Approach to human rights protection
The Company has a clear governance structure with a defined hierarchy for reporting and escalating human rights concerns. The Board of Directors and Management Board review human rights risks. The Sustainable Development and Climate Change Committee of the Board of Directors monitors the effectiveness and efficiency of major amendments to strategies, goals, programmes, projects and other significant initiatives adopted with regard to human rights. At the senior executive level, Nornickel’s human rights agenda falls within the remit of Vladimir Zhukov, Vice President for Investors and Sustainable Development.
Nornickel regularly assesses the potential impact of its operations on human rights. The Risk Management Service monitors key risk management initiatives, including those identified in the process of stakeholder engagement regarding the respect and protection of human rights, and develops company-wide methodological principles and approaches to risk management.
On top of ensuring full compliance with human rights requirements and addressing related risks, the Company also implements best practices (signs employment contracts and collective bargaining agreements, creates favourable work and rest conditions for employees) and expects its suppliers and contractors to respect human rights throughout their operations.
Information on alleged human rights violations is collected via the Corporate Trust Line (CTL) established to process reports from all internal and external stakeholders (including human rights complaints), as well as regular employee questionnaires and sentiment surveys among the local population and indigenous northern minorities. The Company guarantees confidentiality for whistle-blowers and respondents. The Internal Control Department handles complaints/queries in relation to stakeholder engagement filed through the CTL. It verifies, analyses and processes the submitted information, monitors control measures and provides the CTL report statistics, including those in the field of human rights protection, to heads of units of the Company and its business units, business supervisors of Nornickel’s Russian business units and supervisors of the Company’s standalone business units.
Report statistics are regularly reviewed by the Sustainable Development and Climate Change Committee of the Board of Directors.
Nornickel contributes to indigenous rights protection and improved quality of life for indigenous peoples, promotes their development in its regions of operation, and delivers on its commitment to strengthen and develop mutually beneficial relationship.
In 2021, Nornickel confirmed its commitment to the implementation of the Free, Prior and Informed Consent (FPIC) principle, wherever applicable, in line with the standards and recommendations of the International Council on Mining and Metals (ICMM) and procedures adopted by the Company.
Nornickel provides stakeholders with access to a framework for submitting and reviewing applications to address any grievances or proposals, or receive legal protection in connection with them.
In 2021, human rights complaints were sorted into a separate category of reports filed via the Corporate Trust Line.
The Company identifies groups of stakeholders, including local communities and indigenous minorities, to build long-term relations with them based on respect and trust and aimed at mutual benefit and wealth. In 2021, to improve this process, Nornickel developed a Stakeholder Engagement Policy and Stakeholder Engagement Plan for planning, implementing and assessing respective operations of the Company.
Across its supply chain, Nornickel takes a zero-tolerance approach to any kind of modern slavery, including forced or bonded labour, human trafficking, child labour, or any form of discrimination and ensures that its suppliers prevent any violation of human rights in their operations or supply chains.
In 2021, Nornickel developed and approved its Supplier Code of Conduct and Responsible Sourcing Policy, which disclose, among other things, the Company’s approach to principles and obligations related to the protection of human rights.
The Company recognises the risks of adverse impact on human rights, including risks of conflicts in connection with the production, marketing, processing and export of feedstock from areas involved in military conflicts and high-risk areas, and it will not permit, support, or benefit from any form of human rights violation or abuse throughout its supply chains. These include:
cruel, inhuman or degrading treatment, or any kind of torture;
any form of forced labour;
the worst forms of child labour;
other gross human rights violations and abuses such as sexual violence, which is widespread globally;
war crimes or any other violations of international humanitarian law, crimes against humanity or genocide.
2021 saw Nornickel introduce comprehensive employee training in human rights. The Company plans to further expand it to contractors and suppliers.