2021 sustainability report

SOCIAL

Respect for human rights

GRI 102-16/SASB EM-MM-210a.3

Human rights

Respect for human rights is a basic principle that underlies Nornickel’s operations and is embedded into its corporate values, Human Rights Policy, and other corporate documents.

The Company does not tolerate any forms of discrimination and does not use forced or child labour, giving every employee an equal opportunity to exercise their labour rights regardless of gender, race, nationality, origin, financial, social, and occupational status, age, domicile, religion, political beliefs, and other circumstances not related to professional qualities. No operations are run in, and no raw materials are procured from, areas involved in military conflicts.

Nornickel wholeheartedly respects and promotes human rights and freedoms in line with internationally recognised norms and practices. Also, the Company fully complies with the applicable laws of the Russian Federation and other countries of its operations and respects both international standards for human rights protection and labour standards set out in the International Bill of Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work and the UN Guiding Principles on Business and Human Rights.

Nornickel regularly assesses the potential impact of its operations on human rights. On top of addressing human rights risks and ensuring full compliance with applicable requirements, the Company also implements best practices (signs employment contracts and collective bargaining agreements, creates favourable work and rest conditions for employees) and expects its suppliers and contractors to respect human rights throughout their operations.

All of the Company’s new projects are vetted for compliance with national and international legislation and are subject to a comprehensive human rights review, including an impact assessment. These checks involve over ten of Nornickel’s departments and functions.

Geography of operations — low risk of human rights violations

We operate in countries with a mature legal framework where the risk of human rights violations is very low. Hence, by observing applicable Russian laws, for instance, we automatically comply with most of the core ILO conventions on human rights ratified by our government.

If some of the above ILO conventions on human rights are not ratified by Russia and not directly enshrined in the national law, Nornickel seeks to voluntarily comply with them in its by-laws and operations.

Core ILO conventions ratified by the Russian government

Human rights area
ILO convention
Ratified by Russia

Human rights area

Decent working conditions

ILO convention

Weekly Rest (Industry) Convention No. 14 (1921)

Ratified by Russia

+

ILO convention

Protection of Wages Convention No. 95 (1949)

Ratified by Russia

+

ILO convention

Weekly Rest (Commerce and Offices) Convention No. 106 (1957)

Ratified by Russia

+

ILO convention

Holidays with Pay Convention No. 132 (1970)

Ratified by Russia

+

Human rights area

Safe working conditions

ILO convention

Occupational Safety and Health Convention No. 155 (1981)

Ratified by Russia

+

Human rights area

No child or forced labour

ILO convention

Forced Labour Convention No. 29 (1930)

Ratified by Russia

+

ILO convention

Abolition of Forced Labour Convention No. 105 (1957)

Ratified by Russia

+

ILO convention

Minimum Age Convention No. 138 (1973)

Ratified by Russia

+

Human rights area

Freedom of association and collective bargaining

ILO convention

Freedom of Association and Protection of the Right to Organise Convention No. 87 (1948)

Ratified by Russia

+

ILO convention

Right to Organise and Collective Bargaining Convention No. 98 (1949)

Ratified by Russia

+

ILO convention

Workers' Representatives Convention No. 135 (1971)

Ratified by Russia

+

Human rights area

Rights of indigenous peoples

ILO convention

Indigenous and Tribal Peoples Convention No. 169 (1989)

Ratified by Russia

-

Human rights area

Non-discrimination

ILO convention

Equal Remuneration Convention No. 100 (1951)

Ratified by Russia

+

ILO convention

Discrimination (Employment and Occupation) Convention No. 111 (1958)

Ratified by Russia

+

In 2021, the Company updated all of its key by-laws on human rights to ensure alignment with global best practices and the Company’s public commitments. Nornickel’s Board of Directors considered and approved the updated policies in November 2021.

In early 2022, Nornickel launched the procedure for an external assessment of its human rights governance framework. Based on the results, the Company intends to develop and implement an action plan in this area for the period until 2025–2026.

Applicable regulatory framework*

Applicable regulatory framework

Human rights governance

Governance body
Responsibility

Governance body

Board of Directors and Management Board

Responsibility

  • Review information on human rights violations regarding both the Company’s employees and other stakeholders.

Governance body

Sustainable Development and Climate Change Committee of the Board of Directors

Responsibility

  • Oversees the efficiency of introducing changes to the strategy, goals, projects, programmes and other major initiatives concerning respect for and protection of human rights.

Governance body

President of the Company

Responsibility

  • Ensures compliance with the Human Rights Policy.

Governance body

Senior Vice President for Sustainable Development

Responsibility

  • Supports implementation of the human rights agenda across all of the Company’s functions and units.

Governance body

Risk Management Service

Responsibility

  • Monitors the efficiency of risk management initiatives, including risks identified in the process of stakeholder engagement related to human rights.
  • Provides methodology support and develops approaches to human rights risk management.

Procedure to report human rights violations

Information on alleged human rights violations is collected via Nornickel’s Corporate Trust Line, regular employee questionnaires, and sentiment surveys among local population. The Company guarantees anonymity and confidentiality for whistle-blowers and respondents.

Statistics on reports to the Corporate Trust Line are maintained by the Internal Control Department team and submitted for review to the Board of Directors’ Audit Committee.

In 2022, Nornickel plans to provide all stakeholders with a dedicated grievance mechanism to help ensure qualified support as a way to consider all reports in the most effective way, and also to guarantee legal protection.

Women in Mining Russia

2020 saw the establishment of Women in Mining Russia (WIM Russia), a nonprofit organisation that aims to promote professional development of women, raise awareness about engineering jobs, and develop a platform for professional communications. Nornickel acts as the organisation’s key partner.

In 2021, WIM Russia launched the Talented Woman in the Extractive Industry initiative, an unprecedented award in Russia to recognise female professionals. A total of 24 companies in the industry submitted 237 applications. The jury chose 63 finalists, with Nornickel employees winning three categories:

  • In the Project of the Year category, the winner was Olga Merezhko, deputy chief mechanical engineer for buildings and structures of Komsomolsky Mine. Together with her team, Olga helped construct and commission a state-ofthe- art planning centre, or the “heart of the mine”, as the winner describes it.
  • The winner of the Social Project of the Year category was Olga Alexandrova, process engineer at the technical department of Nadezhda Metallurgical Plant. Her project to save the birds of Taimyr is designed to raise public awareness about environmental work.
  • In the Personal Achievement category, the winner was Darya Ermakova, chief expert for sustainable development at Kola MMC. During her five years with the company, she made a tremendous career after having started out as an electric technician of the second qualification category.

Respect for human rights across Nornickel’s operations*

Key human rights*
Business Ethics Code
Human Rights Policy
Equal Opportunities Programme
Working Conditions Policy
Occupational Health and Safety Policy
Personal Data Processing Policy
Freedom of Association Policy
Policy Regarding Support for Small and Medium Enterprises
Community Engagement Policy
Environmental Policy
Environmental Impact Assessment Policy
MMC Norilsk Nickel’s Position Statement on Biodiversity
Renewable Energy Sources Policy
Indigenous Peoples' Rights Policy
Approaches and key achievements in 2021

Key human rights

Right to life, freedom, and privacy, freedom from arbitrary arrest

Business Ethics Code
Human Rights Policy
Equal Opportunities Programme
Working Conditions Policy
Occupational Health and Safety Policy
Personal Data Processing Policy
Freedom of Association Policy
Policy Regarding Support for Small and Medium Enterprises
Community Engagement Policy
Environmental Policy
Environmental Impact Assessment Policy
MMC Norilsk Nickel’s Position Statement on Biodiversity
Renewable Energy Sources Policy
Indigenous Peoples' Rights Policy

Approaches and key achievements in 2021

Nornickel confirms its zero tolerance approach to workrelated fatalities.

Key human rights

Right to health and medical assistance

Business Ethics Code
Human Rights Policy
Equal Opportunities Programme
Working Conditions Policy
Occupational Health and Safety Policy
Personal Data Processing Policy
Freedom of Association Policy
Policy Regarding Support for Small and Medium Enterprises
Community Engagement Policy
Environmental Policy
Environmental Impact Assessment Policy
MMC Norilsk Nickel’s Position Statement on Biodiversity
Renewable Energy Sources Policy
Indigenous Peoples' Rights Policy

Approaches and key achievements in 2021

Although the Company’s LTIFR locally increased to 0.38 in 2021, Nornickel is consistently an above average performer in health and safety across mining peers.

For more details, please see the Occupational Health and Safety section.

Key human rights

Right to protection from discrimination GRI 406-1

Business Ethics Code
Human Rights Policy
Equal Opportunities Programme
Working Conditions Policy
Occupational Health and Safety Policy
Personal Data Processing Policy
Freedom of Association Policy
Policy Regarding Support for Small and Medium Enterprises
Community Engagement Policy
Environmental Policy
Environmental Impact Assessment Policy
MMC Norilsk Nickel’s Position Statement on Biodiversity
Renewable Energy Sources Policy
Indigenous Peoples' Rights Policy

Approaches and key achievements in 2021

The Company does not tolerate discrimination on any grounds.

In 2021, we had no reported cases of racial, gender, religious, political, social or other discrimination.

Key human rights

Right to freedom of association and collective bargaining

Business Ethics Code
Human Rights Policy
Equal Opportunities Programme
Working Conditions Policy
Occupational Health and Safety Policy
Personal Data Processing Policy
Freedom of Association Policy
Policy Regarding Support for Small and Medium Enterprises
Community Engagement Policy
Environmental Policy
Environmental Impact Assessment Policy
MMC Norilsk Nickel’s Position Statement on Biodiversity
Renewable Energy Sources Policy
Indigenous Peoples' Rights Policy

Approaches and key achievements in 2021

The Company maintains a well-developed social partnership framework, with collective agreements covering 94% of the workforce.

Key human rights

Right to work and to fair and adequate remuneration

Business Ethics Code
Human Rights Policy
Equal Opportunities Programme
Working Conditions Policy
Occupational Health and Safety Policy
Personal Data Processing Policy
Freedom of Association Policy
Policy Regarding Support for Small and Medium Enterprises
Community Engagement Policy
Environmental Policy
Environmental Impact Assessment Policy
MMC Norilsk Nickel’s Position Statement on Biodiversity
Renewable Energy Sources Policy
Indigenous Peoples' Rights Policy

Approaches and key achievements in 2021

The average salary paid to Nornickel’s employees is well above Russia’s average, standing at RUB 145,000 per month in 2021. The Company takes steps to secure jobs for vulnerable population groups and people with disabilities.

Women have equal rights to men.

For more details, please see the Human Capital section.

Key human rights

Other labour rights (fair and favourable working conditions, social support, reasonable work schedule, ban on forced labour, regular paid vacations)

Business Ethics Code
Human Rights Policy
Equal Opportunities Programme
Working Conditions Policy
Occupational Health and Safety Policy
Personal Data Processing Policy
Freedom of Association Policy
Policy Regarding Support for Small and Medium Enterprises
Community Engagement Policy
Environmental Policy
Environmental Impact Assessment Policy
MMC Norilsk Nickel’s Position Statement on Biodiversity
Renewable Energy Sources Policy
Indigenous Peoples' Rights Policy

Approaches and key achievements in 2021

The Company operates in strict compliance with Russian Federation employment laws that are in line with the UN documents ratified by Russia. Forced labour is forbidden.

In 2021, Nornickel’s Board of Directors approved the Supplier Code of Conduct and Responsible Sourcing Policy, which disclose, among other things, the Company’s human rights principles and requirements that are mandatory for its suppliers. The Company is committed to a zero tolerance approach to any violations of human rights across the supply chain, including:

  • cruel, inhuman or degrading treatment that includes any form of torture;
  • any form of forced labour or child labour;
  • sexually motivated crimes;
  • war crimes, crimes against humanity, genocide.

Key human rights

Right to education

Business Ethics Code
Human Rights Policy
Equal Opportunities Programme
Working Conditions Policy
Occupational Health and Safety Policy
Personal Data Processing Policy
Freedom of Association Policy
Policy Regarding Support for Small and Medium Enterprises
Community Engagement Policy
Environmental Policy
Environmental Impact Assessment Policy
MMC Norilsk Nickel’s Position Statement on Biodiversity
Renewable Energy Sources Policy
Indigenous Peoples' Rights Policy

Approaches and key achievements in 2021

The Company runs a wide range of training courses for all of its personnel categories, providing career guidance and targeted support to educational institutions across its geographies.

In 2021, we launched our first ever comprehensive employee training on human rights and plan to have this practice rolled out to suppliers and contractors.

Key human rights

Protection of family, maternity and childhood

Business Ethics Code
Human Rights Policy
Equal Opportunities Programme
Working Conditions Policy
Occupational Health and Safety Policy
Personal Data Processing Policy
Freedom of Association Policy
Policy Regarding Support for Small and Medium Enterprises
Community Engagement Policy
Environmental Policy
Environmental Impact Assessment Policy
MMC Norilsk Nickel’s Position Statement on Biodiversity
Renewable Energy Sources Policy
Indigenous Peoples' Rights Policy

Approaches and key achievements in 2021

The Company respects and protects the rights of mothers and pregnant women.

Its social programmes in the fields of housing, healthcare and culture aim to support and provide leisure opportunities for families.

For more details, please see the Human Capital section.

Key human rights

Freedom of movement

Business Ethics Code
Human Rights Policy
Equal Opportunities Programme
Working Conditions Policy
Occupational Health and Safety Policy
Personal Data Processing Policy
Freedom of Association Policy
Policy Regarding Support for Small and Medium Enterprises
Community Engagement Policy
Environmental Policy
Environmental Impact Assessment Policy
MMC Norilsk Nickel’s Position Statement on Biodiversity
Renewable Energy Sources Policy
Indigenous Peoples' Rights Policy

Approaches and key achievements in 2021

The Company does not restrict the freedom of movement of its employees. It reimburses round trip travel expenses and baggage fees as part of the benefits package.

Key human rights

Right to shelter, right to own property

Business Ethics Code
Human Rights Policy
Equal Opportunities Programme
Working Conditions Policy
Occupational Health and Safety Policy
Personal Data Processing Policy
Freedom of Association Policy
Policy Regarding Support for Small and Medium Enterprises
Community Engagement Policy
Environmental Policy
Environmental Impact Assessment Policy
MMC Norilsk Nickel’s Position Statement on Biodiversity
Renewable Energy Sources Policy
Indigenous Peoples' Rights Policy

Approaches and key achievements in 2021

The Company does not implement or plan to implement any business projects related to taking land from the population and forced relocation. No disputes with the local population over land use were recorded.

Key human rights

Right to a healthy environment

Business Ethics Code
Human Rights Policy
Equal Opportunities Programme
Working Conditions Policy
Occupational Health and Safety Policy
Personal Data Processing Policy
Freedom of Association Policy
Policy Regarding Support for Small and Medium Enterprises
Community Engagement Policy
Environmental Policy
Environmental Impact Assessment Policy
MMC Norilsk Nickel’s Position Statement on Biodiversity
Renewable Energy Sources Policy
Indigenous Peoples' Rights Policy

Approaches and key achievements in 2021

The Company continuously works to reduce its environmental footprint and implements a comprehensive environmental policy.

Key human rights

Rights of indigenous peoples

Business Ethics Code
Human Rights Policy
Equal Opportunities Programme
Working Conditions Policy
Occupational Health and Safety Policy
Personal Data Processing Policy
Freedom of Association Policy
Policy Regarding Support for Small and Medium Enterprises
Community Engagement Policy
Environmental Policy
Environmental Impact Assessment Policy
MMC Norilsk Nickel’s Position Statement on Biodiversity
Renewable Energy Sources Policy
Indigenous Peoples' Rights Policy

Approaches and key achievements in 2021

The Company respects the rights of indigenous peoples and is committed to improving their quality of life by supporting economic and cultural development across regions of operation.

Nornickel supports projects aimed at preserving the traditional lifestyle and culture of indigenous peoples while fostering their social and economic development. This includes organising air transportation, supplying construction materials and diesel fuel, and staging festivals and cultural events.

In 2021, Nornickel confirmed its commitment to the Free, Prior and Informed Consent (FPIC) process for indigenous peoples whenever this is applicable, and had this principle included into its updated Indigenous Peoples’ Rights Policy.

In 2021, as a way to improve the effectiveness of engagement with all stakeholders, including indigenous peoples, the Company also developed and approved the Stakeholder Engagement Policy and then the Stakeholder Engagement Plan. Any further stakeholder contacts will be in line with these documents and in accordance with key international standards and guidelines.

For more details, please see the Interaction with Indigenous Northern Minorities section.