1. Scope of the research and research questions

Bettercoal’s public report names Listvyazhnaya mine among the sites visited during the November 2017 site assessment. The SDS-Ugol group’s improvement plan was agreed in May 2018. A disaster occurred at the mine in November 2021. In March 2025, the Prosecutor General’s Office announced the judgment against the group’s executives and the court’s finding of a failure to act in July–November 2021. This sequence poses a verifiable question: what safety information was received between the assessment and the disaster, who considered it, and what measures were taken? DOC-020, p. 4–7; DOC-021.

The same question arises from the perspective of residents of mining areas. In May 2020, Uniper published an account of its September 2019 visit to Kiselyovsk and the proximity of mining operations to homes. Purchases of Russian coal continued in subsequent years. Connecting these circumstances means tracing decisions after the visit: requirements for operations, changes to plans, verification results and the buyer’s commercial actions. Documents recording these transitions are precisely the subject of this research. DOC-001; DOC-003, p. 54; DOC-004, p. 74; DOC-005, p. 46, 93.

The object of the research is Bettercoal’s coal-producer assessment and monitoring system, its use by Uniper and the activities of the Kuzbass operations examined. The subject is the correspondence between stated rules, documented assessments, regulatory and court information, subsequent decisions, and residents’ access to that information.

The study addresses six questions. Who set the rules and controlled the procedure? Which operations were assessed, and which sites were visited? What problems were recorded in the reports, and what violations did state authorities identify? How was plan implementation monitored? How did the buyer use the information received? Could residents and journalists safely report what was happening and obtain a substantive response?

The main period is 2015–2022: Russian site assessments, the 2019 visit, the disaster and the suspension of the Russian programme. Documents from 2012 explain the organisation’s origins. Documents from 2023–2026 are used to verify its continuity, current responsibilities and subsequent court findings. The geographical focus is Kemerovo Region, particularly Kiselyovsk and the operations explicitly named in the reports. Russia-wide purchasing figures retain their original scope.

The author, Natalia Zubkova, is a journalist and a participant in some of the events described. Her testimony about her work, threats, departure and subsequent life is a source in its own right. The research identifies when it is referring to her personal experience, a publication by another organisation, or a court decision. This preserves the human meaning of the story while allowing the provenance of each assertion to be checked.

The research accompanies the article ‘Responsible Coal: Documents and People’, Russian version V11. The article sets the narrative sequence. Here, the documents, methods of comparison, numerical data and questions requiring an organisational response are examined in detail. The matrix in the appendix allows readers to move from an article section to the research chapter and the relevant source page.

2. Verification method and organisation of evidence

2.1. Unit of analysis

The unit of analysis is an assertion about a specific actor, site and time. For example: assessors visited a particular mine; a court suspended particular work; a company reported a particular purchasing share. Before comparison, the legal entity, production site, event date, document date and subject of the decision are recorded. A shared group trading name is insufficient: an incident at a mine requires a separate entry establishing its inclusion in the site visit or a document establishing its relationship to the operator.

2.2. Selection and preservation of materials

The starting corpus comprises the 80 bibliography entries in V11, preserved Bettercoal public reports, Uniper corporate reports, British registry forms, court decisions, regulatory publications and material about the author’s persecution. Working dossiers are used to locate documents. A finding is based on the document located, rather than on an assertion in a dossier. Additional documents receive new numbers following the original sequence; article numbers are not reused.

SHA-256 hashes are calculated for saved files. The register separately records the original address, archived address, local filename and acquisition method. A hash allows the integrity of a saved file to be checked. Provenance is checked against the publisher’s address, details within the document and consistency with other publications. A copy of a court decision hosted by an aggregator is explicitly identified as such. An access-error page is retained in the technical log, but is not included in the corpus as the text of the document sought.

2.3. Reading and comparison

PDF text was extracted page by page. Table images and scanned forms are checked visually: the order of numbers during extraction may differ from the column order. For HTML, the title, date and substantive content are recorded. The date within a court ruling takes precedence over an aggregator’s automatically generated heading. Different publications of the same statement are grouped into a single chain of provenance.

Each main card contains a question, the claim as formulated, the document and precise location, a necessary short excerpt, its translation, the comparison result and a finding. The scope field specifies the site and period to which the finding applies. General limitations are explained here; the chapters discuss particular documents and results.

2.4. Timing and applicable rules

The violation date, inspection date, decision date and publication date are distinguished. A circumstance established by a court in 2025 concerning 2021 is entered in the 2021 chronology, with a separate note on when the court established it. A particular recipient’s knowledge requires a document showing receipt or consideration of information. The Code edition is checked for each site visit; 2025 requirements are used for a present-day submission, rather than to assess the 2017 procedure.

2.5. Numerical data

Purchasing shares are transcribed with their original category and denominator. The Latvia footnote is taken into account for 2019 and 2020. For improvement plans, the sum of the three statuses is checked against the total number of items. Items reported by the producer and independently verified items are presented separately. Financial balances are taken at year-end; expenditure covers the year. These measures are given separate tables and charts.

Charts are constructed from the accompanying data tables. Bars start at zero. Missing values remain blank with an explanation. Statuses are distinguished by labels and hatching. Each line in a diagram represents a specific relationship: a role, Board membership, an assessment or ownership of a site. A supply relationship requires its own documentary basis.

2.6. Testimony, translation and personal data

Natalia’s personal testimony is reproduced with attribution and a date. CPJ and RSF publications are analysed with regard to whom they interviewed and which reports they cited. Matching accounts are not treated as multiple independent eyewitnesses. No interviews, field inspections or expert examinations were conducted as part of this work. The cadastral inspection was carried out by the author of a separate document in 2019.

Short quotations are presented in the document’s language and in Russian. Numbers, the subject of decisions and the degree of certainty are preserved. Public appendices exclude private addresses, contact details, information about the daughter’s health, account access details and other unrelated personal data. The cadastral page is used in a separately prepared copy with personal data redacted.

The research cut-off date is 28 October 2026. The meeting and answers to questions for the picket were still awaited on that date. This work does not create evidence that new requests have been sent; the list at the end has been prepared for a submission.

3. What the sources establish

Bettercoal’s public reports are the principal documents on the scope of site visits, assessment-team members, published findings and the organisation of improvement plans. The full report and public summary differ in extent. The first page of the SDS report explicitly states that the full document is confidential and available to Bettercoal members. The research therefore distinguishes published group ratings from the requested allocation of findings by site. DOC-020, p. 1.

Uniper’s annual reports show how the company itself described purchases, the use of assessments and the Russia group’s work. Registry forms record directors’ appointments and the end of their terms. Election as Board Chair and appointment as a director are treated as separate events. Their sequence is reconstructed from several documents, while the question of when the Chair’s responsibilities began is left for the addressee.

Court decisions allow the subject of a dispute, the assessment of evidence and the final decision in a particular case to be reconstructed. Where a fine was overturned, that outcome is recorded. A prosecution announcement about a judgment and the full judgment differ in extent. A later civil court decision may recount circumstances of a criminal case; where such material is used, the specific document from which they were obtained is identified.

Regulatory statements published by a trade outlet retain that transmission history. Vesti PB cites Rostekhnadzor’s press service; the Union of Industrial and Environmental Safety Specialists’ pages publish statements on inspections. They establish the published substance of the measures, while the official records themselves are needed to reconstruct all orders and their implementation. DOC-034; DOC-037; DOC-041.

The Volza trade database is used as a lead for requesting transaction history. Fortum’s answer is considered in the context of the question about Listvyazhnaya, and the SDS group entry within its own scope. Comparing supplies requires a matching seller, buyer, period and consignment. In the supply diagram, an open question is distinguished from a confirmed link of participation in Bettercoal.

The persecution history draws on the original publication featuring the photomontage, the author’s testimony, CPJ and RSF publications, and interviews from the time. A human rights organisation’s publication confirms the content of its appeal and the information it gathered. Its own interviews are distinguished from retellings of reports. The illustration featuring fire and the private message threatening burning are two different sources.

The archived copy of Uniper’s article is dated separately from the article itself. It preserves text that the reader can compare with the reports. The material does not state why the availability of the original address changed. The register specifies which version was preserved and how it was obtained.

4. Bettercoal and RECOSI: establishment, governance and funding

4.1. Who established the initiative

On 18 April 2012, seven founders announced Bettercoal: DONG Energy, EDF, Enel, E.ON, GDF SUEZ, RWE and Vattenfall. Fortum was named as the first new member. The press release linked the creation of a common system to mining’s effects on workers, neighbouring communities and the environment. It envisaged common requirements and regular site assessments by external specialists, with results provided to member companies. BSR participated in establishing the initiative. Joachim Löchte was named as the first Chair. DOC-066, p. 1–2.

This arrangement matters for the research: buyers agreed a common way of obtaining supplier information. The original document combines a promise of changes on the ground with the sharing of results among members. Evaluating the outcome must therefore include two sides: what the assessor found at an operation, and what the buyer did with the information received.

4.2. Legal continuity

Companies House records incorporation on 28 February 2012, company number 07968009 and the form private company limited by guarantee without share capital. The name BETTERCOAL was in use until 22 November 2023; the current name is Responsible Commodities Sourcing Initiative Ltd. The register retains the same number. The coal programme continues to use the name Bettercoal. DOC-055, sections Company type, Incorporated on, Previous company names; DOC-063, p. 2.

The register gives a registered office in Hildenborough; RECOSI publishes a contact address on Shelton Street in London. These are treated as two different details in the research. The organisation’s name change is accounted for in all tables, so that an appointment to RECOSI in 2025 does not appear to be an appointment to a separate body unconnected with the earlier programme.

4.3. Allocation of responsibilities

The 2021 annual report distinguishes the Board of Directors, secretariat, Members’ Committee and Technical Advisory Committee. The Board provides strategic leadership. The secretariat handles day-to-day work. The Members’ Committee considers plan progress and action in cases of non-performance. The technical committee provides expert advice on the standard and procedures; it includes representatives of civil-society organisations, academia, mining companies and Bettercoal members. DOC-056, p. 13.

In October 2021, members approved governance changes. At year-end, the Board approved changes to the assessment system, including a four-year cycle and deferring the right to call a company a Bettercoal Producer until after a site assessment and agreement of a plan. These decisions affect the meaning of the status: historical profiles recording early participation must be read under the rules of their time. DOC-056, p. 12–13.

The governance page preserved on 28 October 2026 lists 11 directors. The Chair is Gerda Frans of ENGIE; the Vice-Chair is Taco Douma of RWE Generation. Uniper is represented by Nadja Wendler. The Board also lists representatives of BEW, EnBW, Enel, ResInvest Commodities, Jera Trading, ONYX Power and Vattenfall, and Executive Director Katie Warrick. The relationship register and diagram show company representation and the distinction between the Board and the Russia Working Group. DOC-014, Board of Directors.

RECOSI’s Articles of Association, filed in December 2023, explain who votes and appoints the leadership. At a general meeting, each member has one vote. Associate members and programme participants may attend and speak, but may not vote. An ordinary resolution requires a simple majority of members present and voting; a special resolution requires a 75% majority. The meeting quorum is one third of the membership, rounded up. This is the allocation of voting rights under this edition of the Articles; earlier membership and rules are examined through historical documents. DOC-069, provisions 11.2, 15.2, 16.1–16.3, PDF pp. 8, 10.

The Board must comprise six–twelve directors, including the Executive Director; the Articles allow up to two independent directors. The Board gathers members’ proposals, selects candidates and nominates them for election by the organisation’s members. Directors are normally elected for three years. The organisation’s executive head automatically serves on the Board during their tenure. The directors appoint the Chair and Vice-Chair from among themselves; they may also terminate those appointments. DOC-069, provisions 21.1–21.5, 23.1–23.4, PDF pp. 12–14.

The Board appoints the executive head, who implements the strategy approved by the Board. The Board may delegate powers to committees, approves their terms of reference and budgets, and receives their reports. Board decisions are taken by a majority where a quorum is present, or by a unanimous written decision. Reconstructing a particular decision therefore requires not only the directors’ names, but also the minutes, the identities of those voting and the allocation of responsibilities then in force. DOC-069, provisions 25.1, 27–28, PDF pp. 14, 16.

4.4. Money: expenditure and balances

In its 2021 report, Bettercoal identifies annual fees from members and associate members as its funding source. That year, the organisation also moved to a model in which producers pay for site assessments. Expenditure is grouped into four items: secretariat — £395,000; assessments, plan monitoring, online platform and standard — £143,000; internal governance — £19,000; communications — £14,000. The published items total £571,000. This is calculated by adding those rows, rather than taken as a separate income figure. DOC-056, p. 22, printed pp. 42–43.

The explanation of 2021 expenditure explicitly states that there were no site assessments because of the pandemic. Programme costs included remote plan monitoring, revision of the rules and development of the platform. This expense item therefore cannot be used as the cost of Russian site visits. Allocation by country and specific assessment requires contracts, invoices and an analytical breakdown.

The 2017–2022 balance sheets show cash at bank and total assets less current liabilities at year-end. The values are brought together in a separate table and chart using consistent units. A balance sheet describes the financial position on a date; it does not replace an annual Income Statement. All sets examined contain a statement that an Income Statement was not filed under section 444 of the Companies Act 2006. DOC-070–DOC-075, p. 4 of each file.

RECOSI’s new 2025 report, published on 17 August 2026, reports 14 funding members. It separately lists RECOSI expenditure of £572,950, internal governance of £25,279, the Bettercoal programme at £117,637, the gas programme at £80,422, and communications and stakeholder engagement at £49,602. These total £845,890. Producers pay for assessments, and RECOSI pays third-party assessors. These categories are shown in a separate table: the programme structure has expanded, so the figures are not joined to the four 2021 items in a continuous series. DOC-083, p. 12; DOC-087.

4.5. Chapter findings

The organisation was established by buyers, is funded through membership fees and uses producer-funded assessments. Governance, technical expertise and programme implementation are allocated to different bodies. Checking the influence of funding on a particular assessment requires contracts and documents appointing the assessor. The following chapters examine the available selection rules and specific Russian assessments; the question of who paid for each Russian assignment is included in the requests.

5. The Code, assessment and verification of implementation

5.1. Applicable rules

Bettercoal linked assessment to its own Code. In version 1.1, requirements cover lawful operations, workers’ and residents’ rights, safety, pollution, waste, land use and closure of operations. This version was approved on 28 June 2017. KRU’s November 2015 and May 2017 visits predate that approval. The version 1.1 requirements table is therefore used for subsequent monitoring and comparison of issues, rather than as a list of rules automatically applied to earlier site visits. Fully reconstructing the earlier assessments requires the first Code edition and identification of the version specified in the assessor’s contract. DOC-053, PDF 7; DOC-043, p. 5–6.

Provision 1.1 of version 1.1 requires compliance with applicable law. Provision 2.2 concerns reporting violations and grievances, and provides for protection of complainants. Provision 6.9 requires management of health and safety risks. Sections 7, 9 and 10 address effects on residents, resettlement, waste, pollution and biodiversity. These topics allow reports to be compared with specific circumstances: explosive dust in a mine working, exceedances in residential areas, residents’ complaints or the condition of a waste-rock dump. Provision numbers and pages are given in the requirements table. DOC-053, p. 12, 14, 22–25, 28–29.

Version 2.0 was published in March 2021. Bettercoal’s annual report describes its introduction and translation into Russian. That year, the Board also changed the reassessment cycle: the previous range of three to five years was replaced with a four-year period. The timetable in an early report and a later general procedure may therefore differ. The research distinguishes a planned reassessment date from a site visit actually carried out. DOC-065; DOC-056, p. 12, 20.

5.2. Letter of Commitment and joining procedure

Early reports explicitly explain why an assessment could precede a producer’s Letter of Commitment. Such a letter became a requirement following the 2017 process revision. For example, Taldinskaya Mining Company’s desktop assessment is dated October 2016, its letter August 2017 and its site visit November 2018. KRU’s report records a November 2017 letter, although the first visits took place in 2015. DOC-043, p. 5; DOC-045, p. 5.

Later producer profiles sometimes give different engagement start dates. KRU’s timeline begins in April 2015 and SUEK’s in August 2017, while the public reports date their letters to November and September 2017 respectively. An answer requires the letters themselves and an explanation of the event each profile denotes. Site-visit and plan-agreement dates in the table are taken from the assessment descriptions; the differing early registration dates are retained among the requests. DOC-010; DOC-050.

5.3. What happened after the site visit

Assessors reviewed documents, visited selected sites and spoke with stakeholders. Findings formed the basis of a Continuous Improvement Plan, or CIP. The producer was to report implementation of items, and the assessor to verify the evidence submitted. The full report and monitoring materials were available through the members’ information-sharing system. The public report provided a condensed description. This distinction is stated on the first page of the SDS report. DOC-020, p. 1, 5, 7.

In its 2019 report, Uniper stated that Russian producers were reporting on implementation of their improvement plans at least twice a year. What reports arrived between visits, what did they contain, and what decisions followed? A public summary of closed-item counts shows the resulting status, but reconstructing action at a specific mine requires the communications themselves, supporting material and the assessor’s decisions. DOC-003, PDF p. 63 / printed p. 61.

The current January 2024 guidance describes the questionnaire, assessor selection, site visit, report, plan and follow-up monitoring. The October 2025 rules allocate the weighting of an assessor’s proposal between the technical component — 70% — and the financial component — 30%. A producer may object to an assessor for a substantiated reason, such as a conflict of interest. These documents describe the current procedure; the corresponding historical guidance is needed for the Russian visits. DOC-061, p. 11, 19–21, 30; DOC-064, p. 7–9.

5.4. Compliance ratings and urgency — different scales

The SDS report’s key contains four levels: Meets — full compliance with convincing evidence of implementation; Substantially Meets — largely compliant, but with some gaps; Partially Meets — work has begun, but implementation is incomplete; Misses — work has not begun or there is a systemic failure. For the SDS group, section 2.2, ‘Reporting violations / grievances’, was rated Misses, while section 6.9, ‘Health and safety’, was rated Partially Meets. DOC-020, p. 6, 10.

The same page states that there were no findings in the Immediate Resolutions category, requiring immediate action. This characterises the urgency of a particular category. An adverse compliance rating for a section nevertheless appears in the table. Both results must be read together. Allocating findings to mines requires the full report identifying sites and the action plan. The complete table page and its key are included in the appendices.

5.5. Complaints, their handling and consequences

The procedure dated 19 June 2025 provides for complaints about the organisation, its representatives, producers and assessors. Events more than five years old are among the grounds for refusing admissibility. On the research date, 28 October 2026, events in November 2021 still fall within that period. Questions concerning ongoing consequences and earlier events must be put to the organisation with precise dates. DOC-063, p. 2–4.

The procedure permits submissions in a local language, although English is preferred. Confidentiality may be requested; the circumstances can sometimes identify a complainant. The stated acknowledgement period is ten working days, followed by an admissibility decision. The indicative period for proposing a resolution is 60 calendar days. An appeal must be lodged within twenty working days. Review takes place within the programme’s structure, involving the technical committee and Board. This describes the current mechanism; it is not evidence that a particular submission by Natalia has been considered. DOC-063, p. 3–6.

A documented example of participation ending is the announcement concerning JSC Shubarkol Komir dated 24 June 2019: following the November 2017 assessment, the parties decided to disengage because the plan could not be implemented under the strategic and economic circumstances then prevailing. The 2025 report again describes a site visit to Shubarkol in the fourth quarter, and an assessment of Black Royalty Minerals. The report states that completion of both processes was planned for 2026. This history shows why disengagement and subsequent return must be recorded as separate events. DOC-059; DOC-083, p. 17.

Chapter findings. The system provides for more than a single site visit: it includes subsequent reporting, verification of implementation and status changes. For Russian operations, this intervening documentary record is precisely what is needed to answer the research’s central question. In the requirements table, each incident is paired with a specific request concerning verification and results.

5.6. Status, logo and consequences of non-performance

The claims and logo guidance dated 23 January 2023 prohibits producers and buyers from describing participation as certification, accreditation or endorsement. The right to use the status is tied to a completed site assessment and an agreed plan, with no open Immediate Resolutions issues. Where claims are misleading, the secretariat requires correction and may restrict logo use. DOC-054, pp. 3, 5, 8–11.

The policy dated 23 April 2025 provides for disengagement in cases of missed commitments and deadlines, failure to report against the plan, false information or an insufficient response to enquiries after a risk event. The secretariat may agree deadline extensions where circumstances are explained; reminders and an appeal procedure are specified. DOC-062, pp. 3–6. To examine decisions in the Russian period, the edition then in force and decisions for each producer are requested.

6. Russian producers: sites, assessments and violations

6.1. KRU: open-pit mine visits and the 2019 inspection

Bettercoal’s public report covers six Kuzbassrazrezugol open-pit mines: Kedrovsky, Mokhovsky, Bachatsky, Krasnobrodsky, Taldinsky and Kaltansky. The list of actual visits names Krasnobrodsky in November 2015, and Bachatsky and Taldinsky in May 2017. James McNally and Yelena Borovikova of SLR Consulting conducted the assessment. The overall scope and the visit itinerary are distinguished here. DOC-043, p. 5.

The report’s findings noted weaknesses in stakeholder engagement: the list of organisations and people lacked contact details and engagement analysis. At the same time, assessors described water- and energy-management practices and environmental measures. There were no findings in the Immediate Resolutions category. These results concern the KRU assessment within its stated scope. DOC-043, p. 8–9.

On 14 May 2019, Rostekhnadzor’s press-service statement was published concerning an inspection of 70 hazardous industrial facilities at six KRU branches and the separate Salair Mining Production structural unit. More than 200 violations were identified. At Bachatsky, operation of a loading and unloading facility — transfer point No. 2 of open-pit mine No. 5 — was suspended for one month. At Krasnobrodsky, mining and drilling along the roof of the Moshchny seam of open-pit mine No. 7 were suspended for three months. The statement reports liability of the company and 142 officials. This was an inspection of several sites, while the suspensions concerned specific work. DOC-034.

Bachatsky and Krasnobrodsky therefore appear both in Bettercoal’s visit list and in the subsequent regulatory statement. The period between these dates was a period of plan implementation. What inspection information did assessors receive, which items did they change, and what evidence of remediation did they require? Answering requires the monitoring log, KRU’s communications after the inspection and the assessor’s corresponding decisions.

6.2. Vakhrushevsky field and a separate penalty overturned

Case А27-110/2019 concerns JSC Coal Company Kuzbassrazrezugol, taxpayer number (INN) 4205049090, state registration number (OGRN) 1034205040935. It examined requirements relating to coal-beneficiation waste from OUKNS-4 at the Krasnobrodsky branch’s Vakhrushevsky field and payments for 2013–2015. The company linked use of the material to land rehabilitation. The court considered the legal status of the waste’s actual placement and the payer’s duties. The first-instance decision of 16 May 2019 and the appeal of 31 July survived cassation; the cassation ruling was issued on 20 November 2019. DOC-035.

This dispute concerns waste management. It cannot be added to industrial violations from another inspection as a single numerical measure. For Bettercoal, the substantive question is how assessors checked the purpose of the material being placed, permits and subsequent court findings.

In a different case, No. 12-71/2019, Belovo District Court on 27 June 2019 overturned a 10,000-rouble fine concerning rules for operating gas-cleaning installations at the Bachatsky branch. The court terminated proceedings because the circumstances underlying the penalty had not been proved. The research records this incident as an overturned decision, rather than an established fine that remained in force. DOC-036, concluding part of the decision.

6.3. SUEK: mines visited and a preparatory working

In May 2018, assessors visited the Taldinskaya-Zapadnaya-1 and Taldinskaya-Zapadnaya-2 mines, the mines named after V. D. Yalevsky and A. D. Ruban, and the Zarechny open-pit mine. The team named comprises Paul Mitchell, Julija Menise and Tatiana Vasenko. The plan was agreed in March 2019. The report describes meetings with trade unions, city representatives and workers’ associations, as well as findings concerning closure planning, engagement with business partners and biodiversity conservation. DOC-044, p. 5–6, 9.

An inspection on 13 February 2020 at JSC SUEK-Kuzbass’ Ruban mine identified deposits of explosive coal dust, deficiencies in support systems and breaches of equipment explosion-protection requirements. Rostekhnadzor prohibited development of assembly roadway No. 816 — a preparatory mine working — and cargo transport along haulage roadway No. 818. The materials were referred to court. The statement was published on 25 February by the Union of Industrial and Environmental Safety Specialists, citing the regulator. DOC-037.

In the separate sanitary case No. 12-328/2019, Kemerovo Regional Court on 17 June 2019 upheld a 10,000-rouble fine against JSC SUEK-Kuzbass. The court found an exceedance of the average daily maximum permissible concentration of nitrogen dioxide in a residential area by a factor of 2.7, and of the permissible maximum night-time noise level in a bedroom by 1.3 dBA. It considered arguments about sampling points and sources of impact. One measurement beside the haul road was not used, while measurements in the residential area were found admissible. DOC-038.

In the first incident, the site matches the mine visited. In the second, the document establishes the same legal entity’s liability and an impact on a residential environment; a connection to the Ruban mine cannot be inferred from the paragraphs’ proximity. The request to Bettercoal must separately address industrial safety in the named working and consideration of the sanitary decision in the company’s plan.

6.4. SDS-Ugol: a positive public description and the ratings table

The group report lists actual visits to the head office, the Salek and Vostochny sites in Kiselyovsk, Chernigovets and Listvyazhnaya. The wider scope list also includes other group operations. The visit took place in November 2017; the plan was agreed in May 2018. Interviewees included regulators, trade unions, civil-society organisations and residents of several settlements. Establishing who selected interviewees and how their safety was ensured requires the interview programme and confidentiality rules for that visit. DOC-020, p. 4–5.

The March 2018 corporate announcement describes the result positively. Bettercoal’s public table, published in January 2019, also contains Misses for reporting violations and grievances, and Partially Meets for health and safety. These are group ratings. They must be compared with the corporate account as two parts of the published picture, preserving both the good practices noted by assessors and the outstanding work. DOC-048; DOC-020, p. 6–8.

At JSC Chernigovets’ Yuzhnaya mine, Kemerovo District Court on 12 February 2018 suspended development of a transport working in the Vladimirovsky-II seam for ten days. Circumstances listed in the ruling include insufficient stone-dusting, support-system breaches and inadequate dust protection. The suspension period is linked to the prohibition of 8 February. Yuzhnaya is within the group report’s overall scope, but is not named among mines actually visited. DOC-039; DOC-020, p. 4–5.

What specific problems lay behind the ratings for sections 2.2 and 6.9? When were they resolved, who verified this, and what documents confirm implementation? I request the full report and improvement plan identifying which findings relate to each mine.

6.5. Taldinskaya Mining Company

The report covers and lists as visited the Taldinskaya-Yuzhnaya and Kyrgayskaya mines. The November 2018 visit was conducted by The Dragonfly Initiative: Julija Menise, Tatiana Vasenko, Vladimir Simov and Peter Whitbread-Abrutat. The plan was agreed in September 2019. Strengths included anti-corruption measures and record-keeping; findings concerned personal protective equipment, sanitary conditions, handling oils and chemicals, and public reporting. DOC-045, p. 5, 8.

On 2 November 2020, Prokopyevsk District Court heard case No. 5-142/2020 concerning JSC Shakhtoupravleniye Taldinskoye-Yuzhnoye. Following the 27 October inspection, development of a conveyor roadway was suspended for seven days. The decision names hazardous dust, deficiencies in water sprays and supports, and fire-prevention measures. The company’s representative reported that the violations had been remedied; the court ordered suspension. A document confirming subsequent verification of implementation should be requested separately. DOC-040.

6.6. KTK and TalTEK: early stage of the programme

Bettercoal profiles record KTK’s participation as beginning in January 2020 and TalTEK’s in February 2021. The profiles examined place them at an early stage, before a completed site assessment. Their violations are considered as information relevant to selection and initial assessment. DOC-046; DOC-047.

The inspection of PJSC Kuzbasskaya Toplivnaya Company’s Karakansky-Yuzhny site ran from 28 January to 17 February 2021. The regulatory statement names 44 violations, including a danger zone that had not been properly documented and marked, and departures from project designs. A temporary prohibition was imposed from 10 February; the court suspended work in the danger zone for 60 days. The 24 February publication gives total fines of 439,000 roubles. DOC-041.

According to Rostekhnadzor’s press-service statement, reproduced by PravoTEK on 12 January 2022, an inspection of LLC Razrez TalTEK on 23–28 December 2021 identified breaches of bench and safety-berm parameters. On 30 December, Novokuznetsk District Court suspended mining in the danger zone for 90 days. The full court decision is needed for the documentary appendix; the register preserves the source of the regulator’s statement. DOC-042.

6.7. What the four plans show as at July 2022

KRU has 58 published items: 20 verified, 23 reported completed and awaiting verification, and 15 open. SUEK has 40: 17, 8 and 15 respectively. SDS has 49: 16, 11 and 22. Taldinskaya Mining Company has 63: 12, 12 and 39. The four profiles total 210 items: 65 verified, 54 awaiting verification and 91 open. The underlying values table and chart appear below. DOC-010; DOC-050; DOC-011; DOC-051.

The counting unit is a plan item, rather than a legal violation. Items differ in nature and severity between groups. ‘Awaiting verification’ is distinguished from verified implementation. Following suspension of engagement in April 2022, the profile date ‘July’ describes the published summary; the actual verification dates of individual items require monitoring logs.

Chapter findings. The comparisons establish specific matches of sites and legal entities, but distinct events over time. Assessors visited the named KRU open-pit mines, Ruban mine, Listvyazhnaya and Taldinskaya-Yuzhnaya. Yuzhnaya is within the group scope. KTK and TalTEK were at an early stage. This approach allows questions about oversight to be addressed to the precise procedure that existed at the time of an event.

7. Listvyazhnaya: from assessment to court findings

The mine’s legal entity is LLC Shakhta Listvyazhnaya. The Prosecutor General’s Office announcement of 25 March 2025 identifies it as a subsidiary of the SDS-Ugol holding company. Bettercoal’s public report shows a visit to this mine in November 2017 and agreement of a group plan in May 2018. The relationship therefore runs through a specific site, rather than merely through the holding company’s name. DOC-021; DOC-020, p. 4–5.

7.1. Sequence of events

Bettercoal’s report scheduled the next assessment for November 2022. Plan monitoring was envisaged between visits. The 2021 annual report states that the pandemic prevented site assessments that year; engagement and review of materials continued remotely. These details describe how the organisation worked. The mine requires its own record of checks, communications and decisions. DOC-020, p. 5, 7; DOC-056, p. 3–4.

An explosion occurred on 25 November 2021. The Emergencies Ministry recorded 51 deaths, including five mine rescuers. DOC-089, PDF 34. The following day, Bettercoal reported contact with SDS, expressed condolences and stated its intention to establish the causes and necessary preventive measures. In December, the organisation held a webinar with leading independent assessors on Russian producers’ plan statuses, to help buyers understand specific risks and improvement work. DOC-021; DOC-024; DOC-056, p. 20.

On 28 April 2022, Bettercoal announced the suspension of its Russian programme against the backdrop of Russia’s invasion of Ukraine and associated risks. Programme-organised plan verification and the ability to use the status on the previous basis ended. The website publication is dated 3 May and contains the 28 April statement. These dates are distinguished in the chronology. DOC-079.

7.2. Judgment against the executives

According to the Prosecutor General’s Office, Kemerovo’s Central District Court found deliberate inaction by executives in July–November 2021: they failed to take the measures needed to bring the mine into compliance with industrial safety requirements. Mikhail Fedyaev is identified as the group’s Board Chair and a shareholder, Gennady Alekseev as Chief Executive Officer and a Board member, and Anton Yakutov as Technical Director. Alekseev received five years and three months’ imprisonment, Yakutov five years, and Fedyaev a suspended sentence of three years and six months. DOC-021.

On 21 April 2025, Interfax, citing the courts’ press centre, reported that the judgment became final on 17 April and that no appeals had been lodged. Later civil decisions also refer to the final judgment against the executives. Kommersant’s article records the defence’s position, disputing causation and the extent of managerial duties. The register distinguishes the official announcement, court document and journalistic account of the proceedings. DOC-022; DOC-023; DOC-084; DOC-085.

7.3. What the 2026 civil cases add

Kemerovo Regional Court decisions dated 26 March and 2 April 2026 address compensation claims arising from deaths. The court recounts material from the technical investigation and criminal cases. In particular, it mentions a final judgment concerning breaches of the rules for operating the Mikon III atmospheric and gas monitoring system. This is a separate documentary route to the issue of gas monitoring, alongside the general judgment against the executives. DOC-085, case No. 33-2951/2026; DOC-084, case No. 33-2762/2026.

Dates are taken from the decisions’ text: the aggregator’s headings show 25 March and 1 April respectively. The appendices do not reproduce families’ personal circumstances, individual claim amounts or medical information. Verifying the causes of the accident requires the full technical investigation report and court decisions concerning the monitoring system. The civil decision preserves their account within the scope of the case considered.

7.4. What documentary record is needed between 2018 and 2021

Required: the mine-specific section of the improvement plan; all implementation reports with dates; assessors’ observations on the information submitted; information about official inspections received by Bettercoal; decisions on deadline changes and extraordinary checks; December webinar materials; and results of the review promised after the accident. For each document, its recipient and receipt date matter. Publication of a court finding in 2025 concerns events in 2021, but does not replace evidence of what information assessors held earlier.

Chapter findings. The documents connect one mine with the 2017 visit, the 2018 plan, the accident and the court-established failure of executives to act in 2021. Bettercoal’s public response and the December webinar are known. A substantive organisational answer must disclose checks and decisions between these points, and the results of the subsequent review.

8. Uniper: visit, purchases and decisions by governing bodies

8.1. Why a buyer needs assessments

In its 2019 report, Uniper explicitly explains its use of Bettercoal information: assessments form part of environmental, social and governance risk assessment and supply-chain monitoring. Printed page 52 / PDF page 54 contains both this statement and purchasing data. Printed page 61 / PDF page 63 refers to Russian producers’ reporting on plans at least twice a year. This is a documented connection between the procedure and the buyer’s work. DOC-003.

8.2. What the company saw in Kiselyovsk

Uniper’s article ‘The dilemma of investing in social and environmental remediation activities’ describes a visit to Kiselyovsk in September 2019 as part of a Bettercoal mission. The company describes the proximity of mining to housing and the short time spent in the town. A longer conversation in Chuvashka was a separate part of the itinerary. The archived copy preserves discussion of resettlement, rehabilitation of disturbed land and the difficulties of choosing measures. DOC-001, May 2020 publication; archived snapshot dated 18 June 2020.

Uniper also wrote that the most severe impacts involved operations with which neither it nor Bettercoal engaged directly. This position should be read alongside its own description of the town. Which sites were meant, which suppliers were checked after the visit, and what changes were required? Answering requires the itinerary, site list, final memorandum and subsequent decisions.

The cadastral report dated 3 July 2019 provides a separate measurement. On 26 April, the engineer inspected a residential house and the nearest waste-rock dump; the distance from the nearest foot of the dump to the footprint of the house inspected was 461.98 metres. This measures a specific inspected house. The complete page, with personal data redacted, is appended to the research. DOC-080.

8.3. TDI and information about intimidation

TDI Sustainability’s study was prepared for Bettercoal’s Russia Working Group, established in December 2018. The document lists ENEL, ENGIE, ESB, Fortum, RWE, Uniper and Vattenfall. The work included a review of Russian- and English-language material and a visit in September 2019. The authors described their task as gathering and explaining the context of reports by civil-society organisations and researchers. DOC-002, p. 2–3.

Page 4 states: Finally, according to the rights group, FERN, intimidation of local environmental campaigners by coal companies is reportedly prevalent in Kuzbass. The information is attributed to FERN; TDI relays it. The sentence concerns a regional problem. The recommendations include grievance mechanisms and the ability to express concerns safely. DOC-002, p. 4, 6–7.

The question for those commissioning the work is how this information was translated into action: who was responsible for interviewees’ safety, how complaints were checked, and what measures could be taken. The report’s publication date — February 2020 — is distinguished from the 2019 visit and the threats against Natalia reported later.

8.4. Three purchasing figures

Shares of Uniper’s direct contractual purchases were 35.1% for 2019, 29.9% for 2020 and 22.6% for 2021. The first two categories include Latvia; the third is labelled Russia. The chart uses separate bars with full category labels. The percentages describe purchases under direct contracts, rather than company profits. DOC-003, p. 54; DOC-004, p. 74; DOC-005, p. 46, 93.

The 2022 annual report states that Russian purchases ended in August. This means that purchases continued after the visit and into part of 2022. Assessing a specific consignment requires a contract, legal entities and origin information. Country-level reporting does not allocate purchases among mines. DOC-006, PDF p. 41 / printed p. 37.

8.5. What the 94.48% result means

On 19 May 2021, under agenda item 4 at Uniper’s meeting, shareholders approved the Supervisory Board’s actions in 2020. Votes in favour totalled 305,116,131 out of 322,950,342 valid votes — 94.48%; votes against totalled 17,834,211. The percentage’s denominator is valid votes on this item. The document states the subject of the vote alongside the result. DOC-081, p. 1.

The critical shareholders’ counterproposal opposed approval, including for reasons relating to coal-chain responsibility and human rights. It shows the substance of the public criticism, while the official record shows the subject and outcome of the meeting’s decision. Both documents, read separately, matter when relating this to purchases. DOC-019, p. 2–3.

8.6. Suppliers: what can be shown in a diagram

Question 39 from Fortum shareholders in 2022 concerns Listvyazhnaya. The answer states that Fortum and Uniper had not bought coal from this supplier in recent years; years and a legal entity are not separately specified. Volza lists the SDS group among suppliers to Uniper Global Commodities SE, but the public profile does not disclose comparable dates or mines of origin. These records are therefore placed in the table of commercial relationships to be checked. DOC-052, p. 16; DOC-077.

I ask Uniper to disclose its purchasing history with SDS-Ugol: years, sellers’ legal entities, volumes and mines of origin. The same details are needed for KRU and other names in the trade directory. Material concerning other global suppliers must undergo the same checks before being added to the diagram.

Chapter findings. Uniper’s own documents connect the visit, public observations, use of assessments and continued purchases by country. The vote concerns approval of the Supervisory Board’s actions. The next level of verification is supplier-specific decisions and the origins of consignments.

9. People, responsibilities and documented relationships

In this chapter, a line between two names always represents a defined relationship: employment, Board membership, conducting an assessment or ownership of a production site. The period is stated beside the source. Commercial information still requiring consignment-specific documents is placed in a separate requests table.

9.1. Frank Plümacher

The imprint of Uniper’s 2017 report identifies Plümacher as Executive Vice President HSSE & Sustainability. The report was published in May 2018. HSSE encompasses health, occupational safety, security and environmental protection; Sustainability refers to sustainable development. The document confirms this professional role before the Kiselyovsk visit. The precise start date must be established from the appointment, rather than the reporting year. DOC-078, final PDF page, p. 17.

Uniper’s 2019 report dates his election as Bettercoal Board Chair to April and describes a three-year appointment. Registry form AP01 records his appointment as a director on 18 June 2019. Election as Chair and appointment as a director are different events. I request clarification of the sequence of these decisions and the date on which he began exercising the Chair’s responsibilities. DOC-003, p. 54; DOC-076, p. 1.

Plümacher’s governance involvement is reflected in signed accounts. The 2019 balance sheet was approved on behalf of the Board on 30 June 2020, and the 2020 balance sheet on 20 May 2021. The pages bear the name F. Pluemacher. The signature confirms approval of the accounts; specific decisions about Russian mines must be sought in Board minutes and supporting materials. DOC-072, p. 4; DOC-073, p. 4.

In the foreword to Bettercoal’s 2021 annual report, he speaks as Chair. A short statement defines his public position: Site assessments are central to the work of Bettercoal . The same foreword states that the pandemic prevented teams from returning to sites in 2021. The Board updated the Code and rules, while the organisation continued remote work on plans. This provides a specific question for the Chair: how was the adequacy of that monitoring assessed, and when was the need for an extraordinary site visit discussed? DOC-056, p. 3–4, 12.

Another document reveals Uniper’s practical involvement in the secretariat’s work. The Dutch Coal Covenant report for September 2017–October 2018 describes seconding a Uniper employee for two years to support improvement-plan monitoring. It also states that Uniper’s Supervisory Board regularly received information on responsible coal sourcing. The document publishes Plümacher’s comment on a visit to Colombia. This was a separate visit; its information is not transferred to the Russian delegation. DOC-088, p. 24.

Form TM01 records the end of his directorship on 27 November 2025. On 3 December, RECOSI announced Gerda Frans as the new Chair and thanked Plümacher for six years of leadership. At the research date, Uniper presents him as Head of HSSE & Sustainability and Human Rights Officer. In his published statement, he links this work to early identification, assessment and mitigation of human rights and environmental risks in the company’s value chains. DOC-068; DOC-013; DOC-015.

Why he is an addressee. Plümacher connects historical leadership of Bettercoal during the visit and disaster with Uniper’s current human rights function. The documents provide grounds to ask him about Board work, materials received, risk assessment and arrangements for considering a submission today.

1. What Russian-plan reports reached the Board in 2019–2021, and which matters were discussed with your involvement? Please provide the minutes and appendices for those items.
2. How did the Board assess remote monitoring in 2021? What information could trigger an extraordinary visit, and was such a need considered for SDS?
3. What decisions were taken after the disaster and the December webinar? Where are the results of the promised review?
4. Since what date have you been Human Rights Officer? Who will consider Natalia’s submission, within what time frame and with what written outcome?

9.2. Nadja Wendler

The EGYPES 2024 conference report identifies Wendler as Vice President, Sustainability at Wintershall Dea AG. PDF page 15 contains her statement: Governments, industry leaders, innovators, and communities must unite in a shared mission for a sustainable future, leaving no one behind. DOC-058, PDF p. 15 / printed pp. 26–27.

By 3 December 2025, RECOSI described Wendler as Uniper’s Senior Vice President Sustainability and a new Board member. The registry form gives her appointment as a director as 27 November. Her start at Uniper is a separate date; establishing it precisely requires the appointment document. Her 2025 role is not projected back onto Russian events in 2017–2022. DOC-067, p. 1; DOC-013.

In the current structure, the Board is responsible for strategic governance, while the secretariat handles day-to-day work. Wendler represents Uniper on the Board and heads the company’s sustainability function. This offers two routes for a submission: consideration of historical risks within Uniper, and discussion of document disclosure and procedures at RECOSI. DOC-014.

Why she is an addressee. The questions for Wendler concern present-day work on the consequences of past purchases and residents’ participation in considering a submission. Her published call to take communities into account is compared with the specific request to hear Natalia and provide a documented answer.

1. When did you take charge of sustainability at Uniper, and what responsibilities did you receive for historical supply-chain risks and residents’ submissions?
2. Are you prepared to raise disclosure of Russian plans and monitoring with RECOSI’s Board, assign a responsible person and give a deadline?
3. How will residents who remained with the consequences of mining after purchases ended participate in the process?
4. What safe methods of submitting testimony and receiving feedback are available to Natalia today?

9.3. Other participants in governance and assessments

Joachim Löchte is named as Chair in the initiative’s 2012 founding announcement. Gerda Frans, Head of ESG at ENGIE Global Energy Management & Sales, was announced as RECOSI Chair in December 2025. Taco Douma of RWE Generation remained Vice-Chair. Katie Warrick heads the organisation’s executive work. These roles differ: the Board governs and oversees, while executive management runs activities. DOC-066; DOC-013; DOC-014.

Russian assessment-team membership is taken from the reports themselves: James McNally and Yelena Borovikova — KRU; Paul Mitchell, Julija Menise and Tatiana Vasenko — SUEK and SDS; Julija Menise, Tatiana Vasenko, Vladimir Simov and Peter Whitbread-Abrutat — Taldinskaya Mining Company. Assessment participation means carrying out the stated work. Establishing who later verified a particular plan item requires a task-allocation log. DOC-043, p. 5; DOC-044, p. 6; DOC-020, p. 5; DOC-045, p. 5.

Uniper’s published account of Kiselyovsk confirms the participation of company representatives. The delegation’s individual members, allocation of roles and list of recipients of the final report remain the subject of a specific request. The visit diagram does not substitute named executives for unidentified participants.

9.4. How to read the diagrams

Diagram A shows professional appointments and governing bodies by date. Diagram B shows the buyer’s confirmed use of assessments and purchases by geographical category; potential seller–buyer pairs are listed separately for verification. Diagram C connects producers with sites visited. Diagram D places changes in time. Arrows represent their labelled relationship or a procedural sequence; the disaster’s causal links are determined by court and technical documents, rather than arrow direction.

Chapter findings. Governance and professional relationships, assessment-team membership, sites visited and Uniper’s use of the system are confirmed. A commercial connection to a particular Russian mine requires supply documents. An executive’s personal involvement in a decision requires minutes, a signature, an instruction or a dated communication.

10. Natalia Zubkova: work, pressure and consequences

Natalia is the author of the appeal and a direct participant in this part of the story. Her words of 28 October 2026 are reproduced in the appendix in full, following the agreed article version. Below, events are compared with publications from the relevant time. Personal testimony describes lived experience; external publications show when information became public and who sought its verification.

10.1. Residents’ appeal and material available to read

Kiselyovsk residents’ appeal to the Prime Minister of Canada was published by Novosti Kiselyovska on 8 June 2019. Ecodefense’s 2020 report cites this video in notes 17 and 75. In the preserved Russian version, these are PDF pages 5 and 15. This traces the subsequent report’s use of material from Natalia’s outlet. Establishing precisely what the delegation received before September 2019 requires correspondence about the transfer of material. DOC-008, p. 5, 15.

On 26 August 2019, Sibir.Realii reported that the mayor had contacted prosecutors over the journalist’s interviews with residents. The article concerns pressure surrounding information gathering and journalistic work. A letter to prosecutors must be distinguished from the opening of proceedings and a court decision. DOC-025.

10.2. Threats and a publication featuring fire

In its publication of 3 March 2021, CPJ — the Committee to Protect Journalists — relays Natalia’s account of anonymous threats to burn her alive in August 2020 and her submission to the Investigative Committee. On 21 August 2020, the Bez Tsenzury blog published ‘An “attempt on Zubkova’s life” is being prepared’. The page contains a montage featuring fire, and the text ridicules reports of threats. The account name and platform are established from the page; identifying the person behind the account requires a separate document. DOC-026; DOC-032.

The blog publication and the original threatening message are two different documents. The image included in the appendix shows the nature of the public harassment. Information on the correspondence and its dates relies on specific preserved excerpts and Natalia’s publication ‘Two Realities’. This work does not claim to have verified the entire set of 27 screenshots. DOC-033.

10.3. Attack, departure and closure of the outlet

CPJ reported that an unidentified person attacked Natalia while she was walking her dog on 25 February 2021 and threatened her and her children. The organisation spoke to Natalia by telephone. This publication is a dated record of her account and of a professional organisation’s appeal for the journalist’s protection. It also describes its own requests for comment. Those requests were made by CPJ, not by the author of this research. DOC-026.

On 10 March 2021, Reporters Without Borders called on the federal authorities to protect Natalia and conduct an independent investigation. The article mentions her 6 March video appeal concerning complaints to the police, FSB and Investigative Committee. The organisation offered its own assessment of persecution by local authorities. CPJ’s and RSF’s accounts of the same attack are not treated as two independent eyewitness testimonies. DOC-027.

On 26 April 2021, Sibir.Realii reported that Natalia had left Russia roughly a week earlier. The outlet included both her explanation of her fear for her safety and the Investigative Committee’s position that it had visited her as a victim in a case concerning obstruction of journalistic work. On 23 May, Novosti Kiselyovska’s closure was reported, for the editor’s family’s safety and to enable other projects. DOC-028; DOC-029.

10.4. What is compared with Bettercoal’s work

The timeline first places public appeals and the 2019 visit, followed by the February 2020 TDI report, August 2020 threats, and reports of an attack and departure in 2021. This sequence determines the questions about knowledge. What material was received before the visit? Who tracked subsequent publications? Were retaliation risks considered during conversations with residents and grievance handling? Each answer requires a document with a receipt date and a specific action.

The Black Snow press kit is used as a description of the film and the director’s project. This work does not claim to have viewed the entire film or checked scenes against timestamps. DOC-030.

Chapter findings. The story includes specific dated reports of pressure, threats, an attack, forced departure and closure of an outlet. External publications record Natalia’s account and organisations’ responses. Establishing perpetrators and instructions requires investigation materials. Assessing buyers’ and Bettercoal’s responses requires documents showing receipt of information and subsequent measures.

11. Discussion and conclusions

11.1. What the comparisons reveal

The research establishes several different relationships. The legal register links Bettercoal and RECOSI through one registration number. Annual reports and appointment forms connect executives with governing bodies. Public assessment reports identify Russian operations and mines actually visited. Court decisions and regulatory statements record specific circumstances at those operations. Uniper’s reporting shows use of assessments and purchases by country. Each link has its own source.

The principal analytical result is the ability to examine not only the site-visit itinerary but also the work between visits. Bettercoal provided for plans and implementation monitoring; Uniper reported regular updates. Requesting half-yearly reports, assessors’ decisions and Board materials therefore tests the stated procedure against specific examples. For Listvyazhnaya, this record is particularly important between May 2018 and November 2021.

11.2. What results the organisation presents

The July 2022 summaries give 65 verified items out of 210 in four Russian plans. They allow the published status to be checked, but do not openly allocate every item to a mine or provide evidence of its implementation. As at 31 December 2025, RECOSI’s report lists 279 items: 66 closed, 30 awaiting verification and 183 open. They concern six producers. The report was published on 17 August 2026 (DOC-087). DOC-083, p. 18.

The 2022 and 2025 figures are not combined into a single ‘progress’ series: they concern different producers and periods. Similarly, RECOSI’s 2025 expenditure includes the gas programme and expanded organisational activities; it cannot be presented directly as growth in spending solely on Russian coal assessment. The financial table retains the category names.

11.3. Governance, transparency and residents’ participation

Buyers participate in the organisation’s governance and funding, receive assessment results and use them for their own supply checks. Producers implement plans and pay for assessments under current rules. Public summaries give residents part of the results. To verify a change in conditions beside a particular house or the safety of a particular mine working, a resident needs a more detailed operation-specific report and action plan. This is a practical question of information access.

Natalia’s story poses a second question: how to obtain this information and report a problem safely. The Code includes grievance handling, the TDI report relays information about intimidation, and CPJ and RSF publish reports about a particular journalist. Completing the comparison requires records of incoming reports, procedures for protecting interviewees and decisions concerning them.

11.4. Final answers

Who governed and paid? Corporate members established and funded the organisation; leadership and membership changes are confirmed by the register and reports. A payer-by-payer breakdown of contributions requires disclosure.

What was assessed? Public reports provide overall scope and visit lists. They show findings and a number of good practices. The site table preserves the distinction between the entire group and a mine visited.

How were subsequent violations taken into account? Official inspections and court decisions, periodic plan reporting and certain Bettercoal public responses are known. Reconstructing specific action on each violation requires monitoring logs and dated decisions.

What changed in purchasing? Direct contractual purchases of Russian coal continued after the visit; Uniper reported that they ended in August 2022. The origins of individual consignments require contracts and shipping documents.

What happened to the journalist? Her testimony, publications about threats, the attack and departure, and professional organisations’ appeals have been preserved. The question for companies is when they received this information, who considered it, and how they ensured the safety of residents’ reports.

13. Gaps and clarifications concerning the web article

The research is limited to preserved documents and verified passages. Some regulatory statements are available as press-service republications, while the full inspection record or court ruling is requested. For TDI, certain Uniper pages and the trade database, records of web reading have been preserved; the original PDF or complete export was not obtained in every case. The register separately identifies the storage method. Missing details are not filled with assumptions.

1. New information: RECOSI’s 2025 report was published on 17 August 2026. Its results can be added to the article separately from the 2024 section. As at 31 December 2025, RECOSI’s report lists 279 items: 66 closed, 30 awaiting verification and 183 open.
2. Reference clarification: in the preserved Russian Ecodefense report, video references appear on PDF pages 5 and 15, notes 17 and 75. Printed pagination and English-version pages differ.
3. Clarification of the period in office: Uniper’s 2017 report was published in May 2018. It confirms Plümacher’s stated position, but the precise appointment date must come from a personnel document.
4. Profile discrepancies: KRU’s and SUEK’s participation start dates in timelines differ from letter dates in assessment reports. The letters and an explanation of profile fields are needed.
5. Additional court documents: the decisions of 26 March and 2 April 2026 refer to the technical investigation and criminal cases. Dates are taken from within the documents, rather than aggregator headings.
6. Uniper page: the archived snapshot of 18 June 2020 is preserved. On 28 October 2026, the original cr.uniper.energy address was unavailable, while the archived copy opened. Verification details and translation appear in appendix A22.
7. Additional supplier information: included after checking primary documents and matching legal entities.

Article V11 and earlier PDFs are preserved. The list above records documentary additions and clarifications to the article.

14. Cards for material claims

15. Sources and document register

A DOC number is retained on updating. Document date and acquisition date differ. SHA-256 verifies the integrity of a saved file, not its authenticity. The files below are in a separate sources archive; acquisition procedures are set out in appendix C. public-sources is a folder inside that archive. SHA-256 refers specifically to the supplied file; extracts and complete originals are identified separately. External links lead to sources; the cadastral link leads to appendix A23. DOC-086 is an alternative address for DOC-021’s announcement, not separate corroboration. Gaps in numbering preserve the original article’s numbering after duplicates were removed.

Appendix A. Documentary pages

Below are reproductions of key pages and excerpts. Document covers were not recreated. Highlighting on marked copies was added by the editors; the original is available through the register link. The cadastral report uses a complete page with personal data redacted.

Appendix B. Natalia’s questions for the picket

Tomorrow, 29 October 2026, I am going to hold a one-person picket outside Uniper in Düsseldorf. I want a meeting and a substantive conversation. Below are the questions I intend to ask. Today, I do not yet know whether company representatives will come out to speak to me, whether a meeting will take place or whether I will receive answers.

The visit to Kiselyovsk and conversations with residents

1. Did Uniper representatives visit Kiselyovsk in September 2019 as part of the Bettercoal delegation? Who exactly took part in the visit?
2. Who organised the visit to the town, drew up the itinerary and accompanied your delegation?
3. Did you meet residents of Kiselyovsk? If so, whom did you meet, who selected the interviewees, and what problems did they raise? If not, why not?
4. Could residents speak to you without representatives of coal companies or the local administration present?
5. Before the visit, were you aware of the appeal by Kiselyovsk residents to the Prime Minister of Canada dated 8 June 2019? Had you seen material published by Novosti Kiselyovska?
6. What material did you receive from Ecodefense before the visit? Did it include any of my articles or videos, or information about my work?
7. Was the possibility of meeting me, Natalia Zubkova, discussed? If so, what decision was made, and why did the meeting not take place?
8. In your article, you described how close mining operations were to residential homes. What conclusions did you draw about the consequences for residents, including children?

Assessments of operations, violations and verification

9. Listvyazhnaya was among the sites included in Bettercoal’s 2017 site assessment. What deficiencies were identified at this particular mine, and what measures were included in the improvement plan?
10. How did Bettercoal check that these measures were implemented before the disaster of 25 November 2021? When was the last check, what did it find, and to whom were the results reported?
11. Did Bettercoal receive information about industrial safety violations at Listvyazhnaya in 2021? If so, how did it respond? If not, how was the assessment of such risks organised?
12. After the disaster, Bettercoal announced its intention to establish the causes and the preventive measures required. What were the results of this work? Where can the findings and decisions be consulted?
13. What specific requirements did you impose on suppliers after the visit? What did they have to change, by when, and who checked implementation?

Coal purchases

14. Why did Uniper continue buying Russian coal after visiting Kiselyovsk? How did what you saw affect purchasing decisions?
15. From which Russian producers and operations did you buy coal in 2019–2022? Can you provide information on the volumes and origins of supplies?

Persecution of journalists and activists

16. The TDI report for Bettercoal’s working group discusses intimidation of environmental activists by coal companies. How did you respond to this information?
17. What measures did you put in place to enable residents and journalists to report violations to you without fear of persecution?
18. When did you learn of the threats and attacks against me? Did you consider the 2021 reports by CPJ and Reporters Without Borders? What action did you take?

Results, executives’ decisions and a meeting

19. What specific changes for Kiselyovsk residents resulted from your visit and subsequent work? Can you identify projects and time frames and show documents confirming their implementation?
20. Frank Plümacher, how does your experience as Bettercoal Chair inform your current work as Uniper’s Human Rights Officer? How do you assess the results of this work for residents of Russia’s coal-mining regions?
21. Nadja Wendler, what action are you prepared to take as Uniper’s sustainability executive and a member of RECOSI’s Board of Directors to ensure substantive answers to these questions?
22. Are you prepared to meet me, listen to my story and provide written answers supported by documents?

Appendix C. How to verify and reproduce the results

Shared primary-source archive: Bettercoal_Uniper_Research_RU_V03_sources.zip. This unchanged evidence corpus serves both language editions. Original filenames, Russian research metadata, public-sources, source-transfer.json and SHA256SUMS.txt are retained. It is not the editable source of EN_V04.

English-edition source archive: Bettercoal_Uniper_Research_EN_V04_sources.zip. It contains Bettercoal_Uniper_Research_EN_V04.html, editable English SVGs in visuals, CSV tables in datasets, claims-en.json, evidence-register-en.json, quote-language-review.json, production scripts and SHA256SUMS.txt. The HTML embeds all fonts and documentary images.

The delivery manifest SHA256SUMS_EN_V04.txt lists the PDF, English HTML, both archives and the change list with their checksums. No new public download URL is stated.

Reproducing EN_V04. Extract the English archive separately. Verify it with Verify-SHA256.ps1 or the Node verifier before editing. The HTML is the master: changes to SVG/CSV exports must also be made in their inline HTML counterparts. Follow README_EN.txt for scripts and dependencies. After rebuilding, update contents page numbers and verify DOC/CLM links.

Checking primary sources. Extract the shared archive separately. Verify public-sources against SHA256SUMS.txt and source-transfer.json. It contains supplied primary documents, redacted pages and labelled extracts; complete private documents are excluded. Its data.mjs, claims.json, evidence-register.json and content metadata describe Russian V03, not the editable English edition.

Checking numbers: each producer’s three statuses must sum to its item total; the four plans total 210. Financial values are checked against page 4 of each balance sheet. Purchasing shares are checked against the category and footnote, not just the figure. Bar scales start at zero. A missing value is not replaced with zero.

Checking a claim: find its CLM in the correspondence table, open the card, then the DOC and specified page. For a court decision’s date, use its internal heading. To match an operation, check the legal entity and type of work suspended. Establishing knowledge requires an incoming document with a receipt date.

SHA-256 verifies file integrity. source-transfer.json identifies the evidence files; the English manifest lists EN_V04 sources. Editing or re-exporting changes hashes: preserve earlier versions and regenerate the manifest. Rebuilding the English PDF leaves primary documents unchanged. External-address results are those recorded in the underlying research; they were not rechecked for EN_V04.

Appendix D. Availability of external addresses

Checks were conducted on 28 October 2026. The list records automated-request results, rather than proof that a publication was removed. HTTP 403, 429 and browser checks may indicate restrictions on automated access. The complete log, including accessible addresses and redirects, is included in the sources package. Saved copies are listed in the register.

DOC-002 — HTTP 403 / browser check. https://www.uniper.energy/sites/default/files/2022-03/Bettercoal-in-Kuzbass_Public-Report.pdf

DOC-003 — HTTP 403 / browser check. https://www.uniper.energy/sites/default/files/2022-03/uniper_sustainability_report_2019_en.pdf

DOC-006 — HTTP 503. https://www.annualreports.com/HostedData/AnnualReportArchive/u/uniper-se_2022.pdf

DOC-007 — HTTP 403 / browser check. https://www.consilium.europa.eu/en/press/press-releases/2022/04/08/eu-adopts-fifth-round-of-sanctions-against-russia-over-its-military-aggression-against-ukraine/

DOC-012 — HTTP 200 / browser check. https://www.bettercoal.org/bettercoal-producers

DOC-011 — HTTP 200 / browser check. https://www.bettercoal.org/siberian-business-union-coal

DOC-010 — HTTP 200 / browser check. https://www.bettercoal.org/kuzbassrazrezugol-coal-ojsc

DOC-015 — HTTP 403 / browser check. https://www.uniper.energy/sustainability/people-and-society/social-responsibility

DOC-016 — HTTP 200 / browser check. https://www.bettercoal.org/governance

DOC-019 — HTTP 403 / browser check. https://www.uniper.energy/sites/default/files/2022-03/Gegenantraege_HV_2021.pdf

DOC-017 — HTTP 200 / browser check. https://www.bettercoal.org/news/bettercoal-publishes-its-annual-report-2018

DOC-018 — HTTP 200 / browser check. https://www.bettercoal.org/news/bettercoal-announces-appointment-of-new-executive-director-2

DOC-024 — HTTP 200 / browser check. https://www.bettercoal.org/news/accident-at-sds-ugol-mine

DOC-031 — HTTP 403 / browser check. https://www.uniper.energy/news/update-on-unipers-russian-activities-and-way-forward

DOC-046 — HTTP 200 / browser check. https://www.bettercoal.org/ktk

DOC-047 — HTTP 200 / browser check. https://www.bettercoal.org/taltek-open-pit-mine-ltd

DOC-051 — HTTP 200 / browser check. https://www.bettercoal.org/taldinskaya-mining-company-llc

DOC-050 — HTTP 200 / browser check. https://www.bettercoal.org/suek-jsc

DOC-059 — HTTP 200 / browser check. https://www.bettercoal.org/news/jsc-shubarkol-komir-is-no-longer-a-bettercoal-supplier

DOC-077 — HTTP 403 / browser check. https://www.volza.com/company-profile/uniper-global-commodities-se-451916/import/suppliers/

DOC-078 — HTTP 403 / browser check. https://www.uniper.energy/system/files/2024-04/uniper_group_sustainability_report_2017.pdf

DOC-082 — HTTP 403 / browser check. https://www.uniper.energy/sustainability/sustainability-resources

DOC-079 — HTTP 200 / browser check. https://www.bettercoal.org/news/bettercoal-suspends-activities-in-russia-with-immediate-effect

Additional link — No response: host name did not resolve. https://cr.uniper.energy/the-dilemma-of-investing-in-social-and-environmental-remediation-activities/

Additional link — HTTP 403 / browser check. https://www.uniper.energy/sustainability/dilemma-investing-social-and-environmental-remediation-activities

DOC-042 — No response: request timed out. https://www.lawtek.ru/news/119276/sud_po_trebovaniyu_rostekhnadzora_priostanovil_vedeniye_gornykh_rabot_v_opasnoy_zone_ooo_razrez_taltek