Grievance policy GRI 2–16, 2–25, 2–26, 207–2

Corporate Trust Line

In 2010, Nornickel launched its Corporate Trust Line (CTL) as a primary tool to manage complains and queries. Available to a wide range of stakeholders, the line helps to quickly respond to their concerns relating to the protection of assets and corporate interests, prevention of abuse, theft and other violations.

The CTL is accountable to the Internal Control Department and operates in line with the Company’s by-laws. Responsible for the service are its operator and head along with the Director of the Internal Control Department.

Report statistics (broken down by Group company) are submitted to units in charge on a quarterly basis. CTL performance is reviewed by the Board’s Audit Committee. CTL is subject to assessment by the Vice President for Internal Control and Risk Management, the Board’s Audit Committee and employees taking part in an engagement survey named “Let Everyone Be Heard. What Do You Think?”.

Persons in charge of the CTL have individual KPIs such as a timely and proper processing of incoming communications and reporting on CTL performance to interested users.

Key principles

CTL is guided by the following principles designed to prevent retaliation against or pressure on whistle-blowers:

• guaranteed confidentiality for whistle-blowers;
• independent consideration of reports;
• timely and unbiased consideration of all incoming reports irrespective of the position and employment period of the person mentioned therein.

Any stakeholder may contact the CTL reporting both potential corruption and a wider range of matters related to violations of procedures and by-laws, including with respect to human rights, environment, labour relations, etc.

The procedure provides for the operator to fully handle the report (from registration in the information system to review by a dedicated function and assessment of the response by the Head of the Corporate Trust Line) within 21 business days. The exceptions are reports that require immediate action or additional investigation. If found substantiated, the report triggers a set of control measures, and if a violation is confirmed, steps are taken to correct the situation, eliminate any negative consequences, and inform stakeholders

CTL procedures provide for sending a response explaining the results of the review to the applicant only upon their request. In late 2022, the Company prepared a draft update of the Corporate Trust Line Procedure. Among other things, the update provides for informing applicants about the registration of their complaints or queries and the review outcomes upon their request and availability of contact details.

All employees are kept thoroughly informed of this service through information displays and stands, payslips, corporate calendars, brochures, etc.

In 2022, the Corporate Trust Line received 1,463 reports, with 589 accepted for review, 556 resolved and released from control (out of which 159 were confirmed and 397 not confirmed). Most reports had to do with labour relations and commercial and contractual activities. As at 1 January 2022 and 31 December 2022, 70 and 103 reports were at the processing stage, respectively.

Grievance Mechanism

In 2022, the Company introduced additional corporate procedures to improve the Grievance Mechanism and its accessibility to external stakeholders (local and indigenous minority communities, suppliers or contractors, etc.). Company employees and other stakeholders can continue using the Corporate Trust Line and other channels for grievance purposes (telephone numbers, an online form on the Company’s website or an e-mail). The Mechanism does not replace any existing statutory or corporate rights protection mechanisms.

The new Mechanism provides for pre-trial dispute resolution based on dialogue and mediation. It is not mandatory and does not limit the right to statutory remedies, such as legal action.

The Grievance Mechanism serves the following purposes:

• receiving, reviewing and resolving complaints about adverse impacts either caused or contributed by, or directly linked to, our own activities and business relationships;
• early prevention, identification and elimination of social and human rights risks, in addition to supporting continuous improvements in the Company’s operations, to strengthen the relationships between the Company and its stakeholders in the long run.

The Mechanism is not intended to address any pre-existing social, economic, or cultural issues affecting local communities across the Company’s operations. The Company continues to resolve them using other mechanisms and social programmes.

Complaints are filed through CTL channels, community liaison offices, and Company executives. A complaint may be submitted by the initiator or with the help of company representatives and independent experts in case of any difficulties.

The standard review period is 21 business days when filed through the Corporate Trust Line and 30 calendar days for other channels. If more time is needed for review and resolution, the initiator is notified to this effect within 30 days.

Initial assessment of the information received from the applicant 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 redirected to government authorities. This means that the grievance mechanism has three levels such as internal, independent (expert) and government:

• if the review identifies signs of non-compliance which require the complaint to be referred to government authorities, or violations of applicant rights requiring referral to an independent expert group for further consideration, the complaint is redirected as appropriate;
• 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 Russian business units.

To monitor the performance of the Mechanism, we collect feedback from complaint initiators and assess the level of 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 2022, we held discussions with stakeholders on options for improving the corporate Grievance Mechanism. Having assessed the human rights impact, external experts recommended that the Mechanism be updated and stakeholders provided with an effective access to an independent expert review to obtain a full, credible, and objective third-party (independent) decision. By developing this grievance mechanism, the Company becomes one step closer to improving the human rights due diligence system in 2023