Indicators under the Initiative for Responsible Mining Assurance (IRMA). Critical requirements for human rights
| Criterion | Section/comment |
|---|---|
| Principle 1: Business integrity | |
| Chapter 1.2: Community and stakeholder engagement requirements | |
| 1.2.2.2 | section “Stakeholder engagement” |
| Chapter 1.3: Human rights due diligence requirements | |
| 1.3.1.1 | section “Commitment to human rights” |
| 1.3.1.2 | section “Commitment to human rights” |
| 1.3.2.1 | section “Identification and assessment of human rights risks and impacts” |
| 1.3.3.3 | section “Identification and assessment of human rights risks and impacts” The Company liaisons with representatives of regulatory authorities whose engagement is required by the Russian laws (for instance, participation in court cases and accident and fatality investigation) |
| Chapter 1.4: Complaints and grievance mechanism and access to remedy | |
| 1.4.1.1 | section “Stakeholder engagement”, subsection “Grievance policy” |
| Principle 2: Planning and managing for positive legacies | |
| Chapter 2.1: Environmental and social impact assessment and management | |
| 2.1.3.1 | Divisions assess their environmental impact in line with national laws, including direct impact and impact in case of certain accidents, and have in place environmental action plans. Social impact assessment (including potential impact on communities and employees) is expected to be introduced in the future |
| Chapter 2.2: Free, Prior and Informed Consent (FPIC) requirements | |
| 2.2.2.2 | section “Rights of local and indigenous communities”, subsection “Free, Prior and Informed Consent” |
| Chapter 2.4: Resettlement | |
| 2.4.7.1 | The relocation of Tukhard’s residents will be performed fully in line with the FPIC procedure and in accordance with a relevant agreement signed with the Council of Representatives of the settlement. In autumn 2023, the Company plans to sign an agreement to reflect all the Plans referred to by the IRMA Guidance |
| Principle 3: Social Responsibility | |
| Chapter 3.1: Fair labour and terms of work | |
| 3.1.2.1 | section “Employee right to freedom of association and ollective bargaining” |
| 3.1.3.3 | In line with MMC Norilsk Nickel’s Human Rights Policy, the Company ensures that its employees are protected at their workplaces against any form of physical, verbal or psychological harassment, aggression or threats from their colleagues and management. Women’s rights: section “Labour rights”, subsection “Employment, headcount by location and gender” |
| 3.1.5.1 | section “Stakeholder engagement”, subsection “Grievance policy” |
| 3.1.7.2 | The Company has a ban on child labour |
| 3.1.7.3 | The Company does not hire people aged under 18 |
| 3.1.8.1 | The Company has a ban on forced labour. The Company does not engage in human trafficking |
| Chapter 3.2: Occupational health and safety requirements | |
| 3.2.4.1. (critical requirement – a and b only) | section “Basic employee rights”, subsection “Occupational health” section “Employee right to safety, including occupational health and safety” |
| Chapter 3.3: Community health and safety | |
| 3.3.1.1 | In 2022, the Company conducted a preliminary assessment of human rights impact, which included community health and safety (section “Identification and assessment of human rights risks and impacts”) |
| Chapter 3.4: Mining and conflict-affected or high-risk area requirements | |
| 3.4.2.1 | Nornickel does not operate in conflict-affected or high-risk areas and conducts a thorough analysis of its supply chain in this regard |
| Chapter 3.5: Security arrangements (requirements) | |
| 3.5.1.2 | Nornickel has not adopted a separate policy on security arrangements, including the use of force and firearms by security personnel. The Company complies with relevant Russian laws, which are aligned with the IRMA requirements |