ENVIRONMENTAL

Environmental management

Nornickel is committed to making a notable contribution to preserving natural riches and historical lifestyle across its footprint. The Company pays attention to environmental protection at each stage of production, takes all necessary efforts to reduce adverse environmental impact and use natural resources sustainably. Nornickel complies with applicable laws and international standards.

In 2021, the Company elaborated and approved the Environmental and Climate Change Strategy to improve its environmental performance. The new strategy covers six key areas of environmental impact: climate change, air, water, tailings and waste, land, and biodiversity, and takes due account of stakeholder expectations, involvement, and communications. The strategy defines 18 environmental and climate change objectives detailed in Nornickel’s ESG Strategy section.

Nornickel has a system in place to distribute environmental responsibilities among different governance bodies in line with their competencies.

Key environmental management regulations:

• Russian environmental laws;
• MMC Norilsk Nickel’s Environmental and Climate Change Strategy;
• MMC Norilsk Nickel’s Environmental Impact Assessment Policy;
• Renewable Energy Sources Policy;
• MMC Norilsk Nickel’s Environmental Policy;
• MMC Norilsk Nickel’s Climate Change Policy;
• MMC Norilsk Nickel’s Tailings Management Policy;
• MMC Norilsk Nickel’s Position Statement on Biodiversity
• MMC Norilsk Nickel’s Position Statement on Water Stewardship
• Established maximum permissible environmental impact and its limits;
• Plans for reducing pollutant emissions;
• Plans for reducing pollutant discharges.

Key environmental policies are subject to approval by the Board of Directors, as well as regular review and improvement. Trainings on policies and regulations are held in line with annual (quarterly) training plans of respective units.

Precautionary approach

GRI 102-11

Assessment of potential impact of the Company’s activity is a part of its risk management. In accordance with its Investment Project Risk Management Regulations, Nornickel analyses risks and assesses impacts and potential consequences using qualified expert review during both project planning and implementation. If the analysis identifies any material risks, mitigation initiatives are developed, and a decision may be taken to abandon the project.

When planning our operations and in the course of our production activities, we comply with the applicable Russian environmental laws and regulations. During a state expert review, design documents and results of engineering studies for all the ongoing projects undergo mandatory assessment for compliance with the applicable laws.

Environmental management system

For over 15 years, Nornickel has been running an environmental management system as part of the Corporate Integrated Quality and Environmental Management System which covers production, project management, storage, supplies, and sales.

The auditors of Bureau Veritas Certification (BVC), an international certification body, conduct surveillance audits once a year and recertification audits once every three years to confirm compliance of the Company’s environmental management system with ISO 14001:2015 international standard.

In March–April 2021, the recertification audit of the environmental management system was held at the Head Office and production sites of Polar Division in Norilsk, Polar Transport Division in Dudinka, and Murmansk Transport Division in Murmansk. According to the auditors’ conclusions, the Company showed successful implementation, maintenance, and constant improvement of the Corporate Integrated Management System, confirmed compliance with ISO 14001:2015, and received the compliance certificate for the next (sixth) certification period.

In November 2021, a surveillance audit was held to assess the performance of the Company’s environmental management system and its compliance with ISO 14001:2015. The auditors highly commended the Company’s Environmental Policy updated in 2021, which demonstrates leadership of the Company’s senior management in addressing environmental issues.

Environmental protection expenditures

GRI 307-1

Charges for violations of the environmental law imposed in 2021 exceeded RUB 146.2 bln, including the largest damages for diesel fuel spill at NTEC’s HPP-3 in May 2020. The amount of environmental fines imposed on the Company in 2021 is below RUB 12 mln.