We continue to summarize the results of the activities of the departments and divisions of Almalyk MMC JSC in 2024. Today we give the floor to the acting head of the compliance service (CS) Shukhrat ZHURAYEV.

Investigative Committee: purpose and objectives

- Our service was established in May 2021. The main objective of the Investigative Committee is to ensure compliance with the legislation of the Republic of Uzbekistan on combating corruption and monitoring the implementation of measures in this area. The main objective of the Investigative Committee is to introduce effective and efficient tools for preventing corruption and fraudulent offenses, as well as the effective implementation of a system of measures to combat these violations.

In January 2022, the President of Uzbekistan signed the Resolution "On measures to implement a rating system for assessing the effectiveness of anti-corruption work." It is aimed at analyzing and evaluating the effectiveness, as well as eliminating the shortcomings of measures to combat corruption in government agencies and state-owned companies.

The rating assessment is based on 29 indicators in five areas: the creation and implementation of mechanisms and legal frameworks for combating corruption in government organizations (maximum score - 35); the implementation of measures to identify, assess and reduce corruption risks (30 points); the presence of actions by heads of government organizations that demonstrate an uncompromising attitude towards corruption (15 points); employee awareness of internal anti-corruption procedures, implementation of measures to improve knowledge and skills in this area (15 points); the effectiveness of propaganda activities aimed at raising legal awareness and legal culture among the population in combating corruption, the formation of an uncompromising attitude towards this negative phenomenon, in the context of the relevant sphere or industry (5 points).

The effectiveness of anti-corruption work is assessed in a rating from 0 to 100 points based on quarterly and annual reports provided by compliance services and is divided into the categories of “good”, “satisfactory” and “unsatisfactory”.

New heights ahead

- JSC Almalyk MMC has already participated in this rating twice - in 2022 and 2023 - and received a “satisfactory” rating. In September 2024, during a special meeting devoted to issues of combating corruption in the complex system, the Chairman of the Board set the task of raising the bar and receiving a “good” rating. For this, the compliance service carried out certain work. According to preliminary calculations and forecasts for 2024, the complex has significantly improved its position in the rating and will be able to score more than 90 points out of a possible 100.

In particular, when preparing the reports, we worked closely with the anti-corruption services of those enterprises that are in the group of leaders in the rating, in addition, specialists from Alfakon Systems LLC helped us in compiling the annual report in accordance with international requirements and standards. And most importantly, all divisions of the enterprise tried their best in the practical implementation of the measures outlined in the state Program.

Another important task set by the AMMC management is the implementation of the International Standard ISO 37001:2016 "Anti-bribery management system" and obtaining the corresponding international certificate. This will significantly enhance the complex's reputation in the international arena, enter new markets, attract foreign direct investment on preferential terms, etc., since the international standard ISO 37001:2016 helps organizations develop, implement, maintain and improve anti-corruption management systems regardless of the country in which they operate.

By implementing the ISO 37001:2016 standard, the company demonstrates to its partners, government agencies and other stakeholders that it takes adequate and proportionate decisions to prevent, detect and take effective and efficient measures against corruption in accordance with international standards.

In preparation for certification, over the past year, together with Alfakon Systems LLC, we prepared a large package of documents, conducted an audit in almost all divisions of the complex, trained about twenty top managers from among the company's officials holding positions susceptible to corruption, and together with the divisions, identified deficiencies and non-compliance with the requirements of the international standard were eliminated. We developed new materials and also finalized all the necessary documents. Based on the results of the enormous and painstaking work, we expect to receive the certificate in the first quarter of 2025. The technical specifications for hiring the Certification Authority have already been approved and a tender for the selection of the best offer will be announced soon.

Corruption must be eradicated!

- As part of the propaganda of zero tolerance for corruption, an anonymous survey was conducted among the employees of the enterprise on the Internet platforms of JSC Almalyk MMC in 2024. More than 20 thousand people took part in it, and I am sincerely grateful to them for their honesty, concern and responsiveness.

The respondents shared their opinions on what methods of preventing and combating corruption they consider the most effective, what type of corruption crimes are most common at AMMC, where to go in cases of detection of corruption and much more. There were about twenty such survey questions.

As the survey analysis showed, more than 60% of respondents have encountered cases of corruption in the complex system, 40% believe that criminal punishment should be applied to corrupt officials to the fullest extent of the law, 25% think that the problem can be eradicated by increasing the wages and material incentives of employees, 13% see the solution to the problem by ensuring transparency, accountability and maximum digitalization of all types of complex activities (elimination of the human factor), 11% proposed to further improve criminal legislation by tightening liability for committing corruption crimes.

During the survey, 65 proposals were also received aimed at suppressing corruption in the AMMC system. 27 of them were approved by the Anti-Corruption Agency of the Republic of Uzbekistan and will be implemented throughout the country.

Results of 2024

- Every month, we post various information on the AMMC Internet platforms to inform the employees of the enterprise: about innovations in legislation, about communication channels for reporting corruption at the complex.

In addition, there is a group of like-minded people of the compliance service of JSC Almalyk MMC in the Telegram messenger, where employees and the politically active part of the population regularly and very actively discuss issues and measures to combat corruption taken at the complex.

During 2024, propaganda events were held in the AMMC divisions, prepared both by the teams themselves and on the initiative of the compliance service.

Thus, in 2024 alone, the Investigative Committee conducted more than 60 explanatory and preventive events, at which we talked about what regulatory and departmental documents have been adopted in the republic and at AMMC to combat corruption, and what to do if you or your loved ones are extorted for a bribe. For example, our service receives a signal about corrupt actions, which we process for relevance, and then forward it to the special prosecutor's office, special police, and the Anti-Corruption Agency of the Republic of Uzbekistan for action. However, we are also contacted on other issues: for example, personal ones. This is no longer within our competence. We send such statements and messages to other divisions of the complex for their consideration.

Currently, the Department of Administrative and Social Work is producing banners with calls for cooperation against corruption, which will indicate the communication channels for requests. They will be placed in all crowded places of the complex's divisions.

In 2024, together with the complex's training center, about ten specialized training courses were organized to improve the qualifications of officials of the divisions responsible for compliance control and anti-corruption. About 200 top managers of AMMC have already completed training at these courses.

The complex carried out very important anti-corruption work in terms of prevention: in May 2024, based on the "Methodology for identifying and assessing corruption risks in the activities of organizations with a state share of more than 50%", an assessment of 279 functions and tasks of JSC Almalyk MMC was carried out for their susceptibility to committing corruption crimes.

Based on the assessment results, 269 of these functions were recognized as having an acceptable (low) level, 2 - average and 8 - high. Based on the results, the Chairman of the Board approved the List of functions and positions most susceptible to corruption risks, as well as the "Roadmap of the complex for reducing and / or eliminating identified corruption risks".

It should be noted that, based on the results of the corruption risk assessment, 24 positions have a high, 35 have a medium, and 10 have a low risk of corruption.

In 2023, together with the audit organization Ernst & Young Advisory LLC, we prepared a report on the state of affairs in combating corruption at AMMC, conducted an audit, and identified deficiencies. Some departmental documents on combating corruption were prepared, and some were partially updated and approved by the Supervisory Board.

All current local regulatory documents of the complex on combating corruption are posted at the link https://agmk.uz/oz/menu/korrupsiyaga-oid-hujjatlar.

The total number of already approved and current documents as of January 1 of this year is 19.

Announcements of vacant positions, resume submissions, and upcoming exams in AMMC divisions are posted on all Internet platforms on an ongoing basis. This process is under the constant control of the compliance service and the chairman of the board. Exams, selections, tests, interviews for vacant positions are recorded on video camera. In 2024, the number of such announcements in the Telegram channel was more than 90.

By the decision of the Sole Shareholder (Ministry of Economy and Finance) in August 2024, the name of the service was changed: instead of the compliance control service, it is now called the compliance service. And most importantly, its legal status was increased: if earlier the service was subordinate and accountable to the chairman of the board, now it is accountable to the Supervisory Board of JSC Almalyk MMC. In addition, the staff of the SC was increased from three to six units.

Dear colleagues, employees of the complex, if you are honest and decent, confident in yourself and your knowledge, and most importantly, you have an unwavering desire to eradicate corruption in any of its manifestations in the complex system, then this is the opportunity for you: to work in a team of professionals and like-minded people of the compliance service after successfully passing an open competitive selection.

Taking this opportunity, I would like to thank and note our first assistants for the timely and high-quality preparation of reports, materials on a regular basis. This is the team of the information service website represented by web editor Sanobar Avazova, employees of the department for control and coordination of appeals from individuals of the central office (chief Abror Kamilov), the department of material and technical supply (chief Bakhodir Yuldashev, leading engineer Farrukh Sabirov).

I would like to call on all workers of the Almalyk Mining and Metallurgical Complex - from managers to ordinary workers - to be intolerant of corruption and not to stand aside! Only together and by combining our efforts, we can eradicate this phenomenon!