Procurement Practices
KEGOC JSC has established an effective procurement system based on the principles of transparency, openness, equality, and the promotion of fair competition.
In 2025, the Company’s procurement activities were carried out in accordance with the Procurement Procedure of Samruk-Kazyna JSC and organizations in which Samruk-Kazyna JSC directly or indirectly owns 50 % or more of the voting shares (interests) through ownership or trust management, as approved by the Fund’s Board of Directors.
The priorities of procurement activities include:
- purchasing goods from organizations involving individuals with disabilities that are registered in the Samruk-Kazyna Group supplier registry (including individual entrepreneurs with disabilities) and that manufacture the procured products;
- purchasing goods from manufacturers of the procured goods who are registered in the Samruk-Kazyna group manufacturer registry;
- conducting procurement among pre-qualified potential suppliers.
The Company applies a preliminary qualification procedure for potential suppliers, which includes assessing compliance with the qualification requirements defined under the above Procedure. This assessment is conducted through questionnaires and audits.
As part of the preliminary qualification procedure, potential suppliers are evaluated based on the following criteria:
- legal compliance;
- organization of contractual activities;
- availability of supplier resources;
- quality assurance of goods, works, and services;
- project and risk management; occupational health and safety;
- environmental protection.
KEGOC JSC also took measures to support manufacturers of procured goods as stipulated by the relevant procedure.
Potential suppliers are not eligible to participate in the Company’s procurement procedures if:
- the potential supplier, its subcontractor (co-executor), or consortium member is listed in the register of unscrupulous participants of public procurement and/or in the register of dishonest suppliers, and/or in the list of unreliable potential suppliers (suppliers) of Samruk-Kazyna JSC, and/or in the list of debtors recognized bankrupt by a court decision in force;
- the potential supplier and/or its subcontractor (co-executor), and/or their executives or founders (Shareholders) are listed among entities and individuals associated with the financing of terrorism and extremism, or with the financing of the proliferation of weapons of mass destruction, as defined by the Law of the Republic of Kazakhstan On Counteracting Legalization (Laundering) of Proceeds from crime and financing of terrorism;
- the potential supplier is a legal entity, the place of its registration being a state or territory included in the list of states with preferential taxation approved by the authorised state body responsible for overseeing tax and mandatory payment collection.
Accordingly, during procurement procedures, potential suppliers are checked for the presence or absence of restrictions established by the Procedure.
KEGOC JSC ensures that potential suppliers have the right to submit appeals and complaints in the event of disagreement with the actions (or inaction) of the procurement organizer or decisions of the tender or expert commission.
All appeals are reviewed in accordance with established procedures, with a mandatory analysis of the claims presented. Based on the results, reasoned decisions are made to either uphold or reject the complaint, with subsequent notification of the applicants.
For ease of interaction with suppliers, procurement procedures are carried out via the electronic procurement portal of Samruk-Kazyna JSC (www.zakup.sk.kz), which ensures the engagement of a larger number of suppliers of goods, works, and services and creates a competitive environment that contributes to increased efficiency of procurement activities.
The current Annual Procurement Plan and Long-Term Procurement Plan for goods, works and services of KEGOC JSC are published on the Samruk-Kazyna JSC procurement portal (www.zakup.sk.kz), and on the KEGOC JSC website www.kegoc.kz in the Procurement section.
Procurement by KEGOC JSC in 2025, KZT billion
| KEGOC JSC | Energoinform JSC | Total | |
|---|---|---|---|
| Goods (excluding electricity from neighbouring countries, including the Russian Federation and Kyrgyz Republic) | 34.67 | 0.25 | 34.92 |
| Works | 18.19 | 0.01 | 18.2 |
| Services | 15.72 | 0.42 | 16.14 |
| Electricity | 68.58 | 0.68 | 69.26 |
| Total | 137.16 | 1.36 | 138.52 |
To promote the principles of sustainable development and ESG among its counterparties, KEGOC JSC has developed and implemented a Supplier Code of Conduct based on the provisions of the UN Global Compact and the Sustainable Development Goals (SDGs).
The Code is a mandatory part of all supplier contracts and reflects the Company’s commitment to forming a responsible and ethical supply chain. All KEGOC JSC suppliers are required to comply with the provisions of this Code, including the following principles:
- refrain from engaging in corruption-related offences in their work;
- prohibit their employees, representatives, and subcontractors under contracts with the Company from commercial bribery and other corrupt activities;
- eliminate all forms of illegal forced labour;
- prohibit child labour;
- prevent any form of discrimination, including in relation to employment and work activities;
- comply with statutory requirements on working hours and employee rest;
- comply with statutory requirements on minimum wages;
- comply with labour legislation.
The Code establishes requirements for suppliers’ compliance with the following principles:
- Fair employment practices;
- Ethical principles;
- Anti-corruption requirements;
- Occupational health and safety;
- Environmental protection;
- Confidentiality and data security.
KEGOC JSC implements the procurement category strategies of Samruk-Kazyna JSC (PCS), aimed at optimizing approaches to the procurement of goods, works, and services, based on maximizing benefits in the long- or short-term perspective, and including conclusions drawn from analyses of past expenditures, future needs, supply markets, and business requirements.
In 2025, Samruk-Kazyna JSC implemented PCS for the categories “IT Equipment”.
Supplier Indicators for Goods in 2025, KZT
| Suppliers – Registry (MSR) | |
| including | |
| In PCS framework | |
| Not in PCS framework | |
| Total Contract Amount | |
| Suppliers – Non-registry (MSR) | 1 |
| including | |
| In PCS framework | 1 |
| Not in PCS framework | |
| Total Contract Amount | 7,946,250 |
| Suppliers – Registry (SSR) | 1 |
| including | |
| In PCS framework | 1 |
| Not in PCS framework | 0 |
| Total Contract Amount | 1,925,550 |
| Suppliers – Non-registry (SSR) | 1 |
| including | |
| In PCS framework | 1 |
| Not in PCS framework | 0 |
| Total Contract Amount | 6,020,700 |
In 2025, the share of domestic value in KEGOC JSC’s procurement of goods, works, and services was 65 %, including:
- 64 % – in goods procurement (excluding electricity supplies from neighboring countries);
- 67 % – in works and services procurement.
For the subsidiary Energoinform JSC, the domestic value shares were:
- 42.98 % – in goods procurement;
- 99.71 % – in works and services procurement.