The Company’s Corporate Trust Line (CTL),
established in 2010, is the Company’s key grievance mechanism.
Key operating principles
of the Corporate Trust Line:
Guaranteed confidentiality for reporting
persons
Independent consideration of reports
Timely and unbiased consideration of all
reports submitted via the Corporate Trust Line
A clearly structured process ensures that all
submissions are reviewed objectively and impartially, with full respect
for the rights of all parties involved. The Corporate Trust Line
is designed to identify and prevent violations, uphold the highest standards
of corporate ethics, and foster trust within the Company and among
its partners.
CHRB C.4, UNGPs RF C6.2
The Corporate Trust Line covers all Company
units and Group entities, enabling prompt responses to emerging challenges across
the Company’s footprint and ensuring a consistent standard for handling
complaints and reports.
The Corporate Trust Line is available
to all stakeholders, whether they are employees, partners, customers,
or representatives of external organisations. The Company investigates
reports of potential violations, misconduct, or incidents that might cause
financial or reputational damage. All reports are thoroughly reviewed, and
any identified risks trigger appropriate corrective actions to ensure their
mitigation and elimination.
1st Krasnogvardeysky Drive 15, Moscow, Russia, 123112,
Corporate Trust Line of MMC Norilsk Nickel
Information about
the Corporate Trust Line is made available to employeesvia the intranet
portal, the Companywebsite, information screens,
physical stands, posters, and payslips.
The Company does not administer
any punishments, disciplinary action, discrimination, pressure, or retaliation
against individuals who voice their concerns or report identified issues.
The Company guarantees that reporting persons will not face any negative
consequences as a result of reporting, regardless of their position,
status, or manner of cooperation.
UNGPs RF C6.3
The service is governed by the
Procedure on the Corporate Trust
Line of PJSC MMC Norilsk Nickel, which establishes clear rules for receiving,
reviewing, and processing reports. The document ensures that the reporting person
is provided with a response on the decision made and, once
the review process is complete, the opportunity to complete
a feedback form to assess satisfaction with the handling
of the report. To enhance transparency, the Company now publishes
anonymised information on the content of reports and measures taken.
If a report is confirmed as justified, audits are initiated.
The information is brought to the attention of relevant units and
officers to ensure timely response and prevent similar cases in future.
The performance of the Corporate Trust
Line is reviewed annually by the Vice President – Head of Internal
Control and Risk Management, including through the setting of KPIs, and
is also considered at meetings of the Board’s Audit Committee.
Key performance indicators
of the business process:
timely processing of complaints/reports
accepted for review;
proper processing of complaints/reports
accepted for processing (number of refusals to investigate);
timely preparation of reports on CTL
performance to interested users.
Employees responsible
for the operation of the Corporate Trust Line
Vice President – Head
of Internal Control and Risk Management
Director of the Internal
Control Department
CTL head
CHRB C.8, UNGPs RF A2.5, UNGPs RF C6.4
Complaints/reports in 2024 by type
reported
Report statistics (broken down by Group entity
and type of reported abuse) are submitted to relevant Company units, with CTL
performance reviewed by the Board’s Audit Committee.
As part of operating the Corporate
Trust Line, a reporting person is provided with feedback at all report review
stages: confirmation of registration of the complaint/report (including
information on standard review timelines), information on the decision taken
on the report or dismissal of the complaint/report, and
the results of the report’s review (if requested
by the reporting person). If desired, the reporting person may assess
the handling of the report.
The feedback received from applicants
suggests that over 90%of reportingpersonsare satisfied with the handling
of their reports. Additional follow‑up measures were taken for each
unsatisfactory feedback, including with the involvement of experts from
relevant functions, and follow‑up communications with the reportingpersons.
