TauKen Group Ltd.
This Conflict of Interest Policy ("the Policy") sets out TauKen Group Ltd.'s commitment to ethical conduct, transparency, and accountability in all business dealings. It provides a framework for identifying, disclosing, and managing actual, potential, or perceived conflicts of interest across the Group's operations.
The Policy is designed to uphold the integrity of decision-making processes, protect stakeholder trust, and ensure compliance with the legal and regulatory frameworks of the Republic of Kazakhstan and the United Kingdom.
TauKen Group Ltd. complies with the following legislation:
Under Kazakhstan Law:
Under UK Law:
Where legal obligations differ, the stricter standard shall apply.
This Policy applies to all employees, officers, and directors of TauKen Group Ltd. and its subsidiaries, contractors, consultants, and third-party representatives, and any individual involved in procurement, investment, governance, or decision-making processes.
A conflict of interest arises when an individual's personal, financial, or professional interests interfere or appear to interfere with their duties to TauKen Group Ltd. Conflicts may be actual, potential, or perceived.
Conflicts may include: holding financial interest in suppliers/competitors, outside employment competing with TauKen, awarding contracts to family/associates, using company resources for personal gain, participating in decisions with personal benefit, or accepting gifts/hospitality that could influence judgement.
All individuals must disclose any conflict as soon as it arises, complete annual declarations, update promptly if circumstances change, and refrain from decisions where conflict exists. Disclosures must be made to line managers, Company Secretary, Compliance Officer, or Procurement Committee.
The Compliance Officer will assess conflicts and develop mitigation plans including recusal, reassignment, divestment, or termination of engagements. Outcomes are documented and reviewed by the Audit & Risk Committee.
Directors must avoid conflicting situations, declare interests in transactions, and abstain from voting where conflicts exist. All declarations are recorded in the Board's Register of Interests.
TauKen prohibits gifts/hospitality that could improperly influence decisions. Gifts exceeding £100 / KZT 60,000 must be declared and approved. Bribes and facilitation payments are strictly prohibited.
Failure to disclose conflicts may result in disciplinary action, termination, removal from office, legal action, or reputational damage. All breaches are investigated and reported.
All employees and directors receive training on conflict risks, disclosure procedures, and legal obligations during onboarding and annually. Specialised training is provided to procurement, legal, and governance personnel.
This Policy is reviewed annually by the ESG & Compliance Committee and updated to reflect legislative changes, audit findings, and evolving standards. Amendments are approved by the Board.
