This chapter provides recommendations on how Kazakhstan could make its integrity system more coherent and ensure functional autonomy of key institutions. Kazakhstan has updated its anti-corruption laws and strengthened the role of anti-corruption institutions but checks and balances could be improved to protect their functional autonomy. To improve coherence, Kazakhstan could enhance co-ordination across levels of government and with civil society and business.
OECD Integrity Review of Kazakhstan
Advancing Integrity for Economic Development
Abstract
Corruption reduces competition, private and foreign direct investment and international trade. In contrast, improving control has positive long-term effects on per capita gross domestic product growth (Jin, 2021[1]). Tackling corruption across sectors requires a systemic approach to corruption prevention (Pyman and Heywood, 2024[2]). Mainstreaming anti-corruption measures across sectors and organisations allows tailored responses to specific sectoral and organisational challenges. Co-ordination of anti-corruption measures between the national and local levels of governance is critical to respond to possible corruption risks emerging along the fiscal decentralisation (OECD, 2021[3]).
Economic growth and several public sector reforms in Kazakhstan over the last years have significantly strengthened institutions in the country (OECD, 2017[4]). The current National Development Plan of Kazakhstan until 2029 assigns an important role to anti-corruption measures aiming at increasing effectiveness of public governance and rule of law, as well as improving education and the healthcare system. As one of the priorities, the plan aims “to reduce the level of corruption as one of the main threats to the economic and social development of the country” (President of the Republic of Kazakhstan, 2024[5]). Toward this end, Kazakhstan has committed to a strategic effort under its Anti-Corruption Policy Concept of the Republic of Kazakhstan for 2022-2026" (Қазақстан Республикасының сыбайлас жемқорлыққа қарсы саясатының 2022-2026, 2022-2026 Anti-Corruption Policy Concept or 2022-2026 Policy Concept) (Government of Kazakhstan, 2022[6]). A series of laws introduced in the last decade including the Law on Combating Corruption (2015) and the Law on Civil Service (2015), have brought the country closer to international anti-corruption and integrity standards (OECD, 2017[4]). Since then, Kazakhstan has continued to strengthen its legal framework, including amendments to the Anti-Corruption Law regarding the protection of whistleblowers in 2023, as well as extended financial control measures that will enter into force in 2027.
Notwithstanding these positive developments, perceptions of levels of corruption in the Kazakh public sector remain high. Kazakhstan scored 39 on a scale of 0 (highly corrupt) to 100 (very clean) in the 2023 Transparency International Corruption Perception Index (CPI), consolidating its position ahead of the Central Asia region average (27.8/100), but largely below the OECD average (66.6/100) (Transparency International, 2023[7]). There is a considerable push for strengthening public integrity, both domestically and internationally. In 2022, public demonstrations sparked by increasing fuel prices became general protests, calling the government to act against corruption (Walker, 2022[8]; Transparency Kazakhstan, 2022[9]). International organisations such as the Council of Europe and the International Monetary Fund have called for further reforms to strengthen integrity, transparency and accountability and to reduce corruption-related vulnerabilities (Council of Europe, 2023[10]; IMF, 2024[11]).
To ensure that Kazakhstan’s reform efforts in the area of anti-corruption and integrity are effective in practice requires a strong institutional framework with clear and complementary responsibilities, adequate resourcing, as well as effective co-ordination and monitoring. In addition, any reform can only be effective if there is a focus on implementation and mainstreaming across the government through awareness-raising and capacity-development efforts. As such, additional efforts are needed in Kazakhstan to cultivate a robust culture of integrity within the public sector and throughout society, emphasising the importance of allocating adequate resources to effectively implement reforms and initiatives. Moreover, as quasi-public sector1 entities constitute a significant part of the economy of Kazakhstan, efforts to cultivate a culture of integrity as well as appropriate laws and regulations on anti-corruption and integrity could be extended to this sector.
This chapter provides an overview of the laws and institutions that make up Kazakhstan’s integrity framework and serves as a background for the other chapters of this report. It includes recommendations on how to strengthen the institutional framework to address the implementation gap between objectives and results against the background of Kazakhstan’s strategic development goals.
The OECD Recommendation on Public Integrity (OECD, 2017[12]) provides policy makers with a vision and practical framework for a coherent and comprehensive public integrity system. Public integrity is defined there as “the consistent alignment of, and adherence to, shared ethical values, principles and norms for upholding and prioritising the public interest over private interests in the public sector”. As such, it looks at the legal, institutional, and cultural frameworks that support integrity. By shifting the focus from fragmented and ad hoc integrity policies to a context dependent, behavioural and risk-based approach, emphasis is put on building a culture of integrity across government and the whole of society (Figure 1.1). Three pillars are equally important to bring a coherent framework for integrity in place:
1. The system of public integrity is based on the political commitment and results in clear institutional responsibilities, strategic and evidence-based approach to anti-corruption, as well as high standards of conduct applied by public officials.
2. Culture of public integrity is a substantial pillar that promotes whole-of-society approach (i.e. partnering with private sector and civil society), investing in integrity leadership and professional public sector, especially through sufficient training and guidance. This pillar also encompasses an open organisational culture.
3. Effective accountability is crucial for the credibility of the entire framework. It includes control and risk management framework, enforcement mechanisms, external oversight and control as well as transparency and stakeholders’ engagement in policymaking.
Source: OECD (2017[12]), Recommendation of the Council on Public Integrity, https://legalinstruments.oecd.org/en/instruments/OECD-LEGAL-0435.
The legal framework for public integrity in Kazakhstan
Since 2015, Kazakhstan has made significant efforts to develop the legal framework for public integrity,2 including the adoption of the Law on Combating Corruption and the Law on Civil Service (Box 1.1). Several important draft laws and innovations pending to come into force at the time of writing are underway. Declarations of income and property were introduced in 2021 with publication foreseen in 2025 and verification to become fully operational in 2027, based on a digital system of financial control. Additionally, if implemented, a draft law introducing new rules on conflict-of-interest will address a significant gap in terms of standards and procedures for managing conflict of interest. In July 2023, the Anti-Corruption Service opened a public discussion on amendments to the Code on Administrative Offences (2014) and several legislative acts, including the Criminal Code (2014), the Labour Code (2015), the Law on Operational-Investigative Activities (1994), and the Law on Personal Data and Their Protection 2013) (Antikor, 2023[13]). Through these legislative changes Kazakhstan aims to introduce a public register of corrupt officials, develop further financial investigation instruments, introduce liability/responsibility for those that offer bribes, increase responsibility for legal entities that commit corruption, and update regulations on the interaction between the Authorised Ethics Officers and the Anti-Corruption Service. In addition to these reforms, Kazakhstan has been implementing broader reforms on citizen participation (covered in Chapter 6).
Law on Combating Corruption
In 2015, Kazakhstan passed the Law on Combating Corruption which establishes a wide range of integrity elements, including:
anti-corruption monitoring (Article 7)
analysis of corruption risks (Article 8)
formation of an anti-corruption culture (Article 9)
asset and income declarations for elected and public officials (Article 11)
conflict of interest management (Article 15)
institutional arrangements for preventing corruption (Articles 18-24)
requirements for public officials to report corruption and protection of those that report (Article 24).
All state bodies, organisations, quasi-public sector entities and public officials are required to perform anti-corruption measures within their competences.
Law on Civil Service
Also in 2015, Kazakhstan adopted a new Law on Civil Service which contains provisions on:
legal and other protection of civil servants reporting corruption offences (Article 9 and 52(4))
restrictions for those holding an official position, including the requirement to transfer private assets to trust management (Article 13)
conflict of interest management (Article 51)
anti-corruption requirements on public officials (Article 52)
obligations to take measures to prevent corruption among subordinates (Article 60)
the relevant disciplinary offences and penalties (Article 44), the terms of application (Article 45), and outlines the appeal process for public officials (Article 46).
The Law on Civil Service applies to all civil servants, with some exceptions, for example civil servants in technical positions and employees of the National Bank, as well as persons employed in accordance with labour legislation.
In 2019, the Law on Civil Service was amended, requiring elected and appointed public officials to resign if their direct subordinates commit corruption. This amendment especially affected the top tier in public service. Prohibitions on gift-taking under the Law on Civil Service were also introduced in 2022.
Sources: Government of Kazakhstan (2015[14]), Law on Combating Corruption of Republic of Kazakhstan, https://adilet.zan.kz/rus/docs/Z1500000410; Government of Kazakhstan (2016[15]), Law on Civil Service of the Republic of Kazakhstan, https://adilet.zan.kz/rus/docs/Z1500000416.
While Kazakhstan has the main legal building blocks of a public integrity system in place, continuous efforts to strengthen the legal framework in line with stakeholder feedback and recommendations from international bodies (including the recommendations in Chapters 3 and 6 of this report) will ensure that it remains fit for purpose.
The institutional framework for integrity in Kazakhstan
To effectively promote public integrity, it is crucial to involve various official actors in the public sector that cover the diverse functions of an integrity system as defined in the 2017 OECD Recommendation on Public Integrity (Table 1.1). These integrity actors include the “core” integrity actors, such as the institutions, units, or individuals responsible for promoting, implementing and enforcing integrity policies, as well as “complementary” integrity actors with key support functions such as audit, human resource management, finance or public procurement (OECD, 2020[16]). Undoubtedly, the private sector and civil society perform a key role as well. A robust integrity ecosystem is effective when these actors work harmoniously, reinforcing one another’s efforts to maintain ethical conduct, transparency, and accountability.
The Commission under the President of the Republic of Kazakhstan on Anti-Corruption Issues (Қазақстан Республикасы Президентінің жанындағы Сыбайлас жемқорлыққа қарсы комиссия, Anti-Corruption Commission) is the advisory body responsible for ensuring implementation of the tasks set by the President of the Republic of Kazakhstan in this field. In particular, the Commission adopts co-ordinated measures for counteracting corruption and violations of the Code of Ethics and increasing responsibilities in public service (President of the Republic of Kazakhstan, 2002[17]). The tasks of the Commission are to develop and take co-ordinated measures aimed at strengthening the fight against corruption and violations by civil servants of the rules of official ethics, and to increase the level of responsibility of civil servants. The Commission is headed by the State Counsellor of the Republic of Kazakhstan. The Deputy Chairman of the Commission is the Assistant to the President - Secretary of the Security Council, and the Secretary is the Head of the Law Enforcement Division of the Security Council. The Commission includes ex officio heads of the Presidential Administration, the Prosecutor General, the Chairman of the National Security Committee, the Chairman of the Supreme Audit Chamber, the Chairman of the Anti-Corruption Agency, the Chairman of the Financial Monitoring Agency and other heads of state bodies, as well as heads of parliamentary committees. Meetings of the Commission are held as necessary, but at least once a quarter, may be open or closed by decision of the Chairperson of the Commission and the information about the meetings of the Anti-Corruption Commission is available online (President of the Republic of Kazakhstan, n.d.[18]).
Sources: OECD (2020[16]), OECD Public Integrity Handbook, https://doi.org/10.1787/ac8ed8e8-en; OECD (2017[12]), Recommendation of the Council on Public Integrity, https://legalinstruments.oecd.org/en/instruments/OECD-LEGAL-0435.
Kazakhstan has a specialised anti-corruption body, the Anti-Corruption Service (Қазақстан Республикасы Сыбайлас жемқорлыққа қарсы іс-қимыл агенттігі, Antikor), which handles core integrity functions, alongside the Civil Service Agency overseeing policy areas related to public sector integrity. The Anti-Corruption Service is directly subordinate and accountable to the President of the Republic of Kazakhstan and has both law enforcement (detection and pre-trial investigation) and prevention functions. The Anti-Corruption Service is responsible for the development and implementation of the anti-corruption policy. Its structural units include prevention, pre-trial investigation, detection and suppression services, the department of standard-setting and international co-operation, as well as several support units. The Anti-Corruption Service consists of a central office and 20 territorial directorates. Its mandate is described in Box 1.2.
The Anti-Corruption Agency of the Republic Kazakhstan (Anti-Corruption Service, Antikor) performs the following functions:
development of proposals to improve the regulatory framework in the field of anti-corruption
identification of the causes and conditions contributing to the commission of corruption offences in the activities of state bodies, organisations, and quasi-public sector entities
submitting recommendations for the consideration of the government of the Republic of Kazakhstan on minimising and eliminating the causes and conditions of corruption in the activities of state bodies, organisations, and quasi-public sector entities
annual submission of the national report on combating corruption to the president of the Republic of Kazakhstan
formation and co-ordination of an anti-corruption policy, co-ordination of the activities of state bodies and organisations in the prevention of corruption, minimising the causes and conditions conducive to the commission of corruption offenses, including co-ordination of Compliance Officers in the quasi-public sector
assessing the level of corruption and conducting sociological studies necessary to determine the level of corruption in the public and private sectors
monitoring of the implementation by state bodies, organisations, quasi-public sector entities of recommendations on the elimination of causes and conditions conducive to the commission of corruption offenses, made based on the results of an external analysis of corruption risks
monitoring the sale of property confiscated in criminal cases of corruption crimes and acquired with funds obtained by criminal means, as a rule, with the subsequent publication of information about its circulation to the state revenue
development of proposals for improving educational programmes in the field of anti-corruption culture formation
assistance and provision of methodological assistance to anti-corruption entities in the implementation of educational programmes on anti-corruption education and upbringing, information and explanatory activities, execution of the state social order aimed at the formation of an anti-corruption culture
participation in the preparation of drafts of international treaties on anti-corruption issues, interaction with the relevant authorities of foreign states on anti-corruption issues, participation within their powers in the activities of international organisations
other functions assigned by the laws of the Republic of Kazakhstan, as well as acts of the president of the Republic of Kazakhstan.
Source: Responses received from Kazakhstan to the OECD questionnaire.
The Civil Service Agency (Қазақстан Республикасы Мемлекеттік қызмет істері агенттігі) is responsible for issues concerning public officials and the implementation of the Code of Ethics (Box 1.3). It is directly subordinate and accountable to the President of the Republic of Kazakhstan. The Ethics Commission under the Agency deals with violations of the Code of Ethics by high-level civil servants (heads of the central executive bodies (akims) of regions, cities of republican level and the capital, central-level Authorised Ethics Officers of categories B-1, B-2, C-1, C-2, C-O-1, C-O-2). The Commission also develops guidance for preventive measures, provides recommendations for the work of Authorised Ethics Officers that provide advice on integrity standards at entity-level and the work of disciplinary commissions. (Agency for Civil Service Affairs, 2016[19]) The Commission is a collegial body, consisting of minimum 7 members representing central executive bodies, law enforcement, parliament, and non-governmental organisations (NGOs). Like the Anti-Corruption Service, the Civil Service Agency also has 20 territorial directorates. Ethics Councils under the Agency are collegial bodies of the Agency, established in regions (oblast), cities of republican level, and the capital. Ethics Councils deal with the violations of the Code of Ethics among regular civil servants (categories C, D, E) and local-level Authorised Ethics Officers. They also develop corruption prevention measures as they review corruption risk assessments and the work of Authorised Ethics Officers, and disciplinary commissions (President of the Republic of Kazakhstan, 2015[20]). They also review recommendations of the Anti- Corruption Commission under the President.
The Civil Service Agency is responsible for issues concerning public officials and the implementation of the Code of Ethics. It is regulated through the Law on Civil Service (2015), the Law on the Ethical Code of Civil Servants, and the Decree on approval of the Regulations of the Agency of the Republic of Kazakhstan for Civil Service Affairs (2019). The integrity-related functions of the Agency include:
developing proposals to improve the legislation in the field of public service
ensuring meritocracy in the public service and enforcement for the code of ethics
reporting annually on the state of public service in the Republic of Kazakhstan to the Government for subsequent submission to the President of the Republic of Kazakhstan
co-ordinating the activities of state bodies on the issues of training, retraining and advanced training of public officials
exercising state control over compliance with the legislation of the Republic of Kazakhstan in the field of public service by state bodies, over compliance with official ethics by civil servants, over the quality of public services. This includes co-ordinating Authorised Ethics Officers
considering complaints of individuals and legal entities against (in-)actions and decisions of state bodies or officials on issues of violation of the legislation of the Republic of Kazakhstan in the field of public service, as well as compliance with official ethics
making proposals to officials and state bodies on the cancellation of their decisions taken in violation of the Law and other regulatory legal acts of the Republic of Kazakhstan
submitting to the state bodies, within their competence, mandatory submissions on the elimination of violations identified by the results of the audit on public service issues in accordance with the legislation of the Republic of Kazakhstan
assessing of the effectiveness of personnel management in state bodies
monitoring the state of the active list of political and administrative civil servants, as well as political and administrative public positions of the civil service
determine the competitive procedure for holding administrative public positions
assessing the quality of public services, except for digital public services
performing other functions provided for by this Law, other regulatory legal acts.
Source: Responses received from Kazakhstan to the OECD questionnaire.
A 2023 memorandum of understanding (MoU) between the Civil Service Agency and Anti-Corruption Service sets out the modalities of the interaction between the Authorised Ethics Officers that are co‑ordinated by the Civil Service Agency and the Anti-Corruption Service (Agency for Civil Service Affairs, 2023[21]). The Anti-Corruption Service also provides annual recommendations to the Civil Service Agency regarding corruption prevention in the civil service. The Civil Service Agency also has close co‑operation with the Academy of Public Administration (Қазақстан Республикасы Президентінің жанындағы Мемлекеттік басқару академиясы). The Academy is a higher educational institution that provides training, retraining and advanced training for civil servants, including mandatory training on anti‑corruption and integrity. Additionally, the Academy offers courses and programmes leading to officially recognised higher education degrees such as master’s degrees, doctorate degrees in several areas of study. (Further information on training provided by the Academy is set out in Chapter 3)
The Internal Audit Committee of the Ministry of Finance (Қазақстан Республикасы Қаржы министрлігінің Ішкі мемлекеттік аудит комитеті) performs internal audits for all public institutions and entities receiving budget funds. The Supreme Audit Chamber (Жоғарғы есеп палатасы, SAC) is the Supreme Audit Institution (SAI) in Kazakhstan, namely the highest body of state audit and financial control. It is directly accountable and subordinated to the President. The Supreme Audit Chamber is not only responsible for developing and approving procedural standards for external state audit and financial control, but also plays a role in assuring that the government budget is used effectively and that policy goals are achieved. While a Co-ordination Council exists between auditing bodies (Law on State Audit and Financial Control, Article 46), the 2022-2026 Policy Concept highlights that the overlap of state audit and financial control bodies is hampering the efficiency of the control system (Government of Kazakhstan, 2022[6]) (Chapter 5).
The Central Election Commission (Қазақстан Республикасының Орталық сайлау комиссиясы, CEC) and its 246 Territorial Election Commissions oversee the election process, including issues related to political finance. 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 lower house of parliament (Majilis) appoint two members each. Territorial Commissions are permanent bodies whose members are elected by the respective local representative bodies (maslikhat) based on proposals from political parties. In the absence of proposals from political parties within the time period established by the maslikhat, which must be no less than 15 days before the formation of electoral commissions, maslikhat elect the electoral commission members based on proposals from other public associations and higher electoral commissions. Among its oversight functions, the CEC is responsible for publishing campaign finance overviews twice a month in the campaign period, specifying the total amounts received and spent per party. The CEC does not conduct any audits, making campaign finance oversight very limited and ineffective. (See Chapter 6 for recommendations on enhancing competition, transparency, and integrity in election processes).
The role of detection and investigation of corruption offences is played by the Anti-Corruption Service, national security, internal affairs, military police, the Financial Monitoring Agency (Қазақстан Республикасы Қаржылық мониторинг агенттігі) (previously the Economic Investigation Service), and the Border Service of the National Security Committee (Қазақстан Республикасы Ұлттық қауіпсіздік комитетінің Шекара қызметі). The preliminary investigation of corruption crimes is carried out by investigators of the Anti-Corruption Service (Criminal Procedure Code, Article 187(3)). Meanwhile, other bodies can also conduct investigations on certain corruption crimes. According to Article 193 of the Criminal Procedure Code, in exceptional cases, to ensure objectivity and sufficiency of the investigation, the prosecutor has the right to transfer the case from one body to another or assume direct control over the investigation, regardless of the established jurisdiction (Government of Kazakhstan, 2014[22]).
The Prosecutor General’s Office (Қазақстан Республикасының Бас прокуратурасы) performs the oversight of law enforcement, represents the interests of the state in court, and conducts criminal prosecution on behalf of the state within the established legal limits and forms. The Prosecutor General’s Office is directly accountable to the President of the Republic of Kazakhstan and exercises its powers independently of other state bodies and officials. The Prosecutor General's Office is organised as a single centralised system with the subordination of the lower-level prosecutors to the higher, and ultimately to the Prosecutor General (GRECO, 2022[23]). The Prosecutor General's Office also includes a Committee on Legal Statistics and Special Accounts which keeps statistics on all areas of law enforcement, including statistical data on corruption offenses and the results of their investigation. The Academy of Law Enforcement Agencies under the Prosecutor General's Office, created by the Presidential Decree No. 15 of 4 May 2015, organises professional development for law enforcement personnel, including members of the Presidential reserve for leadership positions in Kazakhstan’s law enforcement agencies It also co‑ordinates and conducts interagency scientific research in the field of law enforcement activities.
The Co-ordinating Council of the Prosecutor General's Office (Бас прокуратураның үйлестіру кеңесі) co-ordinates the activities of law enforcement and other state bodies in the protection of human rights and freedoms, strengthening legality, law, and order, as well as combating crime. The Council formulates co-ordinated proposals and actions aimed at improving the effectiveness of law enforcement activities and enhancing its legal regulation. It determines the main directions for combating crime based on the analysis and discussion of the state of crime, its structure and dynamics, as well as forecasting trends in the development of crime and other offences. The Co-ordinating Council comprises the Prosecutor General, heads of law enforcement agencies, the Chairman of the Committee for National Security, and the Minister of Justice. The Committee for Asset Recovery (Қазақстан Республикасы Бас прокуратурасының Активтерді қайтару жөніндегі комитеті) was established in October 2023 by the Prosecutor General’s Office, following the decree of the President. The Committee is responsible for search and return of assets, development of international legal co-operation in this field, as well as identification and elimination of causes and conditions that contributed to illegal concentration of economic resources and illegal removal of assets, in accordance with the Law on Returning Illegally Acquired Assets to the State.
To engage various groups of society on state reforms, the National Qurultai has been created to ensure the “dialogue across the nation” (Antikor, 2023[24]). While its predecessor, the National Council of Public Trust, under the President of the Republic of Kazakhstan was an expert platform, the National Qurultai envisages broader societal engagement including representatives of regional Public Councils. Public Councils have been functioning since 2021 in government authorities and in quasi-public sector entities as a mechanism for ensuring public engagement in decision-making. Their composition was revised in 2022 to boost the participation of civil society. The local level Public Councils operate anti-corruption commissions and local executive authorities report to these commissions (Antikor, 2023[24]).
Regardless of where the responsibilities for anti-corruption and public integrity are assigned, governments should ensure that the actors have the appropriate level of authority to carry out the functions (OECD, 2020[16]). As presented above, Kazakhstan has an elaborate institutional framework, with some noteworthy peculiarities that merit attention.
First, in Kazakhstan, most institutions that take an active part in the integrity system are directly subordinate and accountable to the President. This includes the Anti-Corruption Service, the Civil Service Agency, the Supreme Audit Chamber, the Financial Monitoring Agency, the National Security Committee and the Prosecutor General’s Office (Government of Kazakhstan, 2008[25]). The President directly appoints or plays a decisive role in the appointment of the leadership of these bodies. The approval of the organisational structure and number of staff also pertain to the President’s exclusive competence. While this direct subordination and accountability may benefit these institutions’ ability to act and effect change, without the necessary checks and balances which limit the control exercised by the highest powers of the State, it may also make them vulnerable to political pressure. The Council of Europe’s Group of States Against Corruption (GRECO) has raised similar concerns, recommending a thorough institutional review, amongst other things, to provide adequate functional autonomy to the prosecution and law enforcement bodies in charge of combating corruption in Kazakhstan (GRECO, 2022[23]).
Second, Kazakhstan’s integrity system is evolving dynamically. Several functions, such as co-ordination among integrity actors across government and in the quasi-public sector, are still fairly recent and thus yet to be tested and further developed in practice. This includes the co-ordination of the Anti-Corruption Service with Compliance Officers in quasi-public sector entities as well as with Authorised Ethics Officers in public institutions.
Third, the role of the local level in the overall development strategy of Kazakhstan is increasing. The newly established anti-corruption commissions within local Public Councils face the challenge of ensuring consistent high standards and effectiveness, while accounting for regional differences in resources and culture.
Kazakhstan could develop clear, objective and transparent criteria and procedures for the selection, appointment and dismissal of the leadership of the Anti-Corruption Service
As a state body that is directly subordinate and accountable to the President, the Chair and three deputies (upon the Chair’s proposal) of the Anti-Corruption Service are directly appointed and dismissed by the President. Relevant legislation does not specify the selection procedure or provide for a competitive selection process, and the selection is not based on the assessment of the personal qualities of candidates (e.g. experience, skills, integrity) (OECD, 2024[26]). While there is a presidential reserve for heads of law enforcement bodies, clear and transparent procedures for establishing this list are equally lacking (GRECO, 2022[23]).
According to the Constitutional Law on the President of the Republic of Kazakhstan, the terms of the heads of state bodies directly subordinate and accountable to the President are terminated when the newly elected President takes office. As to the reasons for pre-term dismissal, these are established in the Law on Civil Service, the Law on the Law Enforcement Service and a 2023 Presidential Decree on Some Issues of Personnel Policy in the System of State Authorities, applying also to the Chair of the Anti-Corruption Service. However, the 2023 Presidential Decree is not publicly available, thus limiting transparency around the criteria for early dismissal. In addition, the Civil Service Law stipulates grounds such as "due to loss of confidence for non-performance or improper performance of his or her official duties," or “the emergence of other grounds provided for by the legislation of the Republic of Kazakhstan” which lack specificity and are thus open to interpretation. Finally, much like the selection and appointment procedure, the procedure for early dismissal is not regulated by law and there is no requirement for the publication of the results of such a procedure (OECD, 2024[26]).
Therefore, and even though its independence is stipulated in legislation, the Anti-Corruption Service would benefit from stronger functional and managerial autonomy. As part of establishing clear, objective and transparent criteria and processes for the selection, appointment and dismissal of the institution’s leadership, Kazakhstan could:
Establish a rigorous and transparent process for the selection and appointment of leadership positions, including, where possible, the involvement of persons outside of the Executive branch. The selection should be based on the assessment of the personal qualities of candidates according to clear and objective criteria, such as their relevant experience and skills and their integrity. The selection process should be subject to open competition and be transparent to the public, including reporting on the main steps in the recruitment. Ideally all of these requirements would be set out in law or other enforceable means.
Provide security of tenure for the leadership of such bodies. Criteria for the dismissal of the heads of these bodies or authorities should be adequately detailed in relevant legislation and be related to serious issues such as failure to implement the mandate of the organisation or issues relating to their appropriateness to perform the position. Criteria of dismissal must not be based on the pursuit of specific cases or political affiliations. The criteria and procedures for dismissal should be publicly available, including reporting on the outcome of main steps in any launched procedures.
Kazakhstan could strengthen the independence of the Supreme Audit Chamber in accordance with international standards for Supreme Audit Institutions
External oversight is an essential part of an integrity system, as it ensures that organisations and officials are accountable for their decisions, actions and expenditures. To be effective in proving external oversight, SAIs must be independent from the audited entity and protected from outside influence (OECD, 2020[16]). The International Organization of Supreme Audit Institutions (INTOSAI) has developed several principles and criteria for the independence of Supreme Audit Institutions (SAIs), laid out in the Lima and Mexico Declarations (Box 1.4).
Kazakhstan’s SAI, the Supreme Audit Chamber is a state body directly subordinate and accountable to the President. As such, its Chair is directly appointed and dismissed by the President, and thus the weaknesses identified regarding the criteria and procedure for the selection, appointment and dismissal of the leadership of the Anti-Corruption Service also apply to the Supreme Audit Chamber. In addition, the Presidential Administration has the authority to give instructions to the Supreme Audit Chamber. This is not aligned with INTOSAI’s principles for independence, including the need to ensure the independence of the Head of the SAI and its members, i.e. freedom from instructions, security of tenure (protection from arbitrary dismissal) and legal immunity in the normal discharge of their duties.
Thus, in addition to the recommendations set out in the previous section, Kazakhstan could undertake a review of the legal framework governing the work of the Supreme Audit Chamber, with a view to strengthening its independence in line with international standards, such as those developed by INTOSAI.
The Lima Declaration
The Lima Declaration, endorsed in 1977, sets out the principles of independence of public sector auditing in methodological and professional terms. The Declaration was the first INTOSAI document to comprehensively set out the importance of SAI independence, by reminding INTOSAI members and their stakeholders that SAIs can only be objective, credible and effective if they are independent from the audited entity and are protected from outside influence. The principles laid down in sections 5 to 7 of the Declaration can be summarised as follows:
Organisational independence is to ensure independence of SAI members (acting free from instructions; no possibility of arbitrary dismissal), and supreme authority of the Head of SAI in all staff-related matters, as well as non-interference on auditors by external sources.
Functional independence implies that the audit powers of the SAI are laid down in the Constitution, at least in general terms; the SAI is free to set up its own audit programme, and the SAI is free in drafting reports intended for publication.
Financial independence implies that SAIs can directly apply for the required funding to the body adopting the state budget (Parliament), as necessary, and SAIs can freely dispose of the appropriated budget during the financial year.
Following an increased recognition of the challenges faced by SAI, INTOSAI issued a second key document in 2007, known as the Mexico Declaration. The Mexico Declaration which is now known as INTOSAI- P10 expands on the principles set by the Lima Declaration and highlights eight conditions, known as the eight pillars of independence, which constitutes the benchmark against which the Independence of an SAI can be compared.
The Mexico Declaration and the Eight Pillars of SAI Independence
The Mexico Declaration of 2007 contains the eight principles of SAI Independence:
1. The existence of an appropriate and effective constitutional/statutory/legal framework and of de facto application provisions of this framework.
2. The independence of Head of SAIs and members (of collegial institutions), including security of tenure and legal immunity in the normal discharge of their duties.
3. A sufficiently broad mandate and full discretion, in the discharge of SAI functions.
4. Unrestricted access to information.
5. The right and obligation of SAIs to report on their work.
6. The freedom to decide the content and timing of audit reports, and to publish and disseminate them.
7. The existence of effective follow-up mechanisms on the SAI’s recommendations.
8. Financial and managerial/administrative autonomy, and the availability of appropriate human, material, and monetary resources.
Note: Further resources are available via the INTOSAI Development Initiative’s SAI Independence Resource Centre.
Sources: INTOSAI (2007[27]), Mexico Declaration on SAI Independence, https://sirc.idi.no/document-database/documents/intosai-publications/2-intosai-p-10-mexico-declaration-on-sai-independence; INTOSAI (1977[28]), The Lima Declaration, https://sirc.idi.no/document-database/documents/intosai-publications/1-intosai-p-1-the-lima-declaration.
The Anti-Corruption Service could enhance its co-ordination mechanisms for integrity through a working group at managerial level
Strong co-ordination is critical to strengthen public sector integrity in Kazakhstan, given the dynamic and expanding actions within the integrity system. During interviews with Kazakh officials, co-ordination emerged as one of the most significant challenges that must be addressed to strengthen integrity. Co‑ordination is an iterative process and can vary depending on the specific objective of the actors involved. Table 1.2 below illustrates possible forms of co-ordination and collaboration across a spectrum of low to high intensity (left to right across the table), including: i) establishing information sharing channels on relevant day-to-day activities and context analysis through direct communication channels; ii) developing co-ordinated and systematic action through an active partnership on and ad hoc or ongoing basis; and iii) taking integrated action and a joint decision-making process for achievement of common strategic objectives, and the allocation of the necessary resources. Higher levels of co-ordination require more institutional commitment on behalf of senior leadership.
Anti-corruption policies and actions in Kazakhstan are co-ordinated through a two-tier system: one at the highest political level and another at the working management level. At the highest political level, the Presidential Commission on Anti-Corruption ensures the development and adoption of co-ordinated measures aimed at strengthening the fight against corruption and violations of the Code of Ethics. The Commission is also a platform for reviewing the implementation of the 2022-2026 Anti-Corruption Policy Concept. This level of co-ordination ensures consistency of the Policy Concept with other strategic documents of the country, such as the Kazakhstan 2050 Strategy, the National Development Plan, the Public Administration Development Concept 2030 and others. In addition, the Commission can ensure the implementation of the Action Plan tasks in situations where the Anti-Corruption Service’s influence as a working level co-ordinator is limited. For example, since the beginning of the Policy Concept implementation, the Commission has met three times to review its implementation. Based on the results of these reviews, the Commission makes specific recommendations, and the Law Enforcement Division of the Presidential Administration oversees their implementation.
Note: The intensity of co-ordination can be viewed on a continuum of low to high from left (starting with “Communication”) to right (ending with “Integrated action and decision-making”).
Source: OECD adaptation of Strimling, A. (2006[29]), “Stepping out of the tracks: Cooperation between official diplomats and private facilitators”, International Negotiation, Vol. 11/1, pp. 91-127.
At the working level, the Anti-Corruption Service is authorised to formulate and implement anti-corruption policies and co-ordinate anti-corruption activities. Thus, much attention is paid to the co-ordination of state bodies and organisations in implementing the measures of the 2022-2026 Anti-Corruption Policy Concept and the Action Plan (see Chapter 2). To promote the implementation, monitoring and reporting on the Policy Concept and Action Plan, the Anti-Corruption Service has established a co-ordination and monitoring team of four employees (3 full-time and 1 part-time) to fulfil these tasks. This group monitors and coordinates the Policy Concept through project management instruments, coordinating both the Agency's projects and projects of other state bodies and organisations. The co-ordination and monitoring team oversees the activities at organisational level that contribute to the implementation of anti-corruption activities (4 out of 6 project streams mandatory for all public institutions). The anti-corruption stream for each organisational unit consists of four tasks: Internal corruption risk assessment, anti-corruption compliance, anti-corruption compliance in the quasi-public sector, and building an anti-corruption culture. There are several co-ordination tools in use, such as: i) providing methodological guidelines and evaluation methodology to the relevant agencies for each anti-corruption-related project; ii) weekly scrum3 meetings with each central and local executive body; iii) webinars on corruption prevention tools; iv) training and guidance for anti-corruption commissioners in local government administrations (akimats); v) quarterly meetings of the Anti-Corruption Service’s first deputy with central and local executive bodies; and vi) a series of meetings with the local executive bodies.
There are two limitations to the co-ordination function in the current institutional framework for integrity in Kazakhstan: First, although there are quarterly exchange meetings at the managerial level to share the information, the practice of working-level co-ordinated actions remains limited. Such working-level co‑ordination contributes to effective implementation of anti-corruption plans, boosts innovation and learning from previous mistakes in the development of a new strategic documents and plans. Second, de facto working engagement of non-governmental actors, such as civil society, business associations, academia could also be deepened (see also next section). Such engagement is critical to understand societal needs and ensure the buy-in of non-governmental actors in development and implementation of anti-corruption actions.
A good example of a working-level co-ordination is the 2023 Memorandum between the Anti-Corruption Service and the Agency for Civil Service specifying the interaction of Authorised Ethics Officers under the Civil Service Agency with Anti-Corruption Service regarding their anti-corruption activities (Agency for Civil Service Affairs, 2023[21]). The document foresees co-ordinated action and regular communication activities between the Anti-Corruption Service and the Agency for Civil Service. The Anti-Corruption Service annually submits propositions to the Agency regarding activities related to corruption prevention that the Agency includes them in the annual framework plan of Authorised Ethics Officers. This communication basis can be extended to more frequent working-level interactions, ultimately leading to integrated actions and decision-making related to Authorised Ethics Officers.
Kazakhstan could consider setting up a group as a co-ordination mechanism among relevant corruption prevention actors. Complementary to the high- level Anti-Corruption Commission, the working group would address the managerial level. In line with the high-level quarterly co-ordination, the working-level meetings could take place more often, thus ensuring the co-ordinated implementation of high-level decisions. The working group could consist of a set of permanent members from within the public administration and allow for the ad-hoc invitation of other stakeholders, including non-governmental actors, depending on the agenda of each meeting. This could benefit large co-ordination endeavours like those with Authorised Ethics Officers in public institutions or Compliance Officers in quasi-public sector entities, when engaging with major collegial actors in the quasi-public sector or support the development of sector-specific approaches. Additionally, when bodies such as the Committee on Asset Recovery are established, the working group could play an important role in fostering sustainable collaboration and integrating the Committee into the existing integrity system. Kazakhstan could consider experiences of OECD Members, especially with regards to working-level engagement of non-governmental actors (Box 1.5).
The Council of Anti-Corruption Co-ordinators in Slovakia
In the spring of 2023, Slovakia formally established the Council of Anti-Corruption Co-ordinators (CACC), which serves as the advisory body of the Head of the Government Office as the central authority for co-ordination in the field of corruption prevention. The CACC is primarily composed of Anti‑Corruption Co-ordinators, who are responsible for co-ordinating corruption prevention activities at the level of line ministries and other central authorities, of budgetary organisations and contributory organisations under the jurisdiction of ministries and other central authorities, of the General Prosecutor’s Office, the Judicial Council, the Supreme Audit Office and the Association of Towns and Municipalities. Representatives from the Office for the Protection of Whistleblowers, the private sector and civil society are invited on an ad-hoc basis to contribute to the discussions where relevant.
The Platform for Corruption Prevention in the Netherlands
The Platform for Corruption Prevention in the Netherlands provides an example of how various stakeholders, including CSOs, can be involved in implementing an anti-corruption strategy, as well as in helping design future strategies. Beyond public institutions, representatives from business and civil society were invited. These representatives were from private integrity and investigation services; the corporate risk and security management services of multinationals; the Association of Chambers of Commerce; the Association of Business Enterprises; Transparency International Netherlands; journalists; and academia. The meetings allowed participants to exchange expertise and experiences with anti-corruption developments in the Netherlands, and to share contributions to policy design and implementation, identification of corruption risks, research and training.
Sources: Office of the Government of the Slovak Republic (2023[30]), Statute of the Council of Anti-Corruption Coordinators; NCPA (2022[31]), National Anti-corruption Strategies and Plans: Compendium of Emerging Policies and Practices, https://rm.coe.int/0900001680aa34b5.
The Anti-Corruption Service could encourage co-creation and collaboration formats to involve civil society and the business sector in anti-corruption policymaking
The OECD Recommendation on Public Integrity emphasises the need to engage the private sector, civil society and individuals in the development, regular update and implementation of the public integrity system (OECD, 2017[12]). By actively engaging different stakeholders, diversity of perspectives and expertise is ensured, thus, fostering a more comprehensive and inclusive approach to enhancing public integrity. Inclusive involvement enhances the credibility and effectiveness of anti-corruption policy, ultimately contributing to a more transparent and accountable governance system. The 2023 EU Handbook of Good Practices in the Fight against Corruption identifies three key mechanisms of citizen engagement in anti-corruption that are set out in (Box 1.6).
The EU Handbook of good practices in the fight against corruption identifies three key mechanisms of citizen engagement in anti-corruption:
Mechanism 1: Citizen participation is the direct engagement of citizens in the political process in different capacities and at different stages of policy process. Direct participation can vary from mere consultation during decision-making to direct engagement in actual implementation of policies.
Mechanism 2: Civic monitoring refers to the watch-dog activities of civil society, including independent analysts, journalists, as well as the general public, with the aim to have oversight of the government’s decisions and actions. This mechanism is closely connected to the transparency and access to public information as a precondition for the society to effectively engage in monitoring. The techniques of monitoring include citizens report cards, community scorecards, social audit, citizen councils, etc.
Mechanism 3: Collaboration is about the co-creation of solutions for problems in the form of new institutions, processes, technologies, etc., based on the partnership approach between citizens and government. Collaboration is different from participation, as it requires significant power sharing and partnering, whereas with participation, the government maintains full decision-making powers.
Source: EC (2023[32]), Handbook of Good Practices in the Fight Against Corruption, https://doi.org/10.2837/575157.
Similarly, the OECD Guidelines for Citizen Participation Processes provide a helpful frame of reference to structure citizen engagement. The Guidelines distinguish between three levels of citizen and stakeholder engagement, which differ according to the level of involvement:
First, information, an initial level of participation characterised by a one-way relationship in which government produces and delivers information to citizens and stakeholders.
Second, consultation, a more advanced level of participation that entails a two-way relationship in which citizens and stakeholders provide feedback to government and vice-versa.
Third, engagement, when citizens and stakeholders are given the opportunity and necessary resources (information, data, and digital tools) to collaborate during all phases of the policy cycle and in the design and delivery of services (OECD, 2022[33]).
In Kazakhstan, there are several civil society actors working in the field of anti-corruption (U4, n.d.[34]). Transparency International (TI) Kazakhstan is an accredited national branch of Transparency International. TI Kazakhstan works mainly on asset recovery, implementation of Extractive Industries Transparency Initiative (EITI) in Kazakhstan, and advocates for national and local governments’ transparency. The Kun Jarygy Coalition engages in the public procurement monitoring community platform. Zertteu Research Institute conducts monitoring and evaluation as well sociological research including anti-corruption sphere. At the local level, Adilidik Zholy (“Justice Zholy” NGO) is an association working on anti-corruption, represented with 20 branches across all Kazakhstan regions. The NGO was established in 2020 to support the election programme of President Tokayev.
The main channel of citizen participation in anti-corruption in Kazakhstan are Public Councils. Established as an institution in 2021, Public Councils in public bodies and quasi-public sector entities aim to provide a communication channel between civil society and public authorities. Regular instruments of Public Councils are public hearings, monitoring, examinations as well as scrutiny of reports of state organisations on their activities. Public Councils’ recommendations are mandatory for governments’ consideration. As part of the Policy Concept’s implementation, the role of Public Councils has been strengthened. In particular, the rules for conducting external and internal analyses of corruption risks have been supplemented with provisions on the participation of members of Public Councils in conducting analyses, discussing their results and monitoring the implementation of recommendations to eliminate identified corruption risks. The Public Councils to the Anti-Corruption Service played a key role during public consultations on the 2022-2026 Anti-Corruption Policy Concept and Action Plan. Out of 23 proposals made by the members of the Public Council, 19 were included in the Policy Concept.
Consultation mechanisms should go beyond providing a channel of government communication but be used as an effective feedback mechanism to ensure that inputs from non-state actors are considered. A good example of how high levels of transparency and public participation can benefit from input of stakeholders is that of Latvia (Box 1.7), which established a minimum 2-week public consultation period. This is in line with the criteria established by the OECD Public Integrity Indicators, which require a minimum duration of two weeks for inter-institutional and public consultations, established by legislation.
Kazakhstan is piloting civic monitoring in the implementation process of anti-corruption policy. In August 2023, the project Anti-Corruption volunteering was launched to engage non-governmental actors and citizens in detecting and monitoring corruption risks (Antikor, 2023[35]). The project focuses on key areas such as public procurement, effectiveness of public expenditure, land use, regional development projects, and provision of public services, including education and healthcare. In addition, anti-corruption volunteers can participate in anti-corruption research and education, provide pro bono professional assistance, such as legal support to citizens, and engage in corporate volunteering. As the project is new, its impact is yet to be evaluated. In general, this is a promising approach that can contribute to grass-roots anti-corruption activism and increase bottom-up engagement over time.
Regulation 970 of 2009 foresees notifications regarding the participation process on the website of the Corruption Prevention and Combating Bureau (KNAB) no later than 14 days before submitting the planning document to the decision-making body (this means before start of inter-governmental consultation or before announcement at the State Secretaries meeting).
The public consultation procedure starts with the submission of a draft strategy to the State Secretary’s meetings, where it is announced and made public. Then, the inter-governmental consultation takes place (it is called “Harmonisation of Announced Drafts”). According to point 88 of the Rules of Procedure, there are two weeks for comments to be submitted. If there are objections, further meetings are organised, and inter-governmental consultation continues until there are no objections or until the strategy goes to the Cabinet of Ministers with some objections left.
Source: Republic of Latvia (2009[36]), Sabiedrības līdzdalības kārtība attīstības plānošanas procesā [Procedures for the Public Participation in the Development Planning Process], https://likumi.lv/ta/en/en/id/197033-procedures-for-the-public-participation-in-the-development-planning-process.
In turn, collaboration and co-creation practices could be streamlined in Kazakhstan’s integrity system. Such partnerships in anti-corruption allow to unleash societal innovations, increase legitimacy, and attract expertise. Under the leadership of the Anti-Corruption Agency, Kazakhstan could open up to societal feedback by engaging non-governmental stakeholders in the evaluation of the anti-corruption policy. Furthermore, given the progressive digitalisation of the public sphere, Kazakhstan could encourage citizens with IT skills to design digital tools based on open data provided by the government. Further recommendations are provided in Chapter 4.
The Anti-Corruption Service could strengthen co-ordination across all levels of government through capacity building and information sharing mechanisms for subnational actors
Territorially, Kazakhstan is divided into 17 regions (oblasts) and three cities with special status (the former capital, Almaty, and the current capital, Astana, and Shymkent), led by a government-appointed official who heads the local administration, akim. In addition, ministries and central agencies have regional offices (known as territorial divisions).
Kazakhstan could build on existing national and international good practices to ensure coherence of integrity policies at the regional and municipal levels. At the sub-national level, governments can rely on both formal mechanisms, to ensure coherent decision making and enable support, communication, and information sharing, as well as informal mechanisms, to enable horizontal exchange and support (OECD, 2020[16]). This section provides several ways in which Kazakhstan could improve co-ordination with and between regional stakeholders, through the development of effective communication tools and information sharing mechanisms.
Table 1.3 demonstrates the complexity of functions and the high number of actors involved in the integrity ecosystem of Kazakhstan, covering central, regional and municipal levels of government. Through its regional offices present in 20 territorial departments, the Anti-Corruption Service undertakes work on corruption prevention and has jurisdiction to pursue corruption investigations in the regions. Interviews with Kazakh officials indicate that there is an information exchange between the central and regional offices of the Anti-Corruption Service, that officers from regional offices rotate into the central office and that regular videoconferences and training events occur for the subnational levels. In addition, the regional commissions on anti-corruption issues are responsible for co-ordinating with local executive bodies.
Note: There are no internal audit services within the regional executive bodies.
Source: OECD questionnaire, information provided by the Anti-Corruption Service of Kazakhstan.
Kazakhstan could systematically re-evaluate how the ownership of local authorities over integrity instruments and anti-corruption measures could be strengthened. When it comes to corruption detection, the role of external actors is critical in ensuring effective control, monitoring, and implementation of anti-corruption measures that are not in the interest of local actors. With this regard, there was an important institutional innovation for anti-corruption efforts on the local level, namely the work of interdepartmental anti-corruption commissions. The secretariat used to be with the executive body of akims. According to the National Anti-Corruption Report 2023, this responsibility was “causing conflict of interest and hampered systemic work towards reducing corruption.” As a result, the Anti-Corruption Service took initiative to move the secretariat of the interdepartmental anti-corruption commissions to the territorial departments of the Anti-Corruption Service, which improved co-ordination capacities, the overall quality and implementation of commissions’ recommendations (Antikor, 2024[37]).
Local ownership in identifying corruption risks and designing responses boosts innovative solutions tailored to the context (Keudel, Grimes and Huss, n.d.[38]). One of the challenges in these processes is of the limited capacities of local governments or a lack of understanding of the importance of corruption prevention. Therefore, the Anti-Corruption Service could consider supporting ownership of akims especially with regards to corruption prevention measures through strengthening capacities and awareness of local actors.
Although Kazakh officials noted that several important integrity functions are decentralised, the division of responsibilities between the regional offices and the central office of the Anti-Corruption Service was unclear. An example of this lack of clarity is the oversight of political finance and audit functions at the subnational level. More specifically, how the institutional framework for election oversight functions, involving the Central Election Commission and the 246 Territorial Election Commissions. Furthermore, while the regional Commissions are mandated to co-ordinate activities of state bodies with local executive bodies to enhance anti-corruption efforts, their implementation methods remain unclear.
Finally, to identify implementation gaps and foster coherent implementation across regions, the Anti‑Corruption Service could facilitate co-operation mechanisms. This could include regular meetings of a formal or informal integrity committee or commission to promote exchange of information and support coherence among integrity standards, as is done in Canada and Belgium (Box 1.8), the development of shared reporting requirements for the regions, or a common portal to ensure transparency of regional integrity efforts and enable positive competition to address implementation gaps.
The following examples from Belgium and Canada provide an overview of how federal governments support formal and informal co-operation between it and regional governments.
Belgium – Consultation Committee
In Belgium, a Consultation Committee was established in the Chancellery of the Prime Minister to discuss good governance issues requiring co-operation across different levels of government. The committee, which meets once a month, consists of the ministers from the federal government and the ministers from the governments of the communities and regions. The secretariat of the Consultation Committee is responsible for the administrative and logistical tasks of the committee, such as preparing and sending meeting agendas, organising meetings, and distributing the results of the decisions made. It also oversees the monitoring process for co-operation agreements among the different entities and publishes co-operation agreements involving the federal government.
Canada – Canadian Conflict of Interest Network
The Canadian Conflict of Interest Network (CCOIN) was established in 1992 to formalise and strengthen contact across the different areas of government regarding the conflict-of-interest policy. The commissioners from each of the ten provinces and three territories, along with two from the federal government representing the members of parliament and the senate, meet annually to disseminate policies and related materials, exchange best practices, and discuss ideas on ethics issues and the viability of policies.
Sources: Belgian Chancellery of the Prime Minister (2019[39]), Directorate-General for Secretariats and Coordination, https://chancellerie.belgium.be/en/organisation/directorate-general-secretariats-and-coordination; Parliament of Canada (2019[40]), Canadian Conflict of Interest Network, Office of the Conflict of Interest and Ethics Commissioner.
In addition, considering the government structure and the geographical size of the country, Kazakhstan could establish a public integrity network to enhance information-sharing between subnational integrity actors. Box 1.9 outlines similar arrangements in Colombia and Peru, which could serve as an inspiration for a context-specific solution in Kazakhstan. Another way to enhance co-ordination at the regional and municipal level would be supporting transfers of personnel and knowledge from the centre to the regions and vice-versa to improve information sharing on integrity issues. This good practice already exists in the Anti-Corruption Service where regional officers rotate to the central office but could be expanded to other integrity actors with regional presence, such as the Civil Service Agency, and the Central Election Commission. As a result, through these mechanisms, Kazakhstan could promote an effective implementation of the anti-corruption and integrity system across the regions and municipalities of Kazakhstan, creating synergies between the existing integrity actors.
Anti-Corruption Commissions at county level in Croatia
In Croatia, county assemblies have established Anti-Corruption Commissions that aim to strengthen the transparency, responsibility, and integrity of local and regional self-governments. Amongst other things, these commissions are tasked with the development of anti-corruption action plans in line with the Strategy for the Prevention of Corruption for 2021-2030, as well as codes of conduct for officials at the regional level. Even though the establishment of an Anti-Corruption Commission is not prescribed by law, it is a practice that is increasingly widespread in Croatia, with 17 out of 21 county assemblies having had a commission in place in 2024. While there is no dedicated mechanism for co-ordination between central and subnational levels of government, the positions of subnational self-government units are represented in the Council for the Prevention of Corruption at central government level by the main associations of cities, counties, and municipalities.
The Regional Moralisation Commissions in Colombia
Each department in Colombia has set up a Regional Moralisation Commission (Comisiones Regionales de Moralización, or CRM), which is responsible for supporting implementation of the National Anti-Corruption Policy as well as for sharing information and co-ordinating local initiatives among institutions responsible for prevention, investigation, preventing, investigating, and sanctioning corruption. CRMs are composed of regional representatives of the Attorney General’s Office, the Colombian Treasury Inspector’s Office, the Sectional Council of the Judiciary and the Office of the Departmental, Municipal and District Treasury Inspectors. Other entities can be called on to be a part of the Regional Moralisation Commission, if considered necessary. To promote citizen participation and social control over CRMs, at least one quarterly meeting must be held with CSOs to address and deal with their requests, concerns, complaints, and claims. Consistency among departments is favoured by a set of guidelines elaborated by the National Moralisation Commission (Comisión Nacional de Moralización, or CNM), which are complemented by model documents the CRMs may use to carry out their Action Plans.
Sources: Author’s elaboration based on information provided by the Government of Croatia; Government of Colombia (2011[41]), Colombian Law 1474 of 2011, http://www.anticorrupcion.gov.co/SiteAssets/Paginas/lineamientosCRM/Cartilla_CRM.pdf.
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← 1. The term “quasi-state sector” typically refers to organisations or entities that have some characteristics of both public and private sectors. These entities are not fully government-owned or government-controlled, but they often operate in sectors that are traditionally associated with public services or have a significant impact on the public interest (Government of Kazakhstan, 2008[42]). According to the now repealed Budget Code, the quasi-state sector comprises state enterprises, limited liability companies, joint stock companies, as well as national management holdings, national holdings or national companies – the founder, participant or shareholder of which is the state – as well as subsidiaries, dependent and other legal entities affiliated with them in accordance with the legislative acts of Kazakhstan (OECD, 2024[43]). The government and holding companies manage the state property on behalf of Kazakhstan, and local executive bodies manage the communal property on behalf of their administrative-territorial units.
← 2. In Kazakhstan, laws passed at the national level are applicable at the regional and local levels. The powers of the heads of municipalities (akims) and regions (oblasts), major cities and the capital are set out in the Law on Local Government and Self-Government in the Republic of Kazakhstan (2001).
← 3. Scrum is a management framework that teams use to self-organise and work towards a common goal. It describes a set of meetings, tools, and roles for efficient project delivery.