“The Group’s environmental team has close links with operational and project management teams and is involved in due diligence exercises

Managing health, safety and environmental (HSE) issues

Group and site-specific HSE policies, procedures and standards are in place to ensure that we comply with legislative requirements and support our vision of zero harm. Responsibility for implementing HSE policies and procedures rests with line management. All operations submit quarterly performance reports to the board-appointed HSE committee. Group and operational level HSE specialists support line management in implementing the strategy and in monitoring and managing performance. The Group HSE executive is a member of Exco.

The Group’s environmental team has close links with operational and project management teams and is involved in due diligence exercises undertaken in connection with acquisitions and the development of strategic initiatives. Implementation of our policies is enhanced by our commitment to maintaining ISO 14001 certification for our environmental management systems. Regular compliance audits are conducted at our operations by the Group’s internal auditors, as well as by the external auditor. All of the Group’s operations are now ISO 14001 certified.

In addition to the ISO 14001 certification, the refineries are signatories to Responsible Care^® and retained their certification. Responsible Care^® is the chemical industry’s global voluntary initiative under which companies, through national associations, such as the Chemical and Allied Industries Association (CAIA) in South Africa, work together to continuously improve and communicate on their HSE performance.

Managing our investments in socio-economic development

The sustainable development department based at Impala Rustenburg manages our socio-economic development initiatives in our South African operations. A technical team is responsible for implementing the projects, working together with the stakeholder engagement department. The identification of community projects is an ongoing process based on a needs analysis, undertaken in consultation with stakeholder representatives from communities and local government. The sustainable development project steering committee is responsible for reviewing the proposed projects after due diligence has been done. Once approved by the project steering committee, the projects are recommended to the Exco, a multi-disciplinary executive-level management team that evaluates the merits of investing in each project.

In Zimbabwe, sustainable development initiatives are implemented and managed by the stakeholder engagement executive supported by technical personnel from the operations.

Each year an independent audit (Trialogue) is conducted on selected social projects, based on the financial, legal and reputational risk as well as to determine impact, progress and potential remedial action where a project faces possible failure. A detailed summary of this can be found here.

Managing contractors and suppliers

Implats suppliers span the entire value chain from exploration to final production of precious metals in the refining process. Our approach is to source all goods and services within the country of operation, with a greater emphasis on local suppliers defined as tier 1, 2 and 3 based on their proximity to the operations in South Africa. Tier 1 suppliers are those from directly and indirectly impacted communities (Bafokeng Villages and Freedom Park in Rustenburg, and the Four-farms area in Burgersfort), tier 2 suppliers are within the local municipality around the operations, and tier 3 suppliers are those within the bigger areas surrounding the local municipality. In Zimbabwe local suppliers are those that are within the country of operation. Local procurement is advanced through our enterprise development initiatives as described here.

In response to concerns regarding contractor behaviour not reflecting our value systems, and to minimise any potential liability, last year we reviewed our contractor strategy. This strategy seeks to ensure that we have defined principles that will guide the engagement of reputable contractor companies with the right skills and value systems to undertake specific tasks that we are not able to do ourselves. All contractors and suppliers are appraised on our policies and business practices and are expected to, at a minimum, abide by these principles in their business conduct and practices at all our operations. The strategy has been structured into two phases. The first phase entails using our training and recruitment resources to ensure that all contracting employees are vetted and assessed according to our own internal standards. The second phase specifically interrogates each contracting company and the work they do for us. We have completed the detailed assessments with the assistance of an external specialist and will, over time, effect the required change. In the short term we are planning to insource all development mining, ventilation construction as well as sweeping and vamping services.

In the year under review a pilot project was instituted to survey supplier labour practices and to identify possible risks. The review looked at various supplier aspects such as compliance to legislation, labour hire, diversity management, compensation, living conditions of employees, human rights, skills development and other. The review targeted five of our top suppliers. The findings of the survey highlighted that some suppliers did not have the capacity to provide information requested and that more work needs to be done. We will continue to look at processes to provide such information in order to better mitigate risk associated with suppliers.

We will continue to focus our attention on suppliers’ B-BBEE certificates and prompting suppliers well in advance of their expiry dates. Penalties on annual increases will continue to be levied on untransformed suppliers. During the year no services of suppliers were terminated.