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KBTU Internal Compliance Policy (ICP) in Strategic Trade Control and Sanctions

This is a draft document briefly mentioning policy outlines on how KBTU will comply with International, foreign, and local Strategic Trade Control and Sanctions (STCS) laws, regimes, and regulations.

1. Introduction

- It is the policy of KBTU to conduct its business and academic activity in an honest and ethical manner consistent with relevant laws and regulations.

- KBTU is committed to comply with the Strategic Trade Control and Sanctions laws, regimes, regulations of the Republic of Kazakhstan (‘STCS of RK’).

- As part of this policy, KBTU has no tolerance for violations of STCS of RK and is committed to acting transparently, professionally, fairly and with integrity in all its academic activity and business dealings and relationships, wherever it operates, and implementing and enforcing adequate internal procedures to prevent and minimize any possible violations of STCS of RK.


2.1 KBTU will comply with applicable STCS of RK which are relevant to its academic activity and business.

2.2 KBTU is committed to maintaining an effective system of STCS compliance that is designed to avoid violations, detect them promptly if they occur, and provide timely investigations and appropriate remedial actions.

3.Who does this policy apply to?

3.1 This policy applies to all individuals working for, or on behalf of, KBTU at all levels and grades, whether permanent, fixed-term or temporary, and wherever located, including researchers, teaching staff, administrative staff, students, consultants, contractors, and any other person who performs services for or on behalf of KBTU who carry out any activity or are considering carrying out any activity related to STCS of RK (collectively referred to as Staff in this document).

4.What are STCS of RK? STCS of RK are strategic trade controls, sanctions and other trade restrictions which are administered by the Kazakh Government and other official agencies to protect national security and foreign policy interests of Kazakhstan and they govern how, with whom and where KBTU does business according to the Law of the Republic of Kazakhstan on Specific (Strategic) Trade Control of 28 December, 2022. (further - the Law) The fields under STCS are deemed as high risk as they could potentially be misused for military purposes. These areas are usually but not always in the science, technology, engineering and mathematics (STEM) subjects.

5. Responsibilities

5.1 The management and compliance with STCS of RK is the responsibility of all those Staff conducting such applicable business on behalf of KBTU which is subject to STCS of RK.

5.2 All Staff are required to avoid any activity that might lead to a breach of this policy.

6. Consequences for breach of this policy

6.1 Any member of Staff who breaches this policy (which includes a failure to notify) may face disciplinary action, which could result in dismissal for gross misconduct. We reserve our right to terminate our contractual relationship with non-employee Staff if they breach this policy.

7. Monitoring and review

7.1 KBTU Executive management has a responsibility to ensure that internal control systems and procedures are monitored and subject to regular review to provide assurance that they are effective in compliance with the STCS of RK.

7.2 All Staff must be aware that they are responsible for the success of this policy and should ensure they use it to disclose any suspected breaches or wrongdoing

Please read our Concept Note on Internationalization of Education Programs in Strategic Trade Control

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