Implats’ approach to sustainable development reporting

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.

Governance

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.

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 promotion of equal opportunities at all levels and in all occupational categories;
• the implementation of affirmative action in the workplace in accordance with the Employment Equity Act;
• the elimination of unfair discrimination and the redressing of past imbalances to ensure fair treatment;
• the implementation of employment equity plans and targets as required in terms of the Employment Equity Act;
• that issues that create barriers to transformation are identified and eliminated;
• that there is appreciation for the diversity between different people, cultures, sexes etc., which is based on a foundation of understanding; and
• that line management is energised through appropriate action plans in areas of underachievement.

The functions of the forum are to:

• analyse the skills profile in the workplace so as to ensure compliance with the plans as drawn up in terms of section 20 of the Employment Equity Act;
• monitor the recruitment process and ensure that it gives effect to, among other things, the definition of suitably qualified persons as well as takes cognisance of all official languages;
• conduct a workplace skills analysis as a designated employer and ensure application of ‘recognition of prior learning’ to determine the suitability of candidates from the designated group of employees;
• prepare, implement and monitor the company’s Employment Equity Plan guided by the 10 steps drawn from the Code of Good Practice on Employment Equity;
• monitor the Workplace Skills Plan to match employment equity targets;
• ensure communication and consultation in a manner that establishes commitment from line managers and the workforce;
• conduct compliance audits and verify audit findings; and
• continuously monitor and evaluate the forum’s functionality and effectiveness.

Response to the Mining Charter

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.

Corruption

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.

Reporting in line with GRI

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:

Report content

• All material issues known to the company have been reported.
• The views and needs of stakeholders have been taken into account in preparing this report. Implats recognises, however, that a more formal approach to stakeholder engagement must be embarked upon and the company has set this as an objective for FY2008.
• Where necessary and relevant, the broader sustainability context has been provided. Additional information and, particularly, additional and historical information by operation may be found on the website.
• The report is complete in that it provides a comprehensive picture of our operations and impacts. There is an intrinsic bias in reporting on South Africa as this comprises the bulk of operations and employment and, consequently, the area of greatest impact.

Quality

• Wherever possible comparison has been made with data from the previous financial year and additional historical information has been provided where appropriate to support the principle of comparability.
• The company has endeavoured to ensure that the information is accurate and the primary indicators have been assured by the independent assurer.
• The report is timely in that it is provided as soon as possible after the publication of the annual report.
• Effort has been made to ensure that the report is understandable. Terminology that may be unfamiliar to some stakeholders has been explained or included in the glossary in the report.
• The report has been reviewed by the board and the independent assurer, and is thus deemed to be reliable.