1 st Floor, Building 32 The Woodlands Office Park Woodlands Drive, Woodmead 2148, Johannesburg, South Africa
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1 ERM 1 st Flr, Building 32 The Wdlands Office Park Wdlands Drive, Wdmead 2148, Jhannesburg, Suth Africa Tel: Fax: Independent Assurance Statement T Tngaat Hulett Limited (Tngaat) T the Bard f Directrs and Stakehlders f Tngaat ERM Suthern Africa (Pty) Ltd (ERM) was engaged by Tngaat t prvide assurance in relatin t selected sustainability infrmatin set ut belw and presented in Tngaat s Integrated Annual Reprt fr the year ended 31 March 2018 ( the Reprt ) Engagement Summary 1. Whether Tngaat adheres, in all material respects, t the three AA1000 AccuntAbility Principles f Inclusivity, Materiality and Respnsiveness. 2. Whether the 2018 data, fr the perid 1 April 2018 t 31 March 2018, fr the fllwing selected perfrmance indicatrs, are fairly presented, in all material respects, with the reprting criteria: Engagement Scpe (Subject Matters): a. Ttal vlume f water used (killitres) (page 62); b. Ttal amunt f waste generated (tnnes) (page 62); c. Ttal energy used (gigajules) (page 60); d. Ttal number f envirnmental incidents (page 63); e. Lst-time injury frequency rate (page 52); f. Ttal number f recrdable incidents (page 52); and g. Ttal number f fatalities (page 52). 3. Whether the disclsures n Tngaat s management apprach fr the tpic f Human Rights as presented n page 44 f the Reprt are fairly presented in all material respects. Reprting Criteria: AA1000 AccuntAbility Principles Standard (2008) criteria Glbal Reprting Initiative Sustainability Reprting Standards Tngaat s internal Safety, Health and Envirnment definitins (dated 01/07/2016) Assurance Standard used: AA1000 Assurance Standard (2008) Type 2 Assurance Level: Mderate assurance fr all Subject Matters Page 1 f 5 Registered ffice Envirnmental Resurces Management Suthern Africa (Pty) Ltd 1st Flr, Building 32, The Wdlands Office Park Wdlands Drive, Wdmead 2148, Jhannesburg, Suth Africa Registered number: 2003/001404/07 VAT registratin: Offices wrldwide A member f the ERM Grup Directrs Claudi Bertra Urmilla Bb (Nn-Executive) Tania Swanepel Marinda Rasmussen
2 Page 2 f 5 Respective Respnsibilities: Tngaat is respnsible fr preparing the Reprt, including the cllectin and presentatin f the selected sustainability infrmatin within it, the design, implementatin and maintenance f related internal cntrls, and fr the integrity f its website. ERM s respnsibility is t prvide cnclusins n the selected infrmatin based n the evidence we have btained and exercising ur prfessinal judgement. Our assurance activities We planned and perfrmed ur wrk t btain all the infrmatin and explanatins that we believe were necessary t prvide a basis fr ur assurance cnclusins. A multi-disciplinary team f sustainability and assurance specialists perfrmed the assurance activities, including: A review f external media reprting relating t Tngaat, peer cmpany annual reprts and industry standards t identify relevant sustainability issues in the reprting perid. Interviews with relevant crprate level staff t understand Tngaat s sustainability strategy, plicies and management systems, including stakehlder engagement and materiality assessment. Interviews with human rights issue wners at crprate level t btain an verview f the management and reprting apprach, including internal review prcesses and respnsibilities. Interviews with relevant staff t understand and evaluate the data management systems and prcesses (including internal review prcesses) used fr cllecting and reprting n the data fr the selected indicatrs. A review f the suitability f the internal reprting guidelines, including cnversin factrs used. Testing the prcesses and systems, including internal cntrls, used t generate, cnslidate and reprt the selected sustainability infrmatin. Physical visits t review the cntrl envirnment, surce data and ther evidence at the fllwing site: Verml, Suth Africa Virtual reviews t verify surce data fr the fllwing sites: TH Develpments, Suth Africa Meyertn, Suth Africa (including a face-t-face interview with Meyertn persnnel) Xinavane, Mzambique A review f selected evidence at crprate level related t the design, infrmatin cllectin, and prductin f the Reprt in accrdance with AA1000 AS criteria. An analytical review f the year-end data submitted by the sites listed abve, and testing f the accuracy and cmpleteness f the cnslidated 2018 Grup data fr the selected perfrmance indicatrs. A review f the presentatin f infrmatin relevant t the scpe f ur wrk in the Reprt t ensure cnsistency with ur findings.
3 Page 3 f 5 Basis fr qualified cnclusin During the assurance prcess, we identified deficiencies in the cntrl envirnment at site level, which affect the reliability f the 2018 data fr Subject Matters 2(a) Water Use, (b) Waste Generated, and (c) Energy Use. Recurrent deficiencies included inadequate surce infrmatin fr reprted data (including estimates), differences between site and crprate data, data entry errrs reflecting the manual nature f systems and ineffective management review. Cnsidering the pattern f findings acrss the sites, we cannt exclude the pssibility f material misstatements in the data fr these indicatrs at sites that were nt sampled as part f the mderate assurance engagement. We are therefre unable t cnclude that the cnslidated crprate 2018 data fr these three indicatrs are fairly stated. Our cnclusins AA1000APS (2008) Principles Based n ur activities, nthing has cme t ur attentin t indicate that Tngaat des nt adhere, in all material respects, t the AA1000APS (2008) principles f Inclusivity, Materiality and Respnsiveness. Selected perfrmance indicatrs (qualified cnclusin) Based n ur activities, and with the exceptin f the indicatrs cvered by ur qualificatin abve, nthing has cme t ur attentin t indicate that the 2018 data fr the remaining selected indicatrs, as listed under the scpe abve and presented n pages 52 and 63 f the Reprt, are nt fairly presented, in all material respects, with the reprting criteria. Human rights disclsures Based n ur activities, nthing has cme t ur attentin t indicate that the disclsures n Tngaat s management apprach fr the tpic f Human Rights n page 44 f the Reprt, are nt, in all material respects, fairly presented. Our bservatins and recmmendatins We have prvided Tngaat with a separate management reprt. Withut affecting the cnclusins presented abve, we have the fllwing key bservatins and recmmendatins: In relatin t the Inclusivity principle: Tngaat has numerus stakehlder engagement activities in place that are led by the Cmmunicatins Department at grup level, and by teams at peratinal level. The cmpany links part f its success t sci-ecnmic develpment, and mentins accuntability t stakehlders in internal dcuments such as the Bard Charter, Cde f Business Cnduct and Ethics, and Bard meeting minutes. Additinal dedicated resurces at grup level wuld supprt engagement within the cmpany and with stakehlders. Cnsistent with the previus assurance recmmendatins, and while nting that a draft Stakehlder Engagement Plicy has been drafted in the year under review, this plicy shuld be apprved by the Bard, and Tngaat shuld frmalise the existing Stakehlder Engagement Strategy fr applicatin acrss the cmpany. This shuld ensure that utcmes f engagements influence the determinatin f material issues t be managed and reprted n.
4 Page 4 f 5 In relatin t the Materiality principle: Tngaat has a mature risk management system in place, which cvers relevant sustainability tpics. Independent risk assurance is undertaken at peratinal and grup levels, and the system is seen t influence cmpany strategy. Cnsistent with the previus assurance recmmendatins, the cnnectin and influence f stakehlder perspectives and expectatins n the determinatin f material issues is nt made vertly clear, and the distinctin between risks and material sustainability issues requires clarificatin. In relatin t the Reprt, additinal detail n the materiality determinatin prcess shuld be prvided, and while nting that a GRI Standards-guided materiality determinatin prcess was undertaken during the year under review, the cmpany wuld benefit frm frmally dcumenting the prcess and utcmes in the Reprt. In relatin t the Respnsiveness principle: Tngaat has develped numerus plicies and prcedures apprpriate t stakehlder and rganisatinal interests and expectatins, and while the sustainability strategy develped in 2013 is nt frmally apprved, SHE, scial, and ethics related issues are included in the Annual Budget and Business Plan. There are mechanisms fr stakehlder feedback including investr presentatins, sci-ecnmic develpment activities with cmmunities at peratins, meetings with gvernment authrities, and the publicatin f an Integrated Annual Reprt and Sustainability Reprt. At Bard level, the Scial and Ethics, Risk and SHE functins are integrated int a single cmmittee. The Bard meetings, including the Audit and Cmpliance Cmmittee, als cver sustainability issues. ERM recmmends that Tngaat frmally apprves the sustainability strategy that has been cmpiled. It als recmmends that Tngaat frmalises and cnsistently applies the existing Stakehlder Engagement Strategy t ensure that feedback is prvided t stakehlders n hw the rganisatin respnds t their interests and expectatins. In relatin t the selected perfrmance indicatrs: Due t the manual nature f the data management system, strengthening site-level cntrls and develping site-specific prcedures fr cllecting and handling data is recmmended at sites where these cntrls are currently nt in place r require imprvement. Tngaat shuld prvide supplementary training t site staff n cllecting and reprting n the selected perfrmance infrmatin (particularly fr envirnmental perfrmance indicatrs), and such prcedures shuld be dcumented in a reprting guideline incrprating Tngaat s internal SHE definitins, that are aligned with the GRI Sustainability Reprting Standards fr all material tpics. The cntrls related t the selected perfrmance infrmatin wuld be imprved by the implementatin and rll-ut f a structured data management system applied cnsistently acrss the rganisatin. It is understd that this prcess is planned, hwever its rll-ut has been delayed fr tw years. In relatin t the disclsures n management apprach fr human rights: It is evident that the disclsures n Tngaat s management apprach t human rights are still maturing, and that cnsiderable prgress has been made in frmalising the human rights management apprach within the rganisatin. Prgressive activities include plicy reviews, update f the Cde f Ethics, and effrts t screen suppliers in the prcurement prcess. The disclsures wuld benefit frm clser alignment with selected standards in the Glbal Reprting Initiative s (GRI) Sustainability Reprting Standards, including the reprting requirements fr the management apprach and its cmpnents. This will require Tngaat t further frmalise and structure its human rights management apprach acrss the rganisatin, including frmalising rles and respnsibilities fr human rights management, and begin measuring and reprting n relevant tpic-specific disclsures.
5 Page 5 f 5 The limitatins f ur engagement The evidence gathering prcedures fr mderate assurance are mre restricted than fr high assurance and therefre less assurance is btained with mderate assurance than fr high assurance, as per AA1000AS (2008). It is imprtant t understand ur assurance cnclusins in this cntext. Our independent assurance statement prvides n assurance n the maintenance and integrity f the website, r ther sustainability disclsures, including cntrls used t achieve this integrity and, in particular, whether any changes may have ccurred t the infrmatin since it was first published. Dnald Gibsn Partner 05 July 2018 ERM Suthern Africa (Pty) Ltd, Jhannesburg, Suth Africa dnald.gibsn@erm.cm ERM Suthern Africa (Pty) Ltd is a member f the ERM Grup and an AccuntAbility Licensed Assurance Prviders. Our prcesses are designed and implemented t ensure that the wrk we undertake with clients is free frm bias and cnflict f interest. ERM des nt have any interest r sharehlding in any frm in Tngaat Hulett nr has any member f the ERM team that has been invlved in this engagement held any psitin in Tngaat Hulett. Further, the ERM staff that have undertaken wrk n this assurance exercise prvide n cnsultancy related services t Tngaat in any respect. All services prvided by the ERM team as part f this assurance exercise have been prvided in accrdance with a recgnised prcess fr nn-financial assurance engagements.
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