Sibanye Stillwater : ICMM self-assessment 2020

O U R M I N I N G I M P R OV E S L I V E S

SIBANYE-STILLWATER'S ICMM SELF ASSESSMENT FOR THE YEAR ENDING 31 DECEMBER 2020

JSE: SSW NYSE: SBSW

The ICMM has five subject matters that are covered by the reporting assurance engagement and within our Integrated Annual Report 2020.

Subject matter 1 requires alignment of the member's sustainability policies, standards and procedures to the ICMM principles, mandatory requirements of the position statements, corporate level performance expectations and corporate-level aspects of the relevant combined corporate- and asset-level performance expectations.

Sibanye-Stillwater was accepted as an ICMM member in February 2020. The Group has a two-year period to address the gaps identified during the review process. Progress has been made to close the gaps. As a first step, Sibanye-Stillwater reviewed all ESG-related policy statements to the ICMM mandatory requirements as set out in ICMM Position Statements, the corporate-level Performance Expectations, and the corporate-level aspects of combined Performance Expectations. The policy statements reviewed were those on human rights and stakeholder engagement. An ESG policy statement has been drafted to incorporate the previous sustainability, community and indigenous people, environmental, carbon and water policy statements. Sibanye-Stillwater has also drafted position statements in support of the reviewed policy statements to provide relevant technical guidance. Refer below on remaining ICMM gaps and the related action plans to address them. Further disclosure is also made to page 107 of the Integrated Annual Report.

This year we have added an accountability, governance and assurance section to the performance chapters within the Integrated Annual Report that sets out the primary policies, standards and procedures of the Group. Empowering our workforce, page 185, Continuous safe production, page 205, Health, well-beingand occupational hygiene, page 217, and Minimising our environmental impact, page 246.

The table that follows also provide information stipulating the alignment to the performance expectations.

Subject matter 2 to document the material review process of the Group's material sustainability risks and opportunities based on its own review of the business and the views and expectations of its stakeholders.

We identify and assess our material issues through ongoing business review processes and completed a workshop this year. The process followed is inextricably linked to our integrated thinking and considers various aspects to derive at the material issues that this report reflects on. For further detail on the workshop and the material issues refer to Our material issues, page 68.

Our risk process is explained under Managing our risks and opportunities within the external operating environment, page 26.

Other sustainability related risk discussions have also been included under, Continuous safe production, page 206 - 209, Health, well-being and occupational hygiene, page 221 - 226, Social upliftment and community development page 231 - 240, and as part of our Minimising our environmental impact page 248, 251, 255 - 257, 266 - 270 amongst others.

Subject matter 3 requires Sibanye-Stillwater to provide detail about its systems and approaches that the Group is using to manage workforce safety as a material sustainability risk and opportunity.

Detailed disclosure is provided about our approach to managing Continuous safe production. Refer to page 205 of the Integrated Annual Report.

Sibanye-Stillwater's reported performance during the given reporting period, for a selection of material indicators of the identified material issues, have been assured as part of the Subject matter 4 requirement. The assurance opinion to these indicators can be found on page 307 of the Integrated Annual Report.

Sibanye-Stillwater's disclosure regarding the company's prioritisation process as required by Subject matter 5 for selecting assets for third-party Performance Expectation validation rest on Sibanye-Stillwater's production split. Further to this the operations in Southern Africa accounts for the majority of ounces produced, and account for most of the workforce employed - the majority of our activities occur in South Africa.

Therefore, the asset selection for 2021 third party assurance of the ICMM Performance Expectations will be of the South African PGMs segment. The year thereafter, 2022, it will be the SA gold segment and the US PGM operations will be the last asset to be reviewed in the three-year third party assurance cycle.

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SIBANYE-STILLWATER'S ICMM SELF ASSESSMENT FOR THE YEAR ENDING 31 DECEMBER 2020 CONTINUED

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As part of the ICMM membership application the performance expectations were considered during the self-assessment of the ICMM principles and a summary is represented within the following table:

Performance expectations	Assessment summary				GAP
Principle 1: Apply ethical business practices and sound systems of corporate governance and transparency to support sustainable development
Performance expectations	Corporate	SA PGM	SA gold	US PGM
1.1 Establish systems to maintain compliance	Meets
with applicable law.	Sibanye-Stillwater subscribes a zero-tolerance for regulator non-compliance, for which dedicated compliance officers appointed at the US and SA operations have responsibility. Corporate governance, page 123
Applicable: Corporate and Asset
1.2 Implement policies and practices to prevent	Meets
bribery, corruption and publicly disclose	The fundamental roots of Sibanye-Stillwater are in the Company values and CARES culture, which provide a solid base for the way the Company does business. Our CARES values are presented in Our purpose, vision and
facilitation payments.
strategy, page 6
Applicable: Corporate and Asset	Our code of ethics requires the reporting of contraventions and non-compliance with relevant legislation and regulations and outlines our approach to ethical business practices.
	To facilitate reporting of non-compliance toll free lines are available for the US operations and SA operations. Corporate governance, page 108
	Facilitation payments are addressed within the Code of Ethics available https://www.sibanyestillwater.com/sustainability/reports-policies/
1.3 Implement policies and standards	Partially meets	N/A	N/A	N/A	Ensure that all Corporate and Business Unit (BU)
consistent with the ICMM policy	Sibanye-Stillwater is members of the ICMM since				Level policies and standards have been revised
framework.				to incorporate the requirements of the ICMM
February 2020 following a third party assurance and
				Sustainability Principles, Position Statements and
Applicable: Corporate	independent panel review. The Company has a two-
			Performance Expectations.
	year period to address the gaps identified during the
	review process. The Company is progressing to close				30 August 2021
	these gaps and as a first step has aligned its policies				Ensure that all employees, contractors and suppliers
	to the ICMM requirements. The policies that have
				are aware of the revised Policy Statement and the
	been reviewed are the Sustainable Development
				actions necessary to meet its requirements at all
	Policy Statement, the Human Rights Policy
				BUs.
	Statement and the Stakeholder Engagement Policy
	Statement. The Group has also drafted position				31 December 2021
	statements aligning to the ICMM requirements.
	These position statements are:
	Indigenous People and Mining, Partnership on
	Development, Climate Change, Water, Protected
	Area, and Transparency on Mineral Revenues. A
	tailings procedure has also been adopted.
1.4 Assign accountability for sustainability	Meets	N/A	N/A	N/A
performance at the Board and/or Executive	Social, economic and natural environment as
Committee level.
well as ethics are being considered by the Board's
Applicable: Corporate	Social, Ethics and Sustainability Committee. A sub-
	committee of the Group Executive Committee is
	primarily responsible for environmental, social and
	governance performance and reporting.
	Corporate governance: Page 120

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SIBANYE-STILLWATER'S ICMM SELF ASSESSMENT FOR THE YEAR ENDING 31 DECEMBER 2020 CONTINUED

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Performance expectations	Assessment summary				GAP
Principle 1: Apply ethical business practices and sound systems of corporate governance and transparency to support sustainable development continued
Performance expectations	Corporate		SA PGM	SA gold	US PGM
1.5 Disclose the value and beneficiaries of financial	Meets		N/A	N/A	N/A
and in-kind political contributions whether	No political contributions were made.
directly or through an intermediary.
Applicable: Corporate	Corporate governance: Page 108
Principle 2: Integrate sustainable development in corporate strategy and decision-making processes
2.1 Integrate sustainable development principles	Meets		N/A	N/A	N/A
into corporate strategy and decision-making	Our business strategy were further strengthened
processes relating to investments and in the
by a sixth strategic focus area, embedding
design, operation and closure of facilities.
environmental, social and governance.
Applicable: Corporate	A closure guideline is in place which consider social
	aspects.
	(Our strategy and strategic delivery, page 19;
	Embedding ESG excellence, page 62)
2.2 Support the adoption of responsible health and	Partially meets		Partially meets		Partially meets	Conduct a comprehensive review of Sibanye-
safety, environmental, human rights and labour	The suppliers, business partners and contractors		Requirements to third parties such as supplier and contractors by way of annexures to contract emphasise	The US operations have environmental requirements	Stillwater's supplier and contractor management
policies and practices by joint venture partners,		system elements as they relate to the ICMM
are requiring adherence to the Company's policies		responsibility for Sustainable Development and onsite contractors are subjected to adherence Health and	in vendor contracts.
suppliers and contractors, based on risk		Sustainable Development framework, including
and practices as stipulated in the Company's		Safety requirements as per the Mine Health and Safety Act.
		The terms and conditions to be updated to	but not limited to screening procedures, follow-
Applicable: Corporate and asset	business contracts.
			up procedures for "high-risk" suppliers and
	Surveys to suppliers on ESG compliance have been issued during 2020. For further detail refer to	include human rights and sustainability
			contractors, contractual performance requirements,
	(Social upliftment and community development,		Social upliftment and community development, page 238.	requirements, as well.
		and training, with particular emphasis on
	page 238)
					monitoring and compliance procedures.
						Aspects of this process have been completed by
						31 December 2020, however a third-party review
						of suppliers will take place during 2021 with
						completion of this review by 31 December 2021.
						Due date: 31 December 2021

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SIBANYE-STILLWATER'S ICMM SELF ASSESSMENT FOR THE YEAR ENDING 31 DECEMBER 2020 CONTINUED

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Performance expectations	Assessment summary				GAP
Principle 3: Respect human rights and the interests, cultures, customs and values of employees and communities affected by our activities
	Corporate	SA PGM	SA gold	US PGM
3.1. Support the UN Guiding Principles on	Partially meets	Partially meets			Policy statements:
Business and Human Rights by developing a	Our commitment to respect human rights is	Being a responsible business the Group performed a due diligence investigation on gender specific concerns in 2018, the SA operations completed an	Conduct a comprehensive review of its Human
policy commitment to respect human rights,
Rights Policy Statement, and revise the Policy
stipulated within Sibanye-Stillwater's Human Rights	Employment Equity Barriers Audit focusing on women in mining. The outcomes of this report has seen the establishment of a Women in Mining Working Group
undertaking human rights due diligence and
Statement to ensure it is consistent with the U.N.
Policy Statement.	for the group and the CEO is the co-champion for the Mineral Council's Women-in-Mining initiative for the industry.
providing for or cooperating in processes to
Guiding Principles on Business and Human Rights.
enable the remediation of adverse human
A sexual harassment policy also addresses unfair	Empowering our workforce, page 192
rights impacts that members have caused or			Stakeholder Engagement Policy Statement to
discrimination.
contributed to.	Increase our in-house capacity on human rights and a consolidation of due diligence processes on human rights topics such as the gender barriers report is being	be reviewed to articulate the mechanisms to be
		used by employees and external stakeholders to
Applicable: Corporate and asset	How we engage with stakeholders is stipulated	undertaken. Once consolidated the areas not covered will be receiving attention in 2021.
	report non-compliances and to ensure that redress
in the Stakeholder Engagement policy statement.
	Communities and external stakeholder grievances:			mechanisms are well known.
	Our policy statements are under review to meet all
	ICMM principles.	Grievance process for social matters are discussed within the Integrated Report as part of the grievance procedure.	Due date: 30 August 2021
	Refer to the link where the Human Rights and	• The Grievance register is in place for all the operations
	Stakeholder Engagement policy statements can	• Independence included in resolution matrix
	be found: https://www.sibanyestillwater.com/
	• Grievance mechanism in place to be used by employees and external stakeholders to report and escalate complaints as well as to report non compliances and
	sustainability/reports-policies/
	to ensure that redress mechanism is known.
		Social upliftment and community development, page 231
		A toll-free line managed by an independent party is available for all operations. Corporate governance, page 108
		Worker grievances
		Employees can either formally or informally raise concerns and is guided by the Grievance Policy in place. Empowering our workforce, page 193.
3.2 Avoid the involuntary physical or economic	N/A	Partially meets		Meets	By 31 December 2021, review its Communities
displacement of families and communities.		We have drafted an ESG policy statement with supporting position statements of which one such position	The National Historic Preservation Act (NHPA) requires	and Indigenous Peoples Policy to ensure that it is
Where this is not possible apply the mitigation		consistent with ICMM Performance Expectation.
	statement is on Indigenous people. The ESG policy statement will incorporate a number of existing policy	federal agencies to consider effects of federal actions
hierarchy and implement actions or remedies
	statements, and with the supporting positions statements, will meet the ICMM requirements.	on cultural resources, including traditional cultural	As part of this process, identify the specific
that address residual adverse effects to restore
			properties eligible for or listed in the National Register	standards that will guide its performance if
or improve livelihoods and standards of living of		Sustainable Development Policy Statement and Community and Indigenous People policy statement
	of Historic Places, and to consult with American	resettlement/displacement issues are encountered
displaced people.
	currently in place. Please refer to the link to view the Policy Statements: https://www.sibanyestillwater.
	Indian tribes to identify and resolve any adverse	going forward.
		com/sustainability/reports-policies/
Applicable: Asset			effects. Whenever a new action is proposed at
			Due date: 31 December 2021
		Resettlement procedure in development that will be applicable to all of Sibanye-Stillwater's assets.	the US operations, an environmental assessment is
		completed by federal and state agencies that includes
		Resettlement procedure critical for SA PGM operations as potential of resettlement might occur in
		consultation with American Indian tribes regarding
		future endeavours.
			cultural resources that would potentially be affected
		Social upliftment and community development, page 238	by the proposed action.

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SIBANYE-STILLWATER'S ICMM SELF ASSESSMENT FOR THE YEAR ENDING 31 DECEMBER 2020 CONTINUED

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Performance expectations	Assessment summary				GAP
Principle 3: Respect human rights and the interests, cultures, customs and values of employees and communities affected by our activities continued
	Corporate	SA PGM	SA gold	US PGM
3.3 Implement, based on risk, a human rights and	N/A	Meets		Meets
security approach consistent with the Voluntary		Sibanye Protection Services manages a screening process by which all employees inclusive of security	Training for the US contractors providing
Principles on Security and Human Rights.
	contractors are screened.		security services on human rights is part of initial
Applicable: Asset				employment training.

With regard to security officers in South Africa, all security personnel have to be registered with PSIRA.

		Training through the induction programme includes Human Rights related material.
3.4 Respect the rights of workers by: not employing	Meets
child or forced labour; avoiding human	Refer to the Human Rights Policy Statement in which we stipulate our commitment to not employ children as well as not subject any worker to modern slavery. Within this policy statement we commit to freedom of
trafficking; not assigning hazardous/dangerous
association and collective bargaining process. Please refer to: https://www.sibanyestillwater.com/sustainability/reports-policies/
work to those under 18; eliminating harassment
and discrimination; respecting freedom of	Our grievance process for employees is explained in Empowering our workforce, page 193
association and collective bargaining and;
providing a mechanism to address	Refer to diversity discussion within our Integrated Annual Report 2020. Empowering our workforce, page 110; 193
workers grievances.
Applicable: Corporate and asset
3.5 Remunerate employees with wages that equal	Meets
or exceed legal requirements or represent	The Remuneration Committee assists the Board in discharging its responsibilities for setting and administering remuneration policies and practices. The Group takes care to design remuneration structures which
a competitive wage within that job market
incorporate performance targets, and consider the sustainability of the business, the career paths of leaders and the management of emerging talent.
(whichever is higher) and assign regular and
overtime working hours within legally	Refer to Remuneration Chapter in IAR Remuneration report, page 131- 133; Empowering our workforce, page 199
required limits.
Applicable: Corporate and asset
3.6 Respect the rights, interests, aspirations,	N/A	Partially meets		Partially meets
culture and natural resource based livelihoods		Sibanye-Stillwater's Purpose is: "Our mining improves lives", and our Vision Statement is: 'Superior value		The American Indian Religious Freedom Act (AIRFA)
of Indigenous Peoples in project design,
	creation for all our stakeholders through the responsible mining of our mineral resources."		protects and preserves for American Indians,
development and operation; apply the
			Eskimos, Aleuts, and Native Hawaiians their inherent
mitigation hierarchy to address adverse impacts		A Position Statement: Indigenous people has been drafted defining Indigenous people for the SA
		right of freedom to believe, express, and exercise
and; deliver sustainable benefits for
	operations as well as the governance, monitoring and evaluation of performance with regards to
		their traditional religions.
Indigenous Peoples.
	Indigenous People.
Applicable: Asset					Refer to gap of PE3.2
3.7 Work to obtain the free, prior and informed	N/A	Partially meets
consent of Indigenous Peoples where significant		The draft ESG policy statement specifically commits to free, prior and informed consent.
adverse impacts are likely to occur, as a result of
relocation, disturbance of lands and territories		A draft Heritage Position Statement which is inclusive of a Chance Find Protocol has been created to meet this particular performance expectation of the ICMM.
or of critical cultural heritage, and capture
the outcomes of engagement and consent
processes in agreements.
Applicable: Asset
3.8 Implement policies and practices to respect	Meets
the rights and interests of women and support	"At Sibanye-Stillwater, we are committed to advancing the development of women in the mining industry and better understand the culture of gender inclusion	and equality amongst our workforce. It is our belief
diversity in the workplace.
that excellence does not distinguish between genders and our leaders are sensitised to create a balanced work environment that actively promotes gender equality.
Applicable: Corporate and asset	In my capacity as Minerals Council Vice President, and Women-in-Mining Champion, I am particularly passionate about gender equality and am using my influence to drive a step change in the participation on women
	in our industry." Neal Froneman 7 October 2020.
	Refer to the diversity section of the Integrated Annual Report 2020: Empowering our workforce, page 191 - 192

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