Policy on the Prevention of Conflicts of Interest at the KCA
These regulations establish the requirements and procedures for the prevention, identification, and resolution of conflicts of interest in the activities of the governing bodies, staff, and members of the Kazakhstan Chamber of Actuaries (KCA).
1. General Principles for the Prevention of Conflicts of Interest
The activities of the Chamber are built on the principles of independence, objectivity, and professional autonomy.
- Disclosure of interests: Members of the Board, the Chairman of the Board, and members of the specialized committees (in particular the Committee on Education and Qualification and the Committee on Professional Ethics and Discipline) are required to disclose annually information about their employment, property, and consulting relationships that may affect the objectivity of their decisions.
- Term of office and rotation: To ensure regular rotation, members of the Board and the Chairman of the Board are elected by the General Meeting for a term of up to 3 years with subsequent re-election.
- Separation of roles: The procedures for conducting examinations, assessing qualifications, certification, and ethical oversight are entirely separated from one another. Members of the governing bodies may not use their position to influence the results of examinations or the certification of specific individuals.
2. Restrictions for KCA Officers
- Members of the Board, the Chairman of the Board, and engaged experts may not use the property, intellectual property, or proprietary information of the Chamber for purposes contrary to its statutory objectives, or for obtaining personal commercial gain.
- Officers may not directly or indirectly influence the decisions of the specialized bodies on certification or the imposition of disciplinary penalties with respect to persons connected to them by family, employment, or commercial relationships.
- The Chairman of the Board is required to obtain the prior written consent of the Board to conclude a major business transaction on behalf of the Chamber (in an amount exceeding 1000 MRP).
3. Conflicts of Interest in the Actuarial Practice of KCA Members
In accordance with Principle 7 of the KCA Code of Professional Conduct, actuaries may not provide services involving a conflict of interest (for example, reviewing their own calculations or acting as an independent assessor in a dispute in which they are connected to one of the parties), except in cases where:
- The actuary's ability to act objectively and impartially is not impaired;
- The existence of a potential conflict of interest is fully disclosed to all affected principals (clients / employers);
- Express written consent has been obtained from all parties to continue the work.
4. Resolution of Conflicts of Interest
- Upon the arising of a situation that may be construed as a conflict of interest, the officer or KCA member is required to immediately notify the KCA Committee on Professional Ethics and Discipline thereof.
- A member of the Board or a Committee who is the subject of a matter involving a conflict of interest (or the membership/disciplinary case of a person connected to them) is required to recuse themselves and does not participate in the discussion of or voting on that matter.
- A violation of the rules for the prevention of conflicts of interest constitutes a material violation of the Code of Ethics and entails measures of disciplinary liability.