Statement of management’s responsibilities for the preparation and approval of the consolidated financial statements for the years ended 31 December 2019, 2018 and 2017

The following statement, which should be read in conjunction with the auditors’ responsibility stated in the auditors’ report, is made with a view to distinguishing the respective responsibilities of management and those of the auditors in relation to the consolidated financial statements of Public Joint Stock Company “Mining and Metallurgical Company “Norilsk Nickel” and its subsidiaries (the “Group”).

Management of the Group is responsible for the preparation of the consolidated financial statements that present fairly in all material aspects the consolidated financial position of the Group at 31 December 2019, 2018 and 2017 and consolidated statements of income, comprehensive income, cash flows and changes in equity for the years ended 31 December 2019, 2018 and 2017, in accordance with International Financial Reporting Standards (“IFRS”).

In preparing the consolidated financial statements, management is responsible for:

• selecting suitable accounting principles and applying them consistently
• making judgements and estimates that are reasonable and prudent
• stating whether IFRS have been followed, subject to any material departures disclosed and explained in the consolidated financial statements; and
• preparing the consolidated financial statements on a going concern basis, unless it is inappropriate to presume that the Group will continue in business for the foreseeable future.

Management, within its competencies, is also responsible for:

• designing, implementing and maintaining an effective system of internal controls throughout the Group
• maintaining statutory accounting records in compliance with local legislation and accounting standards in the respective jurisdictions in which the Group operates
• taking steps to safeguard the assets of the Group; and
• detecting and preventing fraud and other irregularities.

The consolidated financial statements for the years ended 31 December 2019, 2018 and 2017 were approved by:

Moscow, Russia
26 February 2020