November 29, 2021
Severstal, one of the world’s leading vertically integrated
steel and mining companies, implemented Clawbacks & Malus policy. The
Policy has been developed to eliminate the risk of intentional occurrence of
financial misstatements or other exceptional circumstances arising from the
actions of key managers.
Key TOP-management directors’ incentive arrangements are
subject to “malus”, under which the Remuneration сommittee may adjust LTI
payments downwards to reflect the director’s actions, including the
misstatement of results, misconduct or reputational damage.
The Remuneration сommittee does not operate clawback
arrangements on directors’ remuneration on the basis that such arrangements
would not be enforceable under the Russian Labour Code. The сommittee will keep
this under review and should the Russian Labour Code change, it will revisit
the inclusion of such provisions in the Key TOP-management directors’ LTI