Goal of Code of Corporate Ethics

The Company's Code of Corporate Ethics (hereinafter - the "Code") is based on the Code of Corporate Ethics adopted by RUSAL in 2005 and is intended to be used by the Company:

  • to give each employee an idea of the Company's mission, values and principles;
  • to set standards of ethical behaviour that define relationships within the Company's team, with customers, business partners, government bodies, the public and competitors;
  • to serve as a tool to prevent possible violations and conflict situations, and to develop a corporate culture based on high ethical standards.

By accepting the Code, the Company confirms its intention to follow high ethical standards of business practice.

We view the provisions and requirements of the Code as one for all and commit ourselves to respecting, implementing and considering them in our daily activities.

Implementation of the Code

The Code conditions are applicable to RUSAL and to all companies controlled by RUSAL. The terms RUSAL and "Company" used in this Code refer to RUSAL and each member of the RUSAL Group; and the term "Board of Directors" refers to the RUSAL Board of Directors.

The Code provisions also apply to agents, consultants and other business partners when they represent or act on behalf of the Company or the RUSAL Group of Companies.

Contents of the Code

The Code is based on the principles of the Corporate Ethics Code adopted by RUSAL on 7 February 2005. Since then, the Code has been supplemented with several new sections. It provides more detailed explanations of certain provisions and requirements than previous versions of the document. The text has been updated to reflect internal and external changes that have occurred in the Company within two years since the first adoption of the Code. These changes are in line with the new requirements to RUSAL and its employees from business partners, government authorities and the public. In addition, the Code was amended to reflect RUSAL's new status following the acquisition of SUAL and Glencore's assets in March 2007.

The Code contains the following paragraphs and sections:

1. Mission of RUSAL

Our mission is to become the most efficient aluminum company in the world, which we and our children can be proud of.

Through RUSAL's success - to the prosperity of each of us and our society.

2. Values of RUSAL

In our Company, we particularly value:

  • Respect for the personal rights and interests of our employees, the demands of our clients, the terms and conditions of cooperation put forward by business partners and society.
  • Fairness, which implies remuneration in accordance with the results achieved and equal conditions for professional growth.
  • Integrity in relations and provision of information necessary for our work.
  • Efficiency as the stable achievement of maximum results in everything we do.
  • The courage to confront what we do not accept, and to take personal responsibility for the consequences of our own decisions.
  • The care we take to protect people from any harm to their lives and health and to preserve our environment.
  • Confidence in our employees that allows us to delegate authority and responsibility for making and implementing decisions.

Following our values, we will be able to maintain the kind of corporate culture that is necessary to achieve the highest level of all our business aspirations.

Our values are reflected in our success, binding on us and offered to all who work with us. We do not retreat from our values to make a profit. We see them as a link in all our activities and expect the same in our relationships with our business partners.

RUSAL's Ethical Principles and Standards

- "Internal relations" (relations with employees)
- "External relations" (relations with investors, clients, business partners, competitors, government agencies and society; gifts and hospitality)
- “Resource usage”
- "Health, Safety and Environment"
- "Efficiency and profitability"
- "Conflict of interest"

4. Enforcement of the Code

The terms of the Code of Corporate Ethics apply to all employees of each company within RUSAL who undertake to be guided in their work regardless of their position or status. When applying to the Company, employees should be familiarised with the Code and trained in its application in their daily work. To this end, and in order to effectively and universally implement the Code, the Company has developed a corporate ethics training course that:

  • clarifies the provisions of the Code, taking into account existing practices in its application;
  • is updated from time to time according to the requirements;
  • is made for all employees regardless of their term of employment with the Company.

If you're not sure:

  • in the ethics of their actions or decisions,
  • in the ethics of the actions or decisions of their colleagues and managers,
  • in accordance of your actions or decisions to the values and principles of the Company, you should seek assistance from your line manager or the Corporate Ethics Officer who operates in each enterprise of the Company.

If your colleague is behaving unethically, you should warn him or her about this by indicating which principle of the Code he or she is violating. Any issues in dispute should be resolved with your supervisor or the Corporate Ethics Officer. Your concerns about ethical issues may be referred to the Human Resources Committee or the Corporate Governance Committee if:

  • the question cannot be resolved locally by your line manager or the Corporate Ethics Officer,
  • the question concerns the actions or decisions of the Corporate Ethics Commissioner.

We guarantee that the information you provide will under no circumstances be used against you, and your treatment will remain confidential. You will be informed in a timely manner of the decision on your application by the Corporate Ethics Officer or a representative of the Human Resources or Corporate Governance Committee.

You may contact the Audit Committee of the Board of Directors or the Corporate Governance and Nominations Committee of the Board of Directors if an ethical issue is related to actions or decisions of the Human Resources Committee or Corporate Governance Committee.

All Company officials and employees must cooperate fully with the investigation of ethical situations and provide materials and documents necessary to verify the circumstances of an ethical violation. Ethical issues should be regularly covered by the corporate media.

Any prosecution of an employee who voluntarily alleges a violation of the Code's principles will be considered a separate violation of the Code's principles.

In addition to the above statements on disclosure of cases of violation of the Code of Corporate Ethics, employees may also use a separate Reporting Policy on Violations, which provides protection to employees who report unethical behavior within the Company.

Information on damage to RUSAL's interests or reputation can be sent by RUSAL's employees to the following address: b/o55, #7-1 Oleko Dundicha str., Moscow, 121096,Russia as well as to e-mail: signal@rusal.com.