Stakeholder
engagement

Stakeholders and interaction mechanisms

102-42

Nornickel maintains an active dialogue and strives to foster relations with stakeholders. Effective stakeholder engagement enables us to properly manage risks and opens up new opportunities for integrating sustainability principles into our strategy.

Nornickel’s guiding principles in cooperating with government bodies, local authorities and non-profit organisations are strict compliance with Russian laws, regional and municipal regulations, and the social responsibility principle, collaboration, and mutual respect of interests.

Stakeholder engagement principles and procedures are set out in MMC Norilsk Nickel’s Business Ethics Code^*, Human Rights Policy, Local Community Relations Policy, Transparency Policy and other by-laws. We maintain dialogue with stakeholders in line with international standards and accountability principles^*.

We focus on timely collecting full information on the interests and proposals of our employees, shareholders, investors, business partners, national and local government authorities, local communities, Russian and international non-profit organisations.

We keep working to strengthen our relations with stakeholders, designing and updating tools to factor stakeholder interests in management practices, improving cooperation mechanisms and enhancing all aspects of dialogue across our footprint.

Since 2010, Nornickel has been operating its Corporate Trust Line, a permanent tool to manage complains and queries for a wide audience. It helps identify and quickly respond to matters of importance for stakeholders (for more details, please see the Corporate Trust Line section).

Dialogue with investors

Nornickel maintains an active dialogue with a wide range of Russian and international investors and equity analysts.

The Company regularly organises conference calls and meetings with investors, takes part in all major investment conferences and arranges site visits across its footprint.

Twice a year, following the disclosure of 6M and 12M results, we organise conference calls for a wide range of investors and analysts involving the Company’s top management to discuss financial and operating results, situation in the commodity markets, progress on strategic projects and implementation of sustainable development projects. Apart from that, we hold annual Investor Day attended by the Company’s top management to discuss our strategic development.

As part of our dialogue with investors, we note their growing interest in responsible investing. We seek to increase transparency by improving and expanding sustainability disclosures on our corporate website and in investor presentations.

We introduced a dedicated ESG Highlights section of the corporate website to address the matters of environmental protection, social responsibility and corporate governance.

Dialogue with employees

Nornickel places a special focus on interacting with its employees. We establish social partnerships regulating labour relations as a key tool to build dialogue with our people. Moreover, the Company has in place offices for social and labour relations, a response centre and task forces at divisions.

For employees facing redundancy as a result of operations closure we provide a package of social guarantees, including comfortable relocation to other sites, retraining and pension plans. In 2020–2022, the Company invested RUB 1,636 mln in a range of social programmes for smelting shop employees.

The Company continuously implements measures to build a dialogue between its top management and employees, which helps raise employee awareness, improve trust between workers and leadership and ensure that employees have a better understanding of the Company’s goals and values. To that end, the following activities were held in 2021:

1. Nornickel Live, a Q&A session;
2. spring and autumn corporate dialogues;
3. Challenges-2022 conference.

These events ensure high quality and regularity of contacts between the staff and the top management, involving over 40,000 employees every year. They allow our staff to get first-hand information and ask questions (over 3,000 queries in 2021), which helps build trust. As a result, for the first time in four years, the Perception of Senior Management indicator left the risk zone as showed by the Let Everyone Be Heard survey.

In addition, we conduct regular surveys to measure employee engagement and assess social programmes, along with targeted polls.

Dialogue with business partners

Nornickel takes its reputation very seriously and seeks to maintain good relations with its partners.

The key projects centred around business partner cooperation in 2021 include:

• registration at, and interaction through, the Shipment Notice and SAP SRM portals;
• the reverse factoring, discounting, implementing electronic workflow, supplier online account, and SAP SRM piloting project;
• implementation of the Supplier Code of Conduct and Responsible Sourcing Policy.

Our plans for 2022:

• further roll-out of the SAP system;
• industry exhibitions in different areas;
• signing long-term agreements (contracts);
• encouraging more suppliers to take part in cost reduction and optimisation programmes.

In our relations with suppliers and contractors, we focus on building an open and productive dialogue supported primarily through competitive procurement, feedback via a dedicated Suppliers section on our website, conferences and SAP SRM interactions. For more details, please see the Supply Chain Responsibility section.

As a participant in the global supply chain, the Company shares its partners’ sustainability values. To that end, it undergoes regular audits in accordance with sustainable development and responsible supply policies. These audits take place as part of systemic independent ESG reviews requested by our partners.

The core element of our relations with partners is advancing the responsible consumption of precious metals and metal-bearing products and creating a global mechanism to ensure the reliability of precious metal supplies as part of international non-profit organisations of producers and market players, such as the International Platinum Group Metals Association (IPA), International Information Security Research Consortium (IISRC) and the International Nickel Institute.

As a strategically important company, Nornickel places a special emphasis on supporting the development of its partners and keeping them updated on various matters. The Company’s expertise and solid track record in creating powerhouse industrial businesses that leverage cutting-edge technologies have laid the groundwork for successful implementation of projects with partners in both traditional and emerging industries.

Twice a year, we publish nickel and PGM market reviews prepared together with ICBC Standard Bank. They offer the market a deep and high-quality insight into trends and forecasts in this domain.

Our contribution to sustainable development and the promotion of green economy takes the form of mutually beneficial partnerships. The Company entered into a strategic partnership with BASF to meet the growing demand for battery materials used in electric vehicles.

Dialogue with authorities, communities and non-profit organisations

We follow the information transparency principle and focus on constructive and effective cooperation with government bodies, local communities and nonprofit organisations. We also actively participate in the work of regional authorities’ expert boards across our geography.

As at the end of 2021, the Company was represented in 25 committees, commissions, expert and working groups established by governmental bodies in association with the business community, thus supporting socially important projects.

The Company takes part in parliamentary sessions and round table discussions organised by the Federation Council and State Duma of the Federal Assembly of the Russian Federation, Government of the Russian Federation, Civic Chamber of the Russian Federation, Russian Union of Industrialists and Entrepreneurs, Chamber of Commerce and Industry of the Russian Federation, Association of Managers (an interregional public organisation), etc.

In order to maintain a constructive dialogue with the government and cut administrative red tape, the Company’s experts engage in draft regulation discussions held by community councils of the federal executive bodies, as well as in anti-corruption due diligence and regulatory impact assessments. This helps improve business climate.

In late 2021, the Company joined the Arctic Economic Council (AEC), an independent international business organisation created by the Arctic Council and representing the companies operating in the Arctic.

Local communities

When interacting with local communities, the Company focuses on collecting and taking into account all concerns of local residents on regional development and social projects. To that end, we organise targeted surveys, polls, focus groups, dialogue and other initiatives. We do our best to collect and take into account all the feedback from local residents on regional development and high-potential projects. Key parties to the dialogue are regional development centres established with Nornickel’s support, such as the Norilsk Development Agency, the Second School Centre for social projects in the Pechengsky District, and the Monchegorsk Development Agency. For more details on these centres and our cooperation with local communities, please see the Development of Local Communities section.

Environmental protection dialogue

Environmental agenda is gaining momentum year after year, becoming the focus of stakeholder attention.

Our representatives are closely involved in developing key draft laws on environmental protection, control (including subsoil use), and economics.

Among other things, Nornickel interacts with its employees and local communities on environmental matters via volunteer movements. One of our major projects in this area is the Let’s Do It environmental marathon bringing together thousands of our employees and local community members to support nature reserves, clean up certain areas, transplant young trees, and carry out other environmental initiatives.

Dialogue in public non-financial reporting

GRI 102-43 102-46

Each year, Nornickel engages in dialogues with stakeholders while drafting sustainability reports and conducts surveys to define the material topics.

As part of preparing the 2021 Sustainability Report, we held an online dialogue. Representing Nornickel were Andrey Bougrov, Senior Vice President for Sustainable Development, Stanislav Seleznev, Vice President for Ecology and Industrial Safety, and Svetlana Ivchenko, Head of the Sustainable Development Department.

In the course of the event, we presented the concept of the 2021 report and our strategy, updated to reflect the report’s focus on the climate change. We also had our matrix of material and additional disclosures verified by the experts.

Public and media relations

Nornickel maintains a continuous commitment to enhancing transparency and information availability for all stakeholders.

The Company has in place the following key documents governing transparency:

• Information Policy Regulations of MMC Norilsk Nickel;
• Procedure for the Interaction between MMC Norilsk Nickel’s Officers and Russian and International Mass Media.

In applying the information policy, the Company is guided by the principles of regularity, timeliness, accessibility, reliability, completeness, balance, and impartiality, all the while taking appropriate measures to ensure protection of its information resources.

We stand by our commitments and go beyond the mandatory disclosure requirements. Nornickel timely responds to stakeholder requests to provide them with material information about its activities, while also making clear its standing on certain topics. We regularly inform the public about the Company’s strategy and mission, policies, key events, and performance.

The key channels used to relay information to the stakeholders and the public are the Company’s official website www.nornickel.com, press conferences, briefings, conference calls, and stakeholder meetings and dialogues. Apart from scheduled meetings, we make sure to clarify the Company’s position on events (including emergencies) that call for comments as part of press conferences, briefings, or press releases. We have put in place an efficient media communications system.

In 2021, Nornickel was the top Russian metals and mining company in terms of mentioning in the media. Over the past year, the number of media publications about Nornickel decreased by 17.6% compared to 2020, which saw a spike in media attention towards the Company due to the incident at HPP-3 in Norilsk. In 2021, this topic continued to get a lot of media coverage, although the number of publications on it went down from 35% to 12%. The focus of publications shifted from the incident’s adverse effect to the clean-up activities, studies, and development of the Company’s facilities.

Throughout 2020, the media covered the Company’s efforts to mitigate the incident’s consequences, in particular the second stage of the Great Norilsk Expedition, infrastructure upgrade and development in Norilsk and the Norilsk Industrial District, and the Clean Norilsk programme.