Let's Unite for Honesty and Justice!

Assalomu aleikum, dear employees and managers of Almalyk Mining and Metallurgical Complex, dear business partners!

In recent years, especially with the new administration, preventing and combating corruption has become not only the state policy, but also the matter of conscience for every organization and every citizen.

Because corruption hinders development of the society and the state, steals the bright future, undermines the principles of justice and honesty and undermines the trust in the state and its agencies.

That is why the uncompromising fight against this evil has risen to the level of state policy under the direct leadership of the Head of State.

Systematic and purposeful work is also being carried out in this direction at Almalyk Mining and Metallurgical Complex.

For example, five years ago, in May 2021, the Compliance Department was established in the organizational structure of the Complex.

The Compliance Department was staffed with young personnel of high qualifications and experience, with special talents, as a result of competitive selection and tests conducted jointly with the Agency's specialists.

The Compliance Department, in close cooperation with the relevant departments of the Complex, developed 19 most important internal local documents aimed at organizing the systematic fight against corruption, agreed with the interested ministries and departments, approved by the Supervisory Board, and posted on the Complex official website in English, Russian and Uzbek for free and open access by everyone.

In addition, particularly commendable legislative initiatives were put forward at the Complex to manage conflicts of interest, and ultimately, the new clause 18 was added to the “List of employees of state organizations who may be exempted from the rules on restricting the joint work of relatives", approved by the Appendix 3 to the Resolution of the Cabinet of Ministers No. 758 dated 14 November 2024.

It is worth noting that the clause 18 included in the “List of Exceptions” approved by the Resolution of the Cabinet of Ministers, gave the right to use the privileges established by the law not only to employees of the Complex, but also to all workers and officers working in the mining and metallurgical industry.

According to the results of the year 2025, the Complex anti-corruption activities were highly appreciated by the Anti-Corruption Agency and independent experts, and the “Efficiency Rating” achieved 89 points out of 100 possible. This is an increase of 4 points compared to the previous year. Most importantly, this indicator evidences that the culture of honesty, openness and accountability is increasingly strengthened at the Complex.

The work to identify and eliminate corruption risks also covered all the divisions and structural enterprises of the Complex.

For example, 66 functions and tasks in the Complex activities and their level of corruption susceptibility were carefully assessed in close cooperation with the Agency's specialists.

It should be noted that, according to the results of the assessment, the level of corruption risks and dangers in most of the functions and tasks of the Complex was noted as low.

As a result of the assessment, the Anti-Corruption Program of the Complex, Corruption Risk Map, and Lists of Corruption-Prone Positions were approved and uploaded to E-anticor.uz platform. At the same time, the measures set out in the Program and the Map to eliminate the identified risks and dangers are being consistently implemented.

Another important aspect of the management system created at the Complex and its constituent enterprises is that it is primarily focused on people, and especially on the plant's employees.

That is why the highest goal is to raise the legal awareness and culture of the Complex's engineering and technical personnel, senior and junior managers, workers and employees, strengthen their anti-corruption knowledge and, ultimately, create an environment in which corruption of any kind and form is completely intolerant at the Complex.

About a thousand engineering and technical personnel and managers of the Complex are regularly trained in specialized and general training courses organized by the prestigious educational institutions of our country, such as the Law Enforcement Academy, the Center for Advanced Training of Lawyers, the Virtual Academy, and qualified specialists of the Anti-Corruption Agency, and the skills and knowledge of employees are systematically improved.

Ensuring transparency, accountability and a fair competitive environment in the Complex's procurement process is one of the top priorities of the managers responsible for this area and the Compliance Department, and is constantly monitored as the most pressing issue on the agenda of the Complex's management.

It is worth noting that as a result of the procurement procedures carried out at the Complex annually, an average of more than 10 thousand agreements and contracts with a total value of 1.5 billion USD are signed.

Therefore, based on advanced international experience, any future partners and counterparties of the Complex are subject to an impartial examination based on the “Due Diligence Rules” in accordance with Article 15 of the Tax Code.

For this purpose, the separate new Section 7 “Anti-Corruption Rules”, has been introduced into all contracts and agreements of the Complex.

Procurement participants are subject to a comprehensive examination based on the “Forensic Audit”, “Due Diligence” and “Know Your Customer”, “Know Your Supplier” procedures as well as the procedures that have proven themselves in international experience.

The systematic application of such advanced and generally recognized precautionary measures in daily financial and economic activities, in turn, serves to reduce the economic and financial risks of the Plant, prevent conflicts of interest and "affiliation" situations when establishing partnerships, and create an environment of cooperation based on mutual trust.

In accordance with the order of the Government of the Republic of Uzbekistan No. 03-08-01 dated 22 January 2025, the international auditing organization KPMG was involved in the comprehensive assessment of the procurement processes of JSC “Almalyk MMC” in 2022-2024, analysis of the effectiveness of the public procurement system, and assessment the effectiveness of anti-corruption systems (forensic audit).

The international auditing organization KPMG carried out the comprehensive analysis of the Complex's procurement activities, compliance control system, organizational structure, current procedures, compliance of procurement processes with legislative requirements, and potential corruption risks.

For example, as part of the international forensic audit, documents and information on the Complex's procurement processes were analyzed, interviews were conducted with senior officials responsible for and in charge of procurement, a thorough examination of procurement operations carried out in 2022-2024 on a competitive basis, and an assessment of existing business processes.

Based on the results of the audit, KPMG has prepared the proposals and recommendations for further improving the Complex's procurement processes.

Accordingly, the audit company KPMG is developing measures aimed at centralizing the processes related to the procurement of works and services for the needs of the Complex, improving the procurement function, further strengthening internal control and accounting mechanisms, digitizing procurement processes, and introducing advanced international practices.

Another important direction is the introduction of the system of inclusion of anti-corruption obligations in the employment contracts of almost two thousand new employees hired into the Complex.

In this case, all new employees are directly familiarized with the most important and basic internal documents of the Complex that promote honesty and transparency, such as the Code of Ethics, Anti-Corruption Policy, Conflict of Interest Management Policy, and Gift Policy, and the content and essence of relevant documents, and the level of understanding of employees is tested through special test questions.

This approach, in turn, serves to educate new employees who have joined the Complex's staff in the spirit of responsibility, legality, and honesty from the first days.

The Anti-Corruption Management System implemented at the Complex has successfully passed the external impartial audit in accordance with the requirements of advanced international standards and has received the international certificate ISO 37001:2016 and the national certificate O’zDSt ISO 37001:2019.

This is a document confirming that the work carried out at the Complex in terms of preventing and combating corruption is organized at the level of international standards.

Of course, ensuring honesty and legality in a major industrial complex with large staff of more than 35 thousand people, uniting more than 40 enterprises, plants and factories, workshops and mines is not an easy task.

In this regard, it would be an unforgivable mistake to consider combating corruption as the task of law enforcement agencies or supervisory bodies only.

The fight against this evil is a nationwide task. I believe that the conscious choice of every person with conscience should be the main criterion of everyday life.

If every manager, worker and officer strictly adheres to the laws and regulations in their work and everyday life, considers honesty as their human duty, respects the rights and interests of others, and demonstrates the zero tolerance attitude towards any illegal situations, the atmosphere of honesty in our cohesive and hardworking team will be further strengthened.

Dear colleagues, managers at all levels, dear business partners,

Let's build our industrial complex together, where justice and law prevail, honesty is valued, and there is absolutely no room for corruption and crime.

I am sure that if all of us, young and old, women and men, unite our strength and will, and fight corruption as one, one body and one soul, one day we will certainly achieve our noble goals.

Where the rule of law prevails, progress prevails, and where justice prevails, trust and prosperity prevail.

Abdulla Khursanov,

Chairman of the Board of JSC “Almalyk MMC”,

Member of the Senate of the Oliy Majlis