Analytical Report
Internal analysis of corruption risks at the state-owned utility company "Vodokanal" of the Ridder City Akimat.
Ridder September 26, 2025
In accordance with paragraph 5 of Article 8 of the Law of the Republic of Kazakhstan "On Combating Corruption", the Model 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 No. 12, at the state-owned municipal enterprise with the right of economic management "Vodokanal" of the Akimat of the city of Ridder (hereinafter referred to as the Enterprise), as part of the working group created by order of the Director of the Enterprise No. 256-P dated August 27, 2025, an internal analysis of corruption risks was conducted for the period from September 1, 2024 to October 3, 2025.
An internal corruption risk analysis was conducted in the following areas:
- identification of corruption risks in regulatory and legal acts affecting the Company's activities;
- identification of corruption risks in the Company's organizational and managerial activities.
According to the Charter, the State Enterprise on Right of Economic Management "Vodokanal" of the Ridder City Akimat is a legal entity in the organizational and legal form of a state enterprise with the right of economic management. The founder of the Company is the Ridder City Akimat. The rights of the subject of state municipal property rights with respect to the Company's property are exercised by the Ridder City Akimat. The body implementing the management of the Company is the state institution "Department of Housing and Public Utilities, Passenger Transport, and Highways of the City of Ridder." The Company has two types of activities: water supply and sanitation services. In addition, due to the absence of legal entities in the city of Ridder that carry out flushing and cleaning of sewer networks, there is a permit from the RGU "Department of the Agency for the Protection and Development of Competition of the Republic of Karelia East Kazakhstan Region" to provide additional services:
- emptying and cleaning cesspools and septic tanks, drains and wastewater wells, servicing toilets with chemical sterilization;
- maintenance and cleaning of sewer systems and drains, including cleaning sewer pipes with flexible rods.
Director of the Enterprise - Makhambet Dauletbekuly Khamitov, appointed by Order No. 58 of the Head of the State Institution "Department of Housing and Public Utilities, Passenger Transport, and Highways of Ridder" dated September 27, 2025.
During the VAKR, the following 1 risk was identified.
I. Identification of corruption risks in regulatory acts affecting the activities of the Enterprise.
No corruption risks were identified in the regulatory legal acts affecting the activities of the State Unitary Enterprise at the Water Utility Company "Vodokanal."
II. Identification of corruption risks in the organizational and managerial activities of the Enterprise.
In the area of HR management, including the identification of positions susceptible to corruption risk:
The Enterprise has a staffing level of 212 people. The actual number of employees at the Enterprise as of September 26, 2025, is 169 (including 5 people on maternity leave), with 43 vacancies. The Enterprise's HR department is working to fill vacancies. Applications are sent to the Labor Mobility Center and also published on the Enbek.kz portal. The large number of vacancies is due to low wages.
Staff turnover:
For the period from September 1, 2024. Between September 2025 and September 2025, 61 employees were dismissed, including:
- 53 employees voluntarily dismissed.
- 0 employees dismissed for negative reasons.
- 8 employees upon reaching retirement age.
- 0 employees due to staff reductions.
There were no disciplinary actions during the analyzed period.
There were no violations of labor discipline, hiring of individuals who had previously committed a corruption offense or crime, or a criminal offense at the Company.
There is no need to conduct an anonymous survey at the State Enterprise at the Water Utility Company "Vodokanal." No employees of the State Enterprise at the Water Utility Company "Vodokanal" committed any corruption-related administrative offenses or crimes during the period from September 2024 to September 2025.
Risk #1
In the area of HR management, including identifying positions exposed to corruption risk based on the indicator:
"- the combination of the duties of a compliance officer with the company's leading lawyer, not specified in the job description"
According to Clause 10 of the Model Regulation on Anti-Corruption Compliance Services in Quasi-Public Sector Entities, "Combining the functions of an anti-corruption compliance service with the functions of other structural divisions of a quasi-public sector entity is not permitted."
Recommendations:
Take measures to fill vacant positions. Post advertisements in city social media groups and on the Company's social media page. Attract potential employees by describing the benefits and prestige of working at the Company.
Introduce and approve a separate staff position for the duties of a compliance officer.
Conflict of Interest Resolution:
During the internal analysis of corruption risks, no conflicts of interest, joint work between close relatives, spouses, or in-laws were identified.
Provision of Public Services:
In accordance with subparagraph 8) of paragraph 2 of the Standard for the Provision of Services by Consumers of Natural Monopoly Entities in the Sector of Water Supply and/or Sanitation, approved by Order No. 573 of the Acting Minister of National Economy of the Republic of Kazakhstan dated July 29, 2015, the Entity maintains a log of consumer service requests.
According to the log of consumer service requests for technical specifications for the period from September 2024 to September 2025, 29 requests from individuals were registered, of which 29 technical specifications were issued, and 9 requests from legal entities, of which 9 were issued. A total of 38 technical specifications were issued. There were no refusals.
The company conducts an annual audit of its financial statements and financial activities.
The company is not authorized to implement permitting functions.
The company is not authorized to implement control and audit functions.
Development and distribution of budgetary funds.
The company is a natural monopoly entity and provides water supply and sanitation services to the city of Ridder at rates approved by the Department of the Committee for Regulation of Natural Monopolies of the Ministry of National Economy of the Republic of Kazakhstan for the East Kazakhstan Region. The company operates using its own funds.
Contracts with individuals and legal entities:
Contracts with individuals and legal entities for the provision of services are concluded by the subscriber department of the company. The contract form is standard. The standard contract was approved by Order No. 58 of the Minister of National Economy of the Republic of Kazakhstan dated June 24, 2019.
Development and operation of information systems:
The Company is not an information systems developer.
Other matters arising from organizational and managerial activities:
Appeals from individuals and legal entities:
The Company has implemented the "E-Otіnіsh" appeals system, in which responsible employees of the Company register, record, and process appeals in accordance with the requirements of the Administrative Procedure Code of the Republic of Kazakhstan (hereinafter referred to as the APPC RK).
During the analyzed period, the Company received 63 appeals, including: 47 applications (including 2 withdrawn applications), 5 inquiries, 3 complaints, and 8 messages (suggestions).
All appeals from individuals and legal entities were reviewed within the timeframes established by law and in accordance with the APPC RK standards.
Report boxes for individuals and legal entities reporting illegal actions by Company employees have been installed in the Company's administrative building. No complaints have been received.
Identifying and mitigating corruption risks, as well as the conditions and causes that contribute to their occurrence, is an ongoing effort. Seminars are held weekly for Company personnel to explain anti-corruption legislation, liability for corruption offenses and crimes, and the basic provisions and principles of the anti-corruption policy.
The analysis identified two corruption risks related to personnel management.
The internal corruption risk analysis adhered to the principles of legality, objectivity, and comprehensiveness. The director and compliance officer (lawyer) oversee the implementation of the committee's recommendations.
Chairperson of the working group:
Director M. Khamitov
Members of the working group:
Chief Engineer V. Pchelintsev
Chief Accountant S. Bubnova
Head of the Economic Department M. Piskun
Head of the Production and Technical Department I. Smirnyagina
Head of the HR Department E. Chernigina
Leading Lawyer (Compliance Officer) N. Topelekova