Human rights due diligence procedure

The system includes a set of initiatives for identifying, assessing, managing, and monitoring risks of human rights violations in order to prevent, mitigate, and eliminate any negative impacts on human rights.

Stakeholder engagement and training on protection of human rights are also an integral part of the system.

In 2023, the following initiatives were implemented to improve the Human Rights Due Diligence System:

• identifying risks of human rights violations based on complaints and reports received by the Corporate Trust Line;
• assessing risks of human rights violations with a breakdown by the Group key production facilities;
• analysing the outcomes of the large‑scale engagement survey named “Let Everyone Be Heard. What Do You Think?” and discussing them with focus groups in order to develop communication plans to increase employee loyalty and satisfaction by address ing their salient concerns (remuneration, bonuses, safety culture, etc.);
• monitoring the efficiency of ongoing measures to manage risks of human rights violations across individual production facilities of the Group.

In 2024, the Company plans to further develop the Human Rights Due Diligence System for Nornickel's business and functional units in Russia.