Grievance mechanism
CHRB C.2, CHRB B.1.6, CHRB C.7The grievance mechanism is a corporate procedure geared towards external stakeholders (residents in the regions of operation, suppliers and contractors, indigenous communities, etc.), as well as towards the Company’s employees.
The main purpose of the grievance mechanism is to efficiently address complaints and grievances received by the Corporate Trust Line or through other channels. It also aims to prevent, identify, and eliminate human rights risks.
Separate remedies are provided for the FPIC procedures concerning the construction of the new Tukhard settlement and the development of the Kolmozerskoye lithium deposit (for more details, please see the Remedies for Local and Indigenous Communities section).
CHRB C.6The new mechanism provides for pre‑trial dispute resolution through dialogue and mediation, which is an alternative dispute resolution method based on finding a mutually acceptable solution through the mediation of an impartial third party (independent expert). The mechanism does not replace any existing statutory or corporate rights protection mechanisms. It is not mandatory and does not limit the right to statutory remedies.
CHRB C.4Stages of the grievance mechanism
1
Receipt of a complaint through one of the available channels
Complaints can be received by phone, email, online form of the Corporate Trust Line, through offices for operating, social and labour relations, and the Company management. Complaints may be submitted by the initiator or through company representatives, independent experts, or ombudsmen.
2
Complaint registration, initial processing, notification of the initiator about the receipt and handling time
The standard handling time is 21 business days when filed through the Corporate Trust Line and 30 calendar days for other channels.
3
Assessment of information, initiation of investigation
Initial assessment of the information received from the whistleblower involves determining which division head should receive the complaint, whether additional information and investigation are required, and whether the complaint should be considered by an independent expert group or referred to government authorities. Starting in 2023, independent experts may be engaged to take part in consideration of complaints/reports, including at the whistleblower’s request.
4
Investigation / engagement of an independent expert
An independent expert review may be requested by the whistleblower.
Responsibility for maintaining the database of independent experts and for contacting them is assigned to the Sustainable Development Department of MMC Norilsk Nickel’s Head Office.
5
Response transmission / remediation / restoration of rights
Internally, complaints are reviewed in accordance with the Company’s by‑laws. Remediation and restoration of stakeholder rights are handled by the Company's Head Office and/or one of the Group companies.
6
Monitoring of performance, efficiency and satisfaction levels
To monitor the performance of the mechanism, we collect feedback from complaint initiators and assess their satisfaction on an ongoing basis and annually by analysing the feedback received during consultations with stakeholders across the Company's footprint and at the Head Office.
In 2024, we intend to further improve our grievance mechanism by using robotics and process automation.