sustainability framework - royal bafokeng nation...3 executive summary the purpose of this document...

1

Sustainability Framework (Incorporating the Stakeholder Engagement Framework)

Draft 0.1

18 July 2013

Social & Ethics committee

2

Contents

Executive Summary............................................................................................................................................................. 3

A. Background to Sustainability ..................................................................................................................................... 4

1. Overview ................................................................................................................................................................... 4

2. The South African Legislative Context: The Companies Act (No. 71 of 2008) ........................................................... 5

3. The Good Practice Context: The UNGC ..................................................................................................................... 6

i. The United Nations Global Compact ................................................................................................................... 7

ii. The International Council on Mining and Minerals ............................................................................................. 9

B. Contexualising RBPlat .............................................................................................................................................. 12

1. The Legislative and Good Practice Context of RBPlat ......................................................................................... 12

2. The RBPlat Social and Ethics Committee: Interpreted Responsibilities and Implications .................................. 15

i. Responsibilities .................................................................................................................................................. 15

ii. Implications ....................................................................................................................................................... 16

3. Sustainability Value Proposition .............................................................................................................................. 17

4. Critical Risk Factors .................................................................................................................................................. 18

C. Approach to Developing the RBPlat Sustainability Framework............................................................................... 19

1. Overview ................................................................................................................................................................. 19

2. Approach ................................................................................................................................................................. 19

D. Step 1: The RBPlat Overarching Theme ................................................................................................................... 20

E. Step 2: The RBPlat Sustainability Framework Guidelines ........................................................................................ 21

F. Step 3: The RBPlat Stakeholder Engagement Framework ....................................................................................... 23

1. Overview ................................................................................................................................................................. 23

2. Stakeholder Engagement Standards ....................................................................................................................... 23

3. Purpose of Stakeholder Engagement ...................................................................................................................... 24

4. Engagement Challenges and Pitfalls ........................................................................................................................ 24

5. High Level Engagement Steps .................................................................................................................................. 25

i. Before the Engagement..................................................................................................................................... 26

ii. During the Engagement..................................................................................................................................... 42

iii. After the Engagement ....................................................................................................................................... 43

G. Step 4: The Sustainability Framework ..................................................................................................................... 44

1. Internal Context - Current and Preferred Status ..................................................................................................... 44

2. The Sustainability Framework ................................................................................................................................. 47

i. Phase 1: Realigning the Company Profile .......................................................................................................... 48

ii. Phase 2: Review of Corporate Governance ....................................................................................................... 50

iii. Phase 3: Integration of sustainability and risk ................................................................................................... 50

iv. Phase 4: Establishment of a Sustainability Committee ..................................................................................... 52

v. Phase 5: Integration of sustainability: Roles, responsibilities and timeframes ................................................. 56

3

Executive Summary

The purpose of this document is to present a sustainability framework to the Social and Ethics

Committee of the Board of Royal Bafokeng Platinum Ltd. (RBPlat) for their consideration in

meeting the sustainability and ethical requirements of the Companies Act (amongst other

regulatory requirements), whilst taking cognizance of national and international best practice

codes and guidelines. Specific reference is made to the United Nations Global Compact (UNGC),

to which RBPlat is a signatory, as the UNGC presents overarching human rights, labour,

environmental and anti-corruption principles; these principles have been unpacked into mining-

industry specific principles by the International Council on Mining and Minerals.

A synopsis of the various legislative and good practice sustainability requirements are listed in

Section A of this document together with an illustrative positioning of RBPlat within this broad

context.

Section B provides an overview of a 4 step-by-step approach to developing a sustainability

framework for RBPlat, which is described in further detail in the sections that follow. Briefly, the

4 steps are:

1. Identification of a personalized theme for RBPlat’s sustainability agenda

2. Development of overarching corporate guidelines for sustainability to inform the

development of the stakeholder engagement and sustainability frameworks

3. Development of a stakeholder engagement framework

4. Development of a sustainability framework

The sustainability framework is further unpacked into 5 implementation phases as follows:

1. Realignment of the company profile

2. Reviewing the corporate governance infrastructure

3. Integration of sustainability and risk management

4. Establishment of a Sustainability Committee

5. Integration of sustainability into existing management processes: Establishment of

internal roles and responsibilities for sustainability

Important note:

This document presents a framework for a business concept that does not necessarily comply with other standard

business processes where decisions and actions can be predetermined and submitted for implementation according to a

set formula. Sustainability requires extensive engagement of pertinent (internal and external) stakeholders to ensure

the relevance and feasibility of the framework and subsequent initiatives. Engagement processes prevent possible

defensive or resistant responses; instead engagement promotes buy-in and importantly, ownership of the decisions that

need to be taken to embark on a sustainable business journey. Hence care has been taken in the development of this

document to ensure that it serves as a guiding framework as opposed to a predetermined structure that is closed to

review by all parties at all levels. Often suggestions are made to serve as an illustrative example of the idea in mind (for

example, the development of an overarching theme for RBPlat’s sustainability agenda is suggested to be ‘responsible

leadership’; this is not meant to be prescriptive but rather a suggestion made by a singular person which may not be

suitable to the company leadership or the company itself and therefore the idea of a theme, and what that theme

should be, needs to be interrogated by the relevant company stakeholders).

4

A. BACKGROUND TO SUSTAINABILITY

1. Overview Corporate sustainability practices are imperative for the improvement of the quality of life

of all peoples, both locally and globally, and the protection of all other species upon which

we depend for our survival.

Companies that have embarked on mainstreaming sustainability into their business practices

have done so for various reasons; the drivers may have been compliance with legislation to

avoid legal action, pursuing a business case that is supported by improved competitiveness,

or as a result of awakened thinking stemming from sound morals and values of their

leadership and shareholders.

The principles of sustainability are contained within the Universal Declaration of Human

Rights (1948), the International Labour Organisation’s Declaration on Fundamental

Principles and Rights to Work (1998), the Rio Declaration on the Environment and

Development (1992), and the United Nations Convention Against Corruption (1992) amongst

others; in South Africa the concepts are enshrined in the South African Constitution (1996)

and recently in the Companies Act (No. 71 of 2008).

Various best practice guidelines, such as that presented by the King III Code of Good Practice

(2009; King III), have also been developed to support and fill the gaps left by legislation.

Companies, that have the foresight to secure their own financial sustainability by competing

responsibly in the market, are at the forefront in understanding the potential risk and

opportunities these issues present to their profit margin in the long term. Various stock

exchanges promote sustainable business practices by listing companies in their sustainability

indices thereby providing a decision making tool for shareholders who would like to consider

a company’s impact on society, the economy and the environment (the 3 pillars of

sustainability) as an integral part of their return on investment.

Advances in information technology are bringing to light many violations and transgressions

made by companies; individuals now have the ability to make informed decisions and take

action against those who violate human rights, degrade the environment, or participate in

unsustainable economic practices. Hence the license to operate, ability to entice

shareholders, or reassure affected stakeholders is becoming increasingly difficult without

proof of responsible and ethical business practices.

5

2. The South African Legislative Context: The Companies Act (No. 71 of

2008)

One of the aims of the Companies Act is to promote compliance with the Bill of Rights

contained within the South African Constitution1 in the application of company law. The

Bill of Rights “enshrines the rights of all people in our country and affirms the democratic

values of human dignity, equality and freedom”, and explicitly addresses issues of social,

economic and environmental well-being. Therefore the Companies Act makes provision for

the Minister of Trade and Industry to prescribe that a company must establish a Social and

Ethics Committee as a sub-committee of the Board to be accountable for social, economic

and environmental impacts of that company. The effective date of the Companies Act, as

gazetted in the Government Gazette No 34239, was 1 May 2011.

Based on the Companies Act (Part F: Governance of Companies, Section 72 [4]), the

Companies Regulations (Chapter 3, Section 43) (2011) details the functions of the Social

and Ethics Committee to support enhanced corporate transparency and accountability as

follows:

1. To monitor the company’s activities, having regard to any relevant legislation, other

legal requirements or prevailing codes of best practice, with regard to matters relating

to:

1.1 social and economic development, including the company’s standing in terms of

the goals and purposes of:

the 10 principles set out in the United Nations Global Compact

Principles (UNGC); and

the Organisation for Economic Cooperation and Development (OECD)

recommendations regarding corruption;

the Employment Equity Act; and

the Broad-Based Black Economic Empowerment Act;

1.2 good corporate citizenship, including the company’s:

promotion of equality, prevention of unfair discrimination, and reduction

of corruption;

contribution to development of the communities in which its activities

are

predominantly conducted or within which its products or services are

predominantly marketed; and

record of sponsorship, donations and charitable giving;

1.3 the environment, health and public safety, including the impact of the

company’s activities and of its products or services;

1 Republic of South Africa. The Constitution of the Republic of South Africa. Act 108 of 1996.

http://www.acts.co.za/constitution/index.htm

http://www.acts.co.za/constitution/index.htm

6

1.4 consumer relationships, including the company’s advertising, public relations

and compliance with consumer protection laws; and

1.5.1 labour and employment, including:

the company’s standing in terms of the International Labour

Organization Protocol on decent work and working conditions; and

the company’s employment relationships, and its contribution

toward the educational development of its employees;

2. to draw matters within its mandate to the attention of the Board as occasion

requires; and

3. to report, through one of its members, to the shareholders at the company’s

annual general meeting on the matters within its mandate.

Further to the Companies Act, various other South African legislative requirements are applicable

to very specific areas of the sustainability pillars, for example, Employment Equity Act (1988) as a

component of the social pillar and the National Environmental Management Act (No. 107 of

2008) as a component of the environmental pillar, amongst a variety of others. Furthermore,

industry specific legislation is also applicable, such as the Mine Health and Safety Act (No. 29 of

1996), Mineral and Petroleum Resources Development Act (MPRDA; No. 28 of 2002), and Broad-

Based Socio-Economic Charter for the South African Mining and Minerals Industry (the Mining

Charter; 2010).

3. The Good Practice Context: The UNGC Numerous codes, standards, guidelines and tools have been developed both nationally and

internationally to drive and support corporate sustainability agendas; these are amongst others

the:

King III Code of Good Practice (2009; and Integrated Reporting Guidelines, 2011)

JSE Socially Responsible Investment Index (JSE-SRI Index; 2011)

United Nations Global Compact (UNGC; 2000)

Code for Responsible Investing in South Africa (CRISA; 2011)

United Nations Principles for Responsible Investing (UN-PRI, 2006)

Global Reporting Initiative (GRI-G3 or G4 - 2013) reporting guidelines

Accountability Assurance Standard (AA1000AS)

International Integrated Reporting Committee (IIRC) – reporting framework (to be

finalized in late 2013)

International Standards Organisation (ISO 26000, ISO 14000, ectetera)

Sustainability Principles of the International Committee for Minerals and Mining (ICMM)

7

i. The United Nations Global Compact

The UNGC presents 10 very broad overarching principles (Box 1) that require

interpretation from a geographical, industrial and company specific point of view. These

principles encompass all the key aspects of sustainability, hence the integration of these

principles into a company’s core business will address the legislative and best practice

requirements listed in aforementioned sections; furthermore, the adherence to the

UNGC is explicitly mentioned in the regulations of the Companies Act.

The UNGC principles have their foundation in the Universal Declaration of Human Rights

(1948), the International Labour Organisation’s Declaration on Fundamental Principles

and Rights to Work (1998), the Rio Declaration on the Environment and Development

(1992), and the United Nations Convention Against Corruption (1992).

Launched in 2000 by former Secretary General of the United Nations: Kofi Annan, the

principles are intended to improve corporate citizenship in public, private and civil-

society entities. With over 10 000 corporate signatories in 130 countries, the

commitment is voluntary with an emphasis on the responsibility and accountability of

organisational leadership. Commitment to the UNGC principles requires the

reassessment of core business processes to support the sustainability pillars, as opposed

to a peripheral focus on corporate social investment, public relations exercises, and

philanthropic activity. Other signatory commitments include mandatory annual reporting

on progress, avocation of the principles within the company’s sphere of influence and a

membership fee based on turnover2. Companies may also seek permission to use the

UNGC logo for promotion of the principles.

In South Africa, the UNGC has a local area network that is hosted by the National

Business Initiative to support UNGC members with their sustainability journey through

discussion forums, seminars and workshops. RBPlat was readmitted to the UNGC as a

signatory in May 2012 with the first communication on progress due August 2013.

2 This has been voluntary until the end of 2012. The mandatory fee is currently being disputed by member

companies, including those in SA)

8

Box 1.

The UNGC Principles

Human Rights

Principle 1: Businesses should support and respect the protection of internationally proclaimed human rights within their sphere of influence; and Principle 2: make sure that they are not complicit in human rights abuses.

Labour Standards Principle 3: Businesses should uphold the freedom of association and the effective recognition of the right to collective bargaining; Principle 4: uphold the elimination of all forms of forced and compulsory labour; Principle 5: uphold the effective abolition of child labour; and Principle 6: uphold the elimination of discrimination in respect of employment and occupation.

Environment Principle 7: Businesses should support a precautionary approach to environmental challenges; Principle 8: undertake initiatives to promote greater environmental responsibility; and Principle 9: encourage the development and diffusion of environmentally friendly technologies.

Anti-Corruption Principle 10: Businesses should work against corruption in all its forms, including extortion and bribery.

http://www.unglobalcompact.org/AboutTheGC/TheTenPrinciples/humanRights.html

http://www.unglobalcompact.org/AboutTheGC/TheTenPrinciples/principle1.html

http://www.unglobalcompact.org/AboutTheGC/TheTenPrinciples/Principle2.html

http://www.unglobalcompact.org/AboutTheGC/TheTenPrinciples/labourStandards.html


http://www.unglobalcompact.org/AboutTheGC/TheTenPrinciples/Principle4.html



http://www.unglobalcompact.org/AboutTheGC/TheTenPrinciples/environment.html




http://www.unglobalcompact.org/AboutTheGC/TheTenPrinciples/anti-corruption.html


9

ii. The International Council on Mining and Minerals

In 2003, a CEO-led International Council on Mining and Minerals (ICMM), committed

member companies to implement and measure their performance against 10 industry

specific sustainability principles (Box 2) which are further unpacked into specific actions

(Box 3).

The principles are based on the issues identified in the Mining, Minerals and Sustainable

Development project and were benchmarked against leading international standards,

including the Rio Declaration, the GRI, the UNGC, OECD Guidelines on Multinational

Enterprises, World Bank Operational Guidelines, OECD Convention on Combating Bribery,

ILO Conventions 98, 169, 176, and the Voluntary Principles on Security and Human

Rights.

Box 2.

The 10 ICMM principles

Principle 1. Implement and maintain ethical business practices and sound systems of

corporate governance.

Principle 2. Integrate sustainable development considerations within the corporate decision-

making process.

Principle 3. Uphold fundamental human rights and respect cultures, customs and values in

dealings with employees and others who are affected by our activities.

Principle 4. Implement risk management strategies based on valid data and sound science.

Principle 5. Seek continual improvement of our health and safety performance.

Principle 6. Seek continual improvement of our environmental performance.

Principle 7. Contribute to conservation of biodiversity and integrated approaches to land use

planning.

Principle 8. Facilitate and encourage responsible product design, use, re-use, recycling and

disposal of our products.

Principle 9. Contribute to the social, economic and institutional development of the

communities in which we operate.

Principle 10. Implement effective and transparent engagement, communication and

independently verified reporting arrangements with our stakeholders.

http://www.icmm.com/our-work/sustainable-development-framework/10-principles#01










10

Box 3.

The 10 ICMM principles: Unpacked

Principle 1

Implement and maintain ethical business practices and sound systems of corporate governance.

develop and implement company statements of ethical business principles, and practices that management is committed to enforcing

implement policies and practices that seek to prevent bribery and corruption

comply with or exceed the requirements of host-country laws and regulations

work with governments, industry and other stakeholders to achieve appropriate and effective public policy, laws, regulations and procedures that facilitate the mining, minerals and metals sector’s contribution to sustainable development within national sustainable development strategies.

Principle 2

Integrate sustainable development considerations within the corporate decision-making process.

integrate sustainable development principles into company policies and practices

plan, design, operate and close operations in a manner that enhances sustainable development

implement good practice and innovate to improve social, environmental and economic performance while enhancing shareholder value

encourage customers, business partners and suppliers of goods and services to adopt principles and practices that are comparable to our own

provide sustainable development training to ensure adequate competency at all levels among our own employees and those of contractors

support public policies and practices that foster open and competitive markets.

Principle 3

Uphold fundamental human rights and respect cultures, customs and values in dealings with employees and others who are affected by our activities.

ensure fair remuneration and work conditions for all employees and do not use forced, compulsory or child labour

provide for the constructive engagement of employees on matters of mutual concern

implement policies and practices designed to eliminate harassment and unfair discrimination in all aspects of our activities

ensure that all relevant staff, including security personnel, are provided with appropriate cultural and human rights training and guidance

minimize involuntary resettlement, and compensate fairly for adverse effects on the community where they cannot be avoided

respect the culture and heritage of local communities, including Indigenous Peoples.

Principle 4

Implement risk management strategies based on valid data and sound science.

consult with interested and affected parties in the identification, assessment and management of all significant social, health, safety, environmental and economic impacts associated with our activities

ensure regular review and updating of risk management systems

inform potentially affected parties of significant risks from mining, minerals and metals operations and of the measures that will be taken to manage the potential risks effectively

develop, maintain and test effective emergency response procedures in collaboration with potentially affected parties.

Principle 5

Seek continual improvement of our health and safety performance.

implement a management system focused on continual improvement of all aspects of operations that could have a significant impact on the health and safety of our own employees, those of contractors and the communities where we operate

take all practical and reasonable measures to eliminate workplace fatalities, injuries and diseases among our own employees and those of contractors

provide all employees with health and safety training, and require employees of contractors to have undergone such training

implement regular health surveillance and risk-based monitoring of employees

rehabilitate and reintegrate employees into operations following illness or injury, where feasible.

11

Box 3. Continued

Principle 6

Seek continual improvement of our environmental performance.

assess the positive and negative, the direct and indirect, and the cumulative environmental impacts of new projects – from exploration through closure

implement an environmental management system focused on continual improvement to review, prevent, mitigate or ameliorate adverse environmental impacts

rehabilitate land disturbed or occupied by operations in accordance with appropriate post-mining land uses

provide for safe storage and disposal of residual wastes and process residues

design and plan all operations so that adequate resources are available to meet the closure requirements of all operations.

Principle 7

Contribute to conservation of biodiversity and integrated approaches to land use planning.

respect legally designated protected areas

disseminate scientific data on and promote practices and experiences in biodiversity assessment and management

support the development and implementation of scientifically sound, inclusive and transparent procedures for integrated approaches to land use planning, biodiversity, conservation and mining.

Principle 8

Facilitate and encourage responsible product design, use, re-use, recycling and disposal of our products.

advance understanding of the properties of metals and minerals and their life-cycle effects on human health and the environment

conduct or support research and innovation that promotes the use of products and technologies that are safe and efficient in their use of energy, natural resources and other materials

develop and promote the concept of integrated materials management throughout the metals and minerals value chain

provide regulators and other stakeholders with scientifically sound data and analysis regarding our products and operations as a basis for regulatory decisions

support the development of scientifically sound policies, regulations, product standards and material choice decisions that encourage the safe use of mineral and metal products.

Principle 9

Contribute to the social, economic and institutional development of the communities in which we operate.

engage at the earliest practical stage with likely affected parties to discuss and respond to issues and conflicts concerning the management of social impacts

ensure that appropriate systems are in place for ongoing interaction with affected parties, making sure that minorities and other marginalized groups have equitable and culturally appropriate means of engagement

contribute to community development from project development through closure in collaboration with host communities and their representatives

encourage partnerships with governments and non-governmental organizations to ensure that programs (such as community health, education, local business development) are well designed and effectively delivered

enhance social and economic development by seeking opportunities to address poverty.

Principle 10

Implement effective and transparent engagement, communication and independently verified reporting arrangements with our stakeholders.

report on our economic, social and environmental performance and contribution to sustainable development

provide information that is timely, accurate and relevant

engage with and respond to stakeholders through open consultation processes.

12

B. CONTEXUALISING RBPLAT

1. The Legislative and Good Practice Context of RBPlat

Figure 1 and 2 clearly illustrate the relationship between key sustainability legislation,

best practice codes, and RBPlat as described in the preceding sections.

From a legislative point of view (Fig. 1) the Social and Ethics Committee of the Board is

responsible for providing oversight for the sustainability activities of the company and

the reporting thereon. From a code of good practice point of view, King III recommends

the development of an integrated report that integrates the corporate financial,

governance and sustainability components in a comprehensive, material, and transparent

manner. The role of the Audit and Risk Committee of the Board is to assure the credibility

of the report through an external, impartial and independent assurance process. Both

committees are therefore responsible for bringing any pertinent sustainability matters to

the attention of the Board and reporting appropriately to the shareholders and other

stakeholders on issues of materiality.

Figure 2 illustrates the unpacked constituents of the Companies Act, King III and the

UNGC to reflect their cornerstone principles and similarities. Other pertinent codes of

good practice and guidelines include the CRISA, the UN-PRI, and the JSE SRI Index. The

broad UNGC Principles (Box 1 included in the Companies Act) are further unpacked by

the industry specific 10 Principles of the International Council on Mining and Minerals

(Boxes 2 & 3) as described in Section 1.

13

South African Constitution Act

108 (1996)

Companies Act No 71 (2008)

Companies Regulations

(2011)

Other relevant legislation

Social & Ethics Committee

RBPlat Board

Risk & Audit Committee

King III (2009) & Framework for

Integrated Reporting (2011)

(JSE & JSE-SRI Index requirement)

Integrated Report (& assurance)

Sustainability & the Integrated reporting

Journey

Legislation Code of Good Practice

Fig 1: Legislative & good practice context of RBPlat

14

Legislation

Companies Act No 71 (2008)

Companies Regulations (2011) King III (2009)

Code of Good Practice Company’s Voluntary Commitment

Draft Framework for Integrated Reporting

(2011)

UNGC Principles

JSE SRI Index

Consumer relations & protection,

advertising, PR ILO Protocol

Education development of

employees

Unfair discrimination Reduction of

corruption

Community development, sponsorships, donations &

charity

UNGC

Equality

EE Act

BBBEE Act

Environment

Health & Public Safety incl .

Products and services

ILO Declaration on Fundamental

Principles and Rights to Work

Universal Declaration of Human Rights

Rio Declaration on the Environment and

Development

UN Convention Against Corruption

Company social, environmental, labour, broader

economic, governance and

financial integration

Fig 2: Legislative and good practice context of RBPlat:

details

CRISA

UN-PRI

ICMM Principles

15

2. The RBPlat Social and Ethics Committee: Interpreted Responsibilities

and Implications

i. Responsibilities

Based on the legislative requirements and codes of good practice guidelines

described in the aforementioned sections, the following responsibilities have been

interpreted for the RBPlat Social and Ethics Committee is as follows:

provide direction and oversight with respect to the company’s impact on

society (internal social and external social issues), the broader economy and

the natural environment.

govern the pillars of sustainability through a company Sustainability Policy,

Code of Ethics/Conduct and other pertinent policies such as an Environmental

Policy, Occupational Health and Welfare Policy, and the Anti-Fraud and

Corruption Policy amongst others.

ensure compliance with relevant legislation such as the Skills Development

Act, Employment Equity Act, National Environmental Management Act and the

Broad Based Back Economic Empowerment Act amongst others.

ensure compliance with relevant legislation in other countries of operations,

complying with internationally accepted codes of practice and UN

declarations3 such as the:

o Universal Declaration of Human Rights (1948)

o International Labour Organisations Declaration on Fundamental Principles

and Rights to Work (1998)

o Rio Declaration on the Environment and Development (1992)

o United Nations Convention against Corruption (1992)

especially where legislation is inadequate or unavailable.

follow the recommendations of best practice codes such as King III, and

adopting internationally accepted principles such as that contained within the

UNGC, amongst others.

ensure that relevant legislation, sustainability principles and codes of best

practice are embedded in the core business areas of the company and in the

corresponding business processes.

give due consideration to product and service safety and impact from a

product “cradle-to-cradle” perspective.

support responsible competitiveness through advertising and other

interactions with the public.

bring to the Board’s attention any company matters that may result in an

adverse effect on the any of the pillars of sustainability .

3 http://www.unglobalcompact.org/AboutTheGC/TheTenPrinciples/index.html

http://www.unglobalcompact.org/AboutTheGC/TheTenPrinciples/index.html

16

report on the company’s activities in an integrated manner using

internationally and nationally accepted reporting guidelines such as the ISO

26000, GRI-G3/4 and the King III Integrated Reporting guidelines.

ii. Implications

Based on the responsibilities of the Social and Ethics Committee listed above, the

following broad company implications are noted:

Establishment of a Sustainability Committee at the management level to drive

and support the implementation of sustainability measures.

Declaration of leadership accountability and responsibility for all sustainability

matters.

Appointment of an executive reporting directly to the CEO on strategic matters

associated with sustainability and integrated reporting.

Assessment of the company’s sustainability baseline, determination of a

preferred status, and prioritisation of sustainability gaps.

Engagement of stakeholders on sustainability matters that affect them and/or

the company and consequent consideration of these material issues at the

governance and strategic levels of the company.

Development and implementation of a short term and long term sustainability

agenda, inclusive of an integrated reporting agenda.

Inclusion of sustainability in the vision and mission statement of the company,

and in the company values.

Development and approval of relevant company policies that address the

pillars of sustainability, such as a Sustainability Policy, Stakeholder Policy,

Codes of Conduct/Ethics, and Environmental Policy, amongst others.

Review of existing policies to integrate issues of sustainability.

Integration of sustainability issues into the company strategy and core

operations; including risk management, internal audit and quality

management.

Monitoring and evaluation of the company’s impact on society, the

environment and broader economy.

Mitigation or avoidance of negative impacts.

Awarding and rewarding sustainability practices.

Public disclosure (via an Integrated Report) on the financial and “non-financial”

impact of the company.

Obtaining third-party, independent and impartial assurance of the Integrated

Report.

Consideration of the company’s UNGC signatory status and adoption of

internationally accepted standards such as the Global Reporting Initiative -

G3/4 reporting guidelines and Accountability Standards amongst others.

17

3. Sustainability Value Proposition

Taking cognizance of the aforementioned legislation, codes of good practice, standards

and guidelines, and choosing to embed them into the core business and associated

process will support the long term sustainability of the company whilst creating and

sustaining value for all stakeholders. From a ‘business case’ point of view the benefits

are as follows:

Assurance of long-term financial sustainability of the company.

Pre-emption of potential challenges and barriers to business strategies and

plans.

Improvement of the health and safety of employees and surrounding

communities.

Improvement of risk management.

Improvement of quality management.

Improvement of company reputation (greater trust, credibility and confidence

amongst shareholders, employees and other stakeholders).

Informed decision making by:

o company leadership and management (once all the social, environmental

and economic implications and consequences of decisions and actions

become clear).

o strategic stakeholders (thereby influencing their impact on the company).

o shareholders (thereby influencing investment choices made by

shareholders).

Use of the sustainability agenda as a team building tool (to energise, inspire

and personalise the work place, attract and retain talented employees, create

an identity, incentivise productivity and innovation, etcetera).

Cost savings as a result of improved processes and services, and efficiency and

effectiveness of processes.

Innovation and exploration of new opportunities.

Built-in resilience to challenges and barriers.

Contribution to the company’s sustainability ranking.

Improvement in competitiveness.

Promotion of internationalization.

Attraction of investment.

18

4. Critical Risk Factors

Ensuring leadership understanding and commitment to sustainability is essential for the

success of any sustainability agenda. Furthermore, the agenda, policies and frameworks

need to be understood as part of an evolutionary journey, implementation of which may

result in some failures, however successes are inevitable through engagement, learning

and innovation which will be beneficial for all stakeholders. As a company embarks on

developing, establishing and embedding sustainability principles into the core of the

business, some common pitfalls and barriers need to be borne in mind to avoid failure

of the initiative at the outset. Hence steps need to be taken to ensure:

Prioritisation of sustainability at all corporate levels

Company-wide understanding of corporate sustainability and the embedded

importance thereof

Integration of sustainability within the core business

Availability, integrity and verifiability of information

Availability of resources

Comprehensive engagement of appropriate stakeholders

19

C. APPROACH TO DEVELOPING THE RBPLAT SUSTAINABILITY

FRAMEWORK

1. Overview This document presents a framework for a business concept that does not necessarily

comply with other standard business processes where decisions and actions can be

predetermined and submitted for implementation according to a set formula.

Sustainability requires extensive engagement of relevant (internal and external)

stakeholders to ensure the relevance and feasibility of the framework and subsequent

initiatives. Engagement processes prevent possible defensive or resistant responses,

instead engagement promotes buy-in and importantly, ownership of the decisions that

need to be taken to embark on a sustainable business journey.

Hence care has been taken in the development of this document to ensure that it

serves as a guiding framework as opposed to a predetermined structure that is closed

to review by all parties at all levels. Often suggestions are made to serve as an

illustrative example of the idea in mind (for example, the development of an

overarching theme for RBPlat’s sustainability agenda is suggested to be ‘responsible

leadership’; this is not meant to be prescriptive but rather a suggestion made by a

singular person which may not be suitable to the company leadership or the company

itself and therefore the idea of a theme, and what that theme should be, needs to be

interrogated by the relevant company stakeholders).

2. Approach With reference to the legislation and good practice guidelines described in the

preceding section, a 4 step-by-step approach to sustainability as RBPlat is proposed

that will be described in the sections to follow. The steps are as follows:

1. Step 1: Identification of a personalized theme for RBPlat’s sustainability agenda

to assist in the championing and communication of the company’s sustainability

drive.

2. Step 2: Development of overarching corporate guidelines for sustainability to

inform the development of the stakeholder engagement and sustainability

frameworks.

3. Step 3: Development of a stakeholder engagement framework to support the

development, establishment, implementation and relevance of the sustainability

framework.

4. Step 4: Development of a sustainability framework to outline the strategic level

actions, roles, responsibilities and timelines.

20

The sustainability framework is further unpacked into 5 implementation phases as

follows:

1. Phase 1: Realignment of the company profile.

2. Phase 2: Reviewing of corporate governance.

3. Phase 3: Integration of sustainability and risk management.

4. Phase 4: Establishment of a Sustainability Committee.

5. Phase 5: Integration of sustainability into existing management processes -

Establishment of internal roles and responsibilities for sustainability.

D. STEP 1: THE RBPLAT OVERARCHING THEME

Before embarking on the development of RBPlat’s sustainability framework it is pertinent to

develop an overarching theme for sustainability to exhibit the level of importance of the

concept within all aspects of the Company’s operations; from governance and strategy, through

to implementation and reporting. This easily identifiable and personalized theme must be able

to resonate with all RBPlat’s stakeholders as they in turn embrace and replicate the theme in

their own areas of authority.

The theme of ‘Responsible Leadership’ is proposed. Box 4 provides an overview of what this

terminology could mean to the company. The theme was identified based on the level of

importance assigned to ethical issues by the Company Board and the CEO. If approved, it is

imperative that the company’s leadership stance on ethics and sustainability within this theme

is developed and communicated within all areas of the business.

Box 4: Defining the theme.

Responsible leadership: value based, ethically driven

relationships between leaders and stakeholders who are

connected through a shared sense of meaning or purpose

through which they raise one another to higher levels of

motivation and commitment for achieving sustainable value

creation and social change (Maak & Pless, 2011).

A Responsible leader reconciles the idea of effectiveness with

the idea of responsibility by being an active citizen inside and

outside the organisations (Maak & Pless, 2011).

Responsible leader’s question: For what and to whom am I

responsible?

21

E. STEP 2: THE RBPLAT SUSTAINABILITY FRAMEWORK GUIDELINES

To support the human rights, labour, environmental, and economic principles (sustainability

pillars) contained in legislative and good practice codes described earlier, the following broad

sustainability guidelines have been developed and used in the development of the RBPlat

stakeholder engagement framework and sustainability framework. Guidelines are essential in

establishing the company’s overarching intention and approach; and they ensure that key issues

are included within the sustainability framework and consequent implementation plans.

Overarching Guidelines

Lines of accountability and responsibility for sustainability impact will be established.

Company stakeholders will be regularly consulted and engaged on various aspects of

sustainability to gauge materiality, risk and opportunities.

Sustainability principles will be integrated within the company’s governance, strategy,

planning, implementation, monitoring and evaluation, review, impact assessment,

assurance and public disclosure.

Sustainability principles will be applicable within the company’s sphere of influence,

namely, amongst all company suppliers, partners and other service providers (to

ensure that RBPlat is not indirectly complicit in human rights abuses, environmental

degradation and other irresponsible business practices).

Public disclosure on sustainability matters will be integrated with financial and

governance disclosure; and the contents thereof will be independently assured.

Governance Guidelines

Accountability for sustainability lies with the RBPlat Board.

Sustainability will be supported by relevant governance structures and policies, and

integrated into current and new policies.

The Board and Social and Ethics Committee will provide appropriate oversight on

sustainability matters and engage with relevant stakeholders accordingly.

Management Guidelines

Responsibility for sustainability lies with the RBPlat leadership (CEO and EXCO).

Sustainability will be embedded within the company’s vision, mission, values, strategy,

and operational plans.

Key impact performance indicators will be developed in consultation with relevant

stakeholder groups.

The cost of embedding sustainability will be included in operational costs.

Planning and implementation will allow for flexibility to enhance or mitigate

sustainability outcomes and impact.

Company processes must provide the information required to understand the social,

economic and environmental impact of company actions and decisions.

Human resource training, and communication and awareness campaigns for successful

implementation, will be established.

22

Information gleaned from monitoring and evaluation, company reviews, and other

assessment and reporting processes will be used to inform decision making.

Rewards and awards will be linked to sustainability performance.

Stakeholder Engagement Guidelines

Stakeholders will be identified, categorised and directly engaged stakeholders on issues

that are material to them and the company.

Material stakeholder concerns will be addressed in the company planning and decision-

making processes.

Concerns of potentially marginalised or vulnerable groups will be given special

consideration.

Impact of company activity will be assessed, and outcomes will be disclosed to

stakeholder groups.

Reporting Guidelines

Company financial and governance information will be disclosed in an integrated

manner with strategic, material, “non-financial” information.

Reporting will be accurate, reliable, quantitative and qualitative, engaged, relevant,

transparent, complete, inclusive, understandable, forward-looking, material and

impact associated.

Assurance Guidelines

Process of internal validation and external assurance will be established to improve

implementation processes and credibility of reporting.

External assurance will be 3rd party, independent and impartial, and inclusive of

engagements with relevant stakeholders.

23

F. Step 3: The RBPlat Stakeholder Engagement Framework

1. Overview The importance of stakeholder engagement in corporate sustainability cannot be

overemphasized. A stakeholder is generally understood to be any individual or group of

individuals that can affect or be affected by the activities of a company4.

Stakeholders are ultimately responsible for a company’s licence to operate since they

experience the impact of corporate activities and therefore have various means at their

disposal to inhibit the day-to-day or long-term functioning of a company.

Engagement with various stakeholder groups in a meaningful manner provides a

company with a ‘sustainability lens’ through which the company can view the impact of

its activities from a governance and management perspective. Therefore the main aims

of the engagement process is to:

determine what are the stakeholder’s material issues.

determine what are the company’s material issues.

determine the impact of the company on the pillars of sustainability.

reduce/mitigate negative impacts or scale-up/enhance positive impacts for

stakeholders.

determine company’s risks and opportunities.

Engagement with relevant stakeholders needs to take place during all phases of

business, from conception, through to implementation, monitoring and evaluation,

reporting and assurance. All corporate activity will affect one or more of the

sustainability pillars (environmental, social or economic) hence the consequent impacts

need to be predetermined and interrogated to support positive outcomes with

minimum (preferably zero) negative impacts.

2. Stakeholder Engagement Standards

For the development of the stakeholder engagement framework, the following national

and international standards were consulted were taken into consideration:

King III Code of Governance Principles for SA (2009)

King III Draft Framework for Integrated Reporting and the Integrated Report (2011)

GRI-G4 (and mining supplement) (2013)

ISO 26000 (International standards organisation - 2010)

AA 1000 SES (Accountability - stakeholder engagement standard - 2011)

4 Reference to a ‘stakeholder group’ in this document, includes individuals who may not belong to a group

per se.

24

AA 1000AS (Accountability - assurance standard -2008)

JSE SRI Index (2011)

ISAE3000 (international standard on assurance engagements - 2005)

IIRC Draft Framework (International Integrated Reporting Committee - 2013)

3. Purpose of Stakeholder Engagement

Stakeholder engagement should seek to achieve the following outcomes:

Develop and sustain company awareness of broader social, economic and

environmental risks and opportunities

Ensure accurate information dissemination to stakeholders

Ensure aligned goals and expectations

Support consensus-based decision-making

Ensure transparency

Establish responsibility and accountability of all parties

Establish and maintain trust in the company and its leadership

Support sustainability and relevance of company activity for value creation for all

stakeholders

4. Engagement Challenges and Pitfalls

The engagement process does pose specific challenges for which the company and

engagement facilitators needs to be prepared; these challenges and possible pitfalls may

be as follows:

Only primary stakeholders who are directly affected by company are engaged.

Only stakeholders who have transport/access to engagement sites are engaged.

Only stakeholders who speak a certain language can participate.

Only confident, articulate, educated or affluent sectors of society are engaged.

Engaging stakeholders through a third party representative who may not have the

mandate or insight to speak on behalf of the stakeholder; and who may also

misrepresent or misunderstand the materiality of the stakeholder’s issues.

Focusing on the most vocal or disruptive stakeholder groups.

Addressing short-term media interrogation after an incident as opposed to

proactive on-going engagement function.

Focusing on non-antagonistic stakeholders only (staying within the company’s

comfort zone).

Raising expectations of stakeholders who are beneficiaries of company activity

e.g. communities.

Stakeholder pressure on facilitators to make decisions/promises on behalf of the

company without consultation with relevant company authorities.

25

Overlooking marginalised (voiceless or disempowered) groups or individuals.

Unhealthy competition or conflict amongst stakeholder groups.

Differing stakeholder priorities.

Misconceptions amongst stakeholders.

Negative changes in community social networks as a result of company activity.

Differing interpretation of outcomes and impact amongst stakeholders and

between stakeholders and the company.

Scope of impact assessment too wide and not focused on important aspects of

impact.

Scope of impact assessment too narrow and does not sufficiently cover all

issues.

Unmanageable number of indicators in assessing impact of company activity.

Company personnel changes disrupts continuity of rapport with stakeholders.

Uncooperative stakeholders.

Stakeholders exhibiting excessive dependency on the company

Unrealistic expectations of the company from stakeholders and vice versa

Unreliable information - e.g. stakeholders providing information they think the

facilitator wants to hear (fear of losing opportunities if the company is

criticised).

Possible fraud/corruption through private engagement processes between

company representatives and stakeholders.

5. High Level Engagement Steps

Initially a high level generic engagement framework is required to ensure that

stakeholders are appropriately identified, engaged and responded to at all governance

and management levels.

This section provides a high level step-by-step approach to stakeholder engagement in 3

distinct areas (Fig. 3):

i) Before the engagement

ii) During the engagement

iii) After the engagement

26

i. Before the Engagement

Before the engagement process, stakeholders needs to be identified,

categorised and prioritised.

Identifying stakeholders

To identify stakeholders the following questions need to be asked5:

o To whom does the organization have legal obligations?

o Who might be positively or negatively affected by the organization's

decisions or activities?

o Who is likely to express concerns about the decisions and activities of the

organization?

o Who has been involved in the past when similar concerns needed to be

addressed?

o Who can help the organization address specific impacts?

o Who can affect the organization's ability to meet its responsibilities?

o Who would be disadvantaged if excluded from the engagement?

o Who in the value chain is affected?

As a result, Table 1 provides a preliminary list of stakeholders that have been

identified as RBPlat stakeholders.

5 ISO 26000

27

1. Identify Stakeholders

2. Categorise and prioritise stakeholders

3. Determine mode and frequency

of engagement

4. Determine

internal roles and

responsibilities

5. Brief stakeholder

s prior to engagement

6. Establish rules of

engagement

7. Achieve objectives

8. Determine

material issues

9. Determine roles and

responsibilities

8. Respond to material

issues

9. Assess impact

10. Feedback to stakeholder

s

11. Learn and

improve

Key:

Before the engagement

During the engagement

After the engagement

Fig 3: Stakeholder Engagement Steps

28

Table 1: RBPlat Stakeholder Groups6

Stakeholder Group Stakeholders Include

Shareholders

Royal Bafokeng Holdings (RBH)

Anglo Platinum Limited

De Beers

Minority Shareholders

o Investors

o Analysts

Employees

BRPM Management (Paterson D1 and above)

BRPM Permanent Employees (Paterson A1 – C5)

BRPM Contractors

Styldrift Contractors

Community

Royal Bafokeng Nation - Office of Kgosi

Royal Bafokeng Nation - Supreme Council

Royal Bafokeng Administration (RBA)

Royal Bafokeng Institute ( RBI)

Robega Village

Chaneng Village

Rasimone/Mafenya Villages

Community Leaders (Councillors & Kgotlas on RBN land)

Community Religious Organizations

Local and neighbouring farmers

Local farmer associations

Sun City

Specialist groups (Women, youth)

Department of Minerals Resources

(DMR)

DMR National (Pretoria)

DMR Regional (Klerksdorp)

Municipality (ies)

Rustenburg Local Municipality

Moses Kotane Local Municipality

Bojanala District Municipality

Trade Unions Trade Unions - National Union of Mineworkers (NUM)

Union of Associations of South Africa (UASA)

Suppliers

Major Suppliers (ESKOM, Magalies Water)

Other major suppliers (mining and plant related)

Sub-Contractors

Indirect employees (employees of suppliers)

Customers Anglo Platinum Limited

Neighbouring Mines/projects

Impala Platinum Limited

Rustenburg Platinum Mines Limited (RPM)

Xstrata/Merafe Resources Limited;

Wesizwe Platinum Limited;

Western Bushveld JV

Other industry peers

Media

Newspapers

Business day

Star – business report

Beeld

Miningmx

Mining weekly

Financial mail

Segoagoa (Phokeng newspaper)

CNBC/Summit/SABC/ Alec Hogg/Classic FM/702

Department of Labour

6 From RBPlat Stakeholder Engagement Framework 2011 (revised)

29

Table 1: RBPlat Stakeholder Groups6

Stakeholder Group Stakeholders Include

Government

Department of Education

Department of Health

Department of Water Affairs

Department of Environment Affairs

Department of Safety and Security

Department of Housing

Department of Traditional Affairs and Cooperative Governance

North West Dace

Department of Rural Development and Land Reform

Non-Governmental Organizations

(NGOs, CBOs, FBOs) Recognised NGOs, CBOs, FBOs

International industry bodies International Platinum Group Metals Associations (IPA)

Platinum Guild International (PGI)

National industry bodies

Chamber of Mines of South Africa

Business Unity South Africa (BUSA)

Southern African Institute of Mining and Metallurgy (SAIMM)

National Business Initiative (NBI)

Sustainability stakeholders

JSE Socially Responsible Investment Index (JSE SRI Index)

United Nations Global Compact (UNGC)

Carbon Disclosure Project

Auditors/assurance providers Certification bodies – ISO 1400, OHSAS 1800,

Integrated Report assurance provider

In identifying stakeholders, the common pitfalls of focusing narrowly on the company’s economic

issues only, or on the risk and opportunities that stakeholder engagement may reveal should be

avoided. Giving consideration to the material issues of the company only, or to material issues of

stakeholders that can affect the company only, thereby ignoring the material issues that affect

stakeholders as well (that may or may not affect the company but are still material to the

stakeholders and are therefore important) is also detrimental.

In essence, everyone has a stake in a company if the conduct of the company in any way affects

the moral rights of that individual (therefore the relationship does not have to be direct as in

the case of employees, but can be indirect through ripple effects from any corporate activity on

any stakeholder).

To supplement Table 1, existing information channels and corporate networks must be used to

engage with all stakeholder groups indicating which stakeholder groups have been identified by

the company and invite input on the identification of additional stakeholder groups.

Categorising and prioritising stakeholders

Categorization of stakeholders is based on the level of importance of the stakeholder in relation

to the stakeholder’s impact on the company and vice versa (such as level of impact, influence,

dependency, responsibility, tension, representation, proximity, etcetera). Using the matrix in Fig.

4 the axes can be changed to reflect the type or magnitude of the impact the company is

30

assessing. Fig. 4 is an example of categorisation and prioritisation with the variables being

‘importance for engagement’ and ‘importance for positive sustainable impact’.

Once the stakeholders have been categorised and prioritised, the objective and scope of

engagement for each group (motives for engagement could include potential legal, financial,

social or environmental risk) needs to be determined. A strategy for engagement also needs to

be developed to ensure that the key principles of inclusivity, materiality and responsiveness are

included. Consideration needs to be given to the stakeholder’s willingness to engage, knowledge

of the issues, potential expectations, inclusion of marginalized or “voiceless” stakeholders, fear of

victimization, conflict of interest, cultural difference, volatility of issues to be discussed, etcetera).

Keep informed: External auditors Organised business Industry peers

Manage closely and maintain regular dialogue: Governments (International, national, provincial & local) JSE & JSE SRI Index Media Civic “watch-dogs” UNGC International Extractive Industry Bodies

Maintain high level of dialogue and keep satisfied: Business partners Shareholders/investors

Manage very closely and maintain very high level of dialogue: Board (Audit & Social and Ethics Committee) EXCO Employees & unions Business units (Operations, logistics, etc) Other support units (IT, HR, etc) Suppliers Communities Indirect employees

Low High

Hig

h

Imp

ort

ance

fo

r e

nga

gem

en

t

Importance for positive sustainability impact

Low

Fig 4: Categorising and prioritizing stakeholders using a variety of criteria

31

Determine mode and frequency of engagement

Based on the categorization of the stakeholder groups, Table 2 provides a guide on the types of

engagement processes that can be followed based on the objectives of the engagement and the

nature of the relationship between the company and the stakeholder.

Table 3 unpacks the RBPlat stakeholders that have been identified, reflects the drivers for

engagement, raises potential key issues, and describes the mode, frequency and names

appropriate company facilitators for the engagement process.

Various tools are available to support differing types of engagement (eg. Anglo American Socio-

Economic Assessment Toolbox (SEAT)7 for community assessment; the International Finance

Corporation: Stakeholder Engagement8 in emerging markets, etcetera).

Determine internal roles and responsibilities

Once the appropriate stakeholder engagement facilitator is identified, s/he needs to obtain

appropriate training for the facilitation process to ensure that the process is professionally

managed in terms of protocol and process.

Briefing the stakeholders prior to engagement

Relevant briefing material needs to be provided to the stakeholders in advance of the

engagement in the appropriate language and format to suit the stakeholder. Potentially

marginalized or vulnerable individuals/groups must be able to physically access the engagement

process. Steps must be taken to ensure an intimidation free engagement process and a grievance

mechanism needs to be established to ensure that any engagement process issue can be

escalated to the appropriate corporate authority.

7 Anglo American plc (Anglo) has made its Socio-Economic Assessment Toolbox (SEAT) freely available as a

contribution to managing the socio-economic impacts of extractive, other natural resource and industrial operations. 8 International Finance Corporation: Stakeholder Engagement. A Good Practice Handbook for Companies

Doing Business in Emerging Markets.

32

9 From RBPlat Stakeholder Engagement Framework 2011 (reviewed)

Table 2: Guide to types of Engagement 9

Level Goal Communication Nature of Relationship Engagement Approaches

Monitor Monitor stakeholders’

views.

One-way: stakeholder to

Company.

No immediate

relationship

Media and internet tracking.

Second-hand reports from other

stakeholders.

Inform Inform or educate

stakeholders.

One-way: company to

stakeholder, there is no

invitation to reply.

Short or long term

relationship with

stakeholders.

"We will keep you

informed."

Bulletins and letters. Brochures, reports and

websites. Speeches, conference and public

presentations.

Open houses and facility tours. Road shows

and public displays. Press releases, press

conferences, media advertising, lobbying.

Transact

Work together in a

contractual

relationship where

one partner directs

the objectives and

provides funding.

Limited two-way: setting and

monitoring performance

according to terms of

contract.

Relationship terms set by

contractual agreement.

“We will do what we said

we would” or “we will

provide the resources to

enable you to do what

we agree”.

‘Public Private partnerships’ and Private

Finance Initiatives, Grant-making, cause

related marketing.

Consult

Gain information and

feedback from

stakeholders to inform

decisions made

internally.

Limited two-way: company

asks questions and the

stakeholders answer,

stakeholders raises other

issues.

Short- or long-term

involvement.

"We will keep you

informed, listen to your

concerns, consider your

insights, and provide

feedback on our

decision."

Surveys. Focus Groups. Workplace

assessments. One-to-one meetings.

Public meetings and workshops.

Standing stakeholder advisory forums.

On-line feedback and discussion.

Involve

Work directly with

stakeholders to

ensure that their

concerns are fully

understood and

considered in decision

making.

Two-way, or multi-way

between company and

stakeholders. Learning takes

place on both sides.

Stakeholders and company

take action individually. There

is responsibility on both sides.

May be one-off or

longer-term

engagement. "We will

work with you to ensure

that your concerns are

understood, to develop

alternative proposals and

to provide feedback

about how stakeholders

views influenced the

decision making

process”.

Multi-stakeholder forums.

Advisory panels. Consensus building

processes.

Participatory decision making processes.

There is responsibility on both sides.

Collaborate

Partner with or

convene a network of

stakeholders to

develop mutually

agreed solutions and

joint plan of action.

Two-way, or multi-way

between company/ies and

stakeholders. Learning,

negotiation and decision

making on both sides.

Stakeholders work together to

take action.

There is responsibility on both

sides.

Long- term. "We will look

to you for direct advice

and participation in

finding and implementing

solutions to shared

challenges.”

Joint projects, voluntary

two-party or multi-stakeholder

Initiatives, Partnerships.


Empower

Delegate decision-

making on a particular

issue to stakeholders.

New organizational forms of

accountability:

Stakeholders have formal role

in governance of an

organisation or decisions are

delegated out to stakeholders.

There is responsibility on both

sides.

Long-term. “We will

implement what you

decide.”

Integration of Stakeholders into Governance

Structure. (E.g. as members, shareholders or

on particular committees, etc.)


33

Table 3: Stakeholder Engagement Process10

Name of

Stakeholder Representative(s)

Key Drivers of

Engagement Level of

Engagement Key Issues Potential Concerns

Method of

Engagement or Media Frequency

Primary

Responsibility

Shar

eh

old

ers

Royal Bafokeng

Holdings (RBH)

Anglo American -

Platinum

Minority Shareholders

Local

employment,

local

procurement,

Social

development,

Environmental

conservation,

operational

performance,

Styldrift project

development

Transact;

Consult;

Involve;

Collaborate

SLP/ Mining Charter/

Transformation

Health & Safety

Licence to operate;

employment equity;

safe working conditions & zero

fatalities;

achieving production

Board Meetings

Regular

technical and

communication

meetings

Board

CEO

Investment

relations

manager

Operational performance

Implementation progress;

meeting targets; dividend

payment

Quarterly Reports Quarterly Sustainability

Project development

Technical Performance

SLP/ Mining Charter/

Transformation Implementation progress;

meeting targets;

compliance

Road shows

Integrated Annual

Reports

Presentations at

conferences

Half-year results

Press

announcements

SENS

Annually

Technical Performance Timely delivery of project;

funding;

ability to operate;

ability to be profitable

Emp

loye

es

BRPM Management

(Paterson D1 and

above)

BRPM Permanent

Employees (Paterson

A1 – C5)

BRPM Contractors

Human,

Economic, Legal &

Transformation

Inform;

Transact;

Consult;

Involve;

Collaborate;

Empower

Health & Safety Safe and healthy working

conditions - Lebone Newsletter

- Meetings -

Workshops, -

Posters, -

Booklets

- Industrial theatre

- Induction training

- Communication

Forums

- Skills Development

Weekly

CEO

HR Exec

GM’s

Change in working condition

as a result of new Company

Redundancy;

Loss of privileges; Conditions of

employment and benefits;

Lack of consultation

Discrimination/

Transformation

Racial transformation

Remuneration

Opportunities and

appointments

Training

10

From RBPlat Stakeholder Engagement Framework 2011 (revised)

34


Name of


Key Drivers of

Engagement Level of


Method of


Primary

Responsibility

Social and Labour Plan/

Mining Charter/

Career development and

promotions;

housing

Committees

- Presentations

- Performance

Reviews

- Transformation

Committee

- CEO letter

- Open days

Latent friction between

contracting and permanent

staff

Optimising local opportunities;

Negotiating / bargaining power

(Minimum wage debates)

o Productivity and

wage bill

Co

mm

un

ity

Royal Bafokeng

Nation (RBN)

Royal Bafokeng

Administration

(RBA)

Royal Bafokeng

Institute( RBI)

RBED

Robega Village

Chaneng Village

Rasimone/ Mafenya

Villages

Community Leaders

Community

Religious

Organizations

Local and

neighbouring

farmers

Local farmer

associations

Sun International

Human,

Economic, Social,

Environmental,

Legal &

Transformation

Monitor;

Inform;

Transact;

Consult;

Involve;

Collaborate;

Empower

Non-Bafokeng on Bafokeng

land or Bafokeng

administrated land

Land use - less land available

for alternative uses;

informal settlements;

proximity of the mine;

disproportionate benefits to

RBH

Focus groups, local

representatives and

public meetings

Village council

meetings

Quarterly

CEO

GM’s

CSI manager

Preferential procurement

SMME development; training

and mentoring; procurement

policy implications;

capability and capacity of

suppliers to be determined;

processing / criteria / access to

information / timing Public meetings or

forums

Quarterly

Housing

Cracked housing:

Informal housing and resultant

social implications/issues;

Availability of land for houses;

RBN ownership of land versus

residents ownership of

property

Quarterly

Infrastructure

Development of roads etc.;

The rate of damage to

infrastructure versus cost and

rate of repair

Public meetings or

forums,

collaborative

projects

Quarterly

35


Name of


Key Drivers of

Engagement Level of


Method of


Primary

Responsibility

Environmental

Noise;

Water usage and pollution;

Dust;

Land use from an agricultural

point of view

Focus groups Quarterly

Job Opportunities

Inherent expectation of

keeping current job and

availing more

Quality of the jobs

Public meetings or

forums Quarterly

Community Development

Variation from village to

village;

Need to effectively counter

negative impact of mine versus

Social Equity;

Sustainable poverty alleviation

and social upliftment;

Education: Residents of state

land cannot get bursaries or

financial aid

Education: Orphans and other

vulnerable groups caught in

vicious cycle due to lack of

education programs

Public meetings or

forums,

collaborative

projects

Village council

meetings

Monthly

Growing social impact of

mine

Sustainability beyond mining;

Health (HIV/AIDS prevalence

amongst “single” migrant

workers);

Women and young girls

increasingly vulnerable;

Increasing rate of rape and

other violent crime

(xenophobia, robberies)

Baseline Socio-

economic Survey Quarterly

Social and Labour Plan Lack of implementation of Public meetings or Quarterly

36


Name of


Key Drivers of

Engagement Level of


Method of


Primary

Responsibility

commitments forums, brochures,

leaflets, posters

Trad

e U

nio

ns

Union of Associations

of South Africa

(UASA)

Trade Unions National

Union of

Mineworkers (NUM)

Human,

Economic, Social

& Transformation

Inform;

Transact;

Consult;

Involve;

Collaborate;

Empower

Social and Labour Plan Lack of implementation of

commitments; Unions’ views

Workshop, posters,

booklets Monthly

CEO

HR Exec

Housing Employee housing

Panels or

committees

Written

communication

Monthly

Job Opportunities Availability of jobs at Styldrift

Health & Safety Injuries and fatalities

Employment Equity Lack of HDSAs and women in

management positions

Remuneration (Collective

Bargaining) Increase in salaries

Future Forum Quarterly

Retrenchments Potential Retrenchments

Skills Development Non-mining portable skills Panels or

committees Quarterly

DM

R

DMR National

DMR Regional

Legal &

Transformation

Inform;

Consult;

Collaborate;

Social and Labour Plan/

Mining Charter Compliance /

Transformation

Fulfilment of mining charter

requirements

Meetings Quarterly CEO

Company

Secretary Site visits/

presentations Bi-annually

Annual Report Annually

Environmental Compliance Compliance with the EMP

Meetings Quarterly

Site visits/



Health & Safety Compliance Increase in fatalities

Meetings Quarterly

Site visits/



37


Name of


Key Drivers of

Engagement Level of


Method of


Primary

Responsibility

Retrenchments Possible job losses Meetings Needs basis

Mu

nic

ipal

ity

Rustenburg Local

Municipality

Bojanala District

Municipality

Human,

Economic, Social,

Environmental &

Transformation

Inform;

Transact;

Consult;

Involve;

Collaborate;

Social and Labour Plan (Local

Economic Development,

Skills Development, Housing,

Job Opportunities,

Preferential procurement &

SMMEs)

Meetings or forums

Quarterly

CEO

GMs

CSI Manager

Revenue generation;

employment creation; regional

development Job creation

Informal settlements;

environmental damage

Partnerships,

collaborative

projects

Brochures, leaflets,

posters Annually

Sup

plie

rs Suppliers

Sub-Contractors

Economic, Social,

Environmental,

Legal &

Transformation

Inform;

Transact;

Consult;

Involve;

Collaborate;

Empower

Contract duration

Pricing

BBBEE Codes

Environmental

Health & Safety

What opportunities are there

to improve and expand our

business relationship with

RBPlat;

Compliance with Charter and

Codes;

Health & Safety of contractors

on site

One-on-one Quarterly Procurement

Exec

Meetings Quarterly

Workshops Bi-annually

Cu

sto

me

rs

Anglo Platinum Economic, Inform;

Transact;

Contract duration

Pricing

Quality of products

Product stewardship

Contract terms and delivery

Reliability of supply

Strong, ongoing customer

relationship

Meetings (BRPM JV

Manco)

Written

communication

Quarterly

CEO

Med

ia Investors

Analysts

Newspapers

Human,

Economic, Social,

Environmental,

Legal &

Monitor;

Inform;

Transformation/Mining

Charter

Transformation , Employment

Equity, Employing women Online information

and forums, annual

reports

Quarterly CEO

Investor

relations

manager Mining Right Compliance Legal and moral licence to

operate Quarterly

38


Name of


Key Drivers of

Engagement Level of


Method of


Primary

Responsibility

Transformation

Environmental Compliance

Impact on the environment -

pollution;

Compliance with the EMP;

Rehabilitation

Quarterly

Sustainability

Exec.

Health & Safety Compliance Injuries and fatalities Quarterly

Impact on society Strike action Quarterly

Retrenchments Large scale retrenchments

Radio, television,

newspapers, public

meetings or forums

Needs basis

Transparency Withholding information

Newspapers,

brochures, leaflets,

posters

Annually

Human Rights Human rights violations

Newspapers,

brochures, leaflets,

posters

Annually

Ne

igh

bo

uri

ng

Min

es

Sustainability and

Mine Managers

Human,

Economic, Social,

Environmental,

Legal &

Transformation

Monitor;

Transact;

Consult;

Collaborate;

Licensing

Collaborative community

projects

Informal settlements

Environmental

Mining LED Forum

No specific concerns

One-on-one, panels

or committees,

partnerships,

collaborative

projects, non-

technical summary

documents and

reports

Quarterly

CEO

GMs

CSI Manager

Pro

vin

cial

Go

vern

m

ent

Department of Labour Legal &

Transformation,

Human,

Economic, Social,

Inform;

Transact;

Consult;

Involve;

Collaborate;

Employment Equity Meeting EE targets Focus groups, one-

on-one, road shows,

stakeholder

networks, panels or

committees, public

Quarterly CEO

Department of Water

Affairs Compliance

Integrated water use license;

water conservation Quarterly

39


Name of


Key Drivers of

Engagement Level of


Method of


Primary

Responsibility

Department of

Education

Environmental

Skills Development

Schools support

Weak school system;

Low mats and science pass

rates;

Sponsoring teachers’ salaries

meetings or forums,

partnerships

including alliances,

collaborative

projects

Quarterly

Department of Health Clinics

Ambulances Poor health facilities Quarterly

Department of

Environment Affairs Environmental compliance Pollution , dust & noise Quarterly

Department of

Housing

Housing for employees;

Informal settlements

RBPlat’s contribution to low

cost housing;

Formalization of informal

settlements

Quarterly

Department of Safety

and Security Influx of non-locals Increase levels of crime Quarterly

Sou

th A

fric

an C

ham

ber

of

Min

es

South African

Chamber of Mines

Economic, Legal &

Transformation Inform;

Consult;

Various industry related

issues

Industry Sustainability

Nationalisation

Trade union relationships

Mine employee health and

safety

Focus groups, one-

on-one, stakeholder

networks, panels or

committees,

partnerships


collaborative

projects, non-

technical summary

documents and

report

Monthly and

other ad hoc

subcommittee

meetings

CEO

Sust

ain

abili

t

y Stak

eho

lder

s

JSE SRI Index Transparency,

ranking and

disclosure Reporting

Stakeholder engagement,

supporting sustainability

pillars, responsibility and

accountability for

sustainability

Fulfilling sustainability

principles

Setting and meeting targets

Public disclosure on

company website.

Direct submission of

reports

Annual

Risk and

Sustainability

Exec

UNGC

40


Name of


Key Drivers of

Engagement Level of


Method of


Primary

Responsibility

Carbon Disclosure

Project

Au

dit

ors

an

d

assu

ran

ce

pro

vid

ers

Certification bodies –

ISO 1400, OHSAS

1800, amongst others

Certification and

assurance of

company’s

sustainability

activities

contractual

Stakeholder engagement,

supporting sustainability

pillars, accountability for

sustainability

Fulfilling sustainability

principles

Data integrity

Transparent and accurate

reporting

One-on-one

meetings Annual

Risk and

Sustainability

Exec

Integrated report

assurance provider

NG

Os

Local and

international NGOs

Human, Social,

Environmental,

Legal &

Transformation

Monitor;

Inform;

Consult;

Collaborate;

Human Rights Human rights violations

Interviews;

Bulletins and letters;

Brochures, reports

and websites;

Public

presentations;

Press releases.

Ad hoc

Risk and

Sustainability

Exec

Environmental Pollution

Social impact

Socio-economic impact of

mining;

Incorporating communities’

views;

Inte

rnat

ion

al

ind

ust

ry

bo

die

s

International

Platinum Group

Metals

Associations (IPA)

Platinum Guild

International (PGI)

Economic,

Innovation

Inform;

Consult;

PGM industry development

e.g. jewelry demand

Sustainable development

Security

Regulatory changes

Focus groups, one-

on-one, stakeholder

networks, panels or

committees,

partnerships


collaborative

projects, non-

technical summary

documents and

report

Annually

CEO

41


Name of


Key Drivers of

Engagement Level of


Method of


Primary

Responsibility

Nat

ion

al in

du

stry

bo

die

s

Chamber of Mines

of South Africa

Business Unity

South Africa

(BUSA)

Southern African

Institute of Mining

and Metallurgy

(SAIMM)

Economic,

Legal &

Transformation

Inform;

Consult;

Sustainable development

Industry development

(technical)

Professional development

Nationalisation

Focus groups, one-

on-one, stakeholder

networks, panels or

committees,

partnerships


collaborative

projects, non-

technical summary

documents and

report

Monthly

(SAIMM and

Chamber of

Mines)

42

ii. During the Engagement

Establishing the rules of engagement

Before the actual engagement process begins, the purpose, scope and rules of

engagement needs to be established, inclusive of disclosure boundaries, confidentiality

and anonymity. The facilitator must also confirm the presence of key stakeholder groups

required for the process to be meaningful; furthermore these key groups must be

personally present or legitimately represented through a direct mandate by alternative

third parties. The principles of engagement need to be outlined to reflect inclusivity,

materiality and responsiveness.11

Inclusivity: company enables stakeholders to participate directly throughout the

decision making process

Materiality: relevance and significance of an issue to the company and its

stakeholders is determined

Responsiveness: company response to stakeholder issues that affects its

sustainability performance is realised through decisions, actions, performance and

communication with stakeholders

Through a consultative process all stakeholders need to agree on a decision making

process. The grievance mechanism that was established to address any matters arising

from the facilitation and outcomes of the meeting must be explained to the stakeholders.

Achieving objectives

During the engagement process itself, it is easy to become side tracked by issues that do

not pertain to the objectives of the day, therefore remaining focused is essential whilst

giving credence to other matters arising that could be addressed in another session or

different platform. Potential disruptions may be caused by:

• Misunderstanding of the issues

• Intimidation

• Emotional diversions

• Rivalries

• Lack of trust

• Complexity of issues

• Poor participation

• Misrepresentation of stakeholder interests

11

AA1000AS (2008)

43

A solutions-oriented approach needs to be adopted with a focus on:

Identifying (listing and confirming) issues of material importance to individual

stakeholder groups through the engagement process.

Determining stakeholders required outcomes in addressing material issues

(include indicators and timeframes).

Determining roles and responsibilities, especially if stakeholders are to

participate actively in addressing the material issues.

Important note:

Stakeholder engagement is primarily and information dissemination and gathering

process to improve the impact of the company; therefore unless authorized to do so, no

decisions or promises should be made without consultation with relevant company

authorities.

iii. After the Engagement

Responding to stakeholder issues and assessing impact

A key component of stakeholder engagement is ensuring that the material issues

identified during the engagement process is actually addressed by the company.

Firstly, it is important to determine how these material issues will affect company

policy, legal compliance, financial and operational performance, competitiveness,

reputation, etcetera.

Secondly, strategies to address material issues (this includes the role and

responsibility the stakeholder groups are expected to play; see Table 2).

Thirdly, material issues need to be integrated into the company’s decision making

processes (governance and strategy), and appropriate interventions need to be

implemented.

Fourthly, performance needs to be monitored and evaluated against agreed

indicators, impact needs to be assessed, and learning for improvement and

innovation is required.

Feedback to stakeholders

Regular feedback to stakeholders on outcomes of strategies to address their material

issues is required and public disclosure on outcomes is essential (reporting must be

comprehensive, transparent and material). Stakeholders must also be involved in the

independent reporting assurance process.

44

G. Step 4: The RBPlat Sustainability Framework

1. Internal Context - Current and Preferred Status

Prior to developing the overarching sustainability framework, it was important to obtain a

broad overview of the company’s current sustainability status. A high level baseline

assessment of RBPlat’s current public disclosure on sustainability was been taken into

consideration in the development of this framework through assessment of the Company’s

2012 Integrated Report and website. This was done to obtain an understanding of the

Company’s current status and to present areas for development. Figure 5 provides a broad

outline of key areas identified for improvement within existing business processes (green

blocks). These issues are discussed throughout this section; and the implementation plan

to address them are listed in Tables 8 and 9.

Fig. 6 provides an overview of the Company’s proposed preferred outcomes after

addressing the areas of improvement. Stakeholder engagement, which will take place

company-wide, is a prominent requirement for successful sustainability outcomes. The

outcomes of stakeholder engagement will influence and ensure informed corporate

decision-making to secure desired impacts, reduce risks, inform mitigation and adaptation

measures, and reveal new opportunities and successes for enhancement. Ultimately,

through support, buy-in and ownership of sustainability measures by all business units and

individuals within the company, sustainability will be embedded within the company

culture as ‘just the way things are done’; perhaps eventually moving from the tag line of

‘more than mining’ to ‘mining responsibly’.

45

RBPlat Board S & E Committee (Accountability)

Commitment Oversight Prioritise

Governance

Stakeholder Engagement

CEO (Responsibility)

Strategy

Risk & Assurance Executive

(Responsibility)

Management

Annual Report 3rd

Party Assurance

Policy register Gap analysis Develop & approve Review of current policies & ToR’s Public disclosure

Prioritise Drive

Champion Commitment Prioritise Incentivise & reward Resources

Material issues Gaps and recommendations Public disclosure

Planning Outcomes Training Opportunities Systems & processes Risks Methods and tools Innovation Indicators M&E Baseline Review Targets Impact Implementation Learning Reporting

Reporting framework Integrated Information management Information availability, integrity and verifiability Benchmarking Public disclosure

Governance Strategy Comprehensive Identification Categorisation Prioritisation Mode and Frequency of engagement Material issues Response Feedback Impact

Unpack Embed sustainability principles, goals Communication & awareness

Fig 5: Suggested Priority Areas

46


Governance

RBPlat Board S & E Committee (Accountability)

CEO (Responsibility)

Strategy Risk & Assurance

Executive (Responsibility)

Management Annual Reporting 3rd

Party Assurance

Decision

making

Impact:

risk

mitigation adaptation

+

opportunities

enhancement

=

resilience

Sustainability Oriented Company Culture

Fig 6: Suggested RBPlat Preferred Status

47

2. The Sustainability Framework

This section describes the overarching sustainability framework into which the

sustainability theme and stakeholder engagement framework described in the previous

sections need be embedded. Since the concept of sustainability already has a

substantial presence within RBPlat, this document is intended to focus on a review and

realignment approach to sustainability.

The 5 key realignment phases identified are as follows:

1. Phase 1: Realignment of the Company profile where necessary (namely, the

vision, mission, values).

2. Phase 2: Review or development of the appropriate governance documents

(Board and committee charters) to reflect accountability for sustainability, and

policies (such as the sustainability policy, code of ethics, environmental policy,

health and safety policy, anti-fraud and corruption policy, etcetera).

3. Phase 3: Integration of sustainability into existing management processes through

risk management.

4. Phase 4: Establishment of a Sustainability Committee to manage the

implementation and integration of sustainability principles inclusive of broader

roles and responsibilities.

5. Phase 5: Integration of sustainability into existing management processes;

establishment of internal roles and responsibilities for sustainability.

48

i. Phase 1: Realigning the Company Profile

The current company profile (in some instances) makes implicit reference to

sustainability; however since these references need to be explicit. A process of

engagement needs to be embarked upon to reassess, define or explain the key

words used to represent the Company and the image the Company wishes to

portray. Once this is achieved, the sustainability embedded Vision, Mission, Values

and strategic intent can be used as the ‘platinum thread’ that runs through and

binds all corporate decisions and actions.

Table 4 is representative of what aspects of the company profile needs to be

unpacked and reassessed to reflect the company image. This tool needs to be taken

through an engagement process with relevant stakeholders to obtain relevant input,

secure pride and ownership in the development of the company’s sustainability

image, and prepare participants for the process of integrating the Company’s

sustainability stance into their areas of authority.

Table 4: Unpacking the Company Profile

Profiled area Current description Words/phrases to be unpacked to

reveal explicit meaning

Business

approach

Maximum value from safe platinum group metals extraction Value

Mission To leave a lasting legacy of sustainable benefits for our

stakeholders

Legacy

Benefits

Stakeholders

Vision To seek and deliver the good from mining Good

Purpose The purpose of our business model is to create economic

value, within a mutually beneficial joint venture, in a manner

that also creates value for society

Value

Strategy Towards operational excellence Operational excellence

Build flexibility Flexibility

Grow organically Grow organically

Pursue value enhancing opportunities Value enhancing opportunities

Logo A crocodile eye - the genealogical icon of and a symbol of

prosperity for the Royal Bafokeng Nation. The green colour

symbolises the natural environment and our principle to

conserve it, while the silver stands for the colour of platinum.

-

Tagline 'More than mining' relates to the significance of the logo

symbolising the bigger picture - mining is what we do and not

who we are.

Explain: mining is what we do and not

who we are

Values Safety and People First: Mining is a high-risk business and

cannot succeed without total trust, respect, teamwork and an

uncompromising commitment to safety and people first.

Values well explained – review where

necessary

49

Table 4: Unpacking the Company Profile

Profiled area Current description Words/phrases to be unpacked to

reveal explicit meaning

Promises delivered: We do what we say we will do.

Mutual Interests & Mutual Rewards: We have mutual goals

and mutual interests, and we depend on each other to realise

our collective vision and mission. We operate in good faith,

openly and transparently.

Characteristics Community Owned

The RBN remains a community with traditional leadership

and community structures complemented by a

"contemporary vision that aims to secure long-term

prosperity by actively 'mining the future' in every possible

way". Our operations are therefore geared to benefit the

community - the majority shareholder in the business

following the restructure of the joint venture; and the lessors

of the land upon which the mining operations are located

(e.g. Boschkoppie 104 JQ and Styldrift 96JQ).

Embracing Multiplicity

While the RBN is the majority shareholder and beneficiary of

the business, the presence of a diversity of skills and cultures

within the organisation is a strength that we embrace as we

face the challenges and opportunities of the future.

Proud Humility

We are proud of our new age approach to mining while

remaining humble and grounded in everything we do.

Sustained Success

We pursue success with the aim of achieving our stakeholder

beneficiation purpose to leave a lasting legacy.

Firm Flexibility

We acknowledge that some issues are negotiable while

others are not - safety is paramount in our business.

Improvement and efficiency are sought in all areas provided

our people, our safety and our environment are not

compromised.

Rare Pragmatism

We focus our efforts on establishing innovative win-win

solutions for all our stakeholders based on our extensive

experience in the business.

Characteristics well explained – review

where necessary

50

ii. Phase 2: Review of Corporate Governance

The next step in the corporate realignment process is to ensure that sustainability is

appropriately governed within the Company. Governance pertains to the Board and sub-

committees’ charters that address issues of oversight, compliance and accountability.

Issue specific policies needs to be developed and/or reviewed to govern the Board’s

stance on essential matters. Policies should include a description of the stakeholder

engagement process that the development of the policies have undergone to legitimize

their value. The corresponding policy goals also need to be ratified at the governance

level. In support of the governance review process, the following needs to be achieved:

• Development of a comprehensive internal policy register (aligned to appropriate

legislation where relevant) inclusive of appropriate sustainability policies needs to

be established together with a description and map of the compliance areas, roles

and responsibilities, and current compliance levels.

• Review of charters (Board and committee charters) to reflect accountability for

sustainability and develop/review relevant sustainability policies (such as the

sustainability policy, code of ethics, environmental policy , health and safety policy,

antifraud and corruption policy, etcetera).

• Establishment of corporate goals with embedded sustainability.

iii. Phase 3: Integration of sustainability and risk

This sustainability framework capitalizes on the recent merger between RBPlat’s

Sustainability portfolio with that of the Risk and Assurance portfolio.

Generally, corporate risk assessments are well established and enjoy a status of

importance as a key business process within companies, therefore the merger between

sustainability and risk provides an opportunity to:

use existing risk management structures for the management of sustainability.

use existing risk reporting methods and processes for reporting on sustainability.

raise the profile of sustainability risks within the risk identification and management

process.

obtain support from internal audit for sustainability assessments.

Fig. 7 illustrates the integration of sustainability (green blocks) within existing risk

structures and functions (blue blocks). Therefore once the various stakeholder groups and

company’s material issues have been identified as in described in Section 2 of this

document, they may then be classified as sustainability risks and follow the same

procedures for the avoidance or mitigation of the risk; namely the various risk

management structures and processes may be used to ensure the development of

appropriate strategies and processes to address these sustainability risks.

Important note:

Not all sustainability issues may be identified as corporate risk issues, however the governance and

management of these issues are still important and due process should be followed to ensure that

they are addressed and reported accordingly.

51

Significance rating Mitigation/enhancement strategy Opportunities Goals, targets & dates Indicators Systems & Processes Outcomes & impact

Divisional Risk Management: Operations Supply Chain Governance Projects Safety, Health & Environment Finance HR IT Investment Communications

RBPlat Risk: Company Wide Assessment

Risk Reporting Risk Management Risk Identification

Sustainability = Broader

economic, social and

environmental Impact

Finance

Sustainability embedded through Risk + additional

reporting on issues that may not be a risk

Governance

Assurance & Integrated

Report

Stakeholder Engagement: Material issues Impact

Impact Feedback to stakeholders Benchmarking Reporting

Fig 7: Proposed Sustainability Model: embedded through Risk

Operational risks Safety, health & environmental risks Strategic risks Financial risks Legal & regulatory risks Reputational risks Project risks + Sustainability

52

iv. Phase 4: Establishment of a Sustainability Committee

Establishment of a Sustainability Committee at an operational level is essential for the

implementation and co-ordination of sustainability activity throughout the company.

Chaired by the Executive: Risk and Sustainability, this committee reports directly to the

Social and Ethics Committee of the Board through the CEO supported by the Executive:

Risk and Sustainability (Fig. 8 & Table 5). Initially, close co-ordination will be required

between the activities of the Sustainability Committee and Risk Management Committee

to ensure aligned goals and processes. However the merger between the management

committees is recommended to avoid misalignment and duplication of function in the

future.

Sustainability Committee: Composition

To ensure comprehensive and company-wide representation in support of the

sustainability framework, the following portfolios must be represented within the

Sustainability Committee at a senior level.

• Executive: Risk and Sustainability (Chair)

• Head: Sustainability

• Risk & Compliance Specialist

• Safety Health and Environmental Manager

• General Manager: BRPM/ Styldrift

• Company Secretary

• Executive: HR

• Head: Projects

• Corporate Finance Executive

• Investment Relations Manager

Sustainability Management Committee: Terms of Reference

To drive engagement and sustainability, the Committee will take responsibility for the

following:

• Support the review of current policies and strategies for realignment with

sustainability principles.

• Support the establishment and implementation of stakeholder engagement and

sustainability processes.

• Support the integration of sustainability principles and stakeholders’ material issues

into the Company strategy.

• Propose and review implementation plans to ensure the integration of sustainability

principles.

• Support the collection and capture of timely and accurate data.

• Consider reports on the implementation and impact of sustainability principles and

advise on further implementation.

• Support the development of the Integrated Report.

• Communicate and advocate the sustainability principles within the Company’s sphere

of influence.

53

Table 5 details the responsibility, reporting lines and meeting schedules for the Sustainability

Committee and related governance and management structures.

54

CEO: Sustainability

Champion

5: GM: Styldrfit

4: Sustainability Committee (Chair: Risk & Sustainability Exec.)

2: Audit and Risk Committee

1: RBPlat Board

3: Social and Ethics Committee

5: GM: BRPM

5: SHE Manager

5: Corporate Finance

Exec.

5: Head:

Sustainability

Fig 8: Governance and Management of Stakeholder Engagement and

Sustainability

5: Head of Projects

5: HR Exec.

5: Company Secretary

5: Risk &

Compliance Specialist

Risk

Management Committee

5: Investment Relations Manager

55

Table 5: Governance and Management of Sustainability

Refer to

Figure 3

Company structure Responsibility Reporting to: Meeting

schedule

Governance

1 RBPlat Board Accountability for the

Sustainability of RBPlat

All stakeholders 4 per annum

2 Social and Ethics Committee Accountable for Sustainability

and the Integrated Report

Full Board & all

stakeholders

4 per annum

3 Audit and Risk Committee With respect to Sustainability

only: Accountable for

Sustainability risk and assurance

of the Integrated Report

Full Board & all

stakeholders

4 per annum

Management

4 Sustainability Committee To provide direction, support

and monitor the management

and implementation of

sustainability

The CEO

Chaired by the Exec:

Risk & Sustainability

6-8 per annum

5 Divisional Sustainability

Committees and other

specialist focus Committees

e.g. the Environmental Impact

Committee

To address sustainability pillars

and other entity/divisional

strategic and/or functional level

issues.

Sustainability

Committee

6-8 per

annum

56

v. Phase 5: Integration of sustainability: Roles, responsibilities and timeframes

This management portion of the sustainability framework has been developed with the

intention of integrating sustainability into existing generic business processes within the

company, thereby utilizing existing structures and personnel. This approach will reduces

cost, avoid duplication, ease acceptability and ensure integration of the concept into the

company’s core business.

This process will probably be the most challenging of all the realignment processes

primarily because implementation will affect every business unit and therefore the way

in which every individual within the company performs his/her function. Appropriate

leadership, communication, training, support and appropriate incentives are key to

ensuring the success of embedding sustainability principles within the company.

The key management components of the sustainability framework are as follows:

establishment of a quantifiable baseline

integration of the sustainability principles into the corporate strategy

stakeholder engagement

establishments of targets, timelines and indicators

integration of sustainability into operational plans

implementation of training, and communication and awareness programmes

data collection

impact assessment on sustainability pillars

integrated reporting

reporting assurance

public disclosure

Table 6 lists the generic business areas into which sustainability related actions and activities can

be incorporated together with the corresponding requirements; Tables 7 and 8 detail specific

activities associated with these requirements and establishes the roles, responsibilities and

timelines for integrating sustainability within RBPlat. Table 7 focuses on initial steps that need to

be taken to prepare for long term sustainability initiatives, whilst Table 8 reflects a 3 year plan.

Table 6: Sustainability Focus Areas

Generic Business Areas Key Sustainability Requirements

Leadership Understanding of sustainability

Commitment to sustainability

Accountability and responsibility for sustainability

Visibility and communication on sustainability

Allocation of resources

Establishment of rewards and incentives

Engagement of stakeholders

57



Stakeholder

Engagement (refer to

Section 2 for the

engagement

framework for more

detail)

Identification, mapping, categorisation & prioritisation

Inclusivity

Dialogue (frequency, mode, etcetera)

Managing concerns, expectations, perceptions, conflict

Material issues

Responsiveness

Communication

Governance Board oversight and accountability

Leadership

Relevant legislation (local and international) and best practice Principles and Codes

Board and Board committee charters

Vision, mission and values

Company policies (Sustainability policy, Code of Ethics, stakeholder engagement policy,

and other social, environmental and broader economic policies)


Strategy Establishment of leadership responsibility

Establishment of objectives and targets with timelines

Allocation of resources

Integration of Company and stakeholders’ material issues

Impact orientation

Embedded sustainability in core strategy: operations & supply chain

Influencing Company culture

Determination of risks and opportunities


Management (Planning

and implementation)

Establishment of leadership responsibility


Planning at divisional and individual levels

Embedded sustainability ‘thinking’ into core business areas: operations & supply chain

Ensuring cross functional collaboration across all business units

Establishment/review of systems & processes

Establishment /review of methods and tools

Establishing goals, targets, indicators

Obtaining skills through development and training

Establishment of communication and awareness programmes

Establishment of information collection and data integrity measures

Monitoring and evaluation of outcomes and impacts

Impact assessment

Assessment of risks and opportunities

Establishment mitigation or enhancement plans

Benchmarking outcomes and impact (internal & external)

Review of (policy, strategy, planning, implementation)

Establishment of a culture of learning

Impact

Assessments


Assessment of positive or negative impacts through quantitative and qualitative

assessment

Establishment of enhancement or mitigation measures

Assessment against goals, targets, timeframes and indicators

58



Integrated Report Reflecting materiality

Exhibiting integration

Ease of availability of information (Annual reports, website, other media)

Assurance Engagement of stakeholders

Credibility of information and data integrity

Gaps and suggestions for improvement

External certification - 3rd

party independent, impartial assurance

Table 7 overleaf depicts the roles, responsibilities, level of urgency and timeframes for actions

and activities from August 2013 to November 2013. The majority of these actions are ‘once-off’

to establish the foundation for sustainability going forward

Table 8 however depicts on-going roles, responsibilities, level of urgency and timeframes for

actions and activities from January 2014 – December 2016. These actions will be cyclical for the

continued integration, implementation and reporting on sustainability activity within the

company and are subject to annual review.

59

Table 7: Roles, responsibilities and timeframes for 2013

Role Primary

responsibility

In consultation

with:

Custodian Current

level of

urgency

Frequency

of actions

Timeframe

2013

Aug Sept Oct Nov

Getting Started

Consider the sustainability theme,

stakeholder engagement and sustainability

framework

Board CEO

EXCO

Exec. Risk &

Assurance

High Once-off

Approve the sustainability theme,

stakeholder engagement and sustainability

framework

Board CEO

EXCO

Exec. Risk &

Assurance

High Once-off

Establish the Sustainability Committee at

the management level

CEO Board

EXCO

Exec. Risk &

Assurance

High Once-off

Work-shop the Sustainability Committee on

the stakeholder engagement and

sustainability framework

Exec. Risk &

Assurance

Exec. Risk &

Assurance

High Once-off

Work-shop the Risk Management team on

the integration of sustainability into the risk

portfolios

Exec. Risk &

Assurance Exec. Risk &

Assurance

High Once-off

Revise the frameworks based on input from

the Sustainability Committee and Risk

Management portfolio

Exec. Risk &

Assurance Exec. Risk &

Assurance

High Once-off

Engage broader stakeholder groups on the

revised frameworks and finalise accordingly

Exec. Risk &

Assurance

Sustainability

Committee

Relevant

stakeholder

groups

Exec. Risk &

Assurance

High Once-off

60

Table 8: Roles, responsibilities and timeframes for 2014-2016

Role Primary

responsibility

In consultation with: Custodian Current

level of

urgency

Frequency of

actions

Timeframe

2014 2015 2016

1st

2nd

1st

2nd

1st

2nd

Getting started

Develop tools for the

establishment of a

quantitative sustainability

baseline

Exec. Risk &

Assurance

Sustainability

Committee

Exec. Risk &

Assurance

High Once-off

Begin the baseline data

collection process

Exec. Risk &

Assurance

Sustainability

Committee

Exec. Risk &

Assurance

High Once-off

Prioritise and set

sustainability targets

(after stakeholder

engagement process in

consultation with the

outcomes of the Ethics

project)

Exec. Risk &

Assurance

Board

CEO

Sustainability

Committee

Relevant stakeholder

groups

Exec. Risk &

Assurance High Annual

Develop sustainability

communication and

awareness programme

(internal and external)

HR Executive

Exec. Risk &

Assurance

Communication

Executive

High Annual

Implement sustainability

communication and

awareness programme

(internal and external)

HR Executive

Exec. Risk &

Assurance

Communication

Executive

High On-going

61

Table 8: Roles, responsibilities and timeframes for 2014-2016

Role Primary

responsibility


level of

urgency

Frequency of

actions

Timeframe

2014 2015 2016

1st

2nd

1st

2nd

1st

2nd

Develop relevant training

programmes

HR

Exec. Risk &

Assurance

CEO

Sustainability

Committee

Exec. Risk &

Assurance High Annual/as

required

Implement training

programmes

HR

Exec. Risk &

Assurance

CEO

Sustainability

Committee

Exec. Risk &

Assurance High Annual/as

required

Develop an Integrated Report

framework

Exec. Risk &

Assurance

Board

CEO

Sustainability

Committee


groups

Exec. Risk &

Assurance High Once

off/annual

review

Implement the Integrated

Reporting framework

Exec. Risk &

Assurance

Board

CEO

Sustainability

Committee


groups

Exec. Risk &

Assurance High annual

62

Table 8 continued: Roles, responsibilities and timeframes for 2014 - 2016

Role Primary

responsibility

In consultation

with:

Custodian Current

level of

urgency

Frequency

of actions

Timeframe

2014 2015 2016

1st

2nd

1st

2nd

1st

2nd


Review identification of

stakeholders

Sustainability

Committee

Exec. Risk &

Assurance

Board

CEO

Current

stakeholders

Exec. Risk &

Assurance

High Annual

revised

Categorise and prioritise

stakeholders

Sustainability

Committee

Exec. Risk &

Assurance

Board

CEO

Current

stakeholders

Exec. Risk &

Assurance

High Annual

revised

Determine of mode and

frequency of engagement per

stakeholder

Sustainability

Committee

Exec. Risk &

Assurance

CEO Exec. Risk &

Assurance

High Annual

revised

Allocate internal roles and

responsibilities per stakeholder

group

Sustainability

Committee

Exec. Risk &

Assurance

Current

stakeholders

Exec. Risk &

Assurance

High Annual

revised

Train appropriate stakeholder

engagement facilitators

HR

Exec. Risk &

Assurance

CEO

Sustainability

Committee

Exec. Risk &

Assurance

High Annual

revised

63

Table 8 continued: Roles, responsibilities and timeframes for 2014 - 2016

Role Primary

responsibility

In consultation

with:

Custodian Current

level of

urgency

Frequency

of actions

Timeframe

2014 2015 2016

1st

2nd

1st

2nd

1st

2nd

Determine stakeholder material

issues

Stakeholders

facilitators

Sustainability

Committee

Exec. Risk &

Assurance

Stakeholders Exec. Risk &

Assurance

High On-going

Determine Company response to

stakeholder material issues

Board

CEO

Relevant operational

department

Stakeholders

Relevant

operational

department

Exec. Risk &

Assurance

High On-going

Feedback to stakeholders on

impact of interventions to

address material issues

Stakeholders

facilitators

Sustainability

Committee

Exec. Risk &

Assurance

Stakeholders Exec. Risk &

Assurance

High On-going

64

Table 8 continued: Roles, responsibilities and timeframes for 2014-2016

Role

Primary

responsibility


level of

urgency

Frequency of

actions

Timeframe

2014 2015 2016

1st

2nd

1st

2nd

1st

2nd

Governance

Realign Company Profile Board

CEO

EXCO

Exec. Risk &

Assurance ,

Sustainability

Committee,

Appropriate

stakeholders

Company

Secretary

Medium Biennial

Review appropriate charters

(Board and committee

charters) to reflect

accountability for sustainability

Board

Company Secretary

EXCO

Primary stakeholder

groups

Company

Secretary

Medium Biennial

Review the governance

documents

Individual policy

custodians, eg. HR for

labour policies

Exec. Risk &

Assurance , relevant

policy implementers

and stakeholders

that policy impacts

upon

Company

Secretary

Medium Biennial

Establish an internal policy

register inclusive of appropriate

sustainability policies

Company secretary Exec. Risk &

Assurance

Company

Secretary

Low Ongoing

maintenance

Establish corporate goals with

embedded sustainability

Board

CEO

EXCO

Sustainability

Committee,

Appropriate

stakeholders

CEO High Annual

65


Role Primary

responsibility


level of

urgency

Frequency of

actions

Timeframe

2014 2015 2016

1st

2nd

1st

2nd

1st

2nd

Management & Impact Assessment

Determine indicators of

impact

Relevant HoDs

CEO

EXCO member

Relevant stakeholders

GMs High Ongoing

Ensure that appropriate

systems, processes, tools,

skills and other resources

are available

Relevant HoDs Relevant EXCO member GMs High Ongoing

Plan and incorporate

possible risks,

opportunities or exist

strategies where

appropriate

Relevant HoDs Relevant EXCO member

Departmental team GMs High Ongoing

Establish divisional

actions and activities

Relevant HoDs

and individuals


Establish individual

actions and activities

Relevant HoDs

and individuals


Establish and maintain

information collection

and data integrity

measures

Relevant HoDs

and individuals

IT

Departmental team IT, GMs High Ongoing

66


Role Primary

responsibility


level of

urgency

Frequency of

actions

Timeframe

2014 2015 2016

1st

2nd

1st

2nd

1st

2nd

Monitor compliance and

quality of implementation

Internal Audit

External

accreditation

bodies

Relevant HoD Internal Audit High Ongoing

Assess impact through

stakeholder engagement

Relevant HoD Sustainability

Committee,


Relevant EXCO member

GMs High Ongoing

Establish enhancement or

mitigation steps

Relevant HoD CEO

Sustainability

Committee,


Relevant EXCO member

GMs High Ongoing

Assess and address risks

and opportunities

Relevant HoD Sustainability

Committee,


GMs High Ongoing

Review to inform policy,

strategy and planning

processes

Relevant HoD Board

CEO

EXCO

Company Secretary

Sustainability comm

Board

CEO

EXCO

Company

Secretary

High Ongoing

67


Role Primary

responsibility


level of

urgency

Frequency of

actions

Timeframe

2014 2015 2016

1st

2nd

1st

2nd

1st

2nd

Integrated Report

Ensure system for appropriate

information management and

data integrity

IT EXCO Member Exec. Risk &

Assurance

HoDs

IT EXCO

member

High Annual

Consolidate and integrate

information for report writing

Exec. Risk &

Assurance

Sustainability

Committee

Exec. Risk &

Assurance

High Ongoing

Benchmark against internal

performance, corporate best

practice and industry peers

Benchmarking

against internal

performance,

best practice

and industry

peers

Integrate with financial and

governance reporting

Exec. Risk &

Assurance

CEO

CFO

Company Secretary

Sustainability

Committee

Social and

Ethics

Committee of

the Board

High Annual

Approve report Social & Ethics

Committee of the

Board

Exec. Risk &

Assurance

EXCO

CEO

Sustainability

Committee

Social & Ethics

Committee

Social and

Ethics

Committee of

the Board

High Annual

68


Role Primary

responsibility


level of

urgency

Frequency of

actions

Timeframe

2014 2015 2016

1st

2nd

1st

2nd

1st

2nd

Assurance

Assure the credibility of the

data and impacts reported in

the integrated report through

support from internal audit

and external accreditation

bodies with specialized

functions.

Exec. Risk &

Assurance

Exec. Risk &

Assurance

Exec. Risk &

Assurance

High Annual

Ensure 3rd

party, independent

and impartial assurance for an

external service provider for

the integrated report

Exec. Risk &

Assurance

Exec. Risk &

Assurance

Exec. Risk &

Assurance

Risk Committee

of the Board

High Annual

Ensure that impacted

stakeholders are involved in

the assurance process

External Assurer Relevant

stakeholders

Exec. Risk &

Assurance

High Annual

Publically disclose integrated

report and data via the

company website and direct

communication to relevant

stakeholders

Exec. Risk &

Assurance

Investor relations

Company

communications

department

Exec. Risk &

Assurance

High Annual

Ensure that information is

easily accessible and

understandable to impacted

stakeholder groups

Exec. Risk &

Assurance

Investor relations

Company

communications

department

Exec. Risk &

Assurance

High Ongoing

sustainability framework - royal bafokeng nation...3 executive summary the purpose of this document...

Documents