MMK adopts a Code of Ethics

This fundamental document sets out corporate norms, principles and requirements that form the basis of ethical business conduct and regulates the behaviour of employees and their interactions within the team, as well as relationships between employees and customers, business partners, investors, government agencies, competitors and society.

Since 2005, there have been several editions of the MMK Code of Business Ethics. The new document applies both to employees of structural subdivisions of MMK and to companies of the MMK Group. Each Group employee pledges to understand, respect and adhere to the uniform conditions and requirements of the Code in their professional activities.

The document defines MMK’s mission – to be a reliable supplier of high-quality steel products that meet the needs of Russian customers, to strive to develop the Company into a world leader in efficiency, to create high added value for shareholders and to improve the quality of life for its employees and people living in the areas where the Company’s assets are located.

The Company’s corporate culture is based on the following values:

∙ Honesty in relations with colleagues and partners, as well as in providing information;

∙ Respect for the rights and interests of employees, for customer requirements, and for the terms of interaction put forward by business partners and society;

∙ Equity, which implies fair remuneration according to results and equal opportunities for professional growth;

∙ Efficiency and stable achievement of optimum results;

∙ Care, which manifests itself in the Group’s desire to protect employees and society fr om any harm to life and health, and to preserve the environment.

The MMK Code of Ethics sets out in detail the Group’s ethical principles and standards related to internal and external relations, relations with public authorities and society as a whole. Additionally, the document sets out the principles that should guide the Group’s employees when using the Company’s resources, as well as in an event wh ere a conflict of interest occurs. The Code defines the Group’s principles in relation to health, industrial safety and the environment; the principles of information disclosure; and employee responsibilities for managing occupational and environmental risks.

Employees are initially familiarised with the Code by the heads of structural divisions with an acknowledgement form during the hiring process. Each employee of the Group, regardless of their position and status, agrees to be guided by the provisions of the Code in their work and to take personal responsibility for any violations of the ethical principles and requirements of the Code, as well as for not reporting Code violations that have become known to them.