OUR GOVERNANCE AND MANAGEMENT APPROACH
Promoting ethics and good governance

We maintain a zero tolerance stance on fraud
and corruption

We are committed to promoting the highest standard of corporate governance, and to ensuring that our practices are materially aligned with the expectations of the King Code of Governance for South Africa 2009 (King III). The Implats board assumes overall responsibility for the effectiveness of internal controls, risk management and governance, and for ensuring that our business objectives are met.

We maintain a zero tolerance stance on fraud and corruption. We expect all our employees, business partners, contractors and associates to conduct themselves in accordance with the Implats Code of Ethics and our fraud policy. The code and policy are both fully compliant with local laws and regulations.

The fraud policy outlines conflict of interest, the prevention of dissemination of Company information, the acceptance of donations and gifts, and the protection of the intellectual property and patent rights of the Company. The policy outlines the disciplinary action (including dismissal or prosecution) that will be taken in the event of any contravention. A “whistle-blowing” toll-free helpline is in place to facilitate the confidential reporting of alleged incidents that are reported to the chief audit executive and the board chairman. The executives and line management are responsible and accountable for the implementation of the fraud policy, Code of Ethics and the procedures associated with these policies.

In the current year 90 cases were reported across the Group, 50% of which were from the South African operation, 44% were from the Zimplats operation and the remaining 6% were from the Mimosa operation. This reflects a 35% reduction from last year's figure. The founded cases also decreased from 47% of total cases last year to 38% of total cases this year.

All reported allegations are investigated in compliance with our fraud policy (see the table below). Of the 90 cases reported and investigated this year, four were classified as BEE fronting; 14 were conflict of interest and corruption; 45 were fraud and theft and 27 related to misconduct and other irregularities.

The status on the 90 cases referred to above is as follows:

• 24 are still pending;
• 32 were unfounded; and
• 34 were founded.

In keeping with our zero tolerance stance on fraud and corruption, 20 of the 34 founded cases resulted in a guilty outcome and appropriate disciplinary action was taken against the parties involved; while in four cases the employees were found not guilty, a further four cases did not warrant disciplinary action and the remaining six are still in process.

The table below provides the classification of the allegations and outcomes in each category:

Nature of cases reported Group-wide in the 2014 financial year