Implats’ responsibility towards its stakeholders is taken seriously by the group and is an integral part of its functioning. Specialist staff are in place at an operational level in various disciplines to support line management in ensuring we are both aware of and responsive to the needs of its employees and communities.
Issues relating to safety, health, environment, and HIV/AIDS are considered by operation–based management and the Executive Committee. A board committee, the Safety, Health and Environment (SHE) Audit Committee, has been designated by the board to guide group policies and monitor performance and progress. This committee meets on a quarterly basis and is chaired by a non–executive director.
The group’s Transformation Committee, which reports to the board, oversees our policies and practices relating to the Mining Charter and compliance with the Mining Charter Scorecard. In addition, there are transformation committees at all the operations which were involved in the formulation of our Employment Equity Plan and they monitor progress on a monthly basis. These committees are broad–based comprising employees, representatives from organised labour, black economic empowerment partners and management. To give an idea of the scope and mandate of these committees, more information is provided on the Rustenburg Transformation Committee.
To assist Impala Rustenburg in the process of addressing historical disparities and discrimination in the company and the surrounding mining communities, a Transformation Forum was established on 14 August 2006. The 29–strong forum comprises representatives of Impala Rustenburg, the National Union of Mineworkers (NUM), the United Association of South Africa (UASA) and other stakeholder groups (women and people with disabilities among others).
The purpose of the forum is to ensure:
The functions of the forum are to:
The company’s Response to the Mining Charter (PDF – 799KB) is on the website. Following the findings and recommendations made by the independent assurer, the group will develop group–wide definitions and reporting structures to ensure the accuracy of information provided to stakeholders. A comprehensive discussion on corporate governance may be found in the Implats 2007 Annual Report.
Implats has a zero tolerance’ approach to dishonesty, fraud, corruption, theft or misconduct. We have a fraud policy in place which is underpinned by a detailed code of ethics. Both comply fully with the Prevention and Combating of Corrupt Activities Act of 2004. Our goal is to have an organisation that is free of politics, favouritism, vindictiveness, sexual harassment, theft, fraudulent and corrupt practices, unfair labour practices, intimidation and victimisation.
The implementation of these policies and their collective procedures rests with executive and line management. The forensic wing of the Internal Audit function, which is an independent assurance activity, handles all fraud–related issues, while the Security function deals with theft and corruption.
Employees have easy access to our policies regarding fraud and corruption; there is regular communication regarding Implats’ fraud prevention strategy, with specific emphasis on the role played by employees in reporting misconduct, criminal activities or suspected corruption; and fraud awareness forms part of the group’s training initiatives. Workshops are conducted with senior management to discuss anti–fraud strategies with a view to introducing the best practices to combat fraudulent activities and behaviour throughout the organisation.
Employees, contractors, suppliers and customers affiliated to South African operations are encouraged to report incidents of fraud and corruption to Whistle Blowers, an external, independent service. All calls made to its 24–hour call centre are fielded by multi–lingual operators who are trained to recognise real issues and to obtain relevant information from the informant with the guarantee of confidentiality. The cases are categorised and reported to the chairman and the CEO at the same time. Most are forwarded to Internal Audit, the rest are handled by the CEO himself or sent to line managers for attention. All reports received by Internal Audit are investigated and reports submitted to the executive in whose area of responsibility the incident occurred. The action taken by management is summarised for the Audit Committee.
In FY2007, preliminary findings on three forensic investigations indicted substance in allegations of fraud and corruption against four staff members. Two disciplinary hearings were scheduled: in the first, the employee involved tendered his resignation before judgement was passed; the second hearing continues. The remaining case is being handled by line management.
There were no cases of contracts with business partners not being renewed because of any corruption–related activities and no instances of corrupt practices being brought against us or our employees during the year under review.
In Zimbabwe, employers, suppliers and other stakeholders have access to the external independent services of Tip Offs Anonymous for confidential reporting on fraud, theft, conflict of interest, corruption and any other forms of unethical behaviour. All allegations are reported to executive management and appropriate investigations are undertaken.
Implats is committed to incremental reporting in terms of GRI. We have self–declared a C+ level of reporting for FY2007 (See box below for more detail on GRI Application Levels). The company has requested that its external assurer, Trialogue Assurance Services, offers an opinion on this self declaration and will request that GRI confirm the self–declaration once the company’s web–based report has been completed. Cognisance has been taken of GRI’s reporting principles regarding:
The Global Reporting Initiative (GRI), which has its headquarters in Amsterdam, is an international network of thousands drawn from business, civil society, labour and professional institutions. Its vision is that reporting on economic, environmental and social performance by all organisations becomes as routine and comparable as financial reporting.
The network creates the content of GRI’s Sustainability Reporting Framework in a consensus-seeking process. The organisation develops, continually improves and builds capacity around this framework.
The GRI has different application levels. Once a report has been completed, the preparers should declare the level to which they have applied the framework through use of the GRI Application Levels system. The purpose of this is to provide readers with clarity about the extent to which the guidelines and reporting framework elements have been applied in the preparation of a report. For the preparers of the report it provides a vision or path for incrementally expanding the application of the framework over time.
To meet the needs of all participants, there are three levels in the system: C, B and A. The reporting criteria found in each level reflect an increasing application or coverage of the framework. An organisation self-declares a reporting level based on its own assessment of its report content against the criteria in the GRI Application Levels.