Responsible Business Conduct for Sustainable Infrastructure in Kazakhstan, Mongolia and Uzbekistan

2. Kazakhstan

Abstract

This chapter analyses how Kazakhstan is encouraging responsible business conduct (RBC) for sustainable infrastructure. It considers the country’s legal and policy framework in a range of policy areas as well as the state’s economic role and commercial activities. It highlights progress and challenges and identifies opportunities for how Kazakhstan can strengthen the integration of RBC in infrastructure development and operations.

2.1. Overview of infrastructure development in Kazakhstan

Kazakhstan is the largest economy in Central Asia in both absolute and per capita terms. Kazakhstan's growth performance since 2000 has averaged nearly 8% per annum in real terms (Government of Kazakhstan, 2024[1]). Openness to trade and investment, particularly in the extractive sector, has played a major role in supporting the country’s economic development, becoming an upper-middle-income country with a gross national income (GNI) per capita of USD 9 672 in 2022 (constant 2015 USD) and reaching a status of “Very High” in the Human Development Index (OECD, 2023[2]; UNDP, 2024[3]; World Bank, 2024[4]). However, Kazakhstan’s socio-economic resilience is challenged by the need to economically diversify and attract quality investments in industrial and infrastructure projects (OECD, 2023[2]; Government of Kazakhstan, 2024[5]; Government of Kazakhstan, 2025[6]).

Kazakhstan’s national strategies and sectoral plans prioritise infrastructure development. The government has set out a number of key plans to aid strategic infrastructure planning (OECD, 2019[7]). Strategy 2050 is the government’s overarching long-term vision to achieve growth and integrate the economy into the global environment, including by developing infrastructure, modernising industry, and attracting foreign investments (2050 Strategy, 2014[8]). The 2024-2029 National Infrastructure Plan aims to create a sustainable infrastructure framework for energy, transport, water supply, and sanitation projects (Government of Kazakhstan, 2024[9]). These plans require Kazakhstan to attract private sector investments to achieve its development goals. The 2024-29 Strategic Development Plan emphasises decarbonisation, renewable energy, sustainable waste management, and biodiversity, including through best available techniques and strengthening Kazakhstan’s emissions trading scheme (Government of Kazakhstan, 2024[1]). The Strategy to Achieve Carbon Neutrality by 2060 sets Kazakhstan’s climate and environmental objectives (Government of Kazakhstan, 2023[10]). Achieving this goal will require an estimated total investment of USD 610 billion, with USD 386.3 billion from redirecting existing investments from traditional industries to greener ones and USD 223.7 billion from new sources (UN, 2023[11]).

Despite Kazakhstan’s efforts, the state of transport infrastructure remains challenging (OECD, 2024[12]). Kazakhstan country ranked 80^th in the 2023 Logistics Performance Index in terms of infrastructure (World Bank, 2023[13]). Some 41% of the population live in rural settlements that are remote from industrial centres and have poorly developed infrastructure (Government of Kazakhstan, 2020[14]). Road density is low due to Kazakhstan’s geographic size, with 3.6 km per 100 km² in 2018, compared to the average road density in the Central Asian region of 28 km per 100 km² (ADB, 2021[15]). Kazakhstan’s transport sector accounted for 10% of fuel combustion greenhouse gas (GHG) emissions in 2020, nearly all from the road sector (IEA, 2023[16]). Infrastructure congestion, and wear and tear remain critical issues. In 2024, the wear rate of the main railway network reached 57%, while 93% of national and 89% of local roads met regulatory requirements (Government of Kazakhstan, 2025[17]).

Kazakhstan is taking measures to address substantial climate-related challenges in its important energy sector. Oil, gas, and coal rents constituted 17.6% of gross domestic product (GDP) in 2020; Kazakhstan attracted over USD 70 billion in foreign direct investment (FDI) from 2012 to 2022 – the largest amount in Central Asia (IEA, 2022[18]). In 2022, coal-fired generation accounted for 62.1% of Kazakhstan’s electricity mix, followed by natural gas (24.9%), hydroelectric power plants (8.1%), other renewables (3.7%), and oil (1.2%) (IEA, 2023[19]). Continued reliance on energy-intensive extractives for exports and public revenues, and an outdated heating supply system dependent on coal make Kazakhstan one of the largest emitters of GHG per capita globally, presenting a major challenge for Kazakhstan’s net-zero ambitions (IEA, 2022[18]; ADB, 2024[20]; Government of Kazakhstan, 2023[21]; Agora Energiewende, 2024[22]) For instance, Kazakhstan’s coal-based activities account for 55% of national emissions – in part due to its aging fleet. Coal is responsible for 60% of electricity generation and 99% of heat generation (IMF, 2025[23]). Kazakhstan is taking measures to address these issues, including by developing its renewable energy sources (RES), hydrogen, and – following a referendum in 2024 – nuclear sectors for electricity generation. It aims to increase the share of RES to 24.4%, hydropower 10.8%, and nuclear energy to 4.7% by 2035, while reducing the shares of coal and gas to 34.3% and 25.8%, respectively (Government of Kazakhstan, 2025[17]; Government of Kazakhstan, 2024[24]). It further aims to co-operate with investors, the private sector, and expert organisations to adopt best practices, acquire innovative technologies, and attract financial sources to reduce GHG emissions (Government of Kazakhstan, 2025[17]; Government of Kazakhstan, 2024[25]).

Industry and mining are major drivers of both Kazakhstan’s economic growth and its greenhouse gas emissions. The industrial sector’s value-added accounted for 35.3% of GDP in 2021 compared to the OECD average of 22.3%. Industrial production is also a significant source of direct and indirect GHG emissions, the latter as the largest consumer of final energy in the country (31.1%). Industrial production contributes 21.6% of all GHG emissions in Kazakhstan’s economy of which 70.4% originates in the metallurgical sector alone (OECD, 2024[26]). Achieving the government’s GHG reduction targets will require a transformation of industrial processes and technologies (OECD, 2024[26]). Mining represented 17% of GDP and 16% of exports in 2021, providing employment for 273 000 people or 3.1% of the employed population (Government of Kazakhstan, 2023[27]). The President announced that Kazakhstan seeks to attract international investments to expand production in critical raw materials for the green transition (Government of Kazakhstan, 2025[28]). However, depleting mineral reserves (particularly in copper, chromium, and iron), few investments, outdated technology, and low operational efficiency threaten Kazakhstan’s competitiveness (World Bank, 2023[29]; MINEX Kazakhstan, 2024[30]).

2.2. Opportunities for promoting RBC in infrastructure development in Kazakhstan

2.2.1. Consolidating legal and policy frameworks relevant for RBC and applicable to infrastructure development

RBC principles and standards set out that all businesses – regardless of their legal status, size, ownership structure or sector – address adverse impacts of their operations on people, planet and society, and contribute to sustainable development where they operate, including throughout their investments and supply chains. Due to their size and nature, infrastructure development and operations can affect the human rights of local communities such as their land rights and livelihoods. They can impact the rights of workers, notably their health and safety, and create significant harm to the environment and contribute to climate change. The large financial amounts involved can also give rise to corruption. As governments seek greater levels of private sector involvement in financing, delivering, operating, maintaining, and decommissioning infrastructure, promoting and enabling a positive business contribution while minimising adverse impacts on people, planet, society is critical (see section 1).

Overarching policies and initiatives relevant for RBC

Kazakhstan is taking steps to create an enabling environment for RBC. It is the only country in Central Asia to adhere to the OECD Declaration on International Investment and Multinational Enterprises (OECD, 2023[31]) and the OECD Guidelines for Multinational Enterprises on RBC (MNE Guidelines) annexed to the Declaration. In 2017, it set up a National Contact Point for Responsible Business Conduct (NCP) (see Box 2.1). It has also adhered to the Recommendations on Due Diligence Guidance in the minerals sector (OECD, 2012[32]) and stakeholder engagement in the extractive sector (OECD, 2016[33]) in 2017 and the Recommendation on the Due Diligence Guidance for RBC in 2018, which support companies in carrying out due diligence in key infrastructure sectors (OECD, 2018[34]). Moreover, Kazakhstan adhered to the 2023 OECD Recommendation on the Role of Government in Promoting Responsible Business Conduct (OECD, 2022[35]), recognising that government should support the effective implementation of RBC principles and standards. Kazakhstan committed in October 2024 to developing a declaration on RBC that sets out expectations for investors to work responsibly and make a positive contribution to sustainable development (Government of Kazakhstan, 2024[36]). Though the 2029 Investment Policy Concept does not specify what this declaration will entail, the NCP would be well placed to contribute to its development as the lead government institution on RBC.

Kazakhstan started developing a National Action Plan on Business and Human Rights (NAP BHR) in 2022. With the support of the United Nations Development Programme (UNDP), Kazakhstan conducted a National BHR Baseline Assessment in 2023 that assessed the level of implementation of the UN Guiding Principles on BHR to formulate and prioritise actions within the NAP BHR. The assessment found a “low level of compliance with the goals and principles of the UN Guiding Principles” and that a very limited number of companies follow an approach based on human rights policies, due diligence, or appropriate stakeholder engagement (UNDP, 2024[37]). The government’s National Human Rights Action Plan includes an objective to adopt a NAP BHR (UNDP, 2024[37]; Government of Kazakhstan, 2023[38]). A working party was created to follow up on the baseline assessment and develop the action plan, with the NCP as its secretariat (ERI, 2023[39]; UNDP, 2023[40]).

Box 2.1. The role of Kazakhstan’s National Contact Point for Responsible Business Conduct

Kazakhstan has committed to setting up a National Contact Point for Responsible Business Conduct (NCP) that operates in a manner that is visible, accessible, transparent, accountable, impartial and equitable, predictable, and compatible with the OECD Guidelines for Multinational Enterprises on RBC. The NCP fulfils its obligations by i) promoting RBC with business and other stakeholders, ii) acting as non-judicial grievance mechanisms in cases of alleged non-observance of the Guidelines by companies, and, iii) where applicable, providing support for government efforts to promote RBC-related policies.

Kazakhstan’s NCP is hosted by the Economic Research Institute under the Ministry of National Economy. The NCP has a multipartite structure, including representation from government, business, and civil society. Representatives from trade unions are called upon on a case-by-case basis. The NCP has been increasingly active since 2020. It has published the OECD Guidelines and Due Diligence Guidance on its website and has (co-)organised promotional events on RBC. It has received seven specific instances regarding alleged non-observance of the Guidelines (all in 2021-2023). Of these:

• five were not accepted for further examination

• one was concluded without agreement as the company did not agree to participate in the NCP process

• one resulted in agreement between the parties.

The NCP is also playing a growing role in policy coherence on RBC in Kazakhstan. The NCP is now the secretariat of the National Action Plan for Business and Human Rights (NAP BHR) working group. The NCP chaired the first meeting in October 2024 and plans to hold bi-monthly meetings until February 2025 to draft a recommendation based on the national baseline assessment.

Source: ERI (2024[41]), NCP Events (События НКЦ), https://eri.kz/ru/Nacionalnyj_kontaktnyj_centr/Sobytija_NKC.

OECD (2024[42]), OECD SIPA visit to Astana.

For companies, there is a greater awareness of the importance of sustainability. 13 out of 27 respondents to a 2023 OECD survey indicated they had used technologies to reduce their emissions, while 12 were using technologies to improve their energy efficiency. Seven respondents noted that they had begun to monitor their carbon footprint, which is a stipulation of the 2021 Environmental Code (OECD, 2023[2]) Additionally, the presence of multinational enterprises (MNEs) and the European Union’s (EU’s) Carbon Border Adjustment Mechanism have intensified expectations of the business community to be aware of and consider ESG and sustainability measures (OECD, 2024[42]). For example, the European Business Association of Kazakhstan, EUROBAK, has an ESG committee that addresses ESG in public procurement, waste management and regulation, and incentives for businesses to implement ESG (EUROBAK, 2024[43]). The United Nations Global Compact (UNGC) aims for businesses to deliver on the SDGs; UNGC’s network in Kazakhstan has grown significantly from eight members in 2021 to 88 members in 2024 (UNGC, 2024[44]).

International partnerships on raw materials have also raised awareness of RBC. Kazakhstan joined the Minerals Security Partnership to help launch a forum to accelerate implementing sustainable critical raw minerals projects, boost sustainable local production, and promote high ESG standards in supply chains (EU, 2024[45]). Kazakhstan also concluded a bilateral strategic partnership with the EU on raw materials, batteries and hydrogen (European Commission, 2022[46]).

Human rights

Promoting policy coherence could help address human rights challenges in infrastructure projects. It is estimated that it takes four to five to acquire land for infrastructure projects due to complex legal frameworks and conflicts with communities (CABAR, 2021[47]; OECD, 2024[42]). For example, because calculating compensation and damages caused by mining projects is not standardised, issues with resettlement in the mining sector often raise concerns about appropriate redress offered to affected communities (World Bank, 2023[29]). Additionally, including social issues in the impact assessments of planned explorations, project developments or resource production – particularly relevant in the mining and energy sectors where fatal workplace accidents and significant adverse impacts are common – improves the understanding of impacts in the surrounding communities (World Bank, 2023[29]).

Promoting meaningful stakeholder engagement has significant benefits. Kazakhstan adheres to the OECD Due Diligence Guidance for Meaningful Stakeholder Engagement in the Extractive Sector (OECD, 2016[33]). There is a strong business case for meaningful stakeholder engagement, including to preserve social license to operate (OECD, 2017[48]). A relevant aspect in this regard is engagement on the sharing of benefits with local communities. Kazakhstan’s Subsoil Use Code provides for financing social development of the region and its infrastructure with at least 1% of investments (Government of Kazakhstan, 2017[49]). However, this process lacks transparency. Establishing clear mechanisms for benefit-sharing in agreement with local stakeholders would enhance the management of the extractive sector’s impacts on communities (World Bank, 2023[29]).

Few companies have dedicated efforts to address their potential human rights impacts. Companies rarely share human rights commitments publicly and, if they do, they do not refer to international instruments. Human rights policies are generally segmented rather than a standalone strategy. Firms do not communicate responsibilities and resources for day-to-day human rights activities. Even larger firms lack employees with independent responsibility for human rights issues and very few firms conduct human rights-based due diligence (UNDP, 2024[37]). Additionally, OECD interviews indicate that firms, particularly small and medium-sized enterprises (SMEs), regularly perceive “business and human rights” to be about entrepreneurial rights rather than impacts on people. This showcases the usefulness of further awareness-raising initiatives on RBC (OECD, 2024[42]).

Labour rights

Revisions to Kazakhstan’s labour code have enhanced the framework for labour rights though gaps remain. The 2011 Constitution of the Republic of Kazakhstan and the Labour Code cover fundamental human rights, including safe work and labour disputes. Key legislation includes measures on occupational safety and health (OSH), child and forced labour, and collective bargaining (OECD, 2024[42]; ILO, 2024[50]). However, the Trade Union Law (2014) and Labour Code (2015) do not fully guarantee collective bargaining and the right to strike, reducing worker representation in construction and energy sectors (ILO, 2024[50]). National legislation insufficiently covers minimum wages and wage protection for migrant workers – common in construction – and those working in the informal economy (ILO, 2025[51]). Stakeholders indicate a need for stronger social partnership and a culture of dialogue, and while trade union functioning is improving, the registration of independent trade unions, including in energy, remains especially challenging (OECD, 2024[42]; ILO, 2024[50]). Amendments in 2020 addressed some of these concerns and the Ministry of Labour and Social Protection is considering further reforms to strengthen the alignment with international standards. (ILO, 2022[52]; Rittmann, 2021[53]; IndustriALL Global Union, 2021[54]). Kazakhstan does not have specific legislation to prevent and address sexual harassment in the workplace and has not adhered to International Labour Organization (ILO) Convention No. 190 on the Elimination of Violence and Harassment at Work (Government of Kazakhstan, 2023[55]). However, the government is currently establishing a Unified Training and Methodological Centre to standardise education on workplace safety and gender sensitivity.

Challenges remain in effectively enforcing the labour code. These reportedly include wage payments, discrimination in employment, harassment, safe work, forced labour – especially in agriculture, construction, and road repair – and migrant labour in the construction industry (US Department of Labor, 2024[56]; UNDP, 2024[37]). In particular, discrepancies in wages and OSH standards between domestic and foreign energy companies have led to strikes in Western Kazakhstan (Kumenov, 2024[57]). Moreover, employees working in non-mining companies associated with the extractives sector face relatively low wages, and this has further contributed to social unrest (OECD, 2024[42]). From 2021 to 2022, the number of appeals on labour right violations grew nearly six-fold, from 53 to 288, mainly concerning allegations of unfair dismissals, wage arrears, management actions and abuse of power (UNDP, 2024[58]).

The government is stepping up efforts to improve working conditions and OSH in infrastructure. Since 2019, Kazakhstan has been promoting the concept of “Zero Injuries” – Vision Zero – with over 580 enterprises having joined (OHCHR, 2022[63]; ILO, 2024[50]). Kazakhstan adopted the 2024-2030 Concept of Safe Labour to improve working conditions and reduce work-related accidents, most of which occur in large and medium-sized enterprises in the mining and construction sectors (see Box 2.2). The 2023 draft Construction Code emphasises improving health and safety issues and includes wording on mitigating adverse impacts on human and environmental considerations (Government of Kazakhstan, 2023[64]). There are opportunities to further strengthen RBC-related considerations in the draft, for instance, through safety standards and best available techniques.

Labour inspections require strengthening. Though the ILO welcomed Kazakhstan’s centralisation of inspections under the Ministry of Labour and Social Protection and its lifting of a moratorium on inspections for smaller enterprises in 2024 (ILO, 2024[50]), challenges remain. Labour inspections still require prior approval from the prosecutor’s office, which reduces their effectiveness. With 0.24 labour inspectors per 10 000 workers, Kazakhstan is below the average of 0.41 of its upper-middle-income peers, and this figure is declining (UNDP, 2024[37]; ILO, 2024[50]; Government of Kazakhstan, 2024[65]; ILO, 2024[66]). Unions have expressed concerns that investigations into OSH violations in the energy sector do not lead to consequences for alleged infringements (ILO, 2024[50]).

Digitalisation aims to improve the monitoring of labour standards. Launched in 2024, the Digital Map of Enterprises enables real-time tracking of risks in OSH and working conditions, implementation of preventive measures, and the social well-being of employees (Government of Kazakhstan, 2025[67]). Since 2021, Kazakhstan has automated the risk management system for inspections to ensure minimal human participation in inspection scheduling. Violations found through inspections are now registered in an online database; Kazakhstan also monitors repeat offenders (OHCHR, 2022[63]). Over 13 000 employers have conducted a self-audit of labour legislation and OSH compliance and received recommendations on the online portal hr.enbek.kz (OHCHR, 2022[63]; ILO, 2024[50]).

Box 2.2. Examples of occupational safety and health (OSH) issues in Kazakhstan

According to the Prime Minister, Kazakhstan has seen a 25.2% increase in occupational injuries from 2021 to 2023 largely due to inadequate standards, physically demanding work, outdated equipment, and lack of personal protective equipment. In 2022, deficiencies in safety training accounted for 20% of workplace accidents, highlighting the need for better training programmes and stricter oversight of training centres. Only 54% of employees are insured against workplace accidents and only 32% of firms have insured employees. Moreover, the government indicated that the current insurance model insufficiently motivates employers to improve conditions. Hazardous work appears to be frequent in mining and construction sectors. In 2023, the local operations of a multinational steel and mining company experienced the deadliest accident in Kazakhstan’s post-Soviet period, with 46 fatalities.

In response to these challenges, the President declared 2025 the Year of Vocational Professions with a focus on workers in energy, construction, and water management. Kazakhstan has introduced the 2024-2030 Concept on Safe Work, a programme that aims to address OSH issues and specifically calls to reduce accidents at hazardous industrial facilities. The Concept focuses on four key areas: modernising the national OSH system, economic incentives for safer workplaces, professional training, and improved control and monitoring. The new Concept is expected to introduce a proactive model to determine insurance benefits based on the likelihood and severity of workplace risks. The government aims to improve its data collection and reporting system, and make it more attractive for employers to provide insurance. Reaction to these efforts by union representatives was generally positive, while expectations to see concrete results (e.g. fewer accidents and deaths) have remained high.

Source: (Government of Kazakhstan, 2023[55]), Positive effect for all parties of social partnership expected as outcome of Safe Labor Concept implementation, https://primeminister.kz/en/news/positive-effect-for-all-parties-of-social-partnership-expected-as-outcome-of-safe-labor-concept-implementation-ministry-of-labor-and-social-protectionnbsp-26807.

(ILO, 2024[50]), Committee on the Application of Standards, https://www.ilo.org/resource/other/can-2024-discussion-individual-case-kazakhstan-c81129.

(Le Monde, 2023[59]), Kazakhstan buys ArcelorMittal subsidiary after mining accidents, https://www.lemonde.fr/en/international/article/2023/12/08/kazakhstan-buys-arcelormittal-subsidiary-after-mining-accidents_6323743_4.html#.

(Astana Times, 2024[60]), Tokayev Reiterates Need for Industry Experts, Future-Oriented Professions, https://astanatimes.com/2024/09/tokayev-reiterates-need-for-industry-experts-future-oriented-professions/.

(Business & Human Rights Resource Centre, 2022[61]), Kazakhstan: Inspections at Vostoktsvetmet & Kazzinc reveal over 1200 labour & industrial safety violation, https://www.business-humanrights.org/en/latest-news/kazakhstan-inspections-at-vostoktsvetmet-kazzinc-reveal-1200-labour-industrial-safety-violations/.

(Government of Kazakhstan, 2023[62]), Safe Labor Concept until 2030 adopted in Kazakhstan, https://primeminister.kz/en/news/safe-labor-concept-until-2030-adopted-in-kazakhstan-26801.

Environment

Kazakhstan has introduced climate targets. The Strategy for Achieving Carbon Neutrality by 2060 has established a clear net-zero target and was communicated to the United Nations Framework Convention on Climate Change (UNFCCC) (Government of Kazakhstan, 2023[10]). Kazakhstan revised its Nationally Determined Contribution (NDC) in 2023 (with a new NDC underway for 2025), reaffirming its commitment to reduce its GHG emissions by 15% by 2030 relative to 1990, and by 25% subject to international financial and technical support (Government of Kazakhstan, 2023[10]). The 2021-2030 Action Plan aims to implement the 2050 Green Economy Concept and to facilitate Kazakhstan’s NDC and Goals under the Paris Agreement. In 2024, Kazakhstan, UNDP, and the Green Climate Fund jointly launched the National Adaptation Plan to integrate climate adaptation issues into Kazakhstan’s strategic planning (UNDP, 2024[68]).

Strategies support progress towards climate goals, including through environmental considerations and renewable energy sources (RES). Updated in 2024, the 2013 Concept for the Transition towards a Green Economy until 2050 sets clear guidelines and targets to achieve Kazakhstan’s green development path, including for renewables to constitute 50% of the energy mix (from less than 2% in 2020 and 6% in 2023 (Government of Kazakhstan, 2024[69])). The 2024-2029 National Infrastructure Plan focuses on heating and electricity, seeking for RES to generate 12.5% of power through large RES projects with international partners. The 2024-2029 National Development Plan further contributes to the carbon neutrality transition and aims to improve air quality, ensure rational use of water resources, conserve biodiversity, and increase waste recycling (Government of Kazakhstan, 2024[1]) Additionally, Kazakhstan is a Party to the United Nations Economic Commission for Europe (UNECE) Convention on Environmental Impact Assessment (EIA) in a Transboundary Context. This convention requires Kazakhstan to consult with neighbouring countries on major projects that could cause significant adverse environmental impacts across their shared borders (UNECE, 2019[70]). OECD interviews indicate that sustainable road management will also be part of the Trans-Caspian International Transport Route, a multimodal corridor for trade, transport and transit connecting East Asia and Europe through Central Asia.

The 2021 Environmental Code has improved standards and approaches for managing adverse impacts on the environment, including through best available techniques (BAT). The Code introduced the “polluter pays” principle, enacted reforms, and brought the regulatory framework for environmental management closer to OECD standards for addressing environmental issues (WECOOP, 2021[71]; Government of Kazakhstan, 2021[72]; OECD, 2023[2]; IMF, 2025[23]). It requires business activities with environmental impact to undergo a comprehensive Environmental Impact Assessment (EIA) overseen by the Ministry of Ecology, Geology, and Natural Resources. This process mandates 30-day public consultations, which are published in the “Unified Environmental Portal” (www.ecogosfond.kz), though interviews indicate that the practical application of this requirement has been mixed. Enterprises need to provide pollutant data that is also posted on this portal (OHCHR, 2022[63]). The Code has introduced BAT to address adverse impacts (see Box 2.3Box 2.3). It also allows for imposing high fines for breaches of environmental standards, yet they appear to be applied infrequently and unevenly. In interviews with the OECD, the government has indicated that it intends to engage with businesses about violations.

Efforts are underway to address issues in the heating supply. This relies on coal for 99% of its generation (IMF, 2025[23]). Heating tariffs were historically kept low and usage is not measured for social reasons. This has resulted in fees failing to cover costs and maintenance, and heating companies unable to generate the necessary capital to upgrade or modernise their assets to be more efficient and cleaner (ADB, 2024[20]). The 2024 Law on Heating Supply aims to sustainably develop Kazakhstan’s heat energy sector and attract investments through a comprehensive planning system, mainstreaming sustainability requirements, and introducing requirements for minimal environmental impact, energy-saving BAT, and renewable energy sources (Government of Kazakhstan, 2024[73]). It will introduce mandatory monitoring of consumption and higher tariffs, while providing direct support for vulnerable groups. Impact, however, remains to be seen. The Roadmap for NDCs Implementation to achieve the 2060 net-zero goals is being developed; it presents another opportunity to address these challenges through revised pricing mechanisms, broader public consultations to raise awareness, and better tailored support of carbon-intense industries and vulnerable groups for a just and green transition.

Box 2.3. Kazakhstan’s use of best available techniques (BAT)

The 2021 Environmental Code introduced best available techniques (BAT) for Kazakhstan’s largest firms in the most polluting sectors to mitigate environmental impacts. BAT are technologies, techniques, and equipment that reduce negative environmental impacts of economic activities in line with target environmental quality indicators. From 1 January 2025, “Category I” facilities are required to obtain comprehensive environmental permits based on the BAT application and compliance of facilities with specified emission levels. Companies using BAT will be exempt from an environment tax on emissions. Non-compliance with BAT will trigger environmental fines that will increase exponentially. An integrated environmental permit is necessary to use facilities with gross emissions of 1 000 tons and more. Firms need to demonstrate using at least one BAT to obtain such a permit.

To promote BAT, Kazakhstan’s International Centre for Green Technologies and Investment Projects is developing BAT reference documents on sector-specific technologies, including in mining, metallurgy, and energy. Kazakhstan achieved the largest overall flare reduction in all countries from 2012 to 2022 and reduced the intensity of gas flaring: in 2006, 3.1 billion cubic metres (bcm) of gas was flared while producing 27 bcm, compared to 0.3 bcm flared in 2024 to produce of 59 bcm. This was achieved through the strict enforcement of the ban on flaring in the Law on Subsoil and Subsoil Use as well as incentives to introduce new technologies.

However, there might be a need for further financial or technical support on BAT to firms. The Asian Development Bank (ABD) and Kazakhstan signed a Memorandum of Understanding in 2024 to implement the Energy Transition Mechanism that aims to accelerate the decommissioning of outdated and non-upgradable coal-fired power plants, increase the use of renewable energy sources, enhance energy efficiency, and introduce new technologies in electricity and heat production. In December 2023, Kazakhstan joined the Global Methane Pledge aiming for a 30% reduction in methane emissions by 2030, especially using BAT. Kazakhstan suffered one of the worst global methane leaks in recorded history that year, with the government fining the offending firm USD 780 000, raising concerns about the enforcement of the code in practice. New coal-fired plants and renewable energy generation auctions also include BAT requirements though OECD interviews suggested that application in practice could be stronger and pointed to the need to review the heating tariff structure for their success.

Source: (Government of Kazakhstan, 2017[49]), On Subsoil and Subsoil Use, https://adilet.zan.kz/eng/docs/K1700000125.

(World Bank, 2022[74]), A Decade of Stalled Progress on Reducing Global Gas Flaring, https://www.worldbank.org/en/news/press-release/2022/05/04/a-decade-of-stalled-progress-on-reducing-global-gas-flaring.

(OECD, 2023[2]), Insights on the Business Climate in Kazakhstan, 10.1787/bd780306-en.

(World Bank, 2023[75]), Global Methande and Flaring Regulations – Kazakhstan, https://flaringventingregulations.worldbank.org/kazakhstan.

(Government of Kazakhstan, 2024[1]), On Approval of the National Development Plan of the Republic of Kazakhstan until 2029 and the invalidation of certain decrees of the President of the Republic of Kazakhstan (Об утверждении Национального плана развития Республики Казахстан до 2029 года и признании утратившими силу некоторых указов Президента Республики Казахстан), https://adilet.zan.kz/rus/docs/U2400000611.

(IGTIPC, 2024[76]), BAT reference documents, https://igtipc.org/en/ndt-reference-books/.

(Mondaq, 2024[77]), Environment and Climate Regulation Comparative Guide, https://www.mondaq.com/environment/1536756/environment-and-climate-regulation-comparative-guide.

(BBC, 2024[78]), Company fined over massive Kazakhstan methane leak, https://www.bbc.com/news/world-asia-68347437.

(ADB, 2024[79]) ADB, Kazakhstan Take Next Step Toward Early Coal Retirement with ETM Agreement, https://www.adb.org/news/adb-kazakhstan-take-next-step-toward-early-coal-retirement-etm-agreement.

OECD (2024[42]), OECD SIPA visit to Astana.

(Government of Kazakhstan, 2025[17]), Information provided during a review of this report.

Kazakhstan aims to make its emissions trading system (ETS) more effective. It was the first post-Soviet Union country to introduce an ETS system in 2013, now covering 43% of total CO2 emissions – indicating scope to further expand sectoral GHG coverage (IMF, 2025[23]). The ETS covers facilities emitting over 20 000 tonnes of CO2/year in the energy, mining, metal, chemical and construction sectors. However, most enterprises had a surplus of free quotas; the cost of USD 1.1 per tonne of CO2 is among the lowest in the world and is considered to insufficiently stimulate enterprises to reduce their carbon footprint (Government of Kazakhstan, 2024[1]; ICAP, 2024[80]; Government of Kazakhstan, 2022[81]; IMF, 2025[23]) The 2024-2029 National Development Plan aims to strengthen the ETS; the 2026-2030 carbon budgeting provides for an increase in the annual rate of GHG reductions (Government of Kazakhstan, 2024[1]). If revenues from the ETS increase, it will be important to further clarify how these resources are allocated.

Kazakhstan has taken steps to improve its waste management. More attention is paid to recycling and environmental standards due to stronger laws and higher fines: 24% of solid municipal waste and 36% of industrial waste was recycled in 2023, with goals of both to reach 60% by 2050 (Government of Kazakhstan, 2023[82]; OECD, 2024[42]). However, self-burn and burial of waste remains common, and as local communities expand construction, they often extend to existing waste burial sites, resulting in adverse social and environmental impacts. Limited government support for waste management, manual waste sorting being frequently required to recycle, a lack of extended producer responsibility, and insufficient employment attractiveness pose further barriers to sustainable waste management (OECD, 2024[42]).

The framework for mine closure and reclamation requires strengthening. Kazakhstan’s Subsoil User Code requires subsoil users to prepare and submit mining reclamation plans and provide financial security for reclamation prior to receiving an exploration license. However, mining companies complain about the focus on financials and the amount of the financial surety. The environmental and industrial safety analysis of reclamation plans is lacking while the management of financial sureties and the use of funds for reclamation is not regulated (World Bank, 2023[29]).

A just transition is needed. Changes in rainfall are increasing aridity, drought occurrences, and catastrophic floods. It will adversely impact agriculture, energy sectors, and water resources, disproportionally affecting rural areas and potentially worsening regional inequalities (IMF, 2025[23]). The upcoming Roadmap for NDCs Implementation and the 2021-2030 Action Plan and future iterations to achieve the 2050 Green Economy Concept present an opportunity to consider social factors alongside climate-related challenges, especially in hard-to-abate industries including construction (cement, steel), transport (trucking, shipping, aviation), and monotowns that rely on single, often polluting, industries, and are vulnerable to significant job losses if the local firm shutters operations (World Bank, 2023[29]; IMF, 2025[23]).

Corruption and business integrity

Kazakhstan continues to grapple with corruption, especially in extractives and construction. Despite comprehensive anti-corruption legislation such as the Law on Combating Corruption and specific provisions in the Criminal Code, corruption remains a significant concern in public administration, public procurement, and large-scale infrastructure (OECD, 2024[83]; 2024[84]). In 2023, former senior officials were convicted for corruption-related offences (OECD, 2024[84]). There were other high-profile cases that same year related to embezzlement and bribery in construction, industry, telecommunications and transportation (KazInform, 2022[85]; 365 Info, 2023[86]; OECD, 2024[84]).

Kazakhstan has improved policymaking on anti-corruption (OECD, 2024[84]). Kazakhstan has adopted a Concept and Action Plan for 2022-26 that is monitored by the Anti-Corruption Agency but lacks civil society participation in its monitoring (OECD, 2024[84]). Kazakhstan has introduced systematic anti-corruption risk assessments, monitoring standards, and compliance frameworks to address these challenges, informed by international best practices from the Baltic countries and Singapore. The Anti-Corruption Agency engages with businesses to implement recommended changes and monitor compliance, aiming to enhance transparency and reduce corruption in quasi-governmental sectors (OECD, 2024[42]).

The country has also made strides in digitalising public services to reduce corruption opportunities and effectively enhance transparency (OECD, 2024[84]). Since 2017, approximately 80-90% of services are accessible online or through mobile devices, limiting human contact and curtailing petty corruption risks (Council of Europe, 2022[87]). An online portal centralises identified instances of corruption (OECD, 2024[42]). The government has digitalised the allocation of land resources and provided free access to information on Kazakhstan’s land use though there are issues with correct data (Government of Kazakhstan, 2023[88]).

Kazakhstan is collaborating with international partners to combat corruption challenges in infrastructure and procurement. The Anti-Corruption Agency conducts risk assessments on large-scale projects to address manipulated specifications, tender information leaks, and opaque selection processes (OECD, 2024[83]). It increasingly collaborates with anti-corruption bodies from international partners, including the People’s Republic of China (China) and Qatar, to enhance transparency in infrastructure funded by foreign investments. For example, external reviews of road infrastructure projects aim to identify risks while training sessions with experts from Hong Kong focus on proactive corruption prevention measures in infrastructure projects. Moreover, legislative reforms are under consideration to address frequent legal disputes and non-compliance with building codes, and enforce accountability for earthquake-resistant construction in high-risk regions.

Kazakhstan’s Ministry of National Economy has integrated anti-corruption practices into state-owned enterprise (SOE) governance. It conducts regular assessments and provides transparency-focused recommendations to align with OECD principles on governance and anti-corruption (OECD, 2024[83]). However, fragmented ownership structures require political will to implement and oversee effective anti-corruption programmes in SOEs (OECD, 2024[83]).

Kazakhstan is a member of the Extractive Industries Transparency Initiative (EITI) that aims to promote revenue transparency in the oil and gas industry. EITI helps strengthen accountability, governance, and public understanding of the extractive sector by ensuring accessible and regular disclosure of information on social and environmental impacts. Including information on the social distribution of mining revenue in EITI reporting would further enhance transparency (World Bank, 2023[29]).

2.2.2. Encouraging RBC in infrastructure development through finance and investment

Sustainable finance and non-financial disclosure can set important incentives for companies in infrastructure sectors to strengthen their observance of RBC-related standards. Through investment promotion and facilitation, the government can help attract infrastructure investors with greater attention to RBC.

Sustainable finance and non-financial disclosure

Kazakhstan is actively promoting green and sustainable finance. In 2017, the government adopted the Concept of Green Financial System, a long-term roadmap including the development of green finance instruments, the creation of a pipeline of green projects, and providing capability building (CAREC, 2022[89]). In 2021, Kazakhstan adopted the Taxonomy of Green Projects to classify activities and projects eligible for green finance, including green bonds and green loans issuance. Updated in 2024, project categories include renewable energy, energy efficiency, green buildings, pollution prevention and control, sustainable water and waste use, clean transportation, and transition energy (PWC, 2024[90]). Kazakhstan launched the Qazaq Green Certificate Programme in 2021 to promote renewable energy development by enabling companies interested in reducing their carbon footprint to obtain certification (IMF, 2025[23]; Qazaq Green, 2023[91]). Kazakhstan’s Astana International Financial Centre (AIFC) has launched sustainable finance initiatives, including the Statement of Commitment to Sustainable Finance Principles. It established the AIFC Green Finance Centre in 2021 as the regional office of the Green Investment Principles for the One Belt One Road Initiative to promote and scale sustainable finance in Central Asia (Green Platform Forum, 2022[92]). The Development Bank of Kazakhstan is an important financier of infrastructure in the country. In 2023, it adopted ESG criteria for assessing projects and a roadmap to promote ESG risk management, followed in 2025 by an environmental and social policy (Development Bank of Kazakhstan, 2025[93]). The bank’s Green & Sustainable Financing Framework requires that eligible projects are assessed for their environmental and social risks, and the usage of green and sustainable bonds is verified, for example for wind energy projects (Development Bank of Kazakhstan, 2024[94]; AIFC Green Finance Centre, 2024[95]).

Kazakhstan promotes environmental, social, and governance (ESG) reporting. The Agency for Regulation and Development of Financial Market (ARDFM) issued ESG reporting guidelines in 2023, which became mandatory as of 2024 (PWC, 2024[96]). The Astana Financial Services Authority has issued the AIFC ESG Disclosure Guidance, effective from October 2024, that applies to all banks, fund managers, and insurers (AIFC, 2024[97]). Banks and financial institutions in Kazakhstan now must have an ESG strategy including targets and indicators, ESG risk identification and management processes, ESG commitment form the Board of Directors, and compliance and monitoring systems (PWC, 2024[96]). ARDFM plans to release Guidance on Environmental and Social Risk Management for financial institutions that integrates environmental, social and climate risk assessment into their credit risk management process (PWC, 2024[96]). ESG disclosure is also mandatory for firms listed on the Kazakhstan Stock Exchange (KASE) and for companies – including in energy, transport, and construction – owned by state holdings Samruk-Kazyna and Baiterek. Since 2015, KASE is part of the UN Sustainable Stock Exchanges Initiative, a peer-to-peer platform to enhance transparency on ESG and encourage sustainable investments. It published its first ESG reporting methodology in 2016, revising it in 2020. KASE and ARFDM regularly hold ESG awareness-raising events; KASE has also held an annual “Best Sustainability Report” award since 2018 (CAREC, 2022[89]).

Some firms go beyond regulatory requirements but gaps in the framework exist. ESG information reporting is improving, such as for Samruk-Kazyna, indicating enhanced alignments with international standards (CAREC, 2024[98]) Certain domestic large mining firms and raw materials suppliers that are not part of Samruk-Kazyna drive their own sustainability initiatives, in some cases going beyond the regulatory requirements, including Scope 3 GHG emissions. Overall, domestic mining companies have only recently started their ESG reporting and efforts to receive sustainability ratings. In is notable that companies tend to equate their responsibility with philanthropic culture, health, and sport activities with local communities rather than RBC (CAREC, 2024[98]).

The national pension fund could be significant driver for sustainable financing. The National Bank of Kazakhstan is the sole shareholder of the Unified Accumulative Pension Fund of Kazakhstan (ENPF), which oversees USD 41 billion in assets and investments in 24 countries. As there is a limited base of institutional investors in Kazakhstan, ENPF is being considered as an alternative finance source in the real economy, providing opportunities for sustainable infrastructure investments (Government of Kazakhstan, 2024[1]). The pension fund’s long-term investment focus could help finance infrastructure in a way that secures sustainable (rather than short-term) benefits. ENPF adopted a concept in 2023 for its activities and monitoring to align with SDGs risk assessment, which naturally extends to sustainability and RBC considerations (ENPF, 2024[99]).

Investment promotion and facilitation

Kazakhstan is seeking to attract private investors for qualitative infrastructure financing (Government of Kazakhstan, 2024[1]). In January 2025, the President outlined the need to attract high-quality investments, including for investors to ensure job retention, modernisation, and adherence to environmental regulations (Government of Kazakhstan, 2025[6]). Kazakhstan has historically enjoyed significant FDI inflows, especially in energy and, notably, oil, and is the highest recipient of FDI flows in Central Asia. FDI has been concentrated in the extractive industries though mobility, manufacturing, and RES sectors experienced strong growth in 2023 (EY, 2024[100]). Nevertheless, investment needs remain high. The 2025 Strategic Development Plan and the 2024-2029 Investment Policy Concept point to private investments, PPPs and the Green Climate Fund for financing sources (Government of Kazakhstan, 2018[101]; Government of Kazakhstan, 2024[36]). The 2029 Strategic Development Plan aims to shift from direct state financing to financing through private institutions and developing alternative sources of financing, including green financing and the pension fund (Government of Kazakhstan, 2024[1])

Challenges in the investment environment remain. Inadequate transparency, regulatory barriers, state ownership, limited English-language information, and the regulatory framework for landownership and expropriation continue to pose challenges that deter broader FDI inflows (OECD, 2023[2]). In a survey of mining companies, challenges related to labour regulations, employment and socio-economic agreements, infrastructure quality, and community development conditions were cited as factors for drags on mining and metallurgy investment attractiveness (Fraser Institute, 2024[102]).Though Kazakhstan has some experience in capacity tariff markets and concessional loans to attract private investment in infrastructure, it has relatively little experience in public-private partnerships (PPPs), capital subsidies, ESG-linked green bonds or tax credits – all of which have significant potential to leverage private sector capital (World Bank, 2023[103]).

A supportive framework for sustainable infrastructure investment is being developed. Kazakhstan adheres to the OECD Declaration on International Investment and Multinational Enterprises. In 2024 it committed to developing a declaration on RBC for investors to make a positive contribution to sustainable development. Kazakhstan also committed to stimulating investment in green projects in line with SDG while promoting ESG principles (Government of Kazakhstan, 2024[36]). Interviews indicate that the institutional framework for investors has become clearer, especially in the heating and energy sectors. In 2021, Kazakhstan created the Council for Attracting Investments to improve the investment climate; its Chair reports directly to the President and Prime Minister. The Ministry of Foreign Affairs’ Investment Committee and its subsidiary, Kazakh Invest, handle investment climate policy issues and work with investors. Kazakh Invest is a one-stop shop for international investors and lists projects, including in RES and waste management – but also gas – on its website. The AIFC, special economic zones, and the Investment Policy Concept 2029 aim to attract FDI into key sectors like energy, telecommunications, and infrastructure. (OECD, 2023[2]). Kazakhstan’s Foreign Investors’ Council aims to promote dialogue between the government and foreign investors, address investment climate issues, and attract investments in infrastructure sectors, including transport, energy, and mining (Astana Times, 2024[104]). The EU-Kazakhstan Enhanced Partnership and Cooperation Agreement includes references to sustainable development and social investment aspects as well as a trade and sustainable development chapter with references to labour rights and environmental issues (EEAS, 2020[105]). Investment facilitation policies have been well-received by the business community and such institutional advancements provide platforms to address investor concerns and facilitate market entry (OECD, 2023[2]).

Kazakhstan is ramping up initiatives to attract private sector investments in sustainable infrastructure. International investors are key to achieve its goal of 12.5% RES share of power by 2029 (Government of Kazakhstan, 2024[9]). Since 2016, RES projects have benefitted from tax privileges. Since 2020, they have also enjoyed exemptions from VAT and customs duties for imported equipment and can receive in-kind grants for up to 30% of the investment in fixed assets (i.e. land, buildings or equipment). As of 2018, Kazakhstan uses an auction-based mechanism to select RES projects, which together with favourable investment preferences, has reduced tariffs and attracted international investments, including from China, Europe, and the Middle East (IEA, 2022[18]; Government of Kazakhstan, 2025[17]). Kazakhstan’s International Centre for Green Technologies and Investment Projects aims to attract green investments as the agency responsible for the UN’s Green Climate Fund and for developing a green finance system and the BAT reference books (IGTIPC, 2024[76]). Even so, coal remains significantly cheaper than RES – not accounting for adverse impacts – in Kazakhstan, thereby disincentivising investments. Depending on its implementation, the Law on Heating Supply may attract new investment and Kazakhstan has introduced a Tariff in Exchange for Investment programme to ensure return on investment and an acceleration of investments in infrastructure and electricity generation capacity (IMF, 2025[23]; Government of Kazakhstan, 2025[17]).

2.2.3. Exemplifying RBC in infrastructure development via the state’s economic role and commercial activities

The state plays a major role in infrastructure development and operations. Frameworks for public procurement, public-private partnerships and corporate governance of state-owned enterprises can therefore incentivise and support responsible business conduct for sustainable infrastructure.

Public procurement

Kazakhstan is integrating RBC-related considerations into procurement laws. Public procurement in Kazakhstan accounts for 13% of GDP – just above the OECD average of 12.6% in 2019 (OECD, 2024[83]). It can therefore significantly drive sustainable activities. Kazakhstan’s 2015 Law on Public Procurement as amended in 2018 contains environmental requirements for tenders (UNECE, 2019[106]). Coming into force in July 2025, the 2024 Law on Public Procurement introduced sustainable public procurement “with the aim of ensuring optimal and efficient spending of funds used for public procurement throughout their entire life cycle, as well as achieving social, economic, and environmental aspects of development” (Government of Kazakhstan, 2024[107]). The law also introduced public monitoring and bans suppliers that have previously committed corruption offenses or are in wage arrears. A new Unified Procurement Platform will unite the procurement of national companies and the national wealth fund Samruk-Kazyna, which will simplify procurement and enhance transparency (OECD, 2024[83]; Government of Kazakhstan, 2024[108]).

Digitalisation aims to address corruption in public procurement. Recently, the government adopted a comprehensive e-procurement system and publishes open contracting data on all procurement cycle stages. Civil society organisations and international partnerships monitor procurement through the one-stop shop prozakup.kz and develop practical guides for procurement officials (Open Contracting Partnership, 2023[109]). The competition agency aims to curb the uncompetitive allocation of land plots for construction and better hold subnational authorities to their responsibility to ensure transparent land sales by digitalising property purchasing processes (OECD, 2024[83]).

Effective implementation of the new public procurement law will be key. Awareness among local suppliers and buyers remains low and discussions on sustainability aspects are absent, with decisions prioritising cost over sustainability factors (UN, 2021[110]). Persistent issues, including corruption, lack of transparency in SOEs, and tailor-made specifications for favoured companies, continue to undermine progress (OECD, 2024[83]). Strengthening implementation through clear sustainability criteria, scaling awareness campaigns, and promoting due diligence for RBC in public procurement are needed if public procurement is to be an effective and strategic tool for RBC in line with the government’s commitment as an Adherent to the Recommendation on the Role of Government in Promoting RBC (OECD, 2022[35]). In 2024, Kazakhstan joined the EU’s SWITCH-Asia programme, providing international expertise to implement sustainable procurement mechanisms and raise awareness about the consequences of not integrating RBC-related considerations in public procurement (IGTIPC, 2024[111]).

Public-private partnerships (PPPs)

Kazakhstan has progressed in developing a comprehensive PPP framework. It has emphasised the private sector’s participation in infrastructure sector development since the 2006 Law on Concessions. The 2015 PPP Law – currently under revision – and more recent amendments have further increased the scope of PPPs, allowing for long-term lease concessions and enhanced investment attraction (OECD, 2024[112]). The 2021 Environmental Code includes mandatory EIAs for PPP facilities that can have an environmental or health impact, while not including a requirement to assess wider human rights and social impacts.

There are few infrastructure PPPs. Most closed PPPs in 1990-2021 were in energy and nearly all PPPs in 2021 were in social infrastructure, including educational and health infrastructure (ADB, 2022[113]). PPP mechanisms have been established under the national project “Zhasyl Kazakhstan” (Green Kazakhstan) for 2021-2025. It covers improving the environmental situation across 10 cities, upgrading water infrastructure, increasing the processing of solid waste from 18% to 34%, reducing the energy intensity of the country’s GDP, and preserving biodiversity (US Trade, 2022[114]). Kazakhstan has over 1 357 PPP-funded projects though just 3% of 2022 projects were in transport infrastructure and only three large-scale transport PPP projects are ongoing, all in and around Almaty (OECD, 2024[112]). Kazakhstan currently lacks a Land Acquisition and Resettlement Framework that would facilitate the management of impacts on land rights in PPPs supported by international financial institutions that apply the Equator Principles and ESG safeguards (see Box 1.3) (ADB, 2022[113]).

State-owned enterprise (SOE) ownership

SOEs continue to play a significant role in Kazakhstan’s economy and especially in its infrastructure sectors, including in energy, mining, and transport. Over 7 000 public enterprises are registered in Kazakhstan; SOEs are present in at least 20 out of 30 sectors and account for 6.2% of national employment – over double the OECD average at 2.8%. (OECD, 2022[115]). Kazakhstan’s Entrepreneurial Code of 2015 contains a chapter on social responsibility of businesses, including a provision for the state itself to commit to creating conditions for social responsibility.

Kazakhstan’s national wealth fund, Samruk-Kazyna, is a standard setter on RBC for SOEs in Kazakhstan. It is the largest holding company of SOEs, amounting to 14% of GDP in 2021 and managing 61% of the state-owned sector in terms of asset size (OECD, 2024[83]). The government is its sole shareholder and thereby the de facto owner of many SOEs in the energy, mining, transport, telecommunications, and construction sectors (OECD, 2024[83]). Samruk-Kazyna has a Corporate Social Responsibility (CSR) policy and its 2015 Corporate Governance Code calls for observance of human rights, prevention of environmental abuse, intolerance of corruption as well as annual disclosure of these issues and more. The Code sets out that the fund and SOEs should develop action plans on sustainable development, explicitly mentioning the MNE Guidelines (OECD, 2022[116]). Samruk-Kazyna uses international standards on accountability and social responsibility to engage with stakeholders. It has established channels for regular dialogue, including developing stakeholder mapping based on risks and degree of direct and indirect impact, liabilities, influence, and more (OECD, 2022[116]). Additionally, Samruk-Kazyna allocates at least 7% of its net income annually to a non-profit organisation though this is indicative of corporate philanthropy rather than RBC (OECD, 2024[83]). There are opportunities to promote RBC in the SOEs overseen by different ministries that currently apply diverging standards of corporate governance (OECD, 2024[83]; OECD, 2024[42]).

2.2.4. Promoting stakeholder participation and access to remedy

As infrastructure can create significant beneficial and adverse impacts for local communities, enterprises’ meaningful engagement with stakeholders throughout the infrastructure life cycle is essential.

Stakeholder engagement

Kazakhstan aims to foster public-private dialogue and ensure comprehensive public consultation for infrastructure projects. Public participation is a legal requirement as part of the EIA process though interviews indicate their quality could be strengthened. Local authorities are responsible for organising hearings, and in some cases, public protests have led to project refusals, including a refusal to construct waste incineration facilities. The 2024 Law on Heating Supply includes heating master plans that will provide opportunities for public discussions on a district level, including on tariff incentives (Government of Kazakhstan, 2024[73]). Trade unions in Kazakhstan are consulted on legislation in more than 60 instances and are part of parliamentary working groups. Despite this involvement, trade unions and civil society have highlighted a lack of a robust public-private dialogue culture, noting that engagement with businesses and public authorities remains limited.

Businesses are also consulted on legislative developments, including RBC. Representatives from business associations indicate they are largely satisfied with the government’s consideration of their concerns during working groups. International companies operating in Kazakhstan are also regularly consulted on business environment legislation related to sustainability though interlocutors indicate they could be involved more consistently in proposed changes. For instance, the EU regularly organises high-level business platforms as part of the EU-Kazakhstan Enhanced Partnership and Cooperation Agreement. The platform fosters transparency, improves the business environment, and promotes information exchange on sustainable practices, including critical raw materials and mining (EEAS, 2022[117]).

There is growing awareness of sustainability considerations among stakeholders and communities. Communities and stakeholders, including environmental non-governmental organisations (NGOs), are increasingly raising concerns about the ecological impacts of infrastructure projects. For example, associations dedicated to protecting migratory birds have influenced legislative processes and regularly engage in consultations with the Ministry of Ecology. Such groups, often active on social media, play a growing role in shaping policies. Public discussions on just transition issues, such as the impact on workers in power plants, are also gaining momentum, with communities pushing for greater consideration of environmental and social factors in decision-making. This has sparked national debates, including a national referendum that was held in October 2024 on the construction of a nuclear power plant (NPP), with 71.12% of voters supporting the initiative. Following this, the government determined the NPP’s location and has initiated a selection process for its construction (Government of Kazakhstan, 2024[118]; Government of Kazakhstan, 2025[17]).

However, gaps remain. For instance, the State Property Law, Joint Stock Company Law, and the Model Corporate Governance Code of Kazakhstan do not include provisions or directives requiring the inclusion of local self-government entities, trade unions, or labour collectives in the Board of Directors meetings of SOEs (OECD, 2024[83]). This is a missed opportunity to ensure that key stakeholders have a voice in the strategic decision-making processes of public enterprises.

Access to remedy

Victims of adverse impacts are increasingly turning to Kazakhstan’s NCP. In 2023, OECD interviews indicated that there was a place for the NCP within the grievance mechanism landscape as an alternative to in-court dispute settlements. This notion that the NCP has a role to play is supported by the fact that, globally, cases with mediation resulted in agreements 73% of the time in 2023 (OECD, 2024[119]). The NCP has put in additional efforts to establish itself and conduct more promotional activities since 2020. The NCP has received seven specific instances from 2021-2023, including two infrastructure cases: a company manufacturing railway rolling stock and a firm providing bearing materials for industrial and infrastructure sectors. Feedback from stakeholders points to a need for greater awareness of the NCP, particularly in civil society. Specific instances in Kazakhstan were submitted by individuals (4 cases) and trade unions (3 cases) (OECD, 2024[120]). Interviews with business highlighted the importance of mediation in Kazakhstan though some noted that more trust would need to be built with the mechanism (OECD, 2024[42]). Though the NCP has a multipartite structure, including representation from government, business, and civil society, it excludes trade union stakeholders from the institutional arrangements, which could limit confidence in the NCP mechanism (OECD, 2024[120]).

Other non-judicial grievance mechanisms exist. The 2011 Law on Mediation aims to offer protection and redress for the violation of human rights and freedoms in Kazakhstan (Government of Kazakhstan, 2011[121]). Though it does not require mediation in any proceedings, courts strongly encourage parties to attempt a mediation procedure and 11.8% of cases received in 2019 were solved through mediation (AEA-EAL, 2021[122]). The 39 257 cases related to government and infrastructure are split into state procurement matters (25 463), property claims (9 916), land matters (3 493), and defamation and business reputation matters (385). Though relatively few, the business reputation cases saw a 27.5% conclusion rate in court. Additionally, consumer protection involving SMEs are handled by the Committee of Consumer Protection under the Ministry of Trade and include an online platform1.

Company-level mechanisms for receiving and addressing grievances can benefit from further development. Though most larger companies have mechanisms in place to receive and address grievances – usually concerning labour rights violations – only half of surveyed firms under the NAP BHR’s National Baseline Assessment have information on their grievance mechanisms online and they rarely have a public statement of their commitment to remediate adverse impacts (UNDP, 2024[37]). Crucially, no human rights due diligence framework was identified in surveyed businesses to identify, prioritise, and address adverse impacts. In the few cases where firms integrate human rights considerations in their risk management, impact assessments, and stakeholder engagement, they rarely publish activity reports or monitor their effectiveness in protecting and redressing violations. Transparency is another issue, as few companies provide information on the procedures for their grievance mechanisms (UNDP, 2024[37]).

2.3. Conclusions

Kazakhstan has important strengths it can build on to advance responsible business conduct (RBC) for sustainable infrastructure development. It also has opportunities to address gaps in its policy framework and further promote responsible business conduct in the infrastructure life cycle. To contribute to an enabling regulatory and policy environment for RBC in infrastructure development, the Government of Kazakhstan could consider the following actions:

• Pursue a whole-of-government approach: As an adherent to OECD standards on RBC and equipped with a National Contact Point for RBC (NCP), Kazakhstan can take advantage of this institutional basis to promote RBC in infrastructure development. The 2023 OECD Recommendation on the Role of Government in Promoting RBC [ (OECD, 2022[35]) provides guidance to ministries and public institutions on how they can encourage RBC and integrate it in their economic activities. The government should ensure that infrastructure-related ministries and institutions such as the NCP work closely together in the development and implementation of RBC-related initiatives, including the National Action Plan on Business and Human Rights.

• Promote due diligence in the extractive sector: In accordance with the OECD Due Diligence Guidance, including the Due Diligence Guidance for Meaningful Stakeholder Engagement in the Extractive Sector, Kazakhstan should raise awareness and build companies’ capacity to conduct RBC due diligence in the minerals and extractive sector.

• Enhance the protection of labour rights in infrastructure sectors: The Concept for Safe Labour provides an important basis for greater progress. Its implementation should be pursued in close collaboration with employers and trade unions. The government should enable unannounced labour inspections and ensure inspection services have the necessary capacity and resources.

• Support the consideration for environmental impacts: Building on its strengthened Environmental Code, the government should further encourage the adoption of Best Available Techniques, while also ensuring companies’ compliance with existing requirements. The government could also explore how the Emissions Trading Scheme can improve businesses’ environmental performance.

• Continue the fight against corruption in infrastructure investments: The OECD Monitoring under the Istanbul Anti-corruption Action Plan provides Kazakhstan with clear recommendations to strengthen anti-corruption and business integrity. The government should support efforts by the Anti-Corruption Agency to accompany infrastructure projects, and identify and prevent corruption risks. This includes incorporating civil society participation in the monitoring of its Anti-Corruption Concept and Action Plan for 2022-26.

As a key economic player, especially in its roles as investor, sponsor, and operator of infrastructure, the Government of Kazakhstan could also consider mainstreaming specific tools to address RBC-related risks and impacts at the infrastructure project-level.

• Leverage public procurement: Kazakhstan has started using public procurement as a strategic tool to encourage RBC and integrate sustainability considerations in its public procurement framework. It should strengthen this by considering aligning suppliers’ practices with environmental, economic, and social sustainability standards.

• Link sustainable finance to infrastructure investments: Kazakhstan has established itself as a leading player for sustainable finance in the region. The government and the financial sector, including through the national wealth and pension funds, should use this leadership to promote RBC in infrastructure financing. Financial institutions could draw on OECD work to help operationalise RBC in the financial sector, including work on Responsible Business Conduct Due Diligence for Project and Asset Finance (OECD, 2022[123]).

• Reinforce RBC expectations for SOEs: Samruk-Kazyna is already setting important RBC-related expectations for state-owned enterprises (SOEs) it holds shares in. The government might consider applying similar expectations to other SOEs in infrastructure sectors – including the 39% of state-owned assets not under Samruk-Kazyna’s control – and reflect together with Samruk-Kazyna on how RBC due diligence can be further promoted in all SOEs.

References

[8] 2050 Strategy (2014), 2050 Strategy address, https://afmrk.gov.kz/en/activity/strategy-and-program/strategy-kazakhstan-2050/ (accessed on 3 April 2023).

[86] 365 Info (2023), Trial of Old Kazakhstanis: The Most High-Profile Sentences of 2023 (Суд над староказахстанцами: самые громкие приговоры 2023 года), https://365info.kz/2023/12/sud-nad-starokazahstantsami-samye-gromkie-prigovory-2023-goda (accessed on 8 November 2024).

[79] ADB (2024), ADB, Kazakhstan Take Next Step Toward Early Coal Retirement with ETM Agreement, https://www.adb.org/news/adb-kazakhstan-take-next-step-toward-early-coal-retirement-etm-agreement (accessed on 3 March 2025).

[20] ADB (2024), Kazakhstan: Supporting Renewable Technology-Inclusive Heat Supply Legislation, https://www.adb.org/sites/default/files/project-documents/53341/53341-001-tcr-en.pdf.

[113] ADB (2022), Public-private partnership monitor Kazakhstan, https://www.adb.org/sites/default/files/publication/850386/public-private-partnership-monitor-kazakhstan.pdf.

[15] ADB (2021), Developing Infrastructure in Central Asia: Impacts and Financing Mechanisms, https://www.adb.org/sites/default/files/publication/688061/adbi-book-developing-infrastructure-central-asia.pdf.

[122] AEA-EAL (2021), Mediation in Kazakhstan, https://aea-eal.eu/2021/01/28/mediation-in-kazakhstan/ (accessed on 5 November 2024).

[22] Agora Energiewende (2024), Modernising Kazakhstan’s coal-dependent power sector through renewables - Challenges, solutions and scenarios up to 2030 and beyond, https://www.agora-energiewende.org/fileadmin/Projekte/2023/2023_27_PST_Kazakhstan_2023/A-EW_319_Kazakhstan_2023_EN_WEB.pdf.

[97] AIFC (2024), AFSA issues AIFC ESG Disclosure Guidance, https://afsa.aifc.kz/en/news/afsa-issues-aifc-esg-disclosure-guidance (accessed on 7 November 2024).

[95] AIFC Green Finance Centre (2024), Post-issuance Verification Report for Certified Climate Bond (Green Bond), https://www.kdb.kz/upload/iblock/e8d/1m7bwx8e6h8tscls9w0k1cak68s58bam/DBK-Post-Issuance-Verification-dated-20-December-2024.pdf.

[104] Astana Times (2024), Kazakh President Outlines Key Areas at Foreign Investors’ Council, https://astanatimes.com/2024/10/kazakh-president-outlines-key-areas-at-foreign-investors-council/ (accessed on 8 November 2024).

[60] Astana Times (2024), Tokayev Reiterates Need for Industry Experts, Future-Oriented Professions, https://astanatimes.com/2024/09/tokayev-reiterates-need-for-industry-experts-future-oriented-professions/ (accessed on 6 November 2024).

[78] BBC (2024), Company fined over massive Kazakhstan methane leak, https://www.bbc.com/news/world-asia-68347437 (accessed on 5 November 2024).

[61] Business & Human Rights Resource Centre (2022), Kazakhstan: Inspections at Vostoktsvetmet & Kazzinc reveal over 1200 labour & industrial safety violation (translated from Антон Сергиенко on Ratel.kz), https://www.business-humanrights.org/en/latest-news/kazakhstan-inspections-at-vostoktsvetmet-kazzinc-reveal-1200-labour-industrial-safety-violations/ (accessed on 4 December 2024).

[47] CABAR (2021), The Significance Of The Land Issue Has Not Yet Been Realized By The Authorities Of Kazakhstan, https://cabar.asia/en/the-significance-of-the-land-issue-has-not-yet-been-realized-by-the-authorities-of-kazakhstan (accessed on 7 November 2024).

[98] CAREC (2024), Prospects for inclusive green growth and sustainability in the CAREC region, https://www.carecinstitute.org/wp-content/uploads/2024/08/3rd-Annual-Research-Book.pdf.

[89] CAREC (2022), Environmental, Social, and Governance in the CAREC Region, https://www.carecinstitute.org/wp-content/uploads/2022/10/ESG-in-the-CAREC-Region-for-publication-final.pdf.

[87] Council of Europe (2022), Joint First and Second Evaluation Rounds: Evaluation Report on Kazakhstan, GRECO 15 June, https://rm.coe.int/joint-first-and-second-evaluation-rounds-evaluation-report-on-kazakhst/1680a6e276.

[93] Development Bank of Kazakhstan (2025), Environmental and Social Management System, https://www.kdb.kz/en/sustainable-development/environmental-and-social-management-sistem/ (accessed on 10 April 2025).

[94] Development Bank of Kazakhstan (2024), Green & Sustainable Financing Framework, https://www.kdb.kz/upload/iblock/77f/r9c2jpo41ki3hdxt28bjuog6op4s0kxc/Green-and-Sustainable-Financing-Framework_GRAPHIC_062024_ENG.pdf.

[117] EEAS (2022), 10th EU-Kazakhstan High-Level Business Platform focussed on Cooperation in the Area of Raw Materials and Sustainable Mining, https://www.eeas.europa.eu/delegations/kazakhstan/10th-eu-kazakhstan-high-level-business-platform-focussed-cooperation-area-raw-materials-and_en?s=222 (accessed on 5 November 2024).

[105] EEAS (2020), EU-Kazakhstan Enhanced Partnership and Cooperation Agreement, https://www.eeas.europa.eu/sites/default/files/eeas-factsheet_eu-kz_epca_entry_into_force_v.2.0_hr_fin.pdf.

[99] ENPF (2024), ANNUAL REPORT OF UAPF JSC FOR 2023, https://www.enpf.kz/upload/medialibrary/10f/10ff192b8404f46215098ea47e5bfd80.pdf.

[41] ERI (2024), NCP Events (События НКЦ), https://eri.kz/ru/Nacionalnyj_kontaktnyj_centr/Sobytija_NKC (accessed on 5 November 2024).

[39] ERI (2023), UN Guidelines and National Baseline Assessment (Руководящие принципы ООН и Национальная базовая оценка), https://eri.kz/ru/Nacionalnyj_kontaktnyj_centr/Sobytija_NKC/id=5614/arch=2023_2 (accessed on 5 November 2024).

[45] EU (2024), EU and partners launch Minerals Security Partnership Forum, https://ec.europa.eu/commission/presscorner/detail/en/ip_24_1807 (accessed on 31 October 2024).

[43] EUROBAK (2024), ESG, https://eurobak.kz/committees/ (accessed on 7 November 2024).

[46] European Commission (2022), Strategic partnership with Kazakhstan on raw materials, batteries and renewable hydrogen, https://international-partnerships.ec.europa.eu/policies/global-gateway/strategic-partnership-kazakhstan-raw-materials-batteries-and-renewable-hydrogen_en (accessed on 4 December 2024).

[100] EY (2024), Navigating new horizons: Kazakhstan attractiveness report - June 2024, https://assets.ey.com/content/dam/ey-sites/ey-com/en_kz/topics/attractiveness/ey-kz-ias-2024.pdf.

[102] Fraser Institute (2024), Survey of Mining Companies 2023, https://www.fraserinstitute.org/sites/default/files/2023-annual-survey-of-mining-companies.pdf.

[28] Government of Kazakhstan (2025), Address by the Head of State Kassym-Jomart Tokayev at the enlarged meeting of the Government (Выступление Главы государства Касым-Жомарта Токаева на расширенном заседании Правительства), https://www.akorda.kz/ru/vystuplenie-glavy-gosudarstva-kasym-zhomarta-tokaeva-na-rasshirennom-zasedanii-pravitelstva-2801458 (accessed on 5 March 2025).

[17] Government of Kazakhstan (2025), Information provided during a review of this report.

[6] Government of Kazakhstan (2025), The head of state held an enlarged meeting of the government (Глава государства провел расширенное заседание Правительства), https://www.akorda.kz/ru/glava-gosudarstva-provel-rasshirennoe-zasedanie-pravitelstva-2804323 (accessed on 5 March 2025).

[67] Government of Kazakhstan (2025), Year of blue-collar jobs: Kazakhstan to launch Digital map of enterprises to identify financial, social and labor risks, https://primeminister.kz/ru/news/god-rabochikh-professiy-v-kazakhstane-zapustyat-tsifrovuyu-kartu-predpriyatiy-pozvolyayushchuyu-opredelyat-finansovye-sotsialnye-i-trudovye-riski-29554 (accessed on 10 March 2025).

[65] Government of Kazakhstan (2024), Main indicators of the labor market in the Republic of Kazakhstan (2 quarter 2024), https://stat.gov.kz/en/industries/labor-and-income/stat-empt-unempl/publications/206422/#:~:text=According%20to%20the%20sample%20survey,of%20the%20total%20number%20of (accessed on 11 December 2024).

[24] Government of Kazakhstan (2024), Ministry of Energy works out measures plan for electric power industry development. 26 GW of new generating capacities to be commissioned, https://primeminister.kz/en/news/ministry-of-energy-works-out-measures-plan-for-electric-power-industry-development-26-gw-of-new-generating-capacities-to-be-commissioned-26978 (accessed on 10 March 2025).

[36] Government of Kazakhstan (2024), On approval of the Concept of Investment Policy of the Republic of Kazakhstan until 2029, https://adilet.zan.kz/rus/docs/P2400000868 (accessed on 7 November 2024).

[1] Government of Kazakhstan (2024), On Approval of the National Development Plan of the Republic of Kazakhstan until 2029 and the invalidation of certain decrees of the President of the Republic of Kazakhstan (Об утверждении Национального плана развития Республики Казахстан до 2029 года...), https://adilet.zan.kz/rus/docs/U2400000611#z967 (accessed on 31 October 2024).

[9] Government of Kazakhstan (2024), On approval of the National Infrastructure Plan of the Republic of Kazakhstan until 2029 (Об утверждении Национального инфраструктурного плана Республики Казахстан до 2029 года), https://adilet.zan.kz/rus/docs/P2400000606 (accessed on 5 November 2024).

[73] Government of Kazakhstan (2024), On Heatin (О теплоэнергетике), https://adilet.zan.kz/rus/docs/Z2400000120 (accessed on 5 November 2024).

[107] Government of Kazakhstan (2024), On public procurement, https://adilet.zan.kz/rus/docs/Z2400000106 (accessed on 6 November 2024).

[118] Government of Kazakhstan (2024), On the area of construction of the nuclear facility ‘Nuclear Power Plant’ (О районе строительства ядерной установки “Атомная электрическая станция”), https://adilet.zan.kz/rus/docs/P2400001137 (accessed on 4 March 2025).

[108] Government of Kazakhstan (2024), Results of the first half of the year: measures to support OTP in public procurement, modernization of tax administration and the National Fund for Children, https://primeminister.kz/ru/news/reviews/itogi-polugodiya-mery-podderzhki-otp-v-goszakupkakh-modernizatsiya-nalogovogo-administrirovaniya-i-natsfond-detyam-28899 (accessed on 6 November 2024).

[69] Government of Kazakhstan (2024), Share of renewable energy research 5.92% (Объем электроэнергии выработанный ВИЭ достиг 5,92%), https://www.gov.kz/memleket/entities/energo/press/news/details/736134?lang=ru (accessed on 18 December 2024).

[5] Government of Kazakhstan (2024), The Majilis approved the Law “On the Republican Budget for 2025-2027”, https://primeminister.kz/ru/news/mazhilis-odobril-zakon-o-respublikanskom-byudzhete-na-2025-2027-gody-29247 (accessed on 31 October 2024).

[25] Government of Kazakhstan (2024), Приказ “Об утверждении Плана мероприятий по развитию электроэнергетической отрасли до 2035 года”, https://www.gov.kz/memleket/entities/energo/documents/details/611688?lang=ru (accessed on 4 March 2024).

[10] Government of Kazakhstan (2023), Approval of the Strategy of the Republic of Kazakhstan on Achieving Carbon Neutrality by 2060, https://unfccc.int/sites/default/files/resource/Carbon_Neutrlaity_Strategy_Kazakhstan_Eng_Oct2024.pdf.

[64] Government of Kazakhstan (2023), Dossier on the Draft Construction Code of the Republic of Kazakhstan (December 2023) (Досье на проект Строительного кодекса Республики Казахстан (декабрь 2023 года)), https://online.zakon.kz/Document/?doc_id=34632371&pos=4;-106#pos=4;-106 (accessed on 16 December 2024).

[27] Government of Kazakhstan (2023), Main indicators of the labor market in the Republic of Kazakhstan (2023), https://stat.gov.kz/en/industries/labor-and-income/stat-empt-unempl/publications/163686/ (accessed on 18 December 2024).

[38] Government of Kazakhstan (2023), n the Plan of Action on Human Rights and the Rule of Law (О Плане действий в области прав человека и верховенства закона), https://www.akorda.kz/ru/o-plane-deystviy-v-oblasti-prav-cheloveka-i-verhovenstva-zakona-811622 (accessed on 12 November 2024).

[55] Government of Kazakhstan (2023), Positive effect for all parties of social partnership expected as outcome of Safe Labor Concept implementation — Ministry of Labor and Social Protection, https://primeminister.kz/en/news/positive-effect-for-all-parties-of-social-partnership-expected-as-outcome-of-safe-labor-concept-implementation-ministry-of-labor-and-social-protectionnbsp-26807 (accessed on 8 November 2024).

[88] Government of Kazakhstan (2023), Punishment up to dismissal: Alikhan Smailov demands to eliminate shortcomings in digitization of land resources, https://primeminister.kz/en/news/punishment-up-to-dismissal-alikhan-smailov-demands-to-eliminate-shortcomings-in-digitization-of-land-resources-26558 (accessed on 8 November 2024).

[62] Government of Kazakhstan (2023), Safe Labor Concept until 2030 adopted in Kazakhstan, https://primeminister.kz/en/news/safe-labor-concept-until-2030-adopted-in-kazakhstan-26801 (accessed on 20 December 2024).

[82] Government of Kazakhstan (2023), Significant increase of municipal and industrial waste recycling planned in Kazakhstan, https://primeminister.kz/en/news/significant-increase-of-municipal-and-industrial-waste-recycling-planned-in-kazakhstan-24781 (accessed on 5 November 2024).

[21] Government of Kazakhstan (2023), Updated Nationally Determined Contribution of the Republic of Kazakhstan to the global response to climate change, https://unfccc.int/sites/default/files/NDC/2023-06/12updated%20NDC%20KAZ_Gov%20Decree313_19042023_en_cover%20page.pdf.

[81] Government of Kazakhstan (2022), PMI KAZAKHSTAN - Implementation Support Program, https://pmiclimate.org/sites/default/files/downloads/publication/Day%203_Session%205_c__PMI%20Kazakhstan%20Implementation%20Support%20Program%20by%20Olzhas%20Agabekov.pdf.

[72] Government of Kazakhstan (2021), Environmental Code of the Republic of Kazakhstan, https://adilet.zan.kz/eng/docs/K070000212_ (accessed on 1 November 2024).

[14] Government of Kazakhstan (2020), Senators are concerned about the issues of rural areas, https://senate.parlam.kz/en-US/news/details/3818 (accessed on 12 November 2024).

[101] Government of Kazakhstan (2018), National Development Plan of the Republic of Kazakhstan until 2025 (Нацолнальный план развития Республики Казахстан ло 2025 года), https://adilet.zan.kz/rus/docs/U1800000636 (accessed on 31 October 2024).

[49] Government of Kazakhstan (2017), On Subsoil and Subsoil Use, https://adilet.zan.kz/eng/docs/K1700000125 (accessed on 16 December 2024).

[121] Government of Kazakhstan (2011), On Mediation, https://adilet.zan.kz/eng/docs/Z1100000401 (accessed on 5 November 2024).

[92] Green Platform Forum (2022), A snapshot of Kazakhstan’s sustainable finance market, http://www.greenfinanceplatform.org/blog/snapshot-kazakhstans-sustainable-finance-market.

[80] ICAP (2024), Kazakhstan Emissions Trading System, https://icapcarbonaction.com/en/ets/kazakhstan-emissions-trading-system (accessed on 1 November 2024).

[16] IEA (2023), Greenhouse Gas Emissions from Energy Highlights, https://www.iea.org/data-and-statistics/data-product/greenhouse-gas-emissions-from-energy-highlights (accessed on 31 October 2024).

[19] IEA (2023), Kazakhstan, https://www.iea.org/countries/kazakhstan/energy-mix (accessed on 4 March 2025).

[18] IEA (2022), Kazakhstan 2022 Energy Sector Review, https://iea.blob.core.windows.net/assets/fc84229e-6014-4400-a963-bccea29e0387/Kazakhstan2022.pdf.

[76] IGTIPC (2024), BAT reference documents, https://igtipc.org/en/ndt-reference-books/ (accessed on 5 November 2024).

[111] IGTIPC (2024), Didar Karimsakov, Deputy Head of ICSTIP NAO, was appointed national coordinator for the implementation of the SWITCH-Asia program in Kazakhstan (Дидар Каримсаков назначен национальным координатором по реализации программы SWITCH-Asia), https://igtipc.org/2024/02/21/4837/ (accessed on 6 November 2024).

[51] ILO (2025), Report of the Committee of Experts on the Application of Conventions and Recommendations, https://www.ilo.org/sites/default/files/2025-02/Report%20III%28A%29-2025-%5BNORMES-241219-002%5D-EN_0.pdf.

[50] ILO (2024), Committee on the Application of Standards - Kazakhstan, https://www.ilo.org/resource/other/can-2024-discussion-individual-case-kazakhstan-c81129.

[66] ILO (2024), Safety in numbers: what labour inspection data tells us, https://ilostat.ilo.org/blog/safety-in-numbers-what-labour-inspection-data-tells-us/ (accessed on 11 December 2024).

[52] ILO (2022), NORMLEX Information System on International Labour Standards, https://www.ilo.org/dyn/normlex/en/f?p=1000:11200:0::NO:11200:P11200_COUNTRY_ID:103538.

[23] IMF (2025), Republic of Kazakhstan - IMF Country Report No 25/31, IMF, https://www.imf.org/-/media/Files/Publications/CR/2025/English/1kazea2025002-print-pdf.ashx.

[54] IndustriALL Global Union (2021), Kazakhstan must respect union rights, https://www.industriall-union.org/kazakhstan-must-respect-union-rights.

[85] KazInform (2022), A project with a strong smell of corruption – Kassym-Jomart Tokayev on the LRT project, https://www.inform.kz/ru/proekt-s-sil-nym-zapahom-korrupcii-kasym-zhomart-tokaev-o-proekte-lrt_a3883841 (accessed on 8 November 2024).

[57] Kumenov, A. (2024), Kazakhstan: Oil workers persist with protest, government ignores, eurasia.net, https://eurasianet.org/kazakhstan-oil-workers-persist-with-protest-government-ignores.

[59] Le Monde (2023), Kazakhstan buys ArcelorMittal subsidiary after mining accidents, https://www.lemonde.fr/en/international/article/2023/12/08/kazakhstan-buys-arcelormittal-subsidiary-after-mining-accidents_6323743_4.html (accessed on 7 November 2024).

[30] MINEX Kazakhstan (2024), Shifting dynamics in Kazakhstan’s mining and metals industry, https://2024.minexkazakhstan.com/shifting-dynamics-in-kazakhstans-mining-and-metals-industry/ (accessed on 9 December 2024).

[77] Mondaq (2024), Environment and Climate Regulation Comparative Guide, https://www.mondaq.com/environment/1536756/environment-and-climate-regulation-comparative-guide (accessed on 2 November 2024).

[84] OECD (2024), Baseline Report of the Fifth Round of Monitoring of Anti-Corruption Reforms in Kazakhstan: The Istanbul Anti-Corruption Action Plan, OECD Publishing, Paris, https://doi.org/10.1787/c9652173-en.

[112] OECD (2024), Diversifying Kazakhstan’s Exports: Institutions, Policies, Infrastructures, OECD Publishing, Paris, https://doi.org/10.1787/7f9cd8aa-en.

[119] OECD (2024), Increasing impact, addressing challenges: A year in review of National Contact Points for Responsible Business Conduct 2023 Annual Report on NCP Activity, OECD Publishing, Paris, https://www.oecd.org/content/dam/oecd/en/networks/national-contact-points/OECD-2023-Annual-Report-on-NCP-Activity.pdf.

[120] OECD (2024), National Contact Point for Responsible Business Conduct Peer Reviews: Kazakhstan 2024, OECD Publishing, Paris, https://doi.org/10.1787/9090c11f-en.

[83] OECD (2024), OECD Review of the Corporate Governance of State-Owned Enterprises in Kazakhstan, Corporate Governance, OECD Publishing, Paris, https://doi.org/10.1787/082c508b-en.

[42] OECD (2024), OECD SIPA visit to Astana - September 2024.

[26] OECD (2024), OECD-SIPA Workshop Best Practices and International Experience for Industrial Exporters in Hard-to-abate Sectors in Kazakhstan, OECD Publishing, Paris, https://www.oecd.org/content/dam/oecd/en/events/2024/3/sipa-kazakhstan-workshop/24-03-13%20KZ%20Agenda_INDUSTRY%20.pdf/_jcr_content/renditions/original./24-03-13%20KZ%20Agenda_INDUSTRY%20.pdf.

[12] OECD (2024), “Other official providers reporting at the aggregate level to the OECD”, in Development Co-operation Profiles, OECD Publishing, Paris, https://doi.org/10.1787/013eabc4-en.

[31] OECD (2023), Declaration on International Investment and Multinational Enterprises, https://legalinstruments.oecd.org/en/instruments/OECD-LEGAL-0144.

[2] OECD (2023), Insights on the Business Climate in Kazakhstan, OECD Publishing, Paris, https://doi.org/10.1787/bd780306-en.

[115] OECD (2022), Annual report on the activity of National Contact Points for Responsible Business Conduct 2021, OECD Publishing, Paris, https://mneguidelines.oecd.org/annual-report-on-the-activity-of-national-contact-points-for-responsible-business-conduct-2021.pdf.

[35] OECD (2022), Recommendation of the Council on the Role of Government in Promoting Responsible Business Conduct, https://legalinstruments.oecd.org/en/instruments/OECD-LEGAL-0486.

[123] OECD (2022), “Responsible business conduct due diligence for project and asset finance transactions”, OECD Business and Finance Policy Papers, No. 14, OECD Publishing, Paris, https://doi.org/10.1787/952805e9-en.

[116] OECD (2022), Responsible Business Conduct in the State-Owned Enterprise Sector in Asia: Stocktaking of National Practices, OECD Publishing, Paris, https://doi.org/10.1787/a68d9977-en.

[7] OECD (2019), Sustainable Infrastructure for Low-Carbon Development in Central Asia and the Caucasus: Hotspot Analysis and Needs Assessment, Green Finance and Investment, OECD Publishing, Paris, https://doi.org/10.1787/d1aa6ae9-en.

[34] OECD (2018), Recommendation of the Council on the OECD Due Diligence Guidance for Responsible Business Conduct, https://legalinstruments.oecd.org/en/instruments/OECD-LEGAL-0443.

[48] OECD (2017), OECD Due Diligence Guidance for Meaningful Stakeholder Engagement in the Extractive Sector, OECD Publishing, Paris, https://doi.org/10.1787/9789264252462-en.

[33] OECD (2016), Recommendation of the Council on the Due Diligence Guidance for Meaningful Stakeholder Engagement in the Extractive Sector, https://legalinstruments.oecd.org/en/instruments/OECD-LEGAL-0427.

[32] OECD (2012), Recommendation of the Council on Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, https://legalinstruments.oecd.org/en/instruments/OECD-LEGAL-0386.

[63] OHCHR (2022), Universal Periodical Review - Mid-Term Report - Kazakhstan.

[109] Open Contracting Partnership (2023), In Kazakhstan, opening up procurement boosts public oversight and prevents millions in wasteful spending, https://www.open-contracting.org/2023/10/30/in-kazakhstan-opening-up-procurement-boosts-public-oversight-and-prevents-millions-in-wasteful-spending/ (accessed on 6 November 2024).

[90] PWC (2024), ESG Awareness in Eurasia, https://www.pwc.com/kz/en/assets/esg-awareness/kz-esg-awareness-eng.pdf (accessed on 18 October 2024).

[96] PWC (2024), ESG Awareness in Eurasia, https://www.pwc.com/kz/en/assets/esg-awareness/kz-esg-awareness-eng.pdf.

[91] Qazaq Green (2023), Qazaq Green Association presents Kazakhstan’s first voluntary carbon standard, https://qazaqgreen.com/en/journal-qazaqgreen/industry-news/1662/ (accessed on 5 March 2025).

[53] Rittmann, M. (2021), A sustained crackdown on independent worker organising – Kazakhstan, a case study, The Foreign Policy Centre, https://fpc.org.uk/a-sustained-crackdown-on-independent-worker-organising-kazakhstan-a-case-study/.

[11] UN (2023), Major step towards Carbon Neutrality in Kazakhstan, https://www.un-page.org/news/major-step-towards-carbon-neutrality-in-kazakhstan/ (accessed on 5 November 2024).

[110] UN (2021), EVALUATION OF THE STATUS OF SUSTAINABLE PUBLIC PROCUREMENT AND LEGAL EXPERT ASSESSMENT, https://www.greenpolicyplatform.org/sites/default/files/SPP%20status%20assessment%20in%20Kazakhstan%20(PPP%20slides%20in%20English).pdf.

[3] UNDP (2024), Human Development Insights, https://hdr.undp.org/data-center/country-insights#/ranks (accessed on 21 October 2024).

[37] UNDP (2024), Key findings - National Baseline Assessment on Business and Human Rights in Kazakhstan 2023.

[58] UNDP (2024), National Baseline Assessment on Business and Human Rights in Kazakhstan 2023 (НАЦИОНАЛЬНАЯ БАЗОВАЯ ОЦЕНКА ПО БИЗНЕСУ И ПРАВАМ ЧЕЛОВЕКА В КАЗАХСТАНЕ 2023).

[68] UNDP (2024), UNDP launches project to integrate climate adaptation into strategic planning in Kazakhstan, https://www.undp.org/kazakhstan/press-releases/undp-launches-project-integrate-climate-adaptation-strategic-planning-kazakhstan (accessed on 12 December 2024).

[40] UNDP (2023), UNDP has announced the results of a National Baseline Assessment on Business and Human Rights conducted in Kazakhstan, https://www.undp.org/kazakhstan/press-releases/undp-has-announced-results-national-baseline-assessment-business-and-human-rights-conducted-kazakhstan (accessed on 5 November 2024).

[106] UNECE (2019), Environmental Performance Reviews Kazakhstan, https://unece.org/sites/default/files/2021-08/ECE_CEP_185_Eng_0.pdf.

[70] UNECE (2019), Revised Guidelines on Environmental Impact Assessment in a Transboundary Context for Central Asian Countries, https://unece.org/sites/default/files/2021-03/1912547E_web_0.pdf.

[44] UNGC (2024), Kazakhstan, https://unglobalcompact.org/engage-locally/asia/kazakhstan (accessed on 11 December 2024).

[56] US Department of Labor (2024), Child Labor and Forced Labor Reports - Kazakhstan, https://www.dol.gov/agencies/ilab/resources/reports/child-labor/kazakhstan (accessed on 13 December 2024).

[114] US Trade (2022), Kazakhstan - Country Commercial Guide, https://www.trade.gov/country-commercial-guides/kazakhstan-environmental-technologies (accessed on 5 November 2024).

[71] WECOOP (2021), Kazakhstan Environmental Code now available in English, https://wecoop.eu/kazakhstan-environmental-code-in-english/.

[4] World Bank (2024), GNI per capita (constant 2015 US$) - Kazakhstan, https://data.worldbank.org/indicator/NY.GNP.PCAP.KD?locations=KZ (accessed on 9 December 2024).

[13] World Bank (2023), Connecting to Compete: Trade Logistics in the Global Economy, https://lpi.worldbank.org/report.

[75] World Bank (2023), Global Methande and Flaring Regulations - Kazakhstan, https://flaringventingregulations.worldbank.org/kazakhstan (accessed on 4 March 2025).

[103] World Bank (2023), Kazakhstan Energy Sector Strategic Engagement P180209 - Power System Analysis to Support Clean Energy Development Strategies for Kazakhstan, https://documents1.worldbank.org/curated/en/099120123032522626/pdf/P18020904c0bd3052083be048479896c1b7.pdf.

[29] World Bank (2023), Mining Sector Diagnostic, https://documents1.worldbank.org/curated/en/099081823001539573/pdf/P17674501063760b08b290a4ae6547845d.pdf.

[74] World Bank (2022), A Decade of Stalled Progress on Reducing Global Gas Flaring, https://www.worldbank.org/en/news/press-release/2022/05/04/a-decade-of-stalled-progress-on-reducing-global-gas-flaring (accessed on 4 March 2025).

Note

← 1.  See https://e-tutynushy.kz/.