Full Disclosure 2016

Summary of findings and company response

Sentula’s 2016 Integrated Report, states that:

As a responsible corporate citizen and in preparation for the changes in environmental legislation, Sentula is focused on monitoring the impact its operations have on the environment. Sentula’s commitment to sound environmental practice requires a continuous review of all environmental procedures and as a result, the Group not only adheres to its own environmental framework but also to the environmental policies, procedures and standards which are in place at its host mines.¹

Other than to reference the widely publicised criminal conviction of Sentula’s subsidiary, Nkomati Anthracite (Pty) Ltd, Sentula makes very little data on environmental non-compliances and incidents available to its shareholders. Nkomati Anthracite (Pty) Ltd received the highest ever penalty handed down in South Africa for criminal breaches of environmental laws.

In addition, while Sentula is a diversified mining company conducting operations through numerous subsidiaries, environmental compliance information is only reported on in a general manner.

In its 2012 Integrated Annual Report, Sentula states:

As part of our commitment to open and transparent engagement with our stakeholders, Sentula took the decision to make copies of all our environmental authorisations and applications available for download on our website. This decision was noted and commended in the Centre for Environmental Rights 2011 publication document on access to information entitled Unlock the Doors: How greater transparency by public and private bodies can improve the realisation of environmental rights.²

As at November 2016, we have been unable to locate any environmental authorisations or applications on Sentula’s website.

In his response to Full Disclosure, Sentula’s CEO, Mr Jacques Badenhorst, failed to respond to any of the CER’s concerns. Mr Badenhorst replied, by way of a “with prejudice” letter, to acknowledge receipt of the CER’s correspondence, note the contents of our assessment, and state that:

We comply with all statutory and legal environmental law requirements and hereby reserve our rights on any results and findings on our company published by the Centre for Environmental Rights.