АО НК "КАЗМУНАЙГАЗ"
The Information Disclosure Policy of NC KazMunayGas JSC
- The Information Disclosure Policy (hereinafter referred to as the Policy) is a set of principles and procedures of NC KazMunayGas JSC (hereinafter referred to as the Company) during information disclosure due to the legislation of the Republic of Kazakhstan and the Charter and connected with the activity of the Company (hereinafter referred to as interested persons) in the volume necessary for making investment and management decisions and taking actions which can influence the financial and economic activity of the Company.
- The policy aims at full and timely disclosure of information about the Company, its current activity, state and developments perspectives to stakeholders in accordance with the legislation requirements of the Republic of Kazakhstan, the Company Charter, and the Rules of information disclosure and best world practices of corporate governance.
- To achieve the aim of the Policy the basic tasks include:
- timely disclosure of exact information about the Company;
- disclosure of additional information which enables investment attractiveness growth owing to increasing transparency of the Company.
- The Policy should enable creating favorable image of the Company, increasing the assets cost, attracting investments, and increasing production and finance indicators of the Company operation.
- The information disclosure policy is determined by the Board of Directors of the Company.
- Information disclosure order is defined by the Rules of information disclosure of the Company and other internal documents.
The basic principles of the Policy are as follows:
- Regularity – constant and systematic disclosure of information about the Company to stakeholders;
- Promptness – providing maximum short time periods of informing interested persons on the most significant events and facts which can influence the financial and economic operation of the Company and regard interests of the persons interested;
- Accessibility – using information spreading methods by the Company which allow free, easy and the least costly access of interested persons to the information disclosed;
- exactness – giving information to interested parties without garbling facts which are known to the Company;
- giving information in volume sufficient for forming the fullest knowledge of interested persons about the real situation in the question they are interested in;
- balance – providing reasonable balance of openness and transparency by the Company on the one hand, and confidentiality on the other one to ensure maximum rights of the interested parties for obtaining information, but under conditions of strict observance of the interests of the Company, the Sole shareholder regarding access limitation to the information which makes up state, official, commercial and other secret of the Company protected by the Law;
- equal rights – ensuring equal rights and opportunities in information gaining, excluding cases which are stipulated by the legislation of the RoK and internal documents of the Company;
- information resources security – the right of the Company to use means and methods allowed by the legislation of the Republic of Kazakhstan to protect information which makes up official, commercial secrets and other secrets of the Company protected by law;
- objectivity – when showing its activity the Company must disclose positive and negative information in equal volume.
Policy implementation mechanism
- To implement the Policy the Company establishes:
additional information disclosure procedure according to significance of facts and events and to timeliness of public disclosure:
- disclosure order of information which is stipulated by the legislation of the Republic of Kazakhstan, touching interests of the Sole Shareholder;
- about executing large transactions;
- about related persons of the Company;
- in a form of the Company securities issue prospectus;
- in a form of report on result of the Company securities floating;
- in a form of the Charter of the Company;
- in a form of annual financial statements of the Company;
- other information covered by the legislation of the Republic of Kazakhstan;
confidential information protection procedure in accordance with the legislation of the Republic of Kazakhstan and internal documents of the Company by observing reasonable balance between the Company’s openness and absolute protection of internal corporate information by:
- about executives of the Company;
- on the Company organization chart;
- about the members of the Committees of the Board of Directors;
- about the Company’s property structure;
- on the Company strategy, development and reforming projects;
- about the dividend policy of the Company;
- about branches and/or representative offices of the Company;
- on corporate governance practice of the Company;
- in a form of audit conclusions;
- in a form of quarterly financial statements of the Company;
- in a form of the Company’s annual report;
- about essential corporate events; other information;
information spreading and use control system in the Company by:
- defining lists of data which are confidential;
- defining persons which have access to confidential information;
- ensuring observance of confidentiality and conditions of working with confidential information;
Responsibility of executives and employees of the Company for confidential information integrity and observance of requirements set for information disclosure by:
- defining methods and forms of information spreading;
- defining persons responsible for preparing and spreading information subject to disclosure;
- defining the order of information disclosure by executives and employees of the Company.
- allocation of responsibility of President (Chairman of the Management Board) and other executives and employees of the Company for complete and reliable nature of information disclosed about the Company and its operation and its protection;
- introduction of confidential information non-disclosure duties in employment contracts of executives and employees of the Company, and statement of the time of the information non-disclosure after employment termination.