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.

NLMK Group does not provide financial support to political parties or movements, or to their representatives. At the same time, the Group recognizes the rights of its employees to participate in political activities in their free time, if such participation does not come into conflict with the undertaking of their professional duties. The political or public position of company employees can in no way be interpreted as being representative of the political or public position of the Group.

Evgeny Ovcharov, NLMK's Vice President for 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.