During June 2013 Implats submitted several section 11 transfer and section 102 extension of existing mining right applications, relating to existing prospecting rights adjacent to the Impala Rustenburg operation, the Afplats Leeuwkop operation and the Two Rivers operation. Furthermore, Marula also submitted a section 102 application to include the mining of the UG2 Reef into the existing Marula converted mining right in respect of a small part of Driekop, which is currently limited to the mining of the Merensky Reef only. The said section 11 and section 102 applications relating to the Two Rivers operation and to the Marula operation have respectively been executed on 6 February 2015 and 16 July 2014. However, the section 11 transfer and section 102 applications in relation to the Impala Rustenburg operation and the Afplats Leeuwkop operation are still pending.

Following discussions with DMR, Afplats is currently preparing a section 102 amendment application of its mine work programme, as well as a section 52 notice in terms of the MPRDA in respect of the deferment of the Afplats Leeuwkop mining project for four years.

In 2011, Impala reached agreement with the Royal Bafokeng Platinum (RBPlat) to access certain of its mining areas at Bafokeng Rasimone Platinum Mine (BRPM) from 6, 8 and 20 shafts. This is essentially a royalty agreement which will provide mining flexibility to these shafts. The mineral resources and reserves involved are not reflected in this report as the ownership has not been transferred.

Fully permitted mining tenements are not specified by SAMREC as a prerequisite for the conversion of mineral resources to mineral reserves. However, Implats is cognisant that a reasonable expectation must exist that such mining rights will be obtained. Implats remains committed to South African legislative requirements to convert applicable prospecting rights to mining rights.

There are still certain sections of the MPRDA Amendment Act, No 49 of 2008 (that was enacted into law on 7 June 2013) that has not come into effect due to critical concerns raised by the mining industry in respect thereof. One concern was the amendment of section 102 that did not allow for the extension of existing mining or prospecting right areas. However, as this amendment did not come into effect, the mentioned section 102 applications may continue to be processed. These sections are being revisited by the MPRDA Amendment Act, 2014 (formerly the MPRDA Amendment Bill (B15-2013). However, media reports confirmed early in 2015, that President Zuma has sent the proposed MPRDA Amendment Act, 2014 back to the National Assembly to be reworked as the President is concerned that some of the new provisions (ie “beneficiation”, “consent of land holders to access land”) “would not pass constitutional muster” in its current form. Mineral resources minister, Ngoako Ramatlhodi, is also advocating a separate legal framework for oil and gas companies (currently regulated in the MPRDA) to assist with new investment into oil and gas ventures.