S O C I A L P E R F O R M A N C E P O L I C Y

S C O P E

This policy is applicable to all the entities of De Beers. Members of De Beers may

adapt the policy to include local legislative and stakeholder priorities within the

countries in which they operate.

R E S P O N S I B I L I T Y F O R T H E P O L I C Y

The maintenance, revision and distribution of this policy are the responsibility of

the De Beers Group Head of Social Performance.

S O C I A L P E R F O R M A N C E P O L I C Y

De Beers is committed to taking responsibility for the short and long term

economic, social and environmental implications of its decisions across the

diamond pipeline.

We commit to building diamond dreams through effective partnerships and

enhancing the confidence of consumers in diamonds. In pursuit of the highest

standards of social performance, De Beers is committed to:

y Managing all aspects of this Social Performance Policy as an integral part of

business.

y Developing and implementing appropriate social performance policies,

systems, programmes and training across all parts of our business.

y Complying with relevant legislation in local jurisdictions where operating

and other requirements to which De Beers subscribes, and aligning with

international good practice.

y Allocating resources commensurate to social risks, potential impacts and

socio-economic opportunities to ensure the appropriate implementation of

social management plans and the meeting of our commitments across all

parts of our business.

y Embedding social performance across the organisation through a culture of

shared responsibility and accountability which integrates social performance

considerations into business decision making.

y Engaging in a transparent and inclusive manner with local stakeholders to

improve understanding, promote constructive interaction and seek solutions

to common social issues and challenges.

y Delivering a lasting positive socio-economic benefit to our host countries and

communities through leveraging our core business for development impact

and engaging in additional corporate social investment activities.

y Adopting the mitigation hierarchy approach by first assessing, seeking to

avoid, minimising and then mitigating potential social impacts and risks when

planning, designing and implementing exploration, mining and related

activities.

y Respecting human rights including the right of Indigenous Peoples to Free,

Prior and Informed Consent.

y Utilising a formal management approach to investigate, respond and, where

appropriate, provide redress to social incidents and stakeholder grievances.

y Ensuring that comprehensive social performance planning, costing and

implementation for exploration, project, operational and closure phases is

undertaken.

y Recognising that potentially vulnerable groups within our affected

communities could be disproportionately impacted by or less able to benefit

from our activities due to the fact that they may be marginalised, historically

disadvantaged and disempowered and seeking to redress this imbalance.

y Complying with the requirements of the Social Way management system at all

operating mines as the foundation for continuous improvement.

y Managing potential risks to community health, safety and security

including integrating stakeholders into emergency response planning, and

implementing the Voluntary Principles on Security and Human Rights.

y Avoiding resettlement where possible and following international best

practice when either physical or economic displacement are unavoidable.

y Seeking to avoid and, where avoidance is not possible, minimise and mitigate

impacts on cultural heritage.

y Including appropriate social performance requirements in our contractual

agreements when significant potential adverse social impacts and/or

opportunities to deliver socio-economic development exist.

y Regularly monitoring and evaluating social performance to ensure

compliance with this Policy and to facilitate continuous improvement.

y Reporting social risks and performance publicly and providing assurance to

the De Beers Société Anonyme Board of Directors through the Sustainability

Committee.

O B J E C T I V E

The objective of this policy is to provide requirements for the leadership, management, application and

administration of social performance within The De Beers Group of Companies (De Beers).

VERSION: JULY 2016

Bruce Cleaver, CEO, De Beers Group

Gareth Mostyn, Executive Head of

Strategy and Corporate Affairs