Severstal : Integrated Report 2024 PDF, 10.23 mB

CHMF.ME

Published on 06/10/2025 at 09:39

A New Strategy for a Sustainable Metallurgy

of the Future

Integrated Report

Table of Contents

Message from CEO

4

Responsible Supply Chain

84

About the Report

6

Supplier and Contractor Engagement

87

About the Report

8

Product Quality and Safety

95

Identification of Material Topics

10

Customer Relationship Management

98

Severstal Today

12

Social Aspect

104

About the Сompany

15

Human Rights

106

Geography and Key Assets

17

HR Management

112

Business Model

19

Contribution to the Development of the

Sustainability Ratings, Rankings and Indices

21

Regions of Presence

Occupational Health and Safety

126

142

Sustainability Awards

22

Environmental Impact

164

Strategic Report

24

Climate Change

166

Market Overview

26

Energy Efficiency

183

Operational and Financial Performance 29

Environmental Management 188

Corporate Governance 30

Appendices 242

Corporate Governance System 32

Ethical Conduct of Business

and Anti-Corruption 38

Effective Risk Management 44

Information Security 52

Innovation Management

and Digitalisation of Production 58

Sustainability Management 68

Sustainable Development Management Structure 70

Severstal's Sustainability Strategy 71

Appendix 1.

GRI Compliance Table 244

Appendix 2.

SASB Compliance Table 256

Appendix 3.

TCFD Compliance Table 260

Appendix 4.

Table of Compliance with the Guidelines of the Ministry of Economic Development (MED) of the Russian

Federation 261

Appendix 5.

Additional Data 264

Contribution to the Focal UN SDGs

73

Independent Practitioner's Assurance

Participation in National Projects

76

Report

281

Participation in Organisations and

Appendix 7.

Initiatives

79

RSPP Independent Assurance Report

285

Key Stakeholder Engagement

82

Appendix 8.

Consolidated Financial Statements

286

Appendix 6.

Message from CEO

GRI 2-22

Sustainability at Any Market Phase

The reporting year was quite challenging for the metals sector due to the fluctuations in domestic demand, ongoing sanctions pressure, and overcapacity in China that continued to negatively impact steel product prices in many regions of the world. Nevertheless, Severstal still remains one of the most profitable metals companies globally.

In 2024, the Company demonstrated its resilience in the challenging market landscape. We managed to make progress in almost all priority areas, improve the Company's performance, and maintain our strong financial standing. Resultantly, Severstal is back to the practice of quarterly dividend payments in accordance with the dividend policy and accrued 100% of free cash flow to the shareholders in the reporting year.

The flexible sales model and business integration enabled Severstal to maintain sales at a decent level in 2024, despite the falling demand in the

Russian market. While cast iron and steel production declined amid the overhauls at the blast furnace

and converter sections, we were able to ramp up sales of steel products to 10.85 million tonnes.

The consolidated 12M revenue rose by 14% YoY to almost RUB 830 billion triggered by the increased share of HVA products in the sales portfolio.

The Company's investment activity soared in the reporting year, with the capital investments up by 63% to RUB 118.5 billion. The key project is

development strategy also takes account of these principles, thus providing for a close connection between the Company's business processes and sustainability efforts.

Social Aspect

In 2024, Severstal expanded its support for employees and residents of the regions of presence: the social investments almost doubled, with an increase in the expenditures on social security and pension liabilities by 2.4 times. Over the reporting year, we continued implementing the well-being programme for employees and members of

their families titled #Dlya Svoikh: With Care for Everyone. Starting 2024, to maintain a decent level of remuneration, the Company increased the average wages by 23%.

The Company's priorities include the production safety. In the reporting year, we kept on boosting the Safety Volunteers movement, where the number

of members reached over 400. In addition, the digitalisation of OHS processes and the upgrade of OHS Control SW package modules was proceeding apace, thus enabling us to maintain safe working conditions not only at Severstal's facilities but also at contractor entities. The Company's systemic work resulted in LTIFR of 0.44 among own employees and contractors, which is 24% lower than the 2023 injury frequency rate.

We continued supporting the integrated urban development projects in the regions of presence in 2024. Over the reporting period, Severstal completed the improvement of the historic centre

of Cherepovets, commenced the elaboration of the Kostomuksha Master Plan, and, as earlier on, was engaged in landscaping. We take good care of the people in the regions of our operations and, therefore, implemented projects in education, healthcare, culture, sports and rendered support to vulnerable

In the reporting year, the Company attained a number of environmental targets and approved new ones

for the period up to 2028. Specifically, in 2024, we managed to decrease the weight of pollutants discharged into water bodies, achieve the target

values of the Clean Air federal project at Cherepovets Steel Mill and reduce the aggregated air pollutant emissions by 30.7% against the 2017 baseline. The waste recycling rate constituted 98.1%. Also, Severstal continued its biodiversity conservation efforts: in the reporting year, we released our Conserve Biodiversity - Preserve Life Strategy 2036, and the Company's representatives joined the task force on the Kunming-Montreal Global Biodiversity Framework under the Conference of the Parties to the United Nations Convention on Biological Diversity (UNCBD).

The Company continued its climate change adaptation work. In 2024, Severstal commenced the elaboration of a corporate climate change adaptation plan by supporting the implementation of the Vologda Region Adaptation Plan. The active dialogue within the climate agenda continued with the authorities of other regions of presence as well, i.e. the Republic

of Karelia and Murmansk Region. The Company implemented an extensive programme for climate-related risks management measures investing over RUB 1.2 billion therein, and, also, expanded the list of green and adaptation products and increased the manufacture thereof.

Looking into the Future

As part of our updated strategy, we will continue to create extra opportunities for our customers and partners, ramp up capital expenditures to RUB 169 billion in 2025 by focusing on upgrading our production facilities and introducing pellet technology in the blast furnace process. This will foster our competitiveness and dominant position in the sector. The Strategy 2024-2028 reflects the

Dear shareholders, colleagues, and partners,

The reporting year 2024 was an important period for Severstal in the context of shaping the Company's long-term vision. Not only did we strengthen our market positioning, but we also presented the updated development strategy 2028 that sets the growth vector for the coming years. This fundamental document retains the time-honoured principles, yet is supplemented with the new goals aligned with the current challenges.

The amended strategy not only reflects the Company's business objectives but also emphasises the importance of environmental and social responsibility for Severstal. It encompasses five priorities: safety and environment, employees' quality of life, customer engagement, digital technologies, and cost of production.

the construction of an iron ore pellet production complex at Cherepovets Steel Mill, which will reduce dependence on sinter and improve environmental performance.

Therefore, despite the external challenges, Severstal retained its leadership position in the industry by combining its strategic investments in the upgrades with the focus on improving the product portfolio quality and financial discipline.

Sustainable Development Management

In the reporting year, Severstal continued delivering its Sustainability Strategy 2030 titled Together Towards Sustainable Metallurgy of the Future.

As normal, the Company adhered to the ESG principles and worked on the environmental, social, and governance aspects. Severstal's updated

groups. On top of that, to gain a better understanding

of how our social projects perform, we assessed the quality of urban environment and identified the key areas for further development for the first time in 2024.

Environmental Aspect

Reducing our climate and environmental footprint remained a focal area for Severstal during the reporting year. We pursued our collaboration with stakeholders on climate change and environmental protection issues and participated in the UN Climate Change Conference (COP29), entered into the cooperation agreement with the Ministry of Natural Resources of the Murmansk Region, and held training programmes and workshops. Moreover, in 2024, we arranged a traditional annual social survey that, inter alia, encompassed questions regarding Severstal's contribution to the Clean Air federal project.

balance between sustainability and innovation. We

maintain our leadership by performance yet strive to become a first-choice company for customers,

employees, and partners. I am confident that through joint efforts we will achieve all of our ambitious goals.

Alexander Shevelev,

CEO

AO Severstal Management

‌01.

About the Report

Integrated Report 2024

‌About the Report

GRI 2-3

The Integrated Report 2024 (hereinafter referred to as the Report) of PAO Severstal (hereinafter referred to as Severstal or Company) contains information on the activities of the enterprises located in and outside the Russian Federation. The reporting period is from 1 January to 31 December 2024. In addition, the

Report covers significant events beyond the specified reporting period to adhere to the principle of timely disclosure.

The Report discloses the approach to managing sustainable development, including climate change, energy efficiency and environmental protection, personnel management, occupational health and industrial safety, and community engagement in the regions where we operate, as well as to respecting human rights, ensuring a responsible supply chain and corporate governance.

The information on PAO Severstal's and its subsidiaries' financial and business operations is uncovered in accordance with the disclosed consolidated financial statements derived from the audited consolidated financial statements of

PAO Severstal and its subsidiaries for 2024, prepared in conformity with the International Financial Reporting Standards (IFRS). The present Integrated Report also contains alternative performance indicators (APIs) that are omitted from the disclosed

Approach to the Report Preparation

consolidated financial statements and are used by the management to assess business performance and as reference information for dividend payment recommendations.

The Board of Directors makes use of such indicators as the free cash flow and net debt (calculated as the total debt financing less cash and cash equivalents) as guidance for giving dividend recommendations. The free cash flow is defined as the sum of the following items: net cash flow from continuing operations, CAPEX, proceeds from fixed assets disposals, and interest and dividends received.

EBITDA, widely used in the industry, stands for the operating profit plus depreciation expense on

production assets (inclusive of the Group's share in depreciation of assets of associated companies' and joint ventures' assets) adjusted for gains/(losses) from sales of fixed assets and intangible assets and for a share of non-operating income/(expenses) of associated companies and joint ventures.

Severstal draws up annual non-financial reporting and publishes sustainability reports on its corporate website. The present Report is the Company's second report containing, inter alia, information on Severstal's financial performance. The Report was published on 9 April 2025.

GRI 2-2

Severstal adheres to the principles of clarity and comparability, owing to which the Report is comprehensible to a broad reading audience. The information in the Report is disclosed for a period of five years, with explanations regarding the dynamics of metrics. To maintain the Report's balanced nature, the Company discloses information not only on its achievements but also on the areas for improvement.

Where there are any data collection or calculation assumptions or adjustments to any values from the previous reporting periods due to the improved methodology or errors eliminated, the Report provides respective explanatory statements. No material restatements of indicators versus the preceding year were in evidence in 2024, unless stated otherwise.

Boundaries of the Report

GRI 2-2 GRI 3-1

Severstal strives to make sure that the boundaries of the Integrated Report fully match the boundaries of its consolidated financial statements prepared in accordance with IFRS. In the 2024 Report, information on certain material topics is disclosed in relation to the assets whose impact is most significant in the context of the relevant topic.

The Company constantly works towards improving its approaches to setting up a system of data collection and consolidation for future single-scope disclosures. Exceptions in the scope and extent of certain disclosures, including versus prior reporting periods, are, in all cases, explained directly in the text of the Report or in the footnotes.

Boundaries of disclosure of material topics

PAO Severstal

AO Izhora Pipe Mill

AO Severstal SMC-Vsevolozhsk

AO Severstal Distribution

OOO Severstal-Vtorchermet

OOO Aircompany Severstal

AO Severstal Steel Solutions

AO Severstal-Metiz

OOO OSPAZ

AO Severstal Kanaty

OOO UniFence

OOO UniSpring

AO Olcon

AO Karelsky Okatysh

OOO Yakovlevskiy Mine

Air quality

Occupational health and industrial safety

Waste and tailings management

Water use and impact on water resources

Climate change and energy efficiency

Land resources and biodiversity

Human capital development

Development of the regions of presence

Information security

Innovation and digitalisation

Product quality and safety for customers

Economic performance

Matches the scope of the IFRS consolidated financial statements

The present Report is prepared in accordance with the recommendations of non-financial reporting standards and sustainability initiatives, including:

Global Reporting Initiative (GRI) standards updated as of 2021 (application level - compliant), GRI Mining and Metals Sector Supplement

Sustainability Accounting Standards Board (SASB) standards for Iron & Steel Producers, Metals & Mining

International Integrated Reporting Framework of the International Integrated Reporting Council (IIRC)

Recommendations of the Russian Union of Industrialists and Entrepreneurs (RSPP) on the use of basic performance indicators

Methodological recommendations of the Ministry of Economic Development of the Russian Federation on the preparation of sustainability reporting

UN Global Compact principles

Recommendations of the Task Force on Climate-related Financial Disclosures (TCFD)

In addition, the Report reflects the Company's progress in achieving the UN Sustainable Development Goals 2030 (SDGs) and its contribution to implementing the National Projects of Russia.

GRI 2-14

The Report preparation is supervised by Severstal's Corporate Social Responsibility and Brand Department. Qualitative and quantitative data to be disclosed in the Report is provided by the relevant divisions.

8

About the Report

Approach to the

Boundaries

Identification of

External

Severstal

Strategic

Corporate

Sustainability

Responsible

Social Impact

Environmental

Appendices

and Materiality

Report Preparation

of the Report

Material Topics

Assurance

Today

Report

Governance

Management

Supply Chain

Impact

9

‌Identification of Material Topics

List of material topics

GRI 3-1 GRI 3-2

In its operations, Severstal consistently factors in stakeholder interests through extensive interaction, including in determining material topics of the Integrated Report. To this end, the Company performs an annual survey to eventually identify the topics of utmost importance for various stakeholder groups. In preparing the 2024 Report, Severstal remained committed to the previous year's approach to material topics identification.

The list compiled by the Company is based on the topics of the Sustainability Report 2023 identified by stakeholders as most material.

For each topic, the Company identified positive and negative impacts (both actual and potential) on the economy, environment and society. With that,

Severstal factored in its long-standing non-financial reporting practices, GRI industry standards, the recommendations of the Ministry of Economic Development of the Russian Federation, and stakeholders' suggestions recorded in drafting the 2024 Report. The resulting list of impacts served the basis for compiling a stakeholder survey questionnaire. Respondents were offered the opportunity to designate additional impacts and topics within each aspect.

Air quality

Occupational health and industrial safety Water use and impact on water resources Waste and tailings management

Product quality and safety for customers

Economic performance Decent working conditions

Climate change and energy efficiency Information security

Development of the regions of presence Innovation and digitalisation

Risk management Responsible supply chain

Land resources and biodiversity

Priority 2

Priority 1

In 2024, 75 stakeholder representatives took part in the survey, including 30 Severstal's employees,

12 shareholders and investors, and 33 representatives of other stakeholder groups.

Respondents by stakeholder groups

30

12

4

4

4

5

6

6

1

3

External Assurance

Governmental bodies, supervisory authorities

Suppliers and contractors

Business associations and unions, industry players

Media, bloggers, influencers

Customers and purchasers

Sustainability experts

Non-profit and public organisations, research, cultural, educational, sports, and

Analysts and banks

Shareholders and investors

Company employees

GRI 2-5

A number of key quantitative data is additionally verified as part of assurance by an independent practitioner to make sure the Report contains accurate and reliable data only. The Company's approach and the external assurance schedule are set out in the Audit and Assurance Policy of PAO Severstal. The assured information is marked in the present Report by a magnifier icon -

The Independent Assurance Report is presented in Appendix 6.

To improve the quality of non-financial disclosures, the Company liaises with the Council on Non-Financial Reporting of the Russian Union of Industrialists and Entrepreneurs and submits the Sustainability Report thereto for an independent public assurance. The Council opines on the significance and completeness of the information disclosed in the Report, being guided by the provisions of the Social Charter of Russian Business, including the principles of responsible business practice.

healthcare institutions

GRI 3-2

Further to assessing impacts by questionnaires, the respective topics were scored. Such scoring entailed summing up the averages for positive and negative impacts within the topics. Eighteen topics were then ranked and nested within three priority groups. According to the Company's approach, the topics that passed the 33% cut-off threshold and that were included in Priorities 1 and 2 are regarded as material; there turned out to be

13 such topics in 2024.

Priority 3 topics are also important for Severstal, for which reason the Company discloses them in the relevant sections. The Land Resources and Biodiversity topic was added to the list of material topics as resolved by the Sustainability Working Group in connection with its paramount importance for the Company and preparation of the relevant strategy in 2024.

10

About the Report

Approach to the

Boundaries

Identification of

External

Severstal

Strategic

Corporate

Sustainability

Responsible

Social Impact

Environmental

Appendices

and Materiality

Report Preparation

of the Report

Material Topics

Assurance

Today

Report

Governance

Management

Supply Chain

Impact

11

‌02.

Severstal Today

Integrated Report 2024

‌2024 Highlights, RUB million

MED-1

About the Сompany

Revenue

EBITDA

CAPEX

2023: 728,314

14%

2023: 262,229

2023: 72,629

GRI 2-1 GRI 2-6

Severstal (hereinafter also referred to as the Company) is one of the world's most efficient steel and mining companies that creates new steel products and integrated solutions together with its customers and partners. Its core assets are based in the European part of Russia.

The Company offers a wide range of goods and regularly expands it on account of new product types, with a focus on HVA items. Severstal takes a rational approach to capital investments by injecting cash in projects directed at the key elements of its strategy, in the first place, that is superior customer experience, cost leadership, implementation of new opportunities in the context of corporate culture, and commitment to sustainable development. The primary goal of investment projects is to enhance profitability, create a maximum value, and increase shareholder returns. Owing to cutting-edge technologies, the Company elaborates innovative solutions, advances HVA products, improves customer service, and reduces negative environmental impacts.

In addition to evolving its core production facilities, the Company dynamically creates innovative products and services, and provides customers with integrated engineering solutions. To date, Severstal captures such

promising practice areas as the production of wind turbines and cryogenic steel for liquefied natural gas (LNG) tanks.

Severstal's Business Strategy

Severstal completed another strategic cycle in 2023. The Company grew more resilient and flexible by having attained almost all the goals set, including the key metric - comprehensive shareholder income.

In the reporting year, Severstal presented its restated development strategy for 2024-2028 retaining its fundamental principles but supplementing it with elements that meet the imperatives of our time.

Severstal's response

Global challenges and trends

Global challenges and trends underlying the Company's strategic response

Free cash flow

2023: 119,970

Higher trade barriers and global steel market stagnation

Higher competition on Russia's steel market

Focus on the domestic market of the Russian Federation

Focus on customer needs

Focus on points of growth in the Russian Federation

Developing the domestic consumption

Net profit

2023: 190,907

Demographic crisis, fight for talent • Increasing labour productivity

Implementing digitalisation and automation

Restricting access to technologies • Import substitution of technologies and competencies

Inflation of costs, more expensive logistics

14

About the Report

Severstal

About the

Geography

Business

Sustainability

Sustainability

Strategic

Corporate

Sustainability

Responsible

Social Impact

Environmental

Appendices

and Materiality

Today

Сompany

and Key Assets

Model

Ratings, Rankings

Awards

Report

Governance

Management

Supply Chain

Impact

15

Severstal's strategy aims to maintain the global leadership in efficiency and strengthen the positions on the Russian market. To achieve the goals set, the Company identified five strategic priorities with transparent metrics.

Geography and Key Assets

GRI 2-1 GRI 2-6

01

02

Severstal Resource

02

01

03

Severstal Russian Steel

04

03

05

Severstal-Metiz, Volgograd Region

05

Izhora Pipe Mill, St. Petersburg

02

Cherepovets Steel Mill, Vologda Region

01

Yakovlevskiy Mine, Belgorod Region

03

Karelsky Okatysh, Republic of Karelia

02

Olcon, Murmansk Region

0011

Severstal comprises two main industrial divisions: Severstal Resource and Severstal Russian Steel. The Company makes use of a vertically integrated business model, which makes it possible to manage all stages of the operating process - from ore mining and processing to the release of finished rolled steel, its distribution, elaboration of integrated solutions for customers and maintenance.

Strategic priorities

Key metric

Financial goal

Leader in occupational safety and environment

Preservation of life and health of employees and local residents, observance

of the legislation

Fatalities 0

LTIFR among employees <0.45

ollutant emissions ↓46%

150

EBITDA as at year-end 2028 against

2023 1

Faster EBITDA growth compared to competitors

Leader in employee life quality

Leader in customer engagement

We are the first one would think of when it comes

to rolled steel

Market share in the Russian Federation in the core segments 20%

Market leader in price efficiency

Leader in digital technologies

Advantage over competitors both in market operations and efficiency improvement

Improving labour productivity, creating an additional source of EBITDA

We are a reliable employer who values each and every employee and takes good care of them and their family members

Number one employer in the regions of presence

03

Severstal-Metiz, Cherepovets

04

Severstal-Metiz, Oryol Region

Severstal Resource

As one of the two key elements of Severstal's business model, Severstal Resource covers all mining assets of the Company in the Belgorod and Murmansk Regions, and in the Republic of Karelia. This segment almost completely supplies Severstal Russian Steel with iron ore and provides external customers with feedstock.

Key assets of Severstal Resource

Region/facility

Products

Operating performance1

Leader in cost

Strengthening global cost leadership in an environmentally friendly manner

Ensuring a 15% gap in the end-to-end cost of converter slab from the nearest competito

Iron ore concentrate

01

Iron ore concentrate -

2.2 million tonnes

Iron ore pellets

02

Pellets -

11.0 million tonnes

03

Iron ore mining and processing

Iron ore concentrate -

3.2 million tonnes

The Strategy 2024-2028 version in effect is available on the website

1 The Company's pre-estimate calculated in macroeconomic conditions and forecasts for H1 2024 is subject to change.

2 This document is only available in Russian.

1 Data for 2024 and as at 31.12.2024.

16

About the Report

Severstal

About the

Geography

Business

Sustainability

Sustainability

Strategic

Corporate

Sustainability

Responsible

Social Impact

Environmental

Appendices

and Materiality

Today

Сompany

and Key Assets

Model

Ratings, Rankings

Awards

Report

Governance

Management

Supply Chain

Impact

17

‌Severstal Russian Steel

Severstal Russian Steel covers the Company's assets involved in manufacturing and selling finished rolled steel. The key asset - Cherepovets Steel Mill - is one of the most cost effective metallurgical enterprises in the world that is well-positioned in terms of its vicinity to Severstal's mining facilities, the Baltic Sea ports, and Russian industrial clusters.

Severstal Russian Steel offers a wide range of products with the largest share of flat rolled steel.

01

High value-added (HVA) flat rolled products

Long products

(including for the construction industry)

Downstream products

Galvanised steel

Cold rolled steel

Hot rolled steel

Steel - 10.4 million including:

Basic Oxygen Furnace (BOF) method - 9.3 million tonnes

Electric Arc Furnace (EAF) method -

1.1 million tonnes (~10%)

Electric welded pipes

02

Large diameter pipes -

0.5 million tonnes

03 04 05

Metalware

and secondary products

Metalware - 0.4 million tonnes

Key assets of Severstal Russian Steel

Region/facility

Products

Operating performance1

Business Model

GRI 2-6

Severstal demonstrates stable financial and non-financial performance owing to the reliance on its efficient vertically integrated business model. A combination of mining and metals operations as well as the Company's self-sufficiency in raw materials help maintain high profitability of production assets and protect the Company from seasonal fluctuations in feedstock prices. Severstal dispatches its finished products to construction, machine building and power engineering enterprises.

Resource business Vtorchermet

(recycled ferrous metals)

Coke agglomeration

and blast furnace process

Upstream

Innovation, business models, exploration

Steelmaking

(up to molten steel inclusively)

Energy Construction Machine building

Distribution

Flat rolled products (including finished slab)

Long products Pipes and tubes Metalware

1 Data for 2024 and as at 31.12.2024.

Responsible business practices are integrated into the Company's business model with due regard to the UN Sustainable Development Goals and the national projects' goals. The Company continuously harmonises its processes in accord with best practices and transforms the resources used to stakeholder value.

Downstream

Severstal adheres to a well-balanced investment policy by injecting capital in projects that are aligned with the key strategic priorities in order to enhance profitability, maximise partner value, and increase shareholder returns.

18

About the Report

Severstal

About the

Geography

Business

Sustainability

Sustainability

Strategic

Corporate

Sustainability

Responsible

Social Impact

Environmental

Appendices

and Materiality

Today

Сompany

and Key Assets

Model

Ratings, Rankings

Awards

Report

Governance

Management

Supply Chain

Impact

19

‌MED-1 MED-2 MED-3 MED-4 MED-5 MED-7 MED-10 EM-MM-000.A EM-IS-000.A EM-IS-000.B

Business model

Sustainability Ratings, Rankings and Indices

MED-39

Capital

Resources in 2024

Performance in 2024

Human capital

Employees, personnel training and development, workplace safety

50,553 employees - average headcount

RUB 118,852 billion - salaries and

social contributions

RUB 452 million - investments in personnel development programmes

RUB 7.1 billion - investments in OHS

activities

Ranks first in the industrial employer IT brand rating (habr.ru)

88% - share of employees covered by training

0.44 - LTIFR among Company employees and contractor

Social capital

Stakeholder engagement

22% - share of purchases from SMEs

33% - share of purchases from local suppliers

RUB 7.5 billion - social investments

RUB 35.2 billion - tax and non-tax payments across the key regions of presence in Russia

97% - overall customer satisfaction

300 charity projects

>30 events dedicated to information support of SMEs and promotion of entrepreneurship

Natural capital

Environmental footprint reduction solutions

>10 iron ore deposits

>10 billion tonnes of iron ore reserves

RUB 10 billion allocated for environmental protection activities

98.4% - share of recycled water

98.1% - share of waste recycling

2.180 tonnes of СO2 / tonne of steel -carbon intensity

Production capital

Production capacity, operating performance

2 segments

46 enterprises

10 million tonnes of cast iron production

10.4 million tonnes of steel production1

RUB 638 billion - Operational Expenditure (OPEX)

>500 partners involved in improving the operating performance and optimising the production processes

205 tonnes of produced steel / person - labour productivity2

Financial capital

Investments in the production activities development

RUB 118.5 billion - investments in production development projects (CAPEX)

RUB 25.5 billion - interest paid

RUB 829.8 billion - revenue

RUB 228.4 billion - net value added3

10.85 million tonnes - sales of steel products, including:

5.62 million tonnes - sales of HVA products

4.76 million tonnes - sales of commercial steel (commercial mill products)

0.47 million tonnes - sales of semi-finished products

16.8 million tonnes - sales of iron ore4

Knowledge capital

Knowledge, skills, and production expertise

RUB 317 million - R&D funding

>66 thousand ideas submitted under the Idea Factory initiative

589 patents in ownership in the Russian Federation

9.2% - share of new product types

RUB 1.7 billion - economic effect from inventions

High ESG index (Level I) among Russian non-financial companies

Ranked first in the ESG ranking of Russian companies in the ferrous metallurgy sector

Ranked ninth in the overall ESG rating1

Ranked second and fourth in the ESG rating of Russian companies leading in waste management quality

Group AA - Very high level

AA.esg - a very high level of the ESG agenda integration into the Company's activities, and of the quality of relevant practices observance

Group A in the Responsibility and Transparency Index - companies with best disclosures

Group A in the Sustainability Vector Index - companies with best performance dynamics

Ranked first in the ferrous metallurgy sector of the ESG Transparency Ranking of Russian companies

Group AAA - companies with a very high anti-corruption level

87% (corresponds to the industry average) out of the maximum 100%

Highest A+ category in the Leaders in Corporate Charity rating

1 ~90% of steel produced through the basic oxygen furnace (BOF) process, and ~10% - through the electric arc furnace (EAF) process.

2 244.5 tonnes of produced steel / person is the 2023 indicator.

3 RUB 359.9 billion is the value added for 2023.

4 Including the ore designated for own use and for sales (2.2 million tonnes - iron ore sales to third parties). 1 As at December 2024.

20

About the Report

Severstal

About the

Geography

Business

Sustainability

Sustainability

Strategic

Corporate

Sustainability

Responsible

Social Impact

Environmental

Appendices

and Materiality

Today

Сompany

and Key Assets

Model

Ratings, Rankings

Awards

Report

Governance

Management

Supply Chain

Impact

21

‌Sustainability Awards

Responsible business practices

First-degree laureate of the Leaders of Responsible Business national award

Finalist in two nominations: For the contribution to achieving environment- and climate-oriented objectives, For the contribution to sustainable development of territories

Ranked first for the Company's Unified Report in the Best ESG Disclosure nomination

Leader status in the Best Sustainability Report nomination

Gold Winner in the 2023 Rating of Best Russian Employers for the contribution to employees and society (S); Platinum Winner in the E and G nominations

Winner of the Leaders of Business: Dynamics, Responsibility, Sustainability 2023 all-Russian competition in two nominations: For the contribution to sustainable development of territories, For the high quality of sustainability/ESG reporting

Ranked second in the competition of annual reports

Highest Quality of Report status for the Company's Unified Report

Best employer among industrial companies in the rating of employers

Five Severstal's programmes contributing to the delivery of national projects are finalists in the Award

Partner of National Projects status

Environmental aspect

The Cherepovets Air Environmental Monitoring project wins the Sustainable Development nomination

The Clean Air project wins the Eco-Enterprise nomination of the Komsomolskaya Pravda National Environmental Award

22

About the Report

Severstal

About the

Geography

Business

Sustainability

Sustainability

Strategic

Corporate

Sustainability

Responsible

Social Impact

Environmental

Appendices

and Materiality

Today

Сompany

and Key Assets

Model

Ratings, Rankings

Awards

Report

Governance

Management

Supply Chain

Impact

23

Social aspect

#Dlya Svoikh: With Care for Everyone welfare programme takes the Grand Prix at the 2024 InterComm International Award

Silver Winner in the Territory of Good nomination for the corporate Doing Good Deeds volunteering programme

Bronze Winner in the Work without Danger nomination for the Safety Volunteers project

Laureate of the Corporate Donor Culture all-Russian competition (III) in the Best Corporate Donor Day nomination

Ranked third for the Severstal Engineering Classes project in the Best Programme (Project) Contributing to the Development of Science and Education in the Russian Federation nomination

Ranked third for the Choose Life project in the Best Programme Contributing to the Achievement of the UN Sustainable Development Goals (UN SDGs) to Ensure Health, Healthy Lifestyle and Well-Being for Sustainable Development nomination

Ranked first in the Healthy Lifestyle nomination for #Dlya Svoikh: With Care for Everyone programme

Ranked second in the Development of Local Communities nomination for the Cherepovets integrated development project

Ranked first in the Transparency of Activity nomination and ranked fifth in the Appreciation by the Society, and Activities in Social Media and Mass Media nomination among corporate and private NPOs for the Company's Way Home charitable foundation

Other

Winner in the For Business Efficiency Improvement nomination for the Autotemp 2.0 software package

Diplomas in the Best Electronic Corporate Media nomination of the Best Corporate Media in the Russian and CIS Metallurgical Industry competition for the first metallurgical podcast 'Ne v Lom' and Severstal. News TV programme

Winner in the special nomination in the national category of the ISAR Honours 2024 award for the Company's ESG metrics automation project

The Safety Volunteers film wins in the Best Camerawork nomination of the Metal-Vision'2024 competition for the best video production in the metals sector

‌03.

Strategic Report

Integrated Report 2024

‌Market Overview

Price for hot rolled sheet EXW Russia, net of VAT, thousand RUB/tonne

80

Global Economy and Steel Market

In 2024, the global economy retained resilience despite multiple negative forecasts on its development. Disinflation supported household consumer spending and allowed monetary policy easing in most major economies, which helped offset the uncertainty caused by geopolitical tensions. The OECD estimates the global GDP growth of 3.2% in 2024, with ambiguous results in developing economies. In China, the GDP growth remained unchanged, encouraged by the rising industrial production owing to stronger exports.

However, consumer demand remained weak, and the lengthy correction in the property sector continued, impacting the steel market.

Steel Prices

According to the World Steel Association, global steel consumption fell by 0.9% in 2024 to 1.75 billion metric tonnes. Global steel production also declined by 0.9% to 1.83 billion tonnes. Chinese smelting declined by 1.7%, with WorldSteel estimating that China's ongoing property market crisis led to a 3.0% fall in domestic steel demand in 2024. The fall in demand at a rate faster than the decline in smelting resulted in a surge in exports of semi-finished and finished rolled steel from China to a record high of 117 million tonnes, up 25.1% YoY. The increased exports of rolled steel from China impacted prices in many regions of the world.

70

60

50

40

Jan '23

Feb '23

March '23

April '23

May '23

June '23

July '23

Aug '23

Sep '23

Oct '23

Nov '23

Dec '23

Jan '24

Feb '24

March '24

April '24

May '24

June '24

July '24

Aug '24

Sep '24

Oct '24

Nov '24

Dec '24

30

Iron Ore Prices

In 2024, the average iron ore prices decreased by 8% to USD 110 per tonne CFR China. In general, the downward trend continued throughout the year. The prices declined from the January 2024 peak of USD 145 per tonne to the low of USD 90 in late September. It was followed by stabilisation at around USD 105 per tonne, which is close to the cost support levels of the least efficient producers.

On average, the export prices for Russian hot rolled coil FOB Black Sea in 2024 decreased by 11% year-on-year. The decline was driven by the pressure exerted by Chinese exports.

The prices for hot rolled steel in Russia in 2024 turned out to be more resilient amid the favourable domestic demand for rolled steel in H1, as well as due to higher (vs the global average) inflation rates. However, in H2, the prices moved downwards due to a tighter monetary policy and the resulting weaker demand for rolled steel.

Nevertheless, in 2024, the prices increased by an average of 2% YoY.

Price for hot rolled coil FOB Black Sea, USD/tonne

Prices for iron ore (62% Fe) CFR China, USD/tonne

150

140

130

120

110

100

800 90

80

700

70

Jan '23

Feb '23

March '23

April '23

May '23

June '23

July '23

Aug '23

Sep '23

Oct '23

Nov '23

Dec '23

Jan '24

Feb '24

March '24

April '24

May '24

June '24

July '24

Aug '24

Sep '24

Oct '24

Nov '24

Dec '24

600 60

500

400

300

Jan '23

Feb '23

March '23

April '23

May '23

June '23

July '23

Aug '23

Sep '23

Oct '23

Nov '23

Dec '23

Jan '24

Feb '24

March '24

April '24

May '24

June '24

July '24

Aug '24

Sep '24

Oct '24

Nov '24

Dec '24

200

26

About the Report

Severstal

Strategic

Market

Operational

Corporate

Sustainability

Responsible

Social Impact

Environmental

Appendices

and Materiality

Today

Report

Overview

and Financial

Governance

Management

Supply Chain

Impact

27

‌Coking Coal Prices

In 2024, the average coking coal prices decreased by 15% to USD 183 per tonne CFR China. As is the case with iron ore prices, among the key factors affecting the price fluctuations in 2024 were the concerns about the property market activity in China. However, the strong demand for coking coal from India, which significantly increased its steel production, was not the least of the factors either.

Prices for coking coal CFR China, USD/tonne

Operational and Financial Performance

Operational Performance

300

280

260

240

220

200

180

160

140

120

Jan '23

Feb '23

March '23

April '23

May '23

June '23

July '23

Aug '23

Sep '23

Oct '23

Nov '23

Dec '23

Jan '24

Feb '24

March '24

April '24

May '24

June '24

July '24

Aug '24

Sep '24

Oct '24

Nov '24

Dec '24

100

Russian Economy and Steel Demand

The Russian economy grew by 4.1% in 2024, as in 2023, according to Rosstat. The greatest influence was exerted by the growth of value added in such industries as information and communication (+11.9%), hotels and restaurants (+9.6%), wholesale and retail trade (+6.9%), and manufacturing sectors (+7.6%). According to Rosstat, inflation for 2024 was 9.5%, while unemployment was at a historic low of 2.3%, reflecting a stressful situation in

the labour market. In 2024, the Bank of Russia anticipated the Russian economy to grow by 1.0-2.0%, whereas the IMF predicted 1.4%.

As per the Company's estimates, steel consumption in Russia declined by 5.6% to 43.8 million tonnes in 2024 primarily due to lower activity in the construction sector against the backdrop of the rising key rate and the resulting lower purchasing and investment activities.

The cast iron production decreased by 11% year-on-year to 10.03 million tonnes amid the overhaul of blast furnace No. 5, whereas the steel production declined by 8% to 10.38 million tonnes.

The consolidated sales of rolled steel rose by 1% to

10.85 million tonnes despite the large-scale repairs. The commercial steel sales (hot rolled and long products) increased by 5% to 4.76 million tonnes, while the sales of HVA products rose by 7% to

Financial Performance

Owing to the average selling prices growth on the back of the growing share of finished rolled steel and HVA products, as well as higher sales volumes, the revenue increased by 14% to RUB 829,779 million.

However, EBITDA decreased by 9% down to

RUB 237,880 million, and EBITDA margin declined by 7 p. p. to 29% on the backdrop of the increased production cost due to higher prices for goods and services of natural monopolies, higher payroll, and the acquisition of the A GROUP.

CAPEX surged by 63% to RUB 118,460 million amid dynamic implementation of projects in tune with the Company's new strategy. The largest projects in the reporting year were the overhaul of blast

furnace No. 5 and continued construction of an iron ore pellet production complex at Cherepovets Steel Mill. Severstal will keep on investing in strategically important projects that will enable the Company to

Financial Standing

5.62 million tonnes. As at year-end 2024, the share of HVA products increased by 3 p. p. to 52%. The semi-finished products sales decreased to 465 thousand tonnes (-51%) due to several major BOF repairs.

The sales of iron ore to third parties increased by 51% to 2.23 million tonnes due to a decline in demand for iron ore raw materials (IORM) at Cherepovets Steel Mill during the overhaul of blast furnace No. 5.

ensure the leadership in costs, expand its customer base, enter new market segments, and reduce

its environmental footprint. In 2025, Severstal's investments are expected to reach RUB 169 billion, of which RUB 81 billion will be allocated to maintain the existing capacities, and RUB 70 billion - to invest

in development projects. Investments in IT and digital projects, as expected by the Company, will amount to around RUB 13 billion, and the amount of investments in environmental protection, occupational health and safety systems improvement shall total RUB 5 billion.

Lower EBITDA and record-breaking investments resulted in a 19% decrease in free cash flow to

RUB 96,767 million for 12M 2024, with Severstal back to paying dividends in the reporting period. Thus, in 2024, the Company accrued dividends for 2023 in the amount of RUB 160.4 billion and interim dividends for Q1-Q3 2024 in the amount of RUB 99.2 billion.

In 2024, the Company managed to retain its strong financial standing with a low debt burden. Monetary funds and equivalents thereof reduced to RUB 128,571 million (vs RUB 373,568 million as of 31 December 2023)

due to payment of dividends in the amount of RUB 242,310. The total debt declined to RUB 108,503 billion

(vs RUB 163,105 million as of 31 December 2023). The net cash position was RUB 20,068 million. The Net Debt/ EBITDA reached -0.08.

28

About the Report

Severstal

Strategic

Market

Operational

Corporate

Sustainability

Responsible

Social Impact

Environmental

Appendices

and Materiality

Today

Report

Overview

and Financial

Governance

Management

Supply Chain

Impact

29

‌04.

Corporate Governance

Integrated Report 2024

‌Corporate Governance System

Corporate Governance Standards and Principles

In its operations, Severstal is guided by best Russian and international corporate governance practices.

Its corporate governance system aims to efficiently administer the Company's activities and manage sustainability risks and opportunities while respecting the interests of shareholders, investors, and other stakeholders.

Internal

The fundamental principles underlying the corporate governance system are outlined in the Corporate Governance Code of PAO Severstal, namely:

Efficient and transparent mechanisms for ensuring shareholder rights and interests

Equal treatment of all shareholders

Exercising shareholder rights to participate in managing the Company

High-level engagement with all stakeholders, including customers, suppliers, employees, and professional communities, and

Increasing the market value of the Company's shares

External

Corporate Governance Code recommended by the Bank of Russia

Key corporate governance documents

Winner of the Director of the Year Award

On 26 February 2025, Corporate Secretary of PAO Severstal won the XIX National Director of the Year Award in the Corporate Governance Director / Corporate Secretary nomination. The award recognises corporate governance leaders for their individual contribution to creation and promotion of advanced corporate governance standards, and introduction of prospective technologies and practices in the Board proceedings of not only public but also private Russian companies.

The Award was founded by the Association of Professional Directors (APD) and the Russian Union of Industrialists and Entrepreneurs (RSPP) in partnership with the Moscow Exchange, PJSC, Sberbank, PJSC, and Unicon, JSC.

50%

the share of independent directors in the Board of Directors

100%

of Severstal's employees

and business partners introduced to the Anti-Corruption Policy

3,786

persons completed the anti-corruption training course (more than twice as much)1

0

cases of violation of personal data confidentiality

2024 Highlights

Principle 10. Businesses should work against corruption in all its forms, including extortion and bribery.

UN Global Compact Principles

UN Sustainable Development Goals

Risk management

Material Topic

Company's Corporate Governance Structure

GRI 2-9

General Meeting of Shareholders

Board of Directors

Audit Committee

Safety and Sustainability

Nomination and Remuneration

Sole Executive Body CEO

1 Against 2023.

32

About the Report

Severstal

Strategic

Corporate

Corporate

Ethical Conduct

Effective Risk

Information

Innovation Management

Sustainability

Responsible

Social Impact

Environmental

Appendices

and Materiality

Today

Report

Governance

Governance

of Business and

Management

Security

and Digitalisation of

Management

Supply Chain

Impact

33

The General Meeting of Shareholders (hereinafter referred to as the Meeting) is the supreme governing body of Severstal. The Meeting's authority is determined by Russian laws and the Charter of PAO Severstal1.

All aspects related with preparing for and conducting the Meeting, including its composition, functions, powers and authority of its working bodies, are governed by the Regulations on the Procedure of Conducting General Meetings of Shareholders.

GRI 2-10 GRI 2-11

When forming the Board composition, the Company proceeds from professional competencies and experience of applicants in the relevant area. The sitting Board members have vast knowledge and many years of experience in such domains as economics and finance, engineering, technology, law, and personnel management.

In conformity with the legislation of the Russian Federation, the Company shall convene the annual General Meeting of Shareholders on an annual basis. Extraordinary meetings may be convened at the initiative of the Board of Directors or as required by the Company's audit firm or by the shareholders (shareholder) holding at least 10% of the Company's voting shares as at the date of the request. In 2024, Severstal conducted the annual General Meeting of Shareholders and two extraordinary meetings by absentee voting.

Board of Directors

GRI 2-12 GRI 2-13 GRI 2-14 MED-37

The Board of Directors is in charge of the overall management of the Company's activities, including actualisation and approval of its strategy and business model, exercises control over the proceedings of its executive

bodies, and executes other functions assigned by PAO Severstal's Charter in accord with the legislation of the Russian Federation. Apart from analysing the implementation of the development strategy, situation on stock markets and trends in the main sales markets, the Board of Directors regularly reviews progress reports on PAO Severstal's focal areas and sustainability issues.

For more details regarding the approach to sustainable development management, see the Sustainability Management section.

The Board of Directors convenes its meetings as deemed necessary, both in person and by absentee voting. Board meetings may be convened at the initiative of the Chairman of the Board of Directors, a member of the Board, Head of the Internal Audit Department or the Company's audit firm, the executive body as well as shareholders (shareholder) cumulatively holding at least 2% of the Company's voting shares.

For more details regarding the standard operating procedures of the Board of Directors, see the Regulation on the Board of Directors of PAO Severstal.

MED-36

In 2024, the Board of Directors conducted ten meetings. The attendance rate was 100%. The Board of Directors considered 88 issues, including the reports of the Chairman of the Safety and Sustainability Committee of

PAO Severstal and the climate-related risks and opportunities analysis.

Structure of issues considered by the Board of Directors, pieces

5%

10%

3%

The Board members are elected by the General Meeting of Shareholders for a term until the next annual Meeting. The Chairman of the Board of Directors is elected by the Board members from among themselves by a majority of votes of all members of the Board. The Board of Directors may reelect the Chairman at any time by a respective resolution passed by the majority of votes.

For more details regarding the Board members election procedure, see the Charter of PAO Severstal.

GRI 2-9 MED-37 MED-44

As at 31 December 2024, the Board of Directors was composed of ten members. With that,the share of women increased to 20% against 2023 (10%), and the share of independent directors grew to 50% (20% in 2023).

Term of office of the Board members

30%

70%

GRI 2-18

Status of the Board members in 2024

50%

Age of the Board members

50%

aged over 50

50%

50%

17%

28%

36%

Sustainable development

The Board of Directors performs a self-assessment on a regular basis. The Board conducts an internal assessment of its performance annually, and an external independent assessment once in three years.

In 2024, it was resolved that it would be inappropriate to assess the performance of the Board of Directors and its committees due to the significant renewal of their members and a short-duration term of office.

1 On 6 December 2024, the General Meeting of Shareholders of PAO Severstal approved the Company's Charter in a new edition so that General Meetings are conducted in conformity with the legislation in effect, with consideration to the amendments introduced by Federal Law dated 08.08.2024 No. 287-FZ On Amendments to the Federal Law on Joint-Stock Companies and Certain Legislative Acts of the Russian Federation. This document is only available in Russian.

34

About the Report

Severstal

Strategic

Corporate

Corporate

Ethical Conduct

Effective Risk

Information

Innovation Management

Sustainability

Responsible

Social Impact

Environmental

Appendices

and Materiality

Today

Report

Governance

Governance

of Business and

Management

Security

and Digitalisation of

Management

Supply Chain

Impact

35

Name of Committee

Audit Committee

Nomination and Remuneration Committee

Safety and Sustainability Committee

100%

100%

80%

20%

Term of office

of Committee

members

0-3 years

over 6 years

100%

67%

33%

60%

40%

Age of

Committee

members

aged 31-50

aged 31-50

aged over 50

aged over 50

Committees of the Board of Directors

GRI 2-13

There are three committees operating under the Board of Directors of PAO Severstal: the Audit Committee, the Nomination and Remuneration Committee, and the Safety and Sustainability Committee. The committees are consultative and advisory bodies in charge of accomplishing the tasks assigned by the Board of Directors.

For more details regarding the election procedure and other aspects of the committees' activities, see the Regulation on the Committees of the Board of Directors of PAO Severstal.

In 2024, the Safety and Sustainability Committee reviewed, inter alia, the following sustainability issues:

Climate-related risks assessment and environmental metrics;

Implementation of the decarbonisation strategy, and

Policy for conservation of biodiversity, ecosystems and ecosystem products.

MED-38

In the reporting year, the Audit Committee conducted three meetings. The attendance rate was 100%.

Name of Committee

Audit Committee

Nomination and Remuneration Committee

Safety and Sustainability Committee

Committee's objectives

Ensures the participation of the Board of Directors in exercising control over the Company's financial and economic activities, including monitoring the

status of risk management, internal control, and corporate governance systems

Facilitates involving qualified specialists in managing the Company and incentivising them to perform efficiently

Renders assistance to the Board of Directors in providing for the

appropriate functioning of the safety and sustainability risk management system

Composition

Three directors

Percentage of men - 100%

Three directors

Percentage of women -33%

Five directors

Percentage of women -40%

Status of Committee members

100%

100%

60%

40%

Committees of the Board of Directors of PAO Severstal in 2024 1

Top Management Remuneration

GRI 2-19 GRI 2-20

At the General Meeting of Shareholders, Severstal's shareholders might pass a resolution on payment of remuneration to the Board members for discharging their duties and on compensation of their expenses related to such activities. The amount of the said remuneration and compensation is determined by a respective resolution of the General Meeting of.

In the reporting year, the annual General Meeting of Shareholders passed the resolution on establishing the following types of remuneration from 1 July 2024 in addition to compensation for documented expenses related to the functions discharged by the Board members:

Monthly remuneration payable to the Board members of PAO Severstal who are ecognized as independent directors in accordance with the Regulation on the Board of Directors of PAO Severstal and the Corporate Governance Code of PAO Severstal, in the amount of RUB 1.2 million;

Monthly remuneration payable to the Chairman of the Board of Directors of PAO Severstal in the amount of RUB 1.2 million, and

Monthly remuneration payable to an independent director elected by the Board's resolution to chair any of PAO Severstal's Board Committees in the amount of RUB 1.6 million.

The remuneration payable to the members of the Board of Directors of PAO Severstal for contributing to the work of the governing body in 2024 amounted to RUB 62.9 million.

Remuneration of Severstal's top managers is determined by local regulations and provisions of respective employment contracts. Moreover, the Company has the Regulation on the Reduction of Long-Term Remuneration Elements in AO Severstal Management in place that enables the Nomination and Remuneration Committee to reduce payments under the long-term incentive and bonus system in favour of the key top managers, should any deliberate wrongful behaviour be revealed on their part. The Regulation aims to mitigate the Company's financial, reputational and other risks occurred for reasons attributable to the said behaviour.

1 As at 31 December 2024.

36

About the Report

Severstal

Strategic

Corporate

Corporate

Ethical Conduct

Effective Risk

Information

Innovation Management

Sustainability

Responsible

Social Impact

Environmental

Appendices

and Materiality

Today

Report

Governance

Governance

of Business and

Management

Security

and Digitalisation of

Management

Supply Chain

Impact

37

‌Ethical Conduct of Business and Anti-Corruption

Approach to Management

Severstal's corporate governance is based on the principles of business ethics and anti-corruption that contribute to building trust-based relationships both within the Company and with contractors and stakeholders. Not only does the Company follow the principles of responsible business conduct, but it advances the corporate ethical and anti-corruption requirements throughout the entire supply chain.

For more details regarding the stakeholder engagement, see the Sustainability Management section.

GRI 2-23 SASB EM-MM-510a.1

Code of Business Conduct of the Severstal Group of Companies

Anti-Corruption Policy of PAO Severstal and Related Legal Entities

Anti-Corruption Policy for Severstal Counterparties

Gifts and Business Hospitality Policy

Conflict of Interest Management Policy1

Human Rights and Community Relations Policy

Anti-Bribery Management System Standard

Employee Code of Conduct of the Severstal Group of Companies

Regulations on the Compliance Commission

Procedure for Documenting Employment/Civil Law Relationships with Former Public Officials at AO Severstal Management and Managed Companies

Key internal business ethics and anti-corruption documents

Board of Directors

Audit Committee

Sole Executive Body CEO

Internal Audit Department

Risk Management and Internal Control Department

Ethics Committee

Business Support Service

Compliance Commission

1 This document is only available in Russian.

38

About the Report

Severstal

Strategic

Corporate

Corporate

Ethical Conduct

Effective Risk

Information

Innovation Management

Sustainability

Responsible

Social Impact

Environmental

Appendices

and Materiality

Today

Report

Governance

Governance

of Business and

Management

Security

and Digitalisation of

Management

Supply Chain

Impact

39

Business unit

Functions

Board of Directors

Responsible for approval and implementation of the Anti-Corruption Policy

Responsible for monitoring the observance of the Anti-Corruption Policy provisions

Audit Committee

Control over the procedures that ensure observance of legislative requirements, and ethical norms, rules and practices of the Company

Management of the Company and operational management

Displays commitment to the principle of zero tolerance towards any signs and forms of corruption

Ensures formation, implementation and efficient operation of the anti-corruption management system

Risk Management and Internal Control Department

Ensures identification and assessment of corruption risks in the business processes

Exercises supervision over elaboration and integration of the anti-corruption management system procedures by the Company

Conducts regular training, consults the Company's management and employees on anti-corruption issues

Forms reporting on anti-corruption risks, outcomes of the anti-corruption management system operation for the Board of Directors and senior executives of the Company

Internal Audit Department

Carries out verification of observance of the ethical principles and corporate values of the Company

Reviews the Ethics Committee's reports on the outcomes of processing the submissions

Informs the Audit Committee, the Board of Directors and the sole executive body about any violations identified, including the outcomes of addressing the submissions on potential business ethics breaches

At least once a year, reports the results of monitoring the observance of the Anti-Corruption Policy provisions to the Board of Directors

Ethics Committee

Reviews submissions on potential business ethics violations

Responsible for explaining the corporate ethics principles (including conflict of interest cases) and investigating the breaches revealed in employees' behaviour

Forms reporting on its performance for the Internal Audit Department and provides recommendations on the Employee Code of Conduct enhancement

Business Support Service

Carries out the actual and potential counterparties checkup procedures

Accepts and processes applications on violations or suspected corrupt practices, carries out internal investigations of corruption incidents

Conducts preventive meetings with the heads of structural units and contractor entities to inform them of the consequences of corruption incidents and measures to be taken in the case of revealment thereof

Conducts training sessions for business units

Liaises with law enforcement agencies

Compliance Commission

Reviews cases of employees' non-observance of the internal anti-corruption documents and takes decisions on appropriate measures in the case of revealment thereof

Business Ethics

GRI 2-15 GRI 2-23 GRI 408-1 GRI 409-1

The Company's key values and principles of ethical behaviour are set forth by Severstal's Employee Code of Conduct, an important pillar of the personnel evaluation, development and motivation system. The Company prioritises employee safety and demonstrates zero tolerance to any forms of discrimination, improper or offensive treatment in its business practices. In this context, the Company's executivesundertake to not

only follow the high standards of behaviour but also to provide a lead in ethical standards and introduce their respective divisions' staff to Severstal's business ethics principles.

Severstal also expects its employees to avoid conflicts of interest, that is situations when a personal interest may affect appropriate, objective and impartial discharge of their duties. The Company looks into each conflict of interest on an individual basis, following an unbiased and equal approach to all employees and balancing the interests of the Company and its personnel. In 2024, 57 conflicts of interest identified in the course of formal declaration procedure were reviewed by the Compliance Commission. In the reporting period, the Commission

conducted a total of three meetings followed by the adoption of measures on the reconciliation of the conflicts of interest cases under review.

For more details regarding the Company's approach to managing conflicts of interest, see the Conflict of Interest Management Policy.1

The Code of Business Conduct sets forth the ethical principles Severstal is guided by in its interaction with partners throughout the supply chain. The Company adheres to high standards of integrity and openness, safety, occupational health, and environmental protection. In carrying out its activities, Severstal does not tolerate human rights abuses, forced or child labour and expects its counterparties to take the same approach. The obligations to observe the provisions of the Code of Business Conduct of PAO Severstal are included in the standard wording of procurement contracts.

For more details regarding the requirements to business partners, see the Responsible Supply Chain section.

Anti-Corruption

MED-42

In addition, all employees take regular training in anti-corruption management. The frequency and programme of such training depend on employees' job duties and are set out in Severstal's local regulations. In 2024, 3,786 employees were covered

by the anti-corruption training, which is twice as much against 2023.

Relationship with Severstal's business partners is governed by the Company's Anti-Corruption Policy for Severstal Counterparties. The obligations to comply with its provisions were added by the Company to the standard wording of procurement contracts. In 2024, Severstal notified over 2,000 suppliers about the Company's anti-corruption policies and procedures in effect. In the event corruption incidents are revealed in the practices of Severstal's business partners, the Company terminates contractual obligations with bad faith counterparties and includes them on the list of non-recommended organisations.

Name of IT system

Number of checks

Outcomes

Automated Scoring

>4,000 supplier checks completed

The acquired data factored in by tender committees in

decision-making under tendering procedures

Supplier Business Reputation Monitoring

>6,000 actual counterparty checks completed

The monitoring outcomes factored in during decision-making on interaction with business partners and in taking measures for mitigating respective risks

Performance of IT systems in 2024

For example, in the reporting period, one corruption incident revealed in the activities of Severstal's business partner led to the Company's refusal to sign a contract therewith.

GRI 205-1

To identify vulnerabilities and enhance its anti-corruption system, Severstal conducts an annual corruption risk assessment. In 2024, the said assessment was performed with regard to all of the Company's functional areas, however, it did not identify any material corruption risks.

In addition, to minimise corruption risks in counterparty engagement, Severstal makes use of the Automated Scoring IT system (prompt obtaining of information on the integrity of a

business partner) and Supplier Business Reputation Monitoring (automated check of significant changes in counterparty's activities that could give rise to corruption risks).

GRI 2-23 GRI 205-2 GRI 205-3 MED-43

Severstal pursues a policy of zero tolerance for any forms of corruption whatsoever. The Company's own-developed anti-bribery management system fully complies with the requirements of Russian

legislation and provisions of the international treaties of the Russian Federation and has been successfully certified under ISO 37001:2016. The anti-corruption management system rests on the Anti-Corruption Policy of PAO Severstal and Related Legal Entities that is binding upon all Severstal's employees, members of the governing bodies, and contractors. In the reporting year, in addition to the anti-corruption management documents in effect, the Company approved the Procedure for Documenting Employment/Civil Law Relationships with Former Public Officials at AO Severstal Management and Managed Companies.

The primary goals of the Anti-Corruption Policy of PAO Severstal and Related Legal Entities consist in:

Mitigation of corruption risks and formation of an efficient anti-corruption mechanism;

Observance of anti-corruption laws;

Instilling and fostering an anti-corruption corporate mindset in employees along with a consistent understanding of Severstal's zero tolerance position towards any forms and manifestations of corruption thereby.

Severstal's fundamental anti-corruption principles include:

Legitimacy;

Zero tolerance for any forms and manifestations of corruption;

Tone at the Top;

Risk assessment and regular monitoring, and

Informing and training.

At all times, Severstal notifies all its new hires of the requirements of the Anti-Corruption Policy and communicates any actualisation thereof to all

employees via email, without exception. The version of the Policy in effect is available to employees on the corporate web portal.

In the reporting year, the Business Support Service designed a special course for all Severstal's business units on risk assessment in counterparty engagement, counterparty checks, and risk mitigation in interaction with business partners. More than 100 employees of the procurement function completed training as part of the course.

Severstal's anti-corruption awards in 2024

Severstal once again became one of the leaders in the RSPP's Anti-Corruption Rating of Russian Business: following the assessment of the anti-corruption system performance, the Company was assigned the highest class of the A category - AAA class (companies with a very high level of anti-corruption). The jury pointed out that Severstal strictly observes the standards of procurement practices, payment process, building relationships with partners and suppliers, and personnel engagement.

1 This document is only available in Russian.

40

About the Report

Severstal

Strategic

Corporate

Corporate

Ethical Conduct

Effective Risk

Information

Innovation Management

Sustainability

Responsible

Social Impact

Environmental

Appendices

and Materiality

Today

Report

Governance

Governance

of Business and

Management

Security

and Digitalisation of

Management

Supply Chain

Impact

41

Feedback Mechanisms

GRI 2-25 GRI 2-26

Unified Hotline communication channels

Ethics Committee

Company's Business Support Service

Confidential telephone call line

Messenger (WhatsApp)

E-mail address [email protected]

Corporate web portal

E-mail address [email protected]

Postal address

E-mail address [email protected]

Any stakeholder is welcome to submit a grievance through Severstal's feedback mechanisms in order to obtain clarifications on the corporate ethics principles and to potentially enhance these, as well as to report any potential fraud and corruption cases. The Company guarantees an independent and unbiased review of all submissions, full confidentiality of information and protection from retaliation against good faith reporters of potential violations.

Submissions structure by topic in 20241

25%

%

8%

8%

12%

5

42%

Upon reviewing the submissions received by the Ethics Committee and via the Unified Hotline, the Company did not identify any cases of discrimination on racial, gender or other grounds in the reporting year.

Business Support Service

GRI 205-3

The Business Support Service (BSS) is in place to examine and check reports on potential or

committed fraud, corruption and theft. Its main goals and objectives are to combat threats and risks of causation of unlawful damage to the Company and to implement economic, information and personnel security measures.

In the reporting year, BSS received and addressed 35 reports of attempted commercial bribery towards the Company employees and identified three confirmed cases of corruption that led to criminal

Ethics Committee

GRI 2-25

Ensuring the observance of the Employee Code of Conduct, the Anti-Corruption Policy and such other local business ethics regulations, prevention and non-admittance of respective violations thereof, and enhancement of the Company's ethical principles and approaches is the responsibility of the Ethics Committee.

Compensation of mortgage interest

Goals and Plans of Development

proceedings.

In 2024, the Committee reviewed 31 submissions. Most of those referred to violations of the standards of behaviour in effect on the part of the Company's employees. The internal investigations carried out on the basis of the applicants' submissions evidenced that 48% of these were well-grounded. Following the consideration of the verified violations, the Ethics Committee elaborated remedial measures listing the actual measures against violators.

Severstal is committed to continuous development and enhancement of its anti-corruption management system. In 2025, the Company intends to update its approaches to the gifts and hospitality practices, conduct

in-person anti-corruption training courses for employees, draw up and implement procedures for monitoring the regulations approved

Unified Hotline

GRI 2-26 GRI 406-1

To promptly respond to ethics-related violations and for question or suggestion submissions, Severstal operates its Unified Hotline for employees and stakeholders.

Over the reporting year, due to the increased workload driven by the launch of #Dlya Svoikh: With Care for Everyone corporate welfare programme and introduction of newer employee financial support measures, the Company embedded new solutions to maintain high quality and prompt responses. In particular, it significantly expanded the Q&A practice on recurring topics and the pool of experts involved in preparing answers. Professionals from the HR, occupational health and safety, administrative support, social, welfare and other departments took on the role of experts. The measures taken provided for high performance of the Unified Hotline service

Submissions to the Unified Hotline, pcs

4,674

774

711

652

590

without increasing the support team size. 2020 2021

2022

2023

2024

1 The Other category covers the preferential lending programme, clean-up events, industrial safety, PPE, working, social and living conditions, non-financial motivation, etc.

42

About the Report

Severstal

Strategic

Corporate

Corporate

Ethical Conduct

Effective Risk

Information

Innovation Management

Sustainability

Responsible

Social Impact

Environmental

Appendices

and Materiality

Today

Report

Governance

Governance

of Business and

Management

Security

and Digitalisation of

Management

Supply Chain

Impact

43

Business unit

Functions

Internal Audit Department (IAD)

Renders assistance to the sole executive body and employees in elaborating and monitoring compliance with the RM&ICS enhancement procedures and activities

Assesses the internal control system performance

Draws up and submits to the Board of Directors and the sole executive body reports on the Department's performance, including information on material risks, deficiencies, results and efficiency of actions that aim to eliminate the deficiencies identified, results of implementing the internal audit plan, results of assessing the actual state, reliability and efficiency of the risk management and internal control system

‌Effective Risk Management

Approach to Risk Management

GRI 2-12 GRI 3-3

Severstal's risk management system is a crucial tool of the Company's business practices that enables it to boost business performance, find most appropriate solutions, and transform potential threats into development opportunities. Owing to its balanced approach to managing risks and opportunities, Severstal steadily attains its strategic goals.

Risk Management and Internal Control System Policy

Regulation on Internal Audit

Key internal risk management documents

Business unit

Functions

Board of Directors

Determines the principles and approaches to setting up the risk management and internal control system (RM&ICS)

Determines the level of the Company's risk appetite

Exercises control over the efficient operation of the risk management system, including regular reviews of the sole executive body's risk management status reports

Audit Committee

Exercises control over the reliability and efficiency of the risk management and internal control system, including the assessment of the procedures' efficiency and preparation of suggestions on the enhancement thereof

Analyses and evaluates the execution of the Risk Management and Internal Control Policy

Assesses the efficiency of the internal audit function

The management of the Company and operational management

Responsible for the risk management system formation and operation

Inform the Audit Committee and the Board of Directors of the RM&ICS status assessment

Risk Management and Internal Control Department

Carries out the overall coordination of the RM&ICS formation and operation

Elaborates, implements and updates the corporate standards governing the risk management and internal control process

Arranges for employee training on risk management and internal control issues

Analyses the key risks portfolio and works out proposals on the response strategy and resource reallocation for administering the relevant risks

Coordinates the drafting of reporting on the risk management process efficiency for the Audit Committee and the Board of Directors

Risk management and internal control structure

The Company's key approaches in this area are governed by the Risk Management and Internal Control Policy elaborated in accord with Russian laws, the recommendations of the Corporate Governance Code of the Bank of Russia, and the recommendations of international professional organisations. Severstal incorporated the

risk management and control functions and responsibilities into employee job descriptions and established risk management KPIs for dedicated personnel.

The Company identifies and analyses risks and elaborates risk management measures on an ongoing basis. The ESG risks identification, assessment and management processes are embedded into the overall risk management system. In this context, Severstal assesses its risk tolerance over three time horizons as follows:

Short-term tolerance (12 months from the date of approving the financial statements);

Medium-term tolerance (one to three years), and

Long-term tolerance (three to 15 years).

The Board of Directors factors in the final outcomes of the risk analysis when revising the Company's strategy and approving the budget.

To improve the employees' risk culture, Severstal conducts training on a systemic approach to risk management and internal control issues, as well as practical training on specific risk categories.

The Internal Audit Department conducts an annual assessment of the RM&ICS performance. In 2024, the Department performed 28 audits across Severstal's key business processes: product sales and logistics, capital projects and repairs, procurement of materials and equipment, contracting, occupational health and safety, operating processes, inventory management, personnel management and IT. Based on the assessment results, it was pointed out that Severstal's risk management and internal control system was by and large efficient in all material aspects and sufficient for achieving the goals of Severstal's business activities.

44

About the Report

Severstal

Strategic

Corporate

Corporate

Ethical Conduct

Effective Risk

Information

Innovation Management

Sustainability

Responsible

Social Impact

Environmental

Appendices

and Materiality

Today

Report

Governance

Governance

of Business and

Management

Security

and Digitalisation of

Management

Supply Chain

Impact

45

The Company's key risks and risk management measures in 2024

Risk factors

Risk mitigation measures

Outcomes in 2024

Risk factors

Risk mitigation measures

Outcomes in 2024

Occupational health and industrial safety risks

For more details, see the Occupational Health and Industrial Safety Risk Management section

Workplace hazards (danger of material collapse, metal structures, electric current, railway and motor vehicles, moving mechanisms, metal

melts, poisonous gases, when moving cargo and working at height), accidents at hazardous production sites

  

← →

regulations, and relevant corporate documents

of fatality risks with the participation of representatives of the OHS function, production and maintenance departments.

It resulted in a 14% reduction in potential fatalities for the top

10 fatality risks, a 17% reduction in severe injuries, and a 39% reduction in total injuries against 2023

140 registered potential fatalities, with the top 10 fatal risks occurrence (eight of them with the injured). In addition, two fatalities occurred in the Material Collapse risk category at Yakovlevskiy Mine

Observance of occupational health and industrial safety laws,

Implementation of the integrated Occupational Health and Safety Strategy adopted in 2021

Thorough control over with the observance of comprehensive health and safety policies

Regular screening of all employees for awareness of health and safety risks using a polygraph

Thorough root cause analysis of all safety issues and implementation of appropriate remedial measures

Continuous training, staff awareness-raising, and behavioural training

Extended contractor control in occupational health and industrial safety

The main activity was the formation of self-organising teams for the core areas

In 2024, there were

Environmental risks

For more details, see the Environmental Management System section

Pollutant emissions, discharges to water bodies, waste management violations that may affect human health, property, and the environment and incur various costs, non-observance of regulatory requirements, accidents with environmental damage

  

← →

2026 targets under the Clean Air project:

Observance of environmental laws, regulations, and relevant corporate documents

Industrial environmental control across the enterprises

Monitoring the engineering condition of the environmentally protected sites

Investing in environmental protection activities, enhancement of industrial equipment and technological processes

Early achievement of the

Reduction of Cherepovets Steel Mill'sgross pollutant emissions by 30.7% against the 2017 baseline

Reduction of Cherepovets Still Mill's emissions of hazardous (priority) pollutants by 27.6% through the implementation of major pollutant emissions reduction projects

Avoidance of any major environmental incidents

Climate-related risks

For more details, see the Climate-related Risks and Opportunities Management section

hydrometeorological and other climate-related phenomena) and chronic (associated

with long-term global and macroregional climate changes)

  

← →

0.78 billion for resource (extraction) assets and RUB 0.43 billion for production (refining) assets

management of 300 buildings and structures

risk management system and activities in progress

3.37% in 2024

Climate-related physical risks: acute (associated with certain dangerous

Climate-related transition risks associated with the transition to a low GHG emission economy and the measures implemented thereupon

Implementation of 346 adaptation, climatic and climate-related risk management measures totalling RUB 1.21 billion, including RUB

Extensive audit of the condition of buildings and structures, including the creation of digital databases

Commencement of elaboration of a climate change adaptation plan for Cherepovets Steel Mill

Consistent implementation of the Decarbonisation Strategy approved in 2023, including major investment activities aimed at improving the overall production efficiency and reducing the carbon footprint of products

Consistent diversification of the product range and expansion of green and adaptation products

Identification, accounting and organisation of efficient

Formation of a list of climate-related key risk factors for Cherepovets Steel Mill, execution of other works under the Climate Risk Management Standard approved in 2023

Preparation of an annual Climate Report detailing the climate

Reduction of specific CO2 emissions from production by 3.4% YoY

Increasing the share of green and adaptation products in the revenue from 2.36% in 2023 to

Supply chain risks

For more details, see theResponsible Supply Chain

Supply disruptions supply

  

← →

ESG risks on the part of suppliers and contractors

  

← →

references to Severstal's policies that are expected to be observed by the Company's suppliers and contractors

Reliable supply channels, solution-minded search for substitutes of the items under restriction

Import substitution, switch to alternative markets

IT systems development to enhance the procurement process efficiency

Timeliness of catering for customer needs constituted 97%

Equivalents found for 58% of imported risky need-based items for 2024

Launch of a procurement automation improvement project

Adding to original contracts the OHS compliance clause, the anti-corruption clause, and

Significant reduction of ESG risks on the part of suppliers and contractors

46

About the Report

Severstal

Strategic

Corporate

Corporate

Ethical Conduct

Effective Risk

Information

Innovation Management

Sustainability

Responsible

Social Impact

Environmental

Appendices

and Materiality

Today

Report

Governance

Governance

of Business and

Management

Security

and Digitalisation of

Management

Supply Chain

Impact

47

Risk factors

Risk mitigation measures

Outcomes in 2024

Risk factors

Risk mitigation measures

Outcomes in 2024

Social risks

For more details, see the Personnel Management section

  

← →

  

← →

300 social and charity projects aimed to support culture, sports, education, and SMEs implemented

projects implemented in Cherepovets and Kostomuksha in partnership with local authorities and non-profit organisations

employees and their family members residing in the Belgorod Region elaborated and implemented

Potential growth of social tension in the workplace related to payroll, potential human rights abuse, scope of work and working conditions or with manpower displacement in the course of ongoing technological enhancement and digital transformation

Efficient communication and feedback system, dialogue with employees and trade union leaders

Maintaining the wage level above the average prevailing in the regions of presence, social support measures for employees and their family members

Implementation of the personnel reallocation system at other enterprises

Analysis of the wage level in the labour markets of the regions of presence, indexation, extra payments

Support to employees and their family members residing in border areas

In 2024, the Company's average salary growth constituted 23%

Launch of #Dlya Svoikh: With Care for Everyone programme aimed to improve the living standards of employees and their family members

Implementation of extra measures to support employees and their family members working and residing in border areas

Potential growth of social tension among local communities related to unfavourable trends in the labour market or changes in socioeconomic conditions

Formation of an unfavourable social climate for the Company's enterprises' operation

Affirmative interaction with local authorities and the public

Investments in building the territories' social capacity

Involvement in addressing specific social issues of the communities

Development programmes for SMEs, local workforce capacity, improvement and creation of a high-quality urban environment

Support to employees and their family members residing in border areas

In 2024, the social investments totalled RUB 7.5 billion;

Integrated development

Support measures for

Strategic risk

High uncertainty in the global political stage and potential actions of governmental authorities (new taxes, export duties), risk of imposing additional sanctions

  

← →

Company's business resilience

Response plans to address the obstacles to ensuring the

Regulatory compliance procedures

The Board of Directors approved the main response plans in terms of addressing the obstacles to ensuring the Company's business resilience

Market risks

Change in steel demand

  

← →

Steel price fluctuations

  

← →

volatility of the average selling prices decreased

Fluctuations in prices for feedstock, fuel, and services

 

← →

Competition risks

 

← →

Customer focus in sales

Optimisation of the sales' geographical structure

Search for new sales markets

Concentration on the most resilient segments with higher added value

Despite the lower demand for steel in the Russian Federation in 2024, the Company managed to ramp up the rolled steel sales to 10.85 million tonnes

The percentage of HVA products in total sales increased by 3 p. p. YoY to 52%

Customer focus

Use of long-term contracts

Liaison with anti-dumping and tariff regulation authorities

Due to the implementation of a new strategy focusing on the Russian market and HVA products, as well as other measures listed above, the

Optimal planning of feedstock purchases, including scrap

Feedstock use efficiency improvement

In 2024, raw materials were purchased in sufficient amounts and at optimal prices. Despite this fact, the cost of production per tonne of slab, with account taken of the vertical integration effect, increased by 22% due to the execution of major repair works

Cost-saving and product quality improvement activities

In 2024, the cost-saving and product quality improvement activities were carried out as scheduled

Regulatory risks

Changes in the legislation of the Russian Federation on taxes and levies

← →

with tax, customs and other regulatory authorities

Observance of the tax, customs, currency and other laws in effect

Tracking and timely response to changes in legislation

Constructive dialogue with regulatory authorities on the interpretation of rules of law and the Company's standpoint (as and where necessary)

In 2024, the Company continued its constructive dialogue

48

About the Report

Severstal

Strategic

Corporate

Corporate

Ethical Conduct

Effective Risk

Information

Innovation Management

Sustainability

Responsible

Social Impact

Environmental

Appendices

and Materiality

Today

Report

Governance

Governance

of Business and

Management

Security

and Digitalisation of

Management

Supply Chain

Impact

49

Risk factors

Risk mitigation measures

Outcomes in 2024

Cyber security risks

For more details, see the Information Security section

External cyber attacks

 

Vulnerability of an internal landscape of IT systems

 

minimised access from external resources

Elaboration of IT service continuity and cyber attack emergency response plans

Implementation of measures for strengthening the cyber defence of IT assets

Enhancement of the processes for monitoring attacks on an external IT perimeter and automatic blocking of unwanted activities

External independent security audit

Increased cyber security awareness among personnel

34,000 Company employees covered by the information security training

Independent cyber security assessment reaffirming the high level of ISMS performance

Absence of incidents that might result in disruption or termination of the operation of critical facilities or critical information infrastructure facilities

Automated control and record of all corporate devices and software

Regular security tests, account security audits, restricted areas access testing

Centralised continuous monitoring of security events and network traffic analysis

Updates and configuration management

Application of best practices in building secure software code development processes

Elaboration of requirements and scoring model for external IT service providers

Improved control environment for software update installation processes

Enhanced segmentation of critical IT services and

Implementation of enhanced monitoring of anomalies, automation of cyber incident handling

Launch of a programme for involving employees in the detection of ISMS vulnerabilities

Risk factors

Risk mitigation measures

Outcomes in 2024

Cyber attacks on users who are the Company employees

corporate systems from the web

Information security training, briefings and workshops

Simulation of phishing attacks to test vigilance

Incident response drills and exercises

Gamification of training

Implementation of a programme to nurture a culture of cyber security and personal digital immunity for employees

Introduction of mandatory two-factor authentication and compliance check of devices when remotely accessing

Implementation of targeted notification of users within the comprehensive cyber threat reporting process and monitoring data leaks from external public services

Relative risk severity:

  - less than three months

 - less than a year

- more than a year

General variation against 2023:

↑- risk increased ← → - no change ↓- risk decreased

Plans for 2025 and Mid-Term

Severstal's risk management plans cover:

Assessing the risks of the data quality management process;

Assessing the risks of critical information systems access, and

Elaborating the measures to assess and manage production risks under the insurance programme development.

50

About the Report

Severstal

Strategic

Corporate

Corporate

Ethical Conduct

Effective Risk

Information

Innovation Management

Sustainability

Responsible

Social Impact

Environmental

Appendices

and Materiality

Today

Report

Governance

Governance

of Business and

Management

Security

and Digitalisation of

Management

Supply Chain

Impact

51

Board of Directors

‌Information Security

Information security management structure

Audit Committee

Sole Executive Body CEO

Information Security Department

96%

of employees covered by the information security training

100%

of cyber attacks successfully repelled

0

personal data leaks

2024 Highlights

Information security

Material Topic

Cyber Security

GRI 3-3

Information Security Policy

Password Protection Policy of Severstal's Corporate Information System

Personal Data Processing and Protection Policy

Regulation on Trade Secret Mode

Regulation on Control of Access to Information Resources of the Severstal Group of Companies

User Manual for the Corporate Information System1

User Agreement on the Use of Access to the Internet1

Key internal information security documents

Severstal places special emphasis on the information security issues by constantly enhancing the measures for the critically important infrastructure protection, hence ensures the integrity of the Company's business processes and confidentiality of information of employees and business partners.

Structure of managing information security issues

Business unit

Functions

Board of Directors

Determines the focal areas of the information security (IS) strategy

Supervises the efficiency of the IS management system (ISMS), reviews reports on the assessment of ISMS performance on an annual basis

Audit Committee

Exercises control over the procedures for ensuring observance of legislative requirements to IS

Reviews the ISMS performance reports on a quarterly basis

Management of the Company and operational management

Responsible for the approval and implementation of the Information Security Policy and local IS regulations

Ensures the ISMS formation, coordination, and robust operation

Information Security Department

Identifies and analyses threats to IS

Determines the procedure and control over the observance of the confidentiality regime of protected information

Responsible for implementation of information protection tools and systems and control thereof

Manages access to information resources

Ensures the detection and elimination of the consequences of computer attacks, responds to cyber incidents

The key principles, objectives and focus areas of Severstal's ISMS are set out in the Information Security Policy. The Company aims to prevent and minimise losses from leaks of confidential information, use of inaccurate or distorted data, and disruption of information processing.

1 This document is only available in Russian.

52

About the Report

Severstal

Strategic

Corporate

Corporate

Ethical Conduct

Effective Risk

Information

Innovation Management

Sustainability

Responsible

Social Impact

Environmental

Appendices

and Materiality

Today

Report

Governance

Governance

of Business and

Management

Security

and Digitalisation of

Management

Supply Chain

Impact

53

Principles underlying Severstal's information security management system

Business focus

Consistency

Integrity

Timeliness

Continuous improvement

Economic expedience

Authority minimisation

Control

Legitimacy

To provide for cyber security, Severstal consistently implements measures in the following areas:

Maintaining and streamlining an ISMS that complies with the business requirements, legislation, and global best practices;

Preventing, detecting, countering, and neutralising external and internal IS threats;

Minimising the damage from their impact;

Implementing measures to secure information systems, personnel, infrastructure, data transmission networks, and data carriers, and

Raising employee awareness of the IS issues.

To minimise the damage from external cyber attacks, malicious activity, and network anomalies, the Company has its incident response system in place. Severstal regularly elaborates IT disaster recovery plans to address the consequences of IT system disruptions. Based on the corporate response and monitoring centre, the Company embedded standard scenarios of responding to cyber threats and IS incidents, as well as a system for robotically detecting and auto-blocking typical cyber attacks.

To improve the efficiency of its activities and identify areas of growth, Severstal sets IS key performance indicators (KPIs) for the Information Security Management staff and IT managers in such ISMS categories as:

Asset management;

Operation of information protection systems (IPS);

Vulnerability management;

IS monitoring;

Backup copying, and

Infrastructure security, etc.

Severstal regularly monitors the efficiency of its IS control systems through independent audits. For example, at the premises of OOO Severstal -Shared Service Centre, Severstal's information security management system was certified to ISO 27001 and is recertified every three years for

compliance with the requirements of this standard, thus reaffirming the operability of data leakage prevention mechanisms, the relevance of measures against unauthorised access, and a high level of the IS risk management performance.

Severstal assesses cyber risks associated with external cyber attacks, internal vulnerabilities in IT systems, and attacks on users as material to its

operations and elaborates and implements mitigation measures on an annual basis.

Severstal achieves the IS risk mitigation through, inter alia, nurturing the corporate cyber security culture that it considers to be a critical element for digitalisation, it being the Company's strategic priority. Severstal notifies all employees about the content of internal IS documents and holds regular training on various aspects of information security - from recognising phishing emails to handling confidential data, including password

protection, device protection, use of cloud services, etc. In addition, the Company has a practice of cyber training for production personnel on the action plan in case of the occurrence of IS threats.

In 2024, Severstal successfully delivered a number of key projects aimed at improving cyber threat protection, in particular, by upgrading the authentication system for corporate IT services and the network traffic analysis system for automatic detection of IS threats for data processing centres' services. These projects resulted

in a two-fold reduction in the number of critical vulnerabilities in the IT infrastructure, mitigation of risks of undeclared network communication and improved security of software products being developed.

Severstal also performed a series of activities under the Cyber Security Culture project and launched an internal programme to engage employees in identifying the ISMS compromises. The Cyber Security Culture project was successfully scaled to all business units of the Severstal Group to encompass 100% of employees working with information systems. In the reporting year, over 9,000 employees contributed to regular knowledge sharing regarding the current threats and changes in the IS requirements. Those activities significantly improved the level of employee cyber literacy in terms of recognising and properly responding to cyber fraudsters.

1 120

34,000

employees of Severstal (96% of the Company's headcount) Completed the IS training in 2024

Over the reporting period, the Company conducted an independent cyber security assessment as part of a comprehensive simulation of real attacks. The assessment reaffirmed the high level of Severstal's ISMS performance.

The Company's IT staff automatically detected and blocked more than 26,000 cyber attacks, and

recorded about 200 minor violations of the IS rules. To prevent the occurrence of similar incidents in the future, the Company carried out compensatory training activities and scheduled the introduction of extra digital controls.

Owing to the ISMS robust operation, there were no incidents that might lead to disruption or termination of the operation of critical facilities or critical information infrastructure facilities in 2024.

Personal Data Confidentiality

GRI 418-1

Observing the Russian legislation on personal data processing and protection and following global best practices, Severstal respects the privacy and is committed to safeguarding the personal information of its employees, suppliers, customers, and other business partners.

Personal Data Processing and Protection Policy

Regulation on the Procedure for Personal Data Processing and Protection

Key internal documents on personal data protection

Sole Executive Body CEO

Personal data security management structure

Information Security Department

Personal Data Commission

54

About the Report

Severstal

Strategic

Corporate

Corporate

Ethical Conduct

Effective Risk

Information

Innovation Management

Sustainability

Responsible

Social Impact

Environmental

Appendices

and Materiality

Today

Report

Governance

Governance

of Business and

Management

Security

and Digitalisation of

Management

Supply Chain

Impact

55

Structure for managing personal data security issues

Business unit

Functions

Management of the Company and operational management

Responsible for approving and implementing the Personal Data Processing and Protection Policy

Exercises control over the personal data protection performance

Information Security Department

Responsible for taking measures to prevent unauthorised access and/ or transfer of personal data to persons with no rights to access such information

Performs timely detection of unauthorised access to personal data

Ensures prevention of any impact on technical means of automated personal data processing, which may result in disturbing their operation

Exercises continuous control over maintaining the appropriate level of personal data protection

Personal Data Commission

Exercises control over the compliance with the personal data protection requirements

Works out recommendations on the personal data protection system improvement

To ensure reliable protection, Severstal incorporates an integrated system of organisational and technical measures to safeguard personal data. In this context, all transactions involving personal information in information systems are subject to mandatory record keeping. Access to work resources used for data processing and to the premises with personal databases is strictly regulated and limited. In its relationship with customers and partners, the Company makes use of statutory personal data protection mechanisms and tools.

Severstal-Infocom, an internal licensee, regularly verifies the Company's observance of personal data protection laws and gives recommendations on handling any defects identified.

To minimise the risks of compromising the confidentiality of personal information, Severstal

Plans for 2025 and Mid-Term

regularly trains employees to enhance their digital competencies through the Digital Steel IT platform and with the help of special training courses on the corporate portal.

In 2024, Severstal continued streamlining its personal data processing processes, adapting them to changes in internal regulations. For instance, the Company launched an updated training course on personal data protection completed by more than four thousand people. On top of that, Severstal held over 400 separate training sessions with employees on how to safeguard confidential data.

In the reporting year, there were no cases of compromising the personal data confidentiality or of illegal transfer of personal data to third parties.

Severstal's objectives for 2025 in cyber security include the following:

Continuing with the implementation of the cyber security improvement integrated programme;

Enhancing the maturity of supporting processes;

Expanding the use of domestic IT solutions;

Improving the cyber security culture among personnel;

Fostering the data security, including the access control processes improvement and limiting off-system processing of information;

Scaling the best practices to all business units, and

Updating the internal documents that govern the IS issues.

56

About the Report

Severstal

Strategic

Corporate

Corporate

Ethical Conduct

Effective Risk

Information

Innovation Management

Sustainability

Responsible

Social Impact

Environmental

Appendices

and Materiality

Today

Report

Governance

Governance

of Business and

Management

Security

and Digitalisation of

Management

Supply Chain

Impact

57

‌Innovation Management and Digitalisation of Production

As one of Severstal's strategic customer focus areas, development of innovation enables the Company to design products that are unique to the market and best cater to the needs of Severstal's customers. In turn, the automation of routine and time-consuming tasks - digital transformation - makes it possible to optimise production, cut costs and increase productivity.

Internal Innovations and Products

GRI 3-3

Severstal successfully implements innovative solutions through a systemic approach. The Company's ecosystem is designed to monitor the current market trends and build robust cooperation with the relevant educational institutions, leading industrial companies, and academic experts to attain the Company's strategic objectives. Severstal's strategy in this domain is implemented in four practice areas:

Product innovation;

Process innovation;

Business model innovation and

Drastic innovation.

Organisation of the Patent Council Operation Proprietary Standard

Management of the Results of Intellectual Activity Proprietary Standard

Organisation of Streamlining Activities Proprietary Standard

Management of Scientific and Scientific and Technical Activities Proprietary Standard

Key internal innovation management documents

Principle 9. Businesses should encourage the development and diffusion of environmentally friendly technologies.

UN Global Compact Principle

589

patents in ownership in the Russian Federation (↑ 6%)

RUB 1.7 billion RUB

economic effect from innovation

2024 Highlights

Innovation and digitalisation

Material Topic

UN Sustainable Development Goals

In 2024, Severstal amended the internal standards governing its innovation activities: the Organisation of the Patent Council Operation Proprietary Standard and the Management of Scientific and Scientific and Technical Activities Proprietary Standard. The amendments, inter alia, referred to the approach to calculating remuneration for the authors of inventions and to harmonising the document flow, which helped reduce the number of reporting forms and optimise their structure for further digitalisation.

Innovation development management structure

Board of Directors

Sole Executive Body CEO

Technical Development and Quality Directorate (TDQD)

Technology Development Centre

Product Innovation and Solutions Department

US (User Story) Technology and Product Department

DS (Data Story) Technology and Product Department

Digital Quality Development Centre

Quality Department

Quality Development Department

Patent Council

58

About the Report

Severstal

Strategic

Corporate

Corporate

Ethical Conduct

Effective Risk

Information

Innovation Management

Sustainability

Responsible

Social Impact

Environmental

Appendices

and Materiality

Today

Report

Governance

Governance

of Business and

Management

Security

and Digitalisation of

Management

Supply Chain

Impact

59

Disclaimer

OAO Severstal published this content on June 10, 2025, and is solely responsible for the information contained herein. Distributed via Public Technologies (PUBT), unedited and unaltered, on June 10, 2025 at 13:38 UTC.