Standards compliance index
| Report section | OECD Guidance | CCCMC Guidelines | IRMAChapter 3.4: Mining and CAHRA of the Standard for Responsible Mining of the Initiative for Responsible Mining Assurance. | Page | Comments |
|---|---|---|---|---|---|
| About Nornickel Group | – | – | – | About Nornickel Group | |
| About the Report | Describe the methods for disclosing supplier information to supply chain participants Report annually on supply chain due diligence | 7.5. Report on process and results of supply chain risk management | 3.4.6.2. Annual public reports | About Nornickel Group | All Extractive Industries Transparency Initiative (EITI) required data disclosed in the Company’s annual reports |
| Approach to managing a responsible supply chain | – | – | – | Approach to managing a responsible supply chain | Nornickel developed and deployed its own risk assessment system containing the steps recommended by the OECD Guidance and the IRMA |
| Corporate responsible supply chain documents | Describe the supply chain management policy | 7.1.1. Adopt and communicate a company responsible sourcing policy to suppliers and the public | – | Corporate responsible supply chain documents | |
| Management of the responsible supply chain for minerals, goods, works and services | – | – | – | Management of the responsible supply chain for mineral raw materials, goods, works and services | |
| Interaction with suppliers | Provide information on capability training for affected stakeholders | 7.1.4. A supply chain policy to be incorporated into contracts and/or agreements with suppliers | – | Management of the responsible supply chain for mineral raw materials, goods, works and services | |
| Procurement automation | – | – | – | Management of the responsible supply chain for mineral raw materials, goods, works and services | |
| Supply agreements to include the responsible supply chain requirements | – | – | – | Interaction with suppliers | |
| Supplier risk identification | – | – | – | Interaction with suppliers | |
| Training in building a responsible supply chain | Provide information on capability training for affected stakeholders | – | – | Interaction with suppliers | |
| Corporate Trust Line | – | 7.1.5. Establish a grievance mechanism | 3.4.2.2. Company's approach to human rights, maintaining documentation on minerals, assigning responsible parties, managing the grievance mechanism | Interaction with suppliers | |
| Summary of responsible supply chain results in 2023 | – | – | – | Interaction with suppliers | |
| Section 1: Management of the responsible mineral supply chain | – | – | – | Summary of responsible supply chain results in 2023 | |
| 1.1 Mineral supply chain Due Diligence Management System | – | – | – | Summary of responsible supply chain results in 2023 | |
| Management framework and responsible parties | Describe the supply chain due diligence management framework | 7.1.2. Structure internal management to support supply chain due diligence | 3.4.3.2. Assessments to follow a recognised risk assessment methodology and to be carried out by competent professionals 3.4.2.2. Company approach to human rights, maintaining documentation on minerals, assigning responsible parties, managing the grievance mechanism 3.4.3.3. Assessments to be based on credible evidence 3.4.6.1. Reporting to the senior management | Mineral supply chain Due Diligence Management System | Nornickel has its Human Rights Policy available on the Company’s website |
| Mineral supply controls and transparency | Describe the control system over the supply chain and the record‑keeping system | 7.1.3. Establish a system of controls and transparency over the mineral supply chain | 3.4.3.3. Assessments to be based on credible evidence | Mineral supply chain Due Diligence Management System | |
| Identification and assessment of mineral supply chain risks | – | – | – | Mineral supply chain Due Diligence Management System | |
| Identification of risk indicators in the mineral supply chain | Describe the risk assessment methodology | 7.2.1. Engage with suppliers to identify risks and confirm basic source information of materials. 7.2.2. Undertake enhanced due diligence to identify risks in the supply chain. 7.2.3. Assess risks of adverse impacts under the CCCMC Guidelines. 7.3.4. Undertake additional risk assessments for risks requiring mitigation, or after a change of circumstances | 3.4.1.1. Conduct analysis to determine whether an area is on the CAHRA list. 3.4.2.1. Respect for human rights. 3.4.3.1. Assess the risks, their roots and whether they may lead to infringement of human rights. 3.4.3.4. Risk assessments to be updated regularly. | Identification and assessment of mineral supply chain risks | Nornickel does not operate in CAHRA, but performs enhanced suppliers due diligence if it identifies risk indicators associated with CAHRA |
| Assessment of mineral supply chain risks | Describe the risk assessment methodology | – | 3.4.1.2. Undertake the additional due diligence steps if an area is on the CAHRA list 3.4.3.1. Assess the risks, their roots and whether they may lead to infringement of human rights | Identification and assessment of mineral supply chain risks | |
| Risk assessment frequency | – | 7.3.1. Report findings of the supply chain risk assessment to the designated senior management of the company | 3.4.3.4. Risk assessments to be updated regularly 3.4.6.1. Reporting to senior management | Identification and assessment of mineral supply chain risks | |
| Suppliers due diligence in 2023 | Publish the results of risk assessments | – | 3.4.4.3. Adhere to the IRMA corporate social responsibility requirements if risks to human rights are identified | Management plan for mineral supply chain risks | No human rights risks confirmed in the reporting period |
| 1.3 Management plan for mineral supply chain risks | – | – | – | Independent audit of the mineral supply chain | |
| Action plan following risk confirmation and risk management strategy | Describe the steps taken to manage risks. Describe the risk management strategy. Describe the efforts made to monitor and track performance of risk management | 7.3.2. Devise a risk management plan and choose a strategy. 7.3.3. Introduce a risk management plan. | 3.4.4.1. Develop and implement a risk management plan 3.4.4.2. Collaborate with relevant stakeholders to develop risk mitigants. 3.4.5.1. Monitor the effectiveness of the risk management plan. 3.4.5.2. Cease operations, mitigate the impact, and monitor due diligence activities in case of human rights violations | Independent audit of the mineral supply chain | In the reporting period the Company had no interaction with representatives of local communities as part of risk management plans development due to the absence of confirmed risks related to mineral suppliers |
| 1.4 Independent audit of the mineral supply chain | Independent third‑party audits | 7.4. Carry out independent third‑party audit at identified points in the supply chain | – | Management plan for mineral supply chain risks | |
| Section 2: Management of the responsible supply chain for goods, works and services | – | – | – | Assessment of the suppliers’ sustainability practices | |
| 2.1. Assessment of the suppliers' sustainability practices | – | – | – | Assessment of the suppliers’ sustainability practices | |
| 2.2. Assessment of the suppliers’ sustainability practices: results | – | – | – | Assessment of the suppliers’ sustainability practices: results |