Improvements to the human rights due diligence system in 2024

The Company continues improving its human rights practices, regularly assessing its progress. The following was developed in 2024:

Classification of reports and complaints	Methodology for assessing integrated human rights risk	Risk assessment at the Group entity level
The Corporate Trust Line was expanded to include a query classification tool. Each incoming query is assigned an appropriate category and subcategory depending on its topic and the human rights potentially involved	A human rights risk assessment system was developed. The system incorporates an analysis of queries received via the Corporate Trust Line, the results of the Let Everyone Be Heard engagement survey, and non‑financial reporting data	Integrated risk is assessed individually for each of the Group’s production facilities, allowing for the prioritisation of areas where corrective and mitigating measures should be developed and implemented in relation to: Group entities with the highest human rights risks; human rights most frequently exposed to violation risks across the Company as a whole; processes that require systemic change

Classification of reports and complaints

Methodology for assessing integrated human rights risk

Risk assessment at the Group entity level

The Corporate Trust Line was expanded to include a query classification tool. Each incoming query is assigned an appropriate category and subcategory depending on its topic and the human rights potentially involved

A human rights risk assessment system was developed. The system incorporates an analysis of queries received via the Corporate Trust Line, the results of the Let Everyone Be Heard engagement survey, and non‑financial reporting data

Integrated risk is assessed individually for each of the Group’s production facilities, allowing for the prioritisation of areas where corrective and mitigating measures should be developed and implemented in relation to:

Group entities with the highest human rights risks;
human rights most frequently exposed to violation risks across the Company as a whole;
processes that require systemic change

Nornickel not only consistently strengthens its internal human rights processes but also demonstrates high standards in its external practices. In 2024, the Company earned a finalist finish in the MINEX Forum’s Russian Mining Excellence Awards, in the Sustainability Project category, for developing a human rights due diligence system. This achievement reflects the results of its comprehensive efforts to integrate risk assessment and management tools, enhance the transparency of internal processes, and actively engage with employees and stakeholders.