Who we are, what we do

A robust approach to
anti-corruption

As a company with public listings on the Johannesburg, New York, Australian and Ghanaian stock exchanges, stakeholders rightly hold high expectations of regulatory compliance. For example, the business is also subject to anti-corruption legislation in every jurisdiction in which it operates, much of which is applicable on an extraterritorial basis.

The potential risk of corruption arises because of the group's presence in areas of the world where the perception of corruption is high and because of the high-value nature of our product, gold. Risks arise particularly where governmental structures at a national or local level are insufficiently robust and where there is a limited pool of potential suppliers who develop close relationships with counterparts in the business. Corruption may impose additional costs on the business in the supply of goods and services and in extreme cases may result in employees being exposed to health or safety risks (for example if equipment is supplied which does not meet the required standards).

Our approach to managing risks relating to corruption

A number of policies and initiatives exist through the business to ensure that our values and approach to anti-corruption are put into practice, and that risks associated with non-compliance are managed effectively. In addition to the policies that have been put in place, a number of additional initiatives have been introduced to support a robust compliance framework. These include conflict of interest, gift registries, due diligence processes for agents and key suppliers, as well as the requirement to document interactions with government. Anti-corruption measures have been put in place globally throughout the business, as we do not believe that only developing regions are at risk.

One important aspect of our governance framework is the Serious Concerns Committee (SCC). This is an internal oversight governance committee established in 2013 with the mandate to review allegations and investigations of unethical behaviour concerning senior-level employees across the group. The SCC deals with any allegation which may arise relating to unethical behaviour on the part of senior-level employees, as well as with other corruption issues if they also form part of any allegation. The principle underlying the formation of the SCC is that all individuals are accountable for violations of the Code of Business Principles and Ethics, or any other related policy violations, regardless of seniority or position.

How we embed this approach in the business

Anti-bribery and anti-corruption training is undertaken at all levels and in all operating jurisdictions through a combination of video, online and face-to-face training. In some instances, training programmes have been extended to third parties, to assist in creating an environment where corruption is not tolerated. In Tanzania, for example, anti-bribery and anti-corruption training is undertaken together with government officials, the national prosecuting authority, employees and, where relevant, community members.

Due diligence of suppliers and intermediaries is also undertaken to ensure the organisation has insight into its business partners. Procurement processes require declarations of government interest in suppliers. Combined assurance processes aim to bring to light instances of non-compliance.

The business also operates an anonymous tip-off line and website, where either employees or third parties can report incidences of corrupt or unethical practice.

During 2015, the organisation will continue to deliver targeted training and develop the capacity of sites. For example, issues relating to ethics will be placed on the agenda of regular production meetings, where appropriate. Employees, will continue to undertake online ethics training in 2015.

Key performance indicators
Number of operations assessed for risks relating to corruption

Security departments at all sites undertake risk of corruption assessments as part of their risk assessment processes. These assessments are reviewed regularly by sites. Other disciplines also consider the risk of corruption as part of their ongoing risk management processes. In addition, our Code of Business Principles and Ethics and related policies are provided to all employees, and all employees have been advised that the company will take active steps against fraud and corruption in all its forms, including bribery and extortion.

Our Group Compliance team provide both DVD training specifically for employees who do not have access to computers, and online training for others. In addition, face-to-face training is provided at a site level (using a risk based assessment to determine the content of the presentations and the specific sites). An online code of ethics training module, launched in September 2012, contains two anti-bribery modules. A bribery and corruption prevention on-line module was also launched to employees most at risk.

Significant fines or non-monetary sanctions for non-compliance

A significant legal issue is defined as one that could result in a potential liability to the company and an issue with a potentially negative consequence for the company’s reputation, as assessed by the executive committee. No administrative fines were issued in 2013. A total of 50 instructions were received in terms of the Mine Health and Safety Act in South Africa to temporarily suspend operations, which resulted in the loss of 23 full shifts and 485 partial shifts.

Our values in practice