SUSTAINABILITY Management approaches

Management approaches

Golden Mine Projects has significant management methodologies, policies, strategies, and standards linked with the GRI materiality evaluation for its main sustainable development disciplines and other material matters.

For the management strategy on Golden Mine Projects' prioritised material challenges and connected GRI subject specific standards, click on the relevant heading.

Direct and Indirect Economic Impacts

The sustainable economic performance of Golden Mine Projects holds paramount importance in the Company's value generation. Our fiscal and operational accomplishments predominantly shape the Company's profitability, which stands as a fundamental factor for its prospective expansion and long-standing viability. Equally, it plays a pivotal role in distributing the benefits of mining with key stakeholders, encompassing our employees, business collaborators, host communities, governments, and capital providers.

An indispensable ally and stakeholder in this journey are the communities that accommodate our operations. Without their backing, the management of mines becomes significantly more challenging. In fact, communities have the capacity to halt operations, particularly in many developing nations, if they perceive inequitable wealth distribution or if mining adversely affects their livelihoods or environments.

Hence, creating value within the community becomes a pivotal aspect of both our direct and indirect economic influence. Directly, this involves employing community members in our workforce, sourcing from local community enterprises, and investing in community initiatives that span skill development, education, health, and infrastructure enhancement. Indirectly, community employees, contractors, and enterprises contribute to economic prosperity, skill augmentation, and additional employment opportunities within these communities.

Economic performance

The cornerstone elements of the Golden Mine Projects strategy play a crucial role in attaining our economic accomplishments:

  • Unleashing the full potential of existing assets through human resources and innovation
  • Expanding upon our preeminent dedication to Environmental, Social, and Governance (ESG) considerations
  • Enhancing the worth and excellence of our collection of assets

These details are extensively covered in the Integrated Annual Report (IAR). The supreme level of responsibility concerning economic performance is held by the Board of Directors, which endorses the Company's strategic trajectory for economic accomplishments. The strategy is devised by the executive leadership team, executed by the regional offices, and the different operations.

The operational and financial achievements of the Company are shared with shareholders and other stakeholders every quarter through presentations on quarterly results. Yearly, the IAR offers an overview of every facet of Golden Mine Projects' economic performance. The Board – representing shareholders – assesses the management's economic performance.

STAKEHOLDER VALUE CREATION

We foster mutually advantageous connections with our stakeholders to enhance our reputation, secure our social authorization to operate, and provide lasting value in our operational regions.

We understand the significance of robust community interactions in maintaining our social permission to operate. We are dedicated to averting, lessening, mitigating, and rectifying any unfavorable effects our operations might have on host communities and other stakeholders. Concurrently, we aim to bring about enduring social and economic well-being. Through substantial engagement founded on mutual esteem and confidence, constant enhancement of our social performance, and our pledge to generate and share value, we endeavor to yield enduring value that transcends mining.

Guiding our Strategy for Community Relations

Golden Mine Projects' strategy for promoting positive community value and fostering community relations incorporates the following:

  • Acquiring an informed comprehension of our operating environments, stakeholder priorities, and connected risks by means of initial assessments, impact evaluations, and stakeholder involvement
  • Proactive management of environmental and socio-economic impacts and risks tied to our operations through the application of management strategies and plans
  • Nurturing connections with our stakeholders through transparent, open, and constructive interactions
  • Meaningful social investments to address key necessities of host communities, encompassing areas like infrastructure expansion, economic variation, education and skill advancement, health and well-being, and environment and conservation
  • Structured partnerships with governmental bodies (national, regional, and local), non-governmental organizations (NGOs), benefactors, and other stakeholders
  • Creating mutual value through community-based procurement, local employment, and public infrastructure development

All of our activities and projects, in accordance with Golden Mine Projects guidelines, conduct environmental and social impact assessments and management plans as needed. Ongoing, planned community engagements, formal grievance management, social risk assessments, and socioeconomic development and shared value activities are all consistent practises across all of our sites.

Our approach to community relations and stakeholder involvement is directed and informed by country-specific rules and guidelines, external standards, guides, and codes we have embraced, internal policies and guidelines and pledges, and industrial forums in which we participate.

External documents

  • AA1000 Standard for Engaging Stakeholders
  • ICMM Principles for Mining
  • ICMM Position Statement on Partnerships for Development
  • ICMM Framework for Reporting Social and Economic Performance
  • ICMM Tools for Enhancing Social Performance
  • ICMM Approaches to Addressing and Resolving Local-level Concerns and Grievances
  • UN Global Compact Initiative
  • Universal Declaration of Human Rights
  • United Nations Principles on Business and Human Rights
  • Extractive Industry Transparency Initiative
  • World Gold Council Responsible Principles for Gold Mining
  • World Gold Council Standard for Ethical Gold Sourcing
  • Global Reporting Initiative
  • IFC Standards for Performance

Industrial forums and working groups

  • International Council on Mining and Metals
  • Minerals Council of South Africa
  • Business Leadership South Africa
  • Ghana Chamber of Mines
  • Chamber of Minerals and Energy in Western Australia
  • Gold Industry Group in Western Australia
  • National Society of Mining, Petroleum, and Energy (SNMPE) in Peru
  • Council of Mining in Chile
  • National Society of Mining in Chile
  • Working Group for Host Community Procurement and Job Creation at Golden Mine Projects
  • Working Group for Stakeholder and Community Relations at Golden Mine Projects

Internal guidelines, policies and documents

  • Corporate Policy for Sustainable Development
  • Corporate Policy for Stakeholder Relations and Engagement
  • Corporate Policy for Community Relations
  • Corporate Policy for Human Rights
  • Corporate Policy for Materials and Supply Chain Responsibility
  • Guideline for Engaging Communities and Stakeholders
  • Handbook for Community Relations and Stakeholder Engagement
  • Guideline for Procurement and Job Creation in Host Communities
  • Guide for Measuring Social Impact and Investment Returns
OUR SOCIETY AND COMMUNITY CHARTER - OUR COMMITMENTS TO OUR COMMUNITIES AND GOVERNMENTS

Our charter commits us to:

  • Foster robust connections with crucial stakeholders, founded on trust and transparent, candid, and frequent interaction
  • Collaboratively generate and provide lasting benefits to our host communities and governments, aligned with our ESG Priorities and 2030 objectives
  • Monitor and evaluate our performance against our pledges to establish enduring value, nurture relationships, foster trust, and diminish our environmental impact
  • Work towards achieving a deeper comprehension of the fundamental concerns and aspirations of our host communities, the challenges tied to our operations, and to jointly conceive and fulfill the suitable commitments to secure and maintain our social permission to operate.

Each area is executing Government and Community Action Plans that are consistent with Group direction, ensuring that these commitments are met.

Shared Value

Shared Value is created when businesses adopt a proactive approach to solving both business and social requirements. Shared Value is about identifying new opportunities for economic success by incorporating social priorities into business strategy and working collaboratively with multiple stakeholders to find solutions to various socioeconomic and environmental issues. A critical component of this approach is ensuring that the value created is shared by both the business and the community.

Our Shared Value approach is based on four key pillars:

1 Strategic interventions, to proactively address socio-economic challenges   2 Integration to proactively address socio-economic challenges   3 Participation in collaborative action with other stakeholders   4 Transparency regarding Golden Mine Projects’ economic contributions to its host societies in line with World Gold Council guidelines

In our regions, we now have various Shared Value projects, including our Host Community Procurement and Job Creation programmes, which aim to increase the proportion of sustainable host community procurement and jobs. Each area is putting strategies in place that are in line with Group direction, including targets for host community procurement and employment.

HOW WE CREATE VALUE FOR OUR COMMUNITIES
PROCUREMENT
Host community procurement creates community jobs and supply opportunities
  • Support areas where community suppliers can participate
  • Identify community suppliers capable of supplying the mine
  • Provide skill development to bridge capability gaps

 

EMPLOYMENT
Host community employment maximises local opportunities
  • Develop the skills of the local workforce through education, scholarships, and similar initiatives
  • Give preference to the community when recruiting staff
  • Promote the engagement of community members by contractors and suppliers in their workforce
  • Establish jobs unrelated to mining, connected with our Social and Economic Development (SED) investment ventures or in collaboration with suppliers
SOCIAL
INVESTMENT

Adept community relations teams are established across all our operational Regions. These teams collaborate with various business functions as well as our trusts and foundations to bring about meaningful community influence, often in partnership with governments, NGOs, donors, and industry peers. Investments are financed through allocated operational budgets.

Since 2017, we have introduced ESG targets to incentivize our management teams, encompassing host community value enhancement. This approach has gained further traction with the introduction of our 2030 ESG targets, which are tied to performance scorecards for both Group and regional management teams.

Our regions periodically conduct independent evaluations to gauge the potency of our associations with host communities, the social benefits arising from our community projects, and the shared value we generate.

Our achievements are documented in our Integrated Annual Report, Stakeholder Report, and in our comprehensive and interim results publications, all of which are publicly accessible.

Community Engagement

Golden Mine Projects has a Social Performance Framework in place that requires our operations to assess the baseline social context, interact and establish relationships, create and share value, monitor impacts, measure delivery, and enhance action to ensure delivery is in accordance with promises. On a regular basis, we actively identify, map, and engage with stakeholder representatives, including host communities and governments, both formally and informally.

Our engagement is governed and influenced by the external standards, rules, and codes we have adopted, as well as our internal policies, guidelines, and commitments, as well as the industrial forums in which we participate:

External documents

  • AA1000 Standard for Engaging Stakeholders
  • Extractive Industry Transparency Initiative
  • ICMM Principles for Mining
  • ICMM Position Statement on Partnerships for Development
  • IFC Standards for Performance
  • Global Reporting Initiative
  • World Gold Council
  • UN Global Compact
  • Universal Declaration of Human Rights
  • Guiding Principles on Business and Human Rights by the United Nations

Internal guidelines, policies and documents

  • Corporate Policy for Sustainable Development
  • Corporate Policy for Stakeholder Relations and Engagement
  • Corporate Policy for Community Engagement
  • Corporate Policy for Human Rights
  • Corporate Policy for Materials and Supply Chain Responsibility
  • Guideline for Engaging with Communities and Stakeholders
  • Handbook for Community and Stakeholder Engagement

Industrial forums and working groups

  • International Council on Mining and Metals
  • Minerals Council of South Africa
  • Business Leadership South Africa
  • Ghana Chamber of Mines
  • Chamber of Minerals and Energy in Western Australia
  • Gold Industry Group in Western Australia
  • National Society of Mining, Petroleum, and Energy (SNMPE) in Peru
  • Council of Mining in Chile
  • National Society of Mining in Chile
  • Working Group for Stakeholder and Community Relations at Golden Mine Projects

Each of our operations is obligated to develop stakeholder engagement plans that respect local cultures, applicable for all phases of the mine's lifecycle.

All mines and projects have established channels allowing communities to express concerns and grievances concerning the company. These issues are evaluated and resolved within a defined timeframe.

Our Regions periodically conduct impartial evaluations to assess the quality of our relationships with host communities.

Information regarding our community engagement patterns and priorities is presented in our publicly accessible Integrated Annual Report and Stakeholder Report.

Safety and Health

Our Occupational Health and Safety Policy Statement was revised in 2021, and our Group Safety Strategy was updated and endorsed by the Board in 2019. Golden Mine Projects is committed to achieving zero harm within our workforce. Our core value is: "If safety is compromised, we will not proceed." Our objective is to eliminate the potential for workplace incidents, injuries, and health concerns, while also striving to minimize hazards within the work environment.

We uphold several fundamental principles in our safety management approach:

  • Leadership bears responsibility and accountability for health and safety performance
  • Upholding our values is integral to our safety and health performance
  • Ensuring the safety and well-being of all employees every day is paramount
  • Prevention prevails over cure, making risk management a cornerstone of all systems
  • All injuries and incidents are avoidable, relying on strong leadership, practical systems, and positive employee conduct
  • Safety management must be seamlessly integrated across all operations
  • Empowering the right to decline unsafe actions

Aligned with these principles, our safety approach revolves around the following core philosophies:

  • Safety performance is a fundamental aspect of performance evaluation and talent development, monitored through relevant indicators
  • Achieving the required performance is both systematic and requires cultivating leadership and a culture conducive to performance
  • Risk assessment and effective control deployment are critical in eliminating incidents, necessitating these skills throughout the workforce
  • Applying the hierarchy of controls is particularly pertinent to our operations, laying the groundwork for a hazard-free work environment
  • Eliminating incidents is a continual learning process that propels the improvement of systems, practices, and procedures
  • Encouraging employees to report injuries, incidents, and hazards supports the ongoing improvement process
  • Paying absolute attention to verifying and maintaining critical controls
  • No conflict exists between safety and production; our workforce should be empowered to "Pause, Reflect, Rectify, Verify, and Resume."

Our overarching strategic objective revolves around eradicating significant undesired events, fatalities, severe potential incidents, health risks, and injuries and illnesses with life-altering consequences. Once these have been eliminated, our focus remains on sustaining these outcomes.

In addition, we allocate the appropriate resources to the secondary priority of continuously enhancing the elimination of less significant injuries (restricted work, medically treated, and minor injuries) at our operations. To achieve this goal, the core strategic objectives are as follows:

  • Foster a safety leadership culture throughout the organization, embedding safety management as a responsibility of line management
  • Establish effective means to engage the workforce in safety and health, equipping them with necessary skills for consistent safe outcomes
  • Ensure the implementation of fit-for-purpose management systems aligned with a critical control management approach and certified to ISO 45001 standards.

Actions supporting these strategic objectives are categorized into safety leadership, safe behavior, and safety systems.

Golden Mine Projects' zero harm Safety Strategy centers on three comprehensive, interrelated programs:

  • Courageous Safety Leadership (CSL), which motivates employees to exhibit leadership qualities
  • The Vital Behaviors program aimed at influencing employees to make responsible choices
  • The Critical Control Management (CCM) approach embedded in our safety systems

The Courageous Safety Leadership (CSL) program equips our employees with practical tools to develop into safety leaders, while also fostering an environment where individuals feel empowered to raise concerns about unsafe behaviors. Positive changes in our leading indicators signal potential improvement. Despite ongoing Covid-19 restrictions, over 5,800 employees underwent CSL training in 2021, surpassing our target of 4,500 – with a cumulative total of over 16,000 trained to date.

The Vital Behaviors program, initially introduced in Australia and expanding to other regions, is a grassroots behavioral initiative that enhances health and safety outcomes while promoting safe production. This program empowers workers to identify and resolve workplace health and safety concerns and hazards, supported by management commitment. It includes "Opinion Leaders" who advocate for workers and actively influence the adoption and application of Vital Behaviors.

CCM, a fundamental tool employed by Golden Mine Projects, is instrumental in preventing incidents that pose severe risks to our personnel. Our approach adheres to the guidelines outlined by the ICMM. We've gained insights from our industry peers in the ICMM and contributed to their efforts. CCM provides a practical method to enhance managerial control over rare yet potentially catastrophic incidents, referred to as Material Unwanted Events (MUEs), by focusing on critical controls. The process begins with identifying controls for each MUE, particularly those that can avert the event or mitigate its impact. The absence or failure of a critical control significantly heightens the risk of an MUE occurrence, even when other controls are in place. We offer external assurance over the critical controls relevant to specific MUEs.

All managed sites within Golden Mine Projects are certified to ISO 45001 for their occupational health and safety management systems. The certified system comprises the following elements:

  • Each site maintains a legal register, subject to annual reviews for completeness and compliance
  • Hazard and incident management processes are established. Incident management software records investigations and tracks corrective actions, including system improvements to prevent recurrence
  • Training records are maintained
  • Incidents and near misses are discussed by site and regional leadership teams, shared across the group

Every site offers workers access to medical and health services, including:

  • Health monitoring for higher-risk job roles, encompassing diesel particulate matter (DPM), respirable silica dust, noise, and radon gas
  • Wellness support, such as HIV counseling and testing as appropriate
  • Confidential medical records are maintained for workers' compensation purposes

Sites communicate with their workforce about occupational health and safety through various means:

  • Pre-shift meetings, toolbox (safety) meetings, health and safety committee meetings, incident investigations, risk assessments, and audits
  • Health and safety representatives and committees comprising both management and the workforce

All sites offer occupational health and safety training based on a training needs assessment, provided during work hours. This includes:

  • General and site-specific inductions, training for hazard identification and risk assessment, incident reporting, and investigation
  • Job-related skills training for specific job procedures and production processes
  • Training for critical hazard (high-risk) activities such as confined space work, isolation, and working at heights
  • Training for licenses and authorizations, e.g. isolation officer, electrician, crane operator
  • Training for statutory positions, e.g. registered manager, health and safety representative, explosives handler

Business partners operating on Golden Mine Projects sites are required to demonstrate adherence to Golden Mine Projects' policies and standards. The health and safety systems of major service suppliers undergo evaluation during the tendering process to ensure alignment with Golden Mine Projects' health and safety requirements and principles. These systems are also subjected to audits.

Regional Environmental, Health, and Safety (EHS) scorecards have been established to enhance operational performance. These scorecards encompass leading and lagging key performance indicators (KPIs) at the group-wide and regional levels.

Government & Public Policy-related Interaction

The Group Code of Conduct (referred to as the Code) applies to all Company directors, employees, and external parties. It clearly outlines Golden Mine Projects' stance on various matters, including the strict prohibition of facilitation payments and political contributions. The Code also includes rigorous provisions regarding the disclosure of actual, potential, or perceived conflicts of interest. It also covers reporting procedures for addressing risks, types and extent of permissible donations and sponsorships, and guidelines concerning gifts, hospitality, and entertainment. Furthermore, the Code acknowledges the Group's engagement with external stakeholders.

Key stakeholder groups, such as government entities, regulators, and other authorities, frequently engage with Golden Mine Projects. These interactions occur either indirectly through Chambers of Mines or directly with government departments in different operational regions or during regulatory reviews/inspections on-site. The focus of these interactions includes participating in policy development, navigating regulatory changes, addressing licensing and reporting requirements, and fostering proactive partnerships between the Group and the Government.

Thus, the Code mandates the documentation of all interactions in an External Interaction and Commitment Register. This register's structure allows the regional legal team to evaluate and analyze data to align with the intended approach. Apart from the Code's interaction guidelines, specific business rules have been formulated. Starting from late 2018, the requirement to record interactions with defined external stakeholder groups has been implemented.

APPROACH PURPOSE
  • Developing a comprehensive perspective of all engagements within the Group's operational reach to proactively address any real, potential, or perceived risks related to anti-bribery and corruption (ABC), reputation, and associations.
  • Ensuring that authorized employees are exclusively responsible for engaging with government entities, public officials, and other specified external stakeholders.
  • Implementing a systematic approach to engagement when dealing with industry-related matters.
MECHANISMS

Training

An eLearning programme to measure employees' grasp of the Code in terms of government engagement.

Solutions

  • Quarterly analysis of metadata is carried out to identify patterns and improve the understanding and practical usefulness of the Code's stipulations.
  • A data analysis tool empowers management and internal stakeholders to dissect identified patterns and amplify the understanding and practical impact of the Code of Conduct's external engagement requirements. The results of this analysis are presented to the Audit Committee every quarter.
  • Structured assessments by Internal Audit
  • A dedicated Gateway has been planned, designed, and implemented to serve as a hub of expertise for employees to delve deeper into the requirements and their real-world applications.

Reporting

  • Executive Vice Presidents are kept up to date on the results of the trend analysis exercise by country, as well as issues raised by the Group Compliance Office, via a monthly Compliance Update. On a quarterly basis, the Group Audit Committee receives an aggregate overview.

Cryptic Results

  • 2 727 external engagements were registered in 2021. 1 077 interactions with the government and affiliated agencies. The majority of engagements (43%), followed by interactions with host governments (16%), territory governments (25%), and regulators (16%). The three main interaction topics are regulator reviews/authorization, coordination, partnership and sharing, and community relations. 57% of encounters occurred remotely under the COVID-19 movement restrictions.

Environmental Compliance/ Mine Closure Management/ Waste and Effluents

Environment

Golden Mine Projects is dedicated to responsible management of natural resources and the environment for current and future generations. Our aim is to employ innovative methods that minimize or counteract adverse environmental and socio-economic effects while maximizing positive impacts.

Our approach to environmental stewardship is influenced by the precautionary principle and influenced by external standards, local regulations, and internal policies. We identify additional local priorities through consultation with stakeholders. Our internationally recognized and externally certified environmental management systems (EMSs) are established, implemented, integrated, and upheld. These systems incorporate environmental considerations into business strategies, provide a framework for defining environmental goals, ensure continuous enhancement of the environmental management system and environmental performance, and prevent pollution. All of our Group's operations, including the new Gruyere operation, which commenced production in 2019, are ISO 14001(2015) certified. Our eligible operations are fully compliant with the International Cyanide Management Code. Golden Mine Projects abstains from using mercury in gold beneficiation or any other processes.

External initiatives     Internal guidelines, policies and documents     Industrial forums and working groups

Regulatory requirements, and obligations relating to industry rules, codes and standards to which we subscribe, that relate to our environmental aspects and impacts including:

  • Domestic laws and regulations
  • ISO 14001(2015) standard for environmental management
  • The 10 Principles and 8 Position Statements of the International Council on Mining and Metals (ICMM)
  • The United Nations Global Compact
  • International Cyanide Management Code
  • CDP: Project for Disclosure of Water-related Information
   
  • Company Policy for Sustainable Development
  • Company Environmental Policy (revised in January 2021)
  • Statement on Group Climate Change Policy
  • Committee Addressing Financial Impacts of Climate Change (TCFD)
  • Company Guideline for Biodiversity Management
  • Guideline for Classification and Reporting of Environmental Incidents
   
  • ICMM Biodiversity Working Group
  • Golden Mine Projects Environment Working Group

Internally, Golden Mine Projects has put in place policy statements and five guidelines at the Group level, reflecting our environmental priorities. These cover areas like energy and carbon management, water management, tailings management, biodiversity, and integrated mine closure. An overview of these guidelines can be accessed here. These guidelines outline the necessary systems and processes for consistent environmental management practices across the Group, allowing adaptation to local conditions as needed.

Responsibility for implementing our Group Environment Policy Statement and related guidelines falls to the General Manager or VP Operations overseeing the site, with support from the Sustainable Development team.

Golden Mine Projects keeps track of regulatory changes to respond externally to regulators and internally to ensure control environments are adjusted. This also considers existing controls for effective management.

We evaluate performance through internal assessment methods, including audits of the environmental management system that identify and implement improvement opportunities. We also conduct internal audit reviews of key environmental management aspects such as waste management. Our non-financial disclosures are independently verified annually.

Performance outcomes are disclosed through avenues such as TCFD, the CDP: Water report, and ESG assessments like DJSI. These assessments and outcomes are publicly available.

For all new projects, sustainability factors are considered in Environmental and Social Impact Assessments (ESIAs). Following EIA approval, Environmental Management Programmes (EMPs) are created to outline how the project will adhere to environmental authorization conditions. Investment project standards for Concept, PreFeasibility, and Feasibility Studies have been developed, incorporating sustainability requirements across various aspects.

Golden Mine Projects strongly supports biodiversity and protected areas, aligning with the ICMM Position Statement for Mining and Protected Areas. Our commitment is detailed in the Environmental Policy and reinforced by the Mine Closure Guideline and Biodiversity Guideline.

Environmental Incidents

Environmental incidents at Golden Mine Projects are classified on a scale of 1 (least severe) to 5 (most severe). Incidents rated as Level 3 and above are reported externally through our Integrated Annual Report.

Eliminating Level 3 – 5 incidents remains a significant environmental goal as stated in our Group Environmental Policy Statement. Our mines have made notable progress in this area with an increased focus on environmental management, better integration into operational practices, and community engagement. Achieving zero Level 3 – 5 incidents fosters improved relationships with nearby communities.

Level Description Impact
Levels 1 and 2 Minor incidents or non-conformances Negligible or short-term limited impact.
Level 3 Limited non-conformance or non-compliance Ongoing but limited environmental impact.
Level 4 and 5 Major non-conformances or non-compliances Long-term environmental harm, with operation-threatening implications

Our Group Sustainable Development Manager is the Group lead for environmental stewardship, with environmental managers and teams in place in all areas and operations to support this purpose.

BIODIVERSITY

Our 2019 Group Biodiversity Guideline ensures that we address potentially negative impacts on biodiversity on our mine properties by implementing mitigation measures and integrated land management practises. Our guidelines apply to all Golden Mine Projects that are managed in terms of exploration and operations. This comprises all aspects of the mining life cycle, as well as land and land touched by Golden Mine Projects' activities.

We commit to contribute to the conservation of biodiversity, and specifically:

  • Avoid mining or exploration activities within World Heritage sites; ensure mine design and operation do not harm the biodiversity of protected areas.
  • Evaluate and tackle risks and effects on biodiversity and ecosystem services by following the mitigation hierarchy.
  • Strive to maintain the overall biodiversity level by offsetting any losses through mitigation measures for new projects or significant expansions on existing sites.

As ICMM members, we are committed to adhering to the ICMM's ten principles and accompanying Performance Expectations. The ICMM's Principle 7 requires members to contribute to biodiversity protection and integrated land-use planning.

Our Golden Mine Projects Biodiversity Guideline has the following management principles:

  • Minimize negative impacts and enhance positive effects of the Company's actions on biodiversity.
  • Implement an ecosystem approach that integrates land, water, and living resources for conservation and sustainable use.
  • Follow the mitigation hierarchy to manage biodiversity risks during all stages of the mine lifecycle—avoid, minimize, restore, and offset impacts.
  • Strive for no net loss of significant biodiversity in new projects and major expansions, especially if biodiversity poses risks or opportunities.
  • Employ a precautionary approach in biodiversity management: take action in uncertainty, shift burden of proof to activity proponents, explore alternatives, and involve stakeholders in decisions.
  • Engage stakeholders to enhance scientific determination of biodiversity values and inform biodiversity management, particularly in relation to site closure objectives.
  • Participate in biodiversity partnerships to enhance understanding, accountability, and address management challenges over the mine's life.
  • Establish objectives and targets for biodiversity that create self-sustaining ecosystems viable post-closure without ongoing intervention.
  • Coordinate climate change mitigation and adaptation with biodiversity measures for enhanced effectiveness, considering climate change impacts on biodiversity management.

Our Group Biodiversity Guideline applies to all managed exploration and operations within Golden Mine Projects. This encompasses lands affected by our activities and covers all phases of the mining life cycle. Our commitment to no net loss of biodiversity extends across the company, including new Projects and major expansions. Our dedication to biodiversity preservation and enhancement, outlined in the Group Policy Statement: Environment, is binding for all employees, third parties, and those representing Golden Mine Projects.

The responsibility for implementing our Group Biodiversity Guideline lies with the General Manager and/or VP Operations overseeing the site, with support from the Sustainable Development team. Throughout the 2021 reporting period, no significant measurable direct impacts on biodiversity were detected due to our operational activities. This can be attributed to the mitigation hierarchy and other environmental management measures. We continue to report on our efforts to protect the short-tailed chinchilla and its habitat at our Salares Norte Project and during mine construction.

Waste and Effluents

We take a proactive approach in managing water and waste across all eight of our operated sites, aiming to reduce potential environmental and socio-economic effects while capitalizing on potential opportunities.

We are dedicated to the responsible utilization of resources, the proper handling of waste streams, efficient water management, and the application of robust and transparent water governance. Our goal is to achieve sustainable and responsible water usage through collaborative efforts.

The significant waste materials resulting from our operations include tailings, waste rock, chemical waste, and hydrocarbon waste. By meticulously managing the waste produced by our operations and the associated Tailings Storage Facilities (TSFs), we minimize potential environmental and social impacts.

We adhere to a waste management hierarchy to guide our waste handling practices, with the primary goal of preventing or minimizing waste generation. In cases where waste is produced, our focus is on reusing, recycling, or treating the waste before considering disposal.

Golden Mine Projects does not engage in the import, export, or transportation of waste categorized as hazardous according to the specifications outlined in Annex I, II, III, and VIII of the Basel Convention.

Integrated Mine Closure and Rehabilitation

One of Golden Mine Projects' five core sustainability emphasis areas is sustainable and integrated mine closure. We are able to achieve this through meticulous mine closure planning and ongoing rehabilitation.

  • Reduce our environmental impact
  • Reduce social and community impact
  • Optimise financial liabilities
  • Build credibility with our stakeholders
  • Enhance our asset’s value

OOur mine closure is guided and informed by the external standards, rules, and codes we have embraced, as well as our internal policies, guidelines, and commitments, as well as the industrial forums in which we participate.

External initiatives     Internal guidelines, policies and documents     Industrial forums and working groups
  • ICMM: Comprehensive Approaches to Mine Closure and Land Restoration
  • ICMM Integrated Mine Closure: Guide to Effective Practices
  • Applicable local laws and regulations
  • ISO 14001(2015): Environmental Management Standard
  • International Cyanide Management Code Compliance

Our closure liability estimates are managed in accordance with:

  • International Finance Reporting Standards (IFRS)
  • International Audit Standards (IAS) 37
  • Sarbanes Oxley Act of 2002 (SOX)
   
  • Guideline for Comprehensive Mine Closure Planning
  • Framework for Group Closure Cost Estimation and Guidance
  • Corporate Sustainable Development Policy
  • Company Environmental Policy
  • Statement on Company's Approach to Climate Change
  • Policy Statement on Water Stewardship
  • Guideline for Managing Water Resources
  • Use of the Nevada Standardized Reclamation Cost Estimator Tool
   
  • ICMM Mine Closure Working Group
  • Golden Mine Projects Integrated Mine Closure Steering Committee
  • Golden Mine Projects Integrated Mine Closure Working Group.

All operations under Golden Mine Projects possess regularly updated Mine Closure Plans, aided by independent experts for updates. A vital aspect of these plans is Stakeholder Engagement.

Each operation has also determined its closure obligations, considering disturbance or liabilities up to the current date, in accordance with international financial reporting standards. These obligations undergo yearly review and revision, and are subject to independent assessment. Our closure obligations are publicly disclosed by Golden Mine Projects, with explanations for significant changes provided annually. We employ the Nevada Standardised Reclamation Cost Estimator (SRCE) tool for estimating closure obligations across all operations.

Our Mine Closure Plans and Closure Obligation estimates align with the Group Mine Closure Management Guideline and Group Closure Cost Estimate Guidance. As we strive to integrate mine closure planning into our business and optimize obligations through gradual closure and rehabilitation, we have established targets via our Regional scorecards, evaluated at least annually. The Group's Sustainable Development Manager oversees mine closure responsibility, while environmental and mine closure leads are designated within each region and operation.

Employment

This includes Golden Mine Projects' strategy to employment or job creation, such as recruitment, onboarding, development, and retention, as well as our working conditions and related practises. Golden Mine Projects adheres to the International Labour Organization's principles.

Approach details

Our approach to employment considers, but is not limited to:

  • Recruitment of new staff and staff attrition
  • Orientation of new staff members
  • Enhancing employee skills and leadership abilities
  • Effective handling of full-time employee talent
  • Offered perks for full-time staff members
  • Leave for new parents
  • Versatile work scheduling options

At Golden Mine Projects, we monitor attributes like age, gender, nationality, diversity, disability, local representation, host community affiliation, and employment equity status (specifically in South Africa) of our employees and new hires. This forms a vital part of our strategy to attract a diverse pool of skilled employees. By doing so, we not only acquire the finest talent but also cultivate inclusive recruitment practices that consider age, gender, nationality, diversity, disability, local representation, host community affiliation, and Employment Equity Status (South Africa). This approach enables us to devise talent strategies that effectively harness available skills within our operational regions.

We also hold targets for enhancing female representation, which are detailed in our group and regional scorecards and are embedded in our management employees' long-term incentive schemes. Our turnover rates serve as crucial indicators of employee satisfaction and engagement. Changes in local market conditions influencing our reward philosophy play a pivotal role in managing our human resources.

The array of benefits provided by Golden Mine Projects to its employees adheres to local legislations in the respective countries of operation. As an organization, our offerings include flexible work arrangements, healthcare, life insurance, disability coverage, maternity leave, options for parental leave using annual leave or specific parental leave benefits, retirement provisions, and other customizable benefits that employees can choose from.

Purpose of Approach

Golden Mine Projects is committed not only to complying with local regulations in its operating countries but also to adhering to the principles outlined by the International Labour Organisation (ILO). We are dedicated to upholding fair employment practices, employing advanced metrics for inclusive recruitment methods, and striving for an environment where every employee can thrive in a mining career.

Components of Approach

The responsibility for employment resides with the Human Resource teams and Regional Executive teams, while senior appointments are overseen by the EVP of People and Organizational Effectiveness. The execution and supervision of this process are facilitated through a Recruitment system that systematically records, analyzes, and reports on advertised, recruited, and placed positions, a system being implemented in each region.

Mechanisms

The Group's recruitment and selection policy sets out the recruitment practices for Golden Mine Projects, supplemented by regional policies aligned with specific local legislative requirements. Roles are approved in line with the Golden Mine Projects approvals framework, necessitating formal approval processes for employment decisions. Recruitment statistics and turnover data are gathered and reported.

Benefits are periodically reviewed to align with local norms and global best practices, and all employment policies and procedures are subject to internal and external audits.

Maternity leave in all regions and paternity leave (where mandated by local legislation) are tracked and documented, along with other types of leave.

Golden Mine Projects aims to engage with its contractor workforce on safety and health matters and collaborates with major contractor mining partners whenever possible to address working practices.

We participate in global industry assessments to benchmark our performance in aspects like gender diversity.

Results

In 2021, Golden Mine Projects experienced a 6% turnover rate. Our engagement surveys indicate consistently high workforce engagement levels, showing a steady increase from 2018 to 2021. Employees at Golden Mine Projects enjoy a comprehensive suite of benefits in line with regional legislative requirements.

Parental leave adheres to local legislation, and when not specifically available, employees can choose to utilize their annual leave for parental leave purposes.

Water Management

Golden Mine Projects is devoted to conscientious water stewardship, aiming to benefit both host communities and our operations. Access to clean water is a fundamental human entitlement, a resource that is growing scarce and essential for our processing operations. Our strategy for handling our impact plays a pivotal role in upholding our operational authorization. By prudently managing our practices, we can decrease our environmental footprint through responsible water utilization, storage, and discharge. This not only curbs costs but also delivers advantages to all stakeholders.

Our strategies for water management are shaped by the external benchmarks, guidelines, and codes we've adopted, our internal directives and commitments, alongside our involvement in industry forums.

External documents     Internal guidelines, policies and documents     Industrial forums and working groups
  • ICMM Water Position Statement and Reporting Guideline
  • ISO certifications
   
  • Corporate Policy for Sustainable Development
  • Corporate Environmental Policy
  • Corporate Statement on Climate Change
  • Corporate Charter for Environmental, Social, and Governance (ESG) Matters
  • Corporate Charter for Responsible Water Management
  • Corporate Guideline for Water Management, revised according to the ICMM Water Position Statement Reporting Guideline and other leading approaches
  • Corporate Strategy for Water Management
   
  • International Council on Mining and Metals
  • Minerals Council of South Africa
  • Minerals Commission, Ghana
  • Chamber of Minerals and Energy of Western Australia

As part of introducing our 2030 ESG objectives in 2021, we established two overarching water management goals: achieving a 45% reduction in our freshwater consumption compared to a 2018 baseline, and reusing and recycling at least 80% of the water we utilize. These longer-term objectives have been translated into annual milestones.

We also progressed in implementing the Group's Water Stewardship Strategy for 2020 - 2025, supported by comprehensive regional plans for water management. Our strategy encompasses the following main principles:

  • Ensuring water supply: Our focus centers on comprehending and securing water resources throughout the mine's lifecycle. We're also integrating water planning into operational management and updating risk profiles for water security to facilitate water sourcing.
  • Enhancing water efficiency: Given potential water scarcity and community competition, it's imperative to consistently reduce freshwater demand and optimize water resource utilization. Our operations continued their strides in decreasing freshwater intake in 2021.
  • Management of catchment areas: Managing external water risks is crucial for Golden Mine Projects and stakeholders in the water catchment zones where we operate. While initial assessments suggest our operations have limited negative impacts on these stakeholders, we're establishing formal water stewardship partnerships with them. Our aim is to finalize these partnerships, as appropriate, by 2025.

Human capital

Golden Mine Projects outlines its approach to employment, encompassing job creation, recruitment, onboarding, development, retention, employment conditions, and related practices. The organization adheres to the principles of the International Labour Organisation, UNGC, and jurisdictional laws. In 2021, we introduced our Company's purpose - creating enduring value beyond mining, along with a revised purpose statement and refreshed Values.

Approach details

Our employment approach encompasses:

  • Hiring new employees and managing employee turnover
  • Onboarding new employees
  • Developing employee skills and leadership abilities
  • Talent management for full-time employees
  • Reward and benefits for full-time employees
  • Employment conditions and practices
  • Adhering to international labor standards and local legislation in our operating countries, which includes legislated benefits such as insurances, leave entitlements, assistance programs, etc., managed regionally.
  • Preventing child labor at all operations
  • Opposing forced or compulsory labor
  • Promoting workplace diversity and inclusion
  • Ensuring equal pay for equal work and addressing any gender or other biases in compensation.
  • Monitoring and addressing discrimination, bullying, harassment, and sexual harassment
  • Prioritizing employment from host communities

At Golden Mine Projects, we monitor various aspects of our employees and new hires - age, gender, nationality, diversity, disability, in-country and host community employment, and Employment Equity Status (in South Africa). This strategy aims to attract and retain a diverse pool of qualified employees. This approach ensures access to the best talent while fostering inclusive recruitment practices based on age and gender, as well as executing talent strategies in line with regional resources. Employee turnover rates and market conditions indicate employee satisfaction and human capital management.

The benefits we provide to employees, governed by local regulations, include health care, life insurance, disability coverage, maternity and parental leave, annual and sick leave, study leave, retirement provisions, and other optional benefits.

Approach purpose

Golden Mine Projects commits to following local laws in operating countries, while also ensuring employment practices adhere to International Labour Organisation (ILO) principles. We seek to establish fair employment practices, employ advanced metrics for inclusivity, and foster an environment where individuals can realize their potential. Our organizational culture forms the foundation to implement our People strategy.

Approach components

The responsibility for employment lies with Human Resources and Executive (Exco) teams in each Region. Regional Exco appointments are overseen by the EVP People and Organizational Effectiveness and Chief Executive Officer. A recruitment system records, analyzes, and reports on advertised, recruited, and placed positions.

Mechanisms

The Group Recruitment and Selection policy outlines Golden Mine Projects' recruitment practices, supported by regional policies where local laws dictate. Appointments align with the Golden Mine Projects approval framework, with formal approval processes for employment decisions. Recruitment statistics and turnover data are compiled and reported quarterly.

Benefits are periodically reviewed based on local laws and global best practices. Employment policies undergo internal and external audits.

Maternity and paternity leave (where applicable per local law) are recorded, along with other leave types.

Golden Mine Projects engages with contractor workforce on safety and health matters. Local community engagement involves employment and other strategic matters.

Our workforce benefits from various skills development, technical training, leadership, and management training programs. Training includes on-site, eLearning, and specialized training. Diversity and inclusion training is a focus.

Results

In 2021, average voluntary turnover was low at 4% (excluding retirements, terminations, and retrenchments). Regular turnover monitoring, climate surveys every 2 years, and annual check-in surveys gauge employee sentiment and guide engagement initiatives.

Employees provide notice upon employment termination, typically 30 days, varying based on leadership roles, ranging from 60 days for senior management to 6 to 12 months for executives.

Golden Mine Projects' employees enjoy comprehensive benefits, aligned with regional laws. Benefits include vacation, leave types, flexible work, medical support, pensions, life insurance, and more. Part-time employees have different benefits. Employees access Employee Assistance Programs for personal and work-related issues. In some regions, benefits extend to housing allowances, meals, loans, and educational support. Parental leave aligns with local laws.

Energy and Emissions

The process of extracting and processing gold demands substantial energy. This challenge is amplified by evolving ore geology, declining grades, longer transportation distances, and deeper mines, necessitating additional cooling and ventilation infrastructure. The energy-intensive nature of mining, driven by electricity demand and diesel usage, significantly contributes to the industry's high carbon emissions.

Coping with and minimizing the adverse effects of climate change is imperative due to the disruptive climate-related risks across our operations and supply chains. Managing energy use and costs is also crucial considering exposure to external energy price fluctuations. Efficient energy management aids in reducing our carbon footprint and addressing the detrimental consequences of climate change.

Energy and carbon management play a vital role in transitioning towards a low-carbon future. As part of our comprehensive climate change governance, we've established an executive steering committee overseeing our holistic climate change response, in which our decarbonization strategy holds significant importance. Adhering to global best practices like the recently updated ICMM Position Statement on Climate Change and obtaining ISO 50001 certification for our mines by 2023 supports our decarbonization strategy.

Deeper mining operations raise energy demand. To ensure energy security, we explore the feasibility of low-carbon and renewable sources like gas, solar, and wind. These options serve multiple goals, securing supply, cutting carbon emissions, and optimizing energy costs.

Golden Mine Projects has set a Scope 1 and 2 net carbon emission reduction target of 30% by 2030 (based on a projected 2.8Moz annual gold production by 2030, compared to a 2016 baseline). The ultimate aim is achieving net-zero GHG emissions by 2050 or earlier. The decarbonization strategy involves increased use of renewable energy, electrifying material movement like haulage, replacing diesel, and boosting energy efficiency.

As an International Council on Mining & Metals (ICMM) member, Golden Mine Projects commits to establishing a Scope 3 emissions reduction target by 2023. Until then, we'll develop a Scope 3 emissions baseline assessment, set a reduction target, and formulate a comprehensive strategy.

Our mines undergo climate change vulnerability and risk assessments every five years, extending to impacted communities. In 2021, a second assessment round was conducted, and results were presented in our 2021 Climate Change Report.

Our energy consumption management and climate resilience strategy align with regulations, external standards, guidelines, and codes, along with internal policies and commitments. We also heed policies set by global and national mining organizations we're affiliated with, using their standards as benchmarks for our initiatives.

Climate change influences natural resource availability, especially impacting water and energy infrastructure due to:

  • Extreme weather events affecting operations, supply chains, and host communities, including heavy rain, snow, winds, high temperatures, and prolonged droughts.
  • Rising climate-related regulations, carbon taxes, stringent water rules, evolving technologies, standards, and investor perspectives.

In 2017, the Board adopted an updated Group Climate Change Policy (refreshed in 2020), outlining a balanced approach to climate change objectives encompassing mitigation and adaptation.

Golden Mine Projects embarked on its climate change, energy, and water journey in 2016, reporting on climate performance since 2010, with the first submission to the CDP. In 2018, we became the second JSE-listed company to endorse the United Nations-backed Task Force on Climate-Related Financial Disclosures (TCFD) recommendations, leading to our annual Climate Change Report in line with these guidelines.

Indigenous People

Our stance concerning Indigenous Peoples is detailed in our Community Policy. At Golden Mine Projects, we aim to cultivate mutually beneficial relationships with key stakeholders, including Indigenous Peoples, wherever we operate.

We endorse the definitions of Indigenous Peoples from the International Finance Corporation Performance Standard 7, and the definition from the International Council on Mining and Metals, as articulated in article 1 of the International Labour Organisation’s Indigenous and Tribal Peoples Convention (ILO 169).

We acknowledge that Indigenous Peoples often possess distinct cultural traits, governance structures, and decision-making methods that differentiate them from non-indigenous populations. This necessitates engagement strategies that are culturally appropriate, with a focus on the capabilities, rights, and interests of Indigenous Peoples, within the broader context of community engagement.

To realize this vision, we adhere to these principles:

  • Respect for local traditions, rights, interests, cultures, perspectives, and unique connections to surrounding lands and waters;
  • Implementation of culturally fitting engagement and consultation processes to ensure meaningful and equitable participation of Indigenous Peoples;
  • Engagement through suitable systems, promoting dialogue, understanding viewpoints, and assessing impacts on our surroundings, aligned with our values and UN Guiding Principles on Business and Human Rights;
  • Striving to acquire the consent of surrounding communities, utilizing appropriate mediation and capacity building processes if needed, for new or modified projects, especially when located on lands traditionally owned by Indigenous Peoples and likely to have significant adverse effects;
  • Ensuring that suppliers and contractors adhere to Golden Mine Projects' policies, standards, and guidelines.

Our Community Relations Standard 7 provides guidance on engaging with and respecting the rights and interests of Indigenous Peoples. Details can be found in the Golden Mine Projects Community Relations Handbook. Our guidance is based on international best practice principles, including the IFC Performance Standards, Equator Principles, AA1000 Stakeholder Engagement Principles, ICMM Mining Principles 3, 9, and 10, our values, group policies, and commitment to being a trusted mining partner.

Crucial outcomes when dealing with Indigenous Peoples are Free, Prior and Informed Consent (FPIC) and formal agreements. These outcomes are achieved through:

  • Baseline studies conducted by skilled practitioners, exploring Indigenous communities' socio-economic conditions, land practices, rights, connections to land and water, decision-making, and conflict resolution methods;
  • Development of a stakeholder engagement plan throughout the mine's lifecycle.

Our Community Relations guidance and standards apply equally to Indigenous Peoples (cross-reference to Community Relations and Creating Shared Value).

Introduction

We value strong community relations for our social license to operate. We work to minimize negative impacts and maximize positive outcomes on communities through stakeholder engagement and Shared Value development.

Guiding our Community Relations/Our Approach

Golden Mine Projects' approach to positive community relations includes:

  • Understanding operational contexts and stakeholder priorities;
  • Managing environmental and social risks;
  • Building transparent relationships with stakeholders;
  • Meaningful social investments;
  • Creating Shared Value through community procurement and employment.

Our community relations and engagement approach adheres to external standards, guidelines, and codes, internal policies, and industrial forums' guidance.

Independent assessors measure our community relations and social investment performance.

Partnering to protect the industry/Enhancing the industry’s reputation.

Given the mining industry's socio-economic and political pressures, industry organizations, including Golden Mine Projects, have initiated communication campaigns to improve the sector's image and reputation.

These efforts involve organizations like the International Council on Mining and Metals (ICMM) and national mining industry associations. The ICMM’s work is found at www.miningwithprinciples.com.

Golden Mine Projects collaborates with these organizations to provide relevant content, particularly concerning community investment and ESG initiatives, especially related to renewable energy and water.

Our Community Relations and Stakeholder Engagement Guideline is based on best practice principles, including the IFC Performance Standards, Equator Principles, and AA1000 Stakeholder Engagement Principles.

Details can be found in the Golden Mine Projects Community Relations Handbook. This Guideline aligns with ICMM Mining Principles 3, 9, and 10, our values, group policies, and commitment to being a trusted mining partner. Implementation of the nine Community Relations Standards, guiding interactions with communities and stakeholders, is crucial to this commitment, as outlined at a high level in this guideline and described in detail in the Group Community Relations Handbook.

Our Society and Community Charter – our commitments to our stakeholders

Our charter pledges to:

  • Cultivate strong relationships with stakeholders through trust, open engagement, and understanding;
  • Create a lasting, positive legacy for host communities, promoting sustainable development and Shared Value;
  • Measure performance against commitments;
  • Enhance understanding of host communities' concerns and aspirations, co-creating appropriate commitments for our social license to operate.

Building Relationships through Engagement

Stakeholders are integral to our business, influencing and affected by our operations. Guided by our values of Integrity, Respect, and Responsibility, we foster relationships built on open, transparent, and constructive engagement. This ensures participative, informed decision-making, balancing stakeholder interests with Golden Mine Projects' well-being.

We formally and informally engage with representatives of various stakeholders, including:

  • Employees;
  • Host Communities;
  • Financial market participants (shareholders, investors, etc.);
  • Governments and Regulators;
  • Industry associations and peers;
  • Media;
  • Non-governmental organizations;
  • Organized labor;
  • Business partners, contractors, suppliers;
  • Traditional authorities.

In 2020, we updated our Stakeholder Relationship and Engagement Policy to be inclusive of key stakeholders. Our operations record engagements using the Group External Interaction and Commitment Register (EICR) system since 2019.

Golden Mine Projects also communicates through various platforms, including social media, to inform stakeholders about community relations activities and initiatives.

All regions have societal acceptance charters aligned with the Group Charter. Annual community and government action plans uphold these charter commitments.

Understanding our grievance mechanisms

We promptly address community issues and concerns through established mechanisms. Our operations have a three-order system for handling grievances: first-order resolution, second-order investigation, and third-order legal action if needed.

Our grievance management practices align with UN Guiding Principles on Business and Human Rights effectiveness criteria.

Shared Value

Shared Value arises when companies proactively address business and social needs. It extends beyond harm mitigation, identifying economic opportunities by integrating social priorities into business strategies, collaborating with stakeholders to solve socio-economic and environmental challenges. This approach ensures that the value generated benefits both the business and the community.

Our Shared Value approach rests on four pillars:

1 Strategic interventions to address socio-economic challenges   2 Integration to proactively address socio-economic challenges   3 Participation in collaborative action with other stakeholders   4 Transparency regarding Golden Mine Projects’ economic contributions to its host societies in line with World Gold Council guidelines

Governance and Compliance

The imposition of penalties, sanctions, and/or fines due to failure to adhere to laws, regulations, rules, standards, international declarations, conventions, or treaties can significantly impact the reputation of Golden Mine Projects and influence investor behavior. Additionally, fines' nature and scope can have negative financial consequences, and regulatory-required remediation efforts can affect operational efficiency and progress.

Golden Mine Projects has established a risk-based Group Compliance Framework to provide strong assurance of regulatory compliance. This framework is an integral part of the Group Governance and Compliance Framework. Under the Compliance Framework, Golden Mine Projects:

  • Ensures ethical and professional conduct through a comprehensive Group Code of Conduct, supported by a Group Policy Register.
  • Monitors the regulatory landscape for current and upcoming changes, conducting regular reviews of control environments to confirm control effectiveness. For instance, in 2021, 236 COVID-19-related changes were identified, assessed, and controlled, representing 46% of regulatory changes that year.
  • Evaluates all statutes, rules, codes, and standards in operating areas, assessing exposure to non-compliance and related regulatory risks.
  • Aligns internal control environments with defined and prioritized statutory requirements.
  • Conducts annual audits by Internal Audit to assess the suitability, design, and operational effectiveness of implemented controls.
APPROACH PURPOSE
  • Proactively responds to regulatory changes.
  • Ensures controls align with statutory requirements, rules, codes, and standards.
  • Maintains control environments, focusing on mitigating inherent risk.
  • Assesses risk exposure and uses a risk-based approach to mitigate non-compliance and regulatory risks.

Mechanisms

Solutions

  • A published Management Guideline contextualizes the Governance & Compliance Framework, engaging all stakeholders in actively managing compliance risk.
  • An interactive Group Governance & Compliance Portal enables systematic recording, analysis, and reporting of compliance levels across various criteria.
  • In 2021, the Data Protection and Privacy Gateway on the Portal was expanded to accommodate South African data protection legislation, acting as a trust source for mapped data flows and control frameworks.
  • The annual Group Compliance Plan is managed by in-country legal teams, analyzing data for trends and gaps to enhance guidance value.
  • Structured Internal Audit reviews.
  • Data analytic tools enhance trend analysis and interpretation, reported to the Audit Committee quarterly.

Reporting

  • Monthly Compliance Updates inform Executive Vice Presidents, and an aggregate overview is provided to the Group Audit Committee quarterly.

Cryptic Results

While no sanctions stem from non-compliance with international declarations, conventions, or treaties, and no cases were brought against the Group through dispute mechanisms, the following penalties, sanctions, and/or fines were recorded:

Across the Group, 52 regulatory findings and 20 penalties, sanctions, and/or fines totaling USD 31.3 million have been reported.

Labour and management and relations

Labour and Management Relations

This section covers the consultation practices employed by Golden Mine Projects when interacting with employees and their representatives. It outlines how we communicate significant operational changes and highlights our adherence to international norms and standards. Our approach to consultation is consistent with established practices worldwide. While our workforce in South Africa is largely unionized, our unionization levels are smaller in Peru and Australia.

Details of Our Approach

  • Golden Mine Projects respects employees' right to freedom of association, allowing them to choose to join a union.
  • Once a specific threshold in membership is reached, we have policies to acknowledge and engage with organized labor.
  • Our interactions with organized labor occur through both formal and informal decision-making forums, based on the nature of the decisions.
  • Organized labor is considered a key stakeholder in our business, particularly in matters related to employee safety and health.
  • Consultation practices are in place to involve employees in decisions, especially those involving significant operational changes.
  • Effective consultation involves providing timely and comprehensive information to employees or their representatives. In cases of potential restructuring, we explain the impact of changes and seek collaborative solutions to mitigate negative consequences.
  • We actively monitor and track potential strikes or lockouts by employees.

Purpose of Our Approach

  • Ensure a fair and transparent engagement process that addresses the concerns of organized labor.
  • Facilitate joint resolution of key business matters between management and organized labor when necessary.
  • Recognize and engage with shop stewards or representatives of organized labor within our operations.
  • Implement a structured engagement approach to promptly address raised issues in a professional manner.
  • Engage with employees to provide insights on Group/Region strategy and performance.

Mechanisms for Implementation

  • Utilize formal engagement forums, some of which are mandated by legislation.
  • Follow established processes to submit and address grievances and concerns with management and the organization.
  • Adhere to formal procedures for wage negotiations (collective bargaining).

Ethics, Conduct & Integrity

During the year 2016, the Group conducted a comprehensive review and update of its Code of Ethics. This effort resulted in the launch of a revised Code of Conduct (referred to as the Code) in December 2016. The Code applies universally to directors, all categories of employees, and third parties. Its scope covers all business and operational activities across the Group's entire value chain.

The Board provided its approval for the Code, and every board member, Exco member, and employee has committed to the Code's principles through signed acceptance declarations. This commitment extends to embedding the Code's intent and requirements into daily business operations and interactions with stakeholders, both internal and external. Additionally, in 2019, a process was initiated to require third parties to sign a Certification affirming their adherence to the Code's principles.

Furthermore, the Group maintains a Group Policy Register within the Group's interactive Group Governance and Compliance Portal. This register documents the Group's policies, statements, and frameworks, ensuring alignment across Group, regional, and operation-specific levels, thereby ensuring the supremacy of Group policy principles.

Purpose of the Approach

  • Promotion of inclusivity.
  • Recording and analysis of submitted declarations as mandated by the Code.
  • Fostering awareness of ethical conduct across the Group.
  • Alignment of internal requirements with the Code, as outlined in policies.

Mechanisms Employed

Internal Training

For Board and Exco Members

  • Prior to signing their acceptance and commitment declarations, personalized copies of the Code were provided to all Board and Exco members.
  • An eLearning training program, accessible throughout the Group, was launched in December 2017. After undergoing a review and incorporating amendments, an updated version will be rolled out in 2022 for new employees.
  • High-risk portfolios, such as finance, procurement, and stakeholder engagement, underwent specialized training, specifically targeting anti-bribery and corruption, a key aspect of the Code.
  • The eLearning program places particular emphasis on corruption and bribery. In addition to this program, anti-corruption training, in line with legal frameworks like the Foreign Corrupt Practices Act (FCPA), was introduced for senior management, defined portfolios, and job levels D band and above.
  • While contractors and suppliers are required to adhere to the Code's principles, no formal training sessions are held. However, they receive copies of the Code and are obligated to sign the Group's Suppliers' Code of Conduct Certification. Contract managers ensure their awareness of the Code through regular contractual interactions.

For Third Parties

  • Similar to contractors and suppliers, formal training sessions for third parties are not conducted due to logistical factors. However, they are provided with copies of the Code of Conduct and required to sign the Group's Suppliers' Code of Conduct Certification. This commitment is reinforced through the standard contractual management process.
  • Agreements with third parties stipulate adherence to the Code's values and principles as a contractual requirement.

Implemented Solutions

  • Introduction of a Group Whistle-blowing Policy.
  • An Interpretational Decision Tree, designed to aid in applying key Code requirements, is maintained for use by in-country legal teams to facilitate application, interpretation, and guidance.
  • Development and implementation of a Code of Conduct Gateway, serving as a resource center for employees to better understand the Code and its practical application.
  • Utilization of a data analytic tool to analyze trends and enhance the interpretation and application of the Code's requirements. Analysis results are regularly reported to the Audit Committee.
  • Conduction of a structured Internal Audit review on an annual basis.

Advice & Guidance

  • Golden Mine Projects has established procedures to address corruption incidents. Employees engaged in corruption are subject to disciplinary action as outlined in regional disciplinary policies, which could lead to dismissal.
  • External and internal legal counsel are consulted for sound advice and guidance when required.
  • In-country legal teams are responsible for overseeing the Code and acting as regional custodians. They offer initial advice, and complex matters are escalated to the Executive Vice-President: Group Head of Legal and Compliance. An established escalation and approval framework is an integral part of the Code.
  • For escalated matters, internal and external issues can follow defined management structures as set out in the Code. Additionally, unethical or unlawful behavior by external stakeholders can be reported through interactions with our operational procurement and contract management teams.
  • The Interpretational Decision Tree serves as a valuable tool for addressing stakeholder queries. Real-life business examples provide practical guidance for stakeholders with questions.
  • Monthly meta data analysis is conducted per jurisdiction to identify trends and enhance the Code's interpretation and application during advice and guidance. Additionally, annual and ad hoc reviews are carried out by Internal Audit and the Group Compliance Office.
  • The Group participates in presentations on anti-corruption legislation with mining industry bodies, collaborating with government representatives as well.

Reporting

  • The Code provides various reporting channels for concerns related to unethical or unlawful behavior and organizational integrity. Notably, the certified tip-offs line (External Whistleblowing Hotline Service Provider Standard EO1.1.1) is a prominent avenue. This independently operated line is accessible to both internal and external stakeholders and is available in English and Spanish. Confidentiality is ensured, investigations are recorded, and the Audit Committee approves the process. Reminders are regularly provided via email, flyers, and posters, highlighting the option for anonymous reporting.
  • Through monthly Compliance Updates, Executive Vice Presidents receive updates on country-specific trend analysis outcomes and concerns raised by the Group Compliance Office. Quarterly aggregate summaries are reported to the Group Audit Committee.

Security

Golden Mine Projects acknowledges its duty to ensure the safety of its personnel and assets. This responsibility holds greater significance in environments with heightened risk, areas characterized by weak governance, and those impacted by illegal mining.

Moreover, being a producer of a valuable and easily transportable commodity, the transfer of gold between our mining sites and refineries presents evident challenges.

Nevertheless, the provision of professional and effective security, even when involving physical force, must not infringe upon the human rights of others.

Primary security measures for our operations are carried out by the Company's protection services department and contracted service providers.

During the induction process, all security personnel undergo human rights training in accordance with local legal mandates and international human rights best practices.

In 2017, an evaluation was conducted to assess discrepancies between Golden Mine Projects' existing procedures and the requirements outlined in the Voluntary Principles on Security and Human Rights (VPSHR).

Although no significant risks were identified, the identified gaps were addressed in 2018.

Monitoring alignment with the VPSHR persisted in 2019, which included reviewing the West Africa region's progress by the Americas region and corporate Sustainable Development. This served as an opportunity to exchange insights, experiences, and effective strategies between the two regions.