Corporate Trust Line
Grievance policy
CHRB A.1.4, CHRB A.1.5, CHRB C.5, UNGPs RF C6.1Corporate Trust Line
CHRB C.1The principal query and claim management tool is the Company’s Corporate Trust Line established in 2010.
CHRB C.4, UNGPs RF C6.2For every stakeholder wishing to make a report, toll‑free channels are available 24/7: telephone, email, online form on the Company's website, or by sending a letter to the Trust Line. It handles reports on a wide range of matters related to violations of procedures and by‑laws, including with respect to human rights, labour, production, social relations, etc.
Contacts of the Corporate Trust Line:
- skd@nornik.ru;
- +7 (800) 700–19–41;
- +7 (800) 700–19–45;
- www.nornickel.com/sustainability/corporate-hotline;
- 15, 1st Krasnogvardeysky Drive, Moscow, 123100, Russia, Corporate Trust Line of MMC Norilsk Nickel.
The Company does not administrate any punishments or disciplinary actions and does not discriminate or retaliate against the persons who voice their concerns.
UNGPs RF C6.3In 2023, MMC Norilsk Nickel developed and approved the new Procedure on the Corporate Trust Line.
New options introduced by the updated Procedure on the Corporate Trust Line
1
Whistleblowers are provided with a confirmation of complaint/report registration (including information on standard handling time)Subject to consent/contact information.
4
Whistleblowers are provided information on the decision made (response)Subject to consent/contact information.
2
Independent experts are engaged to review the grievance and develop corrective actions
5
Whistleblowers can fill in a feedback form to give their opinion on the consideration and settlement of a complaint (whistleblower satisfaction assessment)
3
Whistleblowers and reported employees may be subject to an enquirySubject to consent/contact information.
6
The Company may publish anonymised information on the subject of complaints and the results of their consideration
The standard handling time from the registration of a complaint/report by the service operator to the review of the information received and the following assessment of the response by the Head of the Corporate Trust Line is 21 business days. Exceptions are made for complaints/reports that require immediate action or additional investigation. If a complaint/report is found justified, a set of control measures is taken, and if a violation is confirmed, steps are taken to correct the situation, eliminate any negative consequences, and inform those concerned.
The grievance statistics (broken down by Group company) are submitted to units in charge on a quarterly basis. The efficiency of the Corporate Trust Line is assessed by the Vice President for Internal Control and Risk Management, the Board’s Audit Committee and employees. Questions on the Corporate Trust Line efficiency are included in employee engagement surveys.
CHRB C.8, UNGPs RF A2.5, UNGPs RF C6.4