Analytical report
on the results of an internal analysis of corruption risks
in the activities of the State Institution "Department of Land Relations, Architecture
and Urban Planning of the Zhaksyn district", State Institution "Department of Internal Policy, Culture, Language Development and Sports of the Zhaksyn district"
In accordance with the Law of the Republic of Kazakhstan "On Combating Corruption", the Standard Rules for conducting internal analysis of corruption risks, approved by the order of the Chairman of the Agency of the Republic of Kazakhstan for Civil Service Affairs and Anti-Corruption dated October 19, 2016, methodological recommendations for conducting internal analysis of corruption risks, approved by the order of the Chairman of the Agency of the Republic of Kazakhstan for Combating Corruption dated December 30 2022 No. 488, based on the order of the akim of the district dated April 22, 2025 No. 15 by the working group, an internal analysis of corruption risks in the activities of local executive bodies funded from the local budget of the Akimat of the Zhaksyn district has been conducted in the following areas:
1) identification of corruption risks in regulatory legal acts affecting the department's activities;
2) identification of corruption risks in the organizational and managerial activities of the department.
The analysis period is from May 2 to May 30, 2025.
The analyzed period is from January 1 to December 31, 2024.
An internal analysis of corruption risks was conducted in the State Institution "Department of Land Relations, Architecture and Urban Planning of Zhaksyn district", State Institution "Department of Internal Policy, Culture, Language Development and Sports of Zhaksyn district" by summarizing information, analyzing, and evaluating the results of previous inspections by government agencies, information obtained from legal statistics, appeals from individuals and legal entities. persons and other information not restricted by Law.
The internal analysis of corruption risks was formed by a working group consisting of the following members:
Olga Bocharnikova – Head of the state institution "Office of Akim of Zhaksyn district", Chairman of the working group;
Arman Vladimirovich Kravets – Acting Head of the State Legal Department of the state institution "Office of Akim of Zhaksyn district", Deputy Chairman of the working group;
Segizbayeva Nazgul Sagdatovna – Chief specialist of the State Legal Department of the state institution "Office of Akim of Zhaksyn district", Secretary of the working group;
Tatiana Vasilyevna Balatskaya – Head of the Department of Analysis of Public Services Provision at the state institution "Office of Akim of Zhaksyn district";
Bekturganova Dinara Bekturganovna – Head of the Unified Personnel Management Service of the state institution "Office of Akim of Zhaksyn district";
Shamatova Zigash Abilmagzhanovna – Head of the Department of Documentation support and financial and economic activities of the state institution "Office of Akim of Zhaksyn district";
Ruslan Zhanarovich Abilzhanov – Head of the state institution "Department of Land Relations, Architecture and Urban Planning of Zhaksyn district";
Tortkarina Aynash Sultanovna – Head of the state institution "Department of Internal Policy, Culture, Language Development and Sports of Zhaksyn district";
Kusainov Kairzhan Kozhakhmetovich – Chairman of the Public Council of the Zhaksyn district (by agreement).
and Urban Planning of Zhaksyn district"
The State institution "Department of Land Relations, Architecture and Urban Planning of Zhaksyn district" (hereinafter referred to as the Department) is a state body of the Republic of Kazakhstan that provides leadership in the field of land relations, architecture and urban planning.
The department carries out its activities in accordance with the Regulations approved by the resolution of the Akimat of the Zhaksyn district dated December 20, 2024 No. a-11/214.
The analysis of corruption risks in the Department's activities revealed the following:
The direction "Identification of corruption risks in regulatory legal acts".
The Department, within the scope of its competence, is the developer of the following four regulatory legal acts:
During the monitoring of the NPA, it was revealed that the decision of the Zhaksynsky district maslikhat dated March 16, 2018 No. 6C-21-4 "On approval of the boundaries of assessment zones and correction coefficients to the base rates of payment for land plots in the village of Zhaksy and rural settlements of the Zhaksynsky district" did not make changes to the renamed streets based on the decision of the akim of the village of Zhaksy Zhaksynsky No. 3 dated July 25, 2018 "On renaming the streets of the village of Zhaksy in the Zhaksyn district of the Akmola region" (registered in the Register of Regulatory Legal Acts No. 6756).
Description of corruption risk: The late introduction of amendments to the regulatory legal act related to the renaming of streets creates legal uncertainty and complicates law enforcement practice.
Recommendations for elimination: to make appropriate changes to the decision of the Zhaksyn district Maslikhat dated March 16, 2018 No. 6C-21-4 "On approval of the boundaries of assessment zones and correction coefficients to the base rates of payment for land plots in the village of Zhaksy and rural settlements of the Zhaksyn district."
The direction "Identification of corruption risks in the organizational and managerial activities of the Department.
1) The staff of the Department consists of 3 units: 1 - head of the department, 2-chief specialists.
Anti-corruption restrictions have been signed by the Department's staff within the time limits established by the legislation of the Republic of Kazakhstan and are provided annually.
There were no vacant administrative positions.
There are no dismissals for negative reasons.
During the analyzed period, the head of the Department, R.Zh. Abilzhanov, was brought to disciplinary responsibility (based on the submission of the Department of Legal Statistics and Special Accounts for the Akmola region dated October 11, 2024 No. 2-20-24-03255).
2) Conflict of interest resolution.
No conflict of interest cases have been identified during the analysis.
3) Provision of public services.
The Department provides 4 types of public services. In 2024, 111 services were provided, including through GC -0, PEP - 111, GO-0, and IS-0.
There are no facts of violations of the deadlines for the provision of public services.
The claim of documents not provided for by legal acts has not been revealed.
There are no facts of violations of the procedures for the provision of public services.
There is no contradiction between the requirements of the Rules for the provision of public services and the norms of higher-level regulatory legal acts.
There were no complaints from service recipients. There are no unreasonable refusals.
There were no corruption risks in public services during the analyzed period in the department.
1) Implementation of permissive functions.
The Department does not issue permits, conduct examinations, grant rights, register, or approve services that are not included in the Register of Public Services.
2) Implementation of control and auditing functions.
No corruption risks have been identified in the implementation of control and audit functions.
3) The development and distribution of budgetary and financial resources.
The disbursement of budgetary funds, payroll, bonuses and surcharges is carried out in accordance with the Rules for bonuses, financial assistance and the establishment of allowances for official salaries of employees of the bodies of the Republic of Kazakhstan at the expense of the state budget, approved by Resolution of the Government of the Republic of Kazakhstan dated August 29, 2001 No. 1127.
In the reporting year 2024, with a financing plan of 26,284,400 tenge, 26,283,623 tenge was disbursed, which is 99.9%.
Corruption risks have not been identified in the process of budget allocation and allocation.
4) Conclusion of contracts with individuals and legal entities.
Public procurement of goods, works and services is carried out in strict accordance with the Law of the Republic of Kazakhstan "On Public Procurement" dated December 4, 2015 No. 434-V, the Rules for Public Procurement, approved by Resolution of the Government of the Republic of Kazakhstan dated December 11, 2015 No. 648.
Over the past year, 29 contracts have been concluded, 22 of them using a single source method Due to failed purchases, 7 contracts were concluded by requesting price offers.
No facts of review or cancellation of purchases based on the results of desk control by the state audit bodies have been established.
Отдел оказывает 4 вида государственных услуг. В 2024 году было оказано 111 услуг, из них через ГК -0, ПЭП - 111, ГО-0, ИС-0.
Фактов нарушения сроков оказания государственных услуг не имеется.
Истребование не предусмотренных правовыми актами документов не выявлено.
Фактов нарушения порядка процедур оказания государственных услуг не имеется.
Противоречие требований Правилам оказания государственных услуг нормам вышестоящих нормативных правовых актов не выявлено.
Жалоб со стороны услугополучателей не поступало. Необоснованных отказов не имеется.
Коррупционных рисков по государственным услугам за анализируемый период в отделе не выявлено.
Отделом не осуществляется выдача разрешительных документов, проведение экспертиз, наделение правом, регистрацией, согласованием, не включенных в Реестр государственных услуг.
Коррупционных рисков при реализации контрольно-ревизионных функций не выявлено.
Освоение бюджетных средств, начисление заработной платы, премий и доплат проводится в соответствии Правилами премирования, оказания материальной помощи и установления надбавки к должностным окладам работников органов Республики Казахстан за счет средств государственного бюджета, утвержденных Постановления Правительства Республики Казахстан от 29 августа 2001 года №1127.
За отчётный 2024 год при плане финансирования в размере 26 284 400 тенге освоено 26 283 623 тенге, что составляет 99,9 %.
Коррупционные риски в процессе освоения и распределения бюджетных средств не выявлены.
Государственные закупки товаров, работ и услуг осуществляется в строгом соответствии с Законом РК «О государственных закупках» от 4 декабря 2015 года № 434-V, Правилами осуществления государственных закупок, утвержденным постановлением Правительства РК от 11 декабря 2015 года №648.
За прошедший год заключено 29 договоров, из них 22 способом из одного источника по причине несостоявшихся закупок, 7 договоров способом запроса ценовых предложений.
Фактов пересмотра или отмены закупок по результатам камерального контроля со стороны органов государственного аудита не установлено.
5) Development and operation of information systems.
No corruption risks have been identified in the Information Systems Development and Operation Department.
6) Other issues arising from organizational and managerial activities.
On November 23, 2022, citizen Ilyashev A.N., under an agreement with the Department of Public Procurement and Communal Property of the Akmola region, purchased a real estate object — the former Berezka camp. The specified object was purchased without a land plot.
On July 3, 2024, citizen Ilyashev A.N. submitted an application for the provision of a land plot with an area of 1.0 hectares for a period of 49 years to service the acquired facility.
On August 28, 2024, the land commission adopted a protocol decision to refuse to grant the right to temporary paid long-term land use for other reasons: based on subclause 5) clause 1 of Article 48 of the CC RK (the land plot does not comply with architectural, urban planning and (or) construction documentation), Article 97 of the CC RK (the intended purpose is not related related to agricultural activities, the requested land plot belongs to agricultural lands).
This decision was made in violation of paragraph 2 of Article 52 of the CC RK, according to which, upon transfer of ownership of buildings (structures, structures) and other immovable property, ownership of the land also passes to the acquirer.
Description of the corruption risk: the establishment of restrictions on the rights of an individual.
Recommendations for elimination: conclusion of a contract with Ilyashev A.N. on temporary paid long-term land use (lease) of a land plot based on a court decision.
According to the submission of the Department of Legal Statistics and Special Accounts for the Akmola region dated October 11, 2024 No. 2-20-24-03255 for 2024, a violation of Article 73 of the Administrative Procedural Procedure Code of the Republic of Kazakhstan was revealed - the hearing procedure was not conducted due to the distortion of information about the nature of the decision on 9 appeals. Instead of indicating an unfavorable administrative act, the information systems reflected that the adopted acts were favorable, as a result of which the hearing procedure was not carried out. (ZT-2024-03714459 dated April 12, 2024, ZT-2024-04009508 dated May 13, 2024, ZT-2024-04202657 dated May 28, 2024, ZT-2024-04268984 dated June 4, 2024, ZT-2024-03714459 dated June 24, 2024, No. ZT-2024-04391200 dated June 17, 2024, No. ZT-2024-04724022 dated July 17, 2024).
As a result of the consideration of this submission, disciplinary action was imposed on the head of the Department, Abilzhanov R.Zh
. Description of the corruption risk: non-compliance with the procedural procedure established by the legislation of the Republic of Kazakhstan, in particular the mandatory hearing procedure.
Recommendations for elimination: ensure strict compliance with the hearing procedure in accordance with the requirements of the CPC of the Republic of Kazakhstan.
Based on the results of the analysis of corruption risks in the department's activities, it was recommended:
The State institution "Department of Internal Policy, Culture, Language Development and Sports of Zhaksyn district" (hereinafter referred to as the Department) is a state body of the Republic of Kazakhstan that provides leadership in the fields of internal policy, culture, language development and sports.
The state institution carries out its activities in accordance with the Regulations approved by the resolution of the Akimat of the Zhaksyn district dated April 15, 2022 No. A-3/65.
The analysis of corruption risks in the Department's activities revealed the following:
The direction "Identification of corruption risks in regulatory legal acts".
During the audit, it was established that the Department for its competence is the developer of one regulatory legal act - the decision of the Zhaksyn district Maslikhat of the Akmola region dated January 19, 2021 No. 7BC-2-1 "On certain issues of peaceful assembly" (registered in the Register of Regulatory Legal Acts No. 8334).
In 2022, the reorganization was carried out by merging the state institutions of the Zhaksyn district - the Department of Internal Policy, the Department of Culture and Language Development, the Department of Physical Culture and Sports in the Department of Internal Policy, Culture, Language Development and Sports of the Zhaksyn district.
At the same time, no changes were made to the above-mentioned decision of the Maslikhat, reflecting the fact of reorganization and the new name of the body.
Description of corruption risk: The late introduction of amendments to a regulatory legal act related to the renaming of a government agency creates legal uncertainty and complicates law enforcement practice.
Recommendations for elimination: to make appropriate changes to the decision of the Zhaksyn district Maslikhat of the Akmola region dated January 19, 2021 No. 7BC-2-1 "On certain issues of peaceful assembly".
The direction "Identification of corruption risks in the organizational and managerial activities of the department.
1) The staff consists of 6 units: 1 head of department, 1 deputy head, 4 chief specialists.
Anti-corruption restrictions have been signed by the Department's staff within the time limits established by the legislation of the Republic of Kazakhstan, and income declarations are provided annually.
There were no dismissals for negative reasons.
During the analyzed period, the chief specialist of the Department, Eleusuzova A.M., was brought to disciplinary responsibility (based on the submission of the Department of Legal Statistics and Special Accounts for the Akmola region dated October 11, 2024, No. 2-20-24-03255).
2) Conflict of interest resolution.
No conflict of interest was established during the analysis.
3) Provision of public services.
The Department provides 2 types of public services. In 2024, there were no applications from service recipients.
There are no facts of violations of the deadlines for the provision of public services.
The claim of documents not provided for by legal acts has not been revealed.
There are no facts of violations of the procedures for the provision of public services.
There is no contradiction between the requirements of the Rules for the Provision of public services and the norms of higher-level regulatory legal acts.
There were no complaints from service recipients. There are no unreasonable refusals.
There were no corruption risks in public services during the analyzed period in the department.
4) Implementation of permissive functions.
The Department does not issue permits, conduct examinations, grant rights, register, or approve services that are not included in the Register of Public Services.
5) Implementation of control and auditing functions.
No corruption risks have been identified in the implementation of control and audit functions.
6) The development and distribution of budgetary and financial resources.
In 2024, 423233.1 thousand tenge was allocated, 423066.2 thousand tenge was disbursed, which is 99.99% of the development. No corruption risks were found in the development and allocation of budget funds.
No corruption risks were identified during the accounting audit.
7) Conclusion of contracts with individuals and legal entities.
Public procurement of goods, works and services is carried out in strict accordance with the Law of the Republic of Kazakhstan "On Public Procurement" dated December 4, 2015 No. 434-V, the Rules for Public Procurement, approved by Resolution of the Government of the Republic of Kazakhstan dated December 11, 2015 No. 648.
Over the past year, a total of 81 public procurement contracts were concluded for a total amount of 19883.6 thousand tenge, including from a single source by directly concluding 7 contracts for the amount of 728 thousand tenge, by requesting price proposals, 25 contracts for the amount of 5179.4 thousand tenge were declared invalid, by the method of price proposals 27 contracts for the amount of 10116.7 thousand tenge.
There are no facts of review or cancellation of purchases based on the results of desk control by the state audit bodies.
At the same time, the prosecutor's office of the Zhaksyn district revealed a violation of non-compliance with legislation on public procurement.
So, on April 4, 2024, the Department and IP Inara signed a public procurement contract No. 31 for the purchase of an Iphone 14 Pro Max phone in the amount of 696,550 tenge. The technical specification and the name of the purchase indicated a specific brand name of the product — "iPhone 14 Pro Max", thereby violating paragraph 2 of Article 38 of the Law of the Republic of Kazakhstan "On Public Procurement", prohibiting the indication of trademarks, brand names and other signs that determine the affiliation of the product to a specific supplier.
Description of corruption risk: Specifying a specific trademark in the public procurement documentation restricts competition and prevents the participation of other potential suppliers.
Recommendations for elimination: conduct explanatory work with responsible employees on compliance with legislation on public procurement.
8) Development and operation of information systems.
No corruption risks have been identified in the Information Systems Development and Operation Department.
9) Other issues arising from organizational and managerial activities.
There are no complaints from individuals and legal entities, including in the media, about illegal actions of a corrupt nature in relation to the department.
No corruption risks have been identified in other matters arising from organizational and managerial activities.
Based on the results of the analysis of corruption risks in the department's activities, it was recommended that:
Chairman of the working group O. Bocharnikova
Deputy Chairman
of the working group A. Kravets
Members of the working group: