Strategy

A mining group's integrity exposure is concentrated at three points: the acquisition and maintenance of rights, where dealings with public officials are frequent and consequential; the movement of value, where precious metals attract laundering risk irrespective of the producer's own conduct; and the supply chain, where a counterparty's conduct becomes our problem the moment it is attributed to us.

The human rights exposure follows the same geography. It is concentrated where an activity meets land that people live on and work, where security arrangements meet a community, and where labour is engaged through intermediaries rather than directly.

The strategy is to control those points specifically, rather than to state a general commitment and hope it reaches them.

Integrity and human rights risks are identified through the same processes as any other enterprise risk: assessment at the point a decision is designed, recording in the risk register, and reassessment when the activity or its setting changes. Human rights risk is additionally assessed through impact assessment at activity level, and records are kept of the activities for which an assessment has been completed and of the date each was last reviewed.

Due diligence is risk-based. We classify a counterparty on onboarding by geography, sector, value and exposure to high-risk commodities or jurisdictions, and the diligence we apply follows that classification. We conduct enhanced diligence before engaging a supplier operating in a region with known human rights risks, and where sourcing is from conflict-affected or high-risk areas.

The board endorses the Code of Conduct and holds itself to the standards it sets for others. Responsibility for issuing the integrity policies, monitoring adherence and operating the reporting channels is assigned within the Group and named in the governing policy, as is responsibility for coordinating human rights due diligence and for identifying the requirements that apply in each jurisdiction. Each policy is reviewed on the cycle stated in it, and again on a significant incident or a change in regulation.

Aggregate reporting on case volumes, investigation outcomes and training completion rates is published where reporting it is required of us. We maintain the records so that such reporting can be produced on a consistent basis.