TauKen Group | Procurement Integrity Protocol

1. Purpose

This Procurement Integrity Protocol ("the Protocol") establishes ethical, legal, and procedural standards governing all procurement activities. Designed to ensure transparent, competitive procurement in compliance with Kazakhstan and UK laws, preventing corruption and promoting fair competition.

2. Legal Framework

Kazakhstan: Law on Public Procurement (2015), Law on Combating Corruption (2015), Law on State Audit (2015).

UK: Bribery Act 2010, Public Contracts Regulations 2015, Companies Act 2006, Modern Slavery Act 2015.

3. Scope

Applies to all procurement activities by TauKen Group and subsidiaries, all procurement personnel, and all suppliers/contractors. Covers full procurement lifecycle: planning, tendering, evaluation, contracting, post-award management.

4. Core Principles

Transparency, Fair Competition, Value for Money, Accountability, Integrity, Compliance with laws and standards.

5. Procurement Procedures

Planning: Needs identified via budgets, clear specifications. Tendering: Competitive for >KZT 10M/£17.5K. Evaluation: 3+ panel members, documented scoring. Contracting: Legal review, Board approval >KZT 50M/£75K. Post-Award: Performance monitoring, documented variations.

6. Ethical Conduct and Anti-Corruption

Zero-tolerance for bribery, collusion, unethical conduct. No gifts/hospitality influencing decisions. Suppliers sign Ethical Conduct Declaration. Suspected bid-rigging reported to authorities. Violations result in disqualification and legal referral.

7. Conflict of Interest

All participants must declare conflicts including relationships with bidders, previous employment, or impairing interests. Conflicts managed through recusal or reassignment.

8. Supplier Due Diligence

Due diligence includes company verification, financial health, sanctions screening, ESG compliance, human rights, AML controls. High-risk suppliers undergo enhanced due diligence.

9. Record-Keeping and Audit

Records retained 5 years (Kazakhstan) / 6 years (UK). Includes tender docs, evaluation scores, contracts, correspondence, payments. Internal Audit may review anytime.

10. Whistleblower Protection

Report misconduct via ethics portal, hotline, or Compliance Officer. Protected under PIDA 1998 (UK) and Article 6 Kazakhstan Law. Retaliation prohibited.

11. Training and Awareness

Annual training on procedures, anti-bribery, conflict management, ESG, human rights, data protection. Records maintained by HR and Compliance.

12. Review and Amendment

Protocol reviewed annually, updated for law changes, audit findings, restructuring, supplier feedback. Amendments approved by Board and communicated to all.