Identification and assessment of human rights risks and impacts
The Company assesses risks and impacts of human rights violations, monitors and controls observance of human rights based on internationally recognised methodologies and guidelines, including:
- Human Rights Impact Assessment Guidance and Toolbox, Danish Institute for Human Rights (DIHR), 2020;
- UN Guiding Principles on Business and Human Rights (UNGPs), 2011.
Based on a survey and assessment carried out in 2022–2023, the Company conducted an in‑depth study of current threats, taking into account complaints and reports received through the Corporate Trust Line and holding a series of meetings with employees across its regions of operation. The corporate risk management system covers human rights risks.
| Right | Related risks | Assessment of potential impact on the Company’s goals |
|---|---|---|
| Employee right to occupational health and safety | Group fatality | Extremely high |
| Strained social and labour relations | Medium | |
| Requirements for suppliers to respect human rights as part of supply chain responsibility commitments | Failure to comply with ESG requirements put forward by customers, industry standards, associations and exchanges | High |
| Right of employees and external stakeholders to a healthy environment | Environmental damage caused by emergencies | Extremely high |
| Rights of local and indigenous communities | Risk of adverse impacts on the rights of local and indigenous communities | Low |
Human rights risks in the mineral supply chain are identified through supplier due diligence as part of the Group’s mineral supply chain Due Diligence Management System. In 2024, mineral supplierThe Group’s mineral suppliers include suppliers of mined minerals (primary processed material which has never been previously refined) and suppliers providing minerals transportation, their processing and loading/unloading services. due diligence identified no risks.
Improvements to the methodology for identifying human rights risks
In 2024, Nornickel continued to improve its methodology for identifying and assessing human rights risks. These efforts included processing the results of the Let Everyone Be Heard engagement survey, analysing specific metrics featured in the Sustainability Report, and studying queries submitted through the Corporate Trust Line channels. In the reporting year, the risk assessment process based on incoming queries was automated through the initial classification of queries upon receipt, including the assignment of event categories and subcategories.
Therefore, integrated human rights risk reflects both the level of risk associated with each human right and business unit as well as overall positive or negative trends, which can be used for ongoing monitoring of the due diligence system effectiveness.
Category
Remuneration
Social benefits
Violation of privacy
Violations related to the management of labour processes
Violations of the work and rest schedule
Environmental pollution
Workplace health risks
Workplace amenities
H&S requirements, personal protective equipment (PPE), production equipment
Child labour
Discrimination