(10 March 2026 | Source: electronic procurement portal of JSC "NWF "Samruk-Kazyna")
Kazakhstani PR specialist and media expert Kuat Dombai published a series of posts on social media about the procurement of legal services for the construction project of the CHP plant in Ust-Kamenogorsk. He alleged a possible conflict of interest surrounding the tender held by a structure of the "Samruk-Kazyna" fund. FBKK examined the procurement documents and tender protocols.
WHAT KUAT DOMBAI WROTE
Kazakhstani PR specialist, media expert and author of books on reputation management Kuat Dombai published several posts on Facebook dedicated to the work of the Samruk-Kazyna fund and its procurements.
In particular, he drew attention to the tender for legal support of the thermal power plant construction project in eastern Kazakhstan. According to Dombai, the cost of the services could have reached around 800 million tenge, and among the participants was the law firm GRATA.
The author of the post also stated that the tender requirements could have limited the pool of potential participants. According to his version, the terms of reference contained a condition requiring a specialist in Chinese law, which, in his opinion, could have reduced the number of legal companies able to meet the qualification requirements.
WHAT THE REVIEW OF TENDER DOCUMENTS SHOWED
FBKK reviewed the published procurement documents on the electronic procurement portal of JSC "NWF "Samruk-Kazyna".
According to the tender documentation, the procuring entity is LLP "Uskemen Energo". The subject of the procurement is legal advisory and representation services within the framework of the coal-fired thermal power plant construction project in Ust-Kamenogorsk. The planned cost is 749,168,000 tenge excluding VAT, and the service period is until December 2027.
The documentation states that the legal consultant must support the project using international and Kazakhstani law, including participation in international arbitrations and work with contracts under FIDIC standards.
The tender requirements stipulate the availability of specialists in Kazakhstani, English and Chinese law. The documents note that the specialist in Chinese law must have a relevant education and experience working with international EPC contracts (Engineering Procurement Construction).
WHICH COMPANIES PARTICIPATED IN THE TENDER
According to the protocol for reviewing applications, two companies participated in the procurement — LLP "Unicase" and the consortium of GLF Law Firm Ltd. and LLP "Law Firm GRATA". Unicase offered a price of 610.5 million tenge, while the consortium involving GRATA offered 749.1 million tenge.
However, the commission rejected Unicase's application. The protocol for reviewing the results states that the verification revealed discrepancies and inaccurate information regarding the qualifications of one of the specialists and their involvement in court cases.
Following this, effectively only one participant remained in the procedure — the consortium of GLF Law Firm Ltd. and GRATA.
WHAT THE MEDIA WRITE ABOUT POSSIBLE LINKS
The publication Shyndyk.kz has also previously written about this procurement. The article claims that a partner of the law firm GRATA is Gulnur Nurkeeva, the spouse of the head of the Samruk-Kazyna representative office in Beijing, Saken Muratuly.
The publication highlights a possible conflict of interest, however, no official conclusions from state bodies on this matter are provided. The article also notes that the tender requirements could have limited the number of potential participants.
CONTEXT
The CHP plant construction project in Ust-Kamenogorsk is one of the major infrastructure projects in the energy sector and is being implemented through international EPC contracts, where FIDIC standards are applied.
The tender documentation states that the legal support for the project involves working with international law and potential arbitration disputes.
Such projects are often implemented with the participation of foreign contractors and financial institutions, therefore the legal support may encompass several legal jurisdictions.
The requirement for a specialist in Chinese law, which was discussed on social media, is listed alongside the mandatory availability of lawyers in Kazakhstani and English law, as well as experience working with FIDIC contracts.