Full Disclosure

Atlatsa Resources Corporation (Atlatsa) provides detailed disclosures in relation to its financial provision for environmental rehabilitation in its annual information form.¹

The information which is publicly available for Atlatsa is as follows:

1. The estimated figures for environmental rehabilitation obligations, and the funds and guarantees available to meet those obligations.
2. Detailed explanation of how the environmental rehabilitation costs have been calculated.
3. Detailed explanation of issues pertaining to environmental rehabilitation at operational level.
4. The basic assumptions used in the calculation of the environmental rehabilitation provision, and the accounting treatment of the rehabilitation obligations.
5. That financial guarantees and the Bokoni Environmental Trust Fund are the financial vehicles used to provide for future rehabilitation obligations.
6. One consolidated figure for financial provision for environmental rehabilitation in the annual information form.

Atlatsa discloses significantly more information, and more useful information, than its peers. The disclosures include:

• An overview of the law applicable to financial provision for environmental rehabilitation;
• A narrative explanation of the estimated costs of rehabilitation;
• A narrative explanation of how the contributions to the financial instruments are used to secure the provision for rehabilitation; and
• An operation-specific description of the most significant environmental risks (dust and water pollution) identified and the remedial steps taken to address these risks.

While this disclosure could be more detailed, it is much more in line with our recommendations and provides clear, understandable information about the type and extent of environmental damage caused by Atlatsa’s mining operations. Further information should be provided in relation to:

• the methods and experts used to calculate the estimated liabilities;
• sufficient information to enable external verification that the estimated liabilities have been accurately calculated;
• clear, understandable explanations for why the estimates and funds set aside for financial provision for environmental rehabilitation fluctuate from year to year; and
• information about the way in which the funds set aside for rehabilitation are managed and protected.

Atlatsa did not respond to the CER’s letter requesting further information and clarity.