Full Disclosure 2016

Summary of findings and company response

Royal Bafokeng Platinum Limited (‘RBPlat’) states in its Sustainability Policy that:

We are committed to the goal of sustainability in balancing our aspirations for a prosperous mining business with responsibility and accountability for the impact on the natural environment, society (inclusive of the communities within which we conduct our operations) and the broader economy. It is our mission to create stakeholder value from safe PGM extraction and leave a lasting positive legacy for future generations.¹

RBPlat’s annual reports deal with environmental incidents and legal non-compliances in a relatively cursory manner. Each of the company’s 2011, 2012, 2013 and 2014 integrated annual reports state that “there have been no incidents of non-compliance with regulations and voluntary codes concerning our products and we have not received any fines for non-compliance with laws and regulations concerning the provision and use of our products and services”.

RBPlat’s CEO, Mr Steve Phiri, confirmed in his response to Full Disclosure that RBPlat’s reference to “our products” in this statement “should be understood in the context of the entire lifecycle of the products, from our mining operations to the on-selling of the products”, and that this description is “intended to provide stakeholders with the necessary assurance that all incidents that may arise during each stage of the lifecycle of our products are accounted for and reported on”.

RBPlat’s 2014 integrated annual report states that a DMR inspection had uncovered a number of non-compliances at Styldrift 1 and that a section 93 notice had been issued by the DMR. The report nevertheless claims that, in the year under review, there had been “no incidents of non-compliance”.²

In his response, Mr Phiri does not address this discrepancy. Instead, Mr Phiri states that:

This was the first and only time a section 93 notice had been issued to RBPlat which gave RBPlat cause to report on it, despite the actual non-compliances being of a minor nature. The receipt of this notice was taken very seriously by RBPlat, as are all incidents, and immediate action was taken to ensure compliance with the conditions of this notice and to remedy any impacts that may have arisen as a result of the minor non-compliances.

Mr Phiri stated further that:

It is therefore denied that RBPlat’s annual reports deal with incidents in a “relatively cursory manner” or create “misleading impressions”. The fact that RBPlat has reported on the most minor of incidents is not only an indication of the successful level of environmental management engaged to avoid severe and major incidents from occurring, but is also a clear indication that RBPlat has been transparent in its reporting.

Mr Phiri also stated in his response that RBPlat does “not view the issuing of a fine by a relevant authority as the qualification for what constitutes an incident. All findings, whether they are contained in notices issued by authorities or included in audit reports, are regarded and addressed with equal importance”.