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Full Disclosure 2016

Summary of findings and company response - 2015

Tongaat Hulett describes its “environmental approach” as follows:

The company’s environmental approach is premised on the concept of building value for all stakeholders while working in harmony with nature. It works towards achieving integration between the environment and its agri-processing and property development operations.1

Compared to many other companies assessed in Full Disclosure, Tongaat Hulett provides a significant level of detail about environmental non-compliances in its company reporting.

In his reply to Full Disclosure 2015, Nico Kruger (Executive: Strategic Themes) gives an almost line-by-line response to the findings of the assessment, providing useful additional information and clarity on a number of findings.

The company provides the number of public complaints it receives, regardless of the seriousness of those complaints. In our letter to Tongaat Hulett, we asked the following:

While the company states that Level 1 complaints are deemed “minor”, the only example of a Level 1 complaint provided – that of illegal dumping at the South African agricultural operations – appears to be potentially serious, especially given the number of Level 1 complaints received. Do the complaints of illegal dumping refer to dumping by Tongaat Hulett employees? If so, what steps are being taken to resolve this problem? Why was the level of Level 1 complaints during the 2013 reporting period so high? Please provide some other examples of Level 1 complaints.

Mr Kruger explained as follows:

According to our environmental incident management system, illegal dumping matters are classified as Level 1 incidents (as opposed to Level 1 complaints). They usually involve illegal dumping activities undertaken by unknown people from the general public. While these were captured and reported correctly in our internal database, there was an error in the 2013 Annual Report that resulted in them being reported as complaints instead of incidents. This is the same reason why Level 1 complaints appear to have been quite high. Actually, during the reporting period (2012/3), Tongaat Hulett experienced 22 Level 1 complaints and 2 Level 2 complaints. … We have observed that the same error recurred in the 2015 annual report where we incorrectly reported “a total of 582 complaints (581 level [one] and one level 2)”, instead of reporting a total of 111 complaints (111 level 1 and no level 2). It was actually a total of 582 environmental incidents (581 – Level 1 and 1 – Level 2) that were recorded during the year. … We appreciate this engagement as it has brought to our attention an area that needs to be corrected going forward.

Tongaat Hulett also asked the CER to “critically analyse” the company’s 2015 Integrated Report, stating that each year the company requests 20 key stakeholders to do so, using the feedback from this analysis to improve future reports.