2023-11-14-世界银行-应对冲击_改革哈萨克斯坦国家金融控股以提高发展效率和创造市场（英）-2023-125页_125页_2mb

Postulates and Findings of the Report

Postulates:

• Impact: Baiterek's impact measurement is not credible due to lack of proper attribution and double-counting, and the focus on financial markets and additionality is insufficient.
• Capital: Mobilization of private capital is limited due to governance structures and subsidies, and contingent liabilities are not properly managed.
• Risk: Credit risk underwriting is influenced by politics, and risk management is neither holistic nor decentralized.
• Governance: Lack of political independence in the holding company's governance creates accountability issues.

Implementable Goals:

1. Enhanced Impact Delivery: The double bottom-line impact strategy must be redefined to align ecological factors with financial metrics.
2. Transparent Capital: Redefine state-capital cooperation to improve fiscal disclosures and capital market engagement.
3. Robust Risk Governance: Strengthen the risk management framework through greater independence and verification mechanisms.
4. Political Neutrality: Insulate Baiterek's decision-making from short-term political cycles and enhance the board's accountability.

Recommendations:

A. Impact Measurement Enhancements

• Adopt GEEREF's four-pillar framework for defining impact across beneficiaries and markets.
• Implement rigorous ex-post impact evaluations using quasi-experimental methods.
• Link impact KPIs to the Paris Agreement goals through carbon shadow pricing.
• Commission independent evaluations within a 3-5 year timeframe.

B. Capital Mobilization Strategies

• Restructure financing to facilitate private equity participations and inclusion of multipliers.
• Distinguish funding streams to enable clear budget accounting and lessen fiscal contingent liabilities.
• Establish a transparent fund allocation framework to align capital with impact goals.

C. Governance Reforms

• Achieve independence of the holding company's Board (Option 2).
• Conduct fit, proper, and independence tests for board members via external integrity due diligence firm.
• Create common independent boards for CPG, SFG, and SMFAC entities.

D. Risk Management Strengthening

• Introduce full separation of oversight and management functions to avoid political interference in underwriting.
• Consolidate prudential supervision for Baiterek across all operations to enhance market neutrality.
• Upgrade the internal audit function to a corporate-scale monitoring body.

E. Transparency and Accountability

• Disclose client-level data with proper anonymization for independent analyses.
• Improve fiscal reporting by clearly distinguishing supports for operations versus subsidies/agent functions.
• Periodically engage specialized assessors to report on market and development impacts.

Key Findings and Concluding Remarks

Baiterek's transformation is necessary to move towards impactful, transparent, and independent development finance. The recommendation phasing allows for a transition from visibility to accountability over time. However, without comprehensive reforms, the state digital project remains susceptible to critiques regarding its operational viability.

Reforms, if effectively implemented, could position Baiterek as a globally recognized and efficient DFI conglomerate. Otherwise, further stakeholder criticisms and market disengagement will follow.