ANALYTICAL REPORT
based on the results of the internal analysis of corruption risks
State Institution "Kostanay Department of State Property and Privatization of the Committee for State Property and Privatization of the Ministry of Finance of the Republic of Kazakhstan"
Kostanay, January 16, 2026
The subject of the internal analysis of corruption risks is the activities of the State Institution "Kostanay Department of State Property and Privatization of the Committee for State Property and Privatization of the Ministry of Finance of the Republic of Kazakhstan" (hereinafter referred to as the Department).
The basis for conducting the internal analysis of corruption risks was Order No. 6 of the Head of the Department dated January 12, 2026, "On Approving the Composition of the Working Group for Conducting an Internal Analysis of Corruption Risks."
The analysis of corruption risks was conducted in accordance with the Law of the Republic of Kazakhstan "On Combating Corruption" dated November 18, 2015, No. 410-V, and the Model Rules for Conducting Internal Corruption Risk Analysis, approved by Order No. 12 of the Chairman of the Agency of the Republic of Kazakhstan for Civil Service Affairs and Anti-Corruption dated October 19, 2016, in the following areas:
1) Identification of corruption risks in regulatory legal acts affecting the activities of the Department;
2) Identification of corruption risks in the organizational and managerial activities of the Department.
Period: January 13–16, 2026.
Analysis period: July 1–December 31, 2025.
The internal corruption risk analysis was conducted by the working group for conducting internal corruption risk analysis:
- Altair Kabanbaevich Dabayev – Deputy Head of the Department, Chairman of the working group;
- Berik Seilkhanovich Ayapov, Head of the Department for Work with Property Received on Specific Grounds, member of the working group;
- Saltanat Amantayevna Nugmanova, Head of the Financial Support Department, member of the working group;
- Arnur Askarbekovich Kenzhegarin, Head of the Asset Management Department, member of the working group;
- Kubey Zhumagalievich Kasymov, Head of the Department for Work
with Legal Entities and Property Disposal, member of the working group;
- Aigul Gazizovna Olzhabaeva, Head of the HR and Legal Department, member of the working group;
- Talgat Pazylkhanovich Akbaev, Chief Specialist of the HR and Legal Department, Secretary of the working group.
In order to identify corruption risks in legal acts and internal documents regulating the activities of the Department, the following regulatory legal acts were studied: the Budget Code of the Republic of Kazakhstan dated March 15, 2025 No. 171-VIII, the Law of the Republic of Kazakhstan "On Civil Service" dated November 23, 2015 No. 416-V, the Law of the Republic of Kazakhstan "On State Property" dated March 1, 2011 No. 413-IV, the Law of the Republic of Kazakhstan "On Public Procurement" dated July 1, 2024 No. 106-VIII, the Code of the Republic of Kazakhstan "On Taxes and Other Mandatory Payments to the Budget" (Tax Code) dated December 25, 2017 No. 120-VI, "On Approval of the Rules for the Implementation of Public Procurement" approved by the Order of the Minister of Finance of the Republic of Kazakhstan dated October 9, 2024 No. 687, "Rules for the Transfer state property for property lease (rent)" approved by the Order of the Minister of National Economy of the Republic of Kazakhstan dated March 17, 2015 No. 212, "Rules for the transfer of state property to trust management and the Model Agreement for the trust management of state property" approved by the Order of the Minister of National Economy of the Republic of Kazakhstan dated January 16, 2015 No. 17, "Some issues of accounting, storage, evaluation and further use of property transferred (received) into state ownership on certain grounds" approved by the Resolution of the Government of the Republic of Kazakhstan dated July 26, 2002 No. 833, "Rules for the sale or use of property seized on the basis of a court verdict in a criminal case in terms of confiscation of property or on the basis of a decision to transfer property to the state" approved by the Order of the Minister of Finance of the Republic of Kazakhstan dated March 30, 2015 No. 227, "Rules for the sale of privatization objects" approved by the Resolution of the Government of the Republic of Kazakhstan dated August 9 2011, No. 920.
During the study, the objectives and functions of the State Institution's Regulations affecting the Department's activities were analyzed.
During the internal analysis for corruption risks in the Department's organizational and managerial activities, the following areas were subjected to anti-corruption analysis:
1. Identification of corruption risks in the Department's organizational and managerial activities:
1.1. Corruption risks associated with personnel management, including the identification of positions susceptible to corruption risks.
Department staffing levels – for the analyzed period