“Our human rights commitments form part of our code of ethics. Employees are trained on the code through our intranet and as part of the induction process

Our 2015 human rights achievements and performance

Our human rights policy, which was approved in 2013, commits us to striving for full compliance with applicable legislation in the regions in which we operate, as well as to implementing the human rights principles in the United Nations Global Compact. Our human rights commitments form part of our code of ethics. Employees are trained on the code through our intranet and as part of their induction process.

We have made provision in relevant policies and procedures for the following human rights issues:

• Rights to freedom of association and collective bargaining
• Minimum employment age
• Prevention of forced or compulsory labour
• Equality and fair treatment of all individuals free from discrimination, irrespective of race, gender, creed or place of origin
• Disciplinary and grievance processes
• The need for security personnel to uphold these human rights.

We track implementation of human rights issues through monthly reports. Procedures are in place to ensure that channels are available to deal with unfair practices. No cases of discrimination were reported in the year under review.

While our agreements with contractors do not specifically contain human rights clauses, contractors are expected to abide by our Company policies, practices, standards and the constitution of the countries in which they are operating. We recognise the need to further improve our monitoring of contracted labour on human rights issues. Through stakeholder engagement processes, material community issues pertaining to human rights are addressed in community forums. No claims of human rights abuse were made against the Company this year.

Following the tragic events at Marikana in 2012, and the subsequent recommendations of the Farlam Commission, we recognise the need across the mining industry to manage security-related issues. As part of supporting growth and stability in the mining sector, the President's Framework Agreement was signed by all stakeholders in 2013. Part of this agreement promotes the rights of workers and communities in ensuring safety and security. Refer to here. Enhancing the interface between the South African Police Service (SAPS) and our own security response is critical in avoiding any escalation of conflict. To mitigate this risk we have committed to and are implementing the Voluntary Principles on Security and Human Rights (VPSHR). The VPSHR framework provides useful guidance on: assessing the human rights risks associated with security; engaging with public security providers in a structured manner; establishing a clear set of rules when contracting with private security providers; and creating opportunities for input by affected stakeholders.

We are following a phased approach to the implementation of the VPSHR. Phase 1 of the project is a gap analysis against the requirements of the VPSHR to identify the actions to be taken to fully comply with the requirements. The first phase of the process focused on Impala Springs, which has developed mature security systems in response to the high threat of precious metals criminal activity. The gap analysis has been completed; recommendations will be given to the executive and management for consideration. The next phase is to conduct a similar exercise at Marula and Impala Rustenburg. The assessment of the Rustenburg operation commenced in July 2015.

We will be using this framework to guide and train our security contingent. To formulate appropriate security responses, early identification of the potential for violence is critical, which requires regularly updated and credible information on security threats.

Third-party services are contracted to provide security at our South African operations. An assessment of their practices indicates that awareness programmes are in place for their personnel on the protection of human rights. The gap analysis will assist in determining any further training required and will be disclosed in the following year (2016).