Polymetal has a Hotline, which is used to receive reports of impending or committed acts of corruption, theft, bribery, fraud, abuse of power, violation of rights of employees, participants in procurement, contractors and suppliers, as well as cases of harassment, insults, threats, violence, moral and psychological abuse, alcohol or drug intoxication, disclosure or misuse of confidential information, and violations of applicable laws and regulations. In addition, the Hotline can be used by relatives of Polymetal employees and contractors, if they lose contact with such employed relatives for a long period of time and in other difficult situations.
The incoming information is processed on-line during business hours and in the morning of the following business day, if a message is received at night or on a weekend. All phone messages are recorded by an answering machine.
All messages are treated and thoroughly investigated on a confidential basis and without bias. Best efforts are used to maintain the anonymity of such a message, if requested by a whistleblower. In order to receive a confidential feedback, the whistleblower should identify himself/herself and provide contact information.
Polymetal, in its turn, guarantees that anyone using the Hotline and reporting any information in good faith shall not be sanctioned for whistleblowing. If any adverse measures have been taken against the whistleblower for the disclosure of information, he/she is entitled to directly contact the Audit Committee of the Polymetal International Board via e-mail: email@example.com.
At the same time, the Hotline use, does not exempt a Polymetal employee from disciplinary and other sanctions applied to him/her, in strict adherence to the law and in-house regulations, due to poor performance, violation of work schedule, and on other legal grounds.
An employee, who knowingly provides false information or makes a statement about the alleged sanctions applied to him/her due to information disclosure, if these facts are not confirmed by the investigation, will be subjected to disciplinary actions up to and including termination of employment in accordance with applicable law and in-house regulations. Exception to the above is when an employee provides information he/she, acting in good faith, believed to be reliable and reasonable, but which was not recognized as such in the course of the investigation.