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RUSAL Business Partner Code of Conduct

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United Group RUSAL (hereinafter - the United Group) is the world's largest aluminium producer, the leader of one of the largest and fastest growing industries in the world.

Business principles of the United Group are based on corporate values and approaches to sustainable development issues, which are used in business operations of the Members of the United Group.

The United Group operates in strict compliance with all statutory requirements and standards, in accordance with the principles of honesty and integrity; constantly working to ensure that the employees of the United Group adhere to social, environmental and ethical standards, and requires all business partners to respect these standards and pursue them in their business activity.

The United Group Business Partner Code of Conduct (hereinafter – the Code) defines the principles and requirements of the Members of the United Group to their suppliers of goods, work and services as well as business intermediaries, consultants and other business partners.

The principles and requirements of the Code are based on the Corporate Code of Ethics of the United Group and on the principles of the UN Global Compact.

Main terms used in this Code are defined in Appendix 1 hereto, unless otherwise expressly stated or the context otherwise requires.

Sustainable development

Sustainable development is a long-term vision, which requires deliberate systematic approach that takes into account all factors affecting the existence of secure and prosperous future.

The United Group expects from its Business Partners consistent implementation in their activity of the following principles of sustainable business development:

  • Integrity and honesty in business activity;
  • Responsibility in public relations and government relations;
  • Occupational safety and human rights protection;
  • Health and industrial safety;
  • Environmental protection;
  • Ensuring the quality and safety of goods, work and services.

Integrity and honesty in business activity

The United Group assumes that Business Partners in their business activity represent and warrant the following:

  • Fulfilment of assumed obligations;
  • interest in sustainable development of their business and the business of their business partners;
  • commitment to long-term and mutually beneficial cooperation, establishment of business relations with partners based on respect, trust, honesty and integrity;
  • care about reputation, strict compliance with the standards and rules of business ethics and law;
  • compliance with the prohibition of accepting and/or making illicit payments in any form;
  • compliance with the prohibition of use of unethical and/or unfair methods of influence on their business partners and/or competitors;
  • operation without corruption, including not offering, not soliciting, not giving or accepting, directly or indirectly, any privileges for personal gain from any person, if it goes beyond accepted standards of business relations such as an entertainment expenses or reasonable hospitality;
  • doing business with those business partners that have a good reputation and are engaged in legitimate business, whose funds come from legitimate sources;
  • awareness of facts and information about Business Partners and/or, to the extent that it can or should be known to Business Partners, its substantial shareholders, members and/or persons managing or influencing the operation of the Business Partner regarding the inclusion of these persons in sanction lists, participation in sanction or corruption proceedings or those in relation to environmental or labour violations.

Responsibility in public relations and government relations

The United Group assumes that Business Partners in their relations with public and government represent and warrant the following:

  • compliance with all laws and requirements applicable to their activity in each country of operation;
  • compliance with anti-money laundering legislation;
  • full and timely tax payments;
  • no attempts of dishonest influence on the decisions made by governmental authorities or officers;
  • prohibition of direct or indirect participation in political movements or organisations;
  • development and support of social initiatives aimed at the improvement of the quality of life in the regions of operation;
  • ensuring the production and use of minerals from the sources located in the territories not related to armed conflicts;
  • no production, supply or use in the production process of conflict minerals, the proceeds from the sale of which could be used to fund violence in the country of production.

Occupational safety and human rights protection

The United Group assumes that Business Partners represent and warrant the protection of human rights, compliance with labour regulations and request such compliance from their business partners:

  • Child labour
    Business partners confirm that they do not use child labour and comply with the requirements of applicable law establishing minimum age, the attainment of which is necessary for employment.
  • Voluntary employment. Prohibition of forced labour
    Business Partners guarantee voluntary employment and prohibition of the use of slave labour, hostages, as well as forced labour, labour based on debt or any form of forced labour, slavery and human trafficking.
    Business Partners confirm compliance with prohibition of prison labour. If a Business Partner hires this kind of workers in accordance with applicable labour laws, such activity is not considered a violation of the Code.
    Business Partners guarantee the prohibition of any use or purchase of raw materials or products, the production of which is related to forced labour or human trafficking.
  • Working hours. Salary and wages
    Business Partner represents and warrants compliance with all relevant legislation concerning normal working hours, rest periods, overtime, wage levels, working day, compensations, benefits, overtime and rest days.
  • Migrant workers
    Business Partner represents and warrants the ensuring of working conditions (wages, working hours, etc.) for migrant workers in accordance with the requirements of applicable law and similar working conditions as those of other employees performing similar duties.
    Business Partner confirms the verification of the legal status of migrant workers, and employment of those migrant workers only, who have a valid work permit issued by authorised state bodies.
    Business Partner confirms that it takes into account the special circumstances of legal, social and cultural nature faced by migrant workers, and ensures a decent and respectful treatment of such workers in accordance with the same standards that apply to other employees.
  • Disciplinary sanctions
    Business Partner represents and warrants respecting the dignity of all employees and adherence to local laws in the area of regulation of disciplinary sanctions, creation of conditions necessary for compliance by employees with work discipline, with all applicable disciplinary sanctions documented.
  • Fair and equal treatment, prevention of discrimination and prevention of violence
    Business Partner represents and warrants the respect for individual freedom, human rights and dignity, confidence in the employees and giving everyone equal opportunities.
    Business Partner represents and warrants that the procedure and conditions of employment, including hiring, training, working conditions, salaries, bonuses, promotion, discipline, dismissal or retirement, are determined by qualification, performance, skills and experience of a certain worker only.
    Business partner represents and warrants preventing any form of discrimination or harassment in the workplace, as well as behaviour that would be regarded as offensive and unacceptable by most people.
    Business Partner represents and warrants that it respects the rights of its employees to form trade unions and join them, as well as to bargain collectively in a lawful and peaceful manner in accordance with applicable law, the freedom of association, participation in the political activities, which they see fit, in their own time and at their own expense.
  • Rights of local communities in the framework of mining and production
    Business Partner represents and warrants that it takes into account the cultural sensitivities of the countries and regions of operation during decision-making and performance of its activities.
    A Business Partner carrying out mining operations or organisation of production facilities confirms that it takes effective action to reduce negative consequences for local communities caused by the need for resettlement from released lands.

Health and industrial safety

The United Group assumes that the Business Partner represents and warrants compliance with the applicable laws in the field of health care, industrial and fire safety, provides working conditions safe for life and health, takes measures to prevent occupational injuries.

Environmental protection

The United Group assumes that the Business Partner represents and warrants:

  • compliance with all requirements established by applicable laws in the area of environmental protection and improvement of environmental performance;
  • takes all necessary action required to reduce the impact on the environment by reducing greenhouse gas emissions, implementing energy efficiency projects and using resource-saving technologies, including the reduction of consumption of natural resources, such as water, paper and packaging;
  • rehabilitation and reclamation of mined lands and restoration of biodiversity after the termination of operation of production and mining facilities;
  • proper handling of hazardous materials and waste management, their storage, planning and disposal in compliance with accepted safety standards.

Quality and safety of goods, work and services

The United Group assumes that the Business Partners confirm that all goods, work and services delivered, performed or provided by the Business Partners to the Members of the United Group meet the mandatory standards of quality and safety in line with the current applicable law.

Final provisions

The United Group assumes that:

  • Business Partners adhere to Code provisions after the establishment of the legal relationship.
  • Business Partners endeavour to ensure compliance with Code principles by their direct and indirect business partners and to verify compliance with the Code by their business partners.
  • Business Partners recognise that all existing and future agreements and business relationships with the Members of the United Group are subject to Code provisions.

Members of the United Group are entitled to verify compliance with the Code of the Business Parties in line with the requirements of applicable law.