Compliance and Anti-Corruption

31.10.2017 Object of internal analysis of corruption risks: activities of the payment card department of the JSC “National payment corporation of the National Bank of the Republic of Kazakhstan” (hereinafter referred to as the division). Internal analysis of corruption risks was carried out in accordance with the Standard Rules for Conducting Internal Analysis of Corruption Risks, approved by Order №12 of the Chairman of the Agency of the Republic of Kazakhstan for Civil Service Affairs and Anti-Corruption dated October 19, 2016, by the working group on the basis of the order of the Director General of the JSC “National payment corporation of the National Bank of the Republic of Kazakhstan” (hereinafter – NPC) dated September 04, 2017 №123/1-P. 

1.Identification of corruption risks in regulatory legal acts affecting the activities of the unit.

The Division carries out its activities in accordance with the Civil Code of the Republic of Kazakhstan, the Laws of the Republic of Kazakhstan “On the National Bank of the Republic of Kazakhstan”, “On State Property”, “On payments and payment systems”, Decree of the President of the Republic of Kazakhstan dated December 31, 2003  №1271 “On approval of the Regulations and Structure of the National Bank of the Republic of Kazakhstan”. The Working Group studied regulatory legal acts affecting the activities of the unit. According to the results of the analysis of discretionary powers and norms that contribute to the commission of corruption offenses, it was not revealed.

2. Identification of corruption risks in the organizational and managerial activities of the unit.

In the organizational and managerial activities of the unit, the following areas were subjected to internal analysis:

1. personnel management, including staff turnover: The staffing at the beginning of the analysis was 4 people. At the end of the analysis – 4 people. During the study period, the turnover of personnel has not been established;
2. conflict of interest settlement: no conflicts of interest have been identified;
3. provision of public services: the subdivision does not provide public services;
4. implementation of licensing functions: there are no licensing functions in the subdivision;
5.  implementation of control functions: there are no control functions in the subdivision.

There have been no inspections carried out by State bodies in relation to the activities of the unit. The monitoring of the mass media was carried out to identify negative materials regarding the unit. No negative materials were identified during the study period. There were no appeals to the unit from individuals and legal entities. There were no acts of prosecutorial supervision. There were no judicial acts. Based on the above, we inform you that according to the results of an internal analysis of corruption risks, no corruption risks have been identified in the activities of the unit.

I. Introductory part

The object of internal analysis of corruption risks: the activities of the department of the certification center of the JSC “National payment corporation of the National Bank of the Republic of Kazakhstan” (hereinafter – CC) for the provision of services of the certification center. Internal analysis of corruption risks was carried out in accordance with the Standard Rules for Conducting Internal Analysis of Corruption Risks, approved by Order №12 of the Chairman of the Agency of the Republic of Kazakhstan for Civil Service Affairs and Anti-Corruption dated October 19, 2016, by the working group on internal analysis of corruption risks (hereinafter referred to as the working group) on the basis of the order of the Director General of the JSC “National payment corporation of the National Bank of the Republic of Kazakhstan” (hereinafter referred to as the NPC) dated June 19, 2018 №48-P. The period of the analysis of corruption risks: 4th quarter of 2018

II. Information and analytical part

Internal analysis of corruption risks is carried out by the working group in the following areas:

1) identification of corruption risks in regulatory documents affecting the activities of the CC;

2) identification of corruption risks in the organizational and managerial activities of the Management Center (personnel management, conflict of interest resolution, provision of services, implementation of licensing and control functions, organization and conduct of procurement, other issues arising from the organizational and managerial activities of the Management Center).

As sources of information for the internal analysis of corruption were used:

1) regulatory documents affecting the activities of the UC department;

2) the results of inspections previously conducted by state bodies in relation to the CC;

3) publications in the mass media;

4) appeals of individuals and legal entities;

5) results of customer surveys;

6) other information, the provision of which is allowed by the legislation of the Republic of Kazakhstan.

The CC carries out its activities to certify the compliance of the public key of the electronic digital signature with the private key of the electronic digital signature, as well as to confirm the authenticity of the registration certificate in accordance with the Charter of the NPC. The CC does not carry out licensing and control functions in its activities. Conflict of interest settlement is carried out by direct independent subordination of the CC to the Deputy Director General of the NPC. The full-time number of the CC at the beginning of 2018 is 6 people, the current number is 6 people. One of the employees of the Management Center was transferred to another department, there are no dismissed employees. The head and employees of the CC have no relatives in the structure of the National Bank. According to the results of the analysis of corruption risks, there were no discretionary powers and norms contributing to the commission of corruption offenses in the documents affecting the activities of the CC. In 2018 A survey of the CC was conducted by the Commission on accreditation of certification centers of the Telecommunications Committee of the Ministry of Information and Communications of the Republic of Kazakhstan, within which the main tasks and functions of the CC, technical and operational characteristics of the solution, ensuring the information process, ensuring information security were analyzed. The result of the survey was a conclusion on compliance with technical requirements, sufficiency for the organization in the CC services market and the issuance of an accreditation certificate of the certification center №3 dated 23.04.2018. There were no acts of prosecutorial supervision and judicial acts. Negative reviews and publications about the activities of the CC in the media were not revealed. In 2018, an appeal of an individual was registered, which was in the nature of claims against the activities of the CC. Upon the fact of this appeal, an internal investigation was conducted, an individual was provided with a response with explanations regarding the method of interaction between the CC, second-tier banks and second-tier bank customers.

Based on the results of the survey of the clients of the NPC conducted in order to determine the level of satisfaction with the quality of the services of the NPC, the need of clients to improve the quality level, transparency of the services provided by the CC and the level of feedback, in such areas as:

1) increasing the processing speed and normalization of the operability of the services provided by the control center;

2) timely notification of customers about interruptions in work (about planned work and failures in work);

3) increasing the level of feedback on the quality and timing of responses, ensuring automatic registration of incoming requests;

4) training, raising the level of awareness of clients on working with NPC systems. As part of the analysis of procurement activities, the correctness of the organization of the procurement process for goods, works and services was confirmed, including the justification of the procurement method and the availability of documents confirming the choice of the procurement method; compliance of the procurement with the approved procurement plan for goods, works and services. Violations in the procurement carried out in the period 2017-2018 for the implementation of its activities by the department of the Management Center were not allowed. Based on the results of the 2018 inventory there were no shortages of fixed assets and intangible assets, as well as discrepancies in the actual availability of property with accounting data in the department of the Management Center.

III. Recommendations

To continue the implementation of measures aimed at increasing the level, transparency of the services provided by the CC, and the level of feedback from users: 1) Implement a new application software of the CERTEX CMS Management Center; 2) Participate in the implementation of a software solution for the ServiceDesk system; 3) Provide training events aimed at raising customer awareness.

I. Introductory part

The object of internal analysis of corruption risks: the activities of the Department of operational and technical support of the JSC “National payment corporation of the National Bank of the Republic of Kazakhstan” (hereinafter – MOTS). Internal analysis of corruption risks was carried out in accordance with the Standard Rules for Conducting Internal Analysis of Corruption Risks, approved by Order №12 of the Chairman of the Agency of the Republic of Kazakhstan for Civil Service Affairs and Anti-Corruption dated October 19, 2016, by the working group on internal analysis of corruption risks (hereinafter referred to as the working group) on the basis of the order of the Director General of the JSC “National payment corporation of the National Bank of the Republic of Kazakhstan” (hereinafter referred to as the NPC) dated July 12, 2019 №43-P. The period of the analysis of corruption risks: 4th quarter of 2019

II. Information and analytical part

Internal analysis of corruption risks was carried out by the working group in the following areas: identification of corruption risks in regulatory documents affecting the activities of the MOTS identification of corruption risks in the organizational and managerial activities of the MOTS (personnel management, conflict of interest resolution, provision of services, implementation of licensing and control functions, organization and conduct of procurement, other issues arising from the organizational and managerial activities of the MOTS). The following information sources were used for internal analysis of corruption: regulatory documents affecting the activities of the UTO; results of inspections previously conducted by state bodies; publications in the media; appeals of individuals and legal entities; results of customer surveys; other information, the provision of which is permitted by the legislation of the Republic of Kazakhstan. In accordance with the Charter of the NPC and the Regulations on the MOTS, the main tasks of the MOTS are: organization and implementation of measures for operational support of payment and other systems; organization of measures to improve the technical and operational reliability of payment and other systems; ensuring the operability of the software and hardware complex of payment and other information systems, telecommunications and communications systems, network and communication equipment; ensuring the operability of air conditioners, office ATE, uninterruptible power supply systems; ensuring the uninterrupted operation of the technical equipment of the employees of the NPC; purchase and commissioning of new equipment and technical means; information support for users of payment and other systems; providing feedback to consumers. MOTS does not carry out licensing and control functions in its activities. Conflict of interest settlement is carried out by direct independent subordination of the MOTS to the Deputy Director General of the NPC. The full-time number of MOTS at the beginning of 2019 is 17 people, the current number is 16 people. Two employees were transferred from the UOT to other units of the NPC, one employee was transferred to the MOTS from another unit of the NPC at his own request, there are no dismissed employees. UOTO employees have relatives in the structure of the National Bank of the Republic of Kazakhstan, but they are not directly subordinate to them. There are no facts of affiliation in the procurement process. According to the results of the analysis of corruption risks, there were no discretionary powers and norms contributing to the commission of corruption offenses in the documents affecting the activities of the MOTS. In 2019 The Department of Payment Systems of the National Bank of the Republic of Kazakhstan conducted an inspection (verification) of the organization and functioning of payment systems (hereinafter – verification): the Interbank Money Transfer System (hereinafter – IMTS) and the Interbank Clearing System (hereinafter – ICS), during which the following issues were considered: analysis of technical documentation, the functioning of the IMTS, the functioning of the ICS, analysis of information received from the operational center on payments and (or) money transfers. According to the results of the audit on the main issues of the organization and maintenance of the functioning of the IMTS and ICS, there were no inconsistencies with the requirements of the legislation of the Republic of Kazakhstan on payments and payment systems. At the same time, recommendations were issued aimed at finalizing payment systems in terms of expanding control when parsing payment messages, unifying the features of a payment instrument, as well as updating internal regulatory documents on business continuity. There were no acts of prosecutorial supervision and judicial acts. Negative reviews and publications about the activities of the MOTS in the media were not revealed. Business relations with clients and their satisfaction management are carried out within the framework of meetings, customer surveys, organization of feedback, analysis of complaints and customer requests, planning improvements. According to the results of the survey conducted in 2019, the need of customers was identified in such areas as: timely notification of customers about planned work, interruptions and delays in work; elimination of errors, improvement of systems; increasing the level of feedback; reduction of tariffs for a number of NPC services. A summary table based on the results of the survey is posted on the NPC Internet resource. Based on the results of the analysis of the survey results by the heads of the interested departments of the NPC, comments and suggestions were submitted to the management of the NPC for consideration (memo №4601-33-06/194 dated 28.03.2013). The results of the survey were discussed with clients at a round table at the annual meeting held by the NPC on October 24, 2019. Purchases of NPCare carried out in accordance with the Rules for the Purchase of Goods, Works and Services by the National Bank of the Republic of Kazakhstan, its departments, organizations that are part of its structure, and legal entities, fifty or more percent of the voting shares (participation shares in the authorized capital) of which belong to the National Bank of the Republic of Kazakhstan or are in its trust management, and legal entities affiliated with them, approved by Resolution №192 of the NB RK Board dated August 27, 2018 (hereinafter referred to as the Rules). The share of MOTS purchases in the approved amount of the procurement plan in 2019 It is 40.5% of the total volume of purchases of the NPC. The execution of the procurement plan for MOTS at the moment is 87.6%. For the purposes of fair competition and optimal and efficient spending of money, the procurement of MOTS was carried out by competitive methods in accordance with the requirements of the Rules by means of a tender and a request for price proposals, which resulted in savings in the procurement plan. As part of the analysis of procurement activities, the correctness of the organization of the procurement process of goods, works and services, including justification of the procurement method and the availability of documents confirming the choice of the procurement method; compliance of the conducted purchases with the approved procurement plan for goods, works and services. According to the results of monitoring the procurement of goods, works and services under the 2019 procurement plan, no violations were allowed in the procurement of MOTS, no complaints were received from potential suppliers about the procurement procedures. During the tender procedures for the procurement of network equipment maintenance services in April 2019 an officially registered appeal of the legal entity “NEWTECH DISTRIBUTION” LLP (ex. №105 dated 22.04.2019) was received with a proposal to make adjustments to the technical specification. According to the specified request, a reasoned and motivated response was provided by the NPC within the established time limits, containing explanations on the merits of the appeal (ex. №4601-27-01/346 of 26.03.2019, №4601-23-05/481 of 24.04.2019). According to the results of the inventory of 2019. There were no shortages of fixed assets and intangible assets, as well as discrepancies in the actual availability of property with accounting data.

III. Recommendations

To continue the implementation of measures aimed at improving the activities of the NPC, improving the quality and transparency of the services provided. To develop a customer relationship management process in the NPC to increase the level of feedback with them on emerging issues and suggestions, to continue the practice of discussing existing problems at annual meetings with clients organized by the NPC. In order to conduct an extended analysis of the prevailing prices on the market for equipment and software for payment and other systems, when planning the budget, the NPC should request price proposals from three or more potential suppliers, which should include the winner of a similar (homogeneous) purchase conducted earlier.