Corporate responsible supply chain documents

In 2021, the Board of Directors approved the corporate documents describing the key principles of responsible supply chain management:

• PJSC MMC Norilsk Nickel’s Responsible Sourcing Policy (the “Policy”) setting out Nornickel’s approach to environmental, social and corporate governance issues throughout its supply chain;
• PJSC MMC Norilsk Nickel’s Supplier Code of Conduct (the “Code”) requiring that the Company’s suppliers observe Nornickel’s sustainability goals.

The Policy seeks to ensure that mineral suppliers and suppliers of goods, works and services meet the Company’s sustainability criteria. It sets out Nornickel’s responsible supply chain management principles applicable to both the Group itself and its counterparties. In case if supplier fails to meet the Policy requirements in full, Nornickel identifies supply chain risksThe risks are further detailed in Identification and Assessment of Mineral Supply Chain Risks. and may reconsider its relationship with such supplier if, following corrective actions, the risk is not mitigated.

The Code describes requirements for suppliers in terms of alignment of their activities’ with the Company’s sustainability principles. In managing its responsible supply chain, Nornickel assesses the maturity of its suppliers’ sustainability practices for compliance with the Code.

The Policy and the Code were communicated to stakeholders and published in Russian and English on the Company’s website.