Identification and assessment of human rights risks and impacts

CHRB B.1.3

In 2023, Nornickel continued identifying and assessing risks and impacts on human rights. Following a preliminary assessment completed in 2022,For more details on the preliminary assessment conducted in 2022, please see Norilsk Nickel Group’s 2022 Human Rights Report. the Company conducted an in‑depth analysis of human rights risks and impacts based on complaints and reports received by the Corporate Trust Line. For the purposes of the assessment, the Company used the methodology of the Danish Institute for Human Rights (as recommended by IRMA).For more details on the Danish Institute for Human Rights, please see the its official website.

The general approach to identifying risks involved analysing complaints and reports received, classifying these by topic, and pinpointing rights violated.

Approach to identifying risks of human rights violations

In 2023, to standardise the approach to analysing complaints and reports, the Company developed guidelines for a classifier to identify risks of human rights violations, including a description of human rights and, for each right, a list of categories and subcategories of events involving human rights violations. The incoming information is used for identifying, assessing and mitigating human rights risks.

CHRB B.2.1, B.2.2

The analysis helped map out and prioritise human rights within the GroupNornickel employees. with a breakdown by operations, including the right to health, safe working conditions, protection from forced labour, and fair and decent remuneration.

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 the reporting period, due diligence identified no risks. For a detailed description of Nornickel’s approach to building a responsible supply chain, please see the Responsible Supply Chain Report.

The list of the Company's key risks includes human rights risks. To mitigate these, Nornickel continuously monitors and controls observance of human rights at every stage of its operations.

Human rights risks embedded in the corporate risk management framework

Right	Related risks	Assessment of potential impact on the Company’s goals
Employee right to safety, including 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 the requirements put forward by leading ESG standards and associations	High
Rights 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

The Company assesses risks and impacts of human rights violations, monitors and controls observance of human rights based on the following guidelines and best practices:

UN Guiding Principles on Business and Human Rights, 2011;www.ohchr.org
The Corporate Responsibility to Respect Human Rights: An Interpretive Guide, UNDP, 2012;The Corporate Responsibility to Respect Human Rights | United Nations iLibrary (un-ilibrary.org)
Human Rights Impact Assessment Guidance and Toolbox, Danish Institute for Human Rights, 2020.www.humanrights.dk