Analytical Report on the Results of the Internal Analysis of Corruption Risks in the Activities of the SE «Department of Housing and Communal Services, Passenger Transport, Computational Roads, and Housing Inspection of Zhaksy District» and the SE «Department of Employment and Social Programs of Zhaksy District»
Zhaksy v. July 8, 2026
In accordance with the Law of the Republic of Kazakhstan "On Anti-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, and the Methodological Recommendations for Conducting Internal Analysis of Corruption Risks approved by the Order of the Chairman of the Anti-Corruption Agency of the Republic of Kazakhstan dated December 30, 2022 No. 488, based on the district Akim’s Order dated June 1, 2026 No. 19, the working group conducted an internal analysis of corruption risks in the activities of local executive bodies funded by the local budget of the Akimat of Zhaksy district in the following areas:
- Identification of corruption risks in regulatory legal acts affecting the activities of the department;
- Identification of corruption risks in the organizational and managerial activities of the department.
Analysis period: June 2 to June 30, 2026.
Analyzed period: January 1 to December 31, 2025.
The internal analysis of corruption risks was conducted at the SE "Department of Housing and Communal Services, Passenger Transport, Computational Roads, and Housing Inspection of Zhaksy District" and the SE "Department of Employment and Social Programs of Zhaksy District" by consolidating information, analyzing, and evaluating the results of previously conducted inspections by state bodies, information obtained from legal statistics, appeals from individuals and legal entities, and other information not restricted by law.
The working group for the internal analysis of corruption risks was formed with the following members:
Olga Fridrikhovna Bocharnikova – Head of the State Institution "Apparatus of the Akim of Zhaksy District", Chairperson of the working group;
Nazgul Sagdatovna Segizbayeva – Head of the State-Legal Department of the State Institution "Apparatus of the Akim of Zhaksy District", Deputy Chairperson of the working group;
Aida Kadyrovna Zholdybayeva – Chief Specialist of the State-Legal Department of the State Institution "Apparatus of the Akim of Zhaksy District", Secretary of the working group;
Tatyana Vasilyevna Balatskaya – Head of the Department for Analyzing the Provision of Public Services of the State Institution "Apparatus of the Akim of Zhaksy District";
Dinara Bekturganovna Bekturganova – Head of the Unified Personnel Management Service of the State Institution "Apparatus of the Akim of Zhaksy District";
Zigash Abilmagzhanovna Shamatova – Head of the Department of Documentation Support and Financial and Economic Activities of the State Institution "Apparatus of the Akim of Zhaksy District";
Elaman Muratovich Karashin – Head of the State Institution "Department of Housing and Communal Services, Passenger Transport, Computational Roads, and Housing Inspection of Zhaksy District";
Tatyana Borisovna Kopylova – Head of the State Institution "Department of Employment and Social Programs of Zhaksy District";
Kairzhan Kozhakhmetovich Kusainov – Chairman of the Public Council of Zhaksy District (by agreement).
1. SE «Department of Housing and Communal Services, Passenger Transport, Computational Roads, and Housing Inspection of Zhaksy District»
The State Institution "Department of Housing and Communal Services, Passenger Transport, Computational Roads, and Housing Inspection of Zhaksy District" (hereinafter referred to as the Department) is a state body of the Republic of Kazakhstan providing leadership in the sphere of passenger transport, public roads, and housing inspection.
The Department carries out its activities in accordance with the Regulations approved by the Resolution of the Akimat of Zhaksy District dated July 29, 2022, No. a-6/136.
The subordinate organization under the jurisdiction of the Department is the State Communal Enterprise on the Right of Economic Management (GKP na PKhV) "Zhaksy Su Arnasy" under the Akimat of Zhaksy District.
During the internal analysis of corruption risks in the activities of the Department, the following was established:
Area: «Identification of corruption risks in regulatory legal acts»
Within its competence, the Department is the developer of the following regulatory legal acts (RLAs):
- Resolution of the Akimat of Zhaksy District, Akmola Region, dated November 7, 2022, No. a-11/249 «On Approval of the Rules for Submitting Calculations of Norms for the Generation and Accumulation of Communal Waste in Zhaksy District» (registered in the Register of State Registration of Regulatory Legal Acts under No. 175048);
- Resolution of the Akimat of Zhaksy District, Akmola Region, dated April 3, 2023, No. a-2/51 «On Approval of the List, Names, and Indices of Public Roads of District Significance in Zhaksy District» (registered in the Register of State Registration of Regulatory Legal Acts under No. 179584);
- Decision of the Zhaksy District Maslikhat, Akmola Region, dated April 6, 2023, No. 8S-3-2 «On Approval of the Norms for the Generation and Accumulation of Communal Waste in Zhaksy District» (registered in the Register of State Registration of Regulatory Legal Acts under No. 179802);
- Decision of the Zhaksy District Maslikhat, Akmola Region, dated August 29, 2023, No. 8S-8-3 «On Approval of Tariffs for the Population for the Collection, Transportation, Sorting, and Disposal of Solid Domestic Waste in Zhaksy District» (registered in the Register of State Registration of Regulatory Legal Acts under No. 185666);
- Resolution of the Akimat of Zhaksy District, Akmola Region, dated August 24, 2024, No. a-7/152 «On Approval of the Rules for Providing Communal Services in Zhaksy District» (registered in the Register of State Registration of Regulatory Legal Acts under No. 186856);
- Decision of the Zhaksy District Maslikhat, Akmola Region, dated May 8, 2025, No. 8S-42-1 «On Approval of the Minimum Amount of Expenses for the Management of Condominium Objects and Maintenance of the Common Property of a Condominium Object in Zhaksy District for 2025» (registered in the Register of State Registration of Regulatory Legal Acts under No. 209999);
- Resolution of the Akimat of Zhaksy District, Akmola Region, dated March 31, 2026, No. a-2/248 «On Approval of the Rules for the Organization and Execution of Measures for the Reconstruction, Current or Capital Repair of External Walls and Roofs of Apartment Buildings, Aimed at Giving a Unified Architectural Appearance to the Settlements of Zhaksy District» (registered in the Register of State Registration of Regulatory Legal Acts under No. 223360).
- The monitoring of RLAs revealed that a specific regulatory legal act was not adopted—namely, the resolution of the district Akimat «On Approval of the Rules for Ensuring the Return of Money by Owners of Apartments and Non-Residential Premises Connected with the Repair and Replacement of Elevators and Capital Repair of an Apartment Building in Zhaksy District». This act should have been adopted to implement sub-paragraph 11) of Article 10-3 of the Law of the RK "On Housing Relations".
Description of corruption risk: Untimely adoption of a regulatory legal act creates legal uncertainty and hinders law enforcement practice.
Recommendations for elimination: Develop and approve the aforementioned Rules.
Area: «Identification of corruption risks in the organizational and managerial activities of the Department»
1) The staff size of the Department is 4 units: Head of Department - 1, Sector Head - 1, Chief Specialists - 2.
Within the timeframes established by law, the Department employees accepted anti-corruption restrictions and submitted the relevant information and declarations.
There were no vacant administrative civil service positions.
No facts of dismissal for negative reasons were established.
During the analyzed period, the Head of the Department, E.M. Karashin, was brought to disciplinary responsibility (based on the representation of the Prosecutor's Office of Zhaksy District dated June 3, 2025, No. 2-0212-25-00486).
No corruption risks were identified in this specific direction.
2) Management of Conflict of Interest:
No facts of conflict of interest, nor circumstances contributing to its occurrence, were established.
3) Provision of Public Services:
The Department provides 12 types of public services.
In 2025, 62 public services were provided, all via the electronic government portal.
No facts of violation of deadlines for public service provision, requesting documents not stipulated by legislation, groundless refusals, or complaints from service recipients were established.
However, monitoring revealed the following corruption risk:
- Monitoring the provision of public services revealed a violation of paragraph 7 of the Rules for providing the public service «Registration and Queueing, as well as the Decision of Local Executive Bodies to Grant Housing to Citizens in Need of Housing from the State Housing Fund or Housing Rented by the Local Executive Body in the Private Housing Fund».
According to the requirements of the specified paragraph, the registration of the application should have been carried out on the day of its receipt, i.e., January 30, 2025. In reality, the application was registered on February 3, 2025.
Description of corruption risk: Violation of the business process of public service provision and lack of necessary control over compliance with legislative requirements in the sphere of public services.
Recommendations for elimination: Ensure strict compliance with the stages of the business process when registering applications in the "Kezekte.kz" information system in accordance with the law.
4) Implementation of Permissive Functions:
The Department does not issue permits, conduct expert evaluations, register, or perform other permissive functions not included in the Register of Public Services.
5) Implementation of Control and Audit Functions:
No corruption risks were identified in the implementation of control and audit functions.
6) Utilization and Distribution of Budgetary and Financial Funds:
The utilization of budget funds, calculation of salaries, bonuses, and allowances is carried out in accordance with the Rules for awarding bonuses, providing material assistance, and establishing allowances to the official salaries of employees of state budget-funded bodies of the Republic of Kazakhstan, approved by Government Decree No. 1127 dated August 29, 2001.
For 2025, with a financing plan of 485,293.0 thousand tenge, 481,983.9 thousand tenge was utilized, which amounted to 99.3%.
- According to the results of the state audit by the Audit Commission for Akmola Region, facts of inaccurate data representation in the financial statements totaling 5,145,829.6 thousand tenge were established. Specifically, when compiling financial statements, completeness and accuracy of reflecting all operations for the reporting period were not observed, along with the correct assignment of income and expenses to reporting periods, and identity of analytical accounting data with turnovers and balances on synthetic accounting accounts as of the first day of the month following the reporting period (failure to maintain turnover sheets of accounting entries and the general ledger).
Description of corruption risk: Distortion of financial reporting negatively impacts consolidated financial statements.
Recommendations for elimination: Ensure the elimination of identified violations by bringing accounting and financial reporting into compliance with legislative requirements, and strengthen internal financial control.
7) Development and Operation of Information Systems:
No corruption risks were identified regarding the development and operation of information systems.
8) Other Issues Arising from Organizational and Managerial Activities:
When reviewing appeals from individuals and legal entities, the following was established:
In 2025, the Department received 18 appeals, including: applications – 5, complaints – 1, proposals – 3, others - 9.
A total of 15 appeals were reviewed, 1 was redirected by competence, and 2 were duplicates.
There are no complaints from individuals or legal entities, including in the media, against the Department regarding unlawful actions of a corrupt nature.
No corruption risks were identified in other issues arising from organizational and managerial activities.
Based on the results of the analysis of corruption risks in the activities of the Department, it is recommended to:
- Develop and approve the Rules for Ensuring the Return of Money by Owners of Apartments and Non-Residential Premises Connected with the Repair and Replacement of Elevators and Capital Repair of an Apartment Building in Zhaksy District.
- Ensure strict compliance with the stages of the business process when registering applications in the "Kezekte.kz" information system in accordance with the requirements of the legislation on public services.
- Ensure the elimination of identified violations by bringing accounting and financial reporting into compliance with legislative requirements, and strengthen internal financial control.
2. SE «Department of Employment and Social Programs of Zhaksy District»
The State Institution «Department of Employment and Social Programs of Zhaksy District» (hereinafter referred to as the Department) is a state body of the Republic of Kazakhstan providing leadership in the spheres of population employment, social programs, provision of special social services, and the issuance, extension, and revocation of permits for labor immigrants.
The State Institution carries out its activities in accordance with the Regulations approved by the Resolution of the Akimat of Zhaksy District dated May 14, 2025, No. a-2/72.
The subordinate organization under the jurisdiction of the Department is the KSU «Center for the Provision of Special Social Services at Home».
During the internal analysis of corruption risks in the activities of the Department, the following was established:
Area: «Identification of corruption risks in regulatory legal acts»
Within its competence, the Department is the developer of the following regulatory legal acts:
- Decision of the Zhaksy District Maslikhat dated December 21, 2023, No. 8S-17-5 «On Approval of the Rules for Providing Social Assistance, Establishing Sizes, and Determining the List of Certain Categories of Citizens in Need in Zhaksy District» (registered in the Register of State Registration of Regulatory Legal Acts under No. 191593);
- Decision of the Zhaksy District Maslikhat dated July 31, 2024, No. 8S-28-2 «On Determining the Size and Procedure for Providing Housing Assistance in Zhaksy District» (registered in the Register of State Registration of Regulatory Legal Acts under No. 199543);
- Decision of the Zhaksy District Maslikhat, Akmola Region, dated December 1, 2025, No. 8S-49-2 «On Approval of the Rules and Amount of Social Support for Paying for Utility Services and Purchasing Fuel at the Expense of Budget Funds for Specialists of State Organizations of Healthcare, Social Security, Education, Culture, Sport, and Veterinary Medicine Living and Working in Rural Settlements of Zhaksy District» (registered in the Register of State Registration of Regulatory Legal Acts under No. 217911);
- Resolution of the Akimat of Zhaksy District, Akmola Region, dated December 4, 2025, No. a-10/274 «On Approval of the Tariff for the Provision of Special Social Services in the Field of Social Protection of the Population at Home for 2026» (registered in the Register of State Registration of Regulatory Legal Acts under No. 32987).
1.Monitoring of RLAs revealed that the Decision of the Zhaksy District Maslikhat dated July 31, 2024, No. 8S-28-2 "On Determining the Size and Procedure for Providing Housing Assistance in Zhaksy District" was not updated with the changes stipulated by paragraph 4-1 of the Rules for Providing Housing Assistance introduced by the Order dated July 28, 2025, No. 279. Specifically, the decision lacks the calculation formulas for the size of housing assistance.
Description of corruption risk: Untimely introduction of amendments to a regulatory legal act creates legal uncertainty and complicates law enforcement practice.
Recommendations for elimination: Introduce appropriate amendments to the aforementioned decision.
Area: "Identification of corruption risks in the organizational and managerial activities of the Department"
1) The staff size of the Department consists of 7 units: Head of Department - 1, Sector Heads - 2, Chief Specialists - 4.
Within the timeframes established by law, the Department employees accepted anti-corruption restrictions, and declarations of income and property are submitted annually.
No facts of dismissal for negative reasons were established.
During the analyzed period, the Head of the Employment Sector, N.G. Cheremisova, was brought to disciplinary responsibility (based on the district Akim’s Order dated November 28, 2025, No. 1-83, issued following the review of the representation of the Prosecutor's Office of Akmola Region dated November 3, 2025, No. 2-02-25-12052).
No corruption risks were identified in this area.
2)Management of Conflict of Interest:
No facts of conflict of interest, nor circumstances contributing to its occurrence, were established during the analysis.
3)Provision of Public Services:
The Department provides 17types of public services.
In 2025, 480 public services were provided, including 59 via the State Corporation (GC), 319 via the e-Government Portal (PEP), 0 via the State Body (GO), 0 via the information systems of the service provider without direct contact with the recipient, and 102 via the information systems of the service provider through direct contact with the recipient and manual application entry.
A total of 60 refusals were issued in electronic form containing reasoned grounds.
No facts of violation of deadlines, requesting documents not stipulated by legislation, groundless refusals, or complaints from service recipients were established.
- During a monitoring event regarding compliance with RK legislation on public services for 2025 for the service "Issuance, Extension, and Revocation of Permits to Labor Immigrants", a discrepancy in reporting data for January 2025 was revealed: two refusals to provide the service were not reflected in the report.
Description of corruption risk: Inaccuracy of reporting data creates conditions for distorting statistical reports in the Department's activities and affects the evaluation of work performance.
Recommendations for elimination: High-quality preparation of reporting data in accordance with the legislative requirements for public services.
4) Implementation of Permissive Functions:
The Department is endowed with a permissive function within the framework of one public service: "Issuance, Extension, and Revocation of Permits to Labor Immigrants".
In 2025, 84 public services were provided in this area.
No other corruption risks were identified regarding permissive functions.
5) Implementation of Control and Audit Functions:
The Department does not carry out control and audit functions, state control, or supervision.
6) Utilization and Distribution of Budgetary and Financial Funds:
In 2025, 199,813.9 thousand tenge was allocated, and 199,812.8 thousand tenge was utilized, representing 100% utilization.
No violations in the utilization and distribution of budget funds, nor corruption risks in the sphere of accounting, were established.
7)Conclusion of Agreements with Individuals and Legal Entities:
State procurement is carried out in accordance with the Law of the RK "On Public Procurement" dated July 1, 2024, and the Rules for Public Procurement approved by Order of the Minister of Finance of the Republic of Kazakhstan No. 687 dated October 9, 2024.
In 2025, 37 contracts were concluded for a total amount of 3,770.6 thousand tenge, including 10 contracts via request for price offers, 22 contracts from a single source for failed procurements, and 5 contracts from a single source via direct conclusion.
No corruption risks were identified in this direction.
8) Development and Operation of Information Systems:
No corruption risks were identified in the department regarding the development and operation of information systems.
9) Other Issues Arising from Organizational and Managerial Activities:
In 2025, the Department received 17 appeals, including 12 applications, 1 proposal, and 4 others.
No violations of deadlines for reviewing appeals were established.
A total of 13 appeals were reviewed, and 4 were redirected by competence.
3.When analyzing the review of appeals from individuals and legal entities, it was found that on April 21, 2025, «Agrofirma TNK» LLP applied to the Department with a proposal to simplify the attraction of foreign labor for legal entities.
Upon studying the appeal, it was revealed that part of the issue did not fall within the competence of the Department.
However, in violation of the requirements of Article 65 of the Administrative Procedural Code (APPC) of the RK, a response was sent to the applicant stating that the issue belonged to the competence of the SE «Department for Coordination of Employment and Social Programs of Akmola Region». Instead, this appeal should have been redirected to the authorized state body within three working days from the day of its receipt.
Description of corruption risk: Failure to comply with the requirements of the APPC of the RK when redirecting appeals.
Recommendations for elimination: Ensure the timely redirection of incoming appeals that do not fall within the Department's competence.
Based on the results of the analysis of corruption risks in the activities of the Department, it is recommended to:
- Introduce corresponding amendments to the Decision of the Zhaksy District Maslikhat dated July 31, 2024, No. 8S-28-2 "On Determining the Size and Procedure for Providing Housing Assistance in Zhaksy District".
- Ensure high-quality preparation of reporting data in accordance with the requirements of the legislation of the Republic of Kazakhstan in the sphere of public services.
- Ensure strict compliance with the requirements of the APPC of the RK when reviewing appeals, including the timely redirection of incoming appeals that do not fall within the competence of the Department.
Chairperson of the working group: O. Bocharnikova
Deputy Chairperson of the working group: N. Segizbayeva
Members of the working group:
- Balatskaya
- Bekturganova
- Shamatova
- Karashin
- Kopylova
- Kusainov
- Zholdybayeva