Anti-corruption

Preventing and fighting corruption

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We traditionally pay special attention to developing and implementing anticorruption initiatives covering corporate, government and partner relations.

We value the trust of our shareholders, investors, partners, employees, the government and other stakeholders, and make consistent efforts to build an anticorruption and compliance framework based on zero tolerance to any form of corruption at all levels.

Nornickel’s Anti-Corruption Policy is our underlying document in this area. The policy seeks to ensure compliance with anti-corruption laws, as well as to prevent, identify and eliminate causes of corruption. The document applies to the Company’s representatives and contractors, including foreign public officials and officials of public international organisations. The respective anti-corruption responsibilities are stipulated in agreements made with contractors or are expressly provided for by the applicable laws.

Additionally, Nornickel has in place the Business Ethics Code setting forth corporate rules and ethical standards guiding its employees in discharging their duties.

Nornickel Group’s Russian business units adopt and implement their own anticorruption regulations in line with the Company’s anti-corruption policy. We take all the necessary and reasonable steps to ensure our foreign operations comply with the policy’s key principles and requirements.

Once every two years, we submit a declaration to prove our compliance with anti-corruption requirements as prescribed by the Anti-Corruption Charter of the Russian Business. Our anti-corruption initiatives are regularly covered in corporate press releases.

In 2021, we were awarded A1, the top score in the RSPP’s Russian Business Anti-Corruption Rating. This rating proves the strong anti-corruption efforts of the Company’s management and our high standards in preventing corruption.

Our representatives take an active part in developing and implementing domestic and international policies on combating corruption. Andrey Bougrov, Nornickel’s Senior Vice President for Sustainable Development, is the Company’s top executive in charge of anti-corruption practices. He holds membership in a number of Russian and international organisations that supervise this area, in particular:

• Expert Committee of the Russian Presidential Anti-Corruption Directorate;
• Non-profit Partnership National Council on Corporate Governance;
• Expert Council on Sustainable Development at the Russian Ministry of Economic Development;
• Expert Group for Corporate Governance, Special Administrative Districts, Bankruptcy Proceedings and Valuation at the Russian Ministry of Economic Development (head);
• B20 Integrity and Compliance Task Force;
• representative of the Russian Union of Industrialists and Entrepreneurs engaged in groups and committees of the Business and Industry Advisory Committee to the OECD (BIAC): Anti-Corruption Task Force and the Corporate Governance Committee.

Corruption risk management

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In 2021, the Company started to draft and introduce a new methodology to assess and manage corruption risks. Every quarter, we monitor and revise these risks. In 2021, the assessment covered 100% of our business units, with no corruption risks materialising.

The Company’s security service checks new contractors for involvement in corruption incidents, inclusion in the register of fraudulent suppliers and pending administrative proceedings. In case of negative findings, the Corporate Relations Department assesses the risk of relations with the contractor in question and recommends mitigants if applicable. Regardless of the outcomes, the Company signs a standard master agreement containing an anti-corruption clause with all selected suppliers and contractors.

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In 2021, the active and targeted inspections of Nornickel’s Security Service in cooperation with law enforcement authorities resulted in criminal cases against four of the Group’s employees on charges of commercial bribery (article 204 of the Russian Criminal Code).

These cases are being investigated for the purpose of getting a complete, comprehensive, and unbiased picture of the circumstances surrounding the transgressions, including their reasons and other context.

Anti-corruption governance framework^*

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Nornickel took disciplinary action in the form of dismissal against these employees in strict compliance with the law.

Following convictions under these accusations, the Company conducts mandatory preventive talks with the staff on the unacceptability of law violations and its zero tolerance for any unlawful acts, including corruption. The topics also cover the Business Ethics Code and the inevitability of penalty for any crimes.

Measures like these enable Nornickel to take adequate and timely action not just in identifying such acts, but also in preventing them, which is one of the main goals of the Company’s responsible units.

Anti-corruption training

To raise employee awareness of our anti-corruption initiatives, we organise training in basic relevant practices. All new hires receive an induction briefing in this area. When recruited, they also need to familiarise themselves with the corporate Anti-Corruption Policy and sign an addendum to their employment contract that sets out anti-corruption responsibilities. There is an online anticorruption course for new staff and a dedicated online course on compliance with anti-corruption laws for our HR function.

As at the end of 2021, 100% of employees were made aware of the Group’s existing corruption prevention policies. Over the year, the dedicated training on the requirements and provisions of the corporate anti-corruption regulations covered 9,805 people.

Corporate Trust Line

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In 2010, the Company set up the Corporate Trust Line, part of the Internal Control Department, to ensure prompt management response to reported abuse, theft, and other violations.

The service is governed by the Procedure on the Corporate Trust Line. Responsible for the service are its operator and head along with the Director of the Internal Control Department.

The principles underlying the Corporate Trust Line include guaranteed confidentiality for whistle-blowers, independent review of reports, and timely and unbiased investigation of all cases irrespective of the position and employment period of employees against whom allegations are made. This is how we prevent retaliation against or pressure on whistle-blowers.

Any stakeholder may contact the Corporate Trust Line. The line handles reports on both potential corruption and a wider range of matters related to violations of procedures and by-laws, including with respect to human rights, environment, labour relations, etc.

For everyone wishing to make a report, toll-free channels are available 24/7 +7 800 700 1941 and +7 800 700 1945, email: skd@nornik.ru. Reports can be filed via the dedicated form at https://www.nornickel.com/sustainability/corporate-hotline/

The procedure provides for the operator to fully handle the report (from registration in the information system to review by a dedicated function and assessment of response by the Head of the Corporate Trust Line) within 21 days. The exceptions are reports that require immediate action or additional investigation. If the report is found substantiated, a set of control measures is taken, and if a violation is confirmed, steps are taken to correct the situation, eliminate any negative consequences, and inform stakeholders.

In 2021, the Corporate Trust Line received 1,243 reports, with 422 accepted for review and 96 confirmed. Most reports had to do with production and labour relations. As at 31 December 2021, 70 reports were being processed.

Report statistics (broken down by Group company and type of reported abuse) are submitted to units in charge on a quarterly basis. The performance of the Corporate Trust Line is subject to review by the Board’s Audit Committee and an interactive assessment by the Vice President for Internal Control and Risk Management.

Persons in charge of the Corporate Trust Line have individual KPI targets of improving incoming reports processing.

Framework for registering and reviewing reports by the Corporate Trust Service

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