JSC "Social Entrepreneurship Corporation (SEC) "Tobol" has revised its management and remuneration system following violations identified during a state audit. The inspection covered the corporation's activities for 2023–2024 and found issues in performance evaluation and the distribution of rewards.
WHAT VIOLATIONS THE AUDIT FOUND
According to the Supreme Audit Chamber (SAC), during an inspection conducted in 2025 that covered 13 SECs across the country, a number of systemic violations were recorded in the activities of JSC "SEC "Tobol".
Specifically, during 2023–2024, no independent and comprehensive assessment of the work of the Board of Directors and members of the management board was carried out. A system for evaluating the performance of the management tier was effectively absent.
It was also established that incentive payments were distributed at the discretion of management without regard to financial results. The remuneration rules in force at that time allowed the chairman of the management board to independently set bonuses for themselves and other board members, which contradicts the Law "On Joint-Stock Companies", according to which such decisions fall under the competence of the Board of Directors.
WHAT MEASURES THE CORPORATION TOOK
In compliance with the SAC's directive, the management of JSC "SEC "Tobol" approved a series of changes.
By decision of the Board of Directors, a Regulation on motivational key performance indicators for the management board was developed and introduced. Simultaneously, the rules for remuneration and bonuses for senior employees were updated.
Now, the terms for paying rewards to the chairman and members of the management board are determined solely by a decision of the Board of Directors. Personal bonuses are tied to the results of departmental plan fulfilment — on a monthly, quarterly, or annual basis.
The amount of bonuses is capped — no more than two official salaries per reporting period. These rules apply to both management and regular employees.
Furthermore, an additional agreement was signed to the collective agreement for 2023–2026, enshrining uniform standards for additional payments and allowances for all categories of employees.
CHANGES TO INVESTMENT DOCUMENTS
The audit also revealed a discrepancy between internal documents and legal requirements. The Investment Declaration and the Investment Activity Regulations lacked the concept of 'joint venture', which contradicted the norms of the Civil Code of the Republic of Kazakhstan.
To address this gap, both documents were adopted in a new version incorporating the necessary definitions.
CONTEXT AND SIGNIFICANCE
In February 2025, the FBRK editorial team analysed the financial statements of JSC "SEC "Tobol" for 2023. The article noted that despite nearly halving its revenue, the corporation increased its net profit by 37% and grew its assets more than twofold.
At the same time, a significant portion of labour costs was attributed to senior management: 81% of the payroll fund, or 391.7 million tenge. The average salary level, calculated based on the total fund, was approximately 854,000 tenge per month.
We also drew attention to the presence of significant funds in deposits while simultaneously attracting financing from the akimat, as well as the unprofitability of the stabilisation fund's operations.