Anticorruption policy

NLMK Group is guided by high ethical standards and principles of business transparency. Respect for active legislation, professionalism and honesty are essential for all NLMK Group employees.

NLMK adheres to best corporate governance practices and deems any form of corruption to be unacceptable, including bribery, collusion, corrupt payments, abuse of position, facilitation payments, etc. Direct and indirect involvement of NLMK Group employees in corrupt activities is prohibited without exception.

In 2013, NLMK Group joined the Anti-Corruption Charter of Russian Business, established by the Russian Union of Industrialists and Entrepreneurs, underlining NLMK’s commitment to promoting fair business and corporate governance practice in Russia; in order to encourage fair competition and sustainable economic growth.

Evgeny Ovcharov, NLMK Director for Internal Control and Risk Management is in charge of anti-corruption enforcement; and responsible for implementing the company’s anti-corruption programme.

Feedback

Details of any instances of corruption, past and future; and information that can prevent or resolve a conflict of interests, can be relayed via any of our feedback channels:

NLMK helpline

• from Lipetsk: 06 from other cities / internationally: +7 (4742) 44-07-30 (in online mode 8:00 am to 5:00 pm on business days; in automatic mode 24/7)
• E-mail: anticorruption@nlmk.com
• Written statement to our ‘Trust Mailbox’ (in Lipetsk) (located in old administrative building, at central and ‘old plant’ checkpoints);
• Written statement to: 398040, 2, pl. Metallurgov, Lipetsk (letter can be addressed to a specific manager and be marked ‘confidential’)
• Oral statement at a meeting with Company managers; the manager in charge of anti-corruption enforcement; NLMK’s safety directorate.

The result of NLMK’s anti-corruption programmes will be covered in the Group’s Corporate Social Responsibility reports.