African Rainbow Minerals : ARM ICMM Performance Expectations Self-assessment 2023 (871.15 KB)

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ARM's ICMM Performance Expectations Self-assessment for the year ending 30 June 2023

Overview

In 2020, the ICMM launched enhanced membership requirements that further strengthen members' social and environmental requirements, underpinned by the 38 performance expectations (PEs). These support progress towards the global targets of the United Nations Sustainable Development Goals (UN SDGs) and the Paris Agreement on climate change. The enhanced requirements include robust asset and corporate-level validation, credible assurance, and transparent disclosure to maximise the industry's benefits to host communities and minimise negative impacts to effectively manage issues of concern to society.

Process

All assets subject to PE validation are required to conduct self-assessments once every three years and third-party validation of prioritised assets within a three-year validation cycle. By September 2022, members were required to complete self-assessments for all assets and prioritise assets for validation in the first three-year cycle. ARM started piloting self-assessments of PEs in F2019 and self-assessments for all the assets were completed by the September 2022 deadline.

Prioritisation

ARM's prioritisation of assets selected for PE validation aligns with the ESG report assurance process, with operations selected for external assurance visits in a given year also prioritised for PE validation. In F2023, independent third-party validation of the asset self-assessments was carried out at the Modikwa and Khumani mines. All assets will be subject to external PE validation over a three-year cycle. Gaps in alignment with the PEs identified in these processes are being addressed.

FOR THE YEAR ENDING 30 JUNE 2023

ARM'S ICMM PERFORMANCE EXPECTATIONS SELF-ASSESSMENT

Our business

African Rainbow Minerals (ARM) is a leading South African diversified mining and minerals company with

operations in South Africa and Malaysia. ARM mines and beneficiates iron ore, manganese ore, chrome ore, platinum group

metals (PGMs), nickel and coal. It also produces manganese alloys and has a strategic investment in gold through Harmony Gold Mining

Company Limited.

4

100%

100%

10%

51%

12.1%

Harmony

Gold

PGMs	Iron ore	20%	Coal
41.5% Modikwa1	50% Khumani		Participative Coal	51%
54% Two Rivers	50% Beeshoek		Business (PCB)5
100% Bokoni2
Nickel, PGMs	Manganese		Coal
ore		Goedgevonden
and chrome	50% Nchwaning		(GGV)5
50% Nkomati3	50% Gloria

Manganese

alloys

50% Cato Ridge Works

25% Cato Ridge Alloys

27% Sakura

1. ARM's effective interest in Modikwa Mine is 41.5%, local communities hold an effective 8.5% interest.
2. The acquisition of Bokoni Mine became effective on 1 September 2022. Qualifying employees, host communities and black industrialists will be allocated 15% in Bokoni Mine, with each group owning 5%.
3. Nkomati Mine is on care and maintenance.
4. ARM owns Machadodorp Works which is currently being used to develop more cost-effective and energy-efficient ways of smelting.
5. ARM's effective interest in GGV Mine is 26% and 20.2% in PCB.

ARM'S ICMM PERFORMANCE EXPECTATIONS SELF-ASSESSMENT FOR THE YEAR ENDING 30 JUNE 2023

1

ARM's ICMM Performance Expectations

Self-assessment for the year ending 30 June 2023 continued

								Sites that went through
				Self-assessed sites			external verification
			Cato		Two Rivers				Modikwa
	Beeshoek	Black Rock	Ridge	Machadodorp	Platinum	Nkomati		Khumani	Platinum
ICMM's Mining Principles	Mine	Mine	Works	Works	Mine	Mine	Corporate	Mine	Mine	Comments

PRINCIPLE 1: Apply ethical business practices and sound systems of corporate governance and transparency to support sustainable development

Documents and publications

ICMM PERFORMANCE EXPECTATIONS SELF-ASSESSMENT THE YEAR ENDING 30 JUNE 2023

1.1: Establish systems	Corporate
to maintain	and Asset
compliance with	level
applicable law

1.2: Implement policies	Corporate
and practices	and Asset
to prevent bribery	level
and corruption, and
to publicly disclose
facilitation payments

1.3: Implement policies	Corporate
and standards	level
consistent with the
ICMM policy
framework

The Compliance Executive reviews current compliance systems. A legal
compliance landscape review is facilitated by an external service
provider annually. SHE compliance reviews are conducted
by Corporate on assets on a quarterly basis. Results of compliance are
reported to the social and ethics committee (SEC) and management
risk committee which reports to the audit and risk committee
on a quarterly basis. Each divisional chief executive submits
a compliance certificate to the CEO and SEC quarterly.
The ARM Code of Conduct is in place that contains anti-bribery and	2023 ESG Report
corruption measures. Procedures on theft-fraud-defalcation and	page 34,148
misappropriation of company property, cash and services have been	ESG
rolled out company-wide and related online etraining is conducted
annually. This also covers appropriate joint venture (JV) partners. ARM's
anonymous whistleblowers' hotline [phone]) is operated by an
independent service provider that has been certified by the Ethics
Institute, and includes a 'Please Call Me' option. Details about the
hotline are included in the Code and are posted at the company's
offices and operations. The hotline is available to employees,
contractors, suppliers, communities, and other stakeholders to report
unethical behaviour. Incidents reported through the whistleblower
facility are investigated and progress and actions taken are reported
at the quarterly SEC meetings. Feedback is also provided to the
whistleblowers' facility, who engage with the whistleblower to update
them regarding the investigation.
The SEC charter terms of reference, which is a board instrument,
commits to implement the ICMM policy framework, which is supported
by a number of policies and standards, including among others the
Group SHE Policy, Group Human Rights Policy, Group Code
of Conduct, Water Stewardship Policy, Climate Change Policy, Wellness,
HIV and AIDS Policy, Tailings Storage Facilities (TSF) Management
Policy and TSF Management Standard. This commitment is reaffirmed
in each year's ESG Report and IAR, specifically in the chairman's
review section.

ARM'S ICMM PERFORMANCE EXPECTATIONS SELF-ASSESSMENT FOR THE YEAR ENDING 30 JUNE 2023

ARM'S FOR

Meets	Does not meet	Partially meets	N/A

2

3

ARM's ICMM Performance Expectations

Self-assessment for the year ending 30 June 2023 continued

								Sites that went through
				Self-assessed sites			external verification
			Cato		Two Rivers				Modikwa
	Beeshoek	Black Rock	Ridge	Machadodorp	Platinum	Nkomati		Khumani	Platinum
ICMM's Mining Principles	Mine	Mine	Works	Works	Mine	Mine	Corporate	Mine	Mine	Comments

Documents and publications

PRINCIPLE 1: Apply ethical business practices and sound systems of corporate governance and transparency to support sustainable development continued

ICMM PERFORMANCE EXPECTATIONS SELF-ASSESSMENT THE YEAR ENDING 30 JUNE 2023

1.4: Assign accountability	Corporate
for sustainability	level
performance at the
board and/or
executive committee
level

1.5: Disclose the value	Corporate
and beneficiaries	level
of financial and
in-kind political
contributions whether
directly or through
an intermediary

The ultimate responsibility for monitoring the effective management	2023 ESG Report
of sustainable development lies with the ARM board. The board	ESG
delegates this responsibility to the ARM SEC. The purpose of this
committee is to monitor and report on the manner and extent to which
ARM protects, enhances and invests in the economy, society and
natural environment in which it operates to ensure its business
practices are sustainable. The executive: sustainable development
operates with oversight from the SEC, and reviews sustainability
policies, standards, strategies and targets and ensures these align with
the board's commitment to zero tolerance for harm. The executive:
sustainable development provides input into the management risk and
compliance committee on matters related to sustainable development
as a standard agenda item. The executive: sustainable development
participates in SEC meetings and is a member of the management risk
and compliance committee and the ARM steering committee and also
attends board meetings to respond to any sustainable development-
related matters raised by the board. The terms of reference for the
board and its committees, as well as those of divisional and operational
committees, are regularly reviewed and updated to ensure that they
continue to appropriately address industry and regulatory
developments. The Assmang social and ethics committee monitors
sustainability performance in the ferrous division and is chaired by the
ARM executive: investor relations and new business development.
Quarterly compliance meetings at the ARM Ferrous operations ensure
comprehensive reporting is covered at the operational level. The
operations in the ARM Platinum division each have standalone
sustainable development committees chaired by the ARM executive:
sustainable development. These committees report to exco or board
of the respective joint ventures, as appropriate. The Assmang social
and ethics committee and the sustainable development committees
in the ARM Platinum division report regarding operational performance
and compliance to the ARM SEC at quarterly meetings.
The value of political donations is disclosed in the GRI Table	2023 ARM GRI index
	https://www.arm-ir-
	reports.co.za/reports/
	arm-iar-2022/pdf/
	ARM-GRI-2022.pdf

ARM'S ICMM PERFORMANCE EXPECTATIONS SELF-ASSESSMENT FOR THE YEAR ENDING 30 JUNE 2023

ARM'S FOR

Meets	Does not meet	Partially meets	N/A

4

5

ARM's ICMM Performance Expectations

Self-assessment for the year ending 30 June 2023 continued

								Sites that went through
				Self-assessed sites			external verification
			Cato		Two Rivers				Modikwa
	Beeshoek	Black Rock	Ridge	Machadodorp	Platinum	Nkomati		Khumani	Platinum
ICMM's Mining Principles	Mine	Mine	Works	Works	Mine	Mine	Corporate	Mine	Mine	Comments

PRINCIPLE 2: Integrate sustainable development in company strategy and decision making processes

Documents and publications

2.1: Integrate sustainable	Corporate
development	level
principles into
corporate strategy
and decision making
processes relating
to investments and
in the design,
operation and closure
of facilities
2.2: Support the adoption	Corporate
of responsible health	and Asset
and safety,	level
environmental,
human rights and
labour policies and
practices by joint
venture partners,
suppliers and
contractors, based
on risk

ARM's sustainable development model applies (refer to F2023 ESG	2023 ESG Report,
Report, page 32). Asset-level implementation through management	page 32
systems.	ESG

ARM expects its suppliers and contractors to behave ethically and with respect for human rights through the Code of Conduct that suppliers have to sign up to in contracts. Supplier contracts address sustainability issues as far as is practical through the asset-level EHS management systems. The ARM SHE Policy and the ARM Human Rights Policy also addresses these aspects for suppliers and contractors.

ARM'S ICMM PERFORMANCE EXPECTATIONS SELF-ASSESSMENT FOR THE YEAR ENDING 30 JUNE 2023

Meets	Does not meet	Partially meets	N/A

ARM'S ICMM PERFORMANCE EXPECTATIONS SELF-ASSESSMENT FOR THE YEAR ENDING 30 JUNE 2023

6

7

ARM's ICMM Performance Expectations Self-assessment for the year ending 30 June 2023 continued

								Sites that went through
				Self-assessed sites			external verification
			Cato		Two Rivers				Modikwa
	Beeshoek	Black Rock	Ridge	Machadodorp	Platinum	Nkomati		Khumani	Platinum
ICMM's Mining Principles	Mine	Mine	Works	Works	Mine	Mine	Corporate	Mine	Mine	Comments

PRINCIPLE 3: Respect human rights and the interests, cultures, customs and values of employees and communities affected by our activities

Documents and publications

ICMM PERFORMANCE EXPECTATIONS SELF-ASSESSMENT THE YEAR ENDING 30 JUNE 2023

3.1: Support the	Corporate
UN Guiding	and Asset
Principles	level
on Business and
Human Rights
by developing
a policy commitment
to respect human
rights, undertaking
human rights due
diligence and
providing for
or cooperating
in processes
to enable the
remediation
of adverse human
rights impacts that
members have
caused
or contributed to
3.2: Avoid the involuntary	Asset level
physical or economic
displacement
of families and
communities. Where
this is not possible,
apply the mitigation
hierarchy and
implement actions
or remedies that
address residual
adverse effects
to restore or improve
livelihoods and
standards of living
of displaced people
3.3: Implement, based	Asset level
on risk, a human
rights and security
approach consistent
with the Voluntary
Principles on Security
and Human Rights

ARM has a Human Rights Policy, where the approach to promoting and protecting human rights aligns with South Africa's human rights legislation, including the Constitution and the Bill of Rights, which safeguard basic human rights. We are committed to the 10 principles of the United Nations Global Compact (UNCG) and conduct human rights assessments aligned with the United Nations' Protect, Respect and Remedy Framework. Human rights principles are integrated into business policies and management systems to ensure that human rights are appropriately managed and addressed. The fundamental concepts underlying these rights inform the Code as well as ARM's Grievance Procedure, Protected Disclosure and Sexual Harassment policies. The Code emphasises the company's strong stance against unfair discrimination and, together with the Employment Equity Policy and ARM's human resources management policies, promotes equality and the elimination of unfair discrimination on the basis of race, ethnicity, colour, gender, sexual orientation, nationality, place of origin, citizenship, creed, political persuasion, age, marital or family status or disability. ARM is committed to fair, responsible and competitive remuneration and all non-management employees are afforded freedom of association. We do not use forced, compulsory or child labour. Security personnel, including contractors, receive human rights training as well as regular refresher training. Operational community relations strategies uphold and promote human rights and respect cultural considerations and heritage. Employees who feel that their human rights have been violated can report their grievances anonymously through the whistleblower facility, directly to their supervisors or managers, or to the human resources department. We expect our suppliers and contractors

to behave ethically and with respect for human rights.

ARM'S ICMM PERFORMANCE EXPECTATIONS SELF-ASSESSMENT FOR THE YEAR ENDING 30 JUNE 2023

ARM'S FOR

Meets	Does not meet	Partially meets	N/A

8

9

ARM's ICMM Performance Expectations Self-assessment for the year ending 30 June 2023 continued

								Sites that went through
				Self-assessed sites			external verification
			Cato		Two Rivers				Modikwa
	Beeshoek	Black Rock	Ridge	Machadodorp	Platinum	Nkomati		Khumani	Platinum
ICMM's Mining Principles	Mine	Mine	Works	Works	Mine	Mine	Corporate	Mine	Mine	Comments

PRINCIPLE 3: Respect human rights and the interests, cultures, customs and values of employees and communities affected by our activities continued

Documents and publications

ICMM PERFORMANCE EXPECTATIONS SELF-ASSESSMENT THE YEAR ENDING 30 JUNE 2023

3.4: Respect the rights	Corporate
of workers by: not	and Asset
employing child	level
or forced labour;
avoiding human
trafficking; not
assigning hazardous/
dangerous work
to those under 18;
eliminating
harassment and
discrimination;
respecting freedom
of association and
collective bargaining;
and providing
a mechanism
to address workers
grievances
3.5: Remunerate	Corporate
employees	and Asset
with wages that equal	level
or exceed legal
requirements
or represent
a competitive wage
within that job market
(whichever is higher)
and assign regular
and overtime working
hours within legally
required limits

ARM has a Human Rights Policy, where the approach to promoting and protecting human rights aligns with South Africa's human rights legislation, including the Constitution and the Bill of Rights, which safeguard basic human rights. We are committed to the 10 principles of the UNGC and conduct human rights assessments aligned with the United Nations' Protect, Respect and Remedy Framework. Human rights principles are integrated into business policies and management systems to ensure that human rights are appropriately managed and addressed. The fundamental concepts underlying these rights inform the Code as well as ARM's Grievance Procedure, Protected Disclosure and Sexual Harassment policies. The Code emphasises the company's strong stance against unfair discrimination and, together with the Employment Equity Policy and ARM's human resources management policies, promotes equality and the elimination of unfair discrimination on the basis of race, ethnicity, colour, gender, sexual orientation, nationality, place of origin, citizenship, creed, political persuasion, age, marital or family status or disability. ARM is committed to fair, responsible and competitive remuneration and all non-management employees are afforded freedom of association. We do not use forced, compulsory

or child labour. Security personnel, including contractors, receive human rights training as well as regular refresher training. Operational community relations strategies uphold and promote human rights and respect cultural considerations and heritage. Employees who feel that their human rights have been violated can report their grievances anonymously through the whistleblower facility, directly to their supervisors or managers, or to the human resources department.

We expect our suppliers and contractors to behave ethically and with respect for human rights.

The assets that self-assessed themselves as partially meeting the performance expectations follow ARM policies and standards, but areas of improvement have been identified and the assets are addressing the identified gaps.

ARM'S ICMM PERFORMANCE EXPECTATIONS SELF-ASSESSMENT FOR THE YEAR ENDING 30 JUNE 2023

ARM'S FOR

Meets	Does not meet	Partially meets	N/A

10

11

ARM's ICMM Performance Expectations Self-assessment for the year ending 30 June 2023 continued

								Sites that went through
				Self-assessed sites			external verification
			Cato		Two Rivers				Modikwa
	Beeshoek	Black Rock	Ridge	Machadodorp	Platinum	Nkomati		Khumani	Platinum
ICMM's Mining Principles	Mine	Mine	Works	Works	Mine	Mine	Corporate	Mine	Mine	Comments

PRINCIPLE 3: Respect human rights and the interests, cultures, customs and values of employees and communities affected by our activities continued

Documents and publications

ICMM PERFORMANCE EXPECTATIONS SELF-ASSESSMENT THE YEAR ENDING 30 JUNE 2023

3.6: Respect the rights,	Asset level
interests, aspirations,
culture and natural
resource-based
livelihoods
of Indigenous
Peoples in project
design, development
and operation; apply
the mitigation
hierarchy to address
adverse impacts; and
deliver sustainable
benefits for
Indigenous Peoples
3.7: Work to obtain the	Asset level
free, prior and
informed consent
of Indigenous
Peoples where
significant adverse
impacts are likely
to occur, as a result
of relocation,
disturbance of lands
and territories or of
critical cultural
heritage, and capture
the outcomes
of engagement and
consent processes
in agreements
3.8: Implement policies	Corporate
and practices	and Asset
to respect the rights	level
and interests
of women and
support diversity
in the workplace

ARM has a Human Rights Policy, where the approach to promoting and protecting human rights aligns with South Africa's human rights legislation, including the Constitution and the Bill of Rights, which safeguard basic human rights. We are committed to the 10 principles of the UNGC and conduct human rights assessments aligned with the United Nations' Protect, Respect and Remedy Framework. Human rights principles are integrated into business policies and management systems to ensure that human rights are appropriately managed and addressed. The fundamental concepts underlying these rights inform the Code as well as ARM's Grievance Procedure, Protected Disclosure and Sexual Harassment policies. The Code emphasises the company's strong stance against unfair discrimination and, together with the Employment Equity Policy and ARM's human resources management policies, promotes equality and the elimination of unfair discrimination on the basis of race, ethnicity, colour, gender, sexual orientation, nationality, place of origin, citizenship, creed, political persuasion, age, marital or family status or disability. ARM is committed to fair, responsible and competitive remuneration and all non-management employees are afforded freedom of association. We do not use forced, compulsory

or child labour. Security personnel, including contractors, receive human rights training as well as regular refresher training. Operational community relations strategies uphold and promote human rights and respect cultural considerations and heritage. Employees who feel that their human rights have been violated can report their grievances anonymously through the whistleblower facility, directly to their supervisors or managers, or to the human resources department.

We expect our suppliers and contractors to behave ethically and with respect for human rights.

The assets that self-assessed themselves as partially meeting the performance expectations follow ARM policies and standards, but areas of improvement have been identified and the assets are addressing the identified gaps.

ARM'S ICMM PERFORMANCE EXPECTATIONS SELF-ASSESSMENT FOR THE YEAR ENDING 30 JUNE 2023

ARM'S FOR

Meets	Does not meet	Partially meets	N/A

12

13

ARM's ICMM Performance Expectations

Self-assessment for the year ending 30 June 2023 continued

								Sites that went through
				Self-assessed sites			external verification
			Cato		Two Rivers				Modikwa
	Beeshoek	Black Rock	Ridge	Machadodorp	Platinum	Nkomati		Khumani	Platinum
ICMM's Mining Principles	Mine	Mine	Works	Works	Mine	Mine	Corporate	Mine	Mine	Comments

Documents and publications

ICMM PERFORMANCE EXPECTATIONS SELF-ASSESSMENT THE YEAR ENDING 30 JUNE 2023

PRINCIPLE 4: Implement effective risk management strategies and systems based on sound science and which account for stakeholder perceptions of risks

4.1: Assess environmental	Corporate
and social risks and	and Asset
opportunities of new	level
projects and of
significant changes
to existing operations
in consultation with
interested and
affected stakeholders,
and publicly disclose
assessment results
4.2 Undertake risk-based	Corporate
due diligence	and Asset
on conflict and human	level
rights that aligns with
the OECD Due
Diligence Guidance
on conflict-affected
and high-risk areas,
when operating in,
or sourcing from,
a conflict-affected
or high-risk area

4.3: Implement risk-based Asset level controls to avoid/

prevent, minimise, mitigate and/or remedy health, safety and environmental impacts to workers, local communities, cultural heritage and the natural environment, based upon

1. recognised international standard or management system

4.4: Develop, maintain and Asset level test emergency

response plans. Where risks

to external stakeholders are significant, this should be in collaboration with potentially affected stakeholders and consistent with established industry good practice

ARM's Risk Management Framework is premised on the principles

of ISO 31000:2018 and contains all of the elements that can be found on our 2023 ESG Report, along with our risk assessment process based on the flow. ARM's operations do not currently operate in a conflict- affected or high-risk area. The sites are either certified to or have the management systems aligned to ISO 14001 (Environmental), ISO 9001 (Quality), ISO 45001 (Occupational Health and Safety), and SANS 16001 (Wellness and disease management system). South African national legislation such as the National Environmental Management Act (NEMA) and the Environmental Impact Assessment (EIA) regulations requires the assessment of environmental and social risks and opportunities of new projects and of significant changes to existing operations in consultation with interested and affected stakeholders, and to publicly disclose assessment results. In addition, in all our projects or operations expansions EIAs, we are also assessing those risks

Performance Expectation 4.3. For the asset that self-assessed as partially meets, controls are in place to mitigate environmental impacts. All environmental aspects or indicators that are monitored within the mine have downstream points that are monitored to ensure adverse impacts do not occur or extend to local communities and the natural environment. Although controls are in place to mitigate the environmental impacts, the asset is developing a risk management strategy commensurate with the risk.

2023 ESG Report

ESG

ARM'S ICMM PERFORMANCE EXPECTATIONS SELF-ASSESSMENT FOR THE YEAR ENDING 30 JUNE 2023

ARM'S FOR

Meets	Does not meet	Partially meets	N/A

14

15

ARM's ICMM Performance Expectations Self-assessment for the year ending 30 June 2023 continued

								Sites that went through
				Self-assessed sites			external verification
			Cato		Two Rivers				Modikwa
	Beeshoek	Black Rock	Ridge	Machadodorp	Platinum	Nkomati		Khumani	Platinum
ICMM's Mining Principles	Mine	Mine	Works	Works	Mine	Mine	Corporate	Mine	Mine	Comments

PRINCIPLE 5: Pursue continual improvement in health and safety performance with the ultimate goal of zero harm

Documents and publications

5.1: Implement practices	Corporate
aimed at continually	and Asset
improving workplace	level
health and safety, and
monitor performance
for the elimination
of workplace fatalities,
serious injuries and
prevention
of occupational
diseases, based upon
a recognised
international standard
or management
system
5.2: Provide workers with	Corporate
training in accordance	and Asset
with their	level
responsibilities for
health and safety, and
implement health
surveillance and
risk-based monitoring
programmes based
on occupational
exposures

ARM has a SHE policy, SEC work plan, quarterly sustainable development committee meeting minutes, annual external health and wellness audit

to ARM standards, annual report on health work, and asset-level health and safety management system, policies and interventions. Scope

of annual occupational health specialist compliance audits. Site-level ISO management systems require training in accordance with relevant job descriptions. Induction training is in place and accredited training centres cover all employees annually for relevant training.

PRINCIPLE 6: Pursue continual improvement in environmental performance issues, such as water stewardship, energy use and climate change

ICMM PERFORMANCE EXPECTATIONS SELF-ASSESSMENT THE YEAR ENDING 30 JUNE 2023

6.1: Plan and design for	Corporate
closure in consultation	and Asset
with relevant authorities	level
and stakeholders,
implement measures
to address closure-
related environmental
and social aspects,
and make financial
provision to enable
agreed closure and
post-closure
commitments to be
realised

Review of closure costing is done by independent consultants in line with applicable legislation and is covered by the financial audit. Closure plans are in place for all assets and are submitted to the Department of Mineral Resources and Energy (DMRE) annually. Closure provisioning assessments are done annually as part of the financial audit.

ARM'S ICMM PERFORMANCE EXPECTATIONS SELF-ASSESSMENT FOR THE YEAR ENDING 30 JUNE 2023

ARM'S FOR

Meets	Does not meet	Partially meets	N/A

16

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