On implementation of the Resolution No. PQ-81:

At the end of 2024, the effectiveness of the anti-corruption system implemented at the Complex was adequately assessed.

For example, according to the results of the assessment of the performance of indicators in 5 areas and 29 special indicators at the Complex, JSC “Almalyk MMC” for the first time in the Efficiency Rating scored a total of 85 points out of 100 points, and for the first time in its history, it managed to move to the “Green” (good) group.

At the same time, with the growth rate of 21 points (at the end of 2023, the Complex scored only 64 points, and at the end of 2022, it scored only 68 points), and in the 2024 ranking, it ranked 11^th for the first time among 102 republican ministries, departments and organizations (at the end of 2023, the Complex ranked only 69^th, and at the end of 2022, it ranked 23^rd).

On the implementation of Resolution No. PQ-240:

In January 2025, the level of corruption susceptibility of all functions and tasks specified in the Charter of JSC “Almalyk MMC” was assessed.

The number of functions and tasks with a high level of corruption susceptibility at the Complex was reduced from 21 to 3 compared to the previous year 2024.

• As a result of the consistent preparatory work carried out by Joint Stock Company “Almalyk Mining and Metallurgical Complex” for the past two years, in May-June 2025, the Complex's anti-corruption management systems passed the external impartial audit, and on 30 June of this year, the Certification Body “Management Certification” LLC awarded it with the ISO 37001:2016 International Certificate confirming compliance with the requirements of the international standard ISO 37001:2016 “Anti-Corruption Management System”, as well as the National Certificate UzDSt ISO 37001:2019/ISO 37001:2016.
• Education and Communication

By the order No. 1475 of JSC “Almalyk MMC” dated 18 August 2025, and by the order No. 01599 of 28 August, a total of 33 training courses on the subject of "Fighting Corruption and Managing Conflicts of Interest" were organized by specialists of the "Center for Advanced Training of Lawyers under the Ministry of Justice of the Republic of Uzbekistan" for a total of 66 employees of the Complex (two days – 12 hours).

Newly hired employees of JSC “Almalyk MMC” are regularly trained by the Complex Training Center on the Anti-Corruption Management System within the framework of the "Welcome Training" program.

• In order to ensure the implementation of the order of the Chairman of the Board of JSC “Almalyk MMC” dated 30 November 2024, the draft Resolution "On adding to the List of employees of state organizations who may be exempted from the Rules on restricting the work of relatives together, approved by the Resolution of the Cabinet of Ministers No. 758 dated 14 November 2024", developed by the Compliance Service, was approved on 30 June 2025 by Resolution No. VMQ-400.

What benefits does this Resolution provide to ordinary workers and employees of the Complex?

First of all, it is necessary to pay attention to one aspect. The scope of the Exceptions Rules established by the Resolution VMQ-400 applies only to employees belonging to the category of workers and office personnel, and the share of employees in this category is approximately 70-75 percent of the total number of employees of the Complex.

It is worth noting separately that the “Exceptions Rules” established by the Resolution does not apply to officials included in the categories of “Administrative, management and engineering-technical personnel”, the central office employees, as well as procurement, sales, chief accountant, accountant, HR staff, warehouse workers and materially responsible officers, and all restrictions and prohibitions regarding conflict of interest and the joint work of relatives established by labor legislation will continue to apply in full.

Adoption of the Resolution of the Cabinet of Ministers No. VMQ-400 dated 30 June 2025 serves as a legal solution to the following acute problems facing the Complex:

In particular,

- in organizing the implementation of the Law "On Conflict of Interest", ensuring unconditional compliance with the rights and interests of workers and office personnel of "mining and metallurgical industry enterprises", as well as highly qualified specialists in the field;

- serves to timely and fully satisfying the needs of "mining and metallurgical industry" enterprises for highly qualified workers, office staff and specialists.

The resolution guarantees the right of workers and employees of large industrial enterprises of strategic importance, such as JSC “Almalyk MMC”, JSC “Navoi MMC”, SE "Navoiyuran", JSC “Oʻzmetkombinat”, and “Oʻzbekkoʻmir” JSC, to work freely at an enterprise located in the territory where they, their descendants and their ancestors have lived.

Monitoring and Control

In 2025 (from January 1 to November 15), a total of 18 service inspections were conducted with the participation of the Compliance Service, the employment contracts with 2 (two) employees of the Complex were terminated, and disciplinary measures were applied to 9 (nine) employees.

The identified violations and measures to eliminate them

During the reporting period, the amount of damage caused to the interests of the Complex was 1.114 million UZS (one billion one hundred fourteen million) UZS. The full amount of damage was recovered from the guilty parties.

As of 1 December 2025, the Compliance Service had 6 staff positions, and 5 (five) employees were working actually.

    S.X.Jurayev,

Head of Compliance Service of JSC “Almalyk MMC”