Identification and assessment of human rights risks and impacts
CHRB B.1.3, IRMA 1.3.2.1, IRMA 3.3.1.1
In 2022, Nornickel initiated and completed its first ever preliminary assessment of human rights impact. For the purposes of the assessment, the Company used the methodology of the Danish Institute for Human RightsDanish Institute for Human Rights. (as recommended by IRMA), which was adapted to the operating activities of Nornickel. Note that this methodology was developed as a general model for application. In line with the IRMA recommendations, assessments of impacts produced by individual production assets in large-scale mining projects may require a scale-up of the methodology subject to the company’s size and severity of human rights risks and implications.
The assessment was carried out by the business units of Nornickel’s Head Office (Moscow), Polar Division (Norilsk), Kola MMC (Murmansk), and GRK Bystrinskoye (Trans-Baikal Territory).
Stages and elements of human rights impact assessment
Stage 1. Policy assessment
Stage 2. Risk assessment
Stage 3. Impact assessment at the level of production units
Detailed review of the architecture of Nornickel's sustainability policies and correlation between them, including analysis of compliance with the UN Guiding Principles on Business and Human Rights (UNGPs);
preliminary risk assessment;
analysis of legal and political landscapes in terms of human rights in the key markets;
analysis of gaps in the architecture of Nornickel's sustainability policies.
In-depth analysis of specific human rights risks and relevant mitigation/prevention measures;
preparations for the human rights due diligence procedure.
Assessment of human rights impacts at the level of divisions / production units, and analysis of relevant risks and tools used to prevent violations of human rights;
development of detailed mitigation, monitoring, control, prevention and remediation recommendations for divisions / production units;
development of recommendations on embedding human rights risk assessments into the corporate risk management framework based on the status-quo analysis at the level of divisions / production units.
CHRB B.2.1, B.2.2, IRMA 1.3.3.3
Based on analysis of submitted documents and more than 100 interviews with the Company’s employees and stakeholders, we identified key risks and impacts by the type of relevant human rights.
Nornickel’s exposure to human rights risks in Russia is limited. The key focus areas are occupational health and safety and environmental impact. Risks related to local communities and safety are limited in the majority of cases.
Material human rights risks
Right
Risks
Impact assessment
Risk management measures
The Company’s by-laws
Employee right to safety, including occupational health and safety
Group fatality
Extremely high
Enhance methodological support for health and safety functions
Develop a system for assessing and managing production risks
Ensure continuous and regular controls over compliance with the health and safety requirements
Pursue continuous training
Risk Management Policy
Risk Management Regulations
Corporate Risk Management Framework Regulations
Human Rights Policy
Stakeholder Engagement Policy
Occupational Health and Safety Policy
Regulations on the OHS Safety Management System
Regulations on the Health and Safety Management System
Responsible Sourcing Policy
Supplier Code of Conduct
Know Your Supplier questionnaire, including sustainability matters
Standard supplier contract form
Environmental Policy
Environmental Impact Assessment Policy
Climate Change Policy
Strained social and labour relations
Medium
Conduct regular social monitoring
Maintain dialogue with trade unions
Monitor the activities of social partnership participants
Develop and implement corporate social programmes to encourage long-term employment
Provide information and communication support in case of emergencies
Develop and implement the regional social policy
Develop and implement programmes to improve living standards in the regions where the Company operates
Collect pre-emptive data on potential social tensions in the labour force
Requirements for suppliers to respect human rights as part of supply chain responsibility commitments
Failure to comply with the requirements put forward by leading ESG standards and associations
High
Conduct due diligence of mineral feedstock suppliersHereinafter, mineral raw material suppliers means suppliers, transporters, and processors of nickel-, cobalt-, and copper-containing minerals mineral raw materials.
Rights of employees and external stakeholders to a healthy environment
Environmental damage caused by emergencies
Extremely high
Develop a comprehensive system of regulatory and procedural guidelines on environmental protection
Deliver on environmental initiatives
Implement the Environmental and Climate Change Strategy
Environmental and Climate Change Strategy
Indigenous Peoples’ Rights Policy
Community Engagement Policy
Position Statement on Biodiversity
Position Statement on Water Stewardship
Rights of local and indigenous communities
Risk of adverse impacts on the rights of local and indigenous communities
Low
Monitor impacts within and beyond the sanitary protection zones of relevant production facilities
Hold regular discussions with stakeholders on legacy and outdated production facilities in the run-up to the implementation of growth plans and new projects
Run programmes to support traditional trades, enable processing activities, and enhance housing, social and medical infrastructure in relevant settlements
As a way to minimise its risks, the Company develops action plans to manage relevant risks and monitors performance under these plans on a regular basis. Based on the preliminary assessment, Nornickel’s human rights impact on key stakeholders and the Company’s exposure to human rights risks was scored as “Low”.
The Company will continue improving the procedure for ongoing screening of human rights risks and impacts. In 2023, it plans to finalise the human rights impact assessment by considering the stakeholder opinions.