ER SAI Caspian Contractor LLC (hereinafter – ERSAI) in compliance with the Model stated in Saipem S.p.A.’s group organization, adopts the following Organization, Management and Control Model (“OM&C Model” hereafter). OM&C Model is aimed to prevent illegal behaviors in terms of corruption, extortion, money laundering, frauds and, in general, any offence that may be committed or attempted to be committed in the interests or to the advantage of a company, setting forth disciplinary measures to be enforced in case of illegal behaviors in breach of laws, regulations and/or internal policies.

OM&C Model is inspired by the most updated laws and the best practices for the prevention of “white collar” crimes, and specifically by protocols and precautionary measures ruled within the following regulations: United Nations Convention against Corruption dated 31 October 2003, ratified by Republic of Kazakhstan on 08 May 2008, No 31-IV with exceptions;

Republic of Kazakhstan Law On Combating Corruption No.267-1 dated 2 July 1998.


  1. 1. ERSAI’s Code of Ethics
  2. 2. Risk analysis methodology
  3. 3. Compliance Committee’s role and information flows
  4. 4. Annual schedule of supervision activities
  5. 5. Extension of the OM&C Model to subsidiaries
  6. 6. Disciplinary system
  7. 7. General standards of transparency in the activities
  8. 8. Innovation implementation program

In this regard, at the meetings of 22 February 2010, the Board of Directors of ERSAI approved for the first time the OM&C Model.

The OM&C Model in second edition was approved by Written Resolution of the ERSAI’s Board of Directors on 05 April 2011.

The OM&C Model in third edition was approved by Written Resolution of the ERSAI’s Board of Directors on 01 February 2013.

The OM&C Model in fourth edition was approved by Resolution of the ERSAI’s Board of Directors on 04 December 2015.

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