sustainability framework - royal bafokeng nation...3 executive summary the purpose of this document...
TRANSCRIPT
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Sustainability Framework (Incorporating the Stakeholder Engagement Framework)
Draft 0.1
18 July 2013
Social & Ethics committee
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Contents
Executive Summary............................................................................................................................................................. 3
A. Background to Sustainability ..................................................................................................................................... 4
1. Overview ................................................................................................................................................................... 4
2. The South African Legislative Context: The Companies Act (No. 71 of 2008) ........................................................... 5
3. The Good Practice Context: The UNGC ..................................................................................................................... 6
i. The United Nations Global Compact ................................................................................................................... 7
ii. The International Council on Mining and Minerals ............................................................................................. 9
B. Contexualising RBPlat .............................................................................................................................................. 12
1. The Legislative and Good Practice Context of RBPlat ......................................................................................... 12
2. The RBPlat Social and Ethics Committee: Interpreted Responsibilities and Implications .................................. 15
i. Responsibilities .................................................................................................................................................. 15
ii. Implications ....................................................................................................................................................... 16
3. Sustainability Value Proposition .............................................................................................................................. 17
4. Critical Risk Factors .................................................................................................................................................. 18
C. Approach to Developing the RBPlat Sustainability Framework............................................................................... 19
1. Overview ................................................................................................................................................................. 19
2. Approach ................................................................................................................................................................. 19
D. Step 1: The RBPlat Overarching Theme ................................................................................................................... 20
E. Step 2: The RBPlat Sustainability Framework Guidelines ........................................................................................ 21
F. Step 3: The RBPlat Stakeholder Engagement Framework ....................................................................................... 23
1. Overview ................................................................................................................................................................. 23
2. Stakeholder Engagement Standards ....................................................................................................................... 23
3. Purpose of Stakeholder Engagement ...................................................................................................................... 24
4. Engagement Challenges and Pitfalls ........................................................................................................................ 24
5. High Level Engagement Steps .................................................................................................................................. 25
i. Before the Engagement..................................................................................................................................... 26
ii. During the Engagement..................................................................................................................................... 42
iii. After the Engagement ....................................................................................................................................... 43
G. Step 4: The Sustainability Framework ..................................................................................................................... 44
1. Internal Context - Current and Preferred Status ..................................................................................................... 44
2. The Sustainability Framework ................................................................................................................................. 47
i. Phase 1: Realigning the Company Profile .......................................................................................................... 48
ii. Phase 2: Review of Corporate Governance ....................................................................................................... 50
iii. Phase 3: Integration of sustainability and risk ................................................................................................... 50
iv. Phase 4: Establishment of a Sustainability Committee ..................................................................................... 52
v. Phase 5: Integration of sustainability: Roles, responsibilities and timeframes ................................................. 56
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Executive Summary
The purpose of this document is to present a sustainability framework to the Social and Ethics
Committee of the Board of Royal Bafokeng Platinum Ltd. (RBPlat) for their consideration in
meeting the sustainability and ethical requirements of the Companies Act (amongst other
regulatory requirements), whilst taking cognizance of national and international best practice
codes and guidelines. Specific reference is made to the United Nations Global Compact (UNGC),
to which RBPlat is a signatory, as the UNGC presents overarching human rights, labour,
environmental and anti-corruption principles; these principles have been unpacked into mining-
industry specific principles by the International Council on Mining and Minerals.
A synopsis of the various legislative and good practice sustainability requirements are listed in
Section A of this document together with an illustrative positioning of RBPlat within this broad
context.
Section B provides an overview of a 4 step-by-step approach to developing a sustainability
framework for RBPlat, which is described in further detail in the sections that follow. Briefly, the
4 steps are:
1. Identification of a personalized theme for RBPlat’s sustainability agenda
2. Development of overarching corporate guidelines for sustainability to inform the
development of the stakeholder engagement and sustainability frameworks
3. Development of a stakeholder engagement framework
4. Development of a sustainability framework
The sustainability framework is further unpacked into 5 implementation phases as follows:
1. Realignment of the company profile
2. Reviewing the corporate governance infrastructure
3. Integration of sustainability and risk management
4. Establishment of a Sustainability Committee
5. Integration of sustainability into existing management processes: Establishment of
internal roles and responsibilities for sustainability
Important note:
This document presents a framework for a business concept that does not necessarily comply with other standard
business processes where decisions and actions can be predetermined and submitted for implementation according to a
set formula. Sustainability requires extensive engagement of pertinent (internal and external) stakeholders to ensure
the relevance and feasibility of the framework and subsequent initiatives. Engagement processes prevent possible
defensive or resistant responses; instead engagement promotes buy-in and importantly, ownership of the decisions that
need to be taken to embark on a sustainable business journey. Hence care has been taken in the development of this
document to ensure that it serves as a guiding framework as opposed to a predetermined structure that is closed to
review by all parties at all levels. Often suggestions are made to serve as an illustrative example of the idea in mind (for
example, the development of an overarching theme for RBPlat’s sustainability agenda is suggested to be ‘responsible
leadership’; this is not meant to be prescriptive but rather a suggestion made by a singular person which may not be
suitable to the company leadership or the company itself and therefore the idea of a theme, and what that theme
should be, needs to be interrogated by the relevant company stakeholders).
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A. BACKGROUND TO SUSTAINABILITY
1. Overview Corporate sustainability practices are imperative for the improvement of the quality of life
of all peoples, both locally and globally, and the protection of all other species upon which
we depend for our survival.
Companies that have embarked on mainstreaming sustainability into their business practices
have done so for various reasons; the drivers may have been compliance with legislation to
avoid legal action, pursuing a business case that is supported by improved competitiveness,
or as a result of awakened thinking stemming from sound morals and values of their
leadership and shareholders.
The principles of sustainability are contained within the Universal Declaration of Human
Rights (1948), the International Labour Organisation’s Declaration on Fundamental
Principles and Rights to Work (1998), the Rio Declaration on the Environment and
Development (1992), and the United Nations Convention Against Corruption (1992) amongst
others; in South Africa the concepts are enshrined in the South African Constitution (1996)
and recently in the Companies Act (No. 71 of 2008).
Various best practice guidelines, such as that presented by the King III Code of Good Practice
(2009; King III), have also been developed to support and fill the gaps left by legislation.
Companies, that have the foresight to secure their own financial sustainability by competing
responsibly in the market, are at the forefront in understanding the potential risk and
opportunities these issues present to their profit margin in the long term. Various stock
exchanges promote sustainable business practices by listing companies in their sustainability
indices thereby providing a decision making tool for shareholders who would like to consider
a company’s impact on society, the economy and the environment (the 3 pillars of
sustainability) as an integral part of their return on investment.
Advances in information technology are bringing to light many violations and transgressions
made by companies; individuals now have the ability to make informed decisions and take
action against those who violate human rights, degrade the environment, or participate in
unsustainable economic practices. Hence the license to operate, ability to entice
shareholders, or reassure affected stakeholders is becoming increasingly difficult without
proof of responsible and ethical business practices.
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2. The South African Legislative Context: The Companies Act (No. 71 of
2008)
One of the aims of the Companies Act is to promote compliance with the Bill of Rights
contained within the South African Constitution1 in the application of company law. The
Bill of Rights “enshrines the rights of all people in our country and affirms the democratic
values of human dignity, equality and freedom”, and explicitly addresses issues of social,
economic and environmental well-being. Therefore the Companies Act makes provision for
the Minister of Trade and Industry to prescribe that a company must establish a Social and
Ethics Committee as a sub-committee of the Board to be accountable for social, economic
and environmental impacts of that company. The effective date of the Companies Act, as
gazetted in the Government Gazette No 34239, was 1 May 2011.
Based on the Companies Act (Part F: Governance of Companies, Section 72 [4]), the
Companies Regulations (Chapter 3, Section 43) (2011) details the functions of the Social
and Ethics Committee to support enhanced corporate transparency and accountability as
follows:
1. To monitor the company’s activities, having regard to any relevant legislation, other
legal requirements or prevailing codes of best practice, with regard to matters relating
to:
1.1 social and economic development, including the company’s standing in terms of
the goals and purposes of:
the 10 principles set out in the United Nations Global Compact
Principles (UNGC); and
the Organisation for Economic Cooperation and Development (OECD)
recommendations regarding corruption;
the Employment Equity Act; and
the Broad-Based Black Economic Empowerment Act;
1.2 good corporate citizenship, including the company’s:
promotion of equality, prevention of unfair discrimination, and reduction
of corruption;
contribution to development of the communities in which its activities
are
predominantly conducted or within which its products or services are
predominantly marketed; and
record of sponsorship, donations and charitable giving;
1.3 the environment, health and public safety, including the impact of the
company’s activities and of its products or services;
1 Republic of South Africa. The Constitution of the Republic of South Africa. Act 108 of 1996.
http://www.acts.co.za/constitution/index.htm
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1.4 consumer relationships, including the company’s advertising, public relations
and compliance with consumer protection laws; and
1.5.1 labour and employment, including:
the company’s standing in terms of the International Labour
Organization Protocol on decent work and working conditions; and
the company’s employment relationships, and its contribution
toward the educational development of its employees;
2. to draw matters within its mandate to the attention of the Board as occasion
requires; and
3. to report, through one of its members, to the shareholders at the company’s
annual general meeting on the matters within its mandate.
Further to the Companies Act, various other South African legislative requirements are applicable
to very specific areas of the sustainability pillars, for example, Employment Equity Act (1988) as a
component of the social pillar and the National Environmental Management Act (No. 107 of
2008) as a component of the environmental pillar, amongst a variety of others. Furthermore,
industry specific legislation is also applicable, such as the Mine Health and Safety Act (No. 29 of
1996), Mineral and Petroleum Resources Development Act (MPRDA; No. 28 of 2002), and Broad-
Based Socio-Economic Charter for the South African Mining and Minerals Industry (the Mining
Charter; 2010).
3. The Good Practice Context: The UNGC Numerous codes, standards, guidelines and tools have been developed both nationally and
internationally to drive and support corporate sustainability agendas; these are amongst others
the:
King III Code of Good Practice (2009; and Integrated Reporting Guidelines, 2011)
JSE Socially Responsible Investment Index (JSE-SRI Index; 2011)
United Nations Global Compact (UNGC; 2000)
Code for Responsible Investing in South Africa (CRISA; 2011)
United Nations Principles for Responsible Investing (UN-PRI, 2006)
Global Reporting Initiative (GRI-G3 or G4 - 2013) reporting guidelines
Accountability Assurance Standard (AA1000AS)
International Integrated Reporting Committee (IIRC) – reporting framework (to be
finalized in late 2013)
International Standards Organisation (ISO 26000, ISO 14000, ectetera)
Sustainability Principles of the International Committee for Minerals and Mining (ICMM)
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i. The United Nations Global Compact
The UNGC presents 10 very broad overarching principles (Box 1) that require
interpretation from a geographical, industrial and company specific point of view. These
principles encompass all the key aspects of sustainability, hence the integration of these
principles into a company’s core business will address the legislative and best practice
requirements listed in aforementioned sections; furthermore, the adherence to the
UNGC is explicitly mentioned in the regulations of the Companies Act.
The UNGC principles have their foundation in the Universal Declaration of Human Rights
(1948), the International Labour Organisation’s Declaration on Fundamental Principles
and Rights to Work (1998), the Rio Declaration on the Environment and Development
(1992), and the United Nations Convention Against Corruption (1992).
Launched in 2000 by former Secretary General of the United Nations: Kofi Annan, the
principles are intended to improve corporate citizenship in public, private and civil-
society entities. With over 10 000 corporate signatories in 130 countries, the
commitment is voluntary with an emphasis on the responsibility and accountability of
organisational leadership. Commitment to the UNGC principles requires the
reassessment of core business processes to support the sustainability pillars, as opposed
to a peripheral focus on corporate social investment, public relations exercises, and
philanthropic activity. Other signatory commitments include mandatory annual reporting
on progress, avocation of the principles within the company’s sphere of influence and a
membership fee based on turnover2. Companies may also seek permission to use the
UNGC logo for promotion of the principles.
In South Africa, the UNGC has a local area network that is hosted by the National
Business Initiative to support UNGC members with their sustainability journey through
discussion forums, seminars and workshops. RBPlat was readmitted to the UNGC as a
signatory in May 2012 with the first communication on progress due August 2013.
2 This has been voluntary until the end of 2012. The mandatory fee is currently being disputed by member
companies, including those in SA)
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Box 1.
The UNGC Principles
Human Rights
Principle 1: Businesses should support and respect the protection of internationally proclaimed human rights within their sphere of influence; and Principle 2: make sure that they are not complicit in human rights abuses.
Labour Standards Principle 3: Businesses should uphold the freedom of association and the effective recognition of the right to collective bargaining; Principle 4: uphold the elimination of all forms of forced and compulsory labour; Principle 5: uphold the effective abolition of child labour; and Principle 6: uphold the elimination of discrimination in respect of employment and occupation.
Environment Principle 7: Businesses should support a precautionary approach to environmental challenges; Principle 8: undertake initiatives to promote greater environmental responsibility; and Principle 9: encourage the development and diffusion of environmentally friendly technologies.
Anti-Corruption Principle 10: Businesses should work against corruption in all its forms, including extortion and bribery.
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ii. The International Council on Mining and Minerals
In 2003, a CEO-led International Council on Mining and Minerals (ICMM), committed
member companies to implement and measure their performance against 10 industry
specific sustainability principles (Box 2) which are further unpacked into specific actions
(Box 3).
The principles are based on the issues identified in the Mining, Minerals and Sustainable
Development project and were benchmarked against leading international standards,
including the Rio Declaration, the GRI, the UNGC, OECD Guidelines on Multinational
Enterprises, World Bank Operational Guidelines, OECD Convention on Combating Bribery,
ILO Conventions 98, 169, 176, and the Voluntary Principles on Security and Human
Rights.
Box 2.
The 10 ICMM principles
Principle 1. Implement and maintain ethical business practices and sound systems of
corporate governance.
Principle 2. Integrate sustainable development considerations within the corporate decision-
making process.
Principle 3. Uphold fundamental human rights and respect cultures, customs and values in
dealings with employees and others who are affected by our activities.
Principle 4. Implement risk management strategies based on valid data and sound science.
Principle 5. Seek continual improvement of our health and safety performance.
Principle 6. Seek continual improvement of our environmental performance.
Principle 7. Contribute to conservation of biodiversity and integrated approaches to land use
planning.
Principle 8. Facilitate and encourage responsible product design, use, re-use, recycling and
disposal of our products.
Principle 9. Contribute to the social, economic and institutional development of the
communities in which we operate.
Principle 10. Implement effective and transparent engagement, communication and
independently verified reporting arrangements with our stakeholders.
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Box 3.
The 10 ICMM principles: Unpacked
Principle 1
Implement and maintain ethical business practices and sound systems of corporate governance.
develop and implement company statements of ethical business principles, and practices that management is committed to enforcing
implement policies and practices that seek to prevent bribery and corruption
comply with or exceed the requirements of host-country laws and regulations
work with governments, industry and other stakeholders to achieve appropriate and effective public policy, laws, regulations and procedures that facilitate the mining, minerals and metals sector’s contribution to sustainable development within national sustainable development strategies.
Principle 2
Integrate sustainable development considerations within the corporate decision-making process.
integrate sustainable development principles into company policies and practices
plan, design, operate and close operations in a manner that enhances sustainable development
implement good practice and innovate to improve social, environmental and economic performance while enhancing shareholder value
encourage customers, business partners and suppliers of goods and services to adopt principles and practices that are comparable to our own
provide sustainable development training to ensure adequate competency at all levels among our own employees and those of contractors
support public policies and practices that foster open and competitive markets.
Principle 3
Uphold fundamental human rights and respect cultures, customs and values in dealings with employees and others who are affected by our activities.
ensure fair remuneration and work conditions for all employees and do not use forced, compulsory or child labour
provide for the constructive engagement of employees on matters of mutual concern
implement policies and practices designed to eliminate harassment and unfair discrimination in all aspects of our activities
ensure that all relevant staff, including security personnel, are provided with appropriate cultural and human rights training and guidance
minimize involuntary resettlement, and compensate fairly for adverse effects on the community where they cannot be avoided
respect the culture and heritage of local communities, including Indigenous Peoples.
Principle 4
Implement risk management strategies based on valid data and sound science.
consult with interested and affected parties in the identification, assessment and management of all significant social, health, safety, environmental and economic impacts associated with our activities
ensure regular review and updating of risk management systems
inform potentially affected parties of significant risks from mining, minerals and metals operations and of the measures that will be taken to manage the potential risks effectively
develop, maintain and test effective emergency response procedures in collaboration with potentially affected parties.
Principle 5
Seek continual improvement of our health and safety performance.
implement a management system focused on continual improvement of all aspects of operations that could have a significant impact on the health and safety of our own employees, those of contractors and the communities where we operate
take all practical and reasonable measures to eliminate workplace fatalities, injuries and diseases among our own employees and those of contractors
provide all employees with health and safety training, and require employees of contractors to have undergone such training
implement regular health surveillance and risk-based monitoring of employees
rehabilitate and reintegrate employees into operations following illness or injury, where feasible.
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Box 3. Continued
Principle 6
Seek continual improvement of our environmental performance.
assess the positive and negative, the direct and indirect, and the cumulative environmental impacts of new projects – from exploration through closure
implement an environmental management system focused on continual improvement to review, prevent, mitigate or ameliorate adverse environmental impacts
rehabilitate land disturbed or occupied by operations in accordance with appropriate post-mining land uses
provide for safe storage and disposal of residual wastes and process residues
design and plan all operations so that adequate resources are available to meet the closure requirements of all operations.
Principle 7
Contribute to conservation of biodiversity and integrated approaches to land use planning.
respect legally designated protected areas
disseminate scientific data on and promote practices and experiences in biodiversity assessment and management
support the development and implementation of scientifically sound, inclusive and transparent procedures for integrated approaches to land use planning, biodiversity, conservation and mining.
Principle 8
Facilitate and encourage responsible product design, use, re-use, recycling and disposal of our products.
advance understanding of the properties of metals and minerals and their life-cycle effects on human health and the environment
conduct or support research and innovation that promotes the use of products and technologies that are safe and efficient in their use of energy, natural resources and other materials
develop and promote the concept of integrated materials management throughout the metals and minerals value chain
provide regulators and other stakeholders with scientifically sound data and analysis regarding our products and operations as a basis for regulatory decisions
support the development of scientifically sound policies, regulations, product standards and material choice decisions that encourage the safe use of mineral and metal products.
Principle 9
Contribute to the social, economic and institutional development of the communities in which we operate.
engage at the earliest practical stage with likely affected parties to discuss and respond to issues and conflicts concerning the management of social impacts
ensure that appropriate systems are in place for ongoing interaction with affected parties, making sure that minorities and other marginalized groups have equitable and culturally appropriate means of engagement
contribute to community development from project development through closure in collaboration with host communities and their representatives
encourage partnerships with governments and non-governmental organizations to ensure that programs (such as community health, education, local business development) are well designed and effectively delivered
enhance social and economic development by seeking opportunities to address poverty.
Principle 10
Implement effective and transparent engagement, communication and independently verified reporting arrangements with our stakeholders.
report on our economic, social and environmental performance and contribution to sustainable development
provide information that is timely, accurate and relevant
engage with and respond to stakeholders through open consultation processes.
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B. CONTEXUALISING RBPLAT
1. The Legislative and Good Practice Context of RBPlat
Figure 1 and 2 clearly illustrate the relationship between key sustainability legislation,
best practice codes, and RBPlat as described in the preceding sections.
From a legislative point of view (Fig. 1) the Social and Ethics Committee of the Board is
responsible for providing oversight for the sustainability activities of the company and
the reporting thereon. From a code of good practice point of view, King III recommends
the development of an integrated report that integrates the corporate financial,
governance and sustainability components in a comprehensive, material, and transparent
manner. The role of the Audit and Risk Committee of the Board is to assure the credibility
of the report through an external, impartial and independent assurance process. Both
committees are therefore responsible for bringing any pertinent sustainability matters to
the attention of the Board and reporting appropriately to the shareholders and other
stakeholders on issues of materiality.
Figure 2 illustrates the unpacked constituents of the Companies Act, King III and the
UNGC to reflect their cornerstone principles and similarities. Other pertinent codes of
good practice and guidelines include the CRISA, the UN-PRI, and the JSE SRI Index. The
broad UNGC Principles (Box 1 included in the Companies Act) are further unpacked by
the industry specific 10 Principles of the International Council on Mining and Minerals
(Boxes 2 & 3) as described in Section 1.
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South African Constitution Act
108 (1996)
Companies Act No 71 (2008)
Companies Regulations
(2011)
Other relevant legislation
Social & Ethics Committee
RBPlat Board
Risk & Audit Committee
King III (2009) & Framework for
Integrated Reporting (2011)
(JSE & JSE-SRI Index requirement)
Integrated Report (& assurance)
Sustainability & the Integrated reporting
Journey
Legislation Code of Good Practice
Fig 1: Legislative & good practice context of RBPlat
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Legislation
Companies Act No 71 (2008)
Companies Regulations (2011) King III (2009)
Code of Good Practice Company’s Voluntary Commitment
Draft Framework for Integrated Reporting
(2011)
UNGC Principles
JSE SRI Index
Consumer relations & protection,
advertising, PR ILO Protocol
Education development of
employees
Unfair discrimination Reduction of
corruption
Community development, sponsorships, donations &
charity
UNGC
Equality
EE Act
BBBEE Act
Environment
Health & Public Safety incl .
Products and services
ILO Declaration on Fundamental
Principles and Rights to Work
Universal Declaration of Human Rights
Rio Declaration on the Environment and
Development
UN Convention Against Corruption
Company social, environmental, labour, broader
economic, governance and
financial integration
Fig 2: Legislative and good practice context of RBPlat:
details
CRISA
UN-PRI
ICMM Principles
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2. The RBPlat Social and Ethics Committee: Interpreted Responsibilities
and Implications
i. Responsibilities
Based on the legislative requirements and codes of good practice guidelines
described in the aforementioned sections, the following responsibilities have been
interpreted for the RBPlat Social and Ethics Committee is as follows:
provide direction and oversight with respect to the company’s impact on
society (internal social and external social issues), the broader economy and
the natural environment.
govern the pillars of sustainability through a company Sustainability Policy,
Code of Ethics/Conduct and other pertinent policies such as an Environmental
Policy, Occupational Health and Welfare Policy, and the Anti-Fraud and
Corruption Policy amongst others.
ensure compliance with relevant legislation such as the Skills Development
Act, Employment Equity Act, National Environmental Management Act and the
Broad Based Back Economic Empowerment Act amongst others.
ensure compliance with relevant legislation in other countries of operations,
complying with internationally accepted codes of practice and UN
declarations3 such as the:
o Universal Declaration of Human Rights (1948)
o International Labour Organisations Declaration on Fundamental Principles
and Rights to Work (1998)
o Rio Declaration on the Environment and Development (1992)
o United Nations Convention against Corruption (1992)
especially where legislation is inadequate or unavailable.
follow the recommendations of best practice codes such as King III, and
adopting internationally accepted principles such as that contained within the
UNGC, amongst others.
ensure that relevant legislation, sustainability principles and codes of best
practice are embedded in the core business areas of the company and in the
corresponding business processes.
give due consideration to product and service safety and impact from a
product “cradle-to-cradle” perspective.
support responsible competitiveness through advertising and other
interactions with the public.
bring to the Board’s attention any company matters that may result in an
adverse effect on the any of the pillars of sustainability .
3 http://www.unglobalcompact.org/AboutTheGC/TheTenPrinciples/index.html
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report on the company’s activities in an integrated manner using
internationally and nationally accepted reporting guidelines such as the ISO
26000, GRI-G3/4 and the King III Integrated Reporting guidelines.
ii. Implications
Based on the responsibilities of the Social and Ethics Committee listed above, the
following broad company implications are noted:
Establishment of a Sustainability Committee at the management level to drive
and support the implementation of sustainability measures.
Declaration of leadership accountability and responsibility for all sustainability
matters.
Appointment of an executive reporting directly to the CEO on strategic matters
associated with sustainability and integrated reporting.
Assessment of the company’s sustainability baseline, determination of a
preferred status, and prioritisation of sustainability gaps.
Engagement of stakeholders on sustainability matters that affect them and/or
the company and consequent consideration of these material issues at the
governance and strategic levels of the company.
Development and implementation of a short term and long term sustainability
agenda, inclusive of an integrated reporting agenda.
Inclusion of sustainability in the vision and mission statement of the company,
and in the company values.
Development and approval of relevant company policies that address the
pillars of sustainability, such as a Sustainability Policy, Stakeholder Policy,
Codes of Conduct/Ethics, and Environmental Policy, amongst others.
Review of existing policies to integrate issues of sustainability.
Integration of sustainability issues into the company strategy and core
operations; including risk management, internal audit and quality
management.
Monitoring and evaluation of the company’s impact on society, the
environment and broader economy.
Mitigation or avoidance of negative impacts.
Awarding and rewarding sustainability practices.
Public disclosure (via an Integrated Report) on the financial and “non-financial”
impact of the company.
Obtaining third-party, independent and impartial assurance of the Integrated
Report.
Consideration of the company’s UNGC signatory status and adoption of
internationally accepted standards such as the Global Reporting Initiative -
G3/4 reporting guidelines and Accountability Standards amongst others.
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3. Sustainability Value Proposition
Taking cognizance of the aforementioned legislation, codes of good practice, standards
and guidelines, and choosing to embed them into the core business and associated
process will support the long term sustainability of the company whilst creating and
sustaining value for all stakeholders. From a ‘business case’ point of view the benefits
are as follows:
Assurance of long-term financial sustainability of the company.
Pre-emption of potential challenges and barriers to business strategies and
plans.
Improvement of the health and safety of employees and surrounding
communities.
Improvement of risk management.
Improvement of quality management.
Improvement of company reputation (greater trust, credibility and confidence
amongst shareholders, employees and other stakeholders).
Informed decision making by:
o company leadership and management (once all the social, environmental
and economic implications and consequences of decisions and actions
become clear).
o strategic stakeholders (thereby influencing their impact on the company).
o shareholders (thereby influencing investment choices made by
shareholders).
Use of the sustainability agenda as a team building tool (to energise, inspire
and personalise the work place, attract and retain talented employees, create
an identity, incentivise productivity and innovation, etcetera).
Cost savings as a result of improved processes and services, and efficiency and
effectiveness of processes.
Innovation and exploration of new opportunities.
Built-in resilience to challenges and barriers.
Contribution to the company’s sustainability ranking.
Improvement in competitiveness.
Promotion of internationalization.
Attraction of investment.
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4. Critical Risk Factors
Ensuring leadership understanding and commitment to sustainability is essential for the
success of any sustainability agenda. Furthermore, the agenda, policies and frameworks
need to be understood as part of an evolutionary journey, implementation of which may
result in some failures, however successes are inevitable through engagement, learning
and innovation which will be beneficial for all stakeholders. As a company embarks on
developing, establishing and embedding sustainability principles into the core of the
business, some common pitfalls and barriers need to be borne in mind to avoid failure
of the initiative at the outset. Hence steps need to be taken to ensure:
Prioritisation of sustainability at all corporate levels
Company-wide understanding of corporate sustainability and the embedded
importance thereof
Integration of sustainability within the core business
Availability, integrity and verifiability of information
Availability of resources
Comprehensive engagement of appropriate stakeholders
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C. APPROACH TO DEVELOPING THE RBPLAT SUSTAINABILITY
FRAMEWORK
1. Overview This document presents a framework for a business concept that does not necessarily
comply with other standard business processes where decisions and actions can be
predetermined and submitted for implementation according to a set formula.
Sustainability requires extensive engagement of relevant (internal and external)
stakeholders to ensure the relevance and feasibility of the framework and subsequent
initiatives. Engagement processes prevent possible defensive or resistant responses,
instead engagement promotes buy-in and importantly, ownership of the decisions that
need to be taken to embark on a sustainable business journey.
Hence care has been taken in the development of this document to ensure that it
serves as a guiding framework as opposed to a predetermined structure that is closed
to review by all parties at all levels. Often suggestions are made to serve as an
illustrative example of the idea in mind (for example, the development of an
overarching theme for RBPlat’s sustainability agenda is suggested to be ‘responsible
leadership’; this is not meant to be prescriptive but rather a suggestion made by a
singular person which may not be suitable to the company leadership or the company
itself and therefore the idea of a theme, and what that theme should be, needs to be
interrogated by the relevant company stakeholders).
2. Approach With reference to the legislation and good practice guidelines described in the
preceding section, a 4 step-by-step approach to sustainability as RBPlat is proposed
that will be described in the sections to follow. The steps are as follows:
1. Step 1: Identification of a personalized theme for RBPlat’s sustainability agenda
to assist in the championing and communication of the company’s sustainability
drive.
2. Step 2: Development of overarching corporate guidelines for sustainability to
inform the development of the stakeholder engagement and sustainability
frameworks.
3. Step 3: Development of a stakeholder engagement framework to support the
development, establishment, implementation and relevance of the sustainability
framework.
4. Step 4: Development of a sustainability framework to outline the strategic level
actions, roles, responsibilities and timelines.
20
The sustainability framework is further unpacked into 5 implementation phases as
follows:
1. Phase 1: Realignment of the company profile.
2. Phase 2: Reviewing of corporate governance.
3. Phase 3: Integration of sustainability and risk management.
4. Phase 4: Establishment of a Sustainability Committee.
5. Phase 5: Integration of sustainability into existing management processes -
Establishment of internal roles and responsibilities for sustainability.
D. STEP 1: THE RBPLAT OVERARCHING THEME
Before embarking on the development of RBPlat’s sustainability framework it is pertinent to
develop an overarching theme for sustainability to exhibit the level of importance of the
concept within all aspects of the Company’s operations; from governance and strategy, through
to implementation and reporting. This easily identifiable and personalized theme must be able
to resonate with all RBPlat’s stakeholders as they in turn embrace and replicate the theme in
their own areas of authority.
The theme of ‘Responsible Leadership’ is proposed. Box 4 provides an overview of what this
terminology could mean to the company. The theme was identified based on the level of
importance assigned to ethical issues by the Company Board and the CEO. If approved, it is
imperative that the company’s leadership stance on ethics and sustainability within this theme
is developed and communicated within all areas of the business.
Box 4: Defining the theme.
Responsible leadership: value based, ethically driven
relationships between leaders and stakeholders who are
connected through a shared sense of meaning or purpose
through which they raise one another to higher levels of
motivation and commitment for achieving sustainable value
creation and social change (Maak & Pless, 2011).
A Responsible leader reconciles the idea of effectiveness with
the idea of responsibility by being an active citizen inside and
outside the organisations (Maak & Pless, 2011).
Responsible leader’s question: For what and to whom am I
responsible?
21
E. STEP 2: THE RBPLAT SUSTAINABILITY FRAMEWORK GUIDELINES
To support the human rights, labour, environmental, and economic principles (sustainability
pillars) contained in legislative and good practice codes described earlier, the following broad
sustainability guidelines have been developed and used in the development of the RBPlat
stakeholder engagement framework and sustainability framework. Guidelines are essential in
establishing the company’s overarching intention and approach; and they ensure that key issues
are included within the sustainability framework and consequent implementation plans.
Overarching Guidelines
Lines of accountability and responsibility for sustainability impact will be established.
Company stakeholders will be regularly consulted and engaged on various aspects of
sustainability to gauge materiality, risk and opportunities.
Sustainability principles will be integrated within the company’s governance, strategy,
planning, implementation, monitoring and evaluation, review, impact assessment,
assurance and public disclosure.
Sustainability principles will be applicable within the company’s sphere of influence,
namely, amongst all company suppliers, partners and other service providers (to
ensure that RBPlat is not indirectly complicit in human rights abuses, environmental
degradation and other irresponsible business practices).
Public disclosure on sustainability matters will be integrated with financial and
governance disclosure; and the contents thereof will be independently assured.
Governance Guidelines
Accountability for sustainability lies with the RBPlat Board.
Sustainability will be supported by relevant governance structures and policies, and
integrated into current and new policies.
The Board and Social and Ethics Committee will provide appropriate oversight on
sustainability matters and engage with relevant stakeholders accordingly.
Management Guidelines
Responsibility for sustainability lies with the RBPlat leadership (CEO and EXCO).
Sustainability will be embedded within the company’s vision, mission, values, strategy,
and operational plans.
Key impact performance indicators will be developed in consultation with relevant
stakeholder groups.
The cost of embedding sustainability will be included in operational costs.
Planning and implementation will allow for flexibility to enhance or mitigate
sustainability outcomes and impact.
Company processes must provide the information required to understand the social,
economic and environmental impact of company actions and decisions.
Human resource training, and communication and awareness campaigns for successful
implementation, will be established.
22
Information gleaned from monitoring and evaluation, company reviews, and other
assessment and reporting processes will be used to inform decision making.
Rewards and awards will be linked to sustainability performance.
Stakeholder Engagement Guidelines
Stakeholders will be identified, categorised and directly engaged stakeholders on issues
that are material to them and the company.
Material stakeholder concerns will be addressed in the company planning and decision-
making processes.
Concerns of potentially marginalised or vulnerable groups will be given special
consideration.
Impact of company activity will be assessed, and outcomes will be disclosed to
stakeholder groups.
Reporting Guidelines
Company financial and governance information will be disclosed in an integrated
manner with strategic, material, “non-financial” information.
Reporting will be accurate, reliable, quantitative and qualitative, engaged, relevant,
transparent, complete, inclusive, understandable, forward-looking, material and
impact associated.
Assurance Guidelines
Process of internal validation and external assurance will be established to improve
implementation processes and credibility of reporting.
External assurance will be 3rd party, independent and impartial, and inclusive of
engagements with relevant stakeholders.
23
F. Step 3: The RBPlat Stakeholder Engagement Framework
1. Overview The importance of stakeholder engagement in corporate sustainability cannot be
overemphasized. A stakeholder is generally understood to be any individual or group of
individuals that can affect or be affected by the activities of a company4.
Stakeholders are ultimately responsible for a company’s licence to operate since they
experience the impact of corporate activities and therefore have various means at their
disposal to inhibit the day-to-day or long-term functioning of a company.
Engagement with various stakeholder groups in a meaningful manner provides a
company with a ‘sustainability lens’ through which the company can view the impact of
its activities from a governance and management perspective. Therefore the main aims
of the engagement process is to:
determine what are the stakeholder’s material issues.
determine what are the company’s material issues.
determine the impact of the company on the pillars of sustainability.
reduce/mitigate negative impacts or scale-up/enhance positive impacts for
stakeholders.
determine company’s risks and opportunities.
Engagement with relevant stakeholders needs to take place during all phases of
business, from conception, through to implementation, monitoring and evaluation,
reporting and assurance. All corporate activity will affect one or more of the
sustainability pillars (environmental, social or economic) hence the consequent impacts
need to be predetermined and interrogated to support positive outcomes with
minimum (preferably zero) negative impacts.
2. Stakeholder Engagement Standards
For the development of the stakeholder engagement framework, the following national
and international standards were consulted were taken into consideration:
King III Code of Governance Principles for SA (2009)
King III Draft Framework for Integrated Reporting and the Integrated Report (2011)
GRI-G4 (and mining supplement) (2013)
ISO 26000 (International standards organisation - 2010)
AA 1000 SES (Accountability - stakeholder engagement standard - 2011)
4 Reference to a ‘stakeholder group’ in this document, includes individuals who may not belong to a group
per se.
24
AA 1000AS (Accountability - assurance standard -2008)
JSE SRI Index (2011)
ISAE3000 (international standard on assurance engagements - 2005)
IIRC Draft Framework (International Integrated Reporting Committee - 2013)
3. Purpose of Stakeholder Engagement
Stakeholder engagement should seek to achieve the following outcomes:
Develop and sustain company awareness of broader social, economic and
environmental risks and opportunities
Ensure accurate information dissemination to stakeholders
Ensure aligned goals and expectations
Support consensus-based decision-making
Ensure transparency
Establish responsibility and accountability of all parties
Establish and maintain trust in the company and its leadership
Support sustainability and relevance of company activity for value creation for all
stakeholders
4. Engagement Challenges and Pitfalls
The engagement process does pose specific challenges for which the company and
engagement facilitators needs to be prepared; these challenges and possible pitfalls may
be as follows:
Only primary stakeholders who are directly affected by company are engaged.
Only stakeholders who have transport/access to engagement sites are engaged.
Only stakeholders who speak a certain language can participate.
Only confident, articulate, educated or affluent sectors of society are engaged.
Engaging stakeholders through a third party representative who may not have the
mandate or insight to speak on behalf of the stakeholder; and who may also
misrepresent or misunderstand the materiality of the stakeholder’s issues.
Focusing on the most vocal or disruptive stakeholder groups.
Addressing short-term media interrogation after an incident as opposed to
proactive on-going engagement function.
Focusing on non-antagonistic stakeholders only (staying within the company’s
comfort zone).
Raising expectations of stakeholders who are beneficiaries of company activity
e.g. communities.
Stakeholder pressure on facilitators to make decisions/promises on behalf of the
company without consultation with relevant company authorities.
25
Overlooking marginalised (voiceless or disempowered) groups or individuals.
Unhealthy competition or conflict amongst stakeholder groups.
Differing stakeholder priorities.
Misconceptions amongst stakeholders.
Negative changes in community social networks as a result of company activity.
Differing interpretation of outcomes and impact amongst stakeholders and
between stakeholders and the company.
Scope of impact assessment too wide and not focused on important aspects of
impact.
Scope of impact assessment too narrow and does not sufficiently cover all
issues.
Unmanageable number of indicators in assessing impact of company activity.
Company personnel changes disrupts continuity of rapport with stakeholders.
Uncooperative stakeholders.
Stakeholders exhibiting excessive dependency on the company
Unrealistic expectations of the company from stakeholders and vice versa
Unreliable information - e.g. stakeholders providing information they think the
facilitator wants to hear (fear of losing opportunities if the company is
criticised).
Possible fraud/corruption through private engagement processes between
company representatives and stakeholders.
5. High Level Engagement Steps
Initially a high level generic engagement framework is required to ensure that
stakeholders are appropriately identified, engaged and responded to at all governance
and management levels.
This section provides a high level step-by-step approach to stakeholder engagement in 3
distinct areas (Fig. 3):
i) Before the engagement
ii) During the engagement
iii) After the engagement
26
i. Before the Engagement
Before the engagement process, stakeholders needs to be identified,
categorised and prioritised.
Identifying stakeholders
To identify stakeholders the following questions need to be asked5:
o To whom does the organization have legal obligations?
o Who might be positively or negatively affected by the organization's
decisions or activities?
o Who is likely to express concerns about the decisions and activities of the
organization?
o Who has been involved in the past when similar concerns needed to be
addressed?
o Who can help the organization address specific impacts?
o Who can affect the organization's ability to meet its responsibilities?
o Who would be disadvantaged if excluded from the engagement?
o Who in the value chain is affected?
As a result, Table 1 provides a preliminary list of stakeholders that have been
identified as RBPlat stakeholders.
5 ISO 26000
27
1. Identify Stakeholders
2. Categorise and prioritise stakeholders
3. Determine mode and frequency
of engagement
4. Determine
internal roles and
responsibilities
5. Brief stakeholder
s prior to engagement
6. Establish rules of
engagement
7. Achieve objectives
8. Determine
material issues
9. Determine roles and
responsibilities
8. Respond to material
issues
9. Assess impact
10. Feedback to stakeholder
s
11. Learn and
improve
Key:
Before the engagement
During the engagement
After the engagement
Fig 3: Stakeholder Engagement Steps
28
Table 1: RBPlat Stakeholder Groups6
Stakeholder Group Stakeholders Include
Shareholders
Royal Bafokeng Holdings (RBH)
Anglo Platinum Limited
De Beers
Minority Shareholders
o Investors
o Analysts
Employees
BRPM Management (Paterson D1 and above)
BRPM Permanent Employees (Paterson A1 – C5)
BRPM Contractors
Styldrift Contractors
Community
Royal Bafokeng Nation - Office of Kgosi
Royal Bafokeng Nation - Supreme Council
Royal Bafokeng Administration (RBA)
Royal Bafokeng Institute ( RBI)
Robega Village
Chaneng Village
Rasimone/Mafenya Villages
Community Leaders (Councillors & Kgotlas on RBN land)
Community Religious Organizations
Local and neighbouring farmers
Local farmer associations
Sun City
Specialist groups (Women, youth)
Department of Minerals Resources
(DMR)
DMR National (Pretoria)
DMR Regional (Klerksdorp)
Municipality (ies)
Rustenburg Local Municipality
Moses Kotane Local Municipality
Bojanala District Municipality
Trade Unions Trade Unions - National Union of Mineworkers (NUM)
Union of Associations of South Africa (UASA)
Suppliers
Major Suppliers (ESKOM, Magalies Water)
Other major suppliers (mining and plant related)
Sub-Contractors
Indirect employees (employees of suppliers)
Customers Anglo Platinum Limited
Neighbouring Mines/projects
Impala Platinum Limited
Rustenburg Platinum Mines Limited (RPM)
Xstrata/Merafe Resources Limited;
Wesizwe Platinum Limited;
Western Bushveld JV
Other industry peers
Media
Newspapers
Business day
Star – business report
Beeld
Miningmx
Mining weekly
Financial mail
Segoagoa (Phokeng newspaper)
CNBC/Summit/SABC/ Alec Hogg/Classic FM/702
Department of Labour
6 From RBPlat Stakeholder Engagement Framework 2011 (revised)
29
Table 1: RBPlat Stakeholder Groups6
Stakeholder Group Stakeholders Include
Government
Department of Education
Department of Health
Department of Water Affairs
Department of Environment Affairs
Department of Safety and Security
Department of Housing
Department of Traditional Affairs and Cooperative Governance
North West Dace
Department of Rural Development and Land Reform
Non-Governmental Organizations
(NGOs, CBOs, FBOs) Recognised NGOs, CBOs, FBOs
International industry bodies International Platinum Group Metals Associations (IPA)
Platinum Guild International (PGI)
National industry bodies
Chamber of Mines of South Africa
Business Unity South Africa (BUSA)
Southern African Institute of Mining and Metallurgy (SAIMM)
National Business Initiative (NBI)
Sustainability stakeholders
JSE Socially Responsible Investment Index (JSE SRI Index)
United Nations Global Compact (UNGC)
Carbon Disclosure Project
Auditors/assurance providers Certification bodies – ISO 1400, OHSAS 1800,
Integrated Report assurance provider
In identifying stakeholders, the common pitfalls of focusing narrowly on the company’s economic
issues only, or on the risk and opportunities that stakeholder engagement may reveal should be
avoided. Giving consideration to the material issues of the company only, or to material issues of
stakeholders that can affect the company only, thereby ignoring the material issues that affect
stakeholders as well (that may or may not affect the company but are still material to the
stakeholders and are therefore important) is also detrimental.
In essence, everyone has a stake in a company if the conduct of the company in any way affects
the moral rights of that individual (therefore the relationship does not have to be direct as in
the case of employees, but can be indirect through ripple effects from any corporate activity on
any stakeholder).
To supplement Table 1, existing information channels and corporate networks must be used to
engage with all stakeholder groups indicating which stakeholder groups have been identified by
the company and invite input on the identification of additional stakeholder groups.
Categorising and prioritising stakeholders
Categorization of stakeholders is based on the level of importance of the stakeholder in relation
to the stakeholder’s impact on the company and vice versa (such as level of impact, influence,
dependency, responsibility, tension, representation, proximity, etcetera). Using the matrix in Fig.
4 the axes can be changed to reflect the type or magnitude of the impact the company is
30
assessing. Fig. 4 is an example of categorisation and prioritisation with the variables being
‘importance for engagement’ and ‘importance for positive sustainable impact’.
Once the stakeholders have been categorised and prioritised, the objective and scope of
engagement for each group (motives for engagement could include potential legal, financial,
social or environmental risk) needs to be determined. A strategy for engagement also needs to
be developed to ensure that the key principles of inclusivity, materiality and responsiveness are
included. Consideration needs to be given to the stakeholder’s willingness to engage, knowledge
of the issues, potential expectations, inclusion of marginalized or “voiceless” stakeholders, fear of
victimization, conflict of interest, cultural difference, volatility of issues to be discussed, etcetera).
Keep informed: External auditors Organised business Industry peers
Manage closely and maintain regular dialogue: Governments (International, national, provincial & local) JSE & JSE SRI Index Media Civic “watch-dogs” UNGC International Extractive Industry Bodies
Maintain high level of dialogue and keep satisfied: Business partners Shareholders/investors
Manage very closely and maintain very high level of dialogue: Board (Audit & Social and Ethics Committee) EXCO Employees & unions Business units (Operations, logistics, etc) Other support units (IT, HR, etc) Suppliers Communities Indirect employees
Low High
Hig
h
Imp
ort
ance
fo
r e
nga
gem
en
t
Importance for positive sustainability impact
Low
Fig 4: Categorising and prioritizing stakeholders using a variety of criteria
31
Determine mode and frequency of engagement
Based on the categorization of the stakeholder groups, Table 2 provides a guide on the types of
engagement processes that can be followed based on the objectives of the engagement and the
nature of the relationship between the company and the stakeholder.
Table 3 unpacks the RBPlat stakeholders that have been identified, reflects the drivers for
engagement, raises potential key issues, and describes the mode, frequency and names
appropriate company facilitators for the engagement process.
Various tools are available to support differing types of engagement (eg. Anglo American Socio-
Economic Assessment Toolbox (SEAT)7 for community assessment; the International Finance
Corporation: Stakeholder Engagement8 in emerging markets, etcetera).
Determine internal roles and responsibilities
Once the appropriate stakeholder engagement facilitator is identified, s/he needs to obtain
appropriate training for the facilitation process to ensure that the process is professionally
managed in terms of protocol and process.
Briefing the stakeholders prior to engagement
Relevant briefing material needs to be provided to the stakeholders in advance of the
engagement in the appropriate language and format to suit the stakeholder. Potentially
marginalized or vulnerable individuals/groups must be able to physically access the engagement
process. Steps must be taken to ensure an intimidation free engagement process and a grievance
mechanism needs to be established to ensure that any engagement process issue can be
escalated to the appropriate corporate authority.
7 Anglo American plc (Anglo) has made its Socio-Economic Assessment Toolbox (SEAT) freely available as a
contribution to managing the socio-economic impacts of extractive, other natural resource and industrial operations. 8 International Finance Corporation: Stakeholder Engagement. A Good Practice Handbook for Companies
Doing Business in Emerging Markets.
32
9 From RBPlat Stakeholder Engagement Framework 2011 (reviewed)
Table 2: Guide to types of Engagement 9
Level Goal Communication Nature of Relationship Engagement Approaches
Monitor Monitor stakeholders’
views.
One-way: stakeholder to
Company.
No immediate
relationship
Media and internet tracking.
Second-hand reports from other
stakeholders.
Inform Inform or educate
stakeholders.
One-way: company to
stakeholder, there is no
invitation to reply.
Short or long term
relationship with
stakeholders.
"We will keep you
informed."
Bulletins and letters. Brochures, reports and
websites. Speeches, conference and public
presentations.
Open houses and facility tours. Road shows
and public displays. Press releases, press
conferences, media advertising, lobbying.
Transact
Work together in a
contractual
relationship where
one partner directs
the objectives and
provides funding.
Limited two-way: setting and
monitoring performance
according to terms of
contract.
Relationship terms set by
contractual agreement.
“We will do what we said
we would” or “we will
provide the resources to
enable you to do what
we agree”.
‘Public Private partnerships’ and Private
Finance Initiatives, Grant-making, cause
related marketing.
Consult
Gain information and
feedback from
stakeholders to inform
decisions made
internally.
Limited two-way: company
asks questions and the
stakeholders answer,
stakeholders raises other
issues.
Short- or long-term
involvement.
"We will keep you
informed, listen to your
concerns, consider your
insights, and provide
feedback on our
decision."
Surveys. Focus Groups. Workplace
assessments. One-to-one meetings.
Public meetings and workshops.
Standing stakeholder advisory forums.
On-line feedback and discussion.
Involve
Work directly with
stakeholders to
ensure that their
concerns are fully
understood and
considered in decision
making.
Two-way, or multi-way
between company and
stakeholders. Learning takes
place on both sides.
Stakeholders and company
take action individually. There
is responsibility on both sides.
May be one-off or
longer-term
engagement. "We will
work with you to ensure
that your concerns are
understood, to develop
alternative proposals and
to provide feedback
about how stakeholders
views influenced the
decision making
process”.
Multi-stakeholder forums.
Advisory panels. Consensus building
processes.
Participatory decision making processes.
There is responsibility on both sides.
Collaborate
Partner with or
convene a network of
stakeholders to
develop mutually
agreed solutions and
joint plan of action.
Two-way, or multi-way
between company/ies and
stakeholders. Learning,
negotiation and decision
making on both sides.
Stakeholders work together to
take action.
There is responsibility on both
sides.
Long- term. "We will look
to you for direct advice
and participation in
finding and implementing
solutions to shared
challenges.”
Joint projects, voluntary
two-party or multi-stakeholder
Initiatives, Partnerships.
There is responsibility on both sides.
Empower
Delegate decision-
making on a particular
issue to stakeholders.
New organizational forms of
accountability:
Stakeholders have formal role
in governance of an
organisation or decisions are
delegated out to stakeholders.
There is responsibility on both
sides.
Long-term. “We will
implement what you
decide.”
Integration of Stakeholders into Governance
Structure. (E.g. as members, shareholders or
on particular committees, etc.)
There is responsibility on both sides.
33
Table 3: Stakeholder Engagement Process10
Name of
Stakeholder Representative(s)
Key Drivers of
Engagement Level of
Engagement Key Issues Potential Concerns
Method of
Engagement or Media Frequency
Primary
Responsibility
Shar
eh
old
ers
Royal Bafokeng
Holdings (RBH)
Anglo American -
Platinum
Minority Shareholders
Local
employment,
local
procurement,
Social
development,
Environmental
conservation,
operational
performance,
Styldrift project
development
Transact;
Consult;
Involve;
Collaborate
SLP/ Mining Charter/
Transformation
Health & Safety
Licence to operate;
employment equity;
safe working conditions & zero
fatalities;
achieving production
Board Meetings
Regular
technical and
communication
meetings
Board
CEO
Investment
relations
manager
Operational performance
Implementation progress;
meeting targets; dividend
payment
Quarterly Reports Quarterly Sustainability
Project development
Technical Performance
SLP/ Mining Charter/
Transformation Implementation progress;
meeting targets;
compliance
Road shows
Integrated Annual
Reports
Presentations at
conferences
Half-year results
Press
announcements
SENS
Annually
Technical Performance Timely delivery of project;
funding;
ability to operate;
ability to be profitable
Emp
loye
es
BRPM Management
(Paterson D1 and
above)
BRPM Permanent
Employees (Paterson
A1 – C5)
BRPM Contractors
Human,
Economic, Legal &
Transformation
Inform;
Transact;
Consult;
Involve;
Collaborate;
Empower
Health & Safety Safe and healthy working
conditions - Lebone Newsletter
- Meetings -
Workshops, -
Posters, -
Booklets
- Industrial theatre
- Induction training
- Communication
Forums
- Skills Development
Weekly
CEO
HR Exec
GM’s
Change in working condition
as a result of new Company
Redundancy;
Loss of privileges; Conditions of
employment and benefits;
Lack of consultation
Discrimination/
Transformation
Racial transformation
Remuneration
Opportunities and
appointments
Training
10
From RBPlat Stakeholder Engagement Framework 2011 (revised)
34
Table 3: Stakeholder Engagement Process10
Name of
Stakeholder Representative(s)
Key Drivers of
Engagement Level of
Engagement Key Issues Potential Concerns
Method of
Engagement or Media Frequency
Primary
Responsibility
Social and Labour Plan/
Mining Charter/
Career development and
promotions;
housing
Committees
- Presentations
- Performance
Reviews
- Transformation
Committee
- CEO letter
- Open days
Latent friction between
contracting and permanent
staff
Optimising local opportunities;
Negotiating / bargaining power
(Minimum wage debates)
o Productivity and
wage bill
Co
mm
un
ity
Royal Bafokeng
Nation (RBN)
Royal Bafokeng
Administration
(RBA)
Royal Bafokeng
Institute( RBI)
RBED
Robega Village
Chaneng Village
Rasimone/ Mafenya
Villages
Community Leaders
Community
Religious
Organizations
Local and
neighbouring
farmers
Local farmer
associations
Sun International
Human,
Economic, Social,
Environmental,
Legal &
Transformation
Monitor;
Inform;
Transact;
Consult;
Involve;
Collaborate;
Empower
Non-Bafokeng on Bafokeng
land or Bafokeng
administrated land
Land use - less land available
for alternative uses;
informal settlements;
proximity of the mine;
disproportionate benefits to
RBH
Focus groups, local
representatives and
public meetings
Village council
meetings
Quarterly
CEO
GM’s
CSI manager
Preferential procurement
SMME development; training
and mentoring; procurement
policy implications;
capability and capacity of
suppliers to be determined;
processing / criteria / access to
information / timing Public meetings or
forums
Quarterly
Housing
Cracked housing:
Informal housing and resultant
social implications/issues;
Availability of land for houses;
RBN ownership of land versus
residents ownership of
property
Quarterly
Infrastructure
Development of roads etc.;
The rate of damage to
infrastructure versus cost and
rate of repair
Public meetings or
forums,
collaborative
projects
Quarterly
35
Table 3: Stakeholder Engagement Process10
Name of
Stakeholder Representative(s)
Key Drivers of
Engagement Level of
Engagement Key Issues Potential Concerns
Method of
Engagement or Media Frequency
Primary
Responsibility
Environmental
Noise;
Water usage and pollution;
Dust;
Land use from an agricultural
point of view
Focus groups Quarterly
Job Opportunities
Inherent expectation of
keeping current job and
availing more
Quality of the jobs
Public meetings or
forums Quarterly
Community Development
Variation from village to
village;
Need to effectively counter
negative impact of mine versus
Social Equity;
Sustainable poverty alleviation
and social upliftment;
Education: Residents of state
land cannot get bursaries or
financial aid
Education: Orphans and other
vulnerable groups caught in
vicious cycle due to lack of
education programs
Public meetings or
forums,
collaborative
projects
Village council
meetings
Monthly
Growing social impact of
mine
Sustainability beyond mining;
Health (HIV/AIDS prevalence
amongst “single” migrant
workers);
Women and young girls
increasingly vulnerable;
Increasing rate of rape and
other violent crime
(xenophobia, robberies)
Baseline Socio-
economic Survey Quarterly
Social and Labour Plan Lack of implementation of Public meetings or Quarterly
36
Table 3: Stakeholder Engagement Process10
Name of
Stakeholder Representative(s)
Key Drivers of
Engagement Level of
Engagement Key Issues Potential Concerns
Method of
Engagement or Media Frequency
Primary
Responsibility
commitments forums, brochures,
leaflets, posters
Trad
e U
nio
ns
Union of Associations
of South Africa
(UASA)
Trade Unions National
Union of
Mineworkers (NUM)
Human,
Economic, Social
& Transformation
Inform;
Transact;
Consult;
Involve;
Collaborate;
Empower
Social and Labour Plan Lack of implementation of
commitments; Unions’ views
Workshop, posters,
booklets Monthly
CEO
HR Exec
Housing Employee housing
Panels or
committees
Written
communication
Monthly
Job Opportunities Availability of jobs at Styldrift
Health & Safety Injuries and fatalities
Employment Equity Lack of HDSAs and women in
management positions
Remuneration (Collective
Bargaining) Increase in salaries
Future Forum Quarterly
Retrenchments Potential Retrenchments
Skills Development Non-mining portable skills Panels or
committees Quarterly
DM
R
DMR National
DMR Regional
Legal &
Transformation
Inform;
Consult;
Collaborate;
Social and Labour Plan/
Mining Charter Compliance /
Transformation
Fulfilment of mining charter
requirements
Meetings Quarterly CEO
Company
Secretary Site visits/
presentations Bi-annually
Annual Report Annually
Environmental Compliance Compliance with the EMP
Meetings Quarterly
Site visits/
presentations Bi-annually
Annual Report Annually
Health & Safety Compliance Increase in fatalities
Meetings Quarterly
Site visits/
presentations Bi-annually
Annual Report Annually
37
Table 3: Stakeholder Engagement Process10
Name of
Stakeholder Representative(s)
Key Drivers of
Engagement Level of
Engagement Key Issues Potential Concerns
Method of
Engagement or Media Frequency
Primary
Responsibility
Retrenchments Possible job losses Meetings Needs basis
Mu
nic
ipal
ity
Rustenburg Local
Municipality
Bojanala District
Municipality
Human,
Economic, Social,
Environmental &
Transformation
Inform;
Transact;
Consult;
Involve;
Collaborate;
Social and Labour Plan (Local
Economic Development,
Skills Development, Housing,
Job Opportunities,
Preferential procurement &
SMMEs)
Meetings or forums
Quarterly
CEO
GMs
CSI Manager
Revenue generation;
employment creation; regional
development Job creation
Informal settlements;
environmental damage
Partnerships,
collaborative
projects
Brochures, leaflets,
posters Annually
Sup
plie
rs Suppliers
Sub-Contractors
Economic, Social,
Environmental,
Legal &
Transformation
Inform;
Transact;
Consult;
Involve;
Collaborate;
Empower
Contract duration
Pricing
BBBEE Codes
Environmental
Health & Safety
What opportunities are there
to improve and expand our
business relationship with
RBPlat;
Compliance with Charter and
Codes;
Health & Safety of contractors
on site
One-on-one Quarterly Procurement
Exec
Meetings Quarterly
Workshops Bi-annually
Cu
sto
me
rs
Anglo Platinum Economic, Inform;
Transact;
Contract duration
Pricing
Quality of products
Product stewardship
Contract terms and delivery
Reliability of supply
Strong, ongoing customer
relationship
Meetings (BRPM JV
Manco)
Written
communication
Quarterly
CEO
Med
ia Investors
Analysts
Newspapers
Human,
Economic, Social,
Environmental,
Legal &
Monitor;
Inform;
Transformation/Mining
Charter
Transformation , Employment
Equity, Employing women Online information
and forums, annual
reports
Quarterly CEO
Investor
relations
manager Mining Right Compliance Legal and moral licence to
operate Quarterly
38
Table 3: Stakeholder Engagement Process10
Name of
Stakeholder Representative(s)
Key Drivers of
Engagement Level of
Engagement Key Issues Potential Concerns
Method of
Engagement or Media Frequency
Primary
Responsibility
Transformation
Environmental Compliance
Impact on the environment -
pollution;
Compliance with the EMP;
Rehabilitation
Quarterly
Sustainability
Exec.
Health & Safety Compliance Injuries and fatalities Quarterly
Impact on society Strike action Quarterly
Retrenchments Large scale retrenchments
Radio, television,
newspapers, public
meetings or forums
Needs basis
Transparency Withholding information
Newspapers,
brochures, leaflets,
posters
Annually
Human Rights Human rights violations
Newspapers,
brochures, leaflets,
posters
Annually
Ne
igh
bo
uri
ng
Min
es
Sustainability and
Mine Managers
Human,
Economic, Social,
Environmental,
Legal &
Transformation
Monitor;
Transact;
Consult;
Collaborate;
Licensing
Collaborative community
projects
Informal settlements
Environmental
Mining LED Forum
No specific concerns
One-on-one, panels
or committees,
partnerships,
collaborative
projects, non-
technical summary
documents and
reports
Quarterly
CEO
GMs
CSI Manager
Pro
vin
cial
Go
vern
m
ent
Department of Labour Legal &
Transformation,
Human,
Economic, Social,
Inform;
Transact;
Consult;
Involve;
Collaborate;
Employment Equity Meeting EE targets Focus groups, one-
on-one, road shows,
stakeholder
networks, panels or
committees, public
Quarterly CEO
Department of Water
Affairs Compliance
Integrated water use license;
water conservation Quarterly
39
Table 3: Stakeholder Engagement Process10
Name of
Stakeholder Representative(s)
Key Drivers of
Engagement Level of
Engagement Key Issues Potential Concerns
Method of
Engagement or Media Frequency
Primary
Responsibility
Department of
Education
Environmental
Skills Development
Schools support
Weak school system;
Low mats and science pass
rates;
Sponsoring teachers’ salaries
meetings or forums,
partnerships
including alliances,
collaborative
projects
Quarterly
Department of Health Clinics
Ambulances Poor health facilities Quarterly
Department of
Environment Affairs Environmental compliance Pollution , dust & noise Quarterly
Department of
Housing
Housing for employees;
Informal settlements
RBPlat’s contribution to low
cost housing;
Formalization of informal
settlements
Quarterly
Department of Safety
and Security Influx of non-locals Increase levels of crime Quarterly
Sou
th A
fric
an C
ham
ber
of
Min
es
South African
Chamber of Mines
Economic, Legal &
Transformation Inform;
Consult;
Various industry related
issues
Industry Sustainability
Nationalisation
Trade union relationships
Mine employee health and
safety
Focus groups, one-
on-one, stakeholder
networks, panels or
committees,
partnerships
including alliances,
collaborative
projects, non-
technical summary
documents and
report
Monthly and
other ad hoc
subcommittee
meetings
CEO
Sust
ain
abili
t
y Stak
eho
lder
s
JSE SRI Index Transparency,
ranking and
disclosure Reporting
Stakeholder engagement,
supporting sustainability
pillars, responsibility and
accountability for
sustainability
Fulfilling sustainability
principles
Setting and meeting targets
Public disclosure on
company website.
Direct submission of
reports
Annual
Risk and
Sustainability
Exec
UNGC
40
Table 3: Stakeholder Engagement Process10
Name of
Stakeholder Representative(s)
Key Drivers of
Engagement Level of
Engagement Key Issues Potential Concerns
Method of
Engagement or Media Frequency
Primary
Responsibility
Carbon Disclosure
Project
Au
dit
ors
an
d
assu
ran
ce
pro
vid
ers
Certification bodies –
ISO 1400, OHSAS
1800, amongst others
Certification and
assurance of
company’s
sustainability
activities
contractual
Stakeholder engagement,
supporting sustainability
pillars, accountability for
sustainability
Fulfilling sustainability
principles
Data integrity
Transparent and accurate
reporting
One-on-one
meetings Annual
Risk and
Sustainability
Exec
Integrated report
assurance provider
NG
Os
Local and
international NGOs
Human, Social,
Environmental,
Legal &
Transformation
Monitor;
Inform;
Consult;
Collaborate;
Human Rights Human rights violations
Interviews;
Bulletins and letters;
Brochures, reports
and websites;
Public
presentations;
Press releases.
Ad hoc
Risk and
Sustainability
Exec
Environmental Pollution
Social impact
Socio-economic impact of
mining;
Incorporating communities’
views;
Inte
rnat
ion
al
ind
ust
ry
bo
die
s
International
Platinum Group
Metals
Associations (IPA)
Platinum Guild
International (PGI)
Economic,
Innovation
Inform;
Consult;
PGM industry development
e.g. jewelry demand
Sustainable development
Security
Regulatory changes
Focus groups, one-
on-one, stakeholder
networks, panels or
committees,
partnerships
including alliances,
collaborative
projects, non-
technical summary
documents and
report
Annually
CEO
41
Table 3: Stakeholder Engagement Process10
Name of
Stakeholder Representative(s)
Key Drivers of
Engagement Level of
Engagement Key Issues Potential Concerns
Method of
Engagement or Media Frequency
Primary
Responsibility
Nat
ion
al in
du
stry
bo
die
s
Chamber of Mines
of South Africa
Business Unity
South Africa
(BUSA)
Southern African
Institute of Mining
and Metallurgy
(SAIMM)
Economic,
Legal &
Transformation
Inform;
Consult;
Sustainable development
Industry development
(technical)
Professional development
Nationalisation
Focus groups, one-
on-one, stakeholder
networks, panels or
committees,
partnerships
including alliances,
collaborative
projects, non-
technical summary
documents and
report
Monthly
(SAIMM and
Chamber of
Mines)
42
ii. During the Engagement
Establishing the rules of engagement
Before the actual engagement process begins, the purpose, scope and rules of
engagement needs to be established, inclusive of disclosure boundaries, confidentiality
and anonymity. The facilitator must also confirm the presence of key stakeholder groups
required for the process to be meaningful; furthermore these key groups must be
personally present or legitimately represented through a direct mandate by alternative
third parties. The principles of engagement need to be outlined to reflect inclusivity,
materiality and responsiveness.11
Inclusivity: company enables stakeholders to participate directly throughout the
decision making process
Materiality: relevance and significance of an issue to the company and its
stakeholders is determined
Responsiveness: company response to stakeholder issues that affects its
sustainability performance is realised through decisions, actions, performance and
communication with stakeholders
Through a consultative process all stakeholders need to agree on a decision making
process. The grievance mechanism that was established to address any matters arising
from the facilitation and outcomes of the meeting must be explained to the stakeholders.
Achieving objectives
During the engagement process itself, it is easy to become side tracked by issues that do
not pertain to the objectives of the day, therefore remaining focused is essential whilst
giving credence to other matters arising that could be addressed in another session or
different platform. Potential disruptions may be caused by:
• Misunderstanding of the issues
• Intimidation
• Emotional diversions
• Rivalries
• Lack of trust
• Complexity of issues
• Poor participation
• Misrepresentation of stakeholder interests
11
AA1000AS (2008)
43
A solutions-oriented approach needs to be adopted with a focus on:
Identifying (listing and confirming) issues of material importance to individual
stakeholder groups through the engagement process.
Determining stakeholders required outcomes in addressing material issues
(include indicators and timeframes).
Determining roles and responsibilities, especially if stakeholders are to
participate actively in addressing the material issues.
Important note:
Stakeholder engagement is primarily and information dissemination and gathering
process to improve the impact of the company; therefore unless authorized to do so, no
decisions or promises should be made without consultation with relevant company
authorities.
iii. After the Engagement
Responding to stakeholder issues and assessing impact
A key component of stakeholder engagement is ensuring that the material issues
identified during the engagement process is actually addressed by the company.
Firstly, it is important to determine how these material issues will affect company
policy, legal compliance, financial and operational performance, competitiveness,
reputation, etcetera.
Secondly, strategies to address material issues (this includes the role and
responsibility the stakeholder groups are expected to play; see Table 2).
Thirdly, material issues need to be integrated into the company’s decision making
processes (governance and strategy), and appropriate interventions need to be
implemented.
Fourthly, performance needs to be monitored and evaluated against agreed
indicators, impact needs to be assessed, and learning for improvement and
innovation is required.
Feedback to stakeholders
Regular feedback to stakeholders on outcomes of strategies to address their material
issues is required and public disclosure on outcomes is essential (reporting must be
comprehensive, transparent and material). Stakeholders must also be involved in the
independent reporting assurance process.
44
G. Step 4: The RBPlat Sustainability Framework
1. Internal Context - Current and Preferred Status
Prior to developing the overarching sustainability framework, it was important to obtain a
broad overview of the company’s current sustainability status. A high level baseline
assessment of RBPlat’s current public disclosure on sustainability was been taken into
consideration in the development of this framework through assessment of the Company’s
2012 Integrated Report and website. This was done to obtain an understanding of the
Company’s current status and to present areas for development. Figure 5 provides a broad
outline of key areas identified for improvement within existing business processes (green
blocks). These issues are discussed throughout this section; and the implementation plan
to address them are listed in Tables 8 and 9.
Fig. 6 provides an overview of the Company’s proposed preferred outcomes after
addressing the areas of improvement. Stakeholder engagement, which will take place
company-wide, is a prominent requirement for successful sustainability outcomes. The
outcomes of stakeholder engagement will influence and ensure informed corporate
decision-making to secure desired impacts, reduce risks, inform mitigation and adaptation
measures, and reveal new opportunities and successes for enhancement. Ultimately,
through support, buy-in and ownership of sustainability measures by all business units and
individuals within the company, sustainability will be embedded within the company
culture as ‘just the way things are done’; perhaps eventually moving from the tag line of
‘more than mining’ to ‘mining responsibly’.
45
RBPlat Board S & E Committee (Accountability)
Commitment Oversight Prioritise
Governance
Stakeholder Engagement
CEO (Responsibility)
Strategy
Risk & Assurance Executive
(Responsibility)
Management
Annual Report 3rd
Party Assurance
Policy register Gap analysis Develop & approve Review of current policies & ToR’s Public disclosure
Prioritise Drive
Champion Commitment Prioritise Incentivise & reward Resources
Material issues Gaps and recommendations Public disclosure
Planning Outcomes Training Opportunities Systems & processes Risks Methods and tools Innovation Indicators M&E Baseline Review Targets Impact Implementation Learning Reporting
Reporting framework Integrated Information management Information availability, integrity and verifiability Benchmarking Public disclosure
Governance Strategy Comprehensive Identification Categorisation Prioritisation Mode and Frequency of engagement Material issues Response Feedback Impact
Unpack Embed sustainability principles, goals Communication & awareness
Fig 5: Suggested Priority Areas
46
Stakeholder Engagement
Governance
RBPlat Board S & E Committee (Accountability)
CEO (Responsibility)
Strategy Risk & Assurance
Executive (Responsibility)
Management Annual Reporting 3rd
Party Assurance
Decision
making
Impact:
risk
mitigation adaptation
+
opportunities
enhancement
=
resilience
Sustainability Oriented Company Culture
Fig 6: Suggested RBPlat Preferred Status
47
2. The Sustainability Framework
This section describes the overarching sustainability framework into which the
sustainability theme and stakeholder engagement framework described in the previous
sections need be embedded. Since the concept of sustainability already has a
substantial presence within RBPlat, this document is intended to focus on a review and
realignment approach to sustainability.
The 5 key realignment phases identified are as follows:
1. Phase 1: Realignment of the Company profile where necessary (namely, the
vision, mission, values).
2. Phase 2: Review or development of the appropriate governance documents
(Board and committee charters) to reflect accountability for sustainability, and
policies (such as the sustainability policy, code of ethics, environmental policy,
health and safety policy, anti-fraud and corruption policy, etcetera).
3. Phase 3: Integration of sustainability into existing management processes through
risk management.
4. Phase 4: Establishment of a Sustainability Committee to manage the
implementation and integration of sustainability principles inclusive of broader
roles and responsibilities.
5. Phase 5: Integration of sustainability into existing management processes;
establishment of internal roles and responsibilities for sustainability.
48
i. Phase 1: Realigning the Company Profile
The current company profile (in some instances) makes implicit reference to
sustainability; however since these references need to be explicit. A process of
engagement needs to be embarked upon to reassess, define or explain the key
words used to represent the Company and the image the Company wishes to
portray. Once this is achieved, the sustainability embedded Vision, Mission, Values
and strategic intent can be used as the ‘platinum thread’ that runs through and
binds all corporate decisions and actions.
Table 4 is representative of what aspects of the company profile needs to be
unpacked and reassessed to reflect the company image. This tool needs to be taken
through an engagement process with relevant stakeholders to obtain relevant input,
secure pride and ownership in the development of the company’s sustainability
image, and prepare participants for the process of integrating the Company’s
sustainability stance into their areas of authority.
Table 4: Unpacking the Company Profile
Profiled area Current description Words/phrases to be unpacked to
reveal explicit meaning
Business
approach
Maximum value from safe platinum group metals extraction Value
Mission To leave a lasting legacy of sustainable benefits for our
stakeholders
Legacy
Benefits
Stakeholders
Vision To seek and deliver the good from mining Good
Purpose The purpose of our business model is to create economic
value, within a mutually beneficial joint venture, in a manner
that also creates value for society
Value
Strategy Towards operational excellence Operational excellence
Build flexibility Flexibility
Grow organically Grow organically
Pursue value enhancing opportunities Value enhancing opportunities
Logo A crocodile eye - the genealogical icon of and a symbol of
prosperity for the Royal Bafokeng Nation. The green colour
symbolises the natural environment and our principle to
conserve it, while the silver stands for the colour of platinum.
-
Tagline 'More than mining' relates to the significance of the logo
symbolising the bigger picture - mining is what we do and not
who we are.
Explain: mining is what we do and not
who we are
Values Safety and People First: Mining is a high-risk business and
cannot succeed without total trust, respect, teamwork and an
uncompromising commitment to safety and people first.
Values well explained – review where
necessary
49
Table 4: Unpacking the Company Profile
Profiled area Current description Words/phrases to be unpacked to
reveal explicit meaning
Promises delivered: We do what we say we will do.
Mutual Interests & Mutual Rewards: We have mutual goals
and mutual interests, and we depend on each other to realise
our collective vision and mission. We operate in good faith,
openly and transparently.
Characteristics Community Owned
The RBN remains a community with traditional leadership
and community structures complemented by a
"contemporary vision that aims to secure long-term
prosperity by actively 'mining the future' in every possible
way". Our operations are therefore geared to benefit the
community - the majority shareholder in the business
following the restructure of the joint venture; and the lessors
of the land upon which the mining operations are located
(e.g. Boschkoppie 104 JQ and Styldrift 96JQ).
Embracing Multiplicity
While the RBN is the majority shareholder and beneficiary of
the business, the presence of a diversity of skills and cultures
within the organisation is a strength that we embrace as we
face the challenges and opportunities of the future.
Proud Humility
We are proud of our new age approach to mining while
remaining humble and grounded in everything we do.
Sustained Success
We pursue success with the aim of achieving our stakeholder
beneficiation purpose to leave a lasting legacy.
Firm Flexibility
We acknowledge that some issues are negotiable while
others are not - safety is paramount in our business.
Improvement and efficiency are sought in all areas provided
our people, our safety and our environment are not
compromised.
Rare Pragmatism
We focus our efforts on establishing innovative win-win
solutions for all our stakeholders based on our extensive
experience in the business.
Characteristics well explained – review
where necessary
50
ii. Phase 2: Review of Corporate Governance
The next step in the corporate realignment process is to ensure that sustainability is
appropriately governed within the Company. Governance pertains to the Board and sub-
committees’ charters that address issues of oversight, compliance and accountability.
Issue specific policies needs to be developed and/or reviewed to govern the Board’s
stance on essential matters. Policies should include a description of the stakeholder
engagement process that the development of the policies have undergone to legitimize
their value. The corresponding policy goals also need to be ratified at the governance
level. In support of the governance review process, the following needs to be achieved:
• Development of a comprehensive internal policy register (aligned to appropriate
legislation where relevant) inclusive of appropriate sustainability policies needs to
be established together with a description and map of the compliance areas, roles
and responsibilities, and current compliance levels.
• Review of charters (Board and committee charters) to reflect accountability for
sustainability and develop/review relevant sustainability policies (such as the
sustainability policy, code of ethics, environmental policy , health and safety policy,
antifraud and corruption policy, etcetera).
• Establishment of corporate goals with embedded sustainability.
iii. Phase 3: Integration of sustainability and risk
This sustainability framework capitalizes on the recent merger between RBPlat’s
Sustainability portfolio with that of the Risk and Assurance portfolio.
Generally, corporate risk assessments are well established and enjoy a status of
importance as a key business process within companies, therefore the merger between
sustainability and risk provides an opportunity to:
use existing risk management structures for the management of sustainability.
use existing risk reporting methods and processes for reporting on sustainability.
raise the profile of sustainability risks within the risk identification and management
process.
obtain support from internal audit for sustainability assessments.
Fig. 7 illustrates the integration of sustainability (green blocks) within existing risk
structures and functions (blue blocks). Therefore once the various stakeholder groups and
company’s material issues have been identified as in described in Section 2 of this
document, they may then be classified as sustainability risks and follow the same
procedures for the avoidance or mitigation of the risk; namely the various risk
management structures and processes may be used to ensure the development of
appropriate strategies and processes to address these sustainability risks.
Important note:
Not all sustainability issues may be identified as corporate risk issues, however the governance and
management of these issues are still important and due process should be followed to ensure that
they are addressed and reported accordingly.
51
Significance rating Mitigation/enhancement strategy Opportunities Goals, targets & dates Indicators Systems & Processes Outcomes & impact
Divisional Risk Management: Operations Supply Chain Governance Projects Safety, Health & Environment Finance HR IT Investment Communications
RBPlat Risk: Company Wide Assessment
Risk Reporting Risk Management Risk Identification
Sustainability = Broader
economic, social and
environmental Impact
Finance
Sustainability embedded through Risk + additional
reporting on issues that may not be a risk
Governance
Assurance & Integrated
Report
Stakeholder Engagement: Material issues Impact
Impact Feedback to stakeholders Benchmarking Reporting
Fig 7: Proposed Sustainability Model: embedded through Risk
Operational risks Safety, health & environmental risks Strategic risks Financial risks Legal & regulatory risks Reputational risks Project risks + Sustainability
52
iv. Phase 4: Establishment of a Sustainability Committee
Establishment of a Sustainability Committee at an operational level is essential for the
implementation and co-ordination of sustainability activity throughout the company.
Chaired by the Executive: Risk and Sustainability, this committee reports directly to the
Social and Ethics Committee of the Board through the CEO supported by the Executive:
Risk and Sustainability (Fig. 8 & Table 5). Initially, close co-ordination will be required
between the activities of the Sustainability Committee and Risk Management Committee
to ensure aligned goals and processes. However the merger between the management
committees is recommended to avoid misalignment and duplication of function in the
future.
Sustainability Committee: Composition
To ensure comprehensive and company-wide representation in support of the
sustainability framework, the following portfolios must be represented within the
Sustainability Committee at a senior level.
• Executive: Risk and Sustainability (Chair)
• Head: Sustainability
• Risk & Compliance Specialist
• Safety Health and Environmental Manager
• General Manager: BRPM/ Styldrift
• Company Secretary
• Executive: HR
• Head: Projects
• Corporate Finance Executive
• Investment Relations Manager
Sustainability Management Committee: Terms of Reference
To drive engagement and sustainability, the Committee will take responsibility for the
following:
• Support the review of current policies and strategies for realignment with
sustainability principles.
• Support the establishment and implementation of stakeholder engagement and
sustainability processes.
• Support the integration of sustainability principles and stakeholders’ material issues
into the Company strategy.
• Propose and review implementation plans to ensure the integration of sustainability
principles.
• Support the collection and capture of timely and accurate data.
• Consider reports on the implementation and impact of sustainability principles and
advise on further implementation.
• Support the development of the Integrated Report.
• Communicate and advocate the sustainability principles within the Company’s sphere
of influence.
53
Table 5 details the responsibility, reporting lines and meeting schedules for the Sustainability
Committee and related governance and management structures.
54
CEO: Sustainability
Champion
5: GM: Styldrfit
4: Sustainability Committee (Chair: Risk & Sustainability Exec.)
2: Audit and Risk Committee
1: RBPlat Board
3: Social and Ethics Committee
5: GM: BRPM
5: SHE Manager
5: Corporate Finance
Exec.
5: Head:
Sustainability
Fig 8: Governance and Management of Stakeholder Engagement and
Sustainability
5: Head of Projects
5: HR Exec.
5: Company Secretary
5: Risk &
Compliance Specialist
Risk
Management Committee
5: Investment Relations Manager
55
Table 5: Governance and Management of Sustainability
Refer to
Figure 3
Company structure Responsibility Reporting to: Meeting
schedule
Governance
1 RBPlat Board Accountability for the
Sustainability of RBPlat
All stakeholders 4 per annum
2 Social and Ethics Committee Accountable for Sustainability
and the Integrated Report
Full Board & all
stakeholders
4 per annum
3 Audit and Risk Committee With respect to Sustainability
only: Accountable for
Sustainability risk and assurance
of the Integrated Report
Full Board & all
stakeholders
4 per annum
Management
4 Sustainability Committee To provide direction, support
and monitor the management
and implementation of
sustainability
The CEO
Chaired by the Exec:
Risk & Sustainability
6-8 per annum
5 Divisional Sustainability
Committees and other
specialist focus Committees
e.g. the Environmental Impact
Committee
To address sustainability pillars
and other entity/divisional
strategic and/or functional level
issues.
Sustainability
Committee
6-8 per
annum
56
v. Phase 5: Integration of sustainability: Roles, responsibilities and timeframes
This management portion of the sustainability framework has been developed with the
intention of integrating sustainability into existing generic business processes within the
company, thereby utilizing existing structures and personnel. This approach will reduces
cost, avoid duplication, ease acceptability and ensure integration of the concept into the
company’s core business.
This process will probably be the most challenging of all the realignment processes
primarily because implementation will affect every business unit and therefore the way
in which every individual within the company performs his/her function. Appropriate
leadership, communication, training, support and appropriate incentives are key to
ensuring the success of embedding sustainability principles within the company.
The key management components of the sustainability framework are as follows:
establishment of a quantifiable baseline
integration of the sustainability principles into the corporate strategy
stakeholder engagement
establishments of targets, timelines and indicators
integration of sustainability into operational plans
implementation of training, and communication and awareness programmes
data collection
impact assessment on sustainability pillars
integrated reporting
reporting assurance
public disclosure
Table 6 lists the generic business areas into which sustainability related actions and activities can
be incorporated together with the corresponding requirements; Tables 7 and 8 detail specific
activities associated with these requirements and establishes the roles, responsibilities and
timelines for integrating sustainability within RBPlat. Table 7 focuses on initial steps that need to
be taken to prepare for long term sustainability initiatives, whilst Table 8 reflects a 3 year plan.
Table 6: Sustainability Focus Areas
Generic Business Areas Key Sustainability Requirements
Leadership Understanding of sustainability
Commitment to sustainability
Accountability and responsibility for sustainability
Visibility and communication on sustainability
Allocation of resources
Establishment of rewards and incentives
Engagement of stakeholders
57
Table 6: Sustainability Focus Areas
Generic Business Areas Key Sustainability Requirements
Stakeholder
Engagement (refer to
Section 2 for the
engagement
framework for more
detail)
Identification, mapping, categorisation & prioritisation
Inclusivity
Dialogue (frequency, mode, etcetera)
Managing concerns, expectations, perceptions, conflict
Material issues
Responsiveness
Communication
Governance Board oversight and accountability
Leadership
Relevant legislation (local and international) and best practice Principles and Codes
Board and Board committee charters
Vision, mission and values
Company policies (Sustainability policy, Code of Ethics, stakeholder engagement policy,
and other social, environmental and broader economic policies)
Engagement of stakeholders
Strategy Establishment of leadership responsibility
Establishment of objectives and targets with timelines
Allocation of resources
Integration of Company and stakeholders’ material issues
Impact orientation
Embedded sustainability in core strategy: operations & supply chain
Influencing Company culture
Determination of risks and opportunities
Engagement of stakeholders
Management (Planning
and implementation)
Establishment of leadership responsibility
Engagement of stakeholders
Planning at divisional and individual levels
Embedded sustainability ‘thinking’ into core business areas: operations & supply chain
Ensuring cross functional collaboration across all business units
Establishment/review of systems & processes
Establishment /review of methods and tools
Establishing goals, targets, indicators
Obtaining skills through development and training
Establishment of communication and awareness programmes
Establishment of information collection and data integrity measures
Monitoring and evaluation of outcomes and impacts
Impact assessment
Assessment of risks and opportunities
Establishment mitigation or enhancement plans
Benchmarking outcomes and impact (internal & external)
Review of (policy, strategy, planning, implementation)
Establishment of a culture of learning
Impact
Assessments
Engagement of stakeholders
Assessment of positive or negative impacts through quantitative and qualitative
assessment
Establishment of enhancement or mitigation measures
Assessment against goals, targets, timeframes and indicators
58
Table 6: Sustainability Focus Areas
Generic Business Areas Key Sustainability Requirements
Integrated Report Reflecting materiality
Exhibiting integration
Ease of availability of information (Annual reports, website, other media)
Assurance Engagement of stakeholders
Credibility of information and data integrity
Gaps and suggestions for improvement
External certification - 3rd
party independent, impartial assurance
Table 7 overleaf depicts the roles, responsibilities, level of urgency and timeframes for actions
and activities from August 2013 to November 2013. The majority of these actions are ‘once-off’
to establish the foundation for sustainability going forward
Table 8 however depicts on-going roles, responsibilities, level of urgency and timeframes for
actions and activities from January 2014 – December 2016. These actions will be cyclical for the
continued integration, implementation and reporting on sustainability activity within the
company and are subject to annual review.
59
Table 7: Roles, responsibilities and timeframes for 2013
Role Primary
responsibility
In consultation
with:
Custodian Current
level of
urgency
Frequency
of actions
Timeframe
2013
Aug Sept Oct Nov
Getting Started
Consider the sustainability theme,
stakeholder engagement and sustainability
framework
Board CEO
EXCO
Exec. Risk &
Assurance
High Once-off
Approve the sustainability theme,
stakeholder engagement and sustainability
framework
Board CEO
EXCO
Exec. Risk &
Assurance
High Once-off
Establish the Sustainability Committee at
the management level
CEO Board
EXCO
Exec. Risk &
Assurance
High Once-off
Work-shop the Sustainability Committee on
the stakeholder engagement and
sustainability framework
Exec. Risk &
Assurance
Exec. Risk &
Assurance
High Once-off
Work-shop the Risk Management team on
the integration of sustainability into the risk
portfolios
Exec. Risk &
Assurance Exec. Risk &
Assurance
High Once-off
Revise the frameworks based on input from
the Sustainability Committee and Risk
Management portfolio
Exec. Risk &
Assurance Exec. Risk &
Assurance
High Once-off
Engage broader stakeholder groups on the
revised frameworks and finalise accordingly
Exec. Risk &
Assurance
Sustainability
Committee
Relevant
stakeholder
groups
Exec. Risk &
Assurance
High Once-off
60
Table 8: Roles, responsibilities and timeframes for 2014-2016
Role Primary
responsibility
In consultation with: Custodian Current
level of
urgency
Frequency of
actions
Timeframe
2014 2015 2016
1st
2nd
1st
2nd
1st
2nd
Getting started
Develop tools for the
establishment of a
quantitative sustainability
baseline
Exec. Risk &
Assurance
Sustainability
Committee
Exec. Risk &
Assurance
High Once-off
Begin the baseline data
collection process
Exec. Risk &
Assurance
Sustainability
Committee
Exec. Risk &
Assurance
High Once-off
Prioritise and set
sustainability targets
(after stakeholder
engagement process in
consultation with the
outcomes of the Ethics
project)
Exec. Risk &
Assurance
Board
CEO
Sustainability
Committee
Relevant stakeholder
groups
Exec. Risk &
Assurance High Annual
Develop sustainability
communication and
awareness programme
(internal and external)
HR Executive
Exec. Risk &
Assurance
Communication
Executive
High Annual
Implement sustainability
communication and
awareness programme
(internal and external)
HR Executive
Exec. Risk &
Assurance
Communication
Executive
High On-going
61
Table 8: Roles, responsibilities and timeframes for 2014-2016
Role Primary
responsibility
In consultation with: Custodian Current
level of
urgency
Frequency of
actions
Timeframe
2014 2015 2016
1st
2nd
1st
2nd
1st
2nd
Develop relevant training
programmes
HR
Exec. Risk &
Assurance
CEO
Sustainability
Committee
Exec. Risk &
Assurance High Annual/as
required
Implement training
programmes
HR
Exec. Risk &
Assurance
CEO
Sustainability
Committee
Exec. Risk &
Assurance High Annual/as
required
Develop an Integrated Report
framework
Exec. Risk &
Assurance
Board
CEO
Sustainability
Committee
Relevant stakeholder
groups
Exec. Risk &
Assurance High Once
off/annual
review
Implement the Integrated
Reporting framework
Exec. Risk &
Assurance
Board
CEO
Sustainability
Committee
Relevant stakeholder
groups
Exec. Risk &
Assurance High annual
62
Table 8 continued: Roles, responsibilities and timeframes for 2014 - 2016
Role Primary
responsibility
In consultation
with:
Custodian Current
level of
urgency
Frequency
of actions
Timeframe
2014 2015 2016
1st
2nd
1st
2nd
1st
2nd
Stakeholder Engagement
Review identification of
stakeholders
Sustainability
Committee
Exec. Risk &
Assurance
Board
CEO
Current
stakeholders
Exec. Risk &
Assurance
High Annual
revised
Categorise and prioritise
stakeholders
Sustainability
Committee
Exec. Risk &
Assurance
Board
CEO
Current
stakeholders
Exec. Risk &
Assurance
High Annual
revised
Determine of mode and
frequency of engagement per
stakeholder
Sustainability
Committee
Exec. Risk &
Assurance
CEO Exec. Risk &
Assurance
High Annual
revised
Allocate internal roles and
responsibilities per stakeholder
group
Sustainability
Committee
Exec. Risk &
Assurance
Current
stakeholders
Exec. Risk &
Assurance
High Annual
revised
Train appropriate stakeholder
engagement facilitators
HR
Exec. Risk &
Assurance
CEO
Sustainability
Committee
Exec. Risk &
Assurance
High Annual
revised
63
Table 8 continued: Roles, responsibilities and timeframes for 2014 - 2016
Role Primary
responsibility
In consultation
with:
Custodian Current
level of
urgency
Frequency
of actions
Timeframe
2014 2015 2016
1st
2nd
1st
2nd
1st
2nd
Determine stakeholder material
issues
Stakeholders
facilitators
Sustainability
Committee
Exec. Risk &
Assurance
Stakeholders Exec. Risk &
Assurance
High On-going
Determine Company response to
stakeholder material issues
Board
CEO
Relevant operational
department
Stakeholders
Relevant
operational
department
Exec. Risk &
Assurance
High On-going
Feedback to stakeholders on
impact of interventions to
address material issues
Stakeholders
facilitators
Sustainability
Committee
Exec. Risk &
Assurance
Stakeholders Exec. Risk &
Assurance
High On-going
64
Table 8 continued: Roles, responsibilities and timeframes for 2014-2016
Role
Primary
responsibility
In consultation with: Custodian Current
level of
urgency
Frequency of
actions
Timeframe
2014 2015 2016
1st
2nd
1st
2nd
1st
2nd
Governance
Realign Company Profile Board
CEO
EXCO
Exec. Risk &
Assurance ,
Sustainability
Committee,
Appropriate
stakeholders
Company
Secretary
Medium Biennial
Review appropriate charters
(Board and committee
charters) to reflect
accountability for sustainability
Board
Company Secretary
EXCO
Primary stakeholder
groups
Company
Secretary
Medium Biennial
Review the governance
documents
Individual policy
custodians, eg. HR for
labour policies
Exec. Risk &
Assurance , relevant
policy implementers
and stakeholders
that policy impacts
upon
Company
Secretary
Medium Biennial
Establish an internal policy
register inclusive of appropriate
sustainability policies
Company secretary Exec. Risk &
Assurance
Company
Secretary
Low Ongoing
maintenance
Establish corporate goals with
embedded sustainability
Board
CEO
EXCO
Sustainability
Committee,
Appropriate
stakeholders
CEO High Annual
65
Table 8 continued: Roles, responsibilities and timeframes for 2014-2016
Role Primary
responsibility
In consultation with: Custodian Current
level of
urgency
Frequency of
actions
Timeframe
2014 2015 2016
1st
2nd
1st
2nd
1st
2nd
Management & Impact Assessment
Determine indicators of
impact
Relevant HoDs
CEO
EXCO member
Relevant stakeholders
GMs High Ongoing
Ensure that appropriate
systems, processes, tools,
skills and other resources
are available
Relevant HoDs Relevant EXCO member GMs High Ongoing
Plan and incorporate
possible risks,
opportunities or exist
strategies where
appropriate
Relevant HoDs Relevant EXCO member
Departmental team GMs High Ongoing
Establish divisional
actions and activities
Relevant HoDs
and individuals
Departmental team GMs High Ongoing
Establish individual
actions and activities
Relevant HoDs
and individuals
Departmental team GMs High Ongoing
Establish and maintain
information collection
and data integrity
measures
Relevant HoDs
and individuals
IT
Departmental team IT, GMs High Ongoing
66
Table 8 continued: Roles, responsibilities and timeframes for 2014-2016
Role Primary
responsibility
In consultation with: Custodian Current
level of
urgency
Frequency of
actions
Timeframe
2014 2015 2016
1st
2nd
1st
2nd
1st
2nd
Monitor compliance and
quality of implementation
Internal Audit
External
accreditation
bodies
Relevant HoD Internal Audit High Ongoing
Assess impact through
stakeholder engagement
Relevant HoD Sustainability
Committee,
Relevant stakeholders
Relevant EXCO member
GMs High Ongoing
Establish enhancement or
mitigation steps
Relevant HoD CEO
Sustainability
Committee,
Relevant stakeholders
Relevant EXCO member
GMs High Ongoing
Assess and address risks
and opportunities
Relevant HoD Sustainability
Committee,
Relevant stakeholders
GMs High Ongoing
Review to inform policy,
strategy and planning
processes
Relevant HoD Board
CEO
EXCO
Company Secretary
Sustainability comm
Board
CEO
EXCO
Company
Secretary
High Ongoing
67
Table 8 continued: Roles, responsibilities and timeframes for 2014-2016
Role Primary
responsibility
In consultation with: Custodian Current
level of
urgency
Frequency of
actions
Timeframe
2014 2015 2016
1st
2nd
1st
2nd
1st
2nd
Integrated Report
Ensure system for appropriate
information management and
data integrity
IT EXCO Member Exec. Risk &
Assurance
HoDs
IT EXCO
member
High Annual
Consolidate and integrate
information for report writing
Exec. Risk &
Assurance
Sustainability
Committee
Exec. Risk &
Assurance
High Ongoing
Benchmark against internal
performance, corporate best
practice and industry peers
Benchmarking
against internal
performance,
best practice
and industry
peers
Integrate with financial and
governance reporting
Exec. Risk &
Assurance
CEO
CFO
Company Secretary
Sustainability
Committee
Social and
Ethics
Committee of
the Board
High Annual
Approve report Social & Ethics
Committee of the
Board
Exec. Risk &
Assurance
EXCO
CEO
Sustainability
Committee
Social & Ethics
Committee
Social and
Ethics
Committee of
the Board
High Annual
68
Table 8 continued: Roles, responsibilities and timeframes for 2014-2016
Role Primary
responsibility
In consultation with: Custodian Current
level of
urgency
Frequency of
actions
Timeframe
2014 2015 2016
1st
2nd
1st
2nd
1st
2nd
Assurance
Assure the credibility of the
data and impacts reported in
the integrated report through
support from internal audit
and external accreditation
bodies with specialized
functions.
Exec. Risk &
Assurance
Exec. Risk &
Assurance
Exec. Risk &
Assurance
High Annual
Ensure 3rd
party, independent
and impartial assurance for an
external service provider for
the integrated report
Exec. Risk &
Assurance
Exec. Risk &
Assurance
Exec. Risk &
Assurance
Risk Committee
of the Board
High Annual
Ensure that impacted
stakeholders are involved in
the assurance process
External Assurer Relevant
stakeholders
Exec. Risk &
Assurance
High Annual
Publically disclose integrated
report and data via the
company website and direct
communication to relevant
stakeholders
Exec. Risk &
Assurance
Investor relations
Company
communications
department
Exec. Risk &
Assurance
High Annual
Ensure that information is
easily accessible and
understandable to impacted
stakeholder groups
Exec. Risk &
Assurance
Investor relations
Company
communications
department
Exec. Risk &
Assurance
High Ongoing
69