| A: Governance and policy commitments |
| A.1. Policy commitments |
| A.1.1. Commitment to respect human rights | Internal Documents on Human Rights |
| A.1.2.a. Commitment to respect the human rights of workers: ILO Declaration on Fundamental Principles and Rights at Work | Internal Documents on Human Rights. For more details, please see MMC Norilsk Nickel’s Human Rights Policy |
| A.1.2.b. Commitment to respect the human rights of workers: Health and safety and working hours | Internal Documents on Human Rights. For more details, please see MMC Norilsk Nickel’s Human Rights Policy |
| A.1.3.a. Commitment to respect human rights particularly relevant to the sector: Land, natural resources, and indigenous peoples’ rights | Rights of Indigenous Peoples. For more details, please see MMC Norilsk Nickel’s Human Rights Policy |
| A.1.3.b. Commitment to respect human rights particularly relevant to the sector: Security | Commitment to Human Rights |
| A.1.4. Commitment to remedy | Corporate Trust Line |
| A.1.5. Commitment to respect the rights of human rights defenders | Corporate Trust Line |
| A.2. Board level accountability |
| A.2.1. Commitment from the top | Governance Structure, Responsibilities, and Oversight of Human Rights; Stakeholder Engagement |
| A.2.2. Board responsibility | Governance Structure, Responsibilities, and Oversight of Human Rights |
| A.2.3. Incentives and performance management | Governance Structure, Responsibilities, and Oversight of Human Rights; Management of Human Rights Risks |
| A.2.4. Business model strategy and risks | Governance Structure, Responsibilities, and Oversight of Human Rights |
| B: Embedding respect and human rights due diligence |
| B.1. Embedding respect for human rights in company culture and management systems |
| B.1.1. Responsibility and resources for day‑to‑day human rights functions | Governance Structure, Responsibilities, and Oversight of Human Rights |
| B.1.2. Incentives and performance management | Governance Structure, Responsibilities, and Oversight of Human Rights |
| B.1.3. Integration with enterprise risk management | Identification and Assessment of Human Rights Risks and Impacts |
| B.1.4.a. Communication/dissemination of policy commitment(s): Workers and external stakeholders | Stakeholder Engagement |
| B.1.4.b. Communication/dissemination of policy commitment(s): Business relationships | Contribution to Upholding the Rights of Supplier Employees |
| B.1.5. Training on human rights | Human Rights Training |
| B.1.6. Monitoring and corrective actions | Remedies and Grievance Mechanisms |
| B.1.7. Engaging and terminating business relationships | Contribution to Upholding the Rights of Supplier Employees |
| B.1.8. Approach to engaging with affected stakeholders | Stakeholder Engagement |
| B.2. Human rights due diligence |
| B.2.1. Identifying human rights risks and impacts | Identification and Assessment of Human Rights Risks and Impacts |
| B.2.2. Assessing human rights risks and impacts | Identification and Assessment of Human Rights Risks and Impacts |
| B.2.3. Integrating and acting on human rights risks and impact assessments | Identification and Assessment of Human Rights Risks and Impacts |
| B.2.4. Tracking the effectiveness of actions to respond to human rights risks and impacts | Management of Human Rights Risks |
| B.2.5. Communicating on human rights impacts | Stakeholder Engagement |
| C: Remedies and grievance mechanisms |
| C.1. Grievance mechanism(s) for workers | Remedies and Grievance Mechanisms |
| C.2. Grievance mechanism(s) for external individuals and communities | Remedies and Grievance Mechanisms |
| C.3. Users are involved in the design and performance of the mechanism(s) | Remedies and Grievance Mechanisms |
| C.4. Procedures related to the grievance mechanism(s) are equitable, publicly available, and explained | Remedies and Grievance Mechanisms |
| C.5. Prohibition of retaliation for raising complaints or concerns | Remedies and Grievance Mechanisms |
| C.6. Company involvement with state‑based judicial and non‑judicial grievance mechanisms | Remedies and Grievance Mechanisms |
| C.7. Remedying adverse impacts | Remedies and Grievance Mechanisms |
| C.8. Communication on the effectiveness of grievance mechanism(s) and incorporating lessons learned | Corporate Trust Line |
| D: Company human rights practices |
| D.3.1. Living wage | Key Figures of the Report |
| D.3.2. Transparency and accountability | Nornickel discloses production results and accounting statements prepared under the RAS and IFRS on the Company website |
| D.3.3. Freedom of association and collective bargaining | Respecting Employee Rights (the Collective Bargaining Agreement subsection) |
| D.3.4. Health and safety: Fatalities, lost days, injury, occupational disease rates | Respecting Employee Rights (the Health and Safety subsection) |
| D.3.5. Indigenous peoples’ rights and free prior and informed consent (FPIC) | Rights of Indigenous Peoples |
| D.3.6. Land rights: Land acquisition | The Company lends and acquires land plots for production and administrative buildings and its operations in general. Nornickel focuses on the consistent rehabilitation of all land affected by construction, mining, and emissions caused by its operations, and carries out regular audits of plant and mine closure plans. For more details, please see Nornickel’s 2024 Sustainability Report |
| D.3.7. Security | Respecting Employee Rights (the Health and Safety subsection) |
| D.3.8. Water and sanitation | In 2024, no major impact of Nornickel’s operations on water bodies was identified; water withdrawal was within the pre‑approved limits. The Company has in place water stewardship goals for the future (e.g. keeping water recycling and reuse rates above 80%). To reduce its environmental impact, the Company implements environmental initiatives and programmes (e.g. the maintenance and operation of the auxiliary fleet which serves to prevent river water contamination) |
| D.3.9. Women’s rights | Respecting Employee Rights (the Maternity and Childhood Protection subsection) |
| E: Response to serious allegations |
| E.1. The company has responded publicly to the allegation | There were no serious allegations against the Company in the reporting year |
| E.2. The company has investigated and taken steps to prevent re‑occurence |
| E.3. The company has engaged with affected stakeholders and taken appropriate actions to provide for or cooperate in remedy(ies) |