The new version of the Code was approved by the Financial Market Regulation and Supervision Service. The document replaces the 2020 version and, in addition to sustainable development, shareholder rights and internal controls, now introduces new approaches to corruption prevention and conflict-of-interest management.
One of the new elements of the Code is a separate section on combating bribery. Companies are recommended to establish an appropriate system taking into account the principles of the international ISO 37001 standard, national legislation, and the scale and specific characteristics of their activities.
In particular, such a system should provide for:
- adoption of an anti-bribery policy and assignment of responsibility for its implementation at the governing-body level;
- appointment of a responsible person or unit;
- regular assessment of bribery risks and implementation of controls proportionate to the identified risks;
- due diligence on employees, business partners and intermediaries;
- rules governing gifts, hospitality expenses, charitable and sponsorship contributions, donations and other benefits that may create bribery or conflict-of-interest risks;
- confidential reporting channels for suspected violations and protection of persons who make such reports;
- employee training;
- documentation of checks carried out and measures taken;
- consideration of corruption risks in investment decisions and the selection of business partners;
- regular review of anti-bribery measures in light of changes in legislation, the risk profile and international practice.
The provisions of the Code are recommendatory in nature: the use of ISO 37001 does not imply mandatory certification under the standard. At the same time, the inclusion of an anti-bribery management system in the Code links anti-corruption compliance with broader corporate governance mechanisms.
The update to the Code is consistent with the Kyrgyz Republic’s State Anti-Corruption Strategy for 2025–2030. Its implementation plan provides for promoting ISO 37001 and the G20/OECD Principles of Corporate Governance, as well as introducing principles of sound corporate governance and public reporting in large and medium-sized companies, state-owned enterprises and joint-stock companies with state participation.
