2022 Communication on Progress

Management Company Metalloinvest LLC

Published date

July 15, 2022

No. of questions

64

Supplemental files

CEO Statement

Signed

  • Governance

    Policies and Responsibilities

    1. Does the Board / highest governance body or most senior executive of the company:

    Optional comment
    BoD approves a Social Sustainablility Report and an Annual report on an annual basis with statements for both reports highlighting zero tolerance for corruption, assessment of impacts on both people and environment, committing on Company's sustainability targets, reviewing risks related to the business model

    2. Does the company have a publicly stated commitment regarding the following sustainability topics?

    No, this is not a current priority

    No, but we plan to have a commitment within 2 years

    Yes, and the commitment is focused on our own operations

    Yes, and the commitment includes our own operations and the value chain

    Yes, and the commitment includes our own operations and the value chain along with communities and society

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    3. Does the company have in place a code of conduct regarding each of the following sustainability topics?

    No, this is not a current priority

    No, but we plan to have a code of conduct within two years

    Yes, focused on employee conduct

    Yes, focused on employees and suppliers

    Yes, focused on employees, suppliers, and other business relationships

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    4. Has the company appointed an individual or group responsible for each of the following sustainability topics?

    No one is specifically responsible for this topic

    Yes, with limited influence on outcomes (e.g., limited access to internal information, limited decision-making authority)

    Yes, with moderate influence on outcomes (e.g., has access to relevant information, reports to senior manager)

    Yes, with direct influence of some outcomes (e.g., has access to relevant information, includes one or more senior manager with decision making rights

    Yes, with direct influence at the highest levels of the organization (e.g., has access to relevant information, includes most senior members of organization)

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?

    No formal structure

    Yes, and with limited influence on outcomes (e.g., limited access to internal information necessary to understand risks, poor representation from relevant departments or functions)

    Yes, with moderate influence on outcomes (e.g., it includes representatives of some functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, reports to senior manager)

    Yes, with direct influence on some outcomes (e.g., it includes representatives of functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, it involves one or more members of senior management)

    Yes, and with direct influence at the highest level of the organization (e.g., full access to relevant information, it involves members at highest level of organization)

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Prevention

    6. Does the company have a process or processes to assess risk?

    No, this is not a current priority

    No, but we are planning to develop one in the next two years

    Yes, related to our own operations

    Yes, related to our own operations and entire value chain and other business relationships

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    Optional comment
    As it works to continuously improve its system for managing corruption and fraud risk, Metalloinvest is guided not only by Russian legalrequirements, but also by local and international best practices. In 2020-2021, the Company carried out identification and assessment of corruption risks, after which the Risk Committee approved a Corruption Risk Register; control procedures for each risk were subsequently implemented. The Register contains a description and assessment of 100 corruption risks within 16 business processes of the Company. Anti-corruption requirements are included in all standard employment contracts, as well as in the Company’s internal work regulations, which were updated in 2021. In addition, activities of the Company’s staff are guided by the Code of Corporate Ethics and the Conflict of Interest Regulations

    7. Does the company have a due diligence process through which it identifies, prevents, mitigates, and accounts for actual and potential negative impacts on sustainability topics?

    No, this is not a current priority

    No, but we are planning to develop one in the next two years

    Yes, related to our own operations

    Yes, related to our own operations and entire value chain and other business relationships

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    Optional comment
    The Company maintains a dedicated confidential Hotline for reporting possible misconduct. The Company’s Hotline is a channel for employees and other persons to provide feedback on corrupt practices; corporate fraud; embezzlement; misrepresentation of accounts; bribery; inefficient use of resources; and violations of Russian legislation, local regulations of the Company, and the legitimate interests of employees.

    Concerns and grievance mechanisms

    8. Are there any processes through which members of the company’s workforce can raise concerns about the company’s conduct related to human rights, labour rights, environment, or anti-corruption?

    Optional comment
    The Company’s Hotline is available 24/7 to receive any reports of possible misconduct, which can be submitted anonymously, f.e. in 2021, the Hotline received 222 complaints, 71 more than in 2020. In 40 cases, violations were later confirmed and 24 people faced prosecution after the investigation was completed

    8.1. Please provide additional detail regarding the process(es) the company has through which members of the company’s workforce can raise concerns about the company’s conduct.

    No

    Yes

    Is the process communicated to all employees/workers in local languages?

    Is the process available to non-employees (e.g., contractors, vendors, suppliers)?

    Is the process confidential (e.g., whistleblowing process)?

    Are there processes in place to avoid retaliation?

    Can concerns be raised about suppliers or other business relationships (e.g., clients, partners, etc.)

    Other (Please provide additional information)

    9. Does the company provide or enable access to effective remedy to right holders / stakeholders where it has caused or contributed to the adverse impact?

    No process to enable remedy to stakeholders

    Remedy available to some stakeholders (i.e., some geographies, employees only)

    Remedy is available to all affected stakeholders

    Remedy is available to all stakeholders, and suppliers are expected to have similar policies

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    The Supplier Code was implemented in 2020 we consider the concept of sustainable development to be key in our relationships with suppliers and contractors, and corresponding rules have been embedded into the Supplier Code adopted in 2020. This reflects our commitment to our business partners and society, as well as our expectations of suppliers in terms of professionalism, information security, decent working conditions, OHS, environmental protection, social responsibility, audit and transparency of documentation, and legal compliance.

    Lessons

    10. How does the company capture lessons regarding each of the following sustainability topics?

    No lessons are regularly captured

    Conducts root cause analyses/investigation of major incidents

    Conducts root cause analyses/investigation and changes organizational policies, processes, and practices accordingly

    Systematically conducts root cause analyses/investigation and leverages learnings to influence both internal and external affairs

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    Metalloinvest prohibits any form of discrimination when selecting and hiring staff, as well as during work activities and staff promotions. The Company upholds the universal nature of human and civil rights and freedoms regardless of sex, race, nationality, age, language, origin, property, official status, place of residence, religion, belief, and membership in public associations. It applies these values to all stakeholder groups and requires a similar approach from its business partners. Set up a transparent and objective recruitment process We implemented some programmes and initiatives as follows: • Implemented a programme for employing individuals with physical disabilities • Systematically developed social programmes in its regions of operation • Developed corporate training programmes for employees at all levels • Developed two-way communication programmes with staff • Approved a new model collective contract for 2020–2022

    Executive Pay

    11. Is executive pay linked to performance on one or more of the following sustainability topics?

    No, and we have no intention to change

    No, but we plan to within two years

    Yes

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Board Composition

    12. Percentage of individuals within the company’s Board / highest governance body by:

    Number/Percentage

    Not applicable (Please provide additional information)

    Total number of board members (#)

    12

    Male (%)

    83

    Female (%)

    17

    Non-binary (%)

    0

    Under 30 years old (%)

    0

    30-50 years old (%)

    12

    Above 50 years old (%)

    88

    From minority or vulnerable groups (%)

    0

    Executive (%)

    87

    Independent (%)

    17
    Optional comment
    Each year, Metalloinvest takes out liability insurance for its Board Directors, members of the Management Board, managers, and Company officers (hereinafter, the “Insured Persons”) in compliance with the Russian and international standards of corporate governance and risk management. The liability of the Company’s insured persons is covered by the D&O policy. The terms of the policy were developed jointly with Allianz, which has been insuring Metalloinvest’s D&O risks continuously in the period from 2015nto 2021. The terms of the policy stipulate the optimum amount of coverage taking into account all of Metalloinvest’s insurance protection needs, with a total limit of USD 100 million and an additional limit of USD 5 million in respect of liability for Independent Directors. The policy provides protection against possible claims from third parties that may arise as a result of unintentional wrong actions taken by insured persons while managing the Company. Possible expenses of the Company maynalso be reimbursed if the Company itself has covered the costs and losses of the insured persons.

    13. Do you produce sustainability reporting according to:

    Optional comment
    We also produce non financial reporting under industry (World Steel Association) regulation recomendations

    Data Assurance

    14. Is the information disclosed in this questionnaire assured by a third-party?

    Independent Limited Assurance Report is provided by Independent auditor: AO PricewaterhouseCoopers Audit (PwC). PwC assessed the qualitative and quantitative information, that is disclosed in the Consolidated report and referred to or disclosed in thenGRI and SASB content index of the Consolidated report. The scope of our assurance procedures was limited to the Selected Information for the years ended 31 December 2020 and 2021.
    Optional comment
    Independent Limited Assurance Report is provided by Independent auditor: AO PricewaterhouseCoopers Audit (PwC). PwC assessed the qualitative and quantitative information, that is disclosed in the Consolidated report and referred to or disclosed in thenGRI and SASB content index of the Consolidated report. The scope of our assurance procedures was limited to the Selected Information for the years ended 31 December 2020 and 2021.

  • Human Rights

    Materiality / Saliency

    1. Which of the following has the company identified as material human rights issues connected with its operations and/or value chain, whether based on their salience (i.e., the most severe potential negative impacts on people) or another basis?

    Optional comment
    Metalloinvest is committed to creating and maintaining a work environment free from discrimination of any kind, and it requires its business partners to conduct business in an equally ethical manner. In accordance with the principles of the UNGC, Metalloinvest incorporates internationally recognised human rights into its operations and strategy; advocates for the elimination of all forms of forced, compulsory and child labour; and fights against labour and employment discrimination. We are guided by the demands and statements on human rights issued by international industry associations such as the World Steel Association (WSA), of which the Company is a member.

    Response

    8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the human rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

    Our Company ensured compliance with OHS requirements in the Company and throughout the entire supply chain and has taken other measures in the period of 2020-2021, as follows: • Introduced a range of measures to improve working conditions for staff • Supported the healthcare system in the regions of operation • Developed a corporate healthcare management system • Implemented a comprehensive programme to support employees during the pandemic • Provided employees with the right to visit health resorts Elaborated the Environmental Programme and the Climate Strategy • Developed environmental requirements for suppliers and contractors • Updated the HSE Policy • Contributed to the development of a favourable urban environment in the regions of operation • Introduced a tool to receive and process environmental complaints from individuals and legalentities in the regions of operations

  • Labour

    Commitment

    1. Does the company have a policy commitment in relation to the following labour rights principles?

    No, and we have no plans to develop a policy

    No, but we plan to in the next two years

    Yes, included within a broader policy

    Yes, articulated as a stand-alone policy

    Not applicable (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    2021

    Forced labour

    2021

    Child labour

    2021

    Non-discrimination in respect of employment and occupation

    2021

    Occupational safety and health

    2021

    Working conditions (wages, working hours)

    Optional comment
    In 2021, the Company adopted Metalloinvest Human Rights Policy The Policy incorporates principles and norms stipulated in Russian and international documents including the Universal Declaration of Human Rights, the UNESCO Universal Declaration on Cultural Diversity, and the Labor Code of the Russian Federation. The main objectives of the Policy include establishment of a unified approach to ensuring the protection and development of human rights and freedoms within the Metalloinvest Group and popularisation of a responsible approach to the protection of rights and freedoms at the corporate level. Incorporation of a separate section stipulating the Metalloinvest's commitments to diversity and inclusion into the Company’s Himan Rights Policy became an important outcome of such approach. It reflects evolution of Metalloinvest's approach and vision on this issue: established sustainable and diverse inclusive culture in a team of employees with diverse views, experiences, social and cultural backgrounds while ensuring equal opportunities for each of them.

    1.1. For each labour rights policy, is it:

    Aligned with international labour standards?

    Publicly available?

    Approved at most senior level of the company?

    Applied to the company’s own operations?

    Applied to the company’s supply chain and/or other business relationships?

    Developed involving labour rights expertise from inside and outside the company?

    Other (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Optional comment
    Ensuring occupational health and safety (OHS) is a fundamental goal of Metalloinvest. The Company complies with all relevant requirements of Russian legislation to ensure healthy and safe working conditions for its employees and contractors (as well as subcontractors) and actively fosters a safety culture, both during production and in everyday life. To highlight the special role played by OHS in enabling Metalloinvest to conduct successful, sustainable business, 2021 was declared the Year of Occupational Safety. This has had a significant impact on our approach to OHS management, as shown by improvements to the organisational management model, our development of a separate strategy, the revision of a number of regulatory documents, and the launch of new programmes. The Health, Safety and Environment (HSE) Committee, established in 2020, is still in place to ensure the strategic development of HSE. The Committee carries out the following functions: • Preparing proposals and expert opinions • Determining Metalloinvest’s HSE development strategy • Planning and coordinating HSE activities of the managed companies • Assessing HSE activities of Metalloinvest units and managers

    Prevention

    2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following labour rights issues?

    No engagement on this topic

    To better understand the risks/ impacts in question

    To discuss potential ways to prevent or mitigate the risks/ impacts in question

    To agree on a way to prevent/ mitigate the risks/ impacts in question

    To assess progress in preventing/ mitigating the risks /impacts in question

    To collaborate in the prevention/ mitigation of the risks/ impacts in question

    Other (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this labour rights issue?

    Provided internal training/ capacity building for the direct workforce

    Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)

    Conducting an audit process and/or corrective action plan

    Collective Action with peers or other stakeholders, in particular workers' organizations, to address the issue

    Collaboration with governmental or regulatory bodies

    Other (Please provide additional information)

    No action within reporting period

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    There was independent audits conducted under SMETA 4Pillars on two production plants in 2021

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Optional comment
    There was independent audits conducted under SMETA 4Pillars on two production plants in 2021

    4. Who receives training for the following labour rights issues?

    No training provided

    Select employees

    All employees

    Contractors

    Direct suppliers of the organization

    Indirect suppliers of the organization

    Other – such as partners, clients, etc.

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    5. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights issues?

    No monitoring of progress

    Review issues on ad-hoc basis

    Set annual targets/ goals, track progress over time (internal programs only)

    Set annual targets/ goals, track progress over time (internal and external programs)

    Other (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Optional comment
    Metalloinvest makes significant efforts and spends a considerable amount of money on managing OHS issues. We are constantly studying international practices, the best of which we introduce to our production processes. Likewise, we continuously improve our personnel training systems and motivate employees to take an active part in promoting responsible and safe work. The Company applies the Target Zero strategy, under which it strives to completely eliminate workplace incidents. Not only does Metalloinvest comply with all the standards and requirements of Russian law, it also actively fosters a safety culture — encouraging conscientious safe behaviour amongst employees, both during production and in everyday life.

    Performance

    6. What is the percentage of employees covered under collective bargaining agreements?

    Percent of employees (%)

    Unknown

    Employees covered under collective bargaining (%)

    100
    Optional comment
    The Company’s collective agreement for 2020–2022 contains unified social and labor standards and guarantees for all Company enterprises. The agreement is an act of social partnership that foresees mutual obligations for both the employer and employees. The document was developed in partnership with a trade union, approved by the Social Council, and unanimously approved by all staff. It covers 100% of employees.

    7. What is the percentage of employees in a trade union or other workers' organization?

    Percent of employees (%)

    Unknown

    Not applicable (Please provide additional information)

    Employees in a trade union or on a worker committee (%)

    80
    Optional comment
    Each enterprise of the Company has its own primary trade union organization that can be joined by any employee at his\her own will. Primary trade unions are part of the Russian Mining and Metallurgical Trade Union (MMTU) protecting social and economic rights and interests of mining and metallurgical sector employees at various levels.

    8. In the course of the reporting period, what was the percentage of women in:

    Percent of women (%)

    Unknown

    Senior leadership level position

    17

    Non-executive board

    83
    Optional comment
    95

    9. What was the average ratio of the basic salary and remuneration of women to men (comparing jobs of equal value) during the reporting period?

    Salary ratio (%)

    Unknown

    Choose to not disclose

    Women / Men (%)

    95

    10. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?

    Frequency of injury

    Unknown

    Choose to not disclose

    Frequency of injury

    1
    Optional comment
    LTIFT =1,06 (including contractors), TRIFR = 2,60

    11. In the course of the reporting period, what was the company’s incident rate?

    Incident rate

    Unknown

    Choose to not disclose

    Incident rate

    106
    Optional comment
    Total number of industrial accidents

    Response and Reporting

    12. In the course of the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to the adverse impact associated with the following labour rights issues?

    Yes

    No

    Choose to not disclose

    Not applicable (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    13. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the labour rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

    The Company’s collective agreement for 2020–2022 contains unified social and labor standards and guarantees for all Company enterprises. The agreement is an act of social partnership that foresees mutual obligations for both the employer and employees. The document was developed in partnership with a trade union, approved by the Social Council, and unanimously approved by all staff. It covers 100% of employees. The collective agreement ensures the balance of interests, forms a sound basis for social partnership between the Employer and Employees. It defines engagement principles to guarantee the exercise of rights and obligations of all parties involved. The collective agreement is based on the principles of equal rights, mutual concern, voluntariness, legality, justifiability of obligations and their bona fide fulfillment. The main sections of the collective agreement are: • Working hours and leisure time • Remuneration and quota setting • Social programmes • Guarantees and compensations to employees upon the Company’s liquidation, headcount reductions • Workforce capacity development • Occupational safety • Mutual commitments and guarantees, patterns of social partnership cooperation 100% of our staff were covered by the collective agreement in 2019-2021

  • Environment

    Commitment

    1. Does the company have a formal policy on the following environmental topics?

    No, and we have no plans to develop a policy

    No, but we plan to in the next two years

    Yes, included within a broader policy

    Yes, articulated as a stand-alone policy

    Not applicable (Please provide additional information)

    Climate Action

    Climate Strategy was adopted in 2021, reviewed in 2022. The Company aims to achieve carbon neutrality by 2050

    Water

    Company has been developing complex Ecology programm which includes water, air, biodiversity and waste aspects for the last two years (2020-2021).

    Oceans

    The Company complies with laws concerning water resources; it takes measures to update and develop infrastructure in good time, applies best available technologies, and uses modern wastewater treatment systems. Joint water use at the Company's enterprises never violates the rights of other users of that same body of water.

    Forests / Biodiversity / Land Use

    2021

    Air Pollution

    In 2022, Metalloinvest adopted and updated its Climate Strategy. The Company’s strategic focus is achieving carbon neutrality by 2050. As part of the Climate Strategy, Metalloinvest set its decarbonisation KPIs dividing them in three key stages: up to 2025, up to 2036, and up to 2050. The Hydrogen Strategy developed in 2021 was incorporated in the Climate Strategy.

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    The Company strictly regulates the management of mining and production waste through established procedures. In 2020, a separate recycling programme was developed that is scheduled to begin operations in 2021. About 20 initiatives have been put forward to increase the share of recycled technological waste at the Company. These measures and initiatives form part of the Environmental Programme. The Zero Waste initiative comprises a set of measures aimed at reducing environmental impacts; these involve constructing or repairing waste disposal facilities (tailings storage facilities, dumps, landfills), minimising waste generation, and recycling or disposing of waste

    Energy & Resource Use

    Metalloinvest has an Energy Saving Programme that is coordinated through the corporate management system, including the Company's Business System. The Programme is tightly integrated with the CAPEX plan, which foresees operational improvements that the shops then work to implement. The Company has approved an Energy Efficiency Improvement Programme whose strategic goal is to reduce the share of energy costs in the cost of production, guaranteeing uninterrupted power supply and ensuring that production is allocated sufficient energy resources. During a general audit of Metalloinvest's energy management systems, the Programme’s effectiveness and compliance with ISO 50001 were confirmed.
    Optional comment
    Combatting climate change is one of Metalloinvest’s top priorities. In pursuit of this goal, the Company has elaborated a climate strategy that reflects all its activities related to climate change, discloses its greenhouse gas emissions inventory, outlines measures to reduce them, and formulates long-term goals. So far, the Company has decided that its strategic decarbonisation goals are the most material aspect of its climate strategy

    1.1. For each environmental policy, is it:

    Aligned with international environmental standards?

    Publicly available?

    Approved at most senior level of the company?

    Applied to the company’s own operations?

    Applied to the company’s supply chain and/or other business relationships?

    Developed involving environmental expertise from inside and outside the company?

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    Optional comment
    As a WSA member, Metalloinvest is involved in the Climate Action Programme, which aims to collect data on CO2 emissions from the metals industry. By comparing data from different enterprises, we are able to determine the most efficient tools for reducing emissions. For several years running, the Company has been awarded a Climate Action Certificate, which proves that Metalloinvest fulfils its obligations to provide reliable data pursuant to the unified WSA methodology. These projects also help the Company develop further measures to reduce its impact on the environment.

    Prevention

    2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following environmental issues?

    No engagement on this topic

    To better understand the risks/ impacts in question

    To discuss potential ways to prevent or mitigate the risks/ impacts in question

    To agree on a way to prevent/ mitigate the risks/ impacts in question

    To assess progress in preventing/ mitigating the risks/ impacts in question

    To collaborate in the prevention/ mitigation of the risks/ impacts in question

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    The Company has its own laboratories dedicated to regularly monitoring quality of water and wastewater impacted by the enterprises’ activities. Bodies of water and water protection zones undergo complete monitoring on a yearly basis; this includes controls over morphometric features and the condition/means of using water protection zones. All observation results are submitted to the Federal Agency for Water Resources. The laboratories are equipped with the measuring tools, manuals, reagents, and testing and auxiliary equipment necessary to implement industrial environmental controls, as well as controls over adherence to sanitary rules, as stipulated by current laws. Reaccreditations are conducted on a regular basis

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with these environmental topics?

    Provided internal training/ capacity building for the direct workforce

    Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)

    Conducting an audit process and/or corrective action plan

    Collective Action with peers or other stakeholders to address the issue

    Collaboration with governmental or regulatory bodies

    Other (Please provide additional information)

    No action within reporting period

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    Optional comment
    In 2021, the Company completed a joint project with Megafon PJSC to come up with solutions for systematically automating control of air and water pollution. These solutions include technology to equip stationary sources of pollution at Category I facilities of Metalloinvest's enterprises with automated systems for measuring and registering pollution, as well as hardware for recording and transmitting information on pollution volumes.

    4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?

    No monitoring of progress

    Review issues on ad-hoc basis

    Set annual targets/ goals, track progress over time (internal programs only)

    Set annual targets/ goals, track progress over time (internal and external programs)

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    Optional comment
    In 2020, a comprehensive Green Office programme was launched to keep up with global trends in environmentally friendly business at enterprises

    4.1. For each environmental topic in which the company sets timebound goals / targets, what kind of targets has the company set?

    Description of targets (e.g., what is the target, absolute vs. intensity, externally verified, on track, etc.)

    Climate Action

    Reduce air emissions by 7% (by 2025)

    Energy & Resource Use

    NA

    Water

    NA

    Forests / Biodiversity / Land Use

    NA

    Air Pollution

    NA

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    NA

    Oceans

    NA
    Optional comment
    In 2020, a comprehensive Green Office programme was launched to keep up with global trends in environmentally friendly business at enterprises

    4.2. For each environmental topic in which the company sets timebound goals / targets, how is progress against target / goal tracked?

    Progress is reviewed against goals annually or more frequently

    Progress is reported internally to the most senior level

    Progress is reported externally

    Other (Please provide additional information)

    Climate Action

    Energy & Resource Use

    Water

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Oceans

    5. In the course of the reporting period, has the company been involved in providing or enabling remedy for any actual impacts associated with the following environmental issue(s)?

    Yes

    No

    Choose to not disclose

    Not applicable (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    Climate Action

    6. What were the company’s gross global greenhouse gas emissions for the reporting period?

    Scope 1 Emissions

    Emissions (tCO2e)

    12927444

    Scope 2 Emissions

    Emissions (tCO2e)

    3561735

    Scope 3 Emissions

    Emissions (tCO2e)

    39844000
    Optional comment
    Greenhouse gas emissions at Metalloinvest are calculated using official ISO procedures, Order No. 300 of the Ministry of Natural Resources of the Russian Federation "Methodological Guidelines and Manual for Quantifying Greenhouse Gas Emissions Volume by Organisations Engaged in Business and Other Activities in the Russian Federation" dated 30 June 2015, and Order No. 330 "Methodological Guidelines for Quantifying Indirect Energy Greenhouse Gases Emissions Volume" of the Ministry of Natural Resources of the Russian Federation dated 29 June 2017 and also the international standard The Greenhouse Gas Protocol.

    7. What percentage of the company's revenue was invested in R&D of low-carbon products/services during this reporting period?

    Percent of revenue (%)

    8

    8. Has the organization acted to support climate change adaptation and resilience?

    Energy / Resource Use

    9. Please report the company's renewable energy consumption as a percentage of total energy consumption in the reporting period.

    % of total energy consumption

    19
    Optional comment
    Consumed electric power is measured using an automated electricity metering system that is certified and registered on the WEPCM. Consumed electric power is broken down by type — renewable and other — in accordance with WEPCM data.

    Technology

    10. What percent of the company's revenue came from environmentally friendly products / services during this reporting period?

    Percent of total revenue (%)

    20
    The Company is the leading global producer and supplier of commercial hot briquetted iron (HBI), a green low-carbon raw material for steel production, and a leader in the production of iron ore concentrate, pellets, and high-quality steel.
    Optional comment
    Metalloinvest focuses on ongoing R&D and consistent innovation activities. Their importance is underpinned by the Company’s strategic priorities such as increasing the share of premium products and the outputs, enhancing the quality of manufactured goods, and constantly improving the quality of niche steel products to meet growing customer demands. Amid rapidly developing technologies in the global market and toughened customer requirements for product quality, innovation becomes a pillar supporting the Company’s the longterm sustainability and operations.

    Sector-specific Questions

    11. Which sector(s) does the company operate in? If diversified, choose top 3 by revenue.

    Optional comment
    Metalloinvest is a leading global producer and supplier of HBI and iron ore products, and a regional producer of high quality steel. The Company is a global producer of HBI and processes a large proportion of its iron ore into high added value products, such as pellets and HBI/DRI.

    Sector-specific: Water

    12. Please provide details regarding the company's water withdrawal and consumption (own operations) during the reporting period.

    Water withdrawal (volume of water in megaliters):

    Mega-liters

    Unknown

    Not applicable (Please provide additional information)

    Total

    50

    Groundwater:

    0

    Surface water:

    47

    Rainwater:

    Wastewater:

    1

    Percentage of water withdrawn in regions with high or extremely high water stress (%)

    0

    Water consumption (volume of water in megaliters):

    Mega-liters

    Unknown

    Not applicable (Please provide additional information)

    Total

    156

    Groundwater:

    100

    Surface water:

    56

    Rainwater:

    Wastewater:

    50

    Percentage of water consumed in regions with high or extremely high water stress (%)

    1

    13. Please provide details about the company’s water intensity of products in regions with high or extremely high water stress.

    Water intensity of products (cubic meter/$):

    Sector-specific: Forest, biodiversity, and land use

    14. Please report the number and area (in hectares) of sites owned, leased, or managed by the company in or adjacent to protected areas and/or key biodiversity areas (KBA).

    Number

    Unknown

    Not applicable (Please provide additional information)

    Sites

    2

    Hectares

    40

    15. What area (in hectares) of natural ecosystems was converted during the reporting period in areas owned, leased, or managed by the company?

    Conversion of natural resources (hectares)

    39

    16. Is the company supporting or implementing project(s) focused on ecosystem restoration and protection?

    No

    No, but we plan to in the next 2 years

    Yes

    Forest ecosystem restoration

    Other ecosystem restoration

    The Company's enterprises do not operate in conservation areas or areas of high biodiversity value. However, realising the importance of preserving biodiversity in its regions of operation, Metalloinvest regularly monitors the biological diversity of flora and fauna. Likewise, it supports institutions involved in the study and conservation of typical and unique ecological systems. In 2020, changes were made to Metalloinvest’s Health, Safety and Environment Policy with regards to specially protected natural areas for conservation of biological diversity. For a long time now, LGOK has been supporting the Belogorye State Nature Reserve, which is located in the specially protected natural area Yamskaya Steppe, as well as the Professor V.V. Alekhin Central Black Earth State Natural Biosphere Reserve in the Kursk Region.

    Reforestation

    Natural regeneration

    Agroforestry

    Set-aside land

    Biodiversity offsetting

    As part of a long-term partnership, support was provided to the Belogorye State Nature Reserve and the Professor V.V. Alekhin Central Black Earth State Natural Biosphere Reserve. Research was conducted on this territory to study the biological diversity of technogenic landscapes at MGOK. Researchers concluded that the reserve serves as a habitat for rare animal species, including endangered species, which are found in greater numbers there than in the region in general. The obtained data became the basis for subsequent environmental monitoring of biodiversity conservation. In 2021, we plan to continue with this research and monitoring as part of a biodiversity conservation project.

    Other (please specify in text box)

    Sector-specific: Air pollution

    17. Where applicable, please report the company's emissions of the following pollutants during the reporting period.

    Emissions (tCO2e)

    Unknown

    Not applicable (Please provide additional information)

    NOx

    18

    SOx

    29

    Volatile Organic Compounds (VOC)

    3

    Hazardous air pollutants (HAP)

    18

    Particulate matter (PM10)

    17

    Persistent organic pollutants (POP)

    3

    Other (please specify in text box)

    2

    Sector-specific: Waste

    18. Please report the company's total weight of waste generated in metric tonnes during the reporting period.

    Waste Generated (t)

    120084799
    Optional comment
    Total waste weight by type and treatment method

    19. Please report the percentage of the company's waste that was hazardous waste (i.e., hazardous waste ratio) during the reporting period.

    Hazardous Waste Ratio (%)

    14

    20. Please report the company's estimated metric tonnes of single-use plastic consumed wherever material along the value chain during the reporting period.

    Single-use plastics (tonnes)

    Metalloinvest comprehensively manages mining and production waste. It closely monitors improvements to environmental indicators relating to natural resource use and production waste disposal. The Zero Waste initiative comprises a set of measures aimed at reducing environmental impacts; these involve constructing or repairing waste disposal facilities (tailings storage facilities, dumps, landfills), minimising waste generation, and recycling or disposing of waste.

    Overall Environment

    21. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the environment principles, including any challenges faced and actions taken towards prevention and/or remediation.

    In 2021, Metalloinvest adopted and updated its Climate Strategy. The Company’s strategic focus is achieving carbon neutrality by 2050. As part of the Climate Strategy, Metalloinvest set its decarbonisation KPIs dividing them in three key stages: up to 2025, up to 2036, and up to 2050. The Hydrogen Strategy developed in 2021 was incorporated in the Climate Strategy. Reduce air emissions • Fully transition MGOK and OEMK to a closed-loop recycled water supply system. This will prevent wastewater discharge into bodies of water • Conduct the phased transition of LGOK to a closed-loop recycled water supply system, bringing about a 50% reduction in wastewater discharges • Achieving 100% recycling of technological waste and materials (excluding overburden and tailings at LGOK and MGOK) • Reducing overburden formation at LGOK and MGOK by 33% through construction of conveyor units • Reduce greenhouse gas emissions (CO₂-equivalent) by one million tonnes amongst consumers of Metalloinvest’s iron ore raw materials

  • Anti-corruption

    Commitment

    1. Does the company have an anti-corruption compliance programme?

    2021 - the Company has updated the Anti-corruption Policy, putting oversight of anti-corruption activities under the purview of the Board of Directors, develop a Conflict of Interest Regulation as well

    2. Does your company have policies and recommendations for employees on how to act in case of doubt and/or in situations that may represent a conflict of interest, e.g. with regard to gifts and hospitality, donations, sponsorship, or interactions with public officials?

    Optional comment
    A special refresher course on Company's policies is also available for a number of positions to keep staff updated about legal requirements and internal corporate regulations. In 2021 alone, 21,894 employees underwent this training, which comprised 51% of the total workforce. All in all, a total of 100% of employees have taken this mandatory course at some point, including newly hired and long-time employees.

    Prevention

    3. Who receives training on anti-corruption and integrity?

    Optional comment
    21,894 EMPLOYEES PASSED THE COURSE RAISING EMPLOYEE AWARENESS OF CORRUPTION AND FRAUD PREVENTION MEASURES IN THE REPORTING YEAR (2021) 71 MANAGERS TOOK THE COURSE ANTICORRUPTION EDUCATION FOR EMPLOYEES INVOLVED IN CORRUPTION-PRONE BUSINESS PROCESSES IN THE REPORTING YEAR

    3.1. How often is such training provided?

    One time only

    Every year

    Every two or more years

    We do not collect this data

    All employees

    Select employees

    Contractors

    Direct suppliers of the organization

    Other – such as partners, clients, etc.

    Indirect suppliers of the organization

    4. Does the company monitor its anti-corruption compliance programme?

    Response and Reporting

    5. Please report the company's total number and nature of incidents of corruption during the reporting year.

    Number of incident(s)

    Unknown

    Choose to not disclose

    Confirmed during the current year, but related to previous years

    3
    Conflict of interests and non-compliance with occupational health and industrial hygiene requirements

    Confirmed during the current year, and related to this year

    2
    Conflict of interests and unwarranted liability action against individuals reporting misconduct
    Optional comment
    Some cases were not disclosed in CSR2020-2021 due to internal agreements with parties involved

    6. Within the reporting period, what measures has the company taken to address suspected incidents of corruption independently or in response to a dispute or investigation by a government regulator?

    7. Does your company engage in Collective Action against corruption?

    All Company employees are informed of innovations or amendments to relevant corporate anti-corruption policies in good time. In addition, staff of the Security department responsible for anti-corruption controls are always ready to advise their colleagues should the latter have doubts about the compliance of their actions with legal norms and requirements or the principles of internal corporate anti-corruption documents. A total of 71 Company managers underwent the additional training Anti-Corruption Education for Employees Involved in Corruption-Prone Business Processes. Also, we are establishing collegial bodies to resolve conflicts of interest at Metalloinvest enterprises and automating the Hotline and transfer the processing of claims to Metalloinvest Corporate Service LLC (MCS)
    Optional comment
    The Supplier Code was implemented in 2020 We consider the concept of sustainable development to be key in our relationships with suppliers and contractors, and corresponding rules have been embedded into the Supplier Code adopted in 2020. This reflects our commitment to our business partners and society, as well as our expectations of suppliers in terms of professionalism, information security, decent working conditions, OHS, environmental protection, social responsibility, audit and transparency of documentation, and anti-corruption Company's standards.

    8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the anti-corruption principle, including any challenges faced and actions taken towards prevention and/or remediation.

    Metalloinvest has confirmed its willingness to certify the compliance of its Anti-Corruption Management System with ISO 37001:2016. Some extra measures were implemented during 2021: Upholds standards for employee conduct • Practices corruption risk management • Develops, implements, and updates local regulations to combat corruption • Conducts expert anti-corruption investigations • Applies anti-corruption controls to procurement and sales • Refuses payments through intermediaries in favour of third parties • Ensures compliance with anti-corruption principles when interacting with counterparties • Ensures that gifts and representative expenses comply with anti-corruption restrictions Ensures compliance with anti-corruption principles when handling confidential information • Ensures that allegations of corruption are resolved • Follows up on detected violations and prosecutes the perpetrators • Organises procedures to protect employees who file corruption allegations from retaliation • Engages in accounting and reporting • Lays the foundation for an anti-corruption behaviour amongst staff • Engages in anti-corruption monitoring