Severstal ad EY coduct a ethical stadards compliace audit

November 30, 2021

Severstal, one of the world’s largest vertically integrated
steel and mining companies, has engaged the services of EY to conduct an audit
of compliance with ethical norms and standards. This is part of Severstal’s
comprehensive programme to improve corporate processes in order to comply with
global best ESG practices.

Documentation and on-site inspections will be carried out as
part of the project. The first stage involves an analysis of existing corporate
policies and regulations, the whistleblowing and grievance procedures, along
with an analysis of the results of investigations conducted over reported
incidents of the breach of the Employee Code of Ethics, as well as the
effectiveness of relevant training programmes and ethical standards compliance
monitoring. This part of audit will cover entire company.

At the second stage, focus groups and interviews will be
conducted with employees to independently assess their awareness of the current
ethical compliance policies, the procedures for reporting violations, and the
degree to which the ethical standards established by the Company are
understood. The audit will take place between 2021 and 2022 and, at the end of
the process, a report will be provided with recommendations for improving the
ethical standards control systems in the Company.

Severstal is very proud of its corporate culture which is
founded principally on respect for people. It is extremely important for the
Company that, while working for Severstal, employees feel comfortable and safe.
Severstal has built a system that helps it set the highest ethical standards,
regularly receive feedback from employees, and prevent violations and unethical
behaviou

The Company has an Ethics Committee which is led by the
Chairman of the Board of Directors, Alexey Mordashov and reports to Severstal’s
Audit Committee. The committee examines statements concerning violations of key
Company documents, the Standards of Conduct and Anti-Corruption Policy. At the
same time, ethical norms and societal standards are constantly evolving, with
new areas emerging for consideration. For example, a few years ago Severstal
added a section on behaviour in public spaces and social networks to its
standard for employee behaviour. The Audit Committee, on behalf of the Board,
oversees all aspects of Severstal’s approach to ensuring that the Company, its
employees and suppliers adhere to the highest corporate standards and the
assurance it obtains is set out in Severstal’s Audit and Assurance Policy.
Investors and stakeholders can contribute to this process
here.   

Alexander Shevelev, CEO of Severstal, commented:

“Since we strive to become an ESG leader in Russian
industry, we understand the importance of continuously improving our corporate
procedures. This is why we turned to EY, a leader in corporate consulting. Our
plan is to regularly contract an independent consultant to audit compliance
with the Company’s ethical standards going forward”.

Severstal regularly evaluates employee engagement, analysing
all employees’ awareness of the Company’s ethical standards, corporate values
and relevant corporate documents. Mandatory training on corporate standards of
conduct and compliance with ethical standards is provided for all employees.
Additional training is also provided when corporate ethical standards are
updated.

The Company has a 24/7 unified hotline for employee
feedback. Statements, both anonymous and attributed, are accepted by phone,
e-mail or through the corporate portal 24/7. In 2020, the hotline received 590
calls. An employee can leave complaints on any issue, including personnel
records and remuneration, unethical behaviour from colleagues and managers,
security issues, social and living conditions, coronavirus pandemic, etc.

All appeals are recorded in a single database, responsible
executors are appointed and deadlines for solving the issue are put in place,
which in most cases do not exceed 14 days. Employees can also bring any
problems they have to the attention of the management through “problem solving
boards” and SMS centres, or directly to their immediate supervisor or to the
CEO, by appointment.

If an employee encounters behaviour that does not correspond
to the values of the Company, or is a violation of ethical standards, they can
contact their supervisor or, if this is not possible for any reason, report to
the Ethics Committee. In 2020, the Ethics Committee, headed by Alexey
Mordashov, Chairman of the Board of Directors of PAO Severstal, considered 43
appeals from employees. Information brought forward in 17 appeals was fully or
partially confirmed, and administrative response measures were taken. When
conducting inspections, the Company ensures maximum anonymity for the employee
who sent the request. The applicant’s personal information is not disclosed
during the verification process.


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