In conducting its core operations and building business relationships with stakeholders, Nornickel adheres to the principles of honest and ethical business conduct and maintains a zero‑tolerance approach to all forms and manifestations of corruption at every level of the organisation.
Nornickel’s corporate codes, policies, and regulations define the key principles and focus areas of the Company’s anti‑corruption efforts, govern the management of corruption risks, and set standards of conduct for employees, suppliers, contractors, customers, and other stakeholders.
The anti‑corruption compliance team at Nornickel’s Head Office provides advisory and methodological support on anti‑corruption matters, develops procedures and mechanisms for managing corruption risks, and, within its remit, designs approaches to building corporate culture, promoting corporate values, and upholding ethical conduct. Individual KPIs are set annually for each member of the compliance team.
Reporting corruption
Any stakeholder may report suspected corruption anonymously via several available communication channels (for more information, please see the Grievance Policysection).
Nornickel guarantees protection for employees who report suspected corruption from retaliation, discrimination, or any form of pressure, including dismissal, reduced bonuses, or demotion.
The Company has an anti‑corruption compliance system in place to promote zero tolerance for violations of business ethics, bribery, and corruption. A range of internal initiatives is carried out on a regular basis to enhance the system’s effectiveness, including the review and update of the Company’s anti‑corruption procedural documents.
Measures aimed at developing and improving the anti‑corruption compliance system in 2024
A mechanism for informing counterparties of the Company’s anti‑corruption requirements and principlesThe information materials are fully automated and available to every counterparty with whom an agreement is signed, via a link included in the anti‑corruption clause.was adapted and launched
A training campaign on mitigating corruption risks when engaging with counterparties was delivered to Groupemployeesresponsible for implementing anti‑corruption compliance procedures
Measures were taken to assess the effectiveness of controls implemented to mitigate corruption risks at the Group
A framework for tracking inquiries from regulatory and supervisory authorities regarding anti‑corruption compliance across the Group was established
The development phase for automating the conflict of interest management module was launchedScheduled for completion in 2025–2026.
An employeequestionnaire survey was conducted to evaluate the state of corruption and the effectiveness of anti‑corruption initiatives at the Company’s branches and representative office
Measures were taken to monitor and assess compliance with the legal requirements of the Russian Federation regarding the employment of and contracting with former government officials
For more than 10 years, Nornickel has been a signatory to the Anti‑Corruption Charter of Russian Business, and, as part of this commitment, biennially presents a public statement affirming its adherence to anti‑corruption standards.
In 2024, MMC Norilsk Nickel confirmed its leadership in the Anti‑Corruption Ranking of Russian Business and received the highestAAA+++rating as a company with the most robust anti‑corruption safeguards in place.
In addition, the Kola site’s metals and mining enterprise, which participated in the ranking for the first time in 2024, demonstrated strong anti‑corruption performance with an AA+rating and is focused on incorporating expert recommendations for improving its existing anti‑corruption measures.
Statistics on incidents of corruption in 2024
5
total number of confirmed incidents of corruption
number of confirmed incidents in whichemployeeswere disciplined for corruption (four of them dismissed)
0
confirmed incidents when contracts with business partners were terminated or not renewed due to violations related to corruption in 2024
RUB3.1mln
total amount of corruption‑related fines imposed on the Company or its employees, paid or payable (i.e. acknowledged and not contested by the penalised party) in 2024
2
public legal cases regarding corruption brought against the Company or its employeesor closed during the reporting period
Throughout the reporting period, joint efforts of Nornickel’s Security Service and law enforcement agencies resulted in initiating:
four criminal cases against seven Nornickel Groupemployeeson charges of commercial bribery
one criminal case against a Nornickel Groupemployeeon charges of petty bribery.
Court verdicts were issued in two of the cases under Article 204 of the Criminal Code of the Russian Federation (“Commercial Bribery”), with five employees found guilty of the offences they were charged with.
Employee communication and training on anti‑corruption
GRI 205‑2
GRI 14.22.3
Communication and training on anti‑corruption are a cornerstone of the Company’s anti‑corruption compliance system. The Company continuously works to strengthen this component, employing a wide range of tools to embed the principles of integrity in everyday actions of all Groupemployees. Accordingly, anti‑corruption communication and training initiatives for employeesare carried out in line with the approved annual plan. Specifically:
Internal communication channels are used to facilitate regular broadcasts and publications, including information on:
anti‑corruption practices
amendments to internal documents
achievements and upcoming events related to anti‑corruption compliance
Concise memos summarising regulatory documents are developed
Training programmes are designed and updated to ensure allemployees, across all levels, are trained
Communication and training events at the CompanyThe listed online courses are available at any time on the Nornickel Academy corporate platform.
Signing an addendum to the employment contract outliningemployees’ anti‑corruption obligations
All employees
Anti‑Corruption remote learning course
HR employees
Course on anti‑corruption compliance for HR services
Members of governance bodies
Anti‑Corruption for Managers remote learning course
In addition, in 2024, an educational campaign was held to minimise corruption risks when engaging with counterparties, targeting Group employees responsible for implementing anti‑corruption procedures as well as legal teams across the Nornickel Group.
Number of employeesthat the Group’s anti‑corruption policies and procedures were communicated to (C) and that received training (T) on them in 2022–2024, by region of operationThe decrease in the number of employees that have received training on anti-corruption policies and procedures was due to organisational changes: the remote learning course was updated at the end of 2022 and assigned to all Company employees to be completed by the end of Q1 2023. Accordingly, there was no need for training on this scale in 2024, and the course was only assigned to newly hired employees.
UNCTAD D.2.2
Indicators
Share of employeesthat the Group’s anti‑corruption policies and procedures were communicated to
Share of employeesthat received training on anti‑corruption policies and procedures
Norilsk Industrial District
Krasnoyarsk Territory (excluding the Norilsk Industrial District)
Murmansk Region
Moscow and other Russian regions
Trans‑Baikal Territory
Total
Number of employeesthat the Group’s anti‑corruption policies and procedures were communicated to (C) and that received training (T) on them in 2022–2024, by category
Indicators
Share of employeesthat the Group’s anti‑corruption policies and procedures were communicated to
Share of employeesthat received training on anti‑corruption policies and procedures
Managers
White‑collaremployees
Blue‑collaremployees
Total
Corruption risk management at Nornickel
GRI 205‑1
GRI 14.22.2
Corruption risks are included in Nornickel’s corporate risk register and are managed on a regular basis through processes such as identification, assessment, control, and monitoring, along with timely response and corrective actions where necessary.
Corruption risks (CRs)
Results of anti‑corruption monitoring in 2024
An initiative was put in place to oversee thepracticalenforcement of anti‑corruption procedures across the Nornickel Group
100%
of the Group’s Russian businessunitsadopted the key anti‑corruption regulations and procedures as at the beginning of 2024 (+9 p. p. y‑o‑y)
11.4%
of the Group’s Russian businessunitsreceived recommendations for approving and updating procedural documents, eliminating deficiencies, and enhancing controls in anti‑corruption procedures
Managing conflicts of interest
Nornickel’s key principles for managing conflicts of interest
Nornickel’s key principles for managing conflicts of interest
Regulatory compliance
Impartiality
Objectivity
Confidentiality
Nornickel places particular emphasis on the timely identification and prevention of conflicts of interest.
Regulations on the Prevention and Management of Conflicts of Interest at MMC Norilsk Nickel
requireemployeesto disclose any conflicts of interest that may arise in performing their job duties if personal interests are involved
Standard declaration form approved at MMC Norilsk Nickel
completed by candidates applying for vacant positions at the Company and by individuals entering into independent contractor agreements
The Norilsk Nickel Group set up standing conflict of interest commissions to enhance the effectiveness of managing conflicts of interest and improve corporate culture.
In 2024, Nornickel developed and published an interactive memo on conflict of interest management, available on its corporate portal.
Measures to ensure compliance with antitrust laws
Nornickel maintains an antitrust compliance system aligned with Federal Law No. 135‑FZ, On Protection of Competition, dated 26 July 2006.
Corporate Security identifies unfair competition risks as part of counterparty due diligence.
In 2024, no significant violations of antitrust legislation involving Nornickel were recorded.
Anti‑money laundering, combating the financing of terrorism and proliferation of weapons of mass destruction
