About Implats

Corporate governance

Corruption and Fraud

Implats has a zero-tolerance stance on fraud and corruption. Our expectation is that employees, business partners, contractors and associates conduct themselves with the highest level of integrity and in line with the Implats code of ethics and the fraud policy. A detailed code of ethics forms the foundation of the Group’s fraud policy, in line with the organisational culture which promotes a strong and healthy ethical fibre. Both policies are fully compliant with the Prevention and Combating of Corrupt Activities Act of 2004.

Executives and line management are responsible and accountable for the implementation of the fraud policy, code of ethics and resultant procedures.

Our fraud policy prescribes that all reported allegations be investigated. A total of 139 allegations were reported Group-wide this year, 65 of which were received by the South African operation, 13 from Mimosa and 61 from Zimbabwe. All reported allegations were investigated in compliance with our fraud policy.


Where we operate

Sixty-six allegations were adjudged to be founded and were taken through the disciplinary process as per the disciplinary codes applicable at the different locations. The status of these at year-end was as follows:

  • Forty-three resulted in guilty findings. Sanctions ranged from counselling to dismissal
  • Thirteen cases were still pending
  • Ten were not guilty.

Fraudulent irregular activity and theft reported Group-wide by internal audit in 2013

Nature of allegation          
BEE fronting   2   2   0   4  
Conflict of interest and corruption   12   4   7   23  
Fraud and theft   13   18   42   73  
Misconduct and other   2   20   17   39  
Total   29   44   66   139  


Code of Ethics

Implats has a code of business practice to which all employees and suppliers are expected to adhere. The policy outlines conflicts of interest, the prevention of dissemination of Company information, the acceptance of donations and gifts and the protection of the Company’s intellectual property and patent rights. This policy outlines the disciplinary action (including dismissal or prosecution) that will be taken in the event of any contravention. A “whistleblowing” toll-free helpline is in place to facilitate the confidential reporting of alleged incidents that are then relayed to the chief audit executive, and further to the chairman of the board as a courtesy. All reported allegations are investigated, each to its logical conclusion and formally reported to the appropriate levels in the organisation.