CONFLICT FREE GOLD POLICY

Transcription

1 CONFLICT FREE GOLD POLICY GROUP POLICIES AND PROCEDURES Introduction In light of the regulatory and industry standards and initiatives towards conflict free gold Randgold ( the group ) has evaluated a Conflict Free Gold Policy based on regulatory compliance, existing reporting requirements and best practice. The purpose of this policy is to ensure that the gold produced across the operations under its principles and processes is delivered in a manner which does not fuel armed conflict or fund armed groups, nor contribute to the abuse of human rights associated with such conflicts. STEP 1 Conflict Assessment Management will prepare a risk assessment and conflict assessment on the operation to determine whether or not the operation is in an area which is conflict affected or high risk. This assessment will consider the following areas: International sanctions in place: assessing whether there are any sanctions in place which affect the country or area of operation and whether any sanctions restrict gold or gold bearing material being mined or exported. The assessment should review the publically available sanctions databases (UN, US, EU et al). Recognition of conflict: assessment of the location of the mine and whether the area or country is located in a conflict affected area. The assessment should use the Heidelberg Conflict Barometer and the UN Security Council analysis of the country and area of operation. As part of the assessment management will consider the complete custody of the gold to ensure that the onward transport of gold will not breach any international sanctions. Gold Sales It is group policy that gold or gold bearing material is only sold to board approved refiners where there is a contract in place which makes explicit reference to the chain of custody of the final product. The company only engages in sale contracts with refineries that are accredited by the appropriate bodies and comply with the relevant industry standards. STEP 2 Company Assessment Following the risk and conflict assessment, should the operation be determined to be in an area of conflict or high risk then the operation should ensure compliance in the areas noted below. Should the operation not be in an area of conflict nor high risk then the operation should move to the final step 3 for evaluation. Page 1 of 6

2 AREA 1: Commitment to human rights The group is publically committed to respecting human rights and not tolerating exploitative child labour. The group has a human rights policy in place, which applies to all operations and is available to staff and the public in French and English. The group has a history of respecting human rights and has a recognised human rights guidance and code of conduct available for employees. The group is committed to the following initiatives in relation to human rights: Sustainability report compiled and audited annually includes all significant operations; National Police deployed on site are trained on the voluntary principles on security and human rights according to UN principles; The group has agreements signed with the State governing our interaction with security forces based on voluntary principles on security and human rights; and Employee code includes framework specifically on human rights. AREA 2: Company Activities The group s mining operations have not been subject to any allegations (nor credible allegations) of serious human rights abuses or breaches of humanitarian law. The group can demonstrate that it uses its influence to prevent abuses being committed by others in the vicinity of its operations, if such abuses are occurring. All our security personnel as well as the police assigned to our area are trained in the Voluntary Principles by the UN. The group has an active engagement with the MONUSCO Human Rights representatives. A formal procedure is in place to deal with instances when the operation or personnel are subject to credible allegations of serious human rights abuses or breaches of international humanitarian law and demonstrate action steps that would be taken, even though we have not been subject to such allegations in the past. The following initiatives have been put in place by management: HSE Department include monitoring and identification of any significant issues with respect to its performance on human rights or alleged abuses of human rights or breaches of internal humanitarian law within the area of operation; Formal and documented regular review of relevant information sources and media to identify reports of credible allegations of serious human rights or breaches of international humanitarian law in local/regional/national media covering the past two years; and If a violation or accusation of such should occur, evidence would be compiled of mitigating actions performed for risks identified in relation to human rights violations or international humanitarian laws, e.g. correspondence with government, legal or other reports from those assigned to dealing with the credible allegations. Currently there is no specific group requirement for external human rights audits to independently verify our performance in relation to human rights monitoring and identification, however the necessity is be regularly considered by management. Page 2 of 6

3 AREA 3: Security Gold is produced from mines where: the personnel providing security have not been credibly accused of human rights abuses; where the mine has not financed of provided benefits to armed private groups who have committed or been credibly accused of human rights abuses; and where the mine has sought to use its influence with public security forces acting in the vicinity of the mine to ensure that they observe human rights and international humanitarian law and the rule of law. For private security providers due diligence procedures are performed on both mine security provider and security personnel, including contractors to comply with the above. This is conducted regularly through a system for reviewing security contractor and personnel on a routine basis. Contractual terms with security operating on site state that security will perform an on-going review of the security contractor, security personnel and suppliers in relation to human rights and training of staff with action plan for remedial steps should the necessity arise. The contract also includes the requirement to record and report any human rights abuse or grievance. AREA 4: Payments to Governments The group publically discloses payments to government entities and has systems in place to record payments to governments to comply with regulatory reporting. Communication with governments and government entities are performed on a formal basis through appropriate channels. Any payments to Public Security Forces are made in accordance with the framework of law and shown to be justified and rationale, all payments are separately evaluated. The following procedures are in place in relation to payments to governments and government entities: Commitments to not making payments or providing benefits-in-kind to non-government entities that cause, support or benefit unlawful armed conflict or contribute to serious human rights abuses or breaches of international humanitarian law; and Risk-based due diligence procedures to mitigate against making payments or providing benefits-inkind to non-government entities that cause, support or benefit unlawful armed conflict or contribute to serious human rights abuses or breaches of international humanitarian law. Bribery and extortion and internal procedures to be followed in case serious human rights abuses are credibly linked to such activity. AREA 5: Engagement, Complaints and Grievances The group has a whistle-blower programme and procedure in place; which is communicated to staff and is displayed in French and English. The communication includes a confidential phone number and allows for anonymous reports. There is an on-going stakeholder engagement programme in operation which includes interactions with artisanal and small-scale miners, including assessing the extent to which they and their activities may be considered to be legitimate through seeking to behave in good faith and to seek formalisation. The process for identification of local stakeholders includes identifying minority or historically marginalised groups, including women, youth and indigenous peoples. There is a grievance process in place through which those affected by the mine s operations can raise concerns about the mine s operational activities. Grievances raised are recorded and reviewed on a regular basis. There is timely resolution of grievances. Grievances are reviewed weekly by the operation s Community Manager and quarterly by the group s GM Sustainability. Any grievances that are persistent or pose a risk to Human Rights are reported to the Group Sustainability Committee, where appropriate corrective action is decided. Page 3 of 6

4 AREA 6: Nature of Gold Production Gold is the main metal being extracted at the group s operations. Significant processing takes place on site to extract gold from surrounding material and therefore doré leaves the mine site in a form that can be easily refined into gold. Material that cannot be easily processed into gold is segregated from material that can easily be processed. There is a smelter is on site. Each mine has documentation which records the grade being processed in the plant (input) and grade leaving the mine in the form of doré (output) which is verified by independent assay sampling procedures. Security measures are in place around the plant, gold room (restriction on access and controls around entering and exiting), and around gold shipments. There are formally documented procedures in place relating to the mining and processing of the ore including security measures. AREA 7: Control of Gold at the Operation Appropriate security and management systems are in place to: Track the flow of gold and gold-bearing material within the mine s area of controls; and Minimise the risk or incidence of illegal addition or theft of gold and gold-bearing materials. Management systems, processes and internal controls are in place to secure and track the flow of gold and gold-bearing material within the group s operational area of control. Flow of gold and gold-bearing material at the operations is documented. Assessment to identify the risk points that arise and the security controls in place need to be documented along with controls in place to mitigate each risk point. Internal review process is in place across the group to provide assurance that the controls are in place and operational. Security logs record actual or attempted incidents of gold theft and an assessment of whether it was possibly linked to financing unlawful armed conflict. Traceability systems are in place to map the flow of gold and gold-bearing material from point of origin to point of dispatch. Reference systems are in place to uniquely identify each batch of gold that leave the group s operational area of control and each gold bar is uniquely identified with an imprint reference number in such a way that tampering or removal will be evident. A management system is in place for the security of the gold product. The following security requirements are in place: 1. Processing plant boundaries; 2. Processing plant and equipment; 3. Processing plant maintenance and equipment access; 4. CCTV in operation in the plant; 5. Access control; 6. Gold room security; 7. Guard rotation; and 8. Gold shipment security. Example of risk points and controls are documented by management including a site risk assessment which considers the following points in the gold mine process represent the highest risk for gold-bearing material leaving the site without proper oversight: Gold room and smelt house; Transport from the gold room to the transport vehicle; and Gravity circuit, specifically access to free-gold during maintenance on Knelson Concentrator. Specific controls and procedures are in place to mitigate the high risk areas noted above at all of the operations and compliance with the controls is regularly reviewed and evaluated for effectiveness. Page 4 of 6

5 AREA 8: Transport of Gold Ownership of the gold changes to the Refinery at the point of leaving the airlock therefore the group is not responsible for due diligence requirements on intermediaries who transport the gold, however the group ensures a secure path between the gold room and the airport where the gold shall be shipped. Recommendations from the Refinery appointed security agent/transporter would be implemented by each operation as they arise. STEP 3: Source of Gold The group will not source gold or gold-bearing material from external suppliers. The group will not make local purchases of gold mined by artisanal or small-scale miners or by a third party mining company. The group will not make local purchases of processed gold nor will the group be purchasing gold from a refiner. The group will not be extracting gold to supply to another company for toll treatment or other processing services. The group will not be toll treating ore or gold bearing material from a third party. The group will periodically compare their gold fingerprint with artisanal mined gold from the area to confirm these are obtained from different sources. Management procedures include ore source accounting controls and security controls which are in place to secure the plant and site to ensure that all material processed and gold sold is of a traceable chain from ore to doré. At the Kibali operation, Sokimo tailings were purchased as part of the entire mining concession and management have concluded that these are not externally sourced gold as per the criteria stipulated. Any deviations from the above such as The group entering into a toll treatment agreement or gold purchase agreement would need review by and authorisation of the board. Page 5 of 6

6 Decision Tree for Conflict Free Gold with reference to legal, regulatory and industry compliance Page 6 of 6