Business ethics and anti-corruption
How has Nornickel’s approach to business ethics management and anti‑corruption practices evolved over the past 20 years?
The Company recognises the importance of transparent business practices in sustaining trust with investors, partners, and other stakeholders. A system for transparent procurement and counterparty KYC procedures is in place. The Corporate Trust Line has been operational since 2010, with the Business Ethics Code approved back in 2012.
In line with Russian and international anti‑corruption laws and best practices, the Department of Equity Capital, Compliance, and Prevention of Unauthorised Use of Insider Information was set up at the Head Office in 2013 to reinforce compliance risk management. The anti‑corruption compliance framework was embedded into the Group’s organisational and management structure in accordance with internationally acknowledged practices, including those related to corporate governance and internal controls.
Beyond statutory requirements, Nornickel embraces voluntary commitments exemplified by joining the Anti‑Corruption Charter of the Russian Business in 2014, which entailed the adoption of a wide variety of dedicated anti‑corruption programmes and practices.
In 2022, Nornickel enhanced its anti‑corruption efforts by establishing a standalone business unit tasked with orchestrating a holistic approach to anti‑corruption compliance across the Group.
During the year, several key initiatives advanced the development of the anti‑corruption compliance framework:
- the fundamental elements, principles, and development strategies of the Company’s anti‑corruption compliance framework defined;
- internal regulations and guidelines drafted;
- an approach to adopting internal anti‑corruption regulations and control mechanisms established across the Group;
- a uniform approach to educating and informing employees about anti‑corruption measures established;
- anti‑corruption compliance controls integrated into the Company’s business processes;
- an initial risk assessment of business processes performed, resulting in a consistent methodology for assessing corruption risks throughout the Group.
The maturation of the compliance framework has made a significant impact on Nornickel’s corporate culture. The most notable shift recently has been the marked enhancement of our business ethics culture.
Nornickel sets the bar high for its employees and partners with respect to responsible business conduct, and has zero tolerance to any form of corruption at all levels.
Nornickel’s anti‑corruption approach
Nornickel’s anti‑corruption efforts are underpinned by principles that delineate its conduct model, obligations, and core values.
Nornickel is committed to enforcing Russian laws, notably Federal Law No. 273‑FZ On Combating Corruption dated 25 December 2008, applicable international regulations such as the UN Convention against Corruption, Criminal Law Convention on Corruption, and the Company’s by‑laws. An anti‑corruption compliance framework is in place to ensure adherence to Russian statutory requirements and proactive corruption risk management.
The Corporate Relations Department’s anti‑corruption compliance experts at Nornickel’s Head Office are in charge of overseeing and guiding the Group’s anti‑corruption initiatives, with individual KPIs set for them annually.
The Company maintains a strict no‑sanctions policy for employees who report corruption (this includes protection from dismissal, demotion, or bonus forfeiture), and it actively supports employees who provide verified corruption information.
GRI 2‑9, 2‑12, 2‑13
Key anti‑corruption regulations
Business Ethics Code
Code of Conduct and Ethics for Members of the Board of Directors
Supplier Code of Conduct
Regulations on the Prevention and Management of Conflicts of Interest
Regulations on the Conflict of Interest Commission at the Company’s Head Office
Regulations on Business Gifts
Procedure for Anti‑Corruption Due Diligence of By‑Laws Adopted by the Head Office
Standard anti‑corruption agreement (appendix to the employment contract)
Standard anti‑corruption clause included in counterparty agreements
Nornickel’s Anti‑Corruption Policy is the Company’s fundamental anti‑corruption document. It outlines the main objectives, principles, and focus areas of anti‑corruption efforts, and ensures the prevention, identification, and elimination of causes that give rise to corruption offences. The policy applies to the Company’s employees and third parties. The respective anti‑corruption responsibilities are stipulated in agreements made with contractors or are expressly provided for by the applicable laws.
Nornickel Group’s Russian business units adopt their own anti‑corruption regulations and procedures in line with the Company’s anti‑corruption policy. Nornickel also takes steps to ensure that its foreign business units uphold the core principles and anti‑corruption requirements.
Nornickel’s Business Ethics Code delineates the standards for business conduct and ethical behaviour expected of its employees and stakeholders, encompassing safety and security, anti‑corruption, fair competition practices, human rights, and government relations. There are multiple confidential and anonymous channels for reporting suspected breaches of the Code by Nornickel employees and stakeholders.
The Code applies to the employees of all levels performing their job duties.
Results of anti‑corruption efforts in 2023GRI 205‑3/ SASB EM‑MM‑510a.1
Focus areas
Prevention and management of conflicts of interest
Anti‑corruption due diligence of by‑laws
Counterparty due diligence to confirm their reliability, solvency and financial stability
Procurement procedure control
Government cooperation, promotion of justice and the rule of law
Business gifts and hospitality expenses
Sponsorship and charity
Staff training in preventing and fighting corruption
Raising stakeholder awareness about the Company’s anti‑corruption policy
Adopting standards and codes of conduct
Internal control of business operations and accounting
Participation in collective initiatives
Key results of anti‑corruption efforts
corruption practices revealed in 2023
confirmed cases of corruption‑related employee dismissal / penalties or non‑extension or termination of contracts with business partners in 2023
corruption‑related lawsuits against the Company or its employees initiated/completed in the reporting period
Key actions taken in 2023 to reinforce the anti‑corruption compliance framework include:
Endorsing a harmonised approach to counterparty corruption risk assessment
Delivering training sessions on managing conflicts of interest
Administering an employee survey to gauge the effectiveness of the Company’s anti‑corruption initiatives
Revising the Company’s anti‑corruption regulatory and procedural guidelines
Moreover, as a signatory to the Anti‑Corruption Charter of Russian Business, Nornickel biennially presents a public statement affirming its adherence to anti‑corruption standards. Our anti‑corruption initiatives are regularly covered in corporate press releases.
In 2023, for the third consecutive time, Nornickel featured in the Russian Business Anti‑Corruption Rating. Based on the findings of a thorough independent assessment, the Russian Union of Industrialists and Entrepreneurs awarded the Company the highest AAA+++ rating, attesting to Nornickel’s exceptional anti‑corruption efforts.
in the Anti‑Corruption Rating
Anti‑corruption awareness and training
GRI 205‑2
Nornickel is committed to employee training, and ensuring active participation of employees in anti‑corruption programmes via corporate communication platforms. These channels disseminate key information about anti‑corruption practices and amendments to by‑laws. On top of that, the Company discloses information about anti‑corruption achievements and forthcoming compliance events, while also providing concise guidance on regulatory documents.
In 2023, we drafted communication procedures to inform employees on anti‑corruption measures implemented by the Company, including the way, form, and frequency of educational and awareness raising events.
The Company designs and updates training programmes, regularly delivering them at all levels of the corporate hierarchy. Training content is tailored to specific roles and responsibilities.
All new hires receive an induction briefing in this area and are introduced to Nornickel’s Anti‑Corruption Policy. On top of that, newcomers affirm their commitment to anti‑corruption principles by signing an addendum to their employment contracts.
All Nornickel employees are required to complete an online anti‑corruption training course. HR personnel undergo a dedicated course on compliance with anti‑corruption laws for our HR function, while members of the Board of Directors, Management Board, and top management participate in a tailored anti‑corruption training course for leaders. These online courses are hosted on the Nornickel Academy corporate platform and are available for users at any convenience. Apart from that, in 2023 we organised an educational campaign on managing conflicts of interest for employees responsible for implementing anti‑corruption procedures and legal team members across the Group.
Corruption risk management
GRI 205‑1
Nornickel takes annual measures to identify and assess corruption risks, integrating their management into its corporate risk framework. Business processes are subject to regular controls and monitoring to eliminate corruption risks. When significant risk areas are reassessed, Nornickel updates its corruption risk map and develops additional corrective actions. The Company recognises the risks of violating anti‑corruption laws in its relations with business partners, employees, government officials, as well as in other sensitive areas, including procurement, business gifts and hospitality expenses, charity projects, recruitment and hiring processes.
Nornickel is aware that compliance risks may arise both within the organisation and through interactions with counterparties. The Company’s Corporate Security Unit performs a contractor due diligence review to identify involvement in any corruption incidents, inclusion in the register of fraudulent suppliers and pending criminal or administrative proceedings. In case of negative findings, the Corporate Relations Department assesses the risk of relations with the contractor in question and recommends mitigants if applicable. Recommendations have been put in place to spot potential corruption in procurement and inform the Corporate Security Unit for risk assessment and internal investigation. In 2023, the Company approved a protocol of interaction between its units engaged in contractor due diligence and corruption risk assessment.
Nornickel ensures that every signed contract includes an anti‑corruption clause, enforcing business partners to comply with anti‑corruption practices.
In 2023, the Company devised a training mechanism for counterparties and contractors on its anti‑bribery and anti‑corruption policies, with integration slated for 2024.
Anti‑corruption monitoring
In 2023, Nornickel made efforts to further integrate and enhance anti‑corruption documents and mechanisms across the Group, including:
- during the anti‑corruption monitoring, an initiative was implemented to oversee how anti‑corruption procedures are actually being put into practice across the Group;
- at the beginning of 2024, 91% of Russian business units adopted the key anti‑corruption regulations and procedures;
- 34.5% of Russian business units received recommendations for eliminating deficiencies and bolstering controls in anti‑corruption procedures.
Managing conflicts of interest
Nornickel aims to prevent and resolve in a timely manner pre‑conflict situations and takes appropriate actions.
The Company enforces the Regulations on the Prevention and Management of Conflicts of Interest, which establishes a standardised procedure for managing scenarios where personal interests might affect employees’ job performance or conflict with the Company’s best interests and potentially harm the Company.
In addition, the Company approved the standard declaration form for reporting conflicts of interest, to be filled in by candidates applying for vacant positions and by individuals acting as independent contractors. There are also permanent Conflict of Interest Commissions working to ensure compliance with the principles of legality and improve corporate culture.
Measures taken to comply with antitrust laws
Nornickel maintains an antitrust compliance framework aligned with Federal Law No. 135‑FZ On Protecting Competition dated 26 July 2006, aimed at preventing, identifying, and remedying causes and factors that might lead to legal infractions.
The Corporate Security Unit is vigilant in identifying unfair competition risks as part of the counterparty due diligence.
In 2023, Nornickel was not implicated in any material antitrust law breaches, and no Group entities faced administrative charges for such infringements.
Anti‑money laundering and counter‑terrorist financing initiatives
To establish an effective framework thwarting illegal financial activities and preventing risks associated with suspicious transactions, Nornickel diligently exercises stringent ongoing internal controls. The Company strictly complies with Russian laws on combating money laundering, financing of terrorism and proliferation of weapons of mass destruction (AML/CFT/CPF).
Nornickel consistently updates its Internal Control Rules on Combating Money Laundering, Financing of Terrorism and Proliferation of Weapons of Mass Destruction governing the relevant internal AML/CFT/CPF controls to reflect changes in the legislation:
- Federal Law No. 115‑FZ On Anti Money Laundering and Combating the Financing of Terrorism dated 7 August 2001;
- regulations of the Federal Financial Monitoring Service.
At the heart of the AML/CFT/CPF internal control framework lies a risk‑based approach.
The Company’s units in charge of the AML/CFT/CPF procedures apply a risk‑based approach. The Internal Control Department and a dedicated officer oversee the strict enforcement of compliance with the Federal Law and the Company’s robust Internal Control Rules on AML/CFT/CPF.