Ashburn

Anticorruption Policy

Severstal PJSC and related entities whose statements are used in preparation of consolidated financial statements of Severstal PJSC in accordance with IFRS (hereinafter collectively referred to as the “Company” and individually as the “Severstal” and the “Entity” or the “Entities”), employees and members of the Company’s Board of Directors place great store on conduct of business in accordance with generally acknowledged ethical standards and consider bribery and corruption unacceptable. This Policy, being a part of a comprehensive anti-corruption enforcement programme implemented by the Company, shall be considered as a directly applicable and binding document.

Objectives of this Policy are:

Board of Directors of the Company shall not be responsible for implementation of this policy and enforcement of its requirements.

This Policy establishes requirements in the Company’s anticorruption programme and regulates activities of management bodies of the Entities in this area.

If certain provisions of this Policy contradict with the current legislation, the Policy shall be applied in the part that does not contradict with the legislation.

The Company tends to comply with еру UK Bribery Act, as well as other anticorruption laws applied in countries in which the Company carries its activities.

Current version of the “Anticorruption Policy of Severstal PJSC and related entities”.

Please provide messages concerning possible or committed instances of fraud, corruption and theft via the following feedback channels: security@severstal.com.