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Page 1: Norilsk Nickel

Business & Human Rights Resource Centre invited Norilsk Nickel to respond to the Blacksmith Institute Report “The World's Worst Polluted Places: The Top Ten of the Dirty Thirty”. Norilsk Nickel sent the following documents:

U.S. Blacksmith Institute Releases Annual List of Dirtiest Places in World

Andrey Kozenko, Marina Chistyakova, Yuliya Suhonina, Andrey 454 words

18 September 2007

Bizekon-Russica Izvestia (Russia)(c) 2007 Russica-Izvestia Information Inc. All Rights Reserved.

The U.S. ecological organization Blacksmith Institute released its annual list of the ten dirtiest places in the world. As usual, the Russian cities of Norilsk Nickel and Dzerzhinsk are on the list and, as usual, city officials there reacted sharply to this renewed attention.

Chernobyl, Ukraine; Sumgait, Azerbaijan; Linfen and Tianying, China; Sukinda and Vapi, India; La Oroya, Peru; and Kabwe, Zambia, share the list with the Russian cities. Rudnaya Pristan, Maritime Territory, which was on the institute's 2006 list, is not present in 2007.

The number of people endangered, the hazardousness of the substances involved and their health effects are considered in the compilation of the list. According to the organization 20 percent of deaths in the cities in the top ten list are caused by the effects of pollution.

Norilsk, a center of nickel mining and heavy metals processing, is polluted with particulates, sulfur dioxide, heavy metals, phenols and hydrogen sulfide. "It is getting easier to breathe in Norilsk every year," city council member Leonid Solomakha pointed out, however. Elena Kovaleva, deputy public relations director of Norilsk Nickel, around which the city was founded, stated that "Norilsk is not a garden city yet, and won't be one until 2015, when our ecological program is implemented". Blacksmith Institute noted Norilsk Nickel's cooperation with the organization and its ecological program with approval.

According to the institute, progress is already perceptible. Dzerzhinsk is one of the centers of the Russian chemicals industry (and chemical weapons industry in Soviet times). Improperly stored chemical wastes have led to pollution from Sari and VX gases, phenol, lead and a number of other substances. Acting Mayor of Dzerzhinsk Alexey Khilov stated, echoing the response of city officials last year, that the ecologist's report was made "on order". "If we found out who ordered it, we would file suit," Khilov said. He suspected that someone "does not like it that Dzerzhinsk is being considered as one of the possible location for production facilities for Peugeot Citroen and the Finnish company Stora Enso intends to invest USD 1.5-2 billion in paper production".

Khilov noted that Blacksmith Institute representatives did not conduct research in the city. An official institute spokesman said that its representatives were not allowed into the city. Oleg Mitvol, deputy director of Rosprirodnadzor, the federal environmental watchdog, noted that "It is impossible to deny the ecological problems in Norilsk and Dzerzhinsk". Greenpeace Russia representative Alexey Kiselev cast doubt on any improvements in Rudnaya Pristan and mentioned Monchegorsk and Miass as other Russian cities with critical ecological situations.

Page 2: Norilsk Nickel

Blacksmith Institute to exclude Norilsk from the list of the world’s top ten most polluted cities in 2009 (PRIME-TASS 14 Sept. 2007)

International Blacksmith Institute, an organization involved in environmental studies and relief efforts, expects Norilsk to be excluded from the list of the world’s top ten most polluted cities, says Vladimir Kuznetsov, the Institute representative in Russia.

According to Kuznetsov, major positive changes have occurred in the city of Norilsk, where production operations of Norilsk Nickel Company are the main source of pollution. “The Company reduces air pollutant emissions by 50 thousand tons annually. After the Nickel Plant removal beyond city limits in 2009, Norilsk will no longer remain in the top ten. Our data suggest that by 2015 the company will reduce emissions to maximum allowable limits (MAL) thus ensuring the city is really clean.”

Blacksmith Institute develops and implements solutions for cities where harmful pollutants affect local population. For two years the Institute has drawn up the list of the world’s top ten most polluted cities that pose severe environmental threats.

According to previous announcements, MMC Norilsk Nickel implements a comprehensive program aimed at reducing the impact of its production operations on the environment. The environmental program is incorporated in MMC Norilsk Nickel’s long-term development strategy. The program envisages substantial reduction of industrial pollution of air and water, and improvement of waste disposal operations. In order to achieve the goal MMC Norilsk Nickel is upgrading the existing production facilities, most of which were built in the 1930-s and 1940-s with no regard to environmental safety.

MMC Norilsk Nickel’s environmental program covers the time span of 2004 – 2015, and its estimated cost amounts to RUB 36 bln (about 1 bln Euros).

MMC Norilsk Nickel is one of the world’s major players in base and precious metals production, and accounts for 20% of nickel, more than 10% of cobalt and 3% of copper produced globally. Domestically, the company supplies about 96% of the country’s nickel, 55% of copper and 95% of cobalt.

Page 3: Norilsk Nickel

AN OPEN LETTER TO THE DIRECTOR OF THE BLACKSMITH INSTITUTE,

Mr RICHARD FULLER

NORILSK NICKEL WILL HAVE SPENT OVER 1 BILLION EUROS ON RESOLVING ENVIRONMENTAL ISSUES BY 2015

Dear Mr Fuller,

We have read, with great interest, the report published by the Blacksmith Institute concerning the most polluted cities in the world, which mentions the city of Norilsk, and we cannot help but express our fundamental disagreement with a number of the conclusions you have reached and the comments you have made. We are moved to do this by our desire to defend the reputation of the Mining and Metallurgical Company Norilsk Nickel from tendentious assertions and by our respect for the people who live in Norilsk and have a genuine love of the city.

At the same time, we would like to take the opportunity to inform you of Norilsk Nickel’s environmental activities, as the information referred to in the report is seriously out of date. This, we feel, is necessary in order to present an objective picture instead of the “horror story” that you mention with regard to Norilsk.

As you may be aware, a number of problems of the Russian industry have been the result and the heritage of the soviet approach to industrial activity, when the majority of large-scale industrial enterprises were the central focus of populated areas, and the industrial facilities themselves were located within the city boundaries. More often than not, such facilities were constructed without any concern for environmental protection. In those days the slogan was “Production at any cost!”

Today, the largest Russian corporations, such as Norilsk Nickel, are guided by international standards in the area of ecology, and are investing very heavily in making serious improvements to their performance regarding the environment. In fact, by 2015, Norilsk Nickel will have spent over 1 billion Euros on resolving environmental issues, which we expect to result in a significant improvement in the environmental situation. The achievement of such results demands time and very large amounts of money, since this is, first and foremost, connected with the replacement of existing technology and the reconstruction of production facilities.

Page 4: Norilsk Nickel

Noticeable improvements have been made in the course of the last 10 years, including a 25 per cent reduction in sulphur dioxide emissions (our main industrial waste) per tonne of production. Independent monitoring has already shown examples of the regeneration of nature in the areas in which we operate.

In your commentary on the report, you also speak of “no pollution control”. We trust you will see that this is untrue. The company’s environmental management system is certified in accordance with ISO 14001:2004. Norilsk Nickel keeps a very close watch on atmospheric conditions within the city boundaries, and if limits are exceeded then emissions are reduced by reducing the scale of operation in the smelting facilities.

Besides, Norilsk Nickel also conducts special health – promotion programmes and rest and recuperation at sanatoria and resorts. In 2005 around 30 per cent of workers and members of their families were able to take advantage of subsidised stays at such facilities. The average leave for a citizen of Norilsk is between 60 and 90 days. We pay particular attention to the monitoring and maintenance of the health of children, who undergo a three-month course of rest and recuperation at sanatoria and resorts every year. Our observations show that this has led to an improvement in children’s health.

We have no doubt as to the need for a report of this kind being prepared, but believe that it is wrong that it should contain such sensationalism. Facts and figures concerning the levels of pollution in the Russian cities that the report mentions are freely available and have been reported frequently in the Russian media. The improvement of environmental conditions is something to pay attention to on a continuous basis.Was the preparation of this report stimulated by genuine concerns about the state of the environment and people’s health, or were there other motives at work? If your aim was to attract attention, then you have achieved that aim – you are now known in Russia. If your aim was to create a “horror story”, then you have done even better. The recipe is a well-known one – just paint everything in dark colours.Nevertheless, I do appreciate your report for another opportunity to inform about our work on improving the environmental situation in Norilsk city.Should you genuinely wish to obtain full and objective information concerning Norilsk Nickel’s activities with regard to the environment you are welcome to contact us, obtain the necessary information from our website, or visit Norilsk city.

Sergey Chernitsyn,Director of PR DepartmentMMC Norilsk Nickel

October 24, 2006

The MMC Norilsk Nickel Press ServiceTel: (+7) 495 797 8294Fax (+7) 495 786 8394E-mail: [email protected]

Page 5: Norilsk Nickel

Protecting environment and conserving natural resources

5.1 Environmental policy and management system

Environmental priorities

The Company sets environmentally safe production and protection of the environment as top priorities. And we recognize the magnitude of challenges in this field.

The complexity and scope of the environmental problems stem from the Soviet approach to industry, under which production facilities were built without due consideration for environmental protection.

The Company’s Production Development Strategy through 2015 (reconfirmed in its Strategy through 2020) sets environmental safety improvement, air emissions and wastewater discharge reduction aimed at environmental legislation compliance, as one of the long-term objective of the Company’s business.

Pursuant to the Environmental policy approved of by the Company’s board, the top environmental protection priorities are as follows:

Gradual air emissions reduction, including sulfur dioxide and solid substances;

Gradual reduction of wastewater discharge into rivers, lakes, etc.;

Arrangement of waste disposal zones.

The Company also develops energy efficiency programs, promote alternative energy and biodiversity in the regions where it operates.

Environmental management system

The Integrated Quality Control and Environmental Management System (IQCEMS) was introduced and certified at the Head office. The first supervisory audit was carried out by a certification body in 2006. Preliminary work was conducted at the Polar Division for ISQCEM certification in 2007. ISQCEM implementation and certification is scheduled for the Company’s other business units during 2007-2008.

The Company is implementing its Environmental Management Program (2005-2007), which is aimed at achieving environmental goals and objectives.

The development of separate standards for maximum permissible emissions (MPE), maximum permissible discharges (MPD), waste generation and disposal (WGD) and limits for air emissions, water intake, wastewater discharge, and waste disposal is required for the new companies due to the restructuring of the Company and the spin-off of various subdivisions as separate legal entities in 2006 (for more details, please see Section ’About Norilsk Nickel Company’). Some of the applicable water-use licenses should be reissued in favor of the spun-off entities. These efforts required

Page 6: Norilsk Nickel

revision of the Company’s working water-use, air protection and production waste handling permits.

The Company’s environmental risks associate mainly with the necessity to comply with environmental law and also with the magnitude of the problem of sulfur dioxide emissions reduction, which requires new technological solutions for sulfur disposal and involves high costs.

Organizational structure of environmental management

The environmental department at MMC Norilsk Nickel’s Head office was established in 2003 as the Environmental Use and Protection Department. In 2005, it was reorganized as the Department for Corporate Environmental Regulation.

The Department’s main objective is to ensure that the Company’s industry-based complexes and production units operate in accordance with environmental law and ISQCEM.

The Department identifies the main areas of the corporate Environmental policy, coordinates implementation and maintenance of the Company’s environmental management system and engages with governmental environmental agencies, obtains environmental permits, and cooperates with non-governmental environmental organizations and the environmental committees of the Chamber of Commerce and the Russian Union of Industrialists and Entrepreneurs (Employers).

At the Polar Division environmental management is handled by the Industrial Environmental Protection Department, which includes the Standardization and Licensing Division (consisting of the Atmospheric Bureau, the Hydrosphere Bureau, and the Waste Handling Bureau), the Environmental Management Division, and the Environmental Use Economics Division.

An Environmental Protection Division was organized at NTEC, including the Air protection Bureau, the Water discharge and Waste Bureau.

Environmental training

In order to improve staff competence in environmental protection and to comply with environmental protection law in 2006 the Company’s personnel continued to receive trainings at annual corporate seminars and at training modules on air protection, sound water use and protection and waste management.

To upgrade the environmental training system for staff and ensure maximum coverage of the Company’s regional business units, subsidiaries and associated companies, a corporate workshop on environmental protection safety was organized in Norilsk for representatives of local environmental protection and regulatory authorities, the governments of Norilsk and the Taimyr Autonomous Area, and scientific organizations and NGOs from Norilsk, St. Petersburg and Moscow.

Page 7: Norilsk Nickel

Environmental expenditures

Total environmental protection expenditures and investments by type (in RUR mln)

s/r No.

Type of expenditure, EN30Year

2003 2004 2005 2006

1 Current environmental expenditures* 5,620.3 5,542.7 5,989.5 6,648.0

3 Environmental investments 1,521.2 3,090.2 3,840.6 938.4

*According to the state statistical reports on environmental protection 4-os

Relative decrease in environmental investments in 2006 is conditioned by the fact that a lot of design and exploration, research and development works were executed against the order of the Company. Results of the works will provide the basis for realization of perspective large-scale environmental protection projects in the coming years.

According to the state statistical reports on environmental protection 4-os the current environmental expenditures of NTEC in 2006 were 74 438,7 ths. RUR and environmental investments were 19 792.2 ths. RUR.

Awards

The Company’s environmental performance is widely respected, and in 2006 at the 2nd All-Russian Conference on New Priorities in National Environmental Policy, MMC Norilsk Nickel was recognized as the Environmental Protection Leader in Russia for active environmental protection and management to ensure steady development of the Russian economy and improve the quality of life and public health and the environmental safety of the country; seven Company employees received the Russian Environmental Shield award.

5.2 Environmental impact and performance

Sulfur dioxide emissions

The key problem the Company faces with respect to air pollution is the need to gradually reduce its emissions of sulfur dioxide which is the main air pollutant (more than 97%). The complexity of the problem solution is related to the geographic remoteness of Norilsk from developed regions of Russia, therefore, ineffective application of traditional technologies of sulfur dioxide utilization leading to formation of sulfuric aid used around the world.

Page 8: Norilsk Nickel

The Company’s Action Plan for the Gradual Reduction of Emissions through 2015 envisages a series of measures, including closure of the agglomeration and smelting workshops at the Nickel Plant, production reconstruction of the Nadezhdinsky Metals modernization or reconstruction of sulfur disposal facilities at the Nadezhdinsky Metals Factory and the Polar Division’s Copper Plant etc. In 2006, as part of the plan, technological lines No.1 and No.2 for the production of elementary sulfur using off gasses at the Copper Plant were modernized.

By increasing sulfur production using off gases, the Copper Plant cut its sulfur dioxide emissions by 0.84% y-o-y in 2006.

The Company also initiated a dialogue with stakeholders on this issue. In April 2006, the Russian Academy of Sciences’ presidium reviewed the issue Norilsk Nickel’s Environmental Problems and Possible Solutions. It was decided to develop in 2007 Scientific and Technical Program intended to ensure environmentally, economically and socially balanced gradual reduction in sulfur dioxide emissions in Norilsk to maximum allowable levels. Updated information about the Program is available at the website at http://www.rannoreko.ru.

Solid substances emissions

As a result of efforts aimed at reducing dust emissions at Polar Division units (the Nickel and Copper Plants, Nadezhdinsky Metallurgical Plant, Production Association of Enrichment Plants, etc.), emissions of solid substances fell 12.9% last year compared to 2005.

As a result of measures taken aggregate gross emissions of pollutants from the Company’s divisions fell 1.2% in 2006 compared to 2005.

Significant air emissions by type and weight

EN20 (000 tons) 2003 2004 2005 2006

Air emissions, incl. 2,020.3 2,068.0 2,011.3 1,987.2

Sulfur dioxide 1,960.0 2,011.1 1,955.3 1,938.8

Solid substances 13.9 13.1 12.4 10.8

Control of air emissions under adverse weather conditions

In Norilsk the Company has introduced a network of observation sites monitoring air quality in order to control emissions under adverse weather conditions (atmospheric inversion, still air etc.), as well as measures to reduce emissions that include limiting the processing of raw materials with high sulfur content, and eliminating equipment (agglomerators, furnaces, converters, etc.). Depending on the extent of the adverse nature of weather conditions, three

Page 9: Norilsk Nickel

modes of emission reduction are used prior to full shutdown: Mode I (15%-20% efficiency), Mode II (20%-40% efficiency), and Mode III (40%-60% efficiency).

The maximum recorded sulfur dioxide concentrations fell in 2006 1.6 times compared to 2005, 2.6 times – to 2004, 3.5 times - to 2003.

The annual average atmospheric concentration of sulfur dioxide in 2005-2006 was at the maximum allowable level (0.5 mg/Nm3) for populated areas.

Greenhouse gas emissions

In 2006 greenhouse gas emissions inventory was launched by the Company. Inventory covers production facilities located in Norilsk Industrial Region.

Water Resource Use

The Company has developed and is implementing environmental actions aimed at rational water resource management and the avoidance of pollution.

Water for household and industrial use (including drinking water) is collected from the surface of rivers and lakes (Norilsk River, Kharaelakh Reservoir, Dudinka River, Yenisei River, Lake Podkamennoye, and Lake Samsonkino), and from underground sources (Talnakh, Ergalakhsk, and Ambarninsk underground water fields).

Waste-waters are discharged into the Enisei River basin and the Norilo/Pyasinskaya water system.

In order to gradually reduce its waste-water discharges, the Polar Division is implementing an action plan to achieve maximum permissible discharges (MPD) standards over 2006-2015. Key elements of the plan include the use of modern waste-water treatment technologies, increased water-supply recirculation, modernization of cooling towers, construction of treatment facilities, modernization of facilities for treating household and drinking water, liquidation of water discharge facilities, and installation of water meters.

In 2006, nine projects for treating household, drinking, and production waste-water were developed for Company facilities, including treatment plants for mine waters at the Anhydrite and Zapolyarny Zub Mountain sites. Progress was made on treatment facilities and sewerage networks at Norilsk Railway, ‘Stroycomplect’ Plant and Norilskremont.

Page 10: Norilsk Nickel

In 2006, business units of the Polar Division and Norilskenergo were equipped with water consumption and discharge meters.

In 2006, the volume of water collected for industrial and household needs (incl. drinking water) fell 1.15% y-o-y, total water-discharge volume dropped 8.21%, and the weight of pollutants discharged with waste water declined 11.37%.

Total water withdrawal by source

EN8 2003 2004 2005 2006

Total withdrawal, ‘000 cubic meters, incl.: 299,00 295,000 281,000 277,770

Surface waters (marshes, rivers, lakes) 261,500 256,880 245,410 244,570

Underground waters 37,700 37,620 35,620 33,200

Municipal and other water supply systems - - - -

Percentage and total volume of water recycled and reused

EN10 2003 2004 2005 2006

Total volume of water recycled and reused, 000 cubic meters 1,037,002 995,449 991,646 974,639

Share in total water intake (water turnover), % 71.1 70.4 71.7 71.5

Total water discharge by quality and destination

EN21 (000 cubic meters) 2003 2004 2005 2006

Water discharge, incl.: 185,300 187,200 185,200 170,000

Inadequately treated 45,900 47,100 46,000 34,400

Polluted, untreated 37,500 39,900 39,800 34,300

Standard pure (untreated) 101,900 100,200 100,000 101,300

Page 11: Norilsk Nickel

Pollutants discharge as part of waste-water2003 г. 2004 г. 2005 г. 2006 г.

Pollutants weight as part of waste-water, 000 tons 71.40 73.40 66.40 58.85

Waste management

Notwithstanding that more than 90% of the Company’s waste is considered to be non-hazardous waste (5th hazard class), one of the Company’s environmental goals is a further decrease of development pressure of waste disposal on the environment.

EN22 (000 tons) 2003 2004 2005 2006

Waste generation 30,385.8 31,471.5 32,819.9 33,089.4

Waste use and processing at own production facilities 4,763 7,705.9 10,126.6 19,415.4

Transfer to other companies for use 101,7 70.1 30.6 29.9

Placement at own facilities 25,599.7 2,4421.8 22,950.8 13,792.1

Measures the Company uses to gradually reduce its waste generation and dumping include:

A comprehensive project to solve the problem of enrichment waste storage by building/modernizing tailing dumps and using alternative storage methods.

Expansion of the range and volume of applications for key large-tonnage production waste:

o Overburden and hard rock;

o Mine refuse;

o Waste metallurgical slag.

Expansion of the range and volume of applications and control of key consumption waste:

o Used tires and conveyor belts;

o Construction waste (broken reinforced concrete, bricks etc.);

o Silt and filter cake slump;

Page 12: Norilsk Nickel

o Scavenge oil, wood-processing waste, etc.

Improvement of the waste generation, storage and disposal monitoring system.

In 2006, the Company took additional steps to reduce the negative environmental impact of its production waste via safe storage of ore enrichment waste and preventing pollutants from entering the soil and water. Projects for these purposes include:

Expansion of the Lebyazhie tailings dump; a second storage facility for tailings generated at the Norilsk and Talnakh enrichment plants;

Reconstruction of the Lebyazhie tailings dump by raising dam height to +90.0m;

Upgrading the Industrial dump No. 1 at the Nickel Works’ chlorine/cobalt unit.

By increasing the scope of waste use and disposal, the Company has been gradually reducing the total volume of stored waste year-by-year.

Power savings and alternative sources of energy

The Company devotes considerable attention to initiatives aimed at incorporating power-saving goods and services or those that rely in renewable energy, thereby reducing overall energy consumption, which in turn helps the Company cut costs.

Over the last five years, the Company has supported domestic research on hydrogen power and fuels. In 2003, MMC Norilsk Nickel signed an agreement with the Russian Academy of Sciences for financing development of this field. The scope of funding for 2003-2006 was USD120mn, and the project has moved to the commercialization stage and the development of pilot and mass production technologies. In 2005, Norilsk Nickel established the New Energy Projects company to develop pilot commercial technologies for production of fuel elements and hydrogen electrochemical generators to use them.

The organizational and technical efforts undertaken in 2003/2006 to save fuel and energy, incentivise personnel, and improve the efficiency of hydro power plants has allowed the Company to reduce the fuel consumption for electricity release from 281.6 g/kWh in 2003 to 278.1 g/kWh in 2006 (1.2%), replace NTEC gas-based electricity with hydro in the amount of 381,600 GJ, which is equivalent to reducing fuel consumption by 30,316 tons of coal equivalent, or 2.6% compared to 2003.

Direct energy consumption at the Polar Division by primary energy sourceEN3 (GJ) 2003 2004 2005 2006

Use of direct non-renewable energy resources*, incl: 110278116.8 112606651.9 107160018.4 108482730.7

Natural gas 110260906.8 112526451.5 107131680.6 108259927.8 Diesel fuel 17209.98 80200.36 28337.82 222802.86

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Indirect energy consumption by primary sources

EN4(GJ) 2003 2004 2005 2006

Electricity purchased and consumed from sources outside the Polar Division, incl:

14774202 14580358 14635297 15149279

From hydro plants 14774202 14580358 14635297 15149279

Energy saved due to conservation and efficiency improvements

EN5*,(GJ) 2003 2004 2005 2006

Total energy saved through lower consumption and higher efficiency, incl:

164066 96174 67572 62831

Production process upgrades 6212 1 38 -

Equipment reconfiguration or replacement 22199 8710 7762 5652

Changes in personnel behavior 135656 87463 59773 57179

Note: *for production facilities in Norilsk Industrial Region (thermal power plants 1,2,3, boiler No. 1

5.3 Biodiversity

MMC Norilsk Nickel’s efforts to protect the environment are not limited to addressing industrial pollution issues. Nature conservation and environmental improvement in the regions where it works are equally important to the Company.

Norilsk Nickel invests in nature conservation technologies and is shifting to global environmental protection standards, while supporting organizations helping to protect the flora and fauna of the Taimyr Peninsula.

The General Partnership and Cooperation Agreement between the Company and the Taimyr Autonomous Area (TAA) government envisages implementation of the Protection and Restoration of Lands and Natural Resources in the Taimyr (Dolgano-Nenets) Autonomous Area program in 2004-2007. Funded by the Company and the TAA, the program includes:

Environmental monitoring;

Page 14: Norilsk Nickel

Inventory, collection, disposal, and processing of industrial waste;

Inventory of deer pastures and development of scientifically based recommendations on their management and conservation;

Creating a general register of Taimyr flora and fauna and developing methods for their use and protection;

Forest reclamation;

Financial and technical support for observation sites on protected nature zones;

Environmental education.

R&D programs to preserve biodiversity in the Putoran (Taimyr Peninsula) and Big Arctic (Taimyr Peninsula) national reserves receive financial support from the Company.

The main objectives of the Putoran reserve include protecting mountain, lake, and taiga landscapes, unique flora, and rare species of animals such as the Putoran big-horn (included in the Russian Red Book) and the world’s largest population of wild reindeer, who winters on the reserve (which covers 1,887,000 ha). Since 2006, the Company and the Putoran National Reserve have been studying and protecting the lesser white-fronted goose, which nests on the reserve (see http://gis-lab.info/projects/piskulka.html and http://www.northstarst.com).

Jointly with the non-profit Working Group for North Eastern Geese, the Company is helping to implement the Putoran Tablelands Project1 aimed at preserving rare and endangered species of birds with habitat on the Taimyr Peninsula, including the lesser white-fronted goose, which is included in the Global Red Book and the Russian Red Book. The lesser white-fronted goose is used as the symbol of the Company’s environmental programs.

1 The Putoran tableland was included in UNESCO’s Global Cultural and Natural Legacy list in 2003.

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From: Ковалева Е.В. [mailto:[email protected]] Sent: 27 September 2007 14:07To: Sandra CossartCc: Петров И.И.Subject: >>: Fw: TR: Invitation to respond to Blacksmith Institute report

Subject: >>: Fw: TR: Invitation to respond to Blacksmith Institute report

Уважаемые Кристофер и Сандра,

Спасибо за внимание к ГМК "Норильский никель" и возможность высказать мнение по такому важному для нас вопросу как экология.

Отвечая на ваши вопросы мы хотели бы остановиться на следующем. Нам сложно судить об объективности выводов экспертов Blacksmith Institute, поскольку у нас не было возможности ознакомиться с методикой составления списка наиболее загрязенных мест планеты. Кроме того, мы не беремся судить об объективности и достоверности данных, которые публикуются на сайте Blacksmith Institute, поскольку в 2006 году столкнулись с использованием устаревших и неподтвержденных данных в части Норильска. Об этом мы написали в письме, адресованном господину Фуллеру, с которым Вы можете ознакомиться как на нашем сайте, так и в приложении к настоящему письму.

(See attached file: 061024 Blacksmith Institute Eng.doc)

Вместе с тем, относясь с уважением к деятельности неправительственных оганизаций, в открытом письме мы пригласили г-на Фуллера посетить Норильск и получить информацию об экологической ситуации в городе и мерах по ее улучшению, принимаемых ГМК "Норильский никель".

Поездка представителя по России Владимира Кузнецова состоялась в июле 2007 года, что частично нашло отражение в последнем отчете Blacksmith Institute.В своих комментариях российскому агентству Прайм-ТАСС по итогам поездки Владимир Кузнецов сообщил, что Blacksmith Institute исключит Норильск из перечня десяти наиболее загрязненных мест планеты в 2009 году после того, как будет завершен один из важных этапов программы "Норильского никеля" по улучшению экологической ситуации в городе - перенесен за пределы Норильска плавильный цех одного из заводов Компании. Полный текст сообщения приведен ниже.

(See attached file: Прайм.doc)(See attached file: Прайм рус.doc)(See attached file: russica.doc)

Российская промышленность сейчас стремится приблизиться к международным стандартам экологической безопасности, наверстать упущенное в советские годы. "Норильский никель", как и многие другие предприятия, вкладывает много денег в модернизацию производства и переход на дружественные природе технологии. Мы воспринимаем критику конструктивно, как проявление внимания к нашей деятельности и жизни городов и поселков, в которых живут

Page 16: Norilsk Nickel

наши сотрудники. Вместе с тем, нам хотелось бы, чтобы наши усилия по улучшению экологической ситуации также находили отражение. По крайней мере для того, чтобы картина была объективной.

Мы будем рады ответить на все Ваши вопросы и в дальнейшем. Пожалуйста, обращайтесь к нам, если что-то Вам будет непонятно. Мы готовы направить Вам это письмо на английском языке, если это необходимо.

Более подробно с информацией об экологической программе "Норильского никеля" Вы можете познакомиться на нашем корпоративном сайте www.nornik.ru или в прилагаемой информационной справке из Социального отчета ГМК "Норильский никель" за 2006 год.

(See attached file: 5_Охрана окружающей среды_Eng окончат.rtf)

С уважением,

Елена Ковалева

заместитель ДиректораДепартамента общественных связейГМК "Норильский никель"

+7 (495) 785 58 00