ANALYTICAL REPORT
on the results of an internal analysis of corruption risks in the activities of the
State Institution «Department of Employment and Social Programs of the city of Sarani»
The introductory part:
Based on the order of the head of the State Institution «Department of Employment and Social Programs of Sarani City» dated April 25, 2025 No. 40 od «On conducting an internal analysis of corruption risks in the state institution «Department of Employment and Social Programs of Sarani City for 2024», an internal analysis of corruption risks was conducted from May 1 to June 16, 2025.
The name of the department, whose activities are subject to internal analysis of corruption risks:
The State Institution «Department of Employment and Social Programs of the city of Sarani» (hereinafter referred to as the Department), headed by Marina Vladimirovna Shegai.
The internal analysis of corruption risks covers the period of work for 2024.
The internal analysis of corruption risks was conducted in accordance with the Rules of Internal Analysis of Corruption Risks, 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, and Order No. 19-r of the Akim of Sarani dated April 25, 2025.
An internal analysis of corruption risks was conducted by a working group consisting of the following members:
Chairman of the working group:
Marina Vladimirovna Shegai, Head of the Department of Employment and Social Programs of the city of Sarani.
Deputy Chairman of the working group:
Natalia Nikolaevna Kurgannikova, Head of the Social Programs Sector at the Department of Employment and Social Programs of the City of Sarani.
Members of the working group:
Anastasia Sergeevna Abramovich – Head of the Employment Sector of the State Institution «Department of Employment and Social Programs of the city of Sarani»;
Falchenko Irina Aleksandrovna – Chief specialist of the employment sector of the State Institution «Department of Employment and Social Programs of the city of Sarani»;
Ellada Mikhailovna Moroz – Head of the Department of social assistance at home of the State Institution «Department of Employment and Social Programs of the city of Sarani».
Secretary of the working group:
Diana Sabitova, Social Work Specialist, Department of Social Assistance at Home, Department of Employment and Social Programs of Sarani City.
The descriptive part:
In order to implement the Concept of the Anti-Corruption Policy of the Republic of Kazakhstan for 2022-2026, approved by Decree of the President of the Republic of Kazakhstan dated February 2, 2022 No. 802, work is underway to familiarize employees with the amendments made to regulatory legal acts, including work to clarify the Laws of the Republic of Kazakhstan «On Combating Corruption», «On the Civil Service of the Republic of Kazakhstan Kazakhstan», the Ethical Code of Civil Servants of the Republic of Kazakhstan. Civil servants are familiarized with the Ethical Code of Civil Servants of the Republic of Kazakhstan.
Regulatory legal acts and amendments to them are regularly published on social networks and on the official website of the state body. As well as information about the department's work, there is a news feed.
In the building of the department, the standards of all public services provided by the state body are posted on the stands, and information aimed at preventing corruption is posted.
It should be noted that the Department constantly organizes the broadcast of videos on the procedure for providing public services and combating domestic corruption.
In order to provide assistance to citizens who do not have computers and an Internet connection, a self-service corner is equipped.
1. Personnel management, including the identification of positions subject to corruption risks
Naming of corruption risk in NPAs, business processes
Personnel management, including the identification of positions subject to corruption risks.
1. Description of corruption risk
During budget planning, it is possible to include information in the budget application that affects the increase in allocated funds.
An approximate list of corruption-causing functions
Job functions related to the right to make decisions and perform organizational and managerial functions.
List of positions subject to corruption risks
Head of the Department of Employment and Social Programs of Sarani City
Recommendations for its elimination
When implementing the budget planning procedure, strictly follow the relevant regulations. Avoid planning expenses that do not meet the standards.
2. Description of corruption risk
The possibility of unlawful granting of rights to the entrusted property to other persons, the use of the entrusted state property in personal interests.
An approximate list of corruption-causing functions
Job functions related to accounting and expenditure of inventory items.
List of positions subject to corruption risks
Head of the Department of Employment and Social Programs of Sarani, Chief Accountant of the Department of Employment and Social Programs of Sarani, Head of the household of the Department of Employment and Social Programs of Sarani.
Recommendations for its elimination
Timely inventory of the material assets of the state institution. Compliance with accounting procedures for inventory items. Ensuring the safety of state property.
3. Description of corruption risk
An approximate list of corruption-causing functions Job functions related to the performance of functional duties.
An approximate list of corruption-causing functions
Job functions related to the performance of functional duties.
List of positions subject to corruption risks
All employees of the institution.
Recommendations for its elimination
Not to disclose information received during the performance of official duties affecting the personal life, honor and dignity of citizens, and not to require them to provide such information, except in cases provided for by the laws of the Republic of Kazakhstan.
4. Description of corruption risk
The possibility of rejecting an application on formal grounds, requesting documents that were not provided for, «delaying» the review period, and unlawfully refusing to issue a result in the provision of public services.,
An approximate list of corruption-causing functions
Official functions related to the provision of public services.
List of positions subject to corruption risks
Officials who provide public services.
Recommendations for its elimination
Ensuring the improvement of the quality and accessibility of public services. Ensuring that service recipients are informed in an accessible form about the procedure for providing public services. Professional development of specialists providing public services.
5. Description of corruption risk
The possibility of arbitrary planning, restriction of competition («adjustment») of technical specifications and qualification requirements, non-competitive procurement method, rejection of applications on formal grounds in the organization and conduct of public procurement.
An approximate list of corruption-causing functions
Official functions related to the organization of public procurement.
List of positions subject to corruption risks
Head of the Department of Employment and Social Programs of Sarani, Chief Accountant of the Department of Employment and Social Programs of Sarani, specialist in public procurement of the Department of Employment and Social Programs of Sarani.
Recommendations for its elimination
To ensure transparency in the expenditure of budget funds allocated for conducting public procurement procedures for works, goods and services for the institution in accordance with the law, publish the approved annual public procurement plan on the web portal. To prevent the purchase of goods, works and services that are not provided for in the approved annual public procurement plan.
2. Conflict of interest resolution
Naming of corruption risk in NPAs, business processes
Conflict of interest resolution
1. Description of corruption risk
A conflict of interest can create a corruption risk when a person's personal interest can affect the proper performance of their official duties. This situation may lead to harm to the rights and legitimate interests of citizens, organizations, society and the State.
Recommendations for its elimination
Training and education of officials on anti-corruption issues. Creation of transparent and open decision-making mechanisms. Strengthening the system of internal control and responsibility for corruption offenses. Civil servants should take measures to prevent and resolve conflicts of interest.
3. Provision of public services
Naming of corruption risk in NPAs, business processes
Provision of public services.
1. Naming of corruption risk in NPAs, business processes
According to the Order of the Deputy Prime Minister - Minister of Labor and Social Protection of the Population of the Republic of Kazakhstan dated June 30, 2023 No. 283 «On approval of the Rules for providing sanatorium treatment to persons with disabilities and children with disabilities in accordance with the individual program of habilitation and rehabilitation of persons with disabilities», persons with disabilities (hereinafter referred to as LSI) are provided with state the service «Registration of documents for providing persons with disabilities and children with disabilities with sanatorium treatment».
According To The Order Of The Deputy Prime Minister – The Minister of Labor and Social Protection of the Population of the Republic of Kazakhstan dated June 30, 2023 No. 287 «On approval of the Rules for providing persons with disabilities with prosthetic and orthopedic care, technical auxiliary (compensatory) means, and special means of transportation in accordance with the individual program of habilitation and rehabilitation of persons with disabilities, including the timing of their replacement» provides 3 public services: «Registration of documents for providing persons with disabilities with prosthetic and orthopedic care», «Registration of documents for providing persons with disabilities with technical and auxiliary (compensatory) means», «Registration of documents for providing persons with disabilities with special means of transportation».
During 2024, 816 of the above–mentioned public services were provided, including through the service provider – 3 applications were accepted from persons with disabilities from labor injury or occupational disease.
According to the above rules, when applying for public services from persons with disabilities due to an occupational injury or occupational disease, information about an industrial accident that led to disability and information about the termination of the activity of an individual entrepreneur employer or the liquidation of a legal entity that caused an occupational injury or occupational disease are additionally requested from the relevant state bodies. information systems.
Currently, when submitting an application through the egov e–government portal, there is no integration to obtain information about the termination of the activity of an individual entrepreneur employer or the liquidation of a legal entity that caused a labor injury or occupational disease and a scanned copy is not attached.
Description of corruption risk
Since it is impossible to submit an application through the egov e-government portal, applications are submitted through the department with copies of the relevant documents attached, thus the possibility of providing false documents is not excluded.
Recommendations for its elimination
Send suggestions/recommendations to the Department of Information Technology Development and quality monitoring of public services of the State Institution «Office of the Mayor of Sarani»:
1) To obtain digital documents or necessary information from relevant state information systems, implement measures to integrate with relevant state information systems and eliminate a technical error when uploading a scanned document.
2) Exclude from the register 7 public services for the registration of documents for persons with disabilities for the registration of documents for rehabilitation and social services, as currently applications are received without declaration, i.e. in proactive and electronic formats, the order of issue is formed in the automated information system «E-sobes».
2. Naming of corruption risk in NPAs, business processes
According to the Order of the Minister of Industry and Construction of the Republic of Kazakhstan dated December 8, 2023 No. 117. (Registered with the Ministry of Justice of the Republic of Kazakhstan on December 12, 2023 No. 33763) «On approval of the Rules for the provision of housing assistance», the state service «Appointment of housing assistance» is implemented through the State Corporation «Government for Citizens» and the web portal «electronic governments». The period of rendering public services is 6 working days.
However, it has been established that no changes have been made to the regulatory legal act adopted by the decision of the Saransk City Maslikhat dated March 28, 2024 No. 103 «On Determining the amount and procedure for housing assistance in the city of Sarani and the village of Aktas» (Registered with the Department of Justice of the Karaganda Region on April 1, 2024 No. 6578-09).
Description of corruption risk
According to the deadline for the provision of public services, the regulatory legal act of the Saransk City Maslikhat contradicts the Order of the Minister of Industry and Construction of the Republic of Kazakhstan.
Recommendations for its elimination
The State Institution «Department of Employment and Social Programs of Sarani City», as the program administrator, should develop a project to amend the regulatory legal act and submit it to local representative bodies for consideration.
3. Naming of corruption risk in NPAs, business processes
When analyzing the regulatory legal acts of the state service «Issuance, extension and revocation of a permit for a labor immigrant», the following legal conflicts were identified:
Description of corruption risk
Subparagraph 5 of paragraph 15 of the Rules states that the amount of the advance payment for individual income tax (hereinafter referred to as the IIT) is in accordance with paragraph 2 of Article 360 (4 MCI) or paragraph 5 of Article 658 (2 MCI) The Code of the Republic of Kazakhstan «On Taxes and other mandatory payments to the budget».
However, since 01.01.2025, amendments have been made to the Code of the Republic of Kazakhstan «On Taxes and other mandatory payments to the Budget», paragraph 2 of Article 360 on the payment of individual income tax in the amount of 4 MCI has been canceled. To date, the payment of the IIT by a labor immigrant is made in the amount of 2 MCI in accordance with the current paragraph 5 of Article 658 of the Code of the Republic of Kazakhstan «On Taxes and other mandatory payments to the budget»,
Recommendations for its elimination
State Institution «Department of Employment and Social Programs of Sarani city» to make appropriate proposals to the Ministry of Labor and Social Protection of the Population of the Republic of Kazakhstan:
- it is necessary to amend the Rules of Public Services approved by the Order of the Minister of Labor and Social Protection of the Population of the Republic of Kazakhstan dated July 31, 2024 No. 288, namely, to amend in accordance with the amendments to the Code of the Republic of Kazakhstan «On Taxes and Other mandatory Payments to the Budget», in subparagraph 5) of paragraph 15 of the Rules to cancel the payment of individual income tax in the amount of 4 MCI, paragraph 2 of Article 360.
4. Naming of corruption risk in NPAs, business processes
When analyzing the regulatory legal acts of the state service «Issuance, extension and revocation of a permit for a labor immigrant», the following legal conflicts were identified:
Description of corruption risk
According to paragraph 19 of the Rules, an employment permit is issued to an immigrant for the period specified in the application for the issuance or extension of the permit and may range from 1 (one) to 12 (twelve months), however, in paragraph 2, Article 43-2 of the Law on Migration, the permit is extended for the period specified in the application and may be one, two or three months.
Thus, according to the Rule, a labor immigrant can apply for up to 12 months, and according to the law «On Population Migration» for up to 3 months.
Recommendations for its elimination
State Institution «Department of Employment and Social Programs of Sarani city» to make appropriate proposals to the Ministry of Labor and Social Protection of the Population of the Republic of Kazakhstan:
- to amend the Rules of Public Services approved by the Order of the Minister of Labor and Social Protection of the Population of the Republic of Kazakhstan dated July 31, 2024 No. 288, namely paragraph 19 of the Rules, the permit is issued for the period specified in the application of the recipient and may be from 1 (one) to 3 (three) months.
5. Naming of corruption risk in NPAs, business processes
When analyzing the regulatory legal acts of the state service «Issuance, extension and revocation of a permit for a labor immigrant», the following legal conflicts were identified:
Description of corruption risk
In paragraph 26 of the Rules, «A service recipient who has received a permit for a period of 12 (twelve) months, or whose permit, subject to extensions, has reached 12 (twelve) months, submits an application for a new permit within 4 (four) calendar days prior to the expiration of the current permit». Thus, according to the Rules, a labor immigrant does not need to leave Kazakhstan, he can indefinitely apply for an extension or for a new labor permit, which contradicts the Law on Population Migration (paragraph 1 of Article 43-1 «The maximum period of continuous temporary residence of a labor immigrant in the Republic of Kazakhstan may not exceed twelve months»).
Recommendations for its elimination
State Institution «Department of Employment and Social Programs of Sarani city» to make appropriate proposals to the Ministry of Labor and Social Protection of the Population of the Republic of Kazakhstan:
- it is necessary to amend the Rules of Public Services approved by the Order of the Minister of Labor and Social Protection of the Population of the Republic of Kazakhstan dated July 31, 2024 No. 288, namely paragraph 26 of the Rules, specifying that the maximum period of continuous temporary residence of a labor immigrant in the Republic of Kazakhstan may not exceed twelve months.
6. Naming of corruption risk in NPAs, business processes
When analyzing the regulatory legal acts of the state service «Issuance, extension and revocation of a permit for a labor immigrant», the following legal conflicts were identified:
Description of corruption risk
According to the Standard, the validity period of the imputed medical insurance must be valid for at least the period specified in the application.
In practice, if, at the time of applying, the immigrant's insurance covers the validity period of the permit, but the PSC made a mistake when sending the documents (they did not fully attach all the necessary documents, did not scan the documents clearly, after which they are unreadable, etc.), the employment department decides to refuse to issue the permit, then after the second The immigrant's insurance no longer covers the period specified in the application, through no fault of his own, but according to the Rules, the employment department must refuse to approve the application.
Earlier in the Rules on the provision of public services. It was not specified that the duration of medical insurance should be valid for at least the period specified in the application. Thus, the labor immigrant applied for valid medical insurance at the time of filing the application. At the end of the period of validity of medical insurance, the migrant worker applied for a new medical insurance.
Recommendations for its elimination
State Institution «Department of Employment and Social Programs of Sarani city» to make appropriate proposals to the Ministry of Labor and Social Protection of the Population of the Republic of Kazakhstan:
- it is necessary to amend the Standard of Public Services approved by the Order of the Minister of Labor and Social Protection of the Population of the Republic of Kazakhstan dated July 31, 2024 No. 288, namely, in the list of documents and information required from the service recipient to provide public services to remove the validity period of imputed medical insurance.
7. Naming of corruption risk in NPAs, business processes
When analyzing the regulatory legal acts of the state service «Issuance, extension and revocation of a permit for a labor immigrant», the following legal conflicts were identified:
Description of corruption risk
According to the Rules, the term of the medical report form 028/u should not exceed 12 months. When submitting documents by labor immigrants, it was found that the validity period in this form is 3 months. Thus, when the permit is extended, form 028/y is no longer valid, but since the list of necessary documents for the extension of the work permit does not include a medical report on the health status of a foreigner, labor immigrants do not undergo repeated medical examinations and actually work with an expired certificate form 028/y. Previously, according to the Rules, labor immigrants received a medical certificate form 075/y, which is valid for 12 months, and there were no such facts of overdue medical examinations when the permit was extended.
Recommendations for its elimination
State Institution «Department of Employment and Social Programs of Sarani city» to make appropriate proposals to the Ministry of Labor and Social Protection of the Population of the Republic of Kazakhstan:
- it is necessary to amend the Standard of Public Services approved by the Order of the Minister of Labor and Social Protection of the Population of the Republic of Kazakhstan dated July 31, 2024 No. 288, namely, to add a medical certificate valid at the time of application to the list of documents and information required from the service recipient to extend the work permit.
8. Naming of corruption risk in NPAs, business processes
When analyzing the regulatory legal acts of the state service «Issuance, extension and revocation of a permit for a labor immigrant», the following legal conflicts were identified:
Description of corruption risk
Paragraph 30 of the Rules stipulates that the service provider registers employment contracts between the employer and a labor immigrant in the AIS «IRS» system, but in fact this work is not being carried out due to the lack of the possibility of registering employment contracts by specialists of the employment department in the AIS «IRS» system.
Recommendations for its elimination
State Institution «Department of Employment and Social Programs of Sarani city» to make appropriate proposals to the Ministry of Labor and Social Protection of the Population of the Republic of Kazakhstan:
- it is necessary to exclude paragraph 30 from the Rules of Public Services, approved by the Order of the Minister of Labor and Social Protection of the Population of the Republic of Kazakhstan dated July 31, 2024 No. 288, since the service provider is unable to register employment contracts between an employer and a labor immigrant in the AIS «IRS» system.
9. Naming of corruption risk in NPAs, business processes
When analyzing the regulatory legal acts of the state service «Issuance, extension and revocation of a permit for a labor immigrant», the following legal conflicts were identified:
Description of corruption risk
According to the Rules, when applying for an extension of a work permit, an immigrant must provide an employment contract with an employer. A labor immigrant is unable to provide an employment contract, as the employer has concluded an electronic employment contract with him on the website. enbek.kz.
Recommendations for its elimination
State Institution «Department of Employment and Social Programs of Sarani city» to make appropriate proposals to the Ministry of Labor and Social Protection of the Population of the Republic of Kazakhstan:
- it is necessary to amend the Standard of Public Services approved by the Order of the Minister of Labor and Social Protection of the Population of the Republic of Kazakhstan dated July 31, 2024 No. 288, namely, to the list of required documents for the provision of public services when extending an employment permit, to replace the employment contract with a certificate of electronic employment contract on the website enbek.kz.
4. Development and allocation of budgetary and financial resources
Naming of corruption risk in NPAs, business processes
Development and allocation of budgetary and financial resources.
1. Description of corruption risk
The assumption of misuse of budget funds when making financial payments. Late budget execution, non-compliance with the payment schedule.
Recommendations for its elimination
When using budget funds, do not allow misuse. To prevent non-disbursement of budget funds based on the results of the financial year. In the process of budget execution, be guided by the relevant legislative acts.
5. Conclusion of contracts with individuals and legal entities.
Naming of corruption risk in NPAs, business processes
Conclusion of contracts with individuals and legal entities.
1. Description of corruption risk
Risks associated with interactions between organizations, suppliers, business partners, and officials. Offers of improper benefits, bribes or promises, as well as unfair fulfillment of obligations.
Recommendations for its elimination
Ensuring transparency and openness in procurement procedures, ensuring free access to information about concluded contracts. Preventing the conclusion of contracts with individuals and legal entities that do not comply with current legislation.
Head of the State Institution «Department of
Employment and Social Programs of the city of Sarani» M. Shegai