The material which summarized the activities of the compliance service of JSC “Almalyk MMC” for 2024 interested our readers, who consider corruption to be the enemy of society and the country's development. In addition, they asked the head of the compliance service Shukhrat JURAYEV to answer questions that arose while reading the material.

- Shukhrat Kholbaevich, what do the top managers and compliance officers do?

- The top managers at the enterprise are officials responsible for compliance control and combating corruption: the Chairman of Board, his deputies, members of the board, top managers of subdivisions...

Compliance officers are the staff of the compliance service who coordinate the implementation of the legal requirements system and monitor their implementation at the enterprise. This position is for those who have analytical and critical thinking. In our service, it is occupied by those who have passed the interview and testing, as well as the corresponding check according to the International Standard ISO 37001:2016 "Anti-bribery management system".

The responsibilities of compliance officers include standardization of internal compliance procedures; regular audit and verification of compliance of activities with all standards of anti-corruption, tax, antitrust, sanctions and other legislation; organization of the process of developing a local regulatory framework; reviewing received letters and reports of violations, conducting an investigation, taking measures to eliminate the consequences and prevent the occurrence of such risks in the future; training personnel in the principles of working according to the compliance system and improving the legal culture and legal awareness of the plant's employees.

- Were any cases of bribery found out at AMMC last year?

- We have not recorded any cases of bribery under Criminal Code Articles 210 (accepting a bribe), 211 (giving a bribe), 212 (mediation in bribery) at AMMC in 2024.

I would like to draw attention to the fact that many people believe that corruption is only bribery. But this is far from the case. Corruption is the illegal use by a person of his/her official or service position in order to obtain material or non-material benefits in personal interests or in the interests of other persons, as well as the illegal provision of such benefits. The most common manifestations of corruption are offenses such as fraud, abuse of official powers or exceeding them, bribery, and official forgery.

I would also like to remind you that in December 2020, the Cabinet of Ministers of the Republic of Uzbekistan adopted the Resolution "On Approval of the Regulation on the Procedure for Rewarding Persons Who Reported Corruption Offenses or Otherwise Assisted in the Fight against Corruption." This Regulation determines the procedure for rewarding persons who reported corruption offenses or otherwise assisted in the fight against corruption, in accordance with the Law of Uzbekistan "On Combating Corruption", and also determines the amount of the reward. It should be noted that a similar practice is widely used in many advanced foreign countries at the level of government agencies, as well as on the initiative of companies. This system is called "Whistleblowing policy".

- If a bribe is extorted from an employee of the Almalyk Mining and Metallurgical Complex not at the Plant, but at other institutions, organizations or enterprises, can he/she contact the compliance service of JSC Almalyk Mining and Metallurgical Complex?

- Of course, you can contact us in any cases of corruption. All requests will be forwarded to the compliance services of the relevant ministries and departments, as well as to the Anti-Corruption Agency to monitor the adoption of measures.

- There was information in the Internet that, at the initiative of the head of the Anti-Corruption Agency, all Uzbek civil servants will be tested for corruption using a lie detector starting March 1, 2025. It is also reported that, based on the analysis, officials will be fired or criminal cases will be opened...

- Of course, this is a very good idea and it should be implemented accordingly: openly, transparently, with mandatory video recording. After all, the constitutionally guaranteed human right to the presumption of innocence is at stake.

The public discussion of the draft Presidential Decree on the approval of the State Program for 2025 is currently underway, which includes a proposal on the need for mandatory corruption testing of at least 500 officials.

I will note that the plant's compliance service is constantly carrying out certain work. In particular, on December 6 last year, the Law of the Republic of Uzbekistan "On Conflict of Interest" came into force, regulating relations in situations in which personal interest affects or may affect the proper performance of official or service duties by a person and in which contradictions arise or may arise between personal interest and the rights and legitimate interests of citizens, an organization, society or the state.

According to the Appendix No. 3 of the Resolution of the Cabinet of Ministers of Uzbekistan "On approval of regulatory legal acts on the implementation of the Labor Code of the Republic of Uzbekistan" dated November 14, 2024, the List of categories of employees of state organizations who may be allowed exceptions to the rules of restriction on joint work of relatives was approved.

Taking into account the above-mentioned arguments and reasons, the Chairman of Board of JSC “Almalyk MMC” decided to initiate the development of a draft resolution of the Cabinet of Ministers on amendments to this list and inclusion of employees of enterprises of the mining and metallurgical industries and geology in the above-mentioned category. Currently, the draft regulatory legal act is undergoing the approval procedure on the project.uz platform with interested ministries and departments of the republic. In addition, documents are being prepared, in particular, the Concept of the project, as well as technical and economic calculations of the investment project for the capital reconstruction of the city pool. This is a socially significant investment project to attract foreign direct investment for its reconstruction based on public-private partnership mechanisms.

Taking this opportunity, I would also like to note that in order to improve the legal literacy of citizens of Uzbekistan, the Ministry of Justice has developed the legal chatbot LexAI (https://ai.lex.uz/).

This project was implemented free of charge, without any expenses from the state budget. At the moment, the first function of the chatbot has been launched – prompt answers to legal questions. The following functions will be launched soon: examination of draft documents – the ability to online analyze draft legislative documents; analysis of law enforcement practice; preparation of draft documents.

This project is important because the National Database of Legislation contains more than 48 thousand documents, of which over 34 thousand are valid, and more than 5700 documents providing for changes and additions.

The chatbot is currently in test mode and is being tested by expert lawyers. It will be available to everyone very soon.