“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

We are committed to promoting the highest standards 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 effectively achieved.

We maintain a zero tolerance stance on fraud and corruption. We expect all our employees at Impala operations, Marula and Zimplats operations to conduct themselves in accordance with the Implats code of ethics (the code) and our fraud policy. Both the code and policy are fully compliant with the laws and regulations of the countries within which we operate.

The Implats code of ethics addresses issues relating to conflict of interest, the prevention of dissemination of Company information, the acceptance of donations and gifts, and the protection of the Company’s intellectual property and patent rights. Furthermore, it describes the disciplinary action (including dismissal or prosecution) that will be taken in the event of any contravention. The code is complemented by a recently revised fraud, corruption and whistleblowing policy that applies to all employees as stated above. The policy underlines our commitment to creating an environment that encourages an anti-fraud and anti-corruption culture, informed by our organisational core values and our respect for open and honest communication.

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. Oversight of the code, policy and procedures has been delegated by the board to its SET committee.

An ethics line, which is a toll-free helpline, is in place to facilitate the confidential reporting (whistle-blowing) of alleged incidents. This year, 102 cases were reported across the Group, 48% of which were from the South African operation, 36% from the Zimplats operation, and the remaining 16% from the Mimosa operation. This reflects a 13% increase from last year’s figure. The founded cases, however, levelled at 34% of total cases compared to a slightly higher 38% of last year.

Of the 102 cases reported and investigated this year, only one was classified as BEE fronting; 16 were conflict of interest and corruption; 35 were fraud and theft and 50 related to misconduct and other irregularities.

The status on the 102 cases referred to above is as follows:

• 43 are still pending;
• 24 were unfounded; and
• 35 were founded.

In keeping with our zero tolerance stance on fraud and corruption, out of the 35 founded cases, disciplinary action was taken, with 21 cases receiving sanction ranging from counselling to written warnings to dismissals. Two are still in progress and 12 did not require further action. Only nine of the 35 founded cases were subsequently recommended for prosecution all of which were at the Zimbabwean operations.

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

Number of fraud/ethics-related cases reported Group-wide in the 2015 financial year

	Nature of allegation	Investigation pending	Allegations unfounded	Allegations founded	Total
	BEE fronting	1	0	0	1
	Conflict of interest and corruption	10	2	4	16
	Fraud and theft	9	7	19	35
	Misconduct and other	23	15	12	50
	Total	43	24	35	102