8.1. LOCAL CONTENT PERFORMANCE
NCOC IS COMMITTED TO DEVELOPING A WORLD-CLASS PROJECT
THAT MAXIMIZES THE USE OF LOCAL GOODS, WORKS AND SERVICES,
WHILST DEVELOPING THE SKILLS OF LOCAL PEOPLE AND THE
CAPACITY OF LOCAL COMPANIES.
In 2019 the North Caspian Project spent USD730 million on
local goods, works and services, equivalent to 52.4% of
total expenditures, a new record for NCOC in percentage
terms. This adds up to a year-end total of more than
US$14.8 billion spent on local goods, works and services
since 2004¹¹. These and other facts speak to the depth of
NCOC’s commitment to the use of local content.
8.2. LOCAL CONTENT: NCOC POLICY AND PROGRAMMES
NCOC Local Content Policy is based on the fundamentals of
the Production Sharing Agreement in respect of the North
Caspian Sea (NCSPSA), applicable legislation, and NCOC
Mission, Vision, and Values, as well as its business goals
NCOC Local Content Policy is based on the fundamentals of
the Production Sharing Agreement in respect of the North
Caspian Sea (NCSPSA), applicable legislation, and NCOC
Mission, Vision, and Values, as well as its business goals
NCOC APPROACH TO LOCAL CONTENT DEVELOPMENT COMPRISES
THREE MAIN AREAS: GROWING LOCAL INDUSTRY CAPABILITY; CRAFT
TRAINING AND KNOWLEDGE TRANSFER; AND ENHANCING LOCAL
8.3. GROWING LOCAL INDUSTRY CAPABILITY
Development of local vendors is a priority for NCOC. The
objective is to help local companies improve their
technical and managerial capabilities so that they qualify
as potential suppliers to the project, and longer-term
could bid on other opportunities in national and
Since 2006, about 1,400 local companies have participated
in workshops and forums organized by NCOC. These range
from general awareness seminars to introduce the project
and its contracting requirements, to more specialized
seminars on tender writing and pre-qualification
From 2006 to 2019, the Operator assisted over 200 local
companies to obtain international standards certifications
for their management, goods and services, thus
significantly increasing their competitiveness for
contracts with NCOC.
The Operator has also provided assistance and financial
support to local companies to obtain international
certifications for their goods and services from the
American Society of Mechanical Engineers (ASME) and
American Petroleum Institute (API).
From 2006 to 2019, NCOC conducted more than 350 technical
qualification audits and site visits of local companies,
assessing their ability to meet demanding specifications
and international codes and standards for goods and
services tendered under the North Caspian Project.
From 2006 to 2019 the Operator provided more than 3,800
employees of local companies with specialized professional
training in the most in-demand craft skills, including
Working in Confined Spaces, Industrial Welding Safety,
Electronic Systems and Assembly, Working at Height, Mobile
Crane Operations, etc.
ROADSHOW CAMPAIGN WITH REGIONAL AKIMATS
NCOC successfully continued a Roadshow campaign
initiated in 2018 to improve collaboration between NCOC
and regional Akimats in local content development. In
2019 NCOC signed four Memorandums of Cooperation on
local content development aiming at further development
of local staff skills and increase of local companies’
capacities. On January 18, NCOC signed Memorandum of
Cooperation on Local Content Development Issues with
Atyrau Oblast Akimat. Also, NCOC issued a purchase order
for supply of 120-150 Frack Tanks for Turnaround
activities in 2019 to ZhigerMunaiService LLP and issued
a purchase order for supply of high pressure nitrogen
vessel to AtyrauNefteMash LLP
On June 25, NCOC signed Memorandum of Cooperation on
Local Content Development Issues with Shymkent city
Akimat. The memorandum was signed with participation
of “PSA” LLP and NCOC POD, CP representatives as part
of Roadshow Campaign with Shymkent city Akimat.
On June 26, NCOC signed Memorandum of Cooperation on
Local Content Development Issues with Turkistan Oblast
Akimat as part of Roadshow Campaign
In December 6, NCOC signed Memorandum of Cooperation
on Local Content Development Issues with West
Kazakhstan Oblast Akimat as part of Roadshow Campaign.
THE 2019 MARKET SURVEY RESULTS:
- Cement production: 12 companies identified.
Quality Assurance/Quality Control: 41 companies
Provision of warehouse services: 26 companies
Provision of Expatriate and Local Manpower: 33
Provision of satellite images for oil spill and ice
monitoring: 9 companies identified.
Provision of warehouse services: 26 companies
COMPLETED TECHNICAL GAP ANALYSIS ON 5 CATEGORIES:
- Cement Production
- Offshore diving services
- Quality Assurance/Quality Control
- Machine building (mechanical equipment)
- Machine building (electrical equipment).
As a result of the market analysis under various
commodities of goods and services and technical gap
analysis, site visits have been conducted at 56
prioritized companies across Kazakhstan (Shymkent,
Ust-Kamenogorsk, Semey, Shetpe, Aktau, Karaganda,
Atyrau, Aktobe, Pavlodar and Almaty).
8.4. SOCIAL INFRASTRUCTURE PROJECTS
Under the North Caspian Sea PSA, NCOC allocates a budget
each year for development of social infrastructure
projects. In 2019 this budget amounted to USD 76.8
million. The funds for construction of schools,
kindergartens, hospitals, sport facilities, as well as
utilities such as roads, electric power and water supply
lines, and other infrastructure for the local communities
are split equally between Atyrau and Mangystau oblasts,
the areas of the main operations under the North Caspian
In the period from 1998 to 2019, 214 social infrastructure
projects have been completed.
Thus, cumulative spend on social infrastructure projects
has reached US$697,6 million.
Social infrastructure projects are generally proposed by
the Oblast Akimats (governments). Proposals are reviewed
by NCOC and the PSA Authority to ensure they comply with
PSA requirements and the Operator’s sustainable
development strategy, and are developed into projects in
close collaboration with the Oblast Akimats. Once
approved, NCOC is responsible for all stages of design and
engineering, contract tender, and execution up to
NCOC BUILT THE CULTURE CENTRE NAMED AFTER ABISH
KEKILBAYEV IN AKTAU
NCOC completed a large-scale construction of the
Culture Centre named after Abish Kekilbayev and the
monument to the writer as the part of its Social and
Infrastructure Projects. The complex consists of
three separate buildings – a general library, a
local museum and administrative building. According
to the authors of the project, this Cultural Centre
can be attended by to two thousand guests. The
Centre was opened by the RoK President Kassym-Jomart
Tokayev on October 10
UNIQUE SOCIAL PROJECT IN AKTAU
In August 2019, NCOC completed a unique social
project in Aktau – the “Rocky Trail”. The project
consists of 3 elements. The first is the pedestrian
walkway stretching from the 4th micro-district to
1st micro-district. The second is landscaping of the
Victory Park, and the third is landscaping of the
embankment along the 14th and 15th microdistricts.
The picturesque rocky trail is 1.5 km long, with 24
sky decks and rest areas along the route, including
a large cave and three modular piers. The pedestrian
zone along the massive rocks is made of a
wood-polymer composite material specially designed
for the region’s aggressive environment. The Rocky
Trail naturally blends in the landscape of the rocky
Caspian Sea coastline.
The idea to construct a Rocky Trail was proposed by
Mangystau Akimat. With budget of about 4 bln tenge
and 136 workers involved, the project was
implemented by the local company Nursat LLP. This
unique project stands out among other NCOC social
projects. The Rocky Trail has become an
architectural landmark of Aktau, and will attract
tourists and visitors to Aktau for years to come.
NCOC CONSTRUCTED GAS SUPPLY LINES
NCOC completed two large projects for gasification
of 10 settlements in Azgir Zone of Kurmangazy
District. These projects include over 365 km of main
and inter-settlement high-pressure gas pipelines and
57 km medium and low-pressure domestic gas
pipelines. The automatic gas distribution station
"Blue Flame-3000" was also built as part of the
project. Moreover, NCOC built 28 Gas Pressure
Reduction Units that enable gas supply to the
Currently, the natural gas is supplied to 1,239
houses in the remote settlements that were deprived
of this resource before. The newly commissioned
network is fed from the existing Makat-North
Caucasus main gas pipeline.
Since 1998, the Consortium implemented 31
gasification projects with overall 1,130 km gas
pipelines built in Atyrau and Mangystau Oblasts.
NCOC IS RECOGNIZED AS THE BEST COMPANY IN 2019
NCOC received Zhomart Zhurek award as the Best
Company in 2019 at the “Largesse Heart” Maecenas
Forum in Aktau.
The awarding ceremony was held on November 14, 2019
at the Assembly of the People of Kazakhstan with
participation of Akim of Mangystau Oblast.
The award recognized NCOC Sponsorship & Donation
Programmes implemented in 2019 in Mangystau Oblast.
8.5. SPONSORSHIP AND DONATIONS PROGRAMME
Through its Sponsorship and Donations programme, NCOC
responds directly to the needs and requests of local
communities. US$1.5 million is split equally each year
between Atyrau and Mangystau oblasts for community
sponsorships and donations. The Sponsorships and Donation
programme focuses on five main areas of support for local
communities: healthcare, education, sports, culture and
To be aligned with NCOC’s sustainable development
strategic goals, projects must contain elements of
self-involvement and demonstrate sustainability for local
communities. They should not support political or
religious organizations, create conditions for unfair
market competition, or undermine the ecological
sustainability of local communities and/or natural
ecosystems. The initiative for projects generally comes
from the local communities, but may also be initiated by
53 projects were completed in 2019 (31 in Atyrau Oblast
and 22 in Mangystau Oblast). In total, US$20.5 million has
been spent since 1998.
In addition, up to US$300,000 has been allocated every
year since 2006 for summer camp for 200 underprivileged
children and orphans from Atyrau and Mangystau Oblasts. In
2019 NCOC covered the costs of travel, camp and
cultural-educational activities for these children at
“Baldauren” centre in Burabai.
NCOC continues to support summer school project launched
in 2018 jointly with Kazakhstan-British Technical
University (KBTU) in Almaty. In 2019, during 21 days 100
teens from underprivileged families of Makat and
Tupkaragan Districts studied the English language and the
basics of programming. The classes were held in the
laboratories of KBTU faculties of oil and gas and IT,
business school and the Marine Academy
In 2019 as part of a traditional “Road to School” campaign
NCOC supported 200 children from underprivileged families
from Atyrau city and Makat District of Atyrau Oblast, and
200 children from Aktau city and Tupkaragan District of
Mangystau Oblast. Future first-graders received backpacks
with all necessary school supplies and stationery. Since
the beginning of this campaign NCOC has supported almost
3,000 school children.
CLEAN AIR AND CLEAN WATER FOR SCHOOLS
NCOC sponsored the installation of bactericidal air
recirculators and drinking water fountains in 27
schools in Atyrau. This initiative was held under
the World Health Organizations Programme “Healthy
School”. The benefits of the installed equipment are
Bactericidal air recirculators are absolutely safe
for children, since all reactions take place
inside the device and no harmful substances are
emitted into the atmosphere. Therefore, it can be
continuously used in premises where the children
Drinking fountains have a three-stage water
filtration system to remove mechanical, biological
and chemical impurities and the smell of chlorine.
The equipment is certified. It is hygienic and
8.6. ENGAGEMENT WITH THE LOCAL COMMUNITY
NCOC is proud to call Atyrau its home. Nearly 3,000 NCOC
employees, and thousands more contractors and suppliers
who work for Kashagan Phase 1 Project, are residents of
communities in Atyrau and Mangystau Oblasts.
NCOC is headquartered in Atyrau, Kazakhstan, close to the
North Caspian Project’s resources with its facilities
located in Atyrau and Mangystau Oblasts. We strive to be
an employer of choice and a respected member of the local
community. We care about the communities where we operate
because we are a part of them. We want to proactively
address any concerns raised about our operations,
recognizing that public respect and confidence are earned
through performance, open communications and community
involvement. Voluntary sustainability reporting plays an
important role in achievement of this goal.
Through its Sponsorship and Donations programme, NCOC
positions itself as a socially responsible company that
supports local communities.
In August, NCOC sponsored a one week Environmental Summer
School close to Aktau, where highschool students were
engaged in theoretical classes and practical environmental
studies to promote the ideas of sustainable development of
the Caspian Oblast. The Summer School is traditionally
held in the period of annual celebration of the “Caspian
Day” in August.
During the year, we shared the information with the local
communities on a regular basis and discussed theirs
concerns regarding the North Caspian Project.
On March 15 and April 26, NCOC met with representatives of
Non-Governmental Organizations (NGO) and state bodies of
Atyrau and Mangystau Oblasts to present social projects
implemented in Atyrau and Mangystau Oblasts and share the
experience in engagement with local community as part of
Corporate Social Responsibility.
On May 24, NCOC organized an environmental “round table”
with NGOs, representatives of governmental agencies and
the local community to present the projects on
"Comprehensive study of the Caspian seal population in
cooperation with scientists from Kazakhstan and Russia"
and "Comprehensive study of atmospheric air quality in
Atyrau and nearby settlements". NCOC ecologists reported
on the progress under these projects and plans for further
On October 9, NCOC organized an awareness tour for 20
journalists from national and local media, including
Khabar, 24 KZ, Caspian News and Atyrau TV channels and
Esquire, Kursiv, Oil and Gas Kazakhstan, Prikaspiyskaya
The objective of this tour was to improve journalists’
awareness about the North Caspian Project, Kashagan field,
local content development, NCOC role and other issues,
thus establishing a pool of qualified journalists who
could be involved in NCOC communication campaigns.
This Sustainability Report has become a new and effective
forum for engagement with the local community. At the
beginning of 2019 when we were preparing the 2018 Report
we met with the External Advisory Board, representing the
combined opinions of environmental and social NGOs from
Atyrau and Mangystau Oblasts, to receive their comments
and recommendations. In April 2019, we presented the 2018
Report to the public and answered questions at three
special meetings in Atyrau and Aktau, moderated by Shynar
Izteleuova, Director of the Zhayik-Caspian Aarhus Center.
NCOC has in place a comprehensive programme for
communication with the stakeholders and engagement with
local media on pressing issues. In order to support the
local companies in finding new economic opportunities
related to the North Caspian Project, we provide the
information by using various ways from general awareness
seminars about the Project and participation in industry
conferences, to specialized vendor audits and dedicated
training courses (For more information please see the
Local Content section). Any citizen can raise concerns or
report potential non-compliance with our values and
principles (including anonymously) to NCOC Ethics and
Compliance officer, or use the Compliance Hotline opened
in 2017 (For more information please see the Business
NCOC Women’s Network (NWN) was established in 2015,
with a vision to develop professional skills of NCOC
women and men through formal and informal networking
and professional exchange opportunities, maintaining
a healthy work and family integration.
NWN memberships is open to all NCOC and contractor
staff. The NCOC Women’s Network provides a platform
Facilitate personal growth and professional
advancement of all employees at NCOC
Empower and enable working women in their quest
for professional development, while leading
Connect and interact with other like-minded
individuals in the workplace and outside NCOC
Make a difference to our organization and local
- Leverage cultural diversity of NCOC.
Since 2015 NWN supported a number of programmes and
events, such as mentoring programme, personal
development sessions, family events, guest talks,
charity initiatives and joint events with local
Network has gained a solid reputation and support
among NCOC Senior Leadership Team through working
towards improving our activities and defining
long-term objectives to help business.
8.7. EMPLOYEE ENGAGEMENT IN THE COMMUNITY
NCOC ENCOURAGES EMPLOYEES TO TAKE ACTIVE PART IN THE
BETTERMENT OF THEIR COMMUNITIES.
In 2019 NCOC employees actively participated in nationwide
environmental campaigns “TazaQazaqstan” (“Clean
Kazakhstan”) and “Birge Jasyl Qazaqstan” (“Going Green
On August 3, NCOC staff and their families cleaned up 3
km territory assigned by Atyrau Akimat near the
Atyrau-Makhambet-Astrakhan ring road. Within 3 hours 2
trucks of waste were collected.
On August 24, NCOC volunteers together with KMG Systems
& Services Company with joint support of “Ak Zhaiyk”
Nature Reserve representatives, Regional Inspection of
Forestry and Wildlife and Damba Akimat cleaned the
territory adjacent to the North Caspian Oil Spill
Response Base. Volunteers collected 1,260 kg of waste.
On October 12, NCOC employees from Nur-Sultan, Aktau and
Bautino joined a large-scale campaign “Birge Jasyl
Qazaqstan”. Overall, 220 trees were planted.
On May 26, NCOC organized an annual clean-up campaign of
the Ural River bank ("Atyrau – a clean city ") jointly
with Atyrau Inspection of Forestry and Wildlife and
Atyrau Akimat. The campaign resulted in 25 cubic meters
of garbage collected at site.
NCOC and its employees participated in important local
holidays for the community, such as Nauryz (Kazakh New
Year) and Victory Day.
In 2019 NCOC volunteers delivered fire safety
presentations to more than five thousand kids in Atyrau
schools, raising awareness on actions in case of fire
and teaching escape and evacuation.
8.8. JOB SKILLS TRAINING AND KNOWLEDGE TRANSFER
As a means to achieve its own medium– and long-term
nationalization goals, the Operator has developed a
special, targeted programme for identifying and recruiting
Kazakhstan citizens, and providing them with training for
advancement in a long-term career with NCOC. Since 1998 a
total of more than 18,000 Kazakhstan citizens have
received some form of training, either from NCOC or as
employees of local companies being helped by NCOC.
Over two decades, the Operator has spent in total about
US$289 million on job skills and professional training to
build local capacity for the North Caspian project.
In 2019 116 students completed internships at NCOC. The
programme provides an opportunity for local students to
work in the international oil and gas company, and to get
hands-on experience with the most modern equipment in the
In 2019 13 NCOC employees were assigned for International
Development Assignment Programme. The programme was
launched in 2018 to provide an opportunity for NCOC
employees to work overseas in our shareholders’ companies
for up to two year assignments in order to enhance their
skills, expand the existing knowledge and prepare for
future roles in the Company.
NCOC Scholarship Programme
NCOC established a Scholarship programme for students in
accordance with the NCSPSA. The Operator has sponsored
3,420 students from Kazakhstan to study in educational
institutions inside and outside the Republic of Kazakhstan
with a monetary value over US$8.3 million.
NCOC provides the funding and the Kazenergy Association
manages the Scholarship fund on a competitive basis for
the academic training of Kazakhstan citizens (not NCOC
employees) in the disciplines related to the petroleum
industry, including training courses at universities,
colleges or other educational institutions. In 2019-2020
academic year, NCOC has sponsored 420 students in 42
Article XXVII of the NCSPSA specifies the overall targets
in terms of manning levels of Kazakhstan citizens employed
in carrying out Petroleum Operations. In 2019 Kashagan
Phase 1 Project has significantly exceeded these targets,
- 82% of managerial staff taken by local personnel
95% of technical and engineering employees,
administrative staff, and qualified specialists taken by
100% of workers and supporting personnel taken by local
Overall at the end of 2019, 91% out of over three thousand
employees of NCOC are Kazakhstan citizens, and 95% out of
ten thousand people engaged in the North Caspian project
are Kazakhstan citizens.
8.10. NCOC WORKFORCE; LABOR RIGHTS
NCOC AIMS TO BE AN EMPLOYER OF CHOICE IN KAZAKHSTAN.
NCOC goes well beyond legal requirements of the Labor Code
to provide compensation and benefits that attract,
motivate and retain employees, and to incentivize their
contribution to achieving our business objectives. NCOC
carefully calibrates the competitiveness of its salary and
benefits package with market surveys.
The remuneration philosophy is based on a “pay for
performance” approach that is aligned with our Mission,
Vision, Values and Culture at NCOC. In addition to the
annual General salary increase, Oilman’s Day bonus and
Vacation Wellness Support payment, an employee may receive
an Individual Merit Salary increase and a variable annual
Company Performance bonus, plus discretionary allowances
and special monetary awards for outstanding performance or
adherence to company values. Kazakhstan citizens who are
directly hired by NCOC receive numerous other
compensations and benefits, including generous paid and
unpaid time off, paid pension, continuing education
assistance, medical and life insurance, free commute on
company shuttle bus, financial assistance programmes for
health club membership, home mortgage, wellness and
medical issues, bereavement, children’s education and
NCOC is an exciting, international collective where
English is used in a business setting, and opportunities
exist for International Development Assignments in NCOC
shareholder companies (see Section 7.8 on Job Skills
Training and Knowledge Transfer).
In 2019 NCOC hired 25 Kazakhstan university graduates of
technical specialties background.
NCOC’s aspiration is to attract future leaders and retain
high performers, particularly in business-critical areas
within NCOC, and to lead to increased performance,
stronger engagement within the workforce, driven by strong
relationships between the employee and supervisor.
In 2019 NCOC launched an engagement survey in order to
understand the current overall employee engagement and
check the health of the organizational capability in NCOC.
It serves as a baseline for developing the NCOC Engagement
Action Plan to identify what the organization will do with
any key findings to drive engagement over the next 24
The survey will be conducted every two years and focused
on the following 8 key organizational drivers:
- Direction and Performance
- Structure and Accountabilities
- Process and Systems
- Ways of Working and Behaviours
- People and Skills
- Compensation and Benefits
- Employee Engagement
Diversity and Inclusion
NCOC does not tolerate discrimination in employment. Our
Code of Conduct for employees specifies that employment
decisions are based only on relevant qualifications,
merit, performance and other job-related factors.
NCOC does not tolerate any form of harassment, nor any
action, conduct or behavior which is humiliating,
intimidating or hostile. Managers have a responsibility to
protect their staff from harassment, and to create a
climate where individuals who have concerns about
harassment in their work area may discuss the issues in
NCOC is committed to providing an open working environment
in which respect for each other is fundamental, continuous
improvement is a shared goal, and the concerns of
individuals are taken seriously and dealt with positively,
without prejudice to them or their career.
NCOC has clear policies and procedures for dealing with
workforce grievances, which apply equally to its
contractors and sub-contractors. Grievance procedures
serve to bring employee problems to management’s attention
and ensure open, proper and timely review and resolution
before frustrations can evolve into conflict. Employees
may express their grievances freely and openly without
fear of dismissal and intimidation. NCOC must accept,
register, and review any written grievance submitted by an
employee. Employees have the right to appeal a decision,
which he/she thinks may be violating his/her labor rights
If not resolved within NCOC, the grievance may be referred
to appropriate RoK officials. By law, neither NCOC nor its
contractors may compel employees to join or not join a
legal labor action, and must reserve for the employee any
prior job position and benefits.
NCOC has policies and procedures in place for monitoring
timeliness of salary payment, living conditions and
canteen facilities provided by our contractors and
8.11. HUMAN RIGHTS DUE DILIGENCE
NCOC has been working for many years to promote respect
for human rights within our organization. Our approach
consists of several core elements, including:
- Compliance with applicable laws and regulations
Regular dialogue and engagement with our stakeholders
Contributing, directly or indirectly, to the general
well-being of the communities within which we work
Adherence to our General Business Principles, the Code
of Conduct, and the Anti-Bribery & Corruption Manual,
which address related issues.
As it relates to our staff, this approach manifests as
compliance with law, protection of employees’ personal
data, respect for diversity, and continuous improvement of
our Human Resources programmes and policies (see section
on NCOC Workforce).
Suppliers are also contractually obligated to comply with
our General Business Principles and Code of Conduct in all
aspects of their work with us.
NCOC has programmes and measures in place to provide
security and safeguards as appropriate to protect its
people, operations, facilities, business information, and
other assets. NCOC sites have implemented security
programmes based on a proven, structured risk assessment
methodology. NCOC complies with relevant laws and
regulations affecting security in areas where we operate,
and we support a coordinated and cooperative approach to
infrastructure security with the competent local and
national security agencies.
NCOC security risks management includes the support from
Government Security Forces and private security providers.
Local RoK State Security Forces support NCOC Security
department to deal with all instances of site invasion
including crowd control, large demonstrations or riot.
NCOC Security department ensures compliance with Voluntary
Principles on Security and Human Rights (VPSHR) and
requires its security contractors to abide by these
Principles. VPSHR are included into the contract with
In 2019 NCOC continued to further embed the VPSHR and
implemented trainings to increase awareness at operation
and corporate level.
NCOC Security department organized a number of trainings
and workshops for security contractor. Moreover, we
conduct regular internal self-assurance reviews to ensure
Security contractor’s compliance with “Ethical conduct and
8.12. BUSINESS ETHICS
HONESTY, INTEGRITY AND FAIRNESS IN ALL ASPECTS OF OUR
BUSINESS IS A FUNDAMENTAL PRINCIPLE, AND WE REQUIRE THE
SAME OF ALL THOSE WITH WHOM WE DO BUSINESS.
NCOC’s General Business Principles apply to all our
business affairs and describe the behavior expected of
every staff member of NCOC, including direct-hire
Kazakhstan citizens, secondees, and contract staff. In
addition, all NCOC staff are required to adhere to a Code
of Conduct, which instructs them how to apply the General
Business Principles in line with our core values. It
provides practical guidance on how to comply with laws and
regulations and how to relate to customers, communities
and colleagues. Staff communications and monitoring
programs are designed and implemented to assure
Contractors and suppliers are contractually obligated to
comply with our General Business Principles and Code of
Conduct in all aspects of their work with us.
All those seeking to do business with NCOC undergo “due
diligence” background checks before contracts are signed.
NCOC’s contracts also include the requirement for
contractors and suppliers to conduct their business
activities with integrity and high ethical business
standards. After risk screening, some companies may also
be asked to institute mandatory training or special
contractual conditions to ensure that their business
practices align fully with our expectations.
No one at NCOC may instruct staff to take actions that
violate the law or contradict our General Business
Principles or Code of Conduct. If an employee observes
such an action or instruction, he or she is required to
refer the situation in confidence to a supervisor, to the
NCOC Ethics & Compliance Officer, or to the Compliance
Hotline for further investigation and possible
disciplinary action. The Compliance Hotline is a 3rd party
operated website (
http://www.ncoc.deloitte-hotline.com), with e-mail
address (email@example.com) and phone number (8 800 080 15 65
) that allows anyone to report suspected violations of
law, General Business Principles and Code of Conduct
including on an anonymous basis.
NCOC staff, vendors, suppliers, contractors or anyone else
can raise concerns or report possible non-compliance to
the NCOC Ethics & Compliance Officer or to the Hotline,
even anonymously. Details are kept confidential. The
Ethics & Compliance Officer looks into allegations, and if
confirmed, NCOC’s management takes actions appropriate to
the circumstances. NCOC does not tolerate retaliation of
any kind against those who report an issue concerning our
General Business Principles, the Code of Conduct or
Anti-Bribery & Corruption Manual, or compliance with
8.13. PREVENTING CORRUPTION
NCOC’S GENERAL BUSINESS PRINCIPLES ARE CLEAR: THE OFFER,
PAYMENT, SOLICITING OR ACCEPTANCE OF BRIBES IN ANY FORM,
DIRECT OR INDIRECT, IS UNACCEPTABLE.
NCOC’s internal Anti-Bribery & Corruption Manual contains
policies and procedures to ensure that any interaction
with government officials is directly related to a stated
business purpose or regulatory requirement, and that it is
in strict compliance with the laws of Kazakhstan and
consistent with any international statutes that may
NCOC requires that its staff avoid conflicts of interest
between their private activities or family relationships
and their role in the conduct of NCOC business.
NCOC reflects all business transactions in its accounts in
an accurate and timely manner, in accordance with
established procedures and agreements.
Contractors and suppliers are obligated by their contracts
with NCOC to adhere to our General Business Principles in
all aspects of their work with us.
As started above, concerns or suspected non-compliance may
be reported in confidence to the NCOC Ethics & Compliance
officer or to the Hotline.
Any confirmed non-compliance can have serious consequences
as may be appropriate including dismissal of the staff
concerned and termination of the relevant contracts.
8.14. ENGAGEMENT IN PUBLIC POLICY
In our General Business Principles, NCOC has pledged to
contribute in an ethical and constructive way to enhancing
the laws and regulations of Kazakhstan on health, safety,
security and environmental protection. NCOC is an active
member of KazEnergy, a not-for-profit association of
companies in energy and oil and gas industries in
Kazakhstan. NCOC is a member of the Oil and Gas Committee
of the “Atameken” National Chamber of Entrepreneurs. We
often engage in discussions of priority public policy
issues affecting our industry in the framework of these
organizations. NCOC is also a member of the American
Chamber of Commerce in Kazakhstan, and has participated in
its advocacy activities to improve the foreign investment
NCOC does not make political contributions of any kind.
11 Local goods, works and services are defined
per Unified Methodology (2010) on local content
calculations outlined in the RoK Law “On Subsoil and
Subsoil Use.” (See Link to Subsoil Act definitions of
local content used by NCOC.) Prior to 2010 NCOC used local
content calculation methods in the NCSPSA.
12 The US Foreign Corrupt Practices Act (FCPA)
and the UK Anti-Bribery Act are two foreign laws that
could apply to companies or citizens of those countries,
even if their activities take place in Kazakhstan.