Management approach

We regard sustainability as an essential element of our activities. It is an investment in society as well as in our own future. That’s why we firmly believe that anchoring sustainability as part of our business strategy will lead to economic, environmental and social progress.

Polymetal’s overall approach to sustainability is guided by the UN Global Compact, to which the company has been a signatory since 2009. In addition, our Code of Conduct guides the behaviour of all employees in relation to their colleagues, local communities and the environment. At an operational level, we have a suite of procedures and policies that are published in line with national regulatory and international standards.

All of these taken together influence our approach to the provision of high quality jobs, secure and safe employment, employee wellbeing and access to professional development. They also influence the way that we communicate and consult with our investors, communities, government bodies and NGOs and suppliers in our areas of operation and the systems we have in place to monitor and improve environmental performance.

Сompliance

The Group’s financial and legal teams monitor current legislation and proposed changes in all jurisdictions where Group companies operate, and incorporate these into the practice, involving leading external experts where appropriate

Dialogue

Our directors engage in communication with shareholders’ CSR teams to better understand their approach to governance and sustainability.

Effectiveness

The Audit and Risk Committee helps the Board to monitor the integrity of the Group’s financial statements; reviews the effectiveness of the Group’s system of internal controls and risk management systems.

Ethical conduct

The Safety and Sustainability Committee monitors the Group’s social, ethical, environmental and safety performance, and oversees all sustainable development issues on behalf of the Board.

Stewardship

The Chief Sustainability Officer coordinates sustainability initiatives and activities to ensure transparency and long-term value for investors and other stakeholders.

Fairness

In our approach to human resource development, we aim to attract and retain the very best professionals by providing an inclusive, fair and enabling working environment.

We strongly believe that maintaining high corporate governance standards is essential in creating sustainable shareholder value.

Since our original listing in 2007 and subsequent relisting on London’s Main Market, we have adhered to the highest standards of corporate governance. Under the leadership of a reputable, experienced and diverse Board, we have been able to achieve superior shareholder returns and create a Company where continuous improvement and strategic agility is deeply engrained in the corporate culture

The Board defines business strategy, assesses risks and monitors performance.

The Remuneration Committee is responsible for Group remuneration policy, and for setting pay levels and bonuses for senior management in line with individual performance. Ensures safety KPIs are included in remuneration package.

The Nomination Committee ensures a balance of skills, knowledge, independence, experience and diversity on the Board and its committees.

The Safety and Sustainability Committee monitors the Group’s social, ethical, environmental and safety performance, and oversees all sustainable development issues on behalf of the Board.

The Group CEO takes ultimate responsibility for delivering on strategy and operating performance.

The Technical Council agrees strategy and tactical implementation across the business.

The Chief Sustainability Officer coordinates sustainability initiatives and activities to ensure transparency and long-term value for investors and other stakeholders.

Human Resources
The Human Resources Director defines and monitors employment contracts and employee performance.

Communications
The Communications and PR Director is responsible for identifying and engaging with the majority of external stakeholders, including government and regional authorities, local communities and NGOs.

Environment
The Chief Operating Officer supported by our HSE department defines high-priority environmental issues and ensures full compliance.

Health and Safety
The Chief Operating Officer together with our HSE department sets targets and is responsible for performance in this area.

Operations
Our operating mines and development properties have heads of Operations, Human Resources, Environment and Health and Safety, who implement and monitor corporate systems, supported by specialist PR and engineering teams.

As a premium UK-listed company, Polymetal International is compliant with the UK Corporate Governance Code (the UK Code). As well as complying with the UK Code, the Company has complied with all applicable regulations of the Moscow Stock Exchange and Russian securities laws since its shares were admitted for secondary trading on the Moscow Exchange.

Polymetal Group and the Board of Directors of Polymetal International plc are committed to ensuring adherence to the highest legal and ethical standards. This must be reflected in every aspect of the way in which we operate. Bribery is a criminal offence in the countries in which the Group operates, and corrupt acts expose the Group and its employees to the risk of prosecution, fines and imprisonment, as well as endangering Polymetal’s reputation. Polymetal Group has adopted anti-bribery policies and procedures. Principles set out by these policies and procedures extend across all of Group’s business dealings, and in all countries and territories in which the Group operates and applies to employees of the Group as well as relevant business partners and other engaged individuals and entities. The Board attaches the utmost importance to this these policies and procedures and applies a «zero tolerance» approach to acts of bribery and corruption by any employees or by business partners working on our behalf and prohibits the payment, offer or authorisation of bribes, the receipt or acceptance of a bribe, and the payment, offer or promise to pay any facilitating payments. Any breach of this policy will be regarded as a serious matter by Polymetal and is likely to result in disciplinary action.

As part of the implementation of internal procedures to comply with the UK Bribery Act, the Group has implemented a formalised Whistleblower Policy which describes processes in place for staff to communicate, in confidence, concerns about possible improprieties, unethical or illegal activities and ensures that arrangements are in place for independent investigation of such matters.

Contact details

Polymetal International plc	security@polymetalinternational.com.cy
Polymetal Group companies	sb@polymetal.am sb@polymetal.kz sb@polymetal.ru +7.800.555.1727 (confidential hotline)

Polymetal is fully committed to being transparent about all payments. Company supports EITI in those countries of our operation which adhere to the EITI Standard (Kazakhstan)

Kazakhstan joined the Extractive Industries Transparency Initiative (EITI) in 2005 and in 2013 was granted “EITI Compliant” status. The Company’s mines/ operations in this country (Kyzyl, Varvara, Komar) submit annual audited EITI reporting on a regular basis. For more information visit https://eiti.org.

Our operations in Russia do not support the EITI since Russia has not adhered to the Extractive Industry Transparency Initiative.

The Group conducts all business activities, including those related to mergers, acquisitions and disposals, in accordance with the highest ethical and legal standards set in a range of Group’s policies on Human Rights, Community Engagement, HSE, Environment and Code of Conduct that cover ESG risk management as well as environmental, governance, social and human rights issues. These policies have been approved by the Board of Directors and are regularly monitored by its Safety and Sustainability Committee.