Appendix 4. GRI Indicators
Environmental Performance Indicatorsи

Environmental Performance Indicators

Water sources 303-2 306-5

Percentage and total volume of water recycled and reused 303-3

Total wastewater and pollutant discharge 306-1

NO_X, SO₂, and other significant air emissions, including their type and weight² 305-7

Total weight of waste by type and disposal method, mt 306-2

Waste management in 2017 by hazard class and waste type, t

Norilsk Nickel Group’s power consumption in 2017 302-1

Appendix 5. List of abbreviations

Appendix 6.
Glossary

Safe working conditions means working conditions where occupational exposure to harmful and/or hazardous production factors is prevented or controlled within the set limits.

Charitable activities means the Company's voluntary transfer of property, including cash, free works and services, and other support, to legal entities or individuals free of charge or on preferential terms.

Stakeholder engagement means the Company's activities aimed at identifying stakeholders’ expectations and concerns and their engagement in decision-making process.

Senior executives means President, Vice Presidents, heads of departments in case of the Head Office, and general directors and their deputies in case of entities located in the Norilsk Industrial District and the Kola Peninsula.

Global Reporting Initiative, or the GRI, means an independent organisation developing sustainability reporting guidelines and standards.

Stakeholders means individuals and legal entities or their groups having certain expectations about the Company or affected by its operations, influencing its managerial decisions while being themselves influenced by such decisions. Stakeholders include the Company's shareholders, investors, employees, suppliers, contractors, consumers, trade unions and other public organisations, federal and local authorities, mass media, residents of areas where the Company operates, and others.

HR policy means a set of standards, rules, regulations, concepts and goals determining the Company's HR management practices (personnel planning and record keeping, recruitment, adaptation, training and development, remuneration and incentivisation, performance assessment, social security, etc.) in line with its development strategy.

Compliance means conducting business in compliance with the requirements of government authorities, applicable laws, regulations, guidelines and standards, including corporate policies and procedures, and ethical business practices.

Collective Bargaining Agreement means a legal instrument governing social and labour relationships within a company or a sole trader business and signed by the representatives of employees and the employer.

Corporate culture means a combination of standards, values and beliefs that determine the way the Company addresses the matters of internal integration and external adaptation, guide and motivate daily behaviour of employees, while also transforming under its influence.

Corporate social responsibility, or the CSR means a corporate behaviour philosophy and concept applied by the business community, companies and specific business community representatives to their activities aimed at meeting stakeholder expectations and ensuring sustainable development.

Local communities means population with Russian citizenship.

Mission means a statement of the Company's goals and objectives that distinguish it from its peers.

Young talent means graduates of universities and colleges whose post-graduate experience does not exceed three years.

Incentivisation means tools and methods of boosting staff performance and productivity, motivating an employee or a group of employees to achieve corporate goals.

Sustainability Report (non-financial report) means an accessible, accurate and balanced description of the main aspects of the Company’s activities and achievements pertaining to its values, goals and sustainable development policy, and addressing the matters of most importance for the key stakeholders. This is a way of publicly informing the shareholders, employees, partners and other stakeholders of the Company's progress towards its goals and objectives set out in its mission statement and strategic development plans with respect to financial and environmental stability, and social security.

Health and safety system means an occupational health and safety protection system embracing legal, social, economic, organisational, technical, sanitary, hygienic, healthcare, rehabilitation and other activities.

HR management policy means an end-to-end integrated HR management system including all stages of employee-employer interaction, from recruitment to retirement and post-retirement support.

Environmental protection and resource efficiency means corporate programmes aimed at minimising the Company's environmental impact.

Human Capital Development Programme means a set of priority measures focused on bringing human capital to a new level in line with the Company's strategic goals and objectives.

Occupational disease means a health disorder caused by a systematic and lasting exposure to workplace factors or a combination of production-specific working conditions.

Local community development programmes means corporate social programmes implemented voluntarily and intended to contribute to the development of local communities.

Personnel development means a set of initiatives aimed at employee recruitment, adaptation, retention, and fully unlocking their professional and creative potential.

Risk means a negative impact on achieving the Company’s goals that may be caused by ongoing processes or future events.

Top management means President, Senior Vice Presidents, Vice Presidents, members of the Management Board and heads of departments of MMC Norilsk Nickel; directors of branches of MMC Norilsk Nickel and their deputies; sole executive bodies (directors, general directors) of the Group companies and their deputies.

Certification means confirming compliance of qualitative characteristics with quality standard requirements.

Employee performance management framework means a combination of methods, processes and procedures designed to boost employee performance in line with the Norilsk Nickel Group's corporate strategy. The framework also covers employee performance assessment and competency review.

Social partnership means a framework of relationships among employees (their representatives), employers (their representatives), and federal and local government authorities aimed at reconciling interests of employees and employers on matters pertaining to the regulation of labour relations and other directly associated matters.

Social programmes means voluntary corporate initiatives pertaining to employee development and motivation, creating favourable working conditions, promoting corporate culture and charity, and supporting local communities. These initiatives are implemented on a regular basis in line with the Company’s business strategy and focused on satisfying balanced requests of various stakeholders. From the management perspective, a social programme is a set of initiatives carefully planned in terms of resources, workforce and timeframes, and efficiently addressing the Company’s internal or external social objectives.

Social package means a set of benefits, compensations, additional payments, statutory and additional services provided to employees by the employer on top of their salary.

Standard means a guideline stipulating requirements to the object of activity.

HR management strategy means principles, regulations and approaches to personnel management focused on efficient implementation of the Company's business strategy and providing for unlocking of the employee potential, in order to achieve corporate goals.

Head Office’s business unit means a department, division or other business unit included in the Head Office's organisational structure and/or acting on the basis of the staff list approved by the Senior Vice President for HR, Social Policy and Public Relations.

Significant locations of operation means the Norilsk Industrial District, Krasnoyarsk Territory (except for the NID), Kola Peninsula Industrial District (Murmansk Region), Trans-Baikal Territory, Moscow, and other Russian regions.

Sustainable development means a concept developed by the UN that acknowledges the role of business in ensuring sustainable development of the society; a concept of global community development factoring in the interests of both living and future generations.

Payroll budget means total payroll and social payments.

Appendix 7.
Stakeholder dialogue minutes

Dialogue minutes, Norilsk

Venue: Norilsk, We Are the City! social technologies forum

Date: 31 March 2018

I. Chernova, Chief Manager of the Social Policy Department at MMC Norilsk Nickel, welcomed the participants and told them about the dialogue objectives.

As a company with a history of more than 80 years and a strong social and environmental commitment, Nornickel is making a sizeable contribution to the achievement of the UN Sustainable Development Goals. In 2016, it joined the United Nations Global Compact, which marked the transition to a new strategic development cycle running until 2022. The 2017 report will be the Group's first sustainability report presenting the Company's progress on compliance with the UN Global Compact principles. The dialogue is intended to discuss applicability of the UN 2030 Goals indicators and targets as proposed for the review of the participants to Nornickel’s operations. I. Chernova introduced the speakers and gave the floor to M. Vashukova.

M. Vashukova, Executive Director of the Association “National Global Compact Network”, spoke about the role of the UN Global Compact in making businesses more environmentally friendly. Launched in 1999, the UN Global Compact became one of the world’s most notable initiatives aimed at encouraging businesses to implement sustainable development policies on an ongoing basis. By showing a commitment to environmental protection the companies strive to minimise their environmental footprint, while also improving their governance framework, stakeholder engagement processes, technology, training and education systems along with raising the awareness of employees and local communities.

The speaker emphasised the importance of Nornickel's joining the initiative given the scale of its business and international footprint, and praised the Company’s proactive approach to implementing the Global Compact principles.

A. Ermolin, member of Alexei Kudrin's Committee of Civil Initiatives, explained the procedure for the four upcoming panel discussions (Environmental Protection, Human Rights and Protection of Local Communities, Development of Local Communities, and Industrial Policy and Labour Relations). Each panel will be presenting their view on the applicability of targets and indicators for each of the 17 Sustainable Development Goals to the Company's operations. The moderator made a remark on a more complicated nature of the discussion as compared to last year, as the previous discussion was dedicated to high-level goals only. He also wished the participants an exciting and productive dialogue.

The Industrial Policy and Labour Relations panel speaker presented the results of the panel’s discussion. According to the panel, the Company should focus on the goals and targets related to raising employee income, supporting the community's social, economic and political involvement, encouraging orderly, safe and responsible migration and mobility, ensuring decent work and economic growth, fostering education and employment of the young, promoting responsible production and consumption, and making a contribution to combating climate change. The speaker presented arguments underpinning the panel's position and reiterated the applicability of the global goals to both the Company's operations and regional development in general.

The Development of Local Communities panel speaker presented the results of the panel’s discussion. The panel concluded that there was no gender inequality on the Taimyr Peninsular, which makes the respective targets and indicators irrelevant. Qualified medical staff and targeted funding of expensive surgeries are key to the healthcare development. Another important aspect is the development of professional education and expansion of the educational programmes offering to include both sciences and humanities. It is important to keep enhancing the quality of life in the region, develop tourism and preserve unique indigenous traditions.

The Environmental Protection panel speaker presented the results of the panel’s discussion confirming relevance of the goals and most of the environmental targets for the Company, excluding those applicable to small and insular states and more southern regions.

The Human Rights and Protection of Local Communities panel speaker presented the results of the panel’s discussion citing increased agricultural productivity, enhanced transparency, effective and accountable institutions at all levels, targeted anti-corruption efforts, adoption of new reporting standards, and combating inequality by accounting for the specific context of the Northern region in legislation, as the most relevant objectives for the region.

A. Ermolin noted that the discussion served to prove relevance of the global goals and targets for Russia, Taimyr and Norilsk. At the same time, the moderator stressed inapplicability of certain topics as they reflected the realities of developing countries with a weak legal culture. He thanked the participants for their contribution to the identification of global sustainable development goals and objectives that have most relevance for the Company and the region at the moment.

Dialogue minutes, Monchegorsk

Venue: Monchegorsk, We Are the City! social technologies forum

Date: 14 April 2018

I. Chernova, Chief Manager of the Social Policy Department at MMC Norilsk Nickel, welcomed the participants and told them about the dialogue objectives.

As a company with a strong social and environmental commitment Nornickel seeks to comply with the current global agenda for sustainable development leading the charge in Russia in terms of non-financial reporting. Since 2005, the Company has been publishing corporate social responsibility reports to inform the stakeholders of its policies, plans and achievements in such important areas as corporate governance, environment, development of local communities, and others.

In 2016, Nornickel joined the UN Global Compact, which marked the transition to a new strategic development cycle. The 2017 report is the Group's first sustainability report presenting the Company's progress on compliance with the UN Global Compact principles.

As part of its reporting process, the Company traditionally engages in a dialogue with stakeholders. Today's meeting seeks to find out which of the indicators for achieving the UN goals and targets may be used to assess the Company's performance in its regions of operation.

I. Chernova introduced the speakers and gave the floor to V. Skobarev.

V. Skobarev, Head of Corporate Governance and Sustainability at FBK (independent auditor of the Company's 2017 report), highlighted the increasing importance of non-financial drivers in a company's valuation. According to him, these drivers include human and intellectual resources, experience and relations.

The speaker told the audience about the UN Sustainable Development Goals and various stages of sustainability penetration into the policies and operations of the Company.

He stressed that businesses should not view these goals as a binding obligation and use them as a guidance for further development and transformation of their corporate culture, strategy and policies.

A. Ermolin, member of Alexei Kudrin's Committee of Civil Initiatives, greeted the participants and explained the procedure for the four upcoming panel discussions (Environmental Protection, Human Rights and Protection of Local Communities, Development of Local Communities, and Industrial Policy and Labour Relations). As part of those panels, the participants are invited to discuss the applicability of indicators for each of the UN Sustainable Development Goals to Nornickel's operations in the Murmansk Region.

The Environmental Protection panel speaker presented the panel participants and named the preservation and rehabilitation of land and forests, freshwater and marine ecosystems, comprehensive management of aquatic resources, including as part of cooperation between Russia and Finland, and universal access to cheap electricity as the key focus areas for the Company.

The Human Rights and Protection of Local Communities panel speaker presented the panel participants and opined that, for the Murmansk Region and Nornickel, the most relevant goals were those related to decent wages and living standards, and protection of local communities from the effects of climate, economic, social and environmental changes. To that end, the Murmansk Region authorities have set up a dedicated fund. Another target associated with enhancing agricultural productivity and food security (one of the region's key priorities) is to maintain the genetic diversity of seeds and cultivated plants. On top of that, a lot of effort is being put into combating corruption at the federal, regional and corporate levels. The speaker also suggested appointing more women as top managers to fight inequality.

The Development of Local Communities panel speaker presented the panel participants and highlighted the traditionally high importance of healthcare and education issues that need to be addressed to ensure sustainable development of the Company and the region. Nornickel provides opportunities for the continuous vocational and technical training in the Murmansk Region. Motivating young talents to work at the Company's facilities, including Kola MMC, is yet another relevant target.

The Industrial Policy and Labour Relations panel speaker presented the panel participants and the discussion results. The panel views the goals and targets related to industrialisation, innovation and infrastructure development as an integral part of Nornickel's operations. The Company's focus on disruptive technology and innovation is a sign of sticking to the responsible production and consumption principles, the two elements that are indispensable for meeting the region's goal to ensure sustainable use of natural resources.

The Company is the region’s and the nation's flagship in achieving goals and objectives related to decent work and economic growth.

A. Ermolin thanked the participants and noted that the discussions served to demonstrate the universal character of indicators for the UN Sustainability Goals and Targets, as most of them can be used to assess the Company's operations in the Murmansk Region.

I. Chernova also thanked everyone for participating in the dialogue and discussing the topics that are of great importance to Nornickel. She also reiterated the Company's openness to a dialogue, and invited the participants to continue cooperation in the future.

Appendix 8.
Stakeholder recommendations

Appendix 9.
Awards and accolades 103-3

Awards
of MMC Norilsk Nickel

Safety and security

• InfoSecurity Russia 2017 award for Global Initiatives in Industrial IT Security;

Environment

• Letter of recognition from the Russian President for the contribution to the Year of the Environment in Russia;
• Certificate of honour from the Federation Council for major contribution to reducing the environmental impact; Active Environmental Policy award from the Russian Ministry of Natural Resources and Environment;
• Grand prize of 2016 Leaders of Russian Business: Dynamics and Responsibility contest organised by the Russian Union of Industrialists and Entrepreneurs (RSPP);
• Certificate of honour from V. I. Vernadsky Non-governmental Ecological Foundation and Russian Environmental Academy for major contribution to modernisation projects helping the environment in 2016–2017;
• Mark of Environmental Responsibility (public recognition award by the Union of Environmental Organisations at Third Russian Eco Week);
• Diploma of honour of 2017 V. I. Vernadsky National Environmental Award for the transparency of its environmental policy along with its environmental protection efforts and initiatives implemented during the Year of the Environment in Russia.

Society

• Russia’s Top-100 Employers by HeadHunter: ranking 4th on the job market and 3rd among Power, Mining and Processing companies;
• Russia’s Top Employers 2017 by The White Square Journal: ranking 5th out of 100;
• Graduate Awards 2017 nation-wide competition (Best Schoolchildren Engagement Programme and Community Choice);
• HR Brand award by HeadHunter: the corporate volunteering programme won in the Big Heart nomination;
• 2016 Leaders of Russian Business: Dynamics and Responsibility nation-wide competition by the Russian Union of Industrialists and Entrepreneurs (RUIE): winner of the nomination For Support to Development of Social Entrepreneurship;
• 2017 Leaders of Corporate Charity: winner of the Best Charity Promotion Programme (Project) nomination; RUIE sustainability indices Responsibility and Transparency and Sustainable Development Vector 2017 (the Company has been a leader in the indices since 2014 when the rankings were first compiled) Grand prize of the Competitive Procurement Leaders Awards;
• Commemorative medal and certificate of merit from the Russian President for Nornickel’s contribution to the organisation of 2017 World Festival of Youth and Students in Sochi;
• Eventiada IPRA GWA 2017: winner of the Best Environmental Project for Let’s Do It environmental marathon and the Best Integrated Project for providing high-speed internet connection to Norilsk;
• Made in Russia award for providing high-speed internet connection to Norilsk;
• Sports and Russia 4th annual national award for the best regional programme to promote sports and healthy lifestyle; Sport City 2.0 forum award for development of the regions through sports for holding the international Arctic Curling Cup 2017 in Dudinka;
• Digital Communications AWARDS 2017: winner of the Social Media and Communities nomination; Moscow International Corporate Video Festival award in the Creative Approach to Corporate Advertising nomination; 20th Annual Report Competition awards for the Annual Report, Corporate Social Responsibility Report (a special RUIE nomination) and new corporate website www.nornickel.com;
• Vision Awards 2016/2017 international public reporting award; MarCom international public reporting award.

Awards of other Norilsk Nickel Group companies

NordStar Airlines

• Transportation Safety in Russia award: the Best Air Carrier to Meet Transportation Safety Requirements nomination;
• Diploma of Wings of Russia National Aviation Award named after Evgeny Chibirev;
• Monthly Punctuality Leaders rating of Domodedovo (Moscow), Yemelyanovo (Krasnoyarsk), Koltsovo (Yekaterinburg) and Mineralnye Vody airports.

Yenisey River Shipping Company

• Industry Leader (contest for Russian sea and river shipping companies held by the Federal Agency for Sea and River Transport).

Appendix 10.
Opinion of the RSPP Council on Non-Financial Reporting

Opinion of the RSPP Council on Non-Financial Reporting on the Norilsk Nickel Group’s 2017 Sustainability Report for the purposes of public verification

The Council on Non-Financial Reporting of the Russian Union of Industrialists and Entrepreneurs (the “Council”) established as per the Management Bureau’s Resolution dated 28 June 2007, reviewed, at the request of MMC Norilsk Nickel (the “Company”, the “Group”, “Nornickel”), the Norilsk Nickel Group’s 2017 Sustainability Report (the “Report”).

The Company requested the RSPP to arrange for the public verification of the Report, with the Council on Non-Financial Reporting providing an opinion on the completeness and materiality of the Report’s information about the Company’s operations from the perspective of the Social Charter of the Russian Business. The Charter sets out key principles of responsible business conduct aligned with those of the UN Global Compact, as well as domestic and international CSR standards.

From 26 April to 21 May 2018, the Council members reviewed the content of the Company’s Report and passed this Opinion in accordance with the Council’s Procedure for Public Verification of Corporate Non-Financial Reports.

The Council members possess all the required competencies in corporate responsibility, sustainable development and non-financial reporting, comply with the ethical requirements for independence and impartiality, and provide their personal expert opinion rather than the opinion of organisations they represent.

The Report was assessed based on the following criteria of information completeness and materiality.

Information is considered to be material if it reflects the company’s efforts to implement the principles of responsible business conduct set out in the Social Charter of the Russian Business (see www.rspp.ru).

Completeness implies that the company provides a comprehensive overview of its operations, including the underlying values and strategic benchmarks, governance systems and structures, accomplishments and key results, and the stakeholder relationship framework.

The procedure for the public verification of the Report factors in the Company’s application of international reporting frameworks; this Opinion does not, however, purport to assess the Report’s compliance with such international frameworks.

The Company is responsible for the information and statements provided in the Report. The accuracy of the Report’s information is beyond the scope of the public verification procedure.

This Opinion has been prepared for MMC Norilsk Nickel. The Company may use it for both corporate and stakeholder communication purposes by publishing the original version without any changes.

CONCLUSIONS
Based on the review of the Report and the information publicly available on the Company’s official website, and following a collective discussion of the results of the Report’s independent assessment undertaken by the members of the Council on Non-Financial Reporting, the Council confirms as follows:

The recommendations made by the Council following the public verification of the Norilsk Nickel Group’s 2016 Report were duly noted and incorporated into the 2017 Report. For example, the Company provided a more detailed coverage of the responsibility across the supply chain and contractor interactions.

The Company’s 2016 Report contains material information relating to the following aspects of responsible business conduct.

Economic freedom and responsibility The Report presents the strategic performance of the Norilsk Nickel Group and the Company’s financial and operational results. It discloses the Company’s sustainable development goals and relevant results for 2017, and informs about the completion of major projects to ensure the Company’s economic efficiency, sustainability, and leadership in the global metals and mining industry, supported by specific examples. The Report dwells on the Company’s impact on the domestic economy and regional development, while also featuring information about corporate governance and sustainability management, including the review of non-financial risks and their mitigants.

It also describes the corporate integrated management system, anti-corruption policies and procedures, along with the Company’s compliance with the UN Global Compact principles. A special focus is placed on the corporate culture development programme launched in 2017 to ensure effective implementation of the Company’s strategy.

Business partnerships The Report presents key stakeholders and their interests, interaction mechanisms, and key engagement initiatives in 2017, with the Company’s Business Ethics Code cited as the underlying document that outlines stakeholder engagement principles and procedures. It also informs about target meetings with investors concerning environmental protection, social responsibility and corporate governance (ESG), and features detailed information on HR management practices and policy, the Company’s efforts in ensuring employee health, safety and professional development, and implementing corporate social programmes based on social partnership, collective bargaining agreements and communications, including the employee engagement survey. The Report describes quality assurance measures, procedures to monitor customer satisfaction and compliance with contractual terms, and review complaints. It gives account of the Company’s procurement activities that rely on the principles of openness and transparency, strengthening of competition and procurement automation, feedback channels, prevention of corruption and ensuring compliance with health and safety regulations among suppliers.

A special attention is paid to the Company’s relations with regional and municipal authorities under partnership agreements, interactions with business partners, and support for international and domestic initiatives in the area of sustainable development.

Human rights. The Report declares respect for human rights in line with Russian and international laws and regulations as one of the fundamental principles for Norilsk Nickel’s operations, and gives account of Nornickel’s relevant regulations and procedures. It gives a description of the Corporate Trust Service responsible for collecting and reviewing data on human rights violations, and submitting relevant reports to the Board of Directors’ Audit and Sustainable Development Committee and the Company’s units.

It may be concluded from the Report that the Company does not employ children, minors and women in harmful and/or dangerous working conditions. According to the information contained therein, the Company gives its employees an equal opportunity to exercise their labour rights, prevents any discrimination, and respects the rights of indigenous peoples living in the regions of its operation.

Environmental protection. The Report emphasises the Company’s commitment to reducing emissions, on a phased basis, and sustainable use of natural resources. The Company’s environmental management system that forms part of the integrated quality and environmental management system, is harmonised with production, finance, health and safety management. The Report highlights Nornickel’s environmental management priorities, while also containing information on the revised Environmental Policy approved in 2017 and compliant with ISO 14001:2015. The Company reports numerous internal audits of the environmental management system conducted in 2017 in accordance with international standards and the Company’s by-laws, along with environmental expenses and indicators. It also discloses activities aimed at reducing environmental footprint, progress on energy efficiency improvement, and contribution to fuel and energy development across its geographies. The Report includes details on the Biodiversity Conservation Policy developed in 2017 and cooperation with nature reserves.

Contribution to the development of local communities. The Report outlines key areas of cooperation under the social and economic partnership agreements with the governments and administrations of the Krasnoyarsk Territory, Murmansk Region, Trans-Baikal Territory, Tver Region, Saratov Region and the city of Norilsk. It dwells on the Company’s contribution to the development of local communities, and provides details on the key regional social and economic projects. A special focus is placed on the Company’s successful tackling of socially and economically important freight logistics challenges to ensure continuity and sustainability of operations and well-being of local communities. The Report describes the Company’s participation in establishing the Norilsk Development Agency and its commitments as the general partner of the XXIX International Winter Universiade to be hosted in 2019 by Krasnoyarsk, including the backing of the first-ever 2017 International Forum attended by leaders of volunteer movements from over 90 countries.

A detailed information is provided on the We Are the City! social technologies forum and the funds allocated by Company over the year for social programmes in the regions of operation.

Final provisions

Information in the Report generally reflects the Company’s consistent work towards the integration of corporate social responsibility and sustainable development principles into its business practices. The Report contains a significant amount of information about the Company’s impact on the society and environment, its strategy and policies in the key focus areas, and the effect of the related programmes. It covers the main focus areas and formats of stakeholder engagement, including those used in preparing the Report.

The Report was prepared using internationally and domestically recognised reporting tools (e.g. the GRI Standards, Comprehensive option, GRI Sector Disclosures and the RSPP Reference Performance Indicators), which ensures comparability of the Group’s information with that of other Russian and international companies. The Report is also in line with the UN Global Compact and UN 2030 Agenda for Sustainable Development. Material topics (aspects) and the Report structure were defined based on the contributions from stakeholders.

The 2017 Report is the Company’s fourteenth non-financial report, which demonstrates its determination to consistently develop reporting processes and enhance transparency. The Company uses various forms of independent assessment and confirmation of disclosed information (professional audit and public verification). This reflects the Company’s commitment to keeping stakeholders informed and maintaining the high quality of disclosures.

RECOMMENDATIONS
While acknowledging the Report’s strong points, the Council calls attention to some aspects of disclosures’ materiality and completeness, which should be addressed in the future reporting cycles.

It is recommended that in future reports, the Company disclose more plans for the forthcoming period, including key objectives, and information on their implementation for each reporting period. It is further advised that the Company give more details on how its performance against goals and objectives correlate with the Sustainable Development Goals of the UN 2030 Agenda given the growing attention to these issues globally.

It would be appropriate to comment more on changes in indicators to clarify the details, and also include relevant references to the annual report, including on economic aspects, as cross-references improve the complementarity of disclosed information. The Report provides coverage on the Company’s sustainable development and corporate social responsibility policies.

It is recommended that future reports contain information on their implementation, given its importance for the stakeholders and assessment of the Company’s business practices.

As a mainstay of local economies, the Company is advised to disclose, during at least three years, the amount of investments in the regions of operation along with their effectiveness and contribution to economic potential, social climate, and development of local communities. It is also recommended that further information on the performance of the Norilsk Development Agency established in cooperation with the Company (employment of local population, strengthening cooperation with local suppliers, development of infrastructure, support to small businesses, etc.) be included in the Report.

Given the Company’s experience of working with suppliers, it is advised that future reports describe the Company’s impact on their business ethics, including corruption prevention, social and environmental responsibility. It would be useful to provide examples of how these aspects are monitored as part of assessing reliability of business partners, and how the latter implement relevant policies and standards into their business practices.

As the 2017 Report contains information on corporate governance, it is recommended that next reports feature resolutions made by the Norilsk Nickel Group’s governance bodies on responsible business practices and sustainable development. It would also be appropriate to dwell on the sustainability efforts of the Board of Directors’ dedicated committee.

Traditionally, the reports prepared by the Norilsk Nickel Group contain information about the public verification procedure at the RSPP Council on Non-Financial Reporting. We advise that future reports additionally disclose information on incorporating the RSPP’s recommendations given in the previous report.

The RSPP Council on Non-Financial Reporting hereby takes a positive view of this Report, supports the Company’s commitment to responsible business practices, notes consistency in developing the reporting process, and confirms that the Norilsk Nickel Group’s 2017 Sustainability Report has passed the public verification procedure.

RSPP Council on Non-Financial Reporting

Appendix 11. Independent Assurance Report¹ 102-56