The Company assesses risks and impacts
of human rights violations, monitors and controls observance of human rights based
on internationally recognised methodologies and guidelines, including:
Human Rights Impact Assessment Guidance and
Toolbox, Danish Institute for Human Rights (DIHR), 2020;
UN Guiding Principles on Business and Human
Rights (UNGPs), 2011.
Based on a survey and assessment carried
out in 2022–2023, the Company conducted an in‑depth study of current
threats, taking into account complaints and reports received through the Corporate
Trust Line and holding a series of meetings with employees across its regions
of operation. The corporate risk management system covers human rights risks.
Key human rights risks
Right
Related risks
Assessment of potential
impact on the Company’s goals
Employeeright to occupational
health and safety
Group fatality
Extremely high
Strained social and labour
relations
Medium
Requirements
for suppliers to respect human rights as part
of supply chain responsibility commitments
Failure to comply with
ESG requirements put forward by customers, industry standards,
associations and exchanges
High
Right of employeesand external stakeholders
to a healthy environment
Environmental damage caused
by emergencies
Extremely high
Rights of local and
indigenous communities
Risk of adverse impacts
on the rights of local and indigenous communities
Low
Human rights risks in the mineral supply
chain are identified through supplier due diligence as part
of the Group’s mineral supply chain Due Diligence Management System.
In 2024, mineral supplierThe Group’s mineral suppliers include
suppliers of mined minerals (primary processed material which has never been
previously refined) and suppliers providing minerals transportation, their
processing and loading/unloading services.due diligence identified no risks.
Improvements to the methodology
for identifying human rights risks
In 2024, Nornickel continued to improve
its methodology for identifying and assessing human rights risks. These efforts
included processing the results of the Let Everyone Be Heard engagement
survey, analysing specific metrics featured in the Sustainability Report, and
studying queries submitted through the Corporate Trust Line channels.
In the reporting year, the risk assessment process based on incoming
queries was automated through the initial classification of queries upon
receipt, including the assignment of event categories and subcategories.
Therefore, integrated human rights risk reflects both
the level of risk associated with each human right and business unit
as well as overall positive or negative trends, which can be used
for ongoing monitoring of the due diligence system effectiveness.
X
Number of subcategories
Category
X
Number of subcategories
20
Remuneration
9
Social benefits
3
Violation of privacy
17
Violations related
to the management of labour processes
12
Violations of the work
and rest schedule
4
Environmental pollution
6
Workplace health risks
5
Workplace amenities
18
H&S requirements, personal
protective equipment (PPE), production equipment