AngloGold Ashanti’s board, which has ultimate responsibility for corporate governance, is guided by its commitment to ensuring sound governance principles and practices. These underpin value creation and the long-term sustainability of our Company. They are crucial to achieving our business objectives and delivering on the business strategy.
The Company’s governance structures and processes demonstrate our commitment to high standards of business integrity and ethics in all activities. They are supported by our values-driven culture and Code of Business Principles and Ethics.
The board is committed to promoting good governance and providing ethical leadership. It is supported by five committees to which it delegates certain functions without abdicating any of its own responsibilities. These are the the SES Committee, Audit and Risk Committee, Remuneration and Human Resources Commitee, Nominations Committee and the Investment Committee.
The key responsibility of the SES Committee is to assist the board in monitoring matters relating to safety, health, the environment and ethical conduct, and to ensure that AngloGold Ashanti develops and behaves as a responsible corporate citizen. It also ensures that our sustainability strategy positions AngloGold Ashanti as a leader in responsible mining practices and that our sustainability objectives are effectively integrated into the business. In addition, the SES Committee oversees the integrity of and approves the Sustainability Report.
More information on our approach to governance is available on our website.
General managers are accountable for the on-the-ground implementation of the sustainability strategy. Group Corporate Affairs and Sustainability is responsible for the development of management frameworks and supports the implementation of the sustainability strategy.
Primary responsibility for managing sustainability matters rests with AngloGold Ashanti’s leadership, in particular with the Chief Sustainability and Corporate Affairs Officer who is responsible for executing the sustainability strategy. Other responsible positions are the Chief Executive Officer, Chief Financial Officer, Chief Technical Officer, Chief Operating Officer, Chief Development Officer, Chief People Officer and Chief Legal Officer.
AngloGold Ashanti maintains a comprehensive set of policies and procedures designed to ensure compliance with applicable anti-corruption and anti-bribery laws, including those requiring that accurate accounts and records be maintained. These policies and procedures are used to raise employee and stakeholder awareness relating to bribery and corruption.
To support group-wide compliance with these policies and procedures, training is undertaken periodically, formal compliance communications are issued to the Group focusing on different aspects of the policies and procedures, all new employees undergo induction training that addresses these policies, and compliance risk reviews are performed by Group Compliance.
Our Code of Business Principles and Ethics is available on the Company intranet, the Company website and DVD in the main AngloGold Ashanti operating languages. It is the defining document on AngloGold Ashanti’s values and ethics in addition to applicable laws, regulations, standards and contractual obligations in the countries in which we operate. It provides a framework and sets requirements for the implementation of key corporate policies and guidelines. Among other areas, it addresses fraud, bribery and corruption, conflict of interests, gifts, hospitality and sponsorships, the use of Company assets, privacy and confidentiality, disclosures and insider trading.
The board works to ensure that AngloGold Ashanti is a responsible corporate citizen by not only considering the Company’s financial performance, but by pursuing ESG principles. We work to enhance and invest in the economic life of the communities surrounding our operations and society in general.
AngloGold Ashanti is a strong corporate citizen and supporter of transparency and active stakeholder engagement. We have mechanisms in place to report grievances and concerns, including our whistle-blowing hotline. Site-specific grievance processes for employees and communities at large exist to report concerns related to legal non-compliance, fraud, bribery and corruption, human right infringements, safety and environmental matters. Site-specific grievance process are discussed further under Contributing to resilient, self-sustaining communities.
AngloGold Ashanti’s whistle-blowing platform is administered by a third party. All employees, directors, officers and external parties have access to this platform via hotlines, email and web facilities. Reporting is anonymous unless the reporter specifically chooses to disclose their identity. All concerns are carefully investigated and feedback is provided to the person raising the concern. Whistle-blowing results are communicated to the Audit and Risk Committee and SES Committee and to the Serious Concerns Committee, a management committee, on a quarterly basis.
As a company supporter of the Extractive Industries Transparency Initiative (EITI), the Group reaffirmed its commitment to promoting the open and accountable management of resources, and the reporting of amounts paid to governments. In previous integrated reports, we have outlined our tax management strategy, along with the controls we have in place to manage the risk and to provide appropriate oversight and governance.
We continue to exercise diligence and transparency in line with our Group Tax Management Policy. This has included open and transparent reporting that is consistent with the ICMM’s Mining Principles and updated Position Statement on the transparency of mineral revenues. Our value-added statement represents the value created and shared. See our commitment to transparency in taxes and payments to governments.
While developing our corporate social investments, we seek to establish and prioritise initiatives in line with country national development plans. This ensures that we work collaboratively, supporting national plans in education, local procurement, local employment, and infrastructure development, among other areas.
VALUE CHAIN STRENGTHENING AND LOCAL PROCUREMENT
We support inclusive procurement practices, working with local businesses and communities, and prioritising the employment of people from communities surrounding our operations, in line with our localisation strategy. We maintain a strict governance policy across our global procurement activities that covers the following:
- Supplier Self-Assessment Questionnaire – online forum for registration and disclosure of supplier information prior to contract award
- Supplier Code of Conduct – encourages all our suppliers, including contractors, to align their businesses with our internal policies and codes of ethical behaviour, particularly on human rights practices, labour relations and employment practices, the environment, our anti-bribery and corruption policies, and safety procedures, policies and standards
- Anti-Bribery and Anti-Corruption Policy – commitment to and adherence by employees and suppliers to non-negotiable values
- Conflict of Interest Policy – commitment to and adherence by employees and suppliers and mandatory disclosure of any conflicts related to procurement activities
We seek to comply with local content laws in every country and, where necessary, conduct due diligence on local joint ventures to ensure that they promote skills transfer and capacity-building of local partners to ensure long-term sustainability.
Our local procurement policy emphasises partnerships with locally owned and operated companies and, where appropriate, international firms are requested to establish themselves in-country or through a local joint venture.
This policy reinforces our commitment to local host communities, but also increases transparency of procurement practices in-country. Targets are set to drive continuous improvement in local procurement for each country, while recognising that capacity building in each jurisdiction takes time. While regulatory requirements are not mandating local procurement requirements in Australia, Brazil, or Argentina, our focus is on finding local partners in those jurisdictions as well. This is included in the sourcing and adjudication process for suppliers with preference placed on in-country suppliers.
Managing requests by government departments and government officials is a key compliance risk at AngloGold Ashanti. See Our approach to sustainability for an outline our strategy. This risk is managed through, among other things, Group policies, site-specific procedures, online and face-to-face training, quarterly books and records, review of payments, on-site compliance risk assessments, and awareness raising through communications. Several country-specific procedures address risks, manage how we interact with government officials and other stakeholders, and ensure accurate books and records for payments to government departments and officials or key stakeholders.
There are also government payment procedures and petty cash policies that align to country-specific policies and procedures.
In 2021, Group Compliance continued to strengthen controls to prevent and detect risks, including fraud, bribery and corruption risks, in respect of these payments.
We also continued to adopt a risk-based approach to the vetting of third-party agents and intermediaries and require them to adhere to anti-bribery and anti-corruption policies and procedures, including in relation to payments to government officials.
The Group follows the Procedure on Engagement of Agents and Government Intermediaries and there are also site-specific procedures around payments to government officials.
Review of processes in relation to the above procedures, where applicable, form part of the site reviews conducted by Group Compliance during combined assurance reviews.
On a quarterly basis, sites report on payments to the country or regional audit committees. Information is consolidated for reporting to the Serious Concerns Committee and the SES Committee for transparency.
OUR COMMITMENT TO TRANSPARENCY IN TAXES AND PAYMENTS TO GOVERNMENTS
We are transparent in disclosing taxes paid to governments, per country, in our financial statements. AngloGold Ashanti has, for the last four years, complied with country-by-country reporting to the South African Revenue Service (SARS), which includes profits, taxes paid, number of employees and assets per country. SARS may share this information with other revenue authorities around the world. External auditors perform detailed verification audits on our revenues, profits, taxes, transfer pricing, and cashflows and any detected illicit flows are reported as irregularities. Management’s controls over these areas are evaluated on a quarterly basis.
We are also a member of the ICMM, which through its Tax Working Group, is advocating the adoption of a project by the Global Sustainability Standards Board (GSSB). The project’s objective is to develop new, specific disclosures related to tax and payments to governments, with significant proposals, including the GRI standards on tax reporting. This will encompass country-by-country tax reporting, including qualitative statements relating to our approach to tax planning, the board’s involvement in tax, and our approach to engagement with tax authorities globally. AngloGold Ashanti is currently well positioned in preparing to comply with the standard.