ТОО "Caspian Engineering & Research"  



This Code of Business Behavior and Ethics (hereinafter - the Code) has been developed in accordance with the Charter of Caspian Engineering & Research LLP (hereinafter referred to as CE&R or the Company) and the requirements of the legislation of the Republic of Kazakhstan. This Code contains general guidelines for the conduct of business by the Company, consistent with the highest standards of business ethics. This Code should be regarded as the minimum standard intended to withhold from offenses and to stimulate honest and ethical behavior. To the extent that the Code requires a higher standard than that provided business practice or applicable laws, rules or regulations, the Company will adhere to these higher standards. The implementation of the provisions of this document is aimed at the solution of the following main tasks:

  • Maintaining high reputation of CE&R LLP in relations with the customers and partners;

  • Acquirement of the rules of business behavior, responsibility for the conscientious performance of their official duties by the employees of CE&R LLP;

  • Integrity, honesty, politeness and correctness in the relationship between colleagues, creating an atmosphere of mutual understanding, trust and cooperation, as well as creating a favorable socio-psychological atmosphere in the team;

  • Exchange of experience and information between colleagues, helping each other to achieve the best results, the ability to work in a team;

  • Punctual, precise and timely fulfillment of its obligations to the Company and colleagues at work, self-discipline, organization and the ability to work on the result;

  • Rational use of own working time and time of their colleagues, as well as the Company's assets;

  • Aspiration of the employees to a healthy lifestyle and respect for family values;

  • Improving the efficiency of business interaction between employees of CE&R LLP.
  • This Code applies to all officers and employees of the Company, including the General Director, Deputy of General Director, Director of Finance, Director of Business Development, (hereinafter referred to as the Top Management).

    Implementation and compliance with the requirements of this Code are possible only with the assistance of all employees of CE&R LLP and their proper conduct. Each employee is obliged to adhere to the rules of behavior that contribute to the implementation of these rules.


    In relations with external interested parties (the state, suppliers, customers, etc.), the interests of the Company are represented by its employees, therefore the norms of this Code section apply equally to the Company and its employees.

    Due to the high influence of the trust of counterparties and business partners, as well as other interested parties on the Company's activities, the Company pays special attention to maintaining and developing stable and trusting relationships with the interested parties both in the short and long term.

    The company values its business reputation and image. The Company's external relations are built on the basis of respect for the principles of mutual respect, openness, honesty and responsibility.

    The Company adheres to the principle of neutrality in relation to financial and industrial groups, state bodies, political parties and associations.

    2.1 Business partners

    The company interacts with business partners (customers, suppliers, contractors, consultants) on the basis of long-term cooperation, mutual benefit, respect, trust, honesty and justice.

    The business and public reputation of its partners is important for the Company, the Company responsibly approaches the choice of suppliers and contractors, paying special attention to their business ethics. Therefore, the Company works with business partners engaged only in lawful activities.

    2.2 State Bodies and Public Organizations

    The company seeks to be an example of legal and ethical obligations towards the state. In the process of interaction with the state bodies and public organizations, the Company adheres to the priority of ensuring a balance of interests of business, employees, the population of the territories of presence and society as a whole. The company considers itself as responsible for ensuring state interests in the rational use of natural resources, the introduction of innovative technologies, the creation of favorable working conditions.

    Creation of open, trusting, stable relationships with the state bodies is an precondition for the Company's business. CE&R LLP inviolately abides the legislation, ensures timely and full payment of taxes and other obligatory payments.

    2.3 Relations with the Mass Media

    At the Company website in the public mode information on the Company, its activities, functional and structural subdivisions, contact information, etc..

    The company monitors compliance with high standards in cooperation with the Mass Media (MM).

    Any contacts with Mass Media representatives - interviews, publications, participation in press conferences, press briefings - the Company's employees carry out only in consultation with the Company's Top Management within their competence.


    The reputation of an honest, open Company, strictly adhering to high standards of corporate ethics, is the key to its success and prosperity. Following the high ethical principles and maintaining the reputation of the Company is one of the main tasks of all employees. Any violation of the corporate ethics norms and rules can lead to loss of confidence in the Company by business partners and state agencies.

    Ethical standards set out standards of conduct for each employee and determined what the Company expects from them. Each employee is responsible for the implementation of these requirements.

    The Company appreciates the work of its employees and sees its responsibility in the formation and preservation in the work collective of an atmosphere of benevolence, professionalism, mutual respect, cooperation and stability. The Company strives to maintain a corporate spirit that unites all employees regardless of their position or service position in a team of professionals with a common goal.

    The Company has set itself ambitious goals and confident that their decision in the modern world is impossible without the continuous professional development of employees and increase their level of professional training.

    The Company considers it necessary to build relationships with employees on long-term basis, demonstrating the trust and openness to dialogue.

    The Company does not allow discrimination based on national, sexual, age, cultural or other grounds. The Top Management and employees do not allow actions and statements that may harm the Company to clients and their colleagues. Religious and political preferences and social activities are personal business of employees and should not interfere with the performance of their official duties and communication with colleagues at work. Officials and employees who take part in political, religious and public activities may act in these areas only on their behalf, and not as representatives of the Company.

    Cultural diversity is a solid resource of the Company, which ensures attraction to the workplace of a suitable specialist and allows increasing labor productivity by creating a creative atmosphere in the team. The right to be you in the workplace creates a solid foundation for a favorable atmosphere and the growth of personal motivation. Using cultural differences in the form of advantages, pluralism of opinions and openness lead to the formation of a more motivated work collective capable of showing high results of work.

    The Company's employees conduct their professional activities in accordance with the objectives and taking into account the values and norms adopted on the basis of the following:

  • Professionalism. All business relations of the Company's employees must be carried out on the basis of high professional standards, comply with business practice and do not contradict the law.

  • Responsibility. Every employee is responsible for his actions and decisions and is not entitled to transfer responsibility to other employees.

  • Fairness and objectivity. All management decisions and actions of the Company's employees should be honest and objective. Prejudiced attitude, both to their job duties and to colleagues are not allowed.

  • Honesty. The company makes every effort to prevent any situations in which personal interests of employees, the Company's management may be in conflict with the interests of the Company. Any abuse of official authority for their own benefit or for the benefit of third parties or to the detriment of the Company.

  • Image and reputation. Management decisions and actions of employees must meet the objectives of maintaining a positive image of the Company. Employees direct efforts to prevent situations when their actions may adversely affect the Company's business reputation.

  • Respect. Employees ensure the safety and protection of any confidential information, including information constituting commercial secrets and insider information of the Company, the misuse of which may cause damage to the Company.

  • Privacy. Employees ensure the safety and protection of any confidential information, including information constituting commercial secrets and insider information of the Company, the misuse of which may cause damage to the Company.

  • Transparency. The activities of the employees are aimed at information openness and transparency, with the provision of all interested parties with reliable complete and objective information about their activities, providing the principle of confidentiality, when this is necessary and does not contradict the current legislation of the Republic of Kazakhstan.


    4.1 Conflict of interest potential case determination

    Conflict of interest arises when the employee's personal interest in any way collides with the interests of the Company as a whole. Employees should actively avoid any personal interest that may affect their ability to act in the Company's interests, or which makes it difficult for them to perform their work objectively and effectively. The Code does not establish all the options under which a conflict of interest may arise. Cases that lead to a conflict of interest include, but are not limited to, the following situations:

  • Work in other companies. No employee can, without the consent of the Company, be an employee or otherwise connected with commercial or non-commercial organizations that compete with the Company or deprive the Company of any business.

  • Illegal personal gain. No employee shall receive unlawful personal material benefits or privileges as a result of his or her position in the Company.

  • Financial interest / participation. No employee can have any financial interest / participation (right of ownership or other interest / participation), directly or indirectly, through the spouse or other family member (defined further), in any other commercial or non-profit organization (enterprise), if This interest / participation (1) adversely affects the employee's performance of his / her duties or obligations to the Company or (2) refers to an enterprise that competes, conducts business or strives to conduct business with the Company . In the case of a transaction where the party is an enterprise with the interest / participation of a member of the employee's family, he must (1) inform the Company of the presence of an interest or participation of a member of his or her family in that enterprise, and (2) not participate in the decision on the transaction.

  • Loans or other financial transactions. No employee can get a loan or guarantees of personal obligations from any company that is an essential customer, supplier or competitor of the Company. These guidelines do not prohibit transparent transactions with recognized banks or other financial institutions.

  • 4.2 Conflict of interest information disclosure

    The Company requires that employees fully disclose information to the Company of any situations that might reasonably be assumed to lead a conflict of interest.


    During their work in the Company, employees have access to a variety of confidential information. Confidential information includes all information that is not publicly available, which could be useful to competitors, or which, if disclosed, could be harmful to the Company or its customers.

    Employees are required to keep all confidential information of the Company or third parties with whom the Company conducts business, unless the disclosure is authorized or legally binding.

    The employee's obligation not to disclose confidential information is preserved after his or her quit from the Company. Unauthorized disclosure of confidential information may damage the competitiveness of the Company or its customers and may lead to legal liability of the employee and legal liability of the Company.


    Employees must protect the Company's assets and ensure their effective use only for the purposes of legitimate business. Theft, carelessness and waste have a direct impact on the profitability of the Company. It is prohibited to use the funds or assets of the Company, whether for personal gain or otherwise, with any unlawful or inappropriate purpose.

    To ensure the protection and proper use of the Company's assets, each employee must:

  • Take reasonable care to prevent the theft of the Company's property, damage to it or its abuse;

  • Inform the immediate supervisor about the real property theft;

  • Use the Company's telephone system, other electronic communications services, written materials and other property for purposes related to business;

  • Protect all electronic programs, data, messages and written materials from accidental access by others;

  • Use the Company's property only for the purposes of legitimate business, according to how it is authorized in connection with the employment duties.
  • Employees should be aware that the Company's property includes all data and messages sent to the address of electronic or telephone systems of the Company. Employees and other users of this property should not expect inviolability with respect to these messages and data. To the extent permitted by law, the Company may, and reserves the right to, monitor all telephone and electronic communications.


    In order to consolidate the main directions for the practical implementation of intentions, the Company adopted a Policy in the field of health protection, occupational safety and environment. Contribute to sustainable development the Company strives to ensure rational use of natural resources and the constant improvement of the environmental performance. The Company strictly complies with the requirements of the legislation and international standards, industry and corporate requirements regulating the Company's activities in the field of environmental protection.

    Each employee is responsible for compliance with the requirements aimed at ensuring personal safety, the safety of colleagues and the environment. It is necessary to comply with all laws, regulations, regulations and provisions for the protection of the environment and safety. Each manager is obliged to instruct, support and monitor the activity of the employee in respect of compliance with safety rules and environmental protection. The company supports the behaviors that contribute to the improvement of the health of employees.

    The company constantly develops educational, organizational and environmental activities to reduce the risks that accompany its activities. Environmental safety and environmental protection are one of the priorities in the Company's operations. The Company intends to gradually reduce and, where possible, prevent the environmental impact arising in the course of its operations. The company considers environmental protection activities as an integral part of its business. The company uses resource-saving technologies and consequently reduces environmental and human impact.

    The company is always open to dialogue with all interested parties on environmental issues.


    The Company believes that the abidance for provisions of this Code increases the effectiveness of the Company, as well as promotes the development of effective business relationships with partners. Therefore, all the Company employees, regardless of their positions in their professional activities are obliged to comply with the provisions of this Code and to be responsible for compliance with ethical standards, provided in it.

    The company is committed to the principle of zero tolerance for inappropriate behavior of employees. For an action or failure to act that violates the provisions and requirements of this Code or undermines the reputation of the Company, an employee may be brought to disciplinary liability or other measures provided by the current legislation of the Republic of Kazakhstan, and the issue of the incompatibility of this employee with the position.

    The Company assigns increased responsibilities to the Managers of all levels. Managers are obliged to serve as a model of ethical behavior, by their example to support ethical aspects of corporate culture, if necessary, to explain to subordinates the provisions of this Code.

    Compliance with the requirements of this Code is an important criterion for evaluating the employee's work in making the promotion, professional or career advancement decisions.

    If an employee has any questions regarding the application of the norms and requirements of the Code, the difficulty in the ethical evaluation of his actions and the actions of other employees, he should seek clarification from the immediate supervisor.

    In its turn, the Company guarantees no negative consequences for anyone who has made a report about violations of the requirements of this Code (including any harassment or discrimination). Violation of the anonymity of such communication is a separate violation of the principles of this Code.

    The company expects that any interested person who is not an employee of the Company (for example, a customer, subcontractor, supplier of goods or services for the Company, etc.), will also report on such violations committed by the Company employee.

    Each employee of the Company in case of violation of the requirements of this Code has the right to an objective investigation of his departures from the norms of the Code, and also has the right to receive the results of the conducted investigation and recommendations for preventing such violations in the future.


    The Code is approved by the Supervisory Board of the Company and comes into force from the moment of its approval by the Supervisory Board of the Company. All changes and additions to the Code (approval of the Code in a new revision) are made by decision of the Company's Supervisory Board.

    Компания обеспечивает размещение The code is a public document. The Company ensures the placement of the Code and all changes to it in permanent access on the website of CE&R LLP.

    © 2017 ТОО "Caspian Engineering & Research"