In 2024, Kazakhstan took a significant step toward improving its governance systems by developing a comprehensive methodology aimed at establishing anticorruption standards[1] across public institutions and quasi-public sector.
The framework—aligned with Kazakhstan’s Anti-Corruption Policy Concept and several key legislative acts, such as the laws On Combating Corruption and On the Civil Service, and international commitments like the United Nations Convention against Corruption—represents a concerted effort to address systemic vulnerabilities.
By focusing on transparency, accountability, and preventive measures, the methodology pushes reforms that could improve governance, enhance public trust, and promote sustainable development in Kazakhstan.
One of the primary challenges in effectively implementing anticorruption measures in Kazakhstan has been the absence of a unified, standardized approach to creating anticorruption frameworks. This gap has often led to inefficiencies and inconsistencies in the application of anticorruption standards across the different sectors of government and the public sector. To address this issue, Kazakhstan’s Anti-Corruption Agency partnered with the Asian Development Bank (ADB) under the Joint Government of Kazakhstan and ADB Knowledge and Experience Exchange Program to design a standardized methodology that provides a detailed blueprint for organizations seeking to establish effective anticorruption compliance frameworks.
The methodology developed emphasizes a multifaceted approach that addresses a broad range of governance concerns, from internal controls to personnel management, procurement processes, and supplier relations. It aims to provide a holistic framework that empowers public and private entities to identify risks, adopt preventive measures, and foster transparency.
Key features of the methodology
The new framework—Methodological Recommendations—introduces several structured measures to enhance integrity and reduce corruption risks in both the public and quasi-public sectors. The measures include multiple levels of governance and structure to ensure that these are applied in everyday practices:
The first element of the methodology is the identification and mitigation of corruption risks. Organizations are required to carry out annual internal analyses using defined risk indicators. Once the assessment is complete, each risk is evaluated along two axes: risk likelihood (from very rare to very often) and risk impact (from minor to severe), scored on a scale from 1 to 5. These dimensions form the basis of the visual risk map illustrated below.
Figure 1. Example of Corruption Risk Map
This process results in two separate risk maps. The first map focuses on risks associated with legislative frameworks, such as inconsistencies, ambiguous formulations, or gaps that can be exploited. The second map highlights risks embedded in organizational processes and managerial operations (e.g., recruitment, budgeting, and procurement). Including the risk maps supports a more structured and data-driven approach to corruption prevention. It allows institutions to clearly visualize, assess, and prioritize corruption risks, helping them target vulnerabilities more effectively and implement appropriate mitigation strategies.
Recognizing that conflicts of interest are often precursors to corruption, the framework places emphasis on mitigation. It introduces mandatory disclosure of financial interests by public officials, enforces restrictions on certain activities, and sets up conflict management protocols. By ensuring transparency, it safeguards decision-making processes from undue influence.
The methodology also strengthens financial controls by mandating asset and income declarations for public officials, aligning with international standards like those of the United Nations Convention Against Corruption. Regular audits and financial monitoring are incorporated to detect discrepancies, hold officials accountable, and prevent illicit enrichment.
Sustainable anticorruption efforts require a cultural shift within institutions. The framework advocates for training programs and awareness campaigns to instill transparency, ethics, and accountability as core values across all levels of governance.
Transparency in government operations is promoted through open data initiatives and public consultations. Citizens are encouraged to engage in feedback mechanisms, ensuring that the public can hold government entities accountable. This openness builds trust in governance and reinforces the importance of public participation in decision-making.
The methodology also advocates for merit-based recruitment, promotion, and career advancement within public institutions. Clear criteria for personnel decisions are established to ensure fairness and reduce favoritism. Independent oversight of human resource practices further ensures transparency and accountability in the hiring process.
To address corruption in procurement, the methodology introduces standardized procedures and electronic systems to increase transparency and reduce discretionary decision-making. This approach ensures that procurement contracts are awarded fairly, based on clear criteria, and subject to regular monitoring and oversight.
The framework extends the anticorruption standards to quasi-public and private organizations, encouraging them to adopt compliance programs. These entities are required to implement internal policies promoting transparency, fairness, and accountability. This ensures a unified approach to anticorruption efforts across all sectors, creating a more comprehensive governance system.
Adopted in December 2024, the Methodological Recommendations represent a collaborative, multisectoral approach to anticorruption reform. Government institutions and quasi-public entities are tasked with integrating the methodology into their operations, while Kazakhstan’s Anti-Corruption Agency oversees its implementation. Regular evaluations will ensure its adaptability to emerging challenges.
Stakeholder engagement—through roundtable discussions, workshops, and consultations involving civil society, government officials, and private sector representatives—will be critical in the evaluation process, ensuring continuous refinement and alignment with evolving governance needs.
The adoption of the Methodological Recommendations signals a transformative step in Kazakhstan’s efforts to combat corruption and enhance governance. By addressing systemic weaknesses and fostering a culture of integrity, the framework is expected to reduce corruption cases, enhance public trust, and attract greater foreign investment.
Kazakhstan’s approach serves as a potential blueprint for other developing economies in Asia facing similar challenges. By combining international best practices with localized solutions, the country’s anticorruption framework illustrates how collaborative efforts can drive meaningful governance reforms.
Ultimately, the initiative paves the way for more transparent and accountable public institutions and quasi-public sector in Kazakhstan—supporting the country’s broader aspirations for sustainable development and good governance.
Anti-Corruption Agency of the Republic of Kazakhstan. 2024. Methodological Recommendations for Development of Anti-Corruption Standards. Order of the Chairman of the Anti-Corruption Agency of the Republic of Kazakhstan No. 285.
Law of the Republic of Kazakhstan. 2015. On Combating Corruption № 410-IV LRK. 18 November.
Law of the Republic of Kazakhstan. 2015. On the Civil Service № 416-IV LRK. 23 November.
United Nations Office on Drugs and Crime. 2004. United Nations Convention Against Corruption.
Saltanat Yunussova is an expert in project management with focus on governance, economics and education policy. She has successfully managed over 50 knowledge initiatives at the Asian Development Bank and has handled broad scope of projects under the Organisation for Economic Co-operation and Development, UNICEF, UNESCO, World Bank, and Kazakhstan’s leading think tanks. She holds degrees from University of Konstanz and University of Science and Technology Beijing.
Aizhanat Kushtarova is an expert in anticorruption, civil service development, and behavior insights. She has been involved in developing anticorruption legislation and public sector reforms in Kazakhstan since 2003. She is responsible for Kazakhstan’s ratification of the United Nations Convention against Corruption and joining the Anti-Corruption Network Organisation for Economic Co-operation and Development. She holds a master’s degree in international politics from City University London.
Aipara Adibay has over 12 years of experience in anticorruption compliance, including in the implementation of monitorship recommendations and automated compliance platform methodologies. She is the national methodology developer for Kazakhstan’s anticorruption standard. Previously, she served as chief ethics and compliance officer for Beeline/Veon and as antibribery and corruption compliance trainer for quasi-state and private organizations. She is also a speaker and author of a practical anticorruption compliance course and a member of the Compliance and Business Ethics Association.
