Human rights
Human rights: theory and practice
Childrens Rights and Wellbeing Our Approach
Polyus is committed to protecting human rights and aims to ensure that all employees have a comfortable working environment and opportunities for career growth. The Company prohibits any form of forced and child labor as well as any form of discrimination.
In 2021, Polyus conducted its first comprehensive human rights due diligence, which led to the development of an action plan to improve the management of human rights risks for 2022-2024. This plan includes a comprehensive human rights compliance assessment, the development of a social and cultural workforce diversity initiative or joining an existing initiative, the provision of staff training and support for stakeholders in this area as well as the updating and publication of internal documents on human rights compliance and related issues.
The company assesses human rights violation risks within the scope of its activities. The most recent assessment was conducted based on the principles of the UN General Assembly’s Universal Declaration of Human Rights and the ICMM principles. The project was implemented using the Human Rights Impact Assessment (HRIA) methodology.
As a part or this process, Polyus reviewed its corporate documents, leading industry standards, and corporate risk register. The assessment process included consultations and interviews with Company employees. Based on the analysis results, human rights compliance KPIs were developed, and a risk map was drafted, followed by the prioritization and integration of human rights-related risks into the corporate-wide risk register.
It was established that Polyus complies with the core of the UN Guiding Principles and meets all ICMM requirements. The assessment identified and ranked 25 human rights-related risks and confirmed the absence of any material human rights risks at the Company level.
The child-related risk was assessed as part of the human rights due diligence process and was found to be non-material.
In 2025, Polyus identified no risk of child labor occurrences within its business units; no risk assessment was conducted among contractors.
No confirmed cases of human rights violations or discrimination were recorded.
Polyus revised its Human Rights Policy in 2022. The Company’s approaches to managing the impact on human rights were summarized and amended, and internal procedures were established. Polyus also reaffirms its commitments to protecting the human rights of all stakeholders in general, as well as additional commitments to individual groups, such as employees, business partners and local communities.
The Company intends to regularly review and improve its practices and will update the list of human rights risks every two years. It will also reassess annually the significance of these risks as part of corporate risk management. Furthermore, Polyus undertakes to assess compliance with the Human Rights Policy every two years.
A distance learning course, including theory and practical sections, was developed to enhance awareness of the Policy’s principles by Company personnel. All employees, including those newly hired, shall undergo awareness training on compliance with the Human Rights Policy.
Following best international practice, Polyus intends to encourage diversity and inclusion at all hierarchy levels and denounce discrimination in any form on the grounds of race, gender, nationality, ethnicity or social background, skin color, language, age, physical and mental abilities, religion, culture, social and economic status, experience and education. The Company reaffirms its commitments in the Diversity and Inclusion Position Statement, which was approved by the CEO and disclosed in 2022.
Polyus expects its business partners to act responsibly in terms of human rights and offers cooperation in building a sustainable supply chain that considers human rights equally with environmental issues and other social aspects. The Company requires that contractors fill in a human rights questionnaire based on their legitimate activities. By doing this, contractors confirm that they prohibit any forced and child labor and comply with occupational safety requirements.
In 2025, Polyus assessed the ESG compliance of its key suppliers based on the guidelines of the EKG Rating and the National ESG Alliance. The questionnaire included inquiries regarding the counterparties' environmental impact,
The assessment covered the Company’s key suppliers, whose procurement volume accounts for 21% of the total planned procurement amount for 2025. Based on the analysis results, the evaluated Polyus suppliers scored between 50 and 80 points on a 0–100 scale. Feedback was provided to all counterparties to help them improve their performance in the future.
These findings help identify potential
Stakeholder Engagement Policy
Standard for Engagement with Indigenous Peoples
Resettlement Standard
Polyus pays close attention to the regions of its operation. The Company creates new jobs and ensures equal employment opportunities for local residents, arranges a career guidance program for school students and undergraduates, and provides equal opportunities for candidates to participate in the Company’s educational programs.
Polyus undertakes to consider the culture, values and traditions of local communities, including those of indigenous people, and mitigate the impact of its operations on them, particularly in matters related to human rights. The Company regularly consults with indigenous people about issues regarding its operations, and their representatives can contact the Company through its Hotline.
Polyus promptly informs local residents, holds public hearings and always obtains free, preliminary and informed consent from representatives of indigenous peoples before starting activities that have public significance and may affect their rights and freedom. In case of involuntary resettlement, Polyus undertakes to make its best efforts to compensate for any damage.
Polyus has established and operates a Hotline for receiving feedback. This is a communication channel designed for external and internal stakeholders to submit and review grievances, identify and prevent violations of human rights, including gender issues, and standards of business conduct.
Reporting a violation:
- For all stakeholders:
- Email: code@polyus.com;
- Phone: 8(800) 301-54-44 (available 24/7);
- Using the special corporate web page.
- Additionally, for employees:
- Contact Polyus’ Hotline via the corporate website;
- Contact your line manager or ethics coordinators.
Grievances are automatically processed and forwarded to the relevant persons based on their contents. The Company guarantees the confidentiality of whistleblowers and will not impose any sanctions for the good faith submission of information to the Hotline.
Number of signed and anonymous grievances received via the Hotline, 2018-2025
