GRI content index

Nornickel prepared the Report in accordance with the GRI Standards for the period from 1 January 2022 to 31 December 2022.

GRI standard Disclosure number Disclosure Page/link Assured by the auditor Omission Comments
GRI 1: Foundation 2021
GRI 2: General Disclosures 2021 1. The organisation and its reporting practices
2–1 Organisational details About Nornickel Group,
About the Report
Assured Nature of ownership – private.
2–2 Entities included in the organisation’s sustainability reporting Report boundaries Assured For a list of entities included in the financial statements of Nornickel Group, please see the Group’s IFRS financial statements.
2–3 Reporting period, frequency and contact point About the Report,
Contacts
Assured

Financial and sustainability reporting is prepared annually for the calendar year.

The date of this report is 23.05.23.

2–4 Restatements of information About the Report Assured Information on changes in previous periods’ data is provided in the report in the footnotes below the respective figures.
2–5 External assurance About the Report,
Independent assurance report
Assured
2. Activities and workers
2–6 Activities, value chain and other business relationships About Nornickel Group,
Strategy of sustainable growth,
Supply chain responsibility
Assured There were no significant changes in the supply chain of the core production process in the reporting year. Due to sanctions imposed on the Russian Federation, the Company is in the process of revising its list of equipment and software suppliers.
2–7 Employees HR management and social partnership,
GRI quantitative indicators disclosure
Assured
2–8 Workers who are not employees GRI quantitative indicators disclosure Assured

The relations with such employees are mainly formalised through civil law contracts.

Such contracts are usually made for temporary work, without any prevailing type of activity. There are no significant hiring fluctuations within the reporting periods, and the changes from one reporting period to another may be associated with an increasing number of FTEs (a part of the functions handed over to FTEs).

3. Governance
2–9 Governance structure and composition Climate change and energy efficiency,
Occupational health and safety,
HR management and social partnership,
Development of local communities,
Corporate Governance,
Sustainability Management,
Internal Control and Risk Management,
Tax strategy,
Business Ethics and Anti-Corruption
Assured Disclosure 2-9-с is provided in the Annual Report of MMC Norilsk Nickel for 2022.
2–10 Nomination and selection of the highest governance body Corporate Governance Assured
2–11 Chair of the highest governance body Corporate Governance Assured The Chairman of the Board of Directors is not an executive director.
2–12 Role of the highest governance body in overseeing the management of impacts Enviromental management,
Climate change and energy efficiency,
Occupational health and safety,
HR management and social partnership,
Development of local communities,
Corporate Governance,
Sustainability Management,
Internal Control and Risk Management,
Tax strategy,
Business Ethics and Anti-Corruption
Assured
2–13 Delegation of responsibility for managing impacts> Enviromental management,
Climate change and energy efficiency,
Occupational health and safety,
HR management and social partnership,
Development of local communities,
Corporate Governance,
Sustainability Management,
Internal Control and Risk Management,
Tax strategy,
Business Ethics and Anti-Corruption
Assured
2–14 Role of the highest governance body in sustainability reporting Enviromental management Assured

The Sustainability Report, including the list of material topics, was approved by the Board of Directors, GMK/24-pr-sd

dated 23.05.2023.

2–15 Conflicts of interest Corporate Governance Assured The Company publicly discloses information on related-party transactions in its annual reports.
2–16 Communication of critical concerns Corporate Governance,
Internal Control and Risk Management,
Grievance policy
Assured
2–17 Collective knowledge of the highest governance body Corporate Governance Assured
2–18 Evaluation of the performance of the highest governance body Corporate Governance Assured
2–19 Remuneration policies Corporate Governance Assured

The Board of Directors’ remuneration is set out in Remuneration Policy for Members of Board of Directors are no termination or retirement benefits for members of the Board of Directors, as they are not employees of the Company. The Company’s management are subject to the same termination and retirement benefit rules as other employees of the Company.

2–20 Process to determine remuneration Corporate Governance Assured Information on 2-20 b is not disclosed as not applicable. The Board of Directors’ remuneration is set out in Remuneration Policy for Members of Board of Directors.
2–21 Annual total compensation ratio Not assured Information has not been disclosed due to the protection of the personal data of the highest paid executive.
4. Strategy, policies and practices
2–22 Statement on sustainable development strategy President’s letter,
Chairman’s letter
Assured
2–23 Policy commitments Strategic vision,
Enviromental management,
Respect for human rights
Assured

For sustainable development policies and statements, please see the Company’s corporate website at.

The Company’s employees are familiarised with by-laws upon hiring and in internal training sessions conducted by Nornickel.

Suppliers and contractors of the Company are familiarised with by-laws when entering into contracts if it is stipulated by provisions of the contracts.

2–24 Embedding policy commitments Strategic vision,
Sustainability Management
Assured
2–25 Processes to remediate negative impacts Grievance policy Assured For information on the commitment to assess negative impacts, please see MMC Norilsk Nickel’s Human Rights Policy.
2–26 Mechanisms for seeking advice and raising concerns Stakeholder engagement,
Occupational health and safety,
HR management and social partnership,
Development of local communities,
Grievance policy
Assured
2–27 Compliance with laws and regulations Business Ethics and Anti-Corruption Assured Significant cases of non-compliance with laws/regulations resulting in fines or non-financial penalties are understood as events disclosed in section 26 of the Notes to the IFRS annual consolidated financial statements and/or receiving adverse publicity. There have been no such cases in 2022.
2–28 Membership associations Nornickel’s support for initiatives, standards, and participation in associations focused on sustainable development and corporate social responsibility Assured
5. Stakeholder engagement
2–29 Approach to stakeholder engagement Stakeholder engagement,
Corporate Governanc
Assured
2–30 Collective bargaining agreements HR management and social partnership Assured
GRI 3: Material Topics 2021 Disclosures on material topics
3–1 Process to determine material topics Definition of material topics Assured
3–2 List of material topics Definition of material topics Assured
Employment and decent working conditions in the regions of operation
3–3 Management of material topics HR management and social partnership,
Development of local communities,
Definition of material topics
Assured

The Equal Opportunities Programme defines the Company’s approaches and commitments in providing jobs.

The Working Conditions Policy sets forth the principles and commitments in providing jobs.

201–3 Defined benefit plan obligations and other retirement plans Social policy Assured Payments under the pension plan are made by NPF GAZFOND Pension Savings. For the fund’s public reports, please see the website.
202–1 Ratios of standard entry level wage by gender compared to local minimum wage at significant locations of operation HR management and social partnership Assured The calculation covers the Group’s companies with an average headcount of at least 500 employees in 2022.
202–2 Proportion of senior management at significant locations of operation hired from the local community HR management and social partnership Assured
401–1 New employee hires and employee turnover HR management and social partnership,
GRI quantitative indicators disclosure
Assured
401–2 Benefits provided to full-time employees that are not provided to temporary or part-time employees GRI quantitative indicators disclosure Assured The indicator is partially disclosed. No information is provided for the following types of benefits: life insurance, healthcare, disability/temporary disability coverage, childcare leave and share ownership.
403–6 Promotion of worker health Occupational health and safety,
Social policy
Assured
404–3 Percentage of employees receiving regular performance and career development reviews GRI quantitative indicators disclosure Assured
Emissions
3–3 Management of material topics Air,
Definition of material topics
Assured
305–7 Nitrogen oxides (NOx), sulphur oxides (SOx), and other significant air emissions Air,
GRI quantitative indicators disclosure
Assured Persistent organic pollutants are not emitted. Hazardous air pollutant emissions are not disclosed as there is no such a category according to the Russian laws. Emissions of volatile organic compounds (VOCs) in 2022 amounted to 1,366 t.
Training and education
3–3 Management of material topics HR management and social partnership,
Definition of material topics
Assured Collecting feedback from trainees and assessing their satisfaction serve to assess the effectiveness of training.
404–1 Average hours of training per year per employee HR management and social partnership Assured
404–2 Programmes for upgrading employee skills and transition assistance programmes HR management and social partnership,
Social policy
Assured
Innovation projects pursuing sustainable development goals
3–3 Management of material topics Research and development, digital technologies,
Definition of material topics
Assured

In 2015, Nornickel launched the Technological Breakthrough programme focused on automating process control and enhancing productivity and safety, among other things, by introducing cutting-edge information support and automated systems.

For more details, please see MMC Norilsk Nickel’s Annual Report for 2022.

Contribution to the development of local communities
3–3 Management of material topics Development of local communities,
Definition of material topics
Assured
201–1 Direct economic value generated and distributed GRI quantitative indicators disclosure Assured
203–1 Infrastructure investments and services supported Development of local communities,
Corporate security
Assured
203–2 Significant indirect economic impacts Development of local communities,
Corporate security
Assured
204–1 Proportion of spending on local suppliers Assured The indicator is not disclosed in accordance with the GRI requirements due to no accounting system. The Company will consider disclosure within the next three years. The Development of Local Communities section discloses information on the Company’s expenses associated with procurement from suppliers in the key regions of operation.
207–1 Approach to tax Tax strategy Assured
207–2 Tax governance, control and risk management Tax strategy,
Grievance policy
Assured
207–3 Stakeholder engagement and management concerns related to tax Tax strategy Assured Stakeholders’ tax-related concerns among their other queries can be addressed as part of the mechanisms of the Corporate Trust Line.
207–4 Country-by-country reporting Assured The indicator is not disclosed due to the confidential nature of information (this information is a trade secret of the Company).
413–1 Operations with local community engagement, impact assessments, and development programmes Assured The share of operations with local community engagement is 45% of all business units of the Company.
Climate change
3–3 Management of material topics Climate change and energy efficiency,
Definition of material topics
Assured
201–2 Financial implications and other risks and opportunities due to climate change Climate change and energy efficiency Not assured Financial implications of the risk are not disclosed as there is no such estimate. Estimating financial implications is planned to be conducted within 3–5 years. In 2022, the expenses on the Climate Change and Energy Efficiency initiatives as well as the permafrost-focused activity as part of the Environmental and Climate Change Strategy totalled RUB 8.5 bn.
302–1 Energy consumption within the organisation Climate change and energy efficiency Assured

The Company uses statistical reporting forms applicable in Russia to record energy consumption data. TJ recalculation ratios are derived from the GRI 3.0 Guidelines and Engineering Magazine, a Russian R&D reference book.

The calculation does not include cooling energy as inapplicable.

302–3 Energy intensity Climate change and energy efficiency Assured To calculate internal energy intensity, the Group’s total energy consumption and the consolidated IFRS revenue are taken as the numerator and the denominator.
302–4 Reduction of energy consumption Climate change and energy efficiency Assured Reduction of energy consumption is calculated based on the technical specifications of equipment and other energy-consuming devices that are replaced as part of energy efficiency initiatives (as the difference between the consumption of more energy-efficient new equipment and less energy-efficient old equipment).
305–1 Direct (Scope 1) GHG emissions Climate change and energy efficiency Assured The calculation of GHG emissions relied on GWP values from the IPCC Fifth Assessment Report, which are 1 for CO2, 28 for CH4 and 265 for N2O. The organisational boundaries for the quantitative assessment of GHG emissions in 2022 include MMC Norilsk Nickel companies over which the Company has operational control. At present the Company does not report indirect GHG emissions calculated using a market-based method. The information is not provided due to the need to request it from electric power companies.
305–2 Energy indirect (Scope 2) GHG emissions Climate change and energy efficiency Assured
305–3 Other indirect (Scope 3) GHG emissions Climate change and energy efficiency Assured

The calculation of GHG emissions relied on GWP values from the IPCC Fifth Assessment Report, which are 1 for CO2, 28 for CH4 and 265 for N2O. It takes into account the following greenhouse gases: carbon oxide (CO2), nitrous oxide (N2O), methane (CH4), with no or insignificant emissions of other greenhouse gases.

Biogenic CO2 emissions are inapplicable.

305–4 GHG emissions intensity Climate change and energy efficiency Assured
305–5 Reduction of GHG emissions Assured

In 2022, we prevented GHG emissions of 146.6 kt of CO2 equivalent, of which 26.6 kt of CO2 equivalent are Scope 1 emissions eliminated as a result of direct energy saving initiatives, and 120 kt of CO2 equivalent are Scope 2 emissions eliminated through deregulated bilateral purchase agreements for low-carbon electricity signed by the Trans-Baikal Division companies. Calculation of the emissions prevented as a result of direct energy saving initiatives is based on the calculation of the 302-4 indicator (the prevented emissions estimated result from reduced energy consumption).

Contribution to the national industry by promoting Russian technology
3–3 Management of material topics Tax strategy,
Definition of material topics
Assured As at 31 December 2022, the Company did not adopt policies or set targets as regards contribution to the national industry.
Waste management
3–3 Management of material topics Tailings and waste,
Definition of material topics
Assured
306–1 Waste generation and significant waste-related impacts Tailings and waste Assured
306–2 Management of significant waste-related impacts Tailings and waste Assured
306–3 Waste generated GRI quantitative indicators disclosure Assured
306–4 Waste diverted from disposal Tailings and waste,
GRI quantitative indicators disclosure
Assured

Waste diversion is only disclosed as regards recycling.

Information on the disposal of waste transferred outside the organisation is partially disclosed (without breakdown by type of disposal).

Information on waste management methods is disclosed in a breakdown stipulated by the Russian law (as part of filling the statistic form 2-TP (waste)). In the GRI terms, hzard waste is understood as waste of hazard classes 1–4 defined by the Russian law.
306–5 Waste directed to disposal GRI quantitative indicators disclosure Assured Partially disclosed (without breakdown by incineration with energy recovery and incineration without energy recovery).
Biodiversity
3–3 Management of material topics Biodiversity,
Definition of material topics
Assured
304–1 Operational sites owned, leased, managed in, or adjacent to, protected areas and areas of high biodiversity value outside protected areas Biodiversity Assured No data is disclosed on the size of Kola MMC operational sites located in the vicinity of protected areas due to no accounting system. The Company will consider disclosure within the next three years.
304–2 Significant impacts of activities, products, and services on biodiversity Biodiversity Assured The information on the number of affected (unprotected) species and on the reversibility of the impact is not disclosed as it is subject to the Company’s further research in biodiversity. The Company will consider disclosing this information within three years.
304–3 Habitats protected or restored Soil protection and responsible mining Assured The information on the condition of the restored habitats is not disclosed due to the lack of the accounting system. The Company will consider disclosing this information within three years. The information is disclosed in accordance with the practice of land rehabilitation (restoration) as per the Russian laws. The completion of land rehabilitation is confirmed by government authorities in relevant documents.
304–4 IUCN Red List species and national conservation list species with habitats in areas affected by operations Biodiversity,
GRI quantitative indicators disclosure
Assured For Pasvik and Lapland nature reserves, there is no breakdown by vulnerability of protected species in accordance with GRI 304-4 (CR, EN, VU, NT, LC).
Health and safety
3–3 Management of material topics Occupational health and safety,
Definition of material topics
Assured
403–1 Occupational health and safety management system Occupational health and safety Assured
403–2 Hazard identification, risk assessment, and incident investigation Occupational health and safety Assured

Identification and assessment of occupational health and safety risks take place at all Group companies covered by the Report on an annual basis or ad hoc as described in the STO KISM 121-211-2017 corporate integrated management standard or similar local standards. The quality for these processes is ensured through compliance of assessment requirements with the above standards.

Employees may report workplace hazards through the following channels:

  • orally to their head;
  • problem-solving boards available at all sites;
  • report to an OHS structural unit;
  • authorised persons present at OHS committee meetings;
  • staff meetings;
  • work refusal form.

All injuries are investigated by a dedicated commission as stipulated by the national laws.

403–3 Occupational health services Occupational health and safety Assured Contractors work on the Company’s sites based on a contract that includes mandatory requirements for occupational health and safety. Before the start of a contractor’s work, the Company takes a set of preparatory measures to ensure work safety. During the execution of the contract, the contractor undertakes to provide its employees with personal protective equipment on its own. The contractor ensures that sanitary and epidemiological requirements are met and all necessary OHS measures are taken. In the course of its operations, Nornickel monitors contractor employees’ compliance with OHS requirements. In addition, the Company provides contractor employees with access to first aid at first-aid posts on production sites.
403–4 Worker participation, consultation, and communication on occupational health and safety Occupational health and safety Assured
403–5 Worker training on occupational health and safety Occupational health and safety Assured
403–8 Workers covered by an occupational health and safety management system GRI quantitative indicators disclosure Assured
403–9 Work-related injuries Occupational health and safety,
GRI quantitative indicators disclosure
Not assured

There are no disclosures on the following:

  • contractor injury rates due to the lack of accounting for the number of hours worked;
  • types and causes of non-fatal injuries due to the lack of consolidated accounting.

The Company will consider developing an appropriate accounting system within the next three years.

Data on total registered injuries is shown using the Company’s accounting system based on Russian laws.

In addition, the following data for 2022 is disclosed in line with the GRI -driven methodology:

  • total number of registered injuries among employees (number of workplace injuries and minor injuries): 257;
  • occupational injury rate among employees per million hours worked: 2.21;
  • total number of registered workplace injuries among contractors’ employees engaged at the Company’s sites (number of workplace injuries and minor injuries): 68.
403–10 Work-related ill health Occupational health and safety,
GRI quantitative indicators disclosure
Assured

Types of occupational diseases and the number of fatalities caused by work-related ill health is not disclosed due to the confidential nature of this information and the lack of permission for its use by the government agencies responsible for maintaining and recording such information.

The information on work-related ill health among contractors is also not disclosed, as it is impossible to unambiguously determine whether the contractor’s ill health is directly caused by working at the Company’s facilities.

The information on occupational diseases is not disclosed due to the lack of consolidated records. The Company will consider developing an appropriate accounting system within the next three years.

Water consumption and wastewater discharge
3–3 Management of material topics Water,
Definition of material topics
Assured
303–1 Interactions with water as a shared resource Water,
GRI quantitative indicators disclosure
Assured Supplier relationship as regards impact on water resources is governed by the Company’s Supplier Code of Conduct; there may be consultations with customers at customer request.
303–2 Management of water discharge-related impacts Water Assured The wastewater quality standards of the Company are based on Order of the Ministry of Agriculture of Russia No. 552 On Approval of Water Quality Standards for Water Bodies of Fisheries Significance, Including Standards for Maximum Permissible Concentrations of Harmful Substances in the Waters of Water Bodies of Fisheries Significance dated 13 December 2016 and Decree of the Chief State Sanitary Doctor No. 2 On Approval of Sanitary Rules and Norms SanPiN 1.2.3685-21 “Hygienic Standards and Requirements for Safety and/or Harmlessness of the Living Environment for People” dated 28 January 2021.
303–3 Water withdrawal Water,
GRI quantitative indicators disclosure
Not assured The regions where the Company’s assets are located are areas of normal and high water availability. The volume of water withdrawal is recorded using instrumental controls and readings of certified gauges, as well as by indirect methods as may be approved by the relevant territorial office of the Federal Water Resources Agency.
303–4 Water discharge Water,
GRI quantitative indicators disclosure
Not assured

All water discharged by the Company is not freshwater (in GRI terminology).

In 2022, individual cases of exceeding permissible discharge limits were identified.

303–5 Water consumption Water Not assured Information on the impact that changes in water volumes of water reservoirs (storage basins) have on water bodies is not collected.
Industrial environmental safety of production facilities (including tailings dumps)
3–3 Management of material topics Tailings and waste,
Occupational health and safety,
Definition of material topics
Assured
306–3 (2016) Significant spills Assured In 2022, there were no significant spills.
Impact of transport on water bodies
3–3 Management of material topics Water,
Definition of material topics
Assured

The key principles in managing the environmental impact of the Company’s transport on water bodies are set out in the Environmental Policy.

No targets were set for the environmental impact of the Company’s transport on water bodies in 2022. Stakeholder engagement is mainly interactions with the government agencies and port infrastructure operators as regards compliance with transport operation requirements.

Responsible exploration and land reclamation
3–3 Management of material topics Soil protection and responsible mining,
Definition of material topics
Assured
Supply chain responsibility
3–3 Management of material topics Supply chain responsibility,
Definition of material topics
Assured
308–1 New suppliers that were screened using environmental criteria Assured In 2022, the existing supply chain due diligence management system applied only to suppliers, processors and transporters of metal-containing mineral feedstock (“mineral suppliers”). As part of the due diligence, eight existing mineral suppliers were assessed in 2022, including against environmental and social criteria. The number of new mineral suppliers to the Company in 2022 is zero. Following the exercise, all audited mineral suppliers met the environmental and social criteria set out in Nornickel’s Supplier Code of Conduct. No significant environmental and social risks have been identified. The Company plans to include other categories of suppliers in the due diligence exercise in 2023–2024.
308–2 Negative environmental impacts in the supply chain and actions taken Assured
414–1 New suppliers that were screened using social criteria Assured
414–2 Negative social impacts in the supply chain and actions taken Assured
Anti-corruption and business ethics
205–1 Operations assessed for risks related to corruption Internal Control and Risk Management,
Business Ethics and Anti-Corruption
Assured
205–2 Communication and training about anti-corruption policies and procedures Business Ethics and Anti-Corruption Assured

No training on anti-corruption practices was conducted for Board members in 2022. Training is scheduled for 2023.

No training on anti-corruption practices is provided to external stakeholders; when contracts are signed, counterparties are familiarised with the Anti-Corruption Policy.

205–3 Confirmed incidents of corruption and actions taken Business Ethics and Anti-Corruption Assured
Respect for human rights (including those of indigenous minorities)
401–3 Parental leave GRI quantitative indicators disclosure Assured The indicator is partially disclosed due to the lack of the accounting system; information is provided about employees on maternity leave and/or childcare leave and on those who returned to work after the leave ended. The Company will consider developing an appropriate accounting system within the next three years.
402–1 Minimum notice periods regarding operational changes HR management and social partnership Assured
405–1 Diversity of governance bodies and employees HR management and social partnership,
GRI quantitative indicators disclosure
Assured
405–2 Ratio of basic salary and remuneration of women to men Assured The indicator is not disclosed due to the lack of the accounting system. The Company will consider developing an appropriate accounting system within the next three years.
406–1 Incidents of discrimination and corrective actions taken Assured No discrimination incidents have been recorded.
407–1 Operations and suppliers in which the right to freedom of association and collective bargaining may be at risk Assured There are no such operations. The 2022 due diligence of suppliers covered observance of the right to the freedom of association and collective bargaining as part of checking compliance with the Company’s Supplier Code of Conduct.
408–1 Operations and suppliers at significant risk for incidents of child labour Assured There are no such operations and suppliersThe reporting year saw a due diligence of Polar Division and Kola MMC..
409–1 Operations and suppliers at significant risk for incidents of forced or compulsory labour Assured
411–1 Incidents of violations involving rights of indigenous peoples Development of local communities Assured
413–2 Operations with significant actual and potential negative impacts on local communities Air Assured The main operation (unit) that has a significant negative impact on local communities is Polar Division, whose assets are located in Norilsk. The key source of negative impact is sulphur dioxide emissions into the atmosphere.