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Full Disclosure 2016

Summary of findings and company response - 2015

AngloGold’s Environmental Policy is described in part as follows:

We are committed to responsible stewardship by monitoring, managing and minimising our impact on the environment.1

AngloGold has its own incident reporting system, based on five levels of incident classification ranging from “minor” to “extreme”. Only incidents falling into the top 3 levels are reported to shareholders or to the public. While the number of environmental incidents reported by the company over the assessment period has declined significantly, it is clear that the discharge and potential for discharge of polluted water into the environment remains an ongoing problem. In addition, AngloGold repeatedly refers, in its shareholder communications, to the major risks faced in relation to inter-mine flooding and associated pumping costs.

The Department of Mineral Resources and the Department of Water and Sanitation are responsible for compliance monitoring and enforcement of environmental and water laws by mining companies. Thus far, unlike the Department of Environmental Affairs, neither department has published any information on its compliance monitoring and enforcement action. Both Departments however, in answers to Parliamentary Questions, insist that many inspections take place, many directives and compliance notices are issued, and many criminal prosecutions are instituted.

AngloGold does not refer to any Department of Mineral Resources or Department of Water and Sanitation compliance inspections and findings in its shareholder reporting. The fact that the Departments charged with regulating the sector do not publicise non-compliance findings or enforcement action means that it is impossible to know whether or not the level of disclosure on environmental non-compliances by mining companies in their annual reports is accurate or complete.

In 2015, AngloGold’s Vice President: Investor Relations provided a comprehensive response to the Full Disclosure 2015 findings. The response clarified and expanded on a number of issues raised by the findings, and invited further engagement with the company. The response also stated that “all AngloGold Ashanti operations are required to be (and are) certified to ISO 14001. Recertification is required to be done at least every three years and is undertaken by an external auditor.”

ISO 14001 (the current version being ISO 14001: 2015) sets out the criteria for an Environmental Management System. An Environmental Management System refers to the management of a company’s environmental programmes in a comprehensive, systematic, planned and documented manner. ISO 14001 does not stipulate any requirements for environmental performance, but rather maps out a framework that companies can follow to set up and maintain an effective Environmental Management System.

Retention of ISO 14001 certification is therefore not an indication that a company is in compliance with environmental laws and permits, nor is it a substitute for reporting environmental non-compliance.