable safeguards against special interest groups capturing or imparting biased advice to government.
For example, the Ministry of Local Government and Modernisation in Norway published guidelines on the use of independent advisory committees, which specify that the composition of such groups should reflect different interests, experiences, and perspective. While the guidelines are not legally binding, they provide an example for Kazakhstan on the selection process and managing conflict of interest within these groups (Box 6.4).
The Norwegian Ministry of Local Government and Modernisation has developed guidelines entitled “Committee Work in the State. A guide for leaders, members, and secretaries in government study committees”. Regarding the composition of these committees, the document specifies that there needs to be a balanced composition of interests:
“If the committee is to help clarify issues that are subject to academic disagreement, it is important that the composition is not skewed from an academic standpoint”.
“If the goal of the committee, in addition to acquiring knowledge, is to agree on common goals and values, it is important that the composition reflects different interests, experiences and standpoints”.
Regarding conflict of interest, the document warns that the work method and the effectiveness of the committee can be weakened by members who cannot comment on an independent basis and constantly need to clarify the assessments with the business or organisation to which they belong. As a result, the guidelines specifies that members should “explain any commitments that may involve conflicts of interests”.
Source: Norwegian Government (2024[23]), Committee Work in the State. A Guide for Leaders, Members and Secretaries in Government Study Committees, https://www.regjeringen.no/contentassets/793636d2e55a4236b82e632897f96d50/utvalgsarb.
Along with the composition of advisory or expert groups, a key challenge is ensuring a sufficient level of transparency on the functioning of these bodies. In Kazakhstan, Public Councils establish their own protocols and procedures and carry out their activities in accordance with an annual workplan. Article 14 of the Law on Public Councils specifies that Public Councils must make public the composition of the Public Council, the agenda of meetings and any decisions taken. In addition, and provided that confidential information is protected and without delaying the work of these groups, the minutes of meetings and evidence gathered could also be published to enhance transparency and encourage better public scrutiny. Lastly, these transparency requirements could be extended beyond Public Councils to all advisory and expert groups. The Transparency Code for working groups in Ireland may serve as an example for Kazakhstan (Box 6.5).
In Ireland, any working group set up by a minister or public service body that includes at least one designated public official and at least one person from outside the public service, and which reviews, assesses or analyses any issue of public policy with a view to reporting on it to the Minister of the Government or the public service body, must comply with a Transparency Code.
The following information must be published on the website of the public body on its establishment:
names of chairperson and members, with details of their employing organisation (if they are representing a group of stakeholders, this should be stated)
whether any members who are not public servants were formerly public officials
terms of reference of the group
expected timeframe for the group to conclude its work
reporting arrangements.
In addition, the agenda and minutes of each meeting must be published and updated at least every four months. The chairperson must include with the final or annual report of the group a statement confirming its compliance with the Transparency Code. If the requirements of the Code are not adhered to, interactions within the group are considered to be a lobbying activity under the Regulation of Lobbying Act 2015.
Source: Government of Ireland (2015[24]), Transparency Code prepared in accordance with Section 5 (7) of the Regulation of Lobbying Act 2015, https://www.lobbying.ie/media/5986/2015-08-06-transparency-code-eng.pdf.
In addition to increasing the transparency of the policy-making process, the strength and effectiveness of this process also depends on the integrity of both public officials and those who seek to influence them (OECD, 2021[1]). Public officials should conduct their communication with lobbyists in line with relevant rules, standards and guidelines in a way that bears the closest public scrutiny. In particular, they should cast no doubt on their impartiality to promote the public interest, share only authorised information and not misuse ‘confidential information’, disclose relevant private interests and avoid conflict of interest. Decision makers should also set an example by their personal conduct in their relationship with lobbyists (OECD, 2010[13]).
Lobbying and influence are typically an example where public officials may face ethical dilemmas in cases where there are no clear legal “right” or “wrong” answers, or where there may be conflicts between different values or principles. As such, lobbying-related ethical dilemmas are a key challenge for integrity policies. This is particularly true in an age of social media and information overload, where back and forth between the private and public sectors is commonplace, and where public officials are constantly exposed to public scrutiny and criticism, risking the collapse of their reputations every time an intervention is misperceived or misinterpreted.
Public officials therefore need an integrity framework adapted to the specific risks of lobbying and other influence practices, beyond rules on conflict –of interest, gifts, and benefits. In Kazakhstan, there are general standards as well as guidelines on public integrity for public officials (Chapter 2). This legal framework sets the general rules related to the expected standards of conduct in the public sector. However, Kazakhstan currently lacks specific standards and guidelines tailored to the specific risks of lobbying and influence practice. To foster a culture of integrity in decision making, Kazakhstan could provide standards to give public officials clear directions on how they are permitted to engage with lobbyists, including by: i) introducing lobbying-related integrity standards and guidelines for public officials; ii) designing and implementing legislation that adequately manages the revolving-door phenomenon; iii) providing tailored advice and councils to public officials on their interactions with lobbyists; iv) including lobbying-related risks in risk assessments.
Kazakhstan could introduce integrity standards for public officials that clarify their expected behaviour when dealing with lobbying
Kazakhstan could foster a culture of integrity in public organisations by developing specific principles, standards, and procedures for public officials to give them clear guidance on how they are expected to engage with lobbyists. Lobbying integrity standards may be included in a specific lobbying law, a lobbying code of conduct and guidelines specific to interactions with external parties, or general standards applicable to public officials, such as laws, codes of ethics or codes of conduct.
Depending on the type of document in which the standards are included, standards for public officials and their interactions with lobbyists may include, for example (OECD, 2021[1]):
the duty to treat lobbyists equally by granting them fair and equal access
the obligation to report violations of existing lobbying standards to the competent authorities
the duty to publish information on their meetings with lobbyists (through a lobbying registry or open agendas)
the obligation to refuse to accept gifts (in whole or beyond a certain value) from lobbyists, or to declare gifts and benefits received, among others.
Given the current absence of these standards in the public sector in Kazakhstan, the government could consider including standards and guidelines for public officials on their interactions with lobbyists and representatives of interest groups in the upcoming law on lobbying and/or in existing regulations, codes of ethics and manuals. The Integrity Scan of Kazakhstan recommended that government ministries adapt the revised Code of Ethics to fit the context of its specific work and adapt the Code to high-risk positions (OECD, 2017[15]). Any subsequent revision of the Code could therefore be used to introduce lobbying-related standards of behaviour.
In developing these provisions, Kazakhstan could consider drawing on some of the specific standards for public officials concerning their interactions with lobbyists, developed by other countries. At a minimum, the various codes of conduct applicable to public office holders could, for example, include guidelines and remind public officials of the need to be vigilant about influence communications. In the Netherlands, for example, the Code of Conduct on Integrity in Central Government reminds public officials of the need to consider the indirect ways in which they can be influenced by special interest groups, such as through research funding (Box 6.6).
In addition, these standards can be adapted to sectors or functions of the executive and legislative branches, as well as to higher and more politically exposed positions. For example, it may be necessary to set higher expectations for politically exposed positions (Members of parliament, Ministers and policy advisors) to effectively address the risks of lobbying and other influencing activities affecting them.
Latvia (Extract from the "Values and Ethical Principles of Administration" Regulation)
When communicating with lobbyists, public employees must respect the principles of openness, equality and integrity. They must ensure that all interested lobbyists have an equal opportunity to receive information and communicate with the public administration and its employees. Public officials must inform their direct supervisor or head of their institution of their meeting with lobbyists, and disclose information received from lobbyists.
Chile (Extract from the Law regulating Lobbying and the Representation of Private interests)
Public administrations are not obliged to respond positively to every request for a meeting or hearing; however, if they do so on a specific question, they must accept requests for a meeting or hearing from all those who so request on that question.
Netherlands (Extract from the Dutch Code of Conduct for Public Administration)
You may interact with lobbyists as part of your activities. They represent a cause and undertake to influence decision-making to their advantage. This is permissible. But are you still aware of it? How to approach this issue? Make sure you are able to perform your function transparently and independently. Be aware of the interests of lobbyists and the different possible influence approaches. These can be very direct (through a visit or an invitation, for example), but also more indirect (in particular through the co-financing of research influencing a political decision). Consult with colleagues and supervisors when you may encounter these situations in your business. It is sometimes in the public interest to avoid contact with lobbyists.
Australia (Lobbying Code of Conduct)
The Code prohibits Government representatives from being party to lobbying by a third-party lobbyist who is not registered on the publicly available Register of Lobbyists. It also requires Government representatives to report any breaches of the Code.
Source: OECD (2021[1]), Lobbying in the 21st Century: Transparency, Integrity and Access, https://doi.org/10.1787/c6d8eff8-en.
Kazakhstan could design and implement legislation that adequately manages post-public employment
Another issue of particular importance to consider in the Kazakh context is the “revolving door” between the public and private sectors. The revolving door phenomenon can be characterised as the movement of personnel between the public and private sectors in related fields, and can produce many positive outcomes, including the transfer of knowledge and experience. Nevertheless, it can pose several problems, including conflict of interest and the misuse of inside information. For example, individuals who work in a relevant area of the public sector and then move on to the private sector (or vice versa) may use inside information gained in their role in a way that gives them an unfair advantage (OECD, 2021[1]).
Some OECD countries have introduced a "cooling-off period" from public to private sector employment, as well as from private to public sector employment. When doing so, it is important to strike a balance between attracting qualified and experienced staff while avoiding undue influence on public sector decision-making.
In Kazakhstan, there is currently no cooling-off period after leaving office for any category of public officials. There are also currently no pre-employment restrictions in the public sector. However, the introduction of revolving door regulations is foreseen in point 9 of the Action Plan to implement the 2022-2026 Anti‑Corruption Policy Concept. The need for a more detailed regulation on the identification and resolution of conflict of interest, with the application of effective accountability measures, as well as the principle of “cooling off” before employment and after public service was acknowledged in the Plan.
When designing the provision, it is important to first specify which general provisions can be applied to a job before and after a move to the public sector to reduce integrity risks in the public sector. Restrictions and prohibitions on post-public service employment are useful tools to avoid the use of insider information and to discourage influence peddling, or to avoid being suspected of having previously made decisions that might be favourable to a potential employer. They can take various forms, such as a ban on the use of confidential information obtained during the public mandate, restrictions on certain activities for a certain period, such as agreeing to become a member of a board of directors or to be employed in private entities with which the public official has had official relations, or to participate in consultancy activities. In some countries, the intended professional activity after public employment requires a specific request for permission from the line manager or a dedicated entity (Box 6.7).
For a period of three years, former ministers, presidents of local executives and members of an independent administrative authority must refer the matter to the High Authority for transparency in public life to examine whether the new private activities they intend to carry out are compatible with their former functions.
Public bodies also control the transfer of former public officials to the private sector, which is carried out by the official’s supervisor. The line manager can refer to HATVP in case of doubt on individual cases. Referral to the High Authority is mandatory for certain senior officials.
Source: OECD (2021[1]), Lobbying in the 21st Century: Transparency, Integrity and Access, https://doi.org/10.1787/c6d8eff8-en.
Second, when determining the length of the periods of ineligibility, key factors to be considered include whether the durations are fair, proportionate, and reasonable, considering the seriousness of the potential offence. It is also necessary to tailor the duration of restrictions to the type of problem and the level of the hierarchy. For example, a ban on lobbying may be appropriate for a fixed period, but restrictions on the use of insider information could apply for life, or until the sensitive information is made public. Cooling-off periods on lobbying activities have been implemented for elected officials and certain positions at risk in several OECD countries. Box 6.8 contains examples among OECD countries that can serve as a model for Kazakhstan.
Rules restricting former lobbyists who become public officials from handling cases similar to those they worked on as lobbyists are relatively rare. However, some countries impose such a time limit when electing, appointing or hiring a private sector official to public sector responsibilities. In France, for example, HATVP was given a new "pre-appointment" control for certain positions of responsibility. A preventive check is carried out before appointment to certain high-level posts (including members of a ministerial cabinet, team members of the President of the Republic, directors of central administration), if a person has performed duties in the private sector during the three years preceding the appointment (OECD, 2021[1]).
Australia
In Australia, Ministers and Parliamentary Secretaries cannot, for a period of 18 months after they cease to hold office, engage in lobbying activities relating to any matter that they had official dealings with in their last 18 months in office. Additionally, persons employed in the Offices of Ministers or Parliamentary Secretaries at Adviser level and above, members of the Australian Defence Force at Colonel level or above (or equivalent), and Agency Heads or persons employed in the Senior Executive Service (or equivalent), shall not, for a period of 12 months after they cease their employment, engage in lobbying activities relating to any matter that they had official dealings with in their last 12 months of employment.
European Union
Within 12 months of the end of their duties, senior officials (Directors General and Directors) are prohibited from engaging in lobbying activities against their former institution on matters for which they were responsible during the last three years of their term of office.
Canada
Canadian federal law imposes a prohibition on designated public office holders from engaging in lobbying activities for five years from the end of their duties. These rules are, however, limited to designated holders within the meaning of the Lobbying Act, those who exercise the highest responsibilities in public institutions.
The Netherlands
A specific circular adopted in October 2020, “Prohibition of lobbying for former ministers,” prohibits ministers and any official employed in a department from accepting employment as a lobbyist, ombudsman or intermediary in professional contacts with a ministry representing an area in which they have had public responsibilities. The duration of the lobbying ban is two years. Its objective is to prevent ministers who retire or resign from using their position, knowledge and network acquired in their public service to benefit an organisation for which they work following their resignation. The Secretary General of the ministry concerned has the possibility to grant a reasoned exception to former ministers who request it.
Source: OECD (2021[1]), Lobbying in the 21st Century: Transparency, Integrity and Access, https://doi.org/10.1787/c6d8eff8-en.
The Authorised Ethics Officers could be tasked with providing advice to public officials on lobbying-related ethical dilemmas
Having clear principles, rules, standards, and procedures for public officials on their interactions with lobbyists is key, but it is not sufficient to mitigate the integrity risks of lobbying and other influence activities. Raising awareness of the expected rules and standards as well as enhancing skills and understanding of how to apply them are also essential elements to foster integrity in lobbying. Likewise, well-designed guidance, advice and counselling serve to provide clarity and practical examples, facilitate compliance, and help avoid the risk of misinterpreting rules and standards (OECD, 2021[1]).
Most countries with lobbying transparency frameworks do provide guidance, build capacity, and raise awareness of integrity standards and values for public officials. This may include induction or on-the-job training, disseminating the code of conduct and issuing posters, computer screensavers, employee boards, banners, bookmarks and printed calendars (OECD, 2021[1]). Training offered by public authorities commonly include guidelines on values and standards, expected behaviour, and concrete examples of good practices, ethical dilemmas, and descriptions of potentially problematic situations. Countries where public authorities offer training on interactions with lobbyists include Canada, France, Hungary, Ireland, Lithuania, Slovenia, and the United Kingdom.
The OECD interviews conducted for this report established that this aspect could be strengthened in Kazakhstan. The position of Authorised Ethics Officers recently introduced in state bodies, would be well‑positioned to respond to doubts related to lobbying, to guide and advise public officials and, if necessary, to coach or even accompany public servants during their interactions with interest representatives.
The strength and effectiveness of the policy-making process depends not only on the integrity of public officials but also on the integrity of those who try to influence them. Indeed, companies and lobbyists are critical actors in the policy-making process, providing government with insights, evidence and data to help them make informed decisions. However, they can also at times undermine the policy-making process by abusing legitimate means of influence, such as lobbying, political financing and other activities (OECD, 2021[1]). To ensure integrity in the policy-making process, lobbyists (whether in-house or as part of a lobbying association) require clear standards and guidelines that clarify the expected rules and behaviour for engaging with public officials. In particular, those who engage in public decision-making processes should comply with standards of professionalism and transparency in their relations with public officials (OECD, 2010[13]).
The 2022-2026 Anti-Corruption Policy Concept outlines measures to prevent corrupt behaviour in the private sectors. It emphasises the importance of increasing transparency and enhancing the implementation of international integrity and ethics standards in the business sector. To further reinforce businesses’ and CSOs’ frameworks for transparency and integrity in policymaking, while protecting and promoting civic space, Kazakhstan could increase the accountability and responsibility of the private sector and lobbyists for their activities along the following lines: i) developing and adopting standards of conduct which would apply to all lobbyists; ii) include mandatory responsible engagement principles and disclosures for corporations; and iii) amend the appropriate legislation to include violations of lobbying and influence related rules in the scope of wrongdoings whose disclosure benefits from whistle-blower protection.
Kazakhstan could develop and adopt standards of conduct for professional corporate lobbyists
Lobbyists need standards of professionalism and transparency that specify the rules and behaviour expected for engaging with public officials, as they share responsibility for fostering a culture of transparency and integrity in lobbying (OECD, 2021[1]). In some OECD countries, lobbyists self-regulate through codes of conduct published by employers of lobbyists or lobbying associations. However, the experience of OECD Member has shown that self-regulation remains insufficient to mitigate real or perceived problems of inappropriate influence by lobbyists. For this reason, some countries, such as Australia and Ireland, set standards directly through codes of conduct (Box 6.9). Kazakhstan could adopt a code of conduct for lobbyists based on these models.
Australia
Australia has both a Register of Lobbyists and a Lobbying Code of Conduct. The Code sets out the requirements for contact between third party lobbyists and government officials. Among the principles described in the Code, lobbyists must not make misleading, exaggerated or extravagant allegations, or misrepresent the nature or extent of their access to government officials, members of political parties or any other person. When first contacting government officials with the intention of lobbying, lobbyists who propose to lobby on behalf of clients must inform government officials of the following: the name of their employer and client(s), if they are currently registered on the Register, the nature of the questions their clients would like them to raise with government officials.
Ireland
The Public Service Standards Commission issued a Code of Conduct for Lobbying activities, which came into force on January 1, 2019. The Code sets out several principles with which persons engaged in lobbying activities must comply in the course of their activities, namely: 1. Show respect for public bodies, 2. Acting with honesty and integrity, 3 Ensure accuracy of information, 4. Disclose the identity and purpose of lobbying activities to public bodies and elected or appointed officials, 5. Preserving confidentiality, 6. Avoid undue influence, 7. Comply with the provisions of the Lobbying Regulation Act, and 8. Follow the Code of Conduct.
Source: OECD (2021[1]), Lobbying in the 21st Century: Transparency, Integrity and Access, https://doi.org/10.1787/c6d8eff8-en.
Second, the recommended lobbying regulation could also include explicit obligations for lobbyists clarifying their essential role in providing information which public officials will be then obliged to register and eventually publish on-line, for example:
the obligation to provide in a timely and truthful manner to the officials they meet the information requested in the law, for example their name, the entity they represent, and the objective of their lobbying activities
the obligation to report any violations of lobbying-related rules to competent authorities.
Such obligations do not necessarily require the creation of an additional register. In this sense, the proposed regulation law could follow the example of Chile, whose lobbying law provides for a number of disclosure obligations for lobbyists as well as for sanctions in case they are not complied with (Box 6.10).
Duties of lobbyists (as specified in the Law)
Duty to inform: to request a hearing with a lobbied person, the request must be made on a form including information on the persons who will attend the meeting and the organisation they represent. The form must also contain information on whether lobbyists receive remuneration for the activity they carry out, as well as matters to be dealt with during the meeting, with specific reference to the decision to be obtained.
Duty to provide additional information if required. The public body takes a decision on granting a hearing within three working days. They may request additional information. After the hearing, public officials may also request clarifying information within 10 working days of the meeting. The lobbyist then has 5 working days to respond in writing.
Code of Good Practice for Lobbyists
Lobbyists must abide by the principles of honesty and integrity, transparency, professionalism, and compatibility of private and public interests.
They must comply with regulations applicable to lobbying activities, regulations on political participation (financing of political parties and election campaigns, and all regulations applicable to political participation), refrain from unlawful conduct or provoking unlawful conduct.
In their relations with clients, (…) lobbyists should not accept any demand that would pose a risk to his/her ethical obligations or professional duties towards a client. A client has the right to report violations of the law by a lobbyist.
When interacting with public authorities, lobbyists shall provide the information required by law. They must inform precisely the issue or matter on which they engage in lobbying activities. They ensure the truthfulness and accuracy of the information they give to public authorities. Lobbyists must refrain from employing intermediaries to hide the link with their client. They must report misconduct to the competent authority. They must refrain from offering any payment, commission, compensation or benefit to gain access to information or person, or to influence a decision.
Lobbyists maintain their independence; they refrain from representing a particular interest of a client in conflict with that of another client. (…) Lobbyists must refrain from influencing public authorities or civil servants with which he/she has or had a contractual or family relationship. They must not hire former public officials for two years after leaving office. Lobbyists must refrain from any political activity or investing in the securities of the client without his/her permission.
Source: OECD (2021[1]), Lobbying in the 21st Century: Transparency, Integrity and Access, https://doi.org/10.1787/c6d8eff8-en.
Kazakhstan could include mandatory responsible engagement principles and disclosures in the Code of Corporate Governance, and encourage companies to include such standards in their own corporate governance code
Additionally, considering that lobbyists and companies are under increasing scrutiny, they need a clear integrity framework for engaging with the policy-making process in a way that does not raise concerns over integrity and inclusiveness (OECD, 2021[1]). Indeed, large institutional investors are becoming increasingly aware of the financial and non-financial risk of malpractice and are facing more pressure. As a result, risk and crisis management has become more dominant and the demand for transparency has increased.
Currently, the Law on Joint Stock Company is the principal legal source for corporate governance in Kazakhstan. According to the Law, the board of a company is obliged to act according to the principles of transparency and openness, and in the best interests of the company and its shareholders. All public companies should adopt a corporate governance code and disclose it on their website. The Law also describes the company’s code as follows: “the company’s corporate management code - the document approved by the general shareholders meeting of the company which regulates relations arising in the process of management of the company, in particular relations between shareholders and bodies of the company, between bodies of the company, the company and concerned persons”. In addition to the Joint Stock Company Law, the Law on Accounting and Financial Reports also sets out certain requirements for corporate reporting and requires companies to prepare annual financial statements in compliance with International Financial Reporting Standards. Issues related to environment and society are disclosed only on a voluntary basis.
The National Council on Corporate Governance (NCSM), under the National Chamber of Entrepreneurs Atameken, was established to improve the quality of corporate governance in companies and encourage the introduction of international best practices. The Council includes leading experts, representatives of the Ministry of the National Economy, as well as representatives from the private sector. The NCSM developed a series of initiatives, including maps of issues/risks in the sphere of corporate governance, a concept on the development of national standards of corporate governance, draft methods of assessment and rating of corporate governance of Kazakh companies. Based on the results of extensive public discussions with the involvement of corporate directors and secretaries, public and private companies, and experts, a step-by-step work on the development of national standards was carried out.
In particular, the NCSM developed the following documents:
Corporate Governance Code of the Republic of Kazakhstan. The application of the Code is voluntary, but companies listed at the Kazakhstan Stock Exchange are obliged to follow the Code or another similar instrument, approved at the general shareholder meeting or by the legislation of the jurisdiction of registration of the issuer. Under the listing rules, companies are also required to provide the Exchange with an annual report containing information about compliance with the code the company follows and/or actions taken to comply with it.
Guidance on the application of the Corporate Governance Code of the Republic of Kazakhstan in companies with state participation in the authorised capital.
Guidance on the application of the Corporate Governance Code of the Republic of Kazakhstan in non-public companies.
Handbook for Independent Directors.
Guidance on organising the activities of corporate secretary.
A Questionnaire on compliance with the Corporate Governance Code.
Recommendations on amendments and additions to the legislation of the Republic of Kazakhstan on the issue of development and application of national standards of corporate governance.
On 27 April 2021, the developed standards were approved by decision of the Presidium of the National Chamber. The approaches have been conceptually approved by the Prime Minister of Kazakhstan and worked out with the Ministry of National Economy. However, the Code does not sufficiently highlight the board’s responsibility in reviewing of the company’s lobbying strategies and practices, how they align with broader corporate sustainability pledges, and measures taken by companies to engage responsibly through their corporate governance. In addition, the Integrity Scan reported the practice of corporate social responsibility in Kazakhstan is furthermore not fully aligned with the concept of responsible business conduct as recommended by the OECD instruments, such as the Guidelines for Multinational Enterprises, and may in some cases contain a high risk of corruption due to the lack of accountability (OECD, 2017[15]).
To that end, companies’ internal efforts could be supported by government actions to incentivise carrying out influence and lobbying activities with transparency and integrity. First, the Government of Kazakhstan could encourage companies and organisations to formalise responsible engagement standards and internal processes that address the full scope of corporate and trade association conduct in the policy-making process to reassure the public and institutional investors that lobbying is done professionally and with high standards. Standards could cover issues such as ensuring accuracy and plurality of views, promoting transparency in the funding of research organisations and think tanks, preventing and managing conflict of interest in the research process and ensuring that staff assigned to conduct lobbying activities have a good understanding of transparent, responsible and thus professional interaction (Box 6.11). Such standards could be included in the Code of Corporate Governance, and compliance with the standards could be made mandatory.
The Foreign Investors’ Council, chaired by the President, with the aim of increasing foreign investment and improvement of the country’s investment climate, could also consider responsible engagement related aspects into its work stream; for example, by creating dialogue and spreading knowledge among corporations about responsible engagement / responsible lobbying. Lastly, the Government of Kazakhstan could adopt a mandatory obligation for both private companies (through the Law on Joint Stock Company) and quasi-public sector entities to disclose detailed information on their lobbying activities, as part of their non-financial reporting obligations.
Creation of a responsible engagement/lobbying policy and explaining how lobbying and influence activities align with public commitments to support goals on climate change and other shared sustainability challenges.
Specifying the role of board members, top management and senior executives in regularly monitoring the implementation of the standards. The board should be in charge of monitoring and overseeing the company’s lobbying/influence activities and how they align with broader corporate sustainability pledges. Board members and management can also be held personally liable for violations of the rules.
Establishing adequate due diligence measures to ensure that the positions and practices of those who lobby on a company’s behalf (industry and lobby associations) do not run afoul of the organisation’s values and commitments. This may include:
processes to regularly review membership of trade associations and third-party organisations and identify misalignment
transparency on memberships of trade associations or other third-party organisations that may engage in political activities (charities, foundations, PACs, fundraising organisations)
the level of funding and engagement in these organisations (e.g. representation on the board, funding beyond membership, participation in specific committees or working groups)
actions taken when the positions and lobbying practices of these organisations do not align with the company’s own lobbying practices and commitments.
Mainstreaming these standards across all business lines – including government affairs and sustainability functions to create a coherent position across the company’s government affairs activities and CSR/ESG branches. These policies should ensure that CSR/ESG teams have sufficient access to information on a company’s lobbying activities.
Include lobbying/influence related risks in risk management strategies and disclose information about them.
Adopting transparency and integrity measures on the hiring of former public officials.
Integrity training on conducting lobbying activities. Provision of integrity related training to company board members, management and lobbyists on lobbying responsibly is an effective way to spread knowledge about the key principles that should guide responsible engagement.
Incentivising responsible engagement within companies. For example, linking the promotion and implementation of the company’s integrity policy / lobbying policies to performance-related bonuses and remuneration.
Whistle-blower protection. Developing internal reporting mechanisms and providing protection to whistle-blowers who report violations of lobbying related rules or the companies’ own lobbying policies play an essential role in enhancing companies’ integrity framework.
Reporting initiatives. Some companies can adhere to reporting initiatives to disclose information on their lobbying activities.
Sources: OECD (2022[25]), “Regulating corporate political engagement: Trends, challenges and the role for investors”, https://doi.org/10.1787/8c5615fe-en; OECD (2011[26]), OECD Guidelines for Multinational Enterprises, https://web-archive.oecd.org/2023-06-27/95735-48004323.pdf; OECD (2017[27]), “Responsible business conduct in Kazakhstan and the OECD Guidelines for Multinational Enterprises”, https://doi.org/10.1787/9789264269606-12-en.
One of the ways in which private interests can influence public-decision making processes is to exert control over the election of representatives who will vote for or against certain policies, or who are able to pressure the public administration to take certain decisions. Specific interest groups can help politicians get elected to office and later ask for favours in return. This can be achieved by providing financial contributions to candidates or political parties and their campaigns, by providing services such as opposition research or access to private media, funding online advertisement campaigns, as well as by helping politicians gain votes through vote-buying or by organising and mobilising voters (OECD, 2016[28]; 2021[1]).
Like lobbying practices covered in the section above, political finance is a necessary component of the democratic process: it enables the expression of political support and competition in elections. However, without the necessary guardrails, efforts to influence election processes present risks to endanger the integrity and legitimacy of democratic systems.
In Kazakhstan, general elections are conducted regularly at the national level and universal suffrage by secret ballot is ensured. There are currently seven political parties registered in Kazakhstan, of which six have members in the Majilis. The Law on Political Parties of the Republic of Kazakhstan (2002) and the Constitutional Act on Elections in the Republic of Kazakhstan (1995), which was last amended on 5 November 2022, form the framework for political parties, campaigning, and elections.
However, despite recent attempts to reform, the party system continues to lack real competition and elections are largely perceived as a formality for the ruling party, Amanat, which won 62 of the 98 Majilis seats in the March 2023 elections. While more political formations entered the lower house than in the last term (five, as opposed to two in the previous term), they are considered to be aligned with Nur Otan on the vast majority of issues. Observers from the Organisation for Security and Cooperation in Europe (OSCE) noted that the March 2023 elections “brought elements of competitiveness in the political area” with contestants able to campaign actively and freely, but that limits on the exercise of constitutionally guaranteed fundamental freedoms remained, while some political groups continued to be prevented from participating as political parties in elections (OSCE, 2023[29]).
To enhance transparency and integrity in election processes, Kazakhstan could therefore consider to: i) level the playing field by setting ceilings for private contributions and in-kind donations; ii) improve transparency of public funding; iii) limit the amount of money political parties can spend on political advertising and enhance transparency over these activities; iv) enhance transparency on the sources of funding and the financial expenditures of political parties and candidates; v) strengthen audit capacities in order to enable better enforcement of political financing rules; and vi) ease candidate eligibility and registration requirements.
The recommendations are in line with priorities for political reform set out by President Tokayev in a recent speech: “The substance of the reforms is designed to dismantle the previous super-presidential system and construct a more participatory and inclusive democracy in its place. New powers for our parliament, the removal of prohibitions on the formation and registration of political parties, and a single seven-year term limit for presidential tenures, accompanied by a ban on a president's relatives holding key positions, constitute vital tenets of the reform program.” (Kassym-Jomart Tokayev, 2022[12])
To limit risks of undue influence, Kazakhstan could introduce a nominal ceiling for inkind donations
Political parties and candidates need money to compete and finance election campaigns, and to communicate their proposals to citizens. In this sense, private funding from citizens and interest groups allows for support from society-at-large for a political party or candidate. It is widely recognised as a fundamental right of citizens. Yet, if private funding is not adequately regulated, it can be easily exploited by private interests to influence the result of elections, or push elected public officials to represent the interests of their funders and not of those who elected them. Another key challenge with respect to private funding is to address the high level of informality that endangers accountability.
There are no easy solutions to limit the problem of illicit or undeclared funding, however. More than merely prohibiting informal contributions, inducements have to be provided in a way that private donations are channelled as much as possible through formal means. This can be achieved by adequately framing the rules of the game for private funding, by establishing clear limits on private donations, prohibiting donations in cash and from certain sources, and allowing contributions by legal entities up to a certain amount (OECD, 2016[28]).
Most OECD countries have introduced monetary regulations to prevent uncontrolled, undisclosed and opaque political finance. In Kazakhstan, resources for political parties originate from various public and private sources, as well as membership fees for political parties. For election campaigns (presidential elections, members of Parliament and members maslikhats), political parties rely on “election funds”, in which they can use their own funds and receive private campaign contributions from citizens and legal entities. Candidates are also able to use their own funds and income. The maximum amount independent candidates can receive differs from party candidates, as they are not entitled to resources from a nominating party. Article 34 of the Election Code of the Republic of Kazakhstan prohibits anonymous and foreign donations, as well as voluntary contributions from state bodies or organisations, local self‑government bodies, charitable organisations, religious associations, and legal entities with foreign stock on their charter capital. All donations must go through the banking system. To that end, election funds must be kept on a special temporary bank account after registration of the candidate or the party list, in a bank chosen by the Central Election Commission.
Recent constitutional amendments to the Elections Law in 2022 introduced limits on the amount a donor (individuals and legal entities) can contribute to a political party or candidate during a specific election period, established in Articles 58, 75, 92-1 and 106 of the Election Law. In addition, a limit applies to the total amount of donations (Table 6.3). Funds received above the established amount cannot not be credited to electoral funds and must be returned to the citizens and organisations that provided them, and anonymous donations must be transferred to the republican budget.
The introduction of ceilings for donations from citizens and legal entities is a positive development and reinforces the integrity of election processes. To further limit the risks of undue influence, the legal framework could also specify the types of in-kind contributions a donor can contribute to a political party and candidate and specify a limit for these types of contributions. In-kind contributions refer to non-financial donations provided in the form of goods and services, such as use of venues for events free of charge, using vehicles or non-monetary gifts (International IDEA, n.d.[30]).
Source: Author’s contributions, based on articles 58, 75, 92-1 and 106 of the Election Law.
Kazakhstan could improve the transparency of public funds and subsidies for campaign financing
Public funds give guarantees to political parties that they will have the minimum resources needed to develop political and representative activities, pay ordinary expenses, maintain representative and participation bodies, and organise electoral campaigns. All OECD countries have provisions for direct public funding to political parties, for their ordinary activities as well as their election campaigns. The eligibility criteria for receiving these funds can be based on the share of votes in elections (as in France, Australia, Mexico, or United States) or their representation in elected bodies (as in the United Kingdom, Austria or Japan).
In Kazakhstan, political parties represented in Parliament receive annual financial support from the state proportionate to the number of votes received in elections. Funds from the state budget can be used to cover various expenses specified in the legal framework, including media appearances, printed materials and holding rallies. Each candidate is also granted with funds for a 15-minute speech on TV, 10 minutes broadcasting on the radio, as well as for the publication of 2 articles in the press. Political parties that have nominated their party lists can also participate in political debates on TV organised by the Central Election Commission, within the time limit fixed by the Central Election Commission.
While the rules around campaign finance broadly align with those of OECD countries, some areas for improvement remain. Expenditures from state funding are not published before or after election day. The Central Election Commission specified that this data may be provided to citizens upon request. To enhance transparency, the expenditures from state funding could be made publicly available by the Central Election Commission. In addition, the eligibility criteria for state allocations could be amended, so that registered political parties who participate in the election can receive support from the state budget. Among OECD countries, Chile, Colombia, Estonia, Germany, Lithuania, Poland, and Slovakia, provide such subsidies to political parties who are registered as a political party (International IDEA, n.d.[30]).
Kazakhstan could adopt a legal framework to enhance transparency on political advertising, including online political advertising
As in other countries, Kazakhstanis are increasingly moving their activities onto social media and the Internet and are using these channels as a source of news and information, leading to both opportunities and challenges for the integrity of election processes. To uphold the integrity of elections, it is increasingly important, in today's context, to monitor closely the way in which political parties use data and digital platforms to influence voters (OECD, 2022[25]; 2016[28]).
In Kazakhstan, the legislation currently does not provide for the concept of “political advertising.” The relevant law provides the opportunity for paid advertising without any limitations, apart from those imposed by the overall campaign expenditure limit. In addition, there are no limits on online media advertising. Campaigning is carried out in four ways: i) through the media; ii) by holding public pre-election events (pre‑election meetings and meetings with voters, public pre-election debates and discussions, rallies, processions, demonstrations and other pre-election events in accordance with the procedure established by law; iii) personal meetings of candidates and their proxies with voters; iv) by issuing and (or) distributing printed, audio-visual and other campaign materials; and (v) through online platforms. However, in practice, candidates’ campaign in traditional media is mainly limited to televised debates organised by the Central Election Commission, with political parties relying heavily on political paid advertising. As such, the legal framework could be amended to specify spending limits on political advertising. For example, the French Electoral Code prohibits "any commercial advertising process through the press or any means of audio‑visual communication (including social networks)" during the six months preceding the first day of the month of an election (the prohibitions do not apply to ’sponsored ads’ from other political groups, associations and think tanks). In the United Kingdom, party advertising of any kind count as campaign spending and are subject to the rules on fundraising and spending that political parties must follow in the run-up to certain elections, as specified in the Political Parties, Elections and Referendums Act 2000 (PPERA). Canada’s Elections Act sets spending limits for federal election campaigns. These limits include maximum amounts that parties and candidates can spend on election advertising, including broadcast and online advertising (Box 6.12).
Activities and spending of political entities during the pre-election period
During the pre-election period (starting on June 30 of a fixed-date general election year), many activities of political entities are subject to specific rules. Here is an incomplete list:
All partisan advertising by registered parties, registered associations and third parties must have a tagline stating who authorised the ads.
Regulated online platforms (websites or applications that meet certain criteria for monthly visitors or users) must maintain a registry of political advertising.
Expenses for partisan advertising by registered parties and third parties are subject to a limit.
Expenses for partisan activities and election surveys by third parties are subject to a limit.
Activities and spending of political entities during the election period
During the election period (starting on the day the election is called), many activities of political entities are subject to specific rules. Here is a non-exhaustive list:
All election advertising by registered parties, candidates and third parties must have a tagline stating who authorised the ads.
Election advertising in an electoral district is not allowed on election day before the close of all polling stations in that district.
Results of election surveys that have not been previously transmitted to the public in an electoral district may not be transmitted on election day before all polls close in that electoral district.
Expenses incurred by registered parties and candidates to directly promote or oppose a party, party leader or candidate during an election period are subject to a limit.
Expenses for election advertising, partisan activities and election surveys by third parties are subject to limits (in a given electoral district and overall).
Source: Elections Canada (n.d.[31]), Political Financing, Spending, and Advertising Safeguards, https://www.elections.ca/content.aspx?section=vot&dir=int/pol&document=index&lang=e.
Kazakhstan could enhance transparency on the sources of funding and the financial expenditures of political parties and candidates
To enable effective enforcement of political finance regulations, transparency is essential: it ensures that citizens and the media can serve as watchdogs to effectively scrutinise political actors. That is why in most OECD countries, parties have to report income and expenses, as well as on their finances in relation to election campaigns (Figure 6.2).
In Kazakhstan, all contributions made to political parties and/or candidates must be registered and reported. Article 34 of the Election Code of the Republic of Kazakhstan states that the election funds shall be subject to the state registration. The sources of election funds must be reported, including: i) personal funds of candidates and funds from political parties; ii) funds allocated by the nominating organisation; iii) voluntary donations from citizens and organisations. Banks are obliged to report to the CEC weekly on all incomes and expenditures of political parties. Since 2015, the Central Election Commission has published campaign finance overviews twice a month in the campaign period, specifying the total amounts received and spent per party. According to the legislation, information on the total amount of money and the amount of voluntary donations received, its sources and expenses for the election campaigning is published in the media within five days after the publication of the election results. Between election periods, political parties must also publish their annual financial reports. Within five days after the establishment of the results of the elections, the candidate and political party must present the relevant election commission (Central Election Commission or territorial election commissions) a report on the estimation of the funds from their election fund. Based on these reports the CEC publishes an overview of the total amount received by each party and the sources of those funds.
Note: countries marked with an asterisk (*) do not have centralised data on practice. For annual financial reports, regulations refer to the criterion “Political parties must make financial reports public, including all contributions exceeding a fixed ceiling” and practice refers to the criterion “All political parties have submitted annual accounts within the timelines defined by national legislation for the past five years”. For election campaign financial reports, regulation refers to the criterion “Parties and/or candidates must report their finances (funding and expenses) during electoral campaigns” and practice refers to the criterion “All political parties have submitted accounts related to elections within the timelines defined by national legislation for the past two election cycles.”
How to read: 79 % of OECD countries have regulations requiring political parties to publish annual financial reports, 32 % of OECD countries have both regulations requiring political parties to publish annual financial reports and all political parties published annual financial reports within the timelines defined by national legislation for the past five years, 42 % of OECD countries have regulations requiring political parties to publish annual financial reports but not all political parties published their annual financial reports within the timelines defined by national legislation in the past five years.
Source: OECD (n.d.[16]), OECD Public Integrity Indicators, https://oecd-public-integrity-indicators.org/ (accessed on 1 December 2023).
However, detailed financial reports are currently not made publicly available and posted on the website of the Central Election Commission. This means there is a lack of information on donors and how the funds were spent. In line with OSCE observation reports, which recommended more detailed information on the amount and source of campaign contributions, and the amount and purpose of campaign expenditures (OSCE, 2022[6]), the legal framework could be amended to specify the content and format of campaign finance reports, and include the obligation to specify the sources of funding (in particular from legal entities) and the details of the expenditures by political parties.
Kazakhstan could strengthen audit capacities to enable better enforcement of political financing rules
Even strong regulations require effective monitoring and enforcement. Also, if sanctions are too low, political parties may just factor them in as a cost and continue with the practices that are breaching the law, as the benefits from doing so outweigh the costs. Enforcing regulations has two components; on the one hand, breaches must be effectively detected, on the other hand, detected breaches must be effectively sanctioned (OECD, 2016[28]).
In Kazakhstan, the oversight institutional framework includes the Central Election Commission, as well as 246 Territorial Election Commissions. The Central Election Commission is composed of seven-members appointed for a five-year term. For the CEC, the chairperson and two members are appointed by the President, while the Senate and the Majilis appoint two members each. In addition, oversight is limited to cross-checking data from the election reports with the data submitted by the bank. The Central Election Commission does not conduct any audits, making campaign finance oversight very limited and ineffective.
The Administrative Offences Code defines sanctions for breaches of campaign finance rules, which include fines for failure to report campaign expenditures and for bypassing funding through the designated bank account. In addition, the Election Law provides for the deregistration of parties and candidates, and the invalidation of results if campaign finance violations are revealed after the vote. However, the legislation allows for wide discretion in their application and does not set any specific criteria for application. As a result, no sanctions were reported to have been applied for potential breaches of campaign finance rules.
The legal framework could therefore be amended to require the Central Election Commission to conduct audit of election reports. To that end, the Central Election Commission will need to be provided with adequate audit capacities and resources. Indeed, interviews conducted during the fact-finding mission confirmed that the Commission is currently understaffed to conduct adequate audit activities. See also the recommendations under Chapter 5 on internal controls and audit.
To increase competitiveness of elections, candidate eligibility and registration requirements could be eased
In Kazakhstan, candidates for Presidential elections must be at least 40 years old, fluent in the Kazakh language, have a higher education degree, have been officially resident of the country for the last 15 years, be members of a party or a republican organisation, having served 5 years in the administration. Eligible voters aged 25 years old or older and officially resident of the country for at least 10 years have the right to stand for parliamentary elections, According to the OSCE, these strict eligibility requirements, and in particular the education and residency requirements for candidacy, are excessively restrictive, limit the constitutionally guaranteed right of citizens to stand for elections, and are not in line with international standards and commitments to ensure pluralism and competitiveness (OSCE, 2022[6]). Reforms introduced in 2017 also imposed a submission of detailed medical records, which raised the possibility of candidates being arbitrarily disqualified for health reasons.
In addition, the Election Law also imposes limits on persons serving criminal sentences, those with a criminal record, and those with a prior conviction for a crime or administrative offence involving corruption. While such restrictions may be common in other countries with strong rule of law institutions, there is a concern that these restrictions could be misused to prevent candidates who have faced arbitrary legal action from running for election. To enable more pluralism and competitiveness of elections, candidate eligibility and registration requirements could be eased, in line with OSCE commitments and international standards (OSCE, 2022[6]). Taking action on these recommendations would support President Tokayev’s plans for political reform, including the removal of prohibitions on the formulation and registration of political parties’ issues (Kassym-Jomart Tokayev, 2022[12]).
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