KING III & GRI +13

2012 Review of Sustainability Reporting in South Africa as per the Global Reporting Initiative (GRI) Guidelines

| About the Author

| Acknowledgements
An exercise of this nature could not be possible without the assistance of a number of key role players. In alphabetical order, we would like to thank the following people: Computershare, Sarie Oosthuizen and Amanda Nkosi The collection of Annual and Sustainability Reports would have been a near-impossible job without the exceptional assistance of Sarie, and her colleague Nomsa at Link. JSE Limited, Corli le Roux and Makhiba Mollo Our initial point of research departure began with receipt of a comprehensive database of JSE-listed companies, without which the scope of research may not have been as well-defined.

With 13 years of living in South Africa, it might seem inappropriate to state that Michael H. Rea is a Canadian, but as Joburg winters continue to prove, the thick and insulating blood of the Canadian never diminishes, regardless of how much ones eternal love of South Africa proves the adage that Africa gets into your blood. As the Managing Partner at Integrated Reporting & Assurance Services (IRAS, formerly SustainabilityServices.co.za), Michael has developed a 15-year track record in sustainability-related services, of which the past 13 include sustainability reporting and assurance in more than 25 countries. Having worked for both PwC (SA and Canada) and KPMG (SA), and having partnered with EY and Deloitte on projects, Michael has developed a boutique/niche assurance consultancy over the past six years that not only supports his own sustainability, but helps inform the space around reporting and assurance. With a unique perspective on Big 4 versus boutique approaches to sustainability advisory, authorship and assurance services, Michael respects the role the Big 4 accountancy firms play in sustainability-related services, yet offers a suite of custom services that provide competitively value-adding alternatives that are uniquely positioned to offer greater flexibility when meeting client expectations. With degrees in Biology, Psychology and an MBA in Corporate Social Responsibility, Michael is quick to point out that while he is passionate about sustainability reporting as a mechanism for improved risk management, transparency and accountability his work is merely a means to a more important end. His role at IRAS is one of business developer, principal consultant and assurer,

and educator: sharing his experience with the next generation of sustainability consultants and clients. Michael offers SAs only Certified Sustainability Assurance Practitioner (CSAP) course twice annually to budding practitioners, as well as to companies seeking to ensure that their reporting is assurance ready. Moreover, Michaels fee-generating activities are the means to support his real passions: supporting the Soweto Marimba Youth League (SMYLe) Trust, of which Michael is the Founding Trustee and Programme Director, as well as other local charities. IRAS is a small, specialised, boutique consultancy that thrives on its relationships with a network of Other Sustainability Reporting Practitioners (or other SRPs) to deliver value-adding advisory, sustainability data systems development, report authorship, and assurance services to clients in a wide array of industries. From pro bono clients in the NGO sector (Little Eden, Cotlands and the Orlando Childrens Home), to SMMEs in the garment manufacturing industry (Impahla Clothing, a Cape Town based PUMA supplier, and Vimal Clothing, a Durban based supplier to the likes of Adidas and Nike), to large listed corporations (African Bank, Altron, ARM, Illovo Sugar, Merafe Resources, Metair Holdings, PSV Holdings, Sun International, Tongaat Hulett, Wilderness Safaris and Xstrata South Africa), IRAS is not only the #1 assurance provider in South Africa, but is well poised to provide excellent services to a range of highly respected clients. For more information about our services, please go to www.iras.co.za.

Link Market Services, Nomsa Phosa As mentioned above, gathering the reports was primarily facilitated by Nomsa, Sarie and Amanda, and our sincerest Thanks continue to go out to them for their unwavering support. Studio 5 is not only a fellow-skills partner in the development of the SMYLe and Little Eden GRI-based NGO Annual Reports, but also the brand intelligence behind both SMYLe and IRAS, and thus it was a pleasure to share the development of this report with their highly skilled and motivated team. Their ingenious ability to convert words into stories, coupled with phenomenal attention to detail, has helped develop what is likely to be regarded as the best yet report in our annual series of research documents. The IRAS Team: Julia Wakeling, Lauren Stirling, Matt Cameron, Tahereh Kharestani and Thembi Ndlovu Our research team comprised of one South African Lauren who joined IRAS in January 2011 after returning from teaching high school Sciences in the UK for 10 years, two Zimbabweans Julia and Thembi who joined IRAS earlier this year, an Iranian Tahereh who is currently completing her Masters in Sustainability and Responsibility at Ashridge Business School in the UK and another Canadian Matt who is just entering the work world after completing an undergraduate degree in finance. To assume that this project isnt an insane endeavour would be tantamount to ignoring the number of times the team wanted to lynch their leader (mostly because of unclear instructions). Nonetheless, the research team successfully waded through more than 400 annual and/or sustainability reports to complete the 4th annual review of GRI-based reporting in South Africa, and their excellent attention to detail has been sincerely appreciated. We would also like to thank the first 24 Other SRPs (sustainability reporting practitioners) listed in Appendix IV: our colleagues, peers and competitors who have helped pay for this research report (and the launch event) by purchasing ad space. Thembi Ndlovu

| Our Reporting Theme

Be the CHANGE you want to see.
Mahatma Ghandi
With the exception of scanned images from publicly available annual and/or sustainability reports, or other research documents, all of the photos used in this report are from the private collection of Michael H. Rea, and have been used to help contextualise the reporting paradigm in South Africa. The majority of the photos are from the Orlando Childrens Home (Soweto), which was selected as this years beneficiary of our Making Reporting Matter initiative.
Over the past three years, IRAS has used the launch of our research reports as a mechanism for inviting our reporting colleagues, peers, competitors and clients to participate in a mechanism for giving back to those less fortunate. In 2010, we collected clothing for HIV-affected families in the Hlabisa area of northern KZN, while in 2011 we collected blankets for people living in the Zandspruit Informal Settlement, situated just north of Johannesburg. In preparation for this years report launch, the IRAS team travelled to the Orlando Childrens Home to identify a need that we believed our network of stakeholders could help us meet. Without much debate, we identified a desperate need to fix toilets in the home as an urgent priority. Thus, we decided to host a unique volunteerism project we like to call Extreme Makeover: Bathrooms Edition, or Pimp My Crapper! Thus, the photos contained within this report are used to remind you, the reader, of the way in which this research project makes a difference. Within IRAS, we believe that to whom much is given, much is expected, and we trust that our network of reporting friends equally share in this belief. As South African businesses, its important for all of us to understand the socioeconomic, political and environmental conundrum our fellow citizens frequently find themselves in. With the highest income disparity in the world measured by the Gini coefficient as well as intolerable levels of unemployment and/or under-employment, South Africas frightening level of disparity is frequently blamed for much of the crime, murder and corruption that could potentially undo the near-flawless transformation to democracy that the world has respected South Africa for. While those of us deemed the haves enjoy the privileges of relative wealth and opportunity, insulated by the confines of suburbia, the masses around us struggle to exist in a world that leads many to believe that the apartheid of old is not dead, but rather reincarnated. Its no longer a racial divide that polarises society, but a socioeconomic chasm that appears to have evolved out of equal parts greed, selfishness, fear and uncertainty. For those blessed with access to a meaningful education, as well as the social structures required to develop ambition, determination and self-belief, escaping poverty is almost a forgone conclusion, while millions of others are virtually trapped in an endless cycle of inopportunity. At the same time, those with the means to afford suburbia unwittingly exacerbate the poverty of the masses through behaviour-based ecological destruction.
1

| Content
IFC IFC 01 03 09 | About the Author | Acknowledgements | Our Reporting Theme | Research Scope, Objectives and Approach | King III and the GRI Guidelines: The Why and How of Reporting 13 | GRI Reporters in South Africa: Our Research Findings 25 31 | Independent Third Party Assurance | 10 Tips to Achieve Excellence in Integrated Sustainability Reporting 37 43 49 | Our Personal Favourites | Why Report According to GRI? | The JSEs Role in Encouraging Effective Reporting 53 | Benefits of GRI-based Reporting in the NGO Sector: A Call to Action! 57 61 | Getting the Data Right | The Push Towards More Effective Carbon Disclosure 67 IBC | Appendices | Moving Forward

| Our Reporting Theme continued

As a hobby pilot, the full might of apartheid became much clearer the first time I flew from Grand Central Airport, just north of Johannesburg (in Midrand), south over Alexandra, then Sandton and the northern suburbs, over the Johannesburg CBD, and then southwest to Soweto (the south west township). At about 5 000 feet, one can clearly see how little the divide is between the wealth of Sandton and the poverty of Alex, and can easily identify just how comprehensively the worlds largest man-made urban forest shields the rich few from the devastatingly poor many. Moreover, the extent to which the governments of the past punished non-whites, for no fault of their own, becomes abundantly obvious when winds can be observed sweeping arsenic and cyanide-laden dust from the tops of mine dumps, straight into the near tree-less communities that make up Soweto. Chronic Obstructive Airways Diseases, COADs such as silicosis and pneumoconiosis are to Soweto what oxygen-emitting tree-lined streets are to those living in the north. Acid mine drainage from the long-closed gold mines pollute water ways, and man-made non-biodegradable waste pollutes what open spaces might exist, while a lack of public services more readily available in wealthier parts of the city exponentially exacerbate the plight of the masses. Foreign shop owners are attacked in fits of xenophobic rage, by communities that errantly assume that the success of one must occur at the expense of others. Petty criminals are lynched and, in many cases, publicly executed by otherwise law-abiding citizens who have exceeded their ability to tolerate lawlessness, yet in doing so becoming more the problem than the solution. The homes of councillors in parts of Soweto are attacked, and in some cases completely destroyed, by angry mobs seemingly protected from prosecution merely because of governments inability to cap discontent, coupled with what appears to be a lack of political will to either fix the underlying problems, or punish those who turn protests into criminal acts. What trees do still exist are harvested unsustainably to provide a fuel source even in peri-urban areas. Water sources are polluted by poorly maintained bulk sewage infrastructure, while over-crowding, poor sanitation and a lack of waste management systems ensure that previously eradicated diseases such as cholera become annual crises. Sadly, the average life expectancy of a black male is roughly 48 years, while that of a white male is nearer to 72, and one need only spend time in what could be deemed a black community to understand why black males are so chronologically disadvantaged. Smoking, alcohol and a wide array of cheap drugs are effective coping mechanisms that make life more bearable, while ultimately stripping the consumer of both quantity and quality of life. By working with people such as Johnny Hlaba, an immensely talented musician who supports a family of five in Soweto on less than R3 000 per month, and Albertina Khumalo, a hard working grandmother of AIDS-orphaned grandchildren, who supports a family of 23 also on less than R3 000 per month. In the Hlabisa area of northern KZN, the need for meaningful corporate social responsibility, and effective sustainability reporting has become obvious to me. By no means have I become a communist, but its safe to assert that Ive become somewhat of a free-market socialist. While the business of business will always be business as Friedman effectively postulated the world around us seems to be becoming abundantly aware of the need to earn equitably, spend responsibly, and consume sustainably. We are being alerted to the way in which social media is strengthening community activism, even in poorer communities that are often underestimated with respect to their level of sophistication. Legal licences to operate are beginning to take a back seat to the social
2

licences society rather than government informally issue to companies, and executives are beginning to accept that the income and/or value-added statements taught in school are no longer relevant in the context of a world seeking socioeconomic fairness. As this research report demonstrates, South Africa has become somewhat of a laboratory in which the global corporate world has set about to test the value inherent in effective reporting. With fewer than 400 companies listed on the Johannesburg Stock Exchange and 128 GRI-based reporting entities (including 121 listed companies, 3 NGOs, one SMME, two parastatals and one municipal water board), the uptake of the GRI Guidelines is higher here than in any other country. Driven partly by the size of the high social and environmental impact resource extractive industries (e.g., metals and mining), the path of South Africas post-apartheid transformation agenda has exacerbated the need to collect, collate and report meaningful answers to critical questions such as How responsibly do you generate the wealth you distribute to the shareholders who remain the minority (i.e., the wealthy few regardless of race)? South African companies reports have significantly improved: at least in our observation over the four-year history of this annual research process. They have incorporated a number of compliancerelated reporting expectations such as industry charters (e.g., the Mining Charter), the Workplace Skills Development Act, the Employment Equity Act, the JSEs Socially Responsible Investment (SRI) Index, the dti Codes of Good Practice and a variety of other company and/or industry-specific reporting requirements. They have not only become a message to shareholders and potential investors, but much more importantly an internal management tool tantamount to the tail that wags the dog. They have become tools used to help market goods and services to government, and communication tools used to attract scarce skills from within highly mobile professional career categories (e.g., engineers and CAs). Thus, it is my hope that this document will serve as a tool for the 65% of other South African companies (235) still needing to identify how applying the GRI Guidelines can help manage social, environmental and governance risks.

In the land of the blind, the one-eyed man is king!

While our research does not attempt to identify whether one or more companies has reached some form of ethical utopia, it is the collective hope among the IRAS team including our highly committed interns that the examples of reporting leadership identified in this document will help those yet to embark on a similar journey towards transparency and accountability. As a reader, we implore you to avoid trying to find the perfect example and rather focus on learning from those who have at least one eye on the ball!

| Research Scope, Objectives and Approach

Research Scope, Objectives and Approach

Over the past four years, our incredibly small business has invested heavily in researching the effectiveness of corporate sustainability reporting in South Africa. We have done so primarily to identify scope for our services, but by no means did we end there. Granted, it would have been far easier for us to access global databases of sustainability reports to figure out who might be interested in our services, but this presupposes that global databases are complete and/or accurate. To the best of our knowledge, there are two places interested parties can go to figure out which companies produce sustainability (or integrated annual, inclusive of sustainability) reports. These are: Unfortunately, neither of these databases serves the interests of IRAS or our peers within the South African reporting and assurance market without our efforts to first assist them. Hence, our research. Within a small company such as IRAS, we believe that we have the potential to service 20 clients with our current team complement at a level to which we are not compromising our value proposition. However, we also believe that because we research opportunities for improvement within companies to define potential work for us we may as well share our findings with every single company we review, as a means of helping everyone understand where we as a collective, and as individual reporters stand relative to reasonable expectations for sustainability reporting. In short, King III the King Code of Corporate Governance (version 3, or King III) has established a heads up for companies attempting to identify the future of their business in the context of an ever-changing social, economic and environmental landscape. Among many other governance recommendations, King III encourages companies to produce meaningful integrated annual reports using the guidance set out by the GRI (i.e., the GRI G3 Guidelines). In doing so, King III has effectively set new benchmarks for a level of transparency that has long eluded conscious consumers and investors. Although the goal is courageous, there remains an inadequate amount of information available to stakeholders wishing to understand how to benchmark corporate performance on non-financial matters and/or companies that wish to understand where they continue to fall short of the mark. This is why the team at IRAS has yet again embarked on our annual quest to establish a useful database of GRI-based sustainability reports. As mentioned above, the inherent flaw in the GRIs database is the fact that the GRI does not actually search for reports, but rather waits for companies to send their reports to the GRIs database team. While it might be reasonable to assume that anyone using the GRI Guidelines would want to let the GRI know, and thus be included in the GRIs database, this is not the case. At last check (31 May 2011), the GRIs database only recorded 88 GRI-based reports in South Africa for the 2011 period, which is 40 fewer than our research has found. Hence, our decision to volunteer to become the GRIs data partner for South Africa. To identify our list of 128 GRI-based South African reports, IRAS assembled a team with extensive research and analysis skills, but little to no experience in sustainability reporting matters.
4

The rationale behind using non-sustainability experts is predicated on the assumption that an experienced sustainability advisor, author or assurance provider would most probably bring a hyper-critical set of expectations to the process. By using inexperienced reviewers, the test of GRI-compliance could assess whether companies make their reports simple enough for a wide array of stakeholders to use effectively. For this years review, our research team consisted of one existing team member (Lauren), one new recruit to the IRAS team (Julia), and two fixed-term international interns: Matt (Canada), and Tahereh (Iran). The team was supported by Thembi, our Research & Admin Assistant, who was given the unenviable task of collecting all of the reports we reviewed. Over the course of a five-month period, the team reviewed the most recently published hard copy and/or electronic annual and/or sustainability reports for the more than 420 companies recorded on a list of companies supplied by the Johannesburg Stock Exchange (JSE), as well as reports from non-listed entities which have been known to produce a sustainability report (i.e., known reporters).
NOTE

Global Reporting Initiative (GRI)

The GRI maintains a global database of reports that at least mention the GRIs guidelines. (www.globalreporting.org) Unfortunately, the GRIs database has been historically flawed, in that it only contained reports that had been sent by reporting entities to the GRI for uploading into their known reports database. Typically, this has meant that their database fell short by roughly 50%, given that our annual research has identified twice as many GRI-compliant reports than were found in their database. To help rectify this problem, IRAS has volunteered to become the GRIs local GRI Data Partner, sending all of our research findings on behalf of every SA reporting entity to the GRI for uploading onto their database.

CorporateRegister.com

CorporateRegister.com (CR) maintains a well-populated global database of all annual, integrated annual and sustainability reports (in all forms). (www.corporateregister.com) Unfortunately, CR is apparently at loggerheads with the GRI over their respective databases, and has taken the brutally self-minded decision to deny anyone who helps the GRI access to the CR website (its actually written into the terms of agreement for anyone using their database). Because IRAS shares all of its research findings with everyone including the GRI we can no longer access their database. Thus, you as a reader of this research report can make use of CRs very useful online database. We at IRAS cant! So much for playing nicely in the same sandbox!

To be considered a South African Report, the company must not only be listed on the JSE, but must have as its primary residence, an office in South Africa. In many cases, where it wasnt obvious, our Proudly SA test was conducted by searching for where the auditors reside. Although a company might appear to be South African, or assert that its South African, it might have been deemed un-South African on the basis of not being administratively based in South Africa. In order for a report to be deemed GRI-Compliant, the report had to meet the following requirements: Clearly state that the report was compiled in accordance with the GRI Guidelines (or something to that effect). Either declare a GRI Application Level (C/C+, B/B+ or A/A+, where the + indicates that the report had been assured by a third party), or clearly indicate that an Application Level has not been declared. Exceptions are made if/when a company has not declared a level, but has included a GRI Content Index, thus being GRI Compliant by default.

Some reports were immediately disqualified due to a comprehensive lack of information, leaving a total population sample of 363 reports, of which the vast majority were produced for the 2011 financial year, while some were for the 2012 financial period. To establish a GRI-compliance score, each report was compared against all 127 GRI G3 Guideline indicators (see Appendix IV for a full list of the indicators). Testing was conducted to determine whether or not the reports provided responses to each of the G3 reporting requirements: 42 Strategy & Profile indicators those that essentially provide an overview of the entity, its sustainability paradigm, and the systems and processes for stakeholder engagement and reporting; six Disclosures on Management Approach for Economic, Environmental, Labour, Human Rights, Social and Product Responsibility those that define how the entity manages its performance in each of these areas; 49 Core Performance Indicators, of which seven are Economic, 17 Environmental, nine Labour, seven Human Rights, six Society and four Product Responsibility those that define how the entity manages its performance for common areas; and 30 Additional Performance Indicators, of which two are Economic, 13 Environmental, five Labour, two Human Rights, two Society and five Product Responsibility for more technical and/or less common performance areas. Our team conducted page-by-page reviews of the 363 company reports inclusive of any/all documents or web pages that were clearly referenced in the primary document providing a basic assessment of whether or not responses to the indicators could be found. Each report review required an average of more than 3 hours of researcher effort, plus an additional hour of quality assurance (QA) and/or analysis. It is important to note that the scope of our research did not extend to giving a subjective assessment of whether or not the information provided was accurate, complete or reliable. Rather, our assessment was limited to determining whether or not our team could identify a reasonable or partial response to each indicator. As such, our scoring was based on a 3-grade scale, as follows: A reasonable response a rating score of 2 of 2 for a response that provides enough information to establish a reasonable understanding of the reporting entitys management of the indicator.

NOTE

Just because a company said they offered a response partial or complete doesnt mean our team agreed with the companys assertion. In many cases, responses were implicit (at best) and not explicit, or it was assumed that the reader of the report had memorised the content of the companys prior reports. In many other cases, responses were buried in a web of online information, without clear guidance regarding where the response could be uncovered (thus, not really available). To address this issue, our research includes Non-Compliant as a separate application level in our analysis. A company was deemed Non-Compliant regardless of whether or not the report had been GRI-Checked (by the GRI), or assured by a third party, and only assessed as such if they did not meet the GRIs Application Level requirements. Each GRI-based reporting company was given an opportunity to review our assessment, and argue our findings. Thus, our findings in this report should be deemed fair (or as fair as possible).

A partial response a rating score of 1 of 2 for a response that offers some information regarding the indicators expectations, but not enough to fully understand the entitys management of the indicator. A non-response a rating of 0 of 2 for any indicator where no response could be identified. Upon completion, each Gap Analysis was subjected to a high level peer Quality Assurance (QA) review to ensure that the assessment was comprehensively completed, and then a test for anomalies and/or obvious errors to be corrected. For the first time, our team went one very important step further, and issued each company-specific analysis to the reporting entity if they had produced a GRI-based Report. We firmly believe that the quality of our scoring system, and thus the resultant compliance score, is directly linked to the quality ofthe reports reviewed. In many cases, reports were extremely difficult to navigate, particularly lengthy reports that included incorrect GRI indicator tables, thus making it difficult to find indicator specific data. Ultimately, a report should be produced in a manner that would allow someone new to the company and/or to sustainability reporting to find meaningful data in a timely and efficient manner. Although we respect that we may yet be corrected on one or more company-specific reviews, we believe that the scores
5

BBBEE CDP KING III

On top of your game?

| Research Scope, Objectives and Approach continued

TIPS

The GRI Content Index table is not a nice to have, but rather a required element of GRI compliance, regardless of the application level being sought (C, B or A). The GRI is explicit about this on their website: Reports based on the GRI Guidelines without a GRI Content Index are included as GRI-referenced, but are not considered to be GRI reports. Companies that absurdly choose to produce an index table that guides the reader to a section of the report and not a specific page(s) should stop wasting everyones time and, more importantly, their money! Producing an indicator table that tells the reader to go to the Environmental Section to find a response to environmental indicators is useless. This is particularly pertinent to companies who foolishly avoid producing printed copies, or at least downloadable .pdf versions, of their report. With rare exceptions (e.g., Sasol,), few web-based sustainability reports are easily navigated. When populating the GRI index table with page numbers, ensure that the page numbers refer to the final editors proof of the report, not to the Word document that was sent to the design team. The two reports are almost always completely inconsistent in page numbering. To get this right, it is advisable that companies avoid including the GRI Content Index in the actual printed report, but rather make the table available online, or via a request via email mechanism. This allows for the report to be done and dusted before the table is completed, thereby maximising the potential for page number accuracy (and reducing heaps of last minute stress at the printers).

This document also includes an assessment of how well each of the GRIs indicators are responded to, offering a table (Appendix IV) that breaks down responses for GRI and non-GRI reports. This table is based on requests from researchers, and is designed to help establish areas of specific concern that may require additional support for companies (e.g., reporting expectations for Human Rights).

Our Apologies
To those companies who were unfairly evaluated and/or reported upon in last years research report particularly Barloworld we hereby sincerely apologise for getting the information wrong. We do our best to be as accurate as possible, but accept that we too are human thus fallible and thus likely to make mistakes. To those companies who believe they have been unfairly excluded this year, or unfairly assessed, please email us at info@iras.co.za and well do our best to sort out the problem, and where necessary make it up to you. To those companies who believe that we shouldnt be allowed to include our assessment of your report, our apology is simple, Either accept it, or get over it! Your report is public, and we dont need your permission to review it, or to try to help you improve your reporting (particularly when we do it for mahala)!

presented in Appendix III are as accurate as could be established within the limits of the time invested in this research (more than 2 000 hours over a five-month period). All companies included in our research are invited to request a copy of our gap analysis assessment for their report free of charge! Unlike the reporting databases supplied by CorporateRegister.com and/or the GRI, our research not only leads to THE most comprehensive list of GRI-based reports in South Africa, but it also leads to an understanding of how many companies are producing reports that are nearly there. By evaluating all company reports, regardless of whether they cite the GRI Guidelines or declare an application level, our research provides a tool that all companies can use to help inform their future reporting processes.

MATTERS
For listed companies, sustainability reporting is no longer a nice-to-have. With a strategic approach to the broad spectrum of reporting requirements, Russell & Associates brings fresh ideas to the incorporation of sustainability matters into your quarterly, half-year and annual reporting to stakeholders, building essential environmental, social and governance information into an integrated reporting format, in both print and an on-line environment.

SUSTAINABILITY

As a long-standing Organisational Stakeholder of the GRI we can help you to:

Identify the most significant material issues to report; Develop your sustainability reporting strategy; Implement appropriate reporting and communication systems; and Develop your reports, from concept to finished product.

Tel: +27 11 880 3924 / Fax: +27 11 880 3788 / E-mail: charmane@rair.co.za
For more information please visit our online portfolio at www.russellandassociates.co.za

2012

Contact us:

rest assured...

King III and the GRI Guidelines: The WHY and HOW of Reporting
Unlike most countries, sustainability reporting in South Africa is less of a nice to have than a need to have, particularly for listed companies. Whereas consumer, shareholder and/or other stakeholder requests for additional information drive reporting trends in the more developed economies of Europe and North America, the key motivation for integrated sustainability reporting in our context is centred around the listing requirements of the Johannesburg Stock Exchange (JSE).
In many respects, the JSEs requirements appear to be a measured attempt at responding to a combination of societal trends and the concerns of an unsettled international investor community. However, the corporate sector has repeatedly been able to prove that South Africa is not only a regional economic powerhouse, but also an internationally recognised innovation hub. Leading companies such as Bidvest, SAB, Sasol, Sappi, and many others, are able to demonstrate how success can be both borne and nurtured in a highly advanced business environment in South Africa, and then taken further afield into the rest of the world. As such, sustainability reporting, as part of a broader world-class corporate governance code (i.e., King III), is a mechanism that is often cited as a response to the growing international concern over the security of investments in South Africa, and a means of demonstrating how our companies are able to compete in international markets, with equal if not better governance standards. At the same time, sustainability reporting has become a useful mechanism for communicating with local stakeholders who challenge businesses on matters pertaining to the fair distribution of wealth, black economic empowerment, climate change, a scarcity of potable water and other environmental issues. By reporting to stakeholders on an annual basis, companies are able to reduce conflict as much as reasonably expected while demonstrating that policies, procedures and management systems are in place to help manage an array of company, industry and/or societal challenges. Launched by the Institute of Directors (SA) in 2009, the King Report on Corporate Governance in SA, 2009 (King III, or the Code) became effective as of 2010, thereby requiring companies to apply or explain 75 different recommendations (or principles) outlined within the Code. As a list of recommendations, the Code does not explicitly demand compliance, but rather recommends that companies apply each of the 75 principles, or explain the reasons for not doing so. Broken down into nine separate chapters, the Code requires companies to address the following elements (Source: King III, www.iodsa.co.za): 1. Ethical leadership and corporate citizenship 2. Boards and directors 3. Audit committees 4. The governance of risk 5. The governance of information technology 6. Compliance with laws, rules, codes and standards 7. Internal audit 8. Governing stakeholder relationships 9. Integrated reporting and disclosure Although integrated reporting falls at the end of the list, one shouldnt confuse its positioning with some form of relegation to insignificance. Rather, the concept of integrated reporting is, to reapply the term, integrated throughout the Code, and is woven throughout all recent guidance on governance as a means of heightening the role of reporting as a means of informing business strategy. In fact, of the 75 governance principles cited within the Code (noting that good governance is in essence all about ensuring sustainability), 20 of the principles deal directly with sustainability and/or integrated reporting matters, including (Source: King III, www.iodsa.co.za):

rest assured...

aassurance . advisory . strategy

www.earthinc.co.za

| King III and the GRI Guidelines continued

1.1 The board should provide effective leadership based on an ethical foundation Ethical leaders should: 1.1.1 direct the strategy and operations to build a sustainable business; 1.1.2 consider the short- and long-term impacts of the strategy on the economy, society and the environment; 1.1.3 do business ethically; 1.1.4 do not compromise the natural environment; and 1.1.5 take account of the companys impact on internal and external stakeholders. The board should: 1.1.9 promote the stakeholder-inclusive approach of governance. 1.2 2.2 The board should ensure that the company is and is seen to be a responsible corporate citizen The board should appreciate that strategy, risk, performance and sustainability are inseparable 6.4 The board should delegate to management the implementation of an effective compliance framework and processes 6.4.5 The integrated report should include details of material or often repeated instances of noncompliance by either the company or its directors in their capacity as such 7.3 Internal audit should provide a written assessment of the effectiveness of the companys system of internal controls and risk management 7.3.1 Internal audit should form an integral part of the combined assurance model as internal assurance provider 7.3.2 Internal controls should be established not only over financial matters, but also operational, compliance and sustainability issues 8.1 8.2 8.3 The board should appreciate that stakeholders perceptions affect a companys reputation The board should delegate to management to proactively deal with stakeholder relationships The board should strive to achieve the appropriate balance between its various stakeholder groupings, in the best interests of the company Companies should ensure the equitable treatment of shareholders Transparent and effective communication with stakeholders is essential for building and maintaining their trust and confidence The board should ensure that disputes are resolved as effectively, efficiently and expeditiously as possible The board should ensure the integrity of the companys integrated report Sustainability reporting and disclosure should be integrated with the companys financial reporting Sustainability reporting and disclosure should be independently assured Although not explicitly mentioned within the principles found within the Final version of King III, as they had been in Chapter 6 of the February 2009 Draft Code, the Global Reporting Initiative (GRI) Guidelines remain a key recommended source of guidance for sustainability reporting. The Guidelines are cited not only as an emerging transparency trend throughout the world, but also as a mechanism for identifying subject matter that might be of material benefit for companies to manage and report upon to stakeholders. All organisations (private, public, or non-profit) are encouraged to report against the Guidelines, whether they are beginners or more experienced reporters and regardless of their size, sector or location. The Guidelines are the most widely used in the sustainability reports of global companies, and are widely regarded as the d facto standard for sustainability reporting. In South Africa, the Guidelines are frequently viewed as a useful roadmap for companies embarking upon a journey towards effective reporting. Established to make the Guidelines relevant to all users, the reporting requirements are structured in a way that organisations can ease into reporting by attempting to comply with the GRIs least tedious Application Level (i.e., Level C), ultimately building up to more meaningful Level B or A reports. Interestingly, King III has evolved from Kings I and II in a manner consistent with the GRI Guidelines, attempting to ensure that the Code is applicable to all entities regardless of the manner and form of their incorporation or establishment, and regardless of whether they exist in the public, private or non-profit sectors. Whereas King (I, II and III) was developed primarily through the efforts of the South African Institute of Directors (IoDSA), the GRI is an Amsterdam-based non-governmental organisation (NGO) that works within an international multi-stakeholder process in order to develop what has become a seminal framework for transparency and accountability through sustainability reporting. First released in 1999 and now in their third edition, the Guidelines have been adopted by a diverse range of organisations as the basis for their sustainability reporting. According to the database of reports provided by the GRI, there were 2 202 reports published by companies in 73 different countries in 2011, compared to only 10 reports published in 1999, demonstrating how the Guidelines are meeting the sustainability communication needs of a broader set of reporting entities. Although initially developed and released for use in 1999, the Guidelines continue to undergo further development through a process of consensus-seeking dialogue with an international network of stakeholder groups including business, civil society, academia, unions and other professional institutions. According to the GRI, the process is open, inclusive and takes a global

2.11 The board should appreciate that stakeholders perceptions affect the companys reputation 2.12 The board should ensure the integrity of the companys integrated report 3.4 The audit committee should oversee integrated reporting 8.4 8.5

3.10 The audit committee should report to the board and shareholders on how it has discharged its duties 3.10.4 The audit committee should recommend the integrated report for approval by the board 4.5 The board should ensure that risk assessments are performed on a continual basis

8.6 9.1 9.2 9.3

4.10 The board should ensure that there are processes in place enabling complete, timely, relevant, accurate and accessible risk disclosure to stakeholders

10

PE INTERNATIONAL
E X P E RT S I N S U S TA I N A B I L I T Y

CDP & GRI certified Software Solutions CDP & GRI certified Software Solutions PE INTERNATIONAL provides long-term support for
South African clients provides long-term support PE INTERNATIONAL with CDP & GRI accredited software solutions and consultancy services in for South African clients with CDP & GRI the complete field of sustainability: consultancy accredited software solutions and
(Source: www.globalreporting.org) perspective on the growing understanding of good reporting on key sustainability issues. Having been enhanced as knowledge and awareness of key sustainability matters have evolved, and as the needs of reporters and users have changed, the Guidelines have recently been updated to version 3.1 and are currently in the process of undergoing a complete renovation process that will ultimately lead to the fourth generation of Guidelines, or G4. The G4 version is currently doing the rounds in draft format, and is expected to be launched at the GRIs next global sustainability reporting conference in Amsterdam in May 2013. The GRI G3 Guidelines are presented according to the following categories of indicators, whereby anyone wishing to produce a report that meets the Application Level A requirements, all of the profile and boundary indicators (sections 1 to 4, listed below) are required, as well as all of the core performance indicators: Section 1: Section 2: Section 3: Strategy and Analysis (two indicators) Organisational Profile (10 indicators) Report Profile (four indicators) Report Scope and Boundary (seven indicators) GRI Content Index (one indicator) Assurance over the report (one indicator) Governance (10 indicators) Commitment to External Initiatives (three indicators) Stakeholder Engagement (four indicators) Section 5: Disclosures on Management Approach (one each for Economic, Environmental, Labour, Human Rights, Society and Product Responsibility) Economic Performance, including Market Presence and Indirect Economic Aspects (nine indicators, of which seven are core) Environmental Performance, including Materials, Energy, Water, Biodiversity, Emissions, Effluent & Waste, Compliance and Transport (30 indicators, of which 17 are core) Labour Performance, including Employment, Labour/ Management Relations, Occupational Health & Safety, Training & Education and Diversity & Equal Opportunity (14 indicators, of which nine are core) Human Rights Performance, including Strategy & Management, Non-discrimination, Freedom of Association, Child Labour and Forced Labour (nine indicators, of which six are core)

Section 6:

Section 7:

services inProduct & Corporate Carbon the complete field of sustainability: Footprinting Product &Cycle Assessment (LCA) Life Corporate Carbon Footprinting Efficiency Assessment Energy Life Cycle Assessment (LCA) & Management Energy Efficiency Assessment & Sustainability Reporting Management Greenhouse Gas Reduction Roadmaps Sustainability Reporting

Section 8:

Section 9:

With 20 years experience PE INTERNATIONAL Greenhouse Gas Reduction Roadmaps has a satisfied client community in over 70 With 20 years more than 1 INTERNATIONAL countries. And experience PE 000 multinationals, has a satisfied listed companies, use our including 9 JSE client community in over 70 countries. And more than 1.000 services and software solutions. multinationals, including 9 JSE listed companies, use our services and software solutions.
PE INTERNATIONAL (South Africa). Call us 082 373 4055 m.reichardt@pe-international.com

Section 10: Society Performance, including Community, Corruption, Public Policy and Compliance (eight indicators, of which six are core) Section 11: Product Responsibility, including Customer Health & Safety, Products & Services, Marketing & Communication and Customer Privacy (nine indicators, of which four are core)

Section 4:

PE INTERNATIONAL (South Africa) Call us 082 373 4055 m.reichardt@pe-international.com www.pe-international.com

11

| King III and the GRI Guidelines continued

NOTE

A full set of GRI G3 Indicators, including basic definitions, can be downloaded from the GRIs website (www.globalreporting.org), or from our website (www.iras.co.za), or can be viewed in the format we have included in Appendix IV of this report. As the most comprehensive and wide-ranging of sustainability reporting recommendations, it is generally accepted that the Guidelines can be used as the basis for producing integrated annual and/or sustainability reports that can be deemed comparable within industries and/or countries, or between them. However, the Guidelines, even in their G3 format, remain somewhat limited in their ability to establish a one size fits all reporting methodology. As such, the GRI has established a number of Sector Supplements that help adapt the Guidelines to the unique characteristics of specific industries, or sectors (e.g., Metals & Mining, NGOs, Airport Operators, Electric Utilities, etc.). These supplements complement rather than replace the standard Guidelines by allowing reporters an opportunity to respond to an industry-specific set of sustainability issues, including the following sectors: Airport Operations Apparel and Footwear (in pilot version) Automotive (in pilot version) Construction and Real Estate Electric Utilities Event Organisers Financial Services Food Processing Logistics and Transportation (in pilot version) Media Mining and Metals NGO Oil and Gas (in pilot version) Public Agency (in pilot version) Telecommunications (in pilot version) Although some might argue that the GRI G3 Guidelines are too far-reaching and/or complicated to follow, the collective experience of a wide array of companies, institutions and non-governmental organisations in more than 70 countries suggests otherwise. Based solely on the experience of South African reporting entities, including Impahla Clothing, an SMME supplier to PUMA as well as Cotlands, Little Eden and SMYLe (all NGOs), and the 124 other identified G3 reporters, the G3 Guidelines are both meaningful

and manageable. It should be noted that some indicators require little more than a basic statement of disclosure to meet the reporting requirements, including such basic requirements as stating the reporting entitys name, or including a G3 Indicator Table (a list of references to the indicators, including whether or not a disclosure has been included in the report). More information on compliance to the GRIs G3 Guidelines can be sourced from the GRIs website. However, one must also note that the question still remains, Is there such a thing as a good sustainability report that is not necessarily a good GRI report? Once again, the answer is an emphatic Yes! Several of the non-GRI sustainability reports that were reviewed by our team were ultimately regarded as excellent reports (see table below). Not only did they score well in terms of the GRI G3 content assessment we measured each report by despite not explicitly mentioning use of the GRI Guidelines but they also managed to provide meaningful discussions about the overall sustainability performance of the reporting entity. However, the question isnt Should we report according to the GRI or not, but rather, Why wouldnt you report according to the GRI? The GRI Guidelines are either required or recommended by: King III, for all JSE-listed companies. Moreover, the GRI G3 Guidelines provide an internationally recognised comprehensive framework for reporting that allows for immediate comparability and benchmarking. Thus, if one is to set out on a path to

enlightened sustainability reporting, the question of whether or not to adhere to the GRI G3 Guidelines is rhetorical. Why wouldnt you? The Public Investment Corporation (PIC, the governments principle investment arm, assuming one ignores the stories about Chancellor House), for all entities in which the PIC has an interest. The International Council on Mining and Metals (ICMM), the industry body to which many South African mining companies belong. The JSEs Socially Responsible Investment (SRI) Index, which annually reviews the sustainability performance of South Africas largest companies (by market cap). A growing number of responsible investment mechanisms among the more proactive asset managers and/or pension funds (more to come on this in the coming months). Moreover, the GRI G3 Guidelines provide an internationally recognised comprehensive framework for reporting that allows for immediate comparability and benchmarking. Thus, if one is to set out on a path to enlightened sustainability reporting, the question of whether or not to adhere to the GRI G3 Guidelines is rhetorical. Why wouldnt you? For more answers to the Why wouldnt you? debate, refer to our conversation with leading reporters, in the Why Bother section of this report.

NOTE

To ensure that this research project maintained a maximum level of comparability, the 363 reports were assessed against the main set of indicators and did not consider any of the industry-specific sector supplements.

Our Personal Favourites

Company Sasol Lonmin plc Sappi Anglo American plc Grindrod Ltd Illovo Sugar Woolworths Astrapak Level A+ NC(A+) A A+ B+ B+ NC(B+) Not GRI Sector Energy & Natural Resources Metals & Mining Energy & Natural Resources Metals & Mining Transportation Food & Beverages Retail General Industry Score 99.6% 94.1% 93.3% 88.5% 73.9% 73.5% 72.3% 31.6% Rank 1 5 6 11 30 31 34 154

12

| GRI Reporters in South Africa Our Research Findings

GRI Reporters in South Africa Our Research Findings

The research team reviewed annual and/or sustainability reports from more than 400 reporting entities, based on an initial list supplied by the JSE (supplemented by reports from other known reporters). Several JSE-listed companies were excluded from the population sample due to a lack of adequate reporting (e.g., some companies were new to the JSE and thus had yet to produce an Annual Report, while others were in the process of de-listing), while others were excluded for being deemed un-South African by virtue of their primary administrative offices no longer being in South Africa. The final population sample of reviewed reports was settled at 363, down significantly from the 392 in our last report (383 in our 2010 report). 128 reporting entities (35.3%) were found to produce GRI G3-based reports, up from 100 (25.5%) last year, and 86 (22.5%) in our 2010 report. 10 companies declared a GRI application level of A+, two declared A, 24 declared B+, 11 declared B, 10 declared C+, and 42 declared C. While 29 companies did not declare an application level, and were therefore classified as ND, a further 32 companies declared a level that was determined to be inaccurate (i.e., the report was not compliant based on missing information), including three that had been assured. As such, these companies were rated as Not Compliant, or NC. 66 reporting entities (18.2%) were found to produce reports that nearly met the GRI G3 requirements based on a GRI compliance score equal or greater than the minimum score for GRI compliance (25.3%). 52 reports were found to have been assured, of which 29 (55.8%) were assured by one or more of the Big 4 accounting firms, and 12 (23.1%) were assured ourselves at IRAS (formerly SustainabilityServices.co.za). 16 reports (30.8%) assured in South Africa were assured using AccountAbilitys AA1000AS Assurance Standard, demonstrating continued significant growth in the application of the standard by various assurance providers. The average GRI compliance score for non-assured reports was 51.1%, whereas the average for assured reports was 71.9%. The lowest score for an assured report was 29.6%, barely above the minimum score required for GRI compliance (25.3%). The lowest score for a non-assured GRI-based report was 22.9% (thus non-compliant). The average response rate for all 127 GRI indicators was 33.8%, of which GRI-based reporters provided responses with an average response rate of 61.8%, compared to 24.4% for non-GRI-based reports. Profile and strategy indicators (1.1 to 4.17) had an average response rate of 89.1% among GRI-based reports and 55.5% among non-GRI-based reports. Disclosure on Management Approach indicators had an average response rate of 53.5% among GRI-based reports and only 10.8% among non-GRI-based reports. Amongst the performance indicators for GRI-based reports, the Economic indicators had the highest levels of responses, with an average response rate of 62.8%, followed by Labour Practices (51.1%), Society (48.7%), Product Responsibility (42.5%), Human Rights (36.9%) and then Environmental (36.8%). The research team invested more than 1 600 hours in the primary review portion of this project, plus no fewer than 1 000 hours in the Quality Assurance (QA), writing and editing phase. This report is provided to ALL reporting entities without cost, as part of our commitment to helping companies improve their progress towards effective integrated sustainability reporting in South Africa. This report is also shared with the more than 60 known other sustainability reporting practitioners (i.e., our peers, colleagues and competitors), based on our belief that while knowledge is power, public domain information should be shared for common benefit. 30 of our peers, colleagues and competitors have advertised in this reporthelping to cover the cost of our launch event, in exchange for the opportunity to assist the IRAS team in our own pursuit of sustainability! In reviewing the 363 reports we settled on as our comprehensive reports database, the goal was not simply to focus on companies that explicitly referred to the GRIs G3 Guidelines, but rather to assess compliance to the Guidelines regardless of whether or not the reporting entities appear to be aware of them. In doing so, compliance, for the purposes of this exercise, was extended to whether or not reports offered at least a basic response to each of the G3 indicators, including the full list of the 127 indicators and management approach disclosure requirements. Our goal was not necessarily to assess the accuracy of any of the responses, but rather to determine if reasonable or partial responses could be found. Ultimately, our research team identified 128 GRI G3-based reports and 66 near-reporters (i.e., companies that scored above the minimum C-level compliance score of 25.3%), and hereby offer up a ranking of reports relative to GRI G3 compliance. Scoring was based on a simple 0, 1 or 2 scale, where 0 was scored for no response, 1 was scored for a basic response and 2 was scored for a reasonable response. As such, it is important to note that a company could be GRI G3 C-level (i.e., entry level)
14

NOTE

Each report was reviewed in great detail, whereby the average review time per report exceeded 4 hours. Thus, it should be noted that where a report was deemed difficult to review, the research team may have recorded a no response rating (i.e., a score of 0 for a specific indicator) based on their inability to find a response, even though the reporting entity may ultimately be able to help find one.

compliant with a minimum score of only 25.3%, while A-level compliance can occur with a minimum score of 56.7%. Of principal interest to the research team, it was determined that of the 2 202 GRI-based sustainability reports identified via the GRIs own database of reports (updated using data from our research), 128 (5.8%) are from South African companies. In fact, and although the number of listed reporting countries rose from 53 in 2008 to 64 in 2010 and 73 in 2011, it was interesting to note that the top 10 reporting countries, by number of reports, accounted for 1 216 of the 2 202 reports, or 55.2%, while the top 15 countries accounted for 1 503 of the listed reports (68.3%). The continued growth in the number of GRI-based reports, and reporting countries, is further evidence that the influence of the GRI G3 Guidelines is continuing to spread. Whereas there were only 41 countries represented on the GRIs list of reporting entities seven years ago, there are now 73, with the list being relatively

NOTE

Perhaps its not my place to speculate about subterfuge, but I find it rather interesting that in the year when China suddenly emerges as one of the top 10 reporting countries (#6 with 118 reports), the historical record of Taiwans share of the GRIs reporting database has disappeared. Not only does Taiwan no longer appear in this years record of GRI-based reports, but the reference to Taiwanese companies reports prior to 2011 still residing in my backed-up records from each of the past three years is nowhere to be found. Given that China does not allow its trade partners to recognise Taiwan as a country, maybe its safe to assume that the GRI has been pushed in a more China-friendly direction. Hmmm

diverse and, including such surprises as the United Arab Emirates (UAE), Nigeria, Mongolia and Palestine. Of course, one must remember that the information supplied by the GRI is not completely accurate. The mere fact that the GRI only records 68 SA companies in their database when their attention was drawn to the 100 companies we identified in our 2011 research report (reviewing reports published for 2010) suggests that a 47.1% margin of error may be possible across the entire global database. As such, our assertion that SA is the 3rd largest sustainability reporting entity for 2011 must be taken with a proverbial pinch of salt. At present, the database supplied by CorporateRegister.com is the best possible comparative tool available to assess the uptake of the GRI G3 Guidelines across the full 13-year span of GRI

reporting, although the GRIs own database can be useful in cross-checking for lapses. However, because CorporateRegister. com has opted to ban IRAS from using its database on the basis of our willingness to share our research results with everyone including the GRI we can only draw your attention to their excellent database: we cant use it, and thus cant offer you any research findings based on their data. Nonetheless, based on the available data, South Africa has made the following moves in terms of our dominance in GRI-based reporting over the past few years: from tied for 7th position in our review of 2007 reports, to 3rd for 2008 reports, to 5th for 2009 and 2010 reports, to 3rd for 2011 reports. Regardless of the accuracy of these figures, the results clearly suggest that South Africa is among a rare breed of countries

successfully implementing the GRI G3 Guidelines as a means for demonstrating maximum transparency and accountability. More specifically, the Metals & Mining, Banking & Financial Services, Retail, Health, Energy & Natural Resources and Construction & Materials sectors, within the South African economy, represent local leaders in sustainability reporting. Thus, it should come as little surprise that the GRI has identified South Africa as the next GRI Focal Point, following the establishment of FPs in Australia, Brazil, China, India and the US (as well as their global offices in the Netherlands). Apparently, it is their intention to ensure that the leadership position of South Africa is used as a platform for rolling out the Guidelines into the rest of Africa.

Reports by Industry/Sector
GRI+13
Reports Metals & Mining Banking & Financial Services Construction & Materials Real Estate Services & Other Retail Food & Beverages Electronics & Electrical Equipment Engineering & Support Services General Industry Software & Computers ICT Info, Comms & Telecoms Transportation Hotels & Leisure Energy & Natural Resources Media & Communications Pharmaceuticals & Biotechnology Health Chemicals Household & Leisure Goods NGO Automotive & Parts Average GRI-compliance score: Increase in GRI-based reports: 28.0% 56 55 36 26 23 21 21 17 14 13 12 10 10 9 7 7 6 5 5 4 3 3 363 GRI 24 14 10 2 4 8 8 6 8 7 3 4 6 3 4 4 2 4 3 0 3 1 128 62.3% 45.5% 58.3% 2 235 Avg Score 69.7% 60.8% 51.1% 41.3% 46.9% 55.6% 54.9% 53.8% 39.9% 64.9% 31.8% 56.4% 55.7% 85.2% 85.2% 55.3% 53.0% 57.1% 43.1% Non-GRI 32 41 26 24 19 13 13 11 6 6 9 6 4 6 3 3 4 1 2 4 Avg Score 22.3% 20.3% 23.2% 19.5% 21.2% 22.7% 24.3% 21.3% 15.9% 25.0% 20.9% 16.6% 20.6% 18.8% 14.9% 20.8% 21.9% 24.1% 26.5% 33.1% 62.3% 23.9% 19.0% 20.5% % GRI 42.9% 25.5% 27.8% 7.7% 17.4% 38.1% 38.1% 35.3% 57.1% 53.8% 25.0% 40.0% 60.0% 33.3% 57.1% 57.1% 33.3% 80.0% 60.0% 0.0% 100.0% 33.3% 25.1% 3 392 1 100 70.5% 58.3% 2 292 16.3% 19.0% 33.3% 25.1% Reports 67 63 37 27 9 21 20 17 28 14 16 8 7 14 9 9 5 5 6 7 GRI 24 17 5 0 5 7 5 3 4 5 1 3 3 3 3 3 1 2 4 1 67.6% 60.6% 48.7% 60.8% 37.9% 63.6% 50.4% 55.5% 55.0% 43.8% 83.3% 34.5% 64.2% 54.5% 49.0% 54.7%

GRI+12
Avg Score 68.3% 55.7% 51.3% Non-GRI 43 46 32 27 4 14 15 14 24 9 15 5 4 11 6 6 4 3 2 6 Avg Score 18.1% 18.2% 20.9% 16.3% 14.5% 21.0% 23.5% 18.8% 17.2% 20.2% 20.8% 14.9% 16.7% 19.7% 16.7% 18.2% 22.9% 30.6% 17.3% 22.5% % GRI 35.8% 27.0% 15.6% 0.0% 42.9% 33.3% 25.0% 17.6% 14.3% 35.7% 6.3% 37.5% 42.9% 21.4% 33.3% 33.3% 20.0% 40.0% 66.7% 14.3%

15

| GRI G3 Reporters in South Africa Our Research Findings continued

Whos Reporting? (www.globalreporting.org)
Country 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 USA Spain South Africa Sweden Brazil China Netherlands Germany Australia UK Switzerland Canada Italy Republic of Korea Russian Federation Austria Argentina India Japan Finland Chile Greece Portugal Mexico Peru Colombia Hungary France Belgium Denmark Norway Turkey Israel Philippines New Zealand Singapore Poland Reports 231 164 128 122 119 118 93 89 83 69 69 63 58 53 44 43 39 39 37 36 36 35 35 34 33 31 30 29 24 19 17 17 15 13 12 12 12 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 Country Thailand United Arab Emirates Malaysia Ecuador Sri Lanka Bolivia Jordan Saudi Arabia Uruguay Costa Rica Croatia Czech Republic Indonesia Ireland Luxembourg Bulgaria Honduras Pakistan Romania Kuwait Albania Andorra Bangladesh Egypt Estonia Georgia Kenya Latvia Mongolia Nigeria Papua New Guinea Qatar Serbia Slovakia Slovenia Ukraine Reports 11 10 8 7 7 4 4 4 3 3 3 3 3 3 3 2 2 2 2 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1

NOTE

The above table has been extracted from the GRIs database for reporting purposes even though the data is known to be incorrect. The information for South Africa has been updated using our own results.

16

CLIVE

lotter

Of the 363 companies reviewed, 111 (30.6%) are from the Metals & Mining and Banking & Financial Services sectors, with 38 of the 128 GRI-based reports coming from these two sectors alone. Meanwhile, three of the nine companies in the Hotels & Leisure, and four of the seven companies in the Energy & Natural Resources sectors produced excellent GRI-based reports, with an average GRI-compliance score of 85.2%: the highest for any industry sector. However, not a single GRI based report was found for any of the four companies in the Household & Leisure Goods sector, and only two of the 26 in the Real Estate sector. Overall, more than 35% of the 363 (mostly JSE-listed) South African reporting entities reviewed, were found to produce annual and/or sustainability reports that adhere to the GRI G3 Guidelines.

Interesting notes

The principle of do as I say, not as I do continues to hold true at the JSE, and to a lesser extent at Brait (now that King is no longer at the Chairmans helm). Opting NOT to produce a GRI-based report, in line with their own King III recommendations, the JSEs report ranked 170th with a GRI compliance score of 29.2%, which is not only an improvement on last years 24.4% (albeit ranked 151st), but also a score in excess of the GRI compliance minimum of 25.3%, which would classify the JSE as a near GRI reporter. Brait, at which Mervyn King was the Chairman while heading the King Commissions on corporate governance in South Africa, did manage to declare that they had produced a GRI-based report in 2010, yet our team could not find adequate evidence to support this claim, and did not appear to make a similar assertion this year. Their current report scored 26.9% thus, another near GRI reporter and ranked 181st out of 363 reports. Once again, it should be noted that none of the research team understood who the JSE Limited and/or Brait were, particularly in the context of sustainability reporting in South Africa, prior to the completion of the scoring process. Thus, no research bias was applied to these entities, and thus I calmly assert that Im not trying to pick on them! For the third consecutive year Sasol rose to the top of our ranking of GRI compliance scores for South African sustainability reports, with an impressive 99.6% compliance score, while Gold Fields scored 96.0% and Wilderness Safaris scored 94.9%. Granted, many of the 363 reports reviewed were regarded by the research team as equally impressive from a qualitative perspective, but the primary purpose of this exercise was to determine the extent to which companies have been applying the GRI G3 Guidelines. Not unexpectedly, eight of the top 20 reporting entities are from within the Metals & Mining sector, and another three are from the Energy & Natural Resources sector, thus 11 (55%) are from high environmental impact sectors. However, it may come as somewhat of a surprise that Little Eden, an NGO that provides care to persons with severe mental disabilities, opted to rigorously apply the GRI Guidelines to its first integrated annual report, rounding out the top 20 with a GRI compliance score of 79.1%. The rationale behind such a move, was to use the GRI Guidelines, following in the footsteps of Cotlands, in an attempt to not only assert that they had the necessary financial and governance controls in place to merit the contributions they receive from donors, but also to assess where process improvement might be possible. For anyone setting out on a brand new reporting journey, Little Edens first GRI-based report is well worth reviewing, as it offers up countless examples of how the Guidelines can be applied effectively.
17

Corporate reporting specialist Clive Lotter

consultant since Wordsmith

1996

Cell: +27 Tel: +27 Email:

clive.l

A veteran writer, editor and architect of company reports and business bids, Clive Lotter routinely consults to listed companies and design agencies. As a pathfinder in King III and GRI3.1 compliance, Clive is adept at structuring and preparing reports to meet current requirements.

Skills checklist
Structuring integrated annual and sustainability reports Report writing/editing Preparing and interviewing key persons

Services offered with proven associates

Gap and peer group analyses of reports Design, layout, proofreading Independent assurance
A team leader or team player, depending on your brief, Clive Lotter is your first choice for compliant and tailored corporate reporting.

Contact: Clive Lotter

082 920 3731 clive.lotter@gmail.com

Top 20 GRI Reports

Collaborate
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Company Sasol Gold Fields Wilderness Barloworld Lonmin Sappi African Rainbow Minerals Impahla Clothing Xstrata South Africa Anglo American Platinum Anglo American plc Kumba Iron Ore African Bank Phumelela Gaming & Leisure Sanlam Altron Distribution & Warehousing Network Mondi Northam Platinum Little Eden Sector Energy & Natural Resources Metals & Mining Hotels & Leisure General Industry Metals & Mining Energy & Natural Resources Metals & Mining General Industry Metals & Mining Metals & Mining Metals & Mining Metals & Mining Banking & Financial Services Hotels & Leisure Banking & Financial Services Electronics & Electrical Equipment Construction & Materials Energy & Natural Resources Metals & Mining NGO Score 99.6% 96.0% 94.9% 94.1% 94.1% 93.3% 90.9% 89.3% 88.9% 88.5% 88.5% 87.7% 84.6% 84.6% 82.6% 81.8% 81.8% 81.0% 79.8% 79.1% GRI AL A+ A+ B+ A+ NC(A+) A A+ ND B+ A+ A+ NC(A+) B+ C B+ B+ A B+ B+ B+

Create

Communicate

Equally unsurprising is the fact that 24 of the 128 GRI-based reports are from the Metals & Mining sector. This is undoubtedly due to the nature of mining, both in terms of the high energy consumption and other environmental impacts, as well as the direct link to high occupational health & safety risks. However, an interesting anomaly has arisen with respect to companies in the Banking & Financial Services sector. Although 55 of the 363 companies reviewed, and 14 of the 128 GRI-based reports, are from this sector, none of the reports for this sector scored within the Top 10 and only two African Bank and Sanlam scored within in the Top 20 (13th and 15th, respectively), yet six scored within the bottom 20 reports. The tables on the next page show the sector analyses for each of 18 common industry sectors, plus Miscellaneous, which is an amalgamation of all sectors represented by fewer than three different reporting entities. Its interesting to note that the average scores per sector ranged from 85.2% for the Energy & Natural Resources and Hotel & Leisure sectors (tied), to 31.8% for the Software & Computers sector.

We are a multi-disciplinary creative consultancy offering a complete range of communication services. Partnering with you, we produce content and design of uncompromising quality.

011 783 3187 info@itbmedia.co.za www.itbmedia.co.za

18

page
every page

same

on the

page by page
delivering excellence in integrated reports with integrated process analysis specialist writing and relevant information design

www.envisagesa.co.za

+27 11 325 5944

Salome Brown
communications
19

| GRI G3 Reporters in South Africa Our Research Findings continued

GRI Reports by Industry Sector
(GRI +13) 2012 GRI Compliance Score % (GRI +12) 2011 GRI Compliance Score % (GRI +11) 2010 GRI Compliance Score % (GRI +13) 2012 GRI Compliance Score % (GRI +12) 2011 GRI Compliance Score % (GRI +11) 2010 GRI Compliance Score % (GRI +13) 2012 GRI Compliance Score % (GRI +12) 2011 GRI Compliance Score % 61.0 90.6 61.0 57.5 57.9 48.0 62.7 41.7 52.8 56.3 37.0 47.0 24.0 52.0 43.7 39.9 81.9 49.2 35.4 55.5 30.3 27.2 37.0 39.4 33.5 23.6 42.9 33.3 31.9 43.7 42.9 39.5 31.1 38.2 37.0 29.9 34.1 49.6 63.8 50.4 52.4 55.9 52.9 (GRI +11) 2010 GRI Compliance Score % 82.7 67.7 59.8 59.1 (GRI +13) 2012 Rank (GRI +13) 2012 Rank (GRI +13) 2012 Rank 4 8 48 58 77 83 84 (GRI +13) 2012 Application Level (GRI +13) 2012 Application Level (GRI +13) 2012 Application Level General Industry 16 27 85 95 118 144 81.8 75.9 48.2 44.7 39.1 33.2 53.8 99.6 93.3 81.0 66.8 85.2 59.7 46.2 41.5 40.3 38.3 33.6 30.0 29.6 39.9 73.5 69.2 68.8 54.2 53.8 51.8 36.4 31.6 54.9 63.0 83.3 18.5 22.4 38.6 42.1 15.7 43.7 27.2 14.6 27.9 53.5 50.0 57.5 37.4 33.9 55.5 18.9 18.1 40.6 60.2 78.2 21.7 33.1 23.6 22.0 24.8 33.1 33.9 23.6 27.0 32.3 39.0 43.7 39.4 37.4 50.8 35.4 24.4 37.8 68.9 68.1 45.3 22.0 19.3 17.3 40.2 99.6 87.4 54.3 43.3 33.5 32.7 16.9 Barloworld Impahla Clothing Bidvest Nampak Denel Mpact 36.1 94.9 79.5 Eqstra Average Health Netcare Mediclinic Discovery Life Healthcare Average Hotels & Leisure Wilderness Phumelela Gaming & Leisure A+ ND ND C ND C ND 94.1 89.3 65.6 58.5 49.8 48.6 48.2 64.9 76.7 62.1 52.6 37.2 57.1 94.9 84.6 76.3 85.2 67.6 58.5 53.4 46.2 56.4 66.4 54.9 50.6 49.4 55.3 B NC(C) B ND

Banking & Financial Services African Bank Sanlam Standard Bank Nedbank Absa Group Liberty Brimstone Santam MMI Holdings Investec Sasfin FirstRand Efficient Group Finbond Average Chemicals AECI Omnia African Oxygen Average Construction & Materials Distribution & Warehousing Network Group Five Pretoria Portland Cement Murray & Roberts Esorfranki Basil Read Wilson Bayly Homes-Ovcon Buildmax Stefanutti Stocks KayDav Average B+ B+ B+ A+ B+ B+ ND B C NC(B) C ND C+ C 13 15 22 23 33 35 47 52 79 100 103 106 115 116 84.6 82.6 79.1 78.7 72.3 71.9 66.4 62.1 49.4 42.7 41.9 41.1 39.5 39.5 60.8 47.0 44.7 37.5 43.1 61.8 60.6 76.4 67.3 60.2 76.8 58.7 52.8 15.0 55.5 21.7 40.6 17.7 16.9 48.7 43.3 49.2 61.4 51.3 59.1 25.2 46.9 20.5 19.7 47.6 44.9 44.5 73.2 54.2 47.2 57.9 79.1 69.3 59.4 70.5 24.8 39.4

Electronics & Electrical Equipment Altron Altech Reunert Digicore Delta EMD B+ B+ ND C+ ND

Consolidated Infrastructure Group NC(C) Average Energy & Natural Resources Sasol Sappi Mondi A+ A B+

1 6 18 45

25 51 70 128

Eskom B+ Average Engineering & Support Services PSV Primeserv OneLogix Howden Africa Austro Group Iliad Africa Hudaco Industries C+ ND C C C+ NC(C) NC(C) NC(C)

55 90 105 111 121 143 159 164

B+ C

3 14 26

ND NC(C) ND

86 96 126

Sun International B+ Average ICT Info, Comms & Telecoms MTN Vodacom Telkom Morvest Average Media & Communications Avusa Media24 Naspers MultiChoice Average NC(B) NC(B) C+ C+

44 59 68 89

A ND C+ B+ C NC(C) C C C C+

17 41 65 71 74 81 91 113 125 163

81.8 69.2 54.9 52.6 50.6 49.0 46.2 39.5 37.9 29.6 51.1

37.8 61.0 57.1 55.9 24.4 41.3 31.5 18.5 29.1 11.0 36.8

52.8 60.2 65.7 58.3 28.7 32.7 37.8 27.2 31.1 16.1 41.1

Top Fix Holdings Average Food & Beverages Illovo Sugar Afgri Tongaat Hulett Astral Foods Distell Rainbow Chicken AVI Country Bird Average

B+ C B+ ND NC(C) ND ND ND

31 40 42 66 67 73 135 153

NC(C) NC(C) NC(C) NC(C)

46 64 75 80

20

(GRI +13) 2012 GRI Compliance Score %

(GRI +12) 2011 GRI Compliance Score % 82.7 58.7 83.5 70.9 36.2 12.2 42.5 55.2 52.0 24.4 54.3 19.3 37.5 50.4 33.5 18.9 34.3 68.9 37.0 29.5 59.1 15.4 42.0 64.2 20.1 31.1 22.4 21.7 31.9

(GRI +13) 2012 GRI Compliance Score %

(GRI +12) 2011 GRI Compliance Score %

(GRI +11) 2010 GRI Compliance Score %

(GRI +13) 2012 Rank

Metals & Mining Gold Fields Lonmin African Rainbow Minerals Xstrata South Africa Anglo American Platinum Anglo American plc Kumba Iron Ore Northam Platinum Anglo Gold Ashanti Harmony Gold Merafe Resources Exxarro Impala Platinum Evraz Highveld Steel & Vanadium Royal Bafokeng Platinum Arcelor Mittal DRD Gold Aquarius Platinum Witwatersrand Consolidated Gold Wesizwe Platinum Assore Eastern Platinum Keaton Energy Richards Bay Minerals Average NGO Little Eden Soweto Marimba Youth League Cotlands Average A+ NC(A+) A+ B+ A+ A+ NC(A+) B+ A+ B+ B+ B+ B+ NC(C) B+ ND NC(C) NC(C) C NC(C) C NC(B) NC(C) NC(C) 2 5 7 9 10 11 12 19 24 28 29 32 36 39 43 49 54 57 69 82 87 92 119 134 96.0 94.1 90.9 88.9 88.5 88.5 87.7 79.8 77.5 75.1 74.7 72.7 70.8 69.6 68.0 64.4 60.5 58.5 53.0 49.0 46.6 45.5 39.1 36.8 69.8 79.1 55.7 52.2 62.3 55.5 55.5 54.3 54.3 94.9 93.3 82.3 68.1 83.5 86.6 57.5 81.9 85.0 81.9 61.4 70.1 61.4 74.4 57.1 54.3 65.0 56.3 22.0 28.3 42.9 33.1 39.8 64.4 29.9 63.4 44.9 59.1 48.8 22.4 33.9 36.6 64.2 85.8 83.5 84.6 72.0 76.4 74.8 89.4 83.1 64.6 85.4 65.0

(GRI +13) 2012 Application Level

Retail Massmart Woolworths Foschini JD Group Clicks Verimark Truworths Holdsport Average Services & Other Umgeni Water Adcorp Blue Label Telecoms Workforce Average Software & Computers Gijima Business Connexion Silverbridge Average Transportation Grindrod Transnet Comair Imperial Value Group Cargo Carriers Average Miscellaneous Aspen Pharmacare Metair Investments Adcock Ingram Redefine Properties Hyprop Investments Average ND NC(B+) ND ND ND ND ND ND 21 34 37 38 114 120 129 133 79.1 72.3 70.4 70.4 39.5 39.1 37.2 36.8 55.6 62.1 44.7 43.9 37.2 46.9 37.9 34.4 22.9 31.8 73.9 58.1 56.9 56.5 46.6 42.3 55.7 62.5 45.5 43.5 42.3 40.3 46.8 73.6 54.3 40.9 37.8 48.4 18.5 46.1 45.7 50.4 31.1 48.0 24.8 38.6 26.0 38.6 21.3 28.6 68.9 54.3 32.3 55.9 26.4 22.4 43.4 53.5 21.3 37.8 28.0 35.2

NC(B) ND C+ NC(C)

53 94 98 130

NC(B) NC(C) NC(C)

124 141 210

B+ C C C C C

30 60 61 62 88 101

B+ C ND

20 63 72

NC(B) C+ NC(B) ND ND

50 93 99 102 112

21

(GRI +11) 2010 GRI Compliance Score %

(GRI +13) 2012 Rank

(GRI +13) 2012 Application Level

| GRI G3 Reporters in South Africa Our Research Findings continued

Upon further scrutiny, it was interesting to note that the average GRI compliance score per sector rose significantly for all but two sectors since last year. While the Chemicals sector AECI, Omnia Holdings and African Oxygen dropped from 51.3% to 43.1%. the Software & Computers sector Gijima, Business Connexion and Silverbridge dropped from 34.3% to 31.8%. In all other cases, the average score rose, but none as much as the Hotel & Leisure sector Wilderness, Phumelela Gaming & Leisure and Sun International which skyrocketed from 39.9% to 85.2%, with all three companies making enormous strides in their reporting. Overall, the uptake rate of the GRI Guidelines for the 2011 reporting period was just over 35%, with only the Household & Leisure Goods sector (4 companies) completely opting out of compliance. The fact that the NGO sector has achieved an opt-in compliance rating of 100% is a bit of a fallacy, in that NGOs are not required to opt in, and thus our population sample is strictly limited to the three NGOs we were aware of. However, its worth noting that the Health sector four of five listed entities within the sector has adopted the Guidelines en masse. In the end, 194 South African companies were identified as being either GRI reporters (128) or near reporters (i.e., the 66 companies that are non-GRI but scored above the 25.3% threshold required for GRI compliance, if theyd only paid attention to the Guidelines when drafting their report). What excites me the ber-GRI-Geek is that if each of these companies were to make the minimal effort required. South Africa would escalate its status as a confirmed leader in terms of transparency and accountability through sustainability reporting (194 would catapult South Africa ahead of Spain, and second only to the USA (with its many thousands of listed companies, compared to South Africas 400-ish). appear to have mastered the Profile Disclosures, Organisational Profile, Report Parameter and Governance Indicators, the same cannot be said for the Human Rights, Product Responsibility and Environmental indicators, which appear to trouble reporters.

Average Response Rate per G3 Category of Indicators

GRI Reports GRI+13 Score Profile Disclosures Organisational Profile Report Parameters Governance. Commitments. and Engagement Disclosures on Management Approach (DMAs) Economic Environmental Labour Practices and Decent Work Human Rights Society Product Responsibility ALL INDICATORS All INDICATORS/ALL REPORTS 89.1% 95.9% 84.3% 77.8% 53.5% 62.8% 36.8% 51.1% 36.9% 48.7% 42.5% 57.9% 34.1% GRI+12 Score 90.3% 92.9% 72.5% 76.2% 42.0% 66.8% 42.7% 58.8% 35.1% 48.8% 39.7% 58.0% 29.0% Non-GRI Reports GRI+13 Score 55.5% 77.4% 31.5% 48.0% 10.8% 20.0% 4.0% 10.6% 2.2% 6.9% 1.9% 21.2% GRI+12 Score 53.0% 73.0% 25.6% 37.5% 2.8% 23.7% 3.3% 13.1% 3.2% 5.9% 2.8% 19.0%

Rates of Response to the GRI Indicators

As from last years research report based on queries raised as a result of our first two research reports we now provide detailed indictor-by-indicator response rates for each of the 127 GRI indicators. Appendix IV provides the indicator-specific responses, but it should be noted that some areas within the Guidelines continue to be more of a challenge for reporters than others. While GRI reporters

While experienced reporters such as Sasol, Eskom and Anglo American Platinum may not struggle with these indicators, its reasonable to expect that anyone starting to produce their first report may find the indicators somewhat of a challenge to adapt to their own organisational scenario. As such, and given that the support afforded by the GRI is not always deemed useful, the best advice one could give is to recommend that new reporters interrogate the work of those companies that are oft-respected for the quality of their reports. Perhaps the best place to start is the ACCAs annual awards for sustainability reporting. By identifying which reports are deemed best in class, new authors can short-cut their journey to effective reporting by reading what leaders have done.

Rates of Response to the GRIs Energy, Emissions and Water Consumption Indicators
Not unlike many other countries around the world, South Africa finds itself in a precarious balance between the economy and the environment. Water scarcity threatens not only agricultural output, but also the basic survival of communities throughout the country, while the supply of electricity to meet an ever-expanding demand is having significant impacts on our national carbon emissions tally. With carbon taxes looming on the horizon,
22

as well as the rapidly inflating cost of energy both electricity and oil (i.e., petrol and diesel) one might expect companies to be freely reporting to shareholders (set aside all other interested and affected stakeholders) about how well these costs are being managed in both the short and long-term. Given that these environmental concerns are heaped upon the numerous social challenges privy to a country with one of the highest Gini coefficients in the world (i.e., extremely high levels of income disparity, and the resultant social justice challenges), one might reasonably argue that the GRI Guidelines are precisely the blueprint South African companies need to ascertain how well they are managing their ability to confront energy consumption, carbon emissions and water consumption challenges. Unfortunately, this is not necessarily the case: at least not yet. What may be of significant interest to researchers and practitioners alike is the fact that our research determined that South Africa has become somewhat of a leader in terms of

reasonable expectations for carbon footprint and/or greenhouse gas (GHG) emissions disclosure. Not only have 83 of the JSEs top 100 companies participated in the Carbon Disclosure Projects voluntary reporting protocols. As discussed later in this report, of the 363 companies reviewed, a total of 114 companies (31.4%) offered any responses to EN16 (direct & indirect GHG emissions), while 55 companies provided responses to all five of the GRIs energy consumption and carbon emissions indicators (EN3, EN4, EN16, EN17 and EN18). Whats of particular interest is the significant difference in reporting of energy and emissions for companies that have not yet adopted the GRI G3 Guidelines. Among the 235 non-GRI reporters, the average response rate for these five indicators was roughly 6.9%: far below reasonable expectations for companies that MUST report on how they are managing their impacts on climate change and a growing scarcity of energy supplies.

Response Rates for Key GRI G3 Indicators: Energy Consumption and Emissions
2011 Response Rate GRI EN3 EN4 EN16 EN17 EN18 Direct energy consumption by primary energy source. Indirect energy consumption by primary source. Total direct and indirect greenhouse gas emissions by weight. Other relevant indirect greenhouse gas emissions by weight. Initiatives to reduce greenhouse gas emissions and reductions achieved. 58.6% 62.9% 61.7% 34.8% 41.4% Non-GRI 6.6% 8.3% 10.9% 3.2% 5.5% 2010 Response Rate GRI 58.5% 56.5% 67.0% 43.0% 61.0% Non-GRI 5.7% 2.2% 3.3% 1.5% 8.9%

Whats even more worrying is that in a country deemed to be a water scarce environment, the quality of information being presented by companies is shockingly low. Even though the concept of reporting a water footprint is still a relatively new phenomenon, one would reasonably assume that companies would be far further ahead in reporting their water consumption patterns, and efforts to reduce consumption and/or recycle water.

However, only 30 GRI-reporting companies (8.3%) provided reasonable responses to the GRIs three water indicators EN8, EN9 and EN10 while a further 15 (4.2%) provided partial responses. Among the 235 non-GRI reporters, the average response rate for these three indicators was roughly 3.7%: again, far below reasonable expectations for companies in South Africa.

Response Rates for Key GRI G3 Indicators: Water Consumption and Impacts
2011 Response Rate GRI EN8 EN9 EN10 Total water withdrawal by source. Water sources significantly affected by withdrawal of water. Percentage and total volume of water recycled and reused. 53.5% 33.2% 29.7% Non-GRI 6.6% 1.3% 3.2% 2010 Response Rate GRI 61.0% 32.0% 32.0% Non-GRI 3.3% 0.7% 3.3%

In summary, one must remember that the GRI Guidelines are not merely a tool for reporting, but rather a tool that can be used to identify gaps and/or weaknesses in systems and controls that should be in place to manage risks and/or opportunities. If nothing else, the paltry uptake on the above environmental indicators

should serve to prove that companies have not adopted the GRI Guidelines. In order enhance their ability to prove that they are prepared to mitigate the shifting environmental world around us, companies should adopt the Guidelines as a means for adhering to the adage, that which is not measured is not managed.

23

From

by Mike Fitzpatrick Top: # 9891 West Coast Panoramic Right: # 9884 Wild Lips Mike Fitzpatrick Reproduced with permission

From The Millennium Edition by Mike Fitzpatrick Top: # 9891 West Coast Panoramic Right: # 9884 Wild Lips Mike Fitzpatrick The Reproduced with Edition Millennium permission

4 Repens Street, Heriotdale Telephone (011) 621 3300 Telefax (011) 626 3578 E-mail info@ultra-litho.co.za www.ultra-litho.co.za

Lucrecia, Rebecca, Jerry, Garth, And Peter, Rudo, Millicent, Ajit, Mary-Ann Pieter, Vernando, Israel, Cheryl, Thom Lettie, Mark, Mark, Stella, Peter, Rom Mark, Thylile, Rudolph, Fred, George Wanda, Glen, Lucy, Colin, Eric, Johan Thavarani, Peter, Jason, Norman, Re Karen, Lainy, Llewellyn, Graham, He Ann, Brandon, Levina, Sorina, Jousl Simon, Japie, Maphuli, Buti, Sabela, Wendy, Shy-Ann, Les, Shawn, Takala Dean, Hugo, Sylvia, Marthinus, Andr Natalie, Macdonald, Sunday, Ernest, Mandla, Altaff, Farhana, Alwyn, Mary Hlengani, Malesela, Jack, Freddie, W From The Millennium Editio Zandile, Robert, Michael, Thokozile, Ethel, Phindile, by Mike Fitzpatric Sipho, Goodwill, Nko Top: # Portia, Abram, Mirriam, Dav Sidwell, 9891 West Coast Panoram Angelinah, Dichakge, 9884 Wild Li Right: # Jose, Kesival, Nigel, Oupa, Bernard, Edson, Aaron, Zodwa, Themba, Mike Fitzpatric Timoteo, Phakama Reproduced with permissio Myendran, Sushilan, James, Neledz Grammer, Richard, Izak, Mandla, Mannie, David, Jacob, Martin, Sithembiso, Fikile, Sibonginkosi, Mark, Poobalan, T Mark, Sybil, Thelma, Eric, Neville, Mathlodi, Andr, Marie, Andr, Abiot, Ethel, Ayantra, Manual, Lydia, Marco, Tebo Claude, Sheldon, Phumzile, Ivor, Simphiwe, Harry, Shanton, Garth, Vic, Morwamotsumi, Skhumbuzo, Clement, Joh Henry, Thembisile, Michael, Patience, Benjamin, Cornelius, Henning, Hermanus, Jacobus, Maxwell, Janine, Clive, J Andrew, Ruby, Pesafny, Joseph, Lucrecia, Rebecca, Jerry, Garth, Andrew, Peter, Rudo, Millicent, Ajit, Mary-Anne, Vi Pieter, Vernando, Israel, Cheryl, Thomas, Lettie, Mark, Mark, Stella, Peter, Roman, Mark, Thylile, Rudolph, Fred, Ge Conrad, Wanda, Glen, Lucy, Colin, Eric, Johan, Anand, Thavarani, Peter, Jason, Norman, Reagan, Karen, Lainy, Llew Graham, Herman, Ann, Brandon, Levina, Sorina, Jouslen, Robin, Simon, Japie, Maphuli, Buti, Sabela, Hans, Wendy Shy-Ann, Les, Shawn, Takalani, Carol, Dean, Hugo, Sylvia, Marthinus, Andriette, Natalie, Macdonald, Sunday, Ernes Mandla, Altaff, Farhana, Alwyn, Mary-Ann, Hlengani, Malesela, Jack, Freddie, William, Zandile, Robert, Michael, Th Bedwell, Ethel, Phindile, Sipho, Goodwill, Nkosiyezwe, Sidwell, Portia, Abram, Mirriam, David, Onica, Angelinah, D Jose, Kesival, Roland, Nigel, Oupa, Bernard, Edson, Aaron, Linon, Zodwa, Themba, Timoteo, Phakamani, Myendran Sushilan, James, Neledzani, Grammer, Richard, Izak, Mandla, Mannie, David, Jacob, Martin, Sithembiso, Fikile, Sibonginkosi, Mark, Poobalan, Tony, Mark, Sybil, Thelma, Eric, Neville, Mathlodi, Andr, Marie, Andr, Abiot, Ethel, Manual, Lydia, Marco, Teboho, Claude, Sheldon, Phumzile, Ivor, Simphiwe, Harry, Shanton, Garth, Vic, Morwamotsu Skhumbuzo, Clement, John, Shaun, Henry, Thembisile, Michael, Patience, Benjamin, Cornelius, Henning, Hermanu Jacobus, Maxwell, Janine, Clive, Jacob, Andrew, Ruby, Pesafny, Joseph, Lucrecia, Rebecca, Jerry, Garth, Andrew, P Rudo, Millicent, Ajit, Mary-Anne, Victor, Pieter, Vernando, Israel, Cheryl, Thomas, Lettie, Mark, Mark, Stella, Peter, R Mark, Thylile, Rudolph, Fred, George, Conrad, Wanda, Glen, Lucy, Colin, Eric, Johan, Anand, Thavarani, Peter, Jason Norman, Reagan, Karen, Lainy, Llewellyn, Graham, Herman, Ann, Brandon, Levina, Sorina, Jouslen, Robin, Simon

understanding the art of printing

drew, ne, Victor, mas, man, e, Conrad, n, Anand, eagan, erman, len, Robin, , Hans, ani, Carol, riette, , Rory, y-Ann, William, on Bedwell, ck osiyezwe, mic Onica, vid, Roland, ips , Linon, ck ani, on zani, Tony, oho, hn, Shaun, Jacob, ictor, eorge, wellyn, y, st, Rory, hokozile, Dichakge, n,

From The Millennium Edition by Mike Fitzpatrick Top: # 9891 West Coast Panoramic Right: # 9884 Wild Lips Mike Fitzpatrick Reproduced with permission

Independent Third Party Assurance

, Ayantra, umi, us, Peter, Roman, n, n, Japie,

4 Repens Street, Heriotdale Telephone (011) 621 3300 Telefax (011) 626 3578 E-mail info@ultra-litho.co.za www.ultra-litho.co.za

Independent Third Party Assurance

856 reports (38.9%) of the 2 202 GRI-based reports recorded within the GRIs online database* were assured by third parties, of which the vast majority (460, or 53.7% were Application Level A+ reports). 436 reports (34.1%) of the 1 279 reports recorded for the countries representing the Top 10 reporting countries within the GRIs database* were assured by third parties, of which 200 (45.9%, down from 56.7% last year) were assured by one or more of the Big 4 accounting firms, and 108 (24.8%, up from 14.3% last year) were assured according to AccountAbilitys AA1000AS standard. PwC is the dominant player in the global assurance field, with 16% of the market in the top 10 countries (66 reports assured), with KPMG in second place at 12.7% (52 reports assured). EY and Deloitte fall far behind, with 8.3% (34 reports) and 5.1% (21 reports), respectively. 363 South African reports were reviewed by IRAS for this research report, of which 52 reports were found to have been assured. 29 (55.8%, down from 63.9% last year) were assured by one or more of the Big 4 accounting firms. Having assured reports for 12 different clients (23.1% of all assured reports) IRAS retains its position as the number one assurance provider in South Africa. PwC is in second place with 11 engagements (21.1%), KPMG and PKF are in third place (eight reports or 15.4%), Deloitte is in fifth (seven reports or 13.5%) and EY has dropped to the bottom of the class, with only four reports (7.7%). The assurance market has been set upon ferociously with PKF coming from nowhere to offer assurance to eight clients in the past reporting period, while the likes of ERM (two reports) and Nkonki (one report) have already assured reports. There are now 11 different known assurers in the South African market (see our database of Other Sustainability Reporting Practitioners for details). 16 of the assured reports (30.8%) in South Africa (24.8% of the assured reports in the top 10 reporting countries) were assured using AccountAbilitys AA1000AS Assurance Standard, demonstrating a significant rise in awareness and application of the standard. Even the Big 4 accountancies have adopted the standard, apparently in response to criticism over their own accountancy focused ISAE 3000 standard. The average GRI compliance score for assured reports was 71.9% whereas the average for non-assured reports was 51.1%. The lowest score for an assured report was 29.6%, barely above the minimum score required for GRI compliance (25.3%). The lowest score for a non-assured GRI-based report was 22.9% (thus, Non-Compliant). Assurance has not necessarily guaranteed GRI compliance, although it would seem an obvious thing for the assurance provider to check. Two companies reported an A+ and but were deemed NonCompliant, while another one errantly reported a B+. One company even reported a GRI-checked application level, but was found to be Non-Compliant, where non-compliance is defined as a report that has not adequately met the application level requirements.

Independent Third Party Assurance

Given that stakeholders generally dont trust what companies disclose in their annual reports, and given that stakeholders more specifically interested in matters of social and/or environmental responsibility are even more skeptical of companies public assertions, the merits of Independent Third Party Assurance (ITPA) have been on the rise over the past few years. Not only has there been a rise of companies seeking assurance of their own accord, but governments and legislators have started to demand assurance for non-financial disclosures in annual reports. France has recently legislated that ITPA over sustainability information is a requirement, while in South Africa, ITPA is a recommendation within King III. Chapter 9 of King III (Integrated Reporting and Disclosure) clearly states that all companies ought to ensure that their sustainability reports are assured, particularly within the following two principles: 9.1 The board should ensure the integrity of the companys integrated report (also cited as 2.12 in Chapter 2 on Boards and Directors); and, 9.3 Sustainability reporting and disclosure should be independently assured. Although it is widely accepted that the ultimate indicator of sustainability-related transparency and accountability is whether or not a report has been afforded independent third party assurance (ITPA), the problem remains that there is a lack of clarity around what independently assured means, who is best placed to offer such assurance, where adequate skills and experience might reside, and what form an assurance engagement can take (i.e., under what relevant standards). This is becoming even more problematic as new entrants into the space are adopting their own concepts regarding what assurance ought to look like, with some going so far as to rubber stamp reports for as little as R20 000, as a value-added service linked to the financial audit. Yeah right, value-added? Over the past few years, the uptake of ITPA has grown in prominence, both in terms of who is offering assurance, and the forms in which it is offered, and attention is starting to be paid to
26

whether or not the assurance actually adds value to the reporting process and/or to the final outcomes shared with stakeholders. While earlier reports were typically rewarded based on whether or not an assurance opinion has been sought, and therefore a statement is included, the trend has been rapidly moving towards whether or not the statement of assurance is meaningful. Even with reporters fighting to minimise the total page length of their reports (including PwCs now notorious one-pagers), the length of the assurance statement seems to have settled at two pages, with the content of the statement typically offering an opinion over whether the content of the report adequately reflects the materiality, accuracy, consistency, completeness and/or reliability expectations of the reporting entitys key stakeholders. Granted, little to no criticism has been leveled at assurance providers, or questions raised about the quality and/or extent of the assurance provided, but more knowledgeable sustainability report reviewers and/or committed stakeholders are beginning to change that.

Overview of the main types of assurance

ISAE 3000 The accounting professions mandatory standard for engagements other than financial audits. Although useful in ensuring consistency within both the approach to the assurance engagement, and the form of the assurance statement, ISAE 3000 has been frequently criticised for creating barriers to offering an assurance opinion that an average stakeholder can comprehend. The assurance standard developed by AccountAbility (UK) to offer reporters not only a meaningful alternative to the accounting professions ISAE 3000, but also to offer stakeholders a more comprehensive assurance engagement. Increasingly, the accounting firms are coupling AA1000AS to ISAE 3000 in order to meet growing stakeholder demand for meaningful assurance.

AA1000AS

Non-Aligned All other assurance engagements, which currently makes up for more than 40% of all assurance engagements, which are not assured relative to a local and/or internationally recognised standard (noting that an in-house methodology is not necessarily a standard).
*The GRIs stats have been updated using the information found during our research.

Historically, the Big 4 accountancy firms Deloitte, EY, KPMG and PwC have dominated the assurance space, and have been restricted in terms of their assurance scope, methodologies and assurance statements by their industry regulated assurance standard: ISAE 3000. Deemed by many to offer little to no value-add, the assurance statements typically generated by the accountancies have appeared to be more focused on protecting the accountants than offering meaningful insight into the validity of the reports they purport to assure. Most often, they have been widely criticised for their use of the double negative:

Perhaps this is how News of the World managed their internal controls over information gathering, but its not of particular use to readers of reports. Readers need some form of verification, confirmation, or comfort that somebody has checked the report and can comment about whether or not the company is being fair and factual in the assertions they make. They want to know that the data is reasonably collected, collated and reported without error or omission. They also want to know that the company is giving a fair account of the issues that are deemed most material, based not only on what the company believes to be most material, but on what the companys key stakeholders believe. Ultimately, they want to know: On what basis was the assurance provider deemed competent and/or independent? What within the report was checked, by whom, and where? What did the assurance provider uncover during the assurance process (i.e., the findings)? What recommendations for improvement did the assurance provider identify?

What conclusions did the assurance provider come to with respect to the believability of the report? Unfortunately, ISAE 3000 does not at least not adequately address all of these requirements in an effective manner. Most importantly, ISAE 3000 does not require the assurance provider to assess how well the company has defined its most material issues, and/or how well the report reflects reasonable feedback on these MMIs. As a result, there have been two processes occurring, in parallel, in the world of assurance: 1. The International Federation of Accountants (IFAC) released an exposure draft of a revised version of ISAE 3000, and is planning to not only revise the standard, but to potentially open it up to non-accountants. 2. The accountancies have identified a need to change faster than IFAC can allow, and have adopted a policy of applying AccountAbilitys AA1000AS assurance standard over and above ISAE 3000 (on the same engagement). Although this hasnt yet changed the frequency of double negatives, it has at least offered commentary on the principles of inclusivity, materiality and responsiveness.

Nothing has come to our attention to lead us to believe that the information contained herein is not correct.
Brilliant! This is the equivalent of saying,

At huge expense to the reporting company, we sat in lawn chairs outside their building for two weeks, and because nobody came to tell us that something was wrong, we must assume that everything is OK.

Assurance Uptake per Country

Country USA Spain China South Africa Sweden Brazil Germany Australia Netherlands UK Top 10 Total # of GRI Reports 231 166 161 128 125 119 92 91 97 69 1 279 # Assured 27 94 27 52 63 38 37 37 33 28 436 % Assured 10.4 56.6 16.8 40.6 50.4 31.9 40.2 40.7 34.0 40.6 34.1 # Assured by Big 4 5 33 2 29 41 17 24 13 24 12 200 % Assured by Big 4 18.5 35.1 7.4 55.8 65.1 44.7 64.9 35.1 72.7 42.9 45.9 # Assured via ISAE 3000 6 38 2 38 43 15 24 15 24 8 213 % Assured via ISAE 3000 22.2 40.4 7.4 73.1 68.3 39.5 64.9 40.5 72.7 28.6 48.9 # Assured via AA1000AS 6 24 11 16 4 10 3 19 1 14 108 % Assured via AA1000AS 22.2 25.5 40.7 30.8 6.3 26.3 8.1 51.4 3.0 50.0 24.8 Largest assurance provider Deloitte/Two Tomorrows PwC SGS IRAS (SustainabilityServices.co.za) KPMG BSD Consulting PwC Net Balance KPMG PwC

Within the top 10 reporting countries, the presence of AA1000AS assured reports, and ISAE 3000 & AA1000AS assured reports, has been on the rise. For example, all three of the EY assured reports in the UK have cited both standards, while five of the Big 4 assured reports in South Africa have adopted this approach. At 40.6% (up from 36.0% last year), the rate of assurance uptake in South Africa has jumped well ahead of the 34.1% rate among the top 10 reporting countries identified in the GRIs database (down significantly from 41.4% last year, but likely a function of incomplete and/or inadequate data within the GRIs database).

Although a step in the right direction, SAs assurance uptake rate is still lagging well behind the rates identified for both Spain (56.6%), and Sweden (50.4%). However, its the hell draggers in the USA that are still trying to figure who can, or who cant, provide assurance. Not only is there an assurance uptake rate of only 10.4% (27 of 231 reports) in the US, and the Big 4 only account for five (18.5%) of those engagements. Perhaps not all that surprising is the fact that China has a comparably low assurance uptake rate, 16.8% of known reports, with the Big 4 providing assurance over only two reports (7.4%).

As identified in our previous research reports, the most intriguing trend in assurance is not necessarily related to whos getting assurance, but rather whos giving it. As mentioned above, the Big 4 accounting firms continue to play a dominant role in the provision of ITPA over sustainability reports, but their grip on the market appears to be slipping. Not only have we at IRAS taken the number one position in terms of assurance clients, but the Tier 2 accountancies such as PKF, BDO and Grant Thornton have entered the fray. Others to enter include ERM, Assuredex, Nkonki and Inyebo (the latter two being unknown entities at this stage).

27

| Independent Third Party Assurance continued

Assurance Providers in SA
Assurance Provider IRAS* PwC PKF KPMG Deloitte EY ERM Nkonki PwC/EY KPMG/Deloitte Maplecroft/KPMG Total Number of engagements 12 10 8 7 6 3 2 1 1 1 1 52 33 4 7 9 8 5 6 3 1 1 1 1 1 5 3 1 1 1 ISAE 3000 AA 1000 Type I 4 AA 1000 Type II 5 1 ISAE 3000 & AA1000 Non-Aligned 3

to either the company or their stakeholders. Both Anglo American Platinum and Sasol regularly put their assurance out to tender, with change occurring every three to five years. Taking a major step back, it should be clearly stated that ITPA refers to the practice of reviewing a companys Sustainability Report, or sustainability section within an Integrated Annual Report, and training in this field, aside from project-based experiential learning, has been scarce. While the practice of ITPA has become increasingly more formalised over the past 13 years, the lack of appropriate training has only recently been developed. In partnership with AccountAbility, a UK-based not-for-profit network that has established standards for stakeholder engagement and assurance (AA1000SES and AA1000AS), IRAS established the first training course for budding Certified Sustainability Assurance Practitioners (CSAP) in 2009, and has run 5-day courses biannually since then. Although a course has already been offered in March of this year, a second course is being offered in October due to demand (email info@iras.co.za for more information). In developing the standards and CSAP accreditation process, AccountAbility (www.accountability.org) has attempted to create formal structures around what has been a relatively diverse set of provider-specific approaches to assurance. However, the past 13 years of GRI-based reporting has allowed for the filtration of three standard types of assurance: Content-Based Assurance; Assertion-Based Assurance; and, Indicator-Based Assurance.

* IRAS, or Integrated Reporting & Assurance Services, was formerly known as SustainabilityServices.co.za

Although there has been a significant jump in the number of assurance providers over the past couple of years to where reporters now sit with the option of choosing from a pool of 11 different companies there is still an ongoing lack of assurance skills available in South Africa. Part of the issue appears to be a desire to shift away from the Big 4, for reasons either of cost or a shallow experience base, with too little demonstrated capacity to add value through the process. Even within the Big 4 there appears to be an inability to attract and retain people with sufficient real world experience, and who can therefore understand what reporters must go through to produce their reports. Several companies have complained that the assurance teams they are sent are too young too inexperienced and too focused on the numbers, and not on what is really material. One need only look at the shared engagements, where companies have had to employ assurance teams from two different assurance providers (i.e., PwC + EY, KPMG + Deloitte and KPMG + Maplecroft) to note that companies are not able to get the value theyre looking for from one supplier. This is either a capacity issue, an independence issue, or an approach issue (i.e., companies want the audit rigor of the Big 4, but the value-adding opinion of someone like Maplecroft). The current challenge is therefore for companies to effectively discern who is best placed to provide assurance services that meet their needs, as well as those of their stakeholders. The default answer for many of the larger listed companies will continue to be the Big 4 for the following reasons: 1. Because of the relationship between the accounting firms and the audit committees who are tasked with appointing them (i.e., most audit committee members within larger companies are ex-Big 4 accountants);

2. Because they already seek an audit opinion over their financials from the Big 4; 3. Because the Big 4 firms come with automatic brand recognition locally and internationally; and, 4. Because the Big 4 firms have resources placed all over the world, thereby reducing the need to emit carbon via flights in order to measure carbon from operations. However, recent criticism over the role the Big 4 was perceived to have played in the economic meltdown has spilled over into the debate over who ought to provide sustainability assurance. There is a general assumption that the Big 4 are too intrinsically connected to their clients to be deemed independent, and therefore are not Chinese walls or not in a position to offer a meaningful assurance opinion. As was noted in last years research report, the fact that the Big 4 firms manage over 90% of the audits of the large listed companies, is a concern second only to the fact that the average large company rotates their auditors once in every 48 years (the USs Fortune 500 companies), which smacks of a lack of independence. By being the auditor of a company for any period longer than six years, the service providers independence tends to give way to familiarity, if not collegiality, which does little to offer anything close to meaningful assurance to external stakeholders. The auditor is, in most respects, checking their friends homework, which is far from an impartial opinion. Although no formal rules exist and/or apply at this stage, it is our own opinion at IRAS that companies ought to rotate their assurance provider after no longer than three to four years, or risk diminishing the value-add supplied by the assurance provider
28

Content-Based Assurance (CBA)

CBA refers to one of the simplest forms of assurance, whereby an assurance provider is expected to review the content of a sustainability report and provide an opinion over whether or not the report reasonably reflects the information expectations of the reporting entitys key stakeholders.

Assertion-Based Assurance (ABA)

ABA refers to a rather complex and time-consuming form of assurance, whereby an assurance provider is expected to dissect the content of a sustainability report into specific assertions (e.g., We respect all human rights) and to provide an opinion over whether or not each report assertion can be reasonably proved, either by evidence supplied within the report, or through additional information supplied by the reporting entity.

Indicator-Based Assurance (IBA)

IBA refers to the most common form of assurance sought by mining companies and others with high social and/or environmental risk levels. IBA requires an assurance provider to identify and select a set of high priority sustainability indicators, and to research the accuracy, consistency, completeness and reliability of the data reported relative to each of these indicators. The assurance provider

is expected to review the chain of evidence (i.e., systems and processes employed to collect, collate and report data) for each key indicator and provide an opinion over whether or not the indicator-specific data contained within the report is reliable. AccountAbility, in attempting to address concerns about the usefulness and quality of assurance engagements, launched its updated Assurance Standard (AA1000AS) in 2009, offering specific guidance regarding four specific types of assurance: Type 1 Moderate; Type 1 Reasonable; Type 2 Moderate; and, Type 2 Reasonable.

Uptake of AA1000AS in South Africa

Although its uptake has been relatively slow in South Africa, the application of AccountAbilitys AA1000AS assurance standard has started to grow in the last few years. Whereas only six reports were found to have been assured in accordance with AA1000AS in 2009, of which four reports were assured by our own team, this last years research identified 12 separate reports that had been assured using either AA1000AS (seven reports), or AA1000AS in combination with ISAE 3000 (five reports). We counted 16 AA1000AS assured reports this year, of which five were assured by the Big 4 using a combination of AA1000AS and ISAE 3000. In short, the key differences between AA1000S and ISAE 3000 are as follows: 1. Whereas ISAE 3000 restricts the assurance statement to negative language, including the oft-ridiculed double negative, AA1000AS expects the assurance provider to provide a clear discourse on the assurance providers findings, conclusions and recommendations. Rather than the statement being structured to protect the assurer, as in the case of ISAE 3000, the AA1000AS statement is structured to clearly explain what was done, what was found, and what the company ought to do in the future. In order for the assurance statement to be accepted by AccountAbility as having met their standards, the statement must undergo a 15-point compliance check, for such things as clear findings, recommendations and conclusions. 2. Whereas ISAE 3000 focuses on the quality of sampled data accuracy, completeness, consistency and reliability AA1000AS focuses on the processes behind reporting, including whether or not the company has clear inclusivity processes for defining who their most important stakeholders are (and engaging them), for defining materiality (and managing the most material issues), and responsiveness processes for communicating what the most significant stakeholders want to know about the most significant/material issues. In an AA1000AS Type II assurance engagement, the review of principles is coupled with the same sort of data testing as one would expect from an ISAE 3000 engagement, with the exception that the resultant statement must be phrased using positive language. In closing, it should be noted that any company seeking ITPA should consider investigating the merits of applying AA1000AS in their assurance engagement, regardless of who their assurance provider might be. Without AA1000AS its virtually impossible for stakeholders to understand whether or not the content of the report is appropriate relative to the reporting entitys most material issues, including the most material societal issues that may have a significant impact on the companys activities.
29

GREEN TALENT
SUSTAINABILITY CAREERS FOR ALTERNATIVE FUTURES

Type 1 Assurance (T1A)

T1A refers to a form of assurance similar to that of CBA, whereby an assurance provider is expected to review the content of a sustainability report and provide an opinion over whether or not the report reasonably reflects the information expectations of the reporting entitys key stakeholders. The assurance provider is expected to assess the degree to which the reporting entity has adhered to AccountAbilitys principles of Inclusivity (whether all of the reporting entitys key stakeholders have been engaged), Materiality (whether the reporting entity has identified and prioritised its more significant sustainability risks and/or opportunities) and Responsiveness (whether the reporting entity has adequately considered the material concerns of its key stakeholders and offered a reasonable discussion to meet their information expectations). The difference between Moderate and Reasonable assurance is the extent to which the assurance provider has tested the sustainability reporting systems and processes to provide an opinion. Most notably, Reasonable assurance would require that stakeholders be actively engaged as part of the assurance process to test the validity of the reporting entitys claims around the three reporting principles: inclusivity, materiality and responsiveness.

Its ab o the peo ut ple!

HUMAN CAPITAL NEEDED

The reality of creating sustainable futures is becoming a main stream focus and as a result the green economy is gaining traction.

Human or social capital is fast becoming the foundation of sustainable businesses.

Green Talent was established in 2011 to respond to the growing need for sustainability professionals in the green economy. Our role is to facilitate the development of a skilled workforce that is ready to meet the demands of the emerging green/low carbon economy in Africa. We do this through our Sustainability Career Centre that provides a voice for industry leaders, professionals and course providers to communicate sustainability skills, vacancy offerings, education and training opportunities.

Type 2 Assurance (T2A)

T2A refers to a much more comprehensive form of assurance, similar to that of IBA, whereby an assurance provider is expected to meet the assurance expectations of T1A, and to test the accuracy, consistency, completeness and reliability of data reported relative to a selection of significant sustainability indicators. As with IBA, the assurance provider is expected to review the chain of evidence (i.e., systems and processes employed to collect, collate and report data) for each key indicator and provide an opinion over whether or not the indicator specific data contained within the report is reliable. The difference between Moderate and Reasonable T2A is the extent to which data is tested. Rather than testing a small sample of data for Moderate assurance, the assurance provider must test enough of the available data in order to provide an opinion over whether or not the reported data is accurate, consistent, complete and reliable.

CONTACT US
Cell +27 (0)72 797 1299 elize@greentalent.co.za www.greentalent.co.za

Drive sustainability performance forward in your business

credit360 is a specialist provider of sustainability software. That means you can rely on us to manage your sustainability data and help take your company where you want to be. Its no wonder our customers consistently win awards for their sustainability reporting and we continue to win awards as a supplier in our industry. Whatever sustainability means to your organisation, from carbon reporting to donations tracking, our system provides an efficient, integrated and transparent way to gather and manage data. We help you collect information, analyse and interpret it, and then communicate it to all your different stakeholders.

Over 100 leading companies like Bidvest, Barclays, Philips and Staples use our solutions to manage their sustainability data. Find out more about what we do, how we do it and who were already doing it for, visit

www.credit360.com

mid blue teal grey blue

compliance supply chain

10 TIPS to Achieve Excellence in energy Integrated Sustainability Reporting

csr

10 TIps to Achieve Excellence in Integrated Sustainability Reporting

NOTE

This section has been updated from last years research report. Some 10 tips have been labelled NEW, while others have been labelled UPDATED for obvious reasons.

While an Annual Report almost exclusively focuses on financial performance, with little more than a set of statutory annual financial statements, and an introduction to the company and its governance, an Integrated Annual Report seeks to provide a summary of the companys non-financial performance (remembering that theres no such thing as non-financial in business). Whereas an Annual Report is a review of the companys historical performance, an Integrated Annual Report is expected to give an indication of where the company is headed, and how it plans to get there (i.e., forward looking versus the rear view mirror approach). Whereas an Annual Report avoids almost at all costs making predictions about future performance and/or the setting of targets, target-setting is a fundamental expectation of an Integrated Annual Report, as is the need to report back on previously stated targets (i.e., setting the bar and reporting upon commitments). Ultimately, an effective report is the one that clearly defines a companys Most Material Issues (MMIs), explains how those MMIs were identified (i.e., the materiality process), provides a simple, meaningful and comparable discussion about the companys ability to manage these issues, and then offers an equally meaningful discussion about how the company plans to manage the issues moving forward. A report should not take the form of what we all came to expect from an Annual Report, which is all but irrelevant by the time the report is produced. Rather, an effective integrated annual report should offer a comprehensive discourse around what a company does, what it plans to do, and how it plans to do what it intends to do: including how it intends to monitor and manage its MMIs. One should not assume that MMIs must be limited to risks, but rather all issues that might have a significant impact on the companys short and long-term success. These could be risks, but almost always include opportunities. They will most certainly be things that have an impact on the company, be it positive or negative, and they may very well be ways in which the company has an impact on others (e.g., the communities in which it operates, the physical/natural environment, etc.). In writing a sustainability report, one must remember what may very well be the cardinal rule of integrated sustainability reporting:
32

The value is in the process not the report!

The Integrated Annual Report should not be the objective, but rather a document that seeks to explain performance against objectives. It should be a milestone within a cyclical process of introspection and process improvement, and should be a well-scribed summary of the companys ability to meet its objectives during the reporting period. It should be somewhat of a regurgitation of outcomes of key discussions the company has had with its most significant stakeholders over the reporting period, including a free and frank discourse about how engaging stakeholders has led to policy, procedures and/or strategic change. It should be an effective summary of the direction the company is taking in the future, and how it plans to get there. In developing an effective sustainability report, one should at least consider the following unsolicited advice

Having played in the sustainability reporting and assurance space, in one way or another, for the better part of the past 13 years, I Michael H. Rea, the primary author of this report have come to believe that I might know a thing or two about what should be reasonably expected from a sustainability report (or the sustainability content within an Integrated Annual Report). However, the closer I feel Im getting to having the answers, the closer I may only be to having some of the questions. Nonetheless, I have revisited the list of 10 tips included in the past two versions of this research report, and have updated them to reflect discussions Ive had with my team and our clients over the past year. Some of my preferred tips are predicated on historical and/or current reporting principles, particularly as set out by the GRI and AccountAbility, but others stem from the discussions and debates Ive been privy to over the past few years. Others have come from the frustration that arises having to endure the painful challenge of evaluating reports that should never have been published. In fact, I often sum up my advice to companies with the following ten suggestions: 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. Introduce yourself! Explain your materiality process! Integrate does not necessarily mean combine! Let the data tell the story! Ask and answer the So what? question! Tick the boxes later! An A is not necessarily better than a C! Neutrality works! Seek meaningful assurance! If youre gonna link it, do it right!

1 Introduce yourself! *NEW Until such time as the GRI publishes the next version of its Guidelines the G4, expected to be launched at next years GRI Conference (May 2013) I will continue to point out that the single-most useless GRI indicator is:
2.1 Name of the Organisation Granted, it is understood that this is required in the context of idiot-proofing the Guidelines for those companies that are registered under one name, yet trading under another, but its safe to assume that a company would find it difficult to produce a report without at least once mentioning its name. Nonetheless, it is not safe to assume that companies will remember to explain who they are and/or what they do. Far too often, companies waffle on about what great work they are doing, why everyone else is to blame for its shortcomings, and how they intend to be the next Apple in the post-Jobsian era, but fail to explain what they actually do in a clear and concise manner. In many cases, its difficult to understand what industry sector they actually fall under and/or whether they make anything, or simply invest in companies that do so. As a result, it can be extremely difficult to assess whether or not a company is a going concern as a result of mere dumb luck, or if there is a clear strategy that is being managed in an effective and controlled manner. For a report to be truly effective, the introduction to the report should offer a clear understanding of what they do, where they do it, as well as what their core products and services are.

Perhaps its important to first offer a simplistic overview of the main differences between Annual Reports and Integrated Annual Reports. These include:

2 Explain your materiality process! *NEW

(For those companies errantly seeking to generate an Integrated Annual Report that scores a high near-useless GRI Compliance Score such as those we disclose within this research report, heres the only piece of advice youre likely interested in) As per the GRIs Guidelines, a reasonable response to any of the 127 indicators can be as simple as stating usually within a comprehensive GRI Index Table the following:

Heres the challenge of materiality: talk to everyonelisten to those who have a valid pointand determine whats material not only on what the Board talks about, but also on what the world in which the company operates in talks about. Do not assume that the Board understands the risks and/or opportunities linked to a global shift to a low carbon economy. Rather, use the reporting process inclusive of effective stakeholder engagement as a mechanism for informing the Board about what ought to be considered material.

Based on our materiality assessment, this indicator has been deemed not material and therefore we do not report on it. (or something to that effect).
The trick here is that you must first define your materiality process, which requires explaining how the company arrives at a series of indicators and/or issues that are important for the company to discuss within its reports. In most cases, this tends to occur as a function of the Risk and/or Audit Committees establishment of a Risk Register, but this does not necessarily mean that this is adequate. Rather, for the company to come up with a truly comprehensive list of most material issues, there must be some mechanism for stakeholder commentary and/or concern to influence the companys understanding of what isor is not material, and thus what should be discussed within its reports. In a recent JSE gathering of what was called the Big 4 (i.e., Deloitte, EY, KPMG, PwC and Grant Thorntonthe ), a member of the audience asked the oft-posed question of How does one know what is material?, to which the representative of Deloitte asserted (albeit paraphrased), If its not something the Board is talking about, then its not material. Interesting! This presupposes that the Board is made up of people who actually pay attention to the world around them and/or that anyone actually listens to the Board. It assumes that the Board understands that business has changed and/or that the world of business isnt as insulated from social unrest as it might once have been. It also assumes that the Board has joined the information age, let alone a world quickly becoming dominated by the rapid fire impacts of social media. Consider Brait, the investment company that was chaired by Mervyn King affectionately referred to (at least by me) as the King of King (not to be confused with the King of Kings) and the company that not only failed to get onto the first King-based JSE SRI Index for failure to interpret King effectively, but that also continues to produce an Annual Report that is not aligned to the GRI Guidelines and/or King III. How is it that Brait could have been chaired by King who recently stepped down from his chairmanship of the GRI, and who now chairs the International Integrated Reporting Committee (IIRC) without listening to the advice he sells to everyone else willing to attend an over-priced SAICA event?

3 Integrate does not necessarily mean combine! *UPDATED

As was discussed in greater detail in last years version of this research report, there is a fundamental difference between integrated reporting and the integrated report. The former is the process by which companies ensure that sustainability is woven into the fabric of the business, from vision, mission and values all the way through to strategy and operational tactics. The latter is the document that is produced at the end of the financial period to update stakeholders on not only the historical performance of the organisation, but also the outlook and performance targets for the near, mid and long-term future of the company. An integrated report is to be written in a manner that will be able to clearly demonstrate how environmental, social and governance matters are managed within the organisation, including, for example: What information is managed under the watchful eye of the Board and/or its committees? What formalised policies, procedures and systems are deployed to monitor and measure progress against key performance indicators? What assurance procedures are in place to test controls over the companys most material issueshow often, by whom (i.e., internal or external assurance providers), and under the watchful eye of what Board/Committee/Executive function? What stakeholders are engaged, for what reason, how frequently, in what format, and what has resulted from that engagement (i.e., has stakeholder engagement had an impact on the strategies and/or tactics of the business)? An integrated report does not, however, need to be weighed down by reams of statutory financial statements that many stakeholders cannot interpret, nor does it need to include an endless photo-laden rant about the self-proclaimed effectiveness of community development projects (i.e., the poverty pornography I love to talk about). Thus, the authors of an integrated report should not attempt to produce a 400-page report that combines the statutory financial statements and the comprehensive sustainability report, but should shoot for a 60 to 80 page summary report. Sasols most recent report, as well as those of the likes of Altron, Vodacom and Massmart are strong examples of reports that have been whittled down from the door stops of old, to become much more
33

SUSTAINABLE SOLUTIONS FOR SUSTAINABLE COMPANIES

Audit Advisory Tax Sustainable development creates value for customers, investors and the environment.
Our clients respect us for our specialist sustainability skills. Skills that help them build credibility and establish trust with stakeholders. Through our dedicated sustainability services team, we provide independent, third party assurance on the performance of a companys sustainability strategy. We assess business processes systems and controls in place relating to sustainability objectives, stakeholder engagement, information gathering and reporting, and best practice benchmarking. We then recommend areas for improvement. Independent third party assurance of your sustainability report provides the added comfort your stakeholders, investors and members of the public need to make up their minds about your business practices and commitment to not only the communities within which you work, but the world as a whole.

Sustainable communities need sustainable businesses.

Contact Ursula van Eck on +27 10 060 5068 today to see how we can help you.

www.bdo.co.za

| 10 Tips to Achieve Excellence in Integrated Sustainability Reporting continued

manageable summary reports, with comprehensive supporting documentation available in other reports and/or on the web. A well-written and effectively designed report offers stakeholders a meaningful interpretation of the companys financial performance in the context of how well environmental, social and governance matters are managed in concert. Sources of data; Weaknesses in the data collection, collation and/or reporting processes (where applicable); Re-statements of previously reported data, where errors might have been identified; Identification of trends and anomalies within the data, as well as their root causes; and, Any future changes to data systems or processes. Reasonability testing of data should support graphs, wherever possible, and include an explanation of why a specific anomaly might have occurred. For example, a spike in water consumption ought to be contextualised relative to production figures, in that it might make sense for a significant spike in water consumption IF there was a significant spike in total production (assuming that production is directly correlated to water consumption). If this anomaly cannot be deemed reasonable, an explanation of what led to the spike should be offered and/or a commitment to rectifying whatever latent problems may yet exist. A statement that water consumption per unit of production should always be explained in terms of whether the company has invested in water recycling systems, implemented less waterdependent production methods, or identified a prior leak that was
NOTE

4 Let the data tell the story! *UPDATED

If youre attempting to write an Integrated Annual Report and are not a numbers geek, you have three choices: become one, find one in your company, or rent one! Truth is, an excellent author can twist words to tell any story, but not always the right story, whereas a numbers geek may not be as eloquent, but their numbers will always tell the truth! For years, I have witnessed numerous reports getting to the final stages of a misguided production process, when the data tables are finally ready to be plotted within an otherwise complete report. Graphs are generated and inserted, yet no link is made between the data and the text, often resulting in paragraphs that tell a wonderful story about how the company has for example invested heavily in improving the overall health and safety of workers, while an accompanying graph shows a sharp increase in work-related injuries. As much as I might argue that accountants are not necessarily the best people to measure sustainability, I have to admit that my own training was largely influenced by seven years of earning and learning at PwC and KPMG. Thus, it would be disingenuous of me not to publicly assert that accountants taught me that numbers tell stories, and that effective data management is critical to business success. Unfortunately, this has only recently extended beyond financial data, and into the realm of social and environmental performance reporting (for all but the handful of South African companies that have been measuring non-financial performance for several yearssuch as Anglo American Platinum and Sasol). Typically, sustainability report authors begin the reporting process long before they have usable performance data to work with. They make assumptions about performance, and then hope to weave year-end data into the stories they have attempted to tell. In many cases this results in either a complete absence of data, or an unmistakable disconnect between the data reported and the discourse around the issue. Ultimately, a report should provide a combination of current data (i.e., performance data from the reporting period), historical or trend data (e.g., 3 to 5-year history of performance data for the specific indicator), benchmark or comparable data (i.e., data from other companies, preferably industry or sector peers), and a meaningful projection of future trends. Once the data has been presented, the author should then offer a clear, concise and intelligent analysis of the data, interpreting trends and anomalies, and explaining the following:

This is not necessarily a concern that is limited to quantitative data and/or assertions. In many cases, the report is written almost exclusively for a well-informed shareholder (or worse, the Board), which can leave the reader guessing about what the strategy and/or business objectives of the company are thus failing to offer any contextualisation for performance assertions.

5 Ask and answer the So what? question! *UPDATED

A common weakness in sustainability reports or the sustainability sections within integrated annual reports is that authors do not appear to apply their minds to predicting the readers ability to interpret information, or to predicting how a readers interpretation might lead to different conclusions than intended. As such, one must consider that it is the role of the author to predict, and then answer, any possible questions raised by information presented within the report. Assume nothing explain everything! In some cases, readers are left hanging on data that is neither explained, nor contextualised. It is assumed that the reader can interpret the data and come to a reasonable conclusion about the point the author intends to make, or to assume what has led to a specific trend or anomaly within data. On the one hand, this may suggest that the author does not necessarily understand the data, but the bigger concern is that readers are left to define their own errant conclusions. Thus, it is critically important for any assertion, be it a set of data or a worded statement, to be fully explained in the context of So what? For example, when providing water consumption data (i.e., the total volume of water consumed), its important to ensure that year-on-year trend data is supplied, preferably a three-year minimum, that trends and/or anomalies are explained, and that the consumption is contextualised in terms of either a unit of production or head count. A volume in and of itself does not indicate whether the company is an efficient consumer of water. Until the volume is compared against a unit of production (e.g., litres per unit of production), and a year-on-year trend can be displayed, the indicator does little to explain the companys sustainability performance. Moreover, the consumption should be explained by asking and answering the So what? question.
34

wasting massive volumes of water for an unknown period of time. Furthermore, the reduction in water consumption should be taken to its logical end, ultimately stating how this might impact on the current and/or future financial performance of the company, such as whether an investment in low-flow technologies will protect the company against forecasted hikes in the cost of water.

6 Tick the boxes later! *UPDATED

Although some might argue that there have been many, the first problem that GRI Guidelines created was the fact that companies have frequently fallen into a compliance trap. They believe that in order to apply the GRI Guidelines, the company must be able to tick as many of the boxes as possible, and if not, they must avoid producing a report that mentions adoption and/or application of the Guidelines. What they have overlooked is the principle of materiality. One must remember that the GRI has not produced a prescriptive text that is applicable in its entirety to ALL reporting entities. Rather, the Guidelines are a reasonable set of indicators that can be applied in part, or in whole, to companies, NGOs, public institutions and anyone else seeking to produce a comparable sustainability report. Within the guidance around the Guidelines, the GRI has provided clear instructions about ensuring that the reporting entity determines the subject matter that is most material to the organisation, and to produce a report that focuses almost exclusively on only those issues. In fact, the GRIs guidance indicates that when companies attempt to produce a sustainability report that meets their Application Level A requirements, the reporter should be mindful of the need to adhere to the materiality principle. Thus, a response of not material to our company is a reasonable response to an indicator (as long as the reporting entity can clearly define their processes for determining materiality, and therefore justify the not material assertion).

NOTE

NOTE

I am well aware of the fact that this research report, now in its 4th edition, has led to the misguided assumption that a high GRI compliance score is indicative of a good report. This is not true! As Ive tried to state in each years research report, there is no guaranteed positive correlation between a high GRI compliance score and effective reporting. Rather, it is a complete red herring! An effective report is measured not by the number of indicator boxes ticked, but rather by how well the GRI Guidelines are applied, in accordance with the principles of materiality and neutrality.

Our research this year more than in the past has noted that many companies have shot up the rankings in our GRI Compliance Score table merely as a result of producing a comprehensive GRI Content Index Table, inclusive of a number of meaningless attempts at offer a response, rather than a meaningful response. In some cases this is as blatant as a supplemental sustainability report that is little more than the blanking out of the GRI Gap Analysis template we gave them last year, now populated with poorly crafted responses to numerous indicators. Brilliant!

In some cases, companies have taken the notion of GRI-based reporting far too literally, and have merely produced a report that offers a response to as many of the GRIs G3 indicators, without an attempt to either contextualise the information, or to make the report readable. These reports do little to provide an understanding of the companys sustainability performance and/or outlook, and almost always suggest that the company is not serious about sustainability matters. Although some might (and many do) argue that the GRI G3 guidelines are not entirely applicable and/or appropriate, the GRI is nonetheless THE benchmark standard for reporting. Thus, a report should contain clear and detailed Disclosures on Management Approach, and responses to all G3 indicators, even if only to indicate that they are not material to the company. Where deemed not material its critical to explain why not. For those companies that have not yet produced a GRI-based report, I wonder out loud: Why not? The GRI Guidelines have as reported by the interviewees in the Why Bother? section of this report become the benchmark standard for sustainability reporting, and offer opportunities for meaningful comparability. They are recommended albeit not necessarily applied by King, and while they may not yet be nearing perfection, do offer a useful framework for effective reporting.

of the Guidelines appear to be set to tackle the oft-misguided assumption that companies should all seek to get an A. As ex-students, weve all been habituated into believing that in the presence of a C, B and an A, the best of the three must be the A. Thus, companies far too frequently race towards an A with little regard for ensuring that a meaningful discourse can be provided on each of the performance indicators. In the context of
NOTE

In order to be GRI compliant, a report MUST be supported by a GRI Content Index (as per Indicator 3.12). The GRI differentiates between reports that apply the Guidelines and those that are GRI compliant. Thus, the indicator table MUST be supplied, either within the report, or as a downloadable appendix on the companys website (or available upon request by email).

sustainability reporting, an A only means that the report has answered more of the GRIs indicators than C-level or B-level reports. Perhaps it would be helpful if I reminded everyone that under the watchful eye of our current government, a Malema-inspired interpretation of basic math has somehow resulted in a pass occurring at the paltry sum of 30%, thus suggesting that anyone who can get to 50% is somewhat of a genius! In that context, it may be useful to point out that in the context of the GRI Guidelines, a company can be GRI-complaint if they have a GRI Compliance Score of only 25.3%. Thus, there should be no reason for any company not to be GRI-compliant (not even Brait).

7 An A is not necessarily better than a C! *UPDATED

The second most commonly criticised problem that the GRI Guidelines created is the race to an A, under the assumption that an A is fundamentally better than a C.

Good news
The GRI appears to be getting rid of the A, B or C system of classifying reports. Although theyre not yet finalised, the G4 version
35

| 10 Tips to Achieve Excellence in Integrated Sustainability Reporting continued

8 Neutrality works! *UPDATED The principle of neutrality was first floated by the GRI in its pre-G3 reporting principles, and was a cornerstone element of successful sustainability reporting in the early years. In essence, neutrality is all about balance. Its about ensuring that a report is not produced in a manner that attempts to green wash environmental performance, or avoids occupational health and safety matters that paint the company as unsafe. It is about telling the whole story: warts and all.
Most companies still tend to follow a PR approach to reporting; failing to recognise the importance of explaining what might have gone wrong during the reporting period, and what is being done to rectify it. However, companies with more mature reporting processes now understand that while it is important to explain what you do right, this should not be the full extent of an effective report. Rather, it is far more important to inform stakeholders of the on-going challenges the company faces, as well as the companys ability to address those challenges. Neutrality requires companies to be truly open and transparent, and to offer stakeholders an opportunity to effectively gauge their performance: not just to applaud the company for what its doing well, or right. However, this often presents a risk in and of itself, particularly at senior levels within companies. While report authors are often quick to adhere to the principle, senior executives tend to be quick to wield the red pen, ultimately erasing most discussions that offer balance. Thus, the challenge is for authors to write the good news in a manner that does not appear overly self-congratulatory, while offering the bad news in a manner that protects the companys reputation and/or brand image. Companies must not be afraid to say We dont know! and should never make statements to the effect that We are perfect! Companies are fallible. They make mistakes, and they are unlikely to be able to police all people at all times without some lapses occurring. The question is not why arent you perfect?, but rather what are you doing to try to be perfect? No right-minded stakeholder would expect a company to operate in the absence of error. Thus, companies must be willing to make over-arching policy statements, but then conclude that either performance data is not yet available, or that policies do not always root out human error. The alternative is to create an expectation of perfection, only to fall flat on ones face when a stakeholder identifies a problem. I truly believe that transparency and accountability are not to be hauled out only when it suits the picture a company attempts to paint. They are principles that ought to be applied consistently and without exception. They do not negate the probability of imperfection and error, but rather support the quest for goodwill among stakeholders.

9 Seek meaningful assurance! *UPDATED As this years evidence shows, assurance is quickly becoming a must have rather than a nice to have. Its a recommendation within King III, and has been adopted not only by 52 of the 128 GRI-based reporting entities reviewed in our research, but has become the playing field for a rapidly expanding number of assurance providers. In the past year, the market has been penetrated by a few of the Tier 2 auditing firms (BDO, Grant Thornton and PKF), as well as by a number of smaller, more niche-based entities (e.g., IRAS). Even Theo Botha, South Africas all-but-sole shareholder activist, has started up an assurance practice (CA-G Assurance), as has Empowerdex, SAs leading BEE verification company (Assuredex). However, with 11 assurance providers now offering services to reporters with the likes of some of the Big 4 accountancies losing ground to new market entrants the question of standards and quality assurance is becoming far more poignant.
The challenge is for companies to seek not only assurance or an audit-like opinion over their sustainability report, but valueadding assurance. Companies should gain an understanding of what an assurance provider ought to be doing as part of the assurance process, and should be questioning whether or not the assurance adds value to the reporting process, or adds a level of comfort for stakeholders reading the report about whether or not the content of the report is fair, factual, reasonably complete, neutral, and comparable. At present, there are only a handful of reasonably experienced assurance providers in South Africa, of which the vast majority will not necessarily have adequate industry and/or assurance-related experience to conduct Type II assurance engagements, as per AccountAbilitys AA1000AS recommendations. Thus, any company seeking assurance will need to understand the differences between the primary assurance standards ISAE 3000 and AA1000AS and what assurance options should be available to them. I sincerely hope that the rise of new assurance providers encourages companies to take the time to understand that they do not need to hire expensive consultants to offer assurance, but rather could seek an independent opinion from as diverse a set of stakeholders as academics, activist groups (e.g., the Northwest Eco Forum, or the World Wildlife Fund), or to put assurance engagements out to public tender to gain a better understanding of what value assurance might actually offer. Of course, this is only possible if both parties know what they are seeking from an assurance engagement, and if both parties are sufficiently schooled in assurance methodologies. For assurance to be truly meaningful, companies ought to avoid a process that simply attempts to tick a series of Did you do this? boxes. Rather, the assurance should test for compliance to principles such as AccountAbilitys Inclusivity, Materiality and Responsiveness, to assess reporting systems and outcomes, and ultimately test for data accuracy, consistency, completeness and
36

reliability. Ask any company that has sought a Type II assurance opinion over their report, and Im confident they would assert that the process added value to much more than merely the report, but to the overall success of the business.

10 If youre gonna link it, do it right! *NEW Perhaps this is the first time my research report has fallen into your hands (or the first time youve actually opted to read it), so Ill once again repeat my dissatisfaction with inane statements such as We opted to be environmentally responsible. What a load of bio digestible crap! Not printing a report at least not a few hundred copies that can be highly targeted in their distribution is little more than a cheap excuse for getting someone else to pay the cost of printing,
Granted, the iPad, Kindle and other e-readers are taking over some of the publication market, but e-readers are not great for report review (at least not yet), and have not yet pushed the printed word off the shelves. Not unlike many others in my generation, I prefer to read reports that I can hold in my hands. I want to scribble notes on the pages, and to dog-ear pages that offer important bits of info. Thus, I continue to encourage all companies that cant afford to print a hard copy report to accept that if your business is going to collapse because of a few printed reports, you ought to start seeking new employment without delay! Nonetheless, Im not a complete Australopithecine, and I can walk upright without scraping my knucklesat least to the point of being able to navigate my way around a website or two. However, I might be more willing to read online reports if companies were getting it right. During a review of GRI-based reports for UK companies, I was stunned by how easy some companies have made it for readers to navigate through their online reports. GRI Content Index tables are hyper-linked to precisely the spot the reader wants to go (for any given indicator). Assurance statements are hyperlinked not only from the body of the main report to the statement, but also from an assertion within the statement back to the relevant section within the report (e.g., if diesel consumption was assured, the mention of diesel in the assurance statement was hyper-linked back to the diesel stats page in the online report). At present, and with some notable exceptions (yet again, Sasol) the online versions of South African reports are little more than the .pdf version of a printable report being uploaded, page-bypage, onto the companys website (rather than a meaningful and user-friendly HTML version). Altron has cleverly adapted their report for iPad use (downloadable as an app), and have created a comprehensive multi-media report linking videos to relevant sections. Inasmuch as Id still appreciate getting a hard copy of a report, I might be encouraged to spare a tree or two if companies could use the services of design houses who know how to create reports that can be printed, or viewed in a searchable online format. However, this would require companies ensuring that links work!

Our Personal Favourites

Combing through quite literally hundreds of annual, integrated annual, sustainability and/or sustainable development reports is a daunting task, made all the more mundane by the countless reports representing the have nots in our reporting society. Despite the 13 year history of GRI-based reporting (12 years in South Africa), the vast majority of companies (65%) still havent awoken to the possibilities entrenched in the adoption of a set of reporting guidelines geared to improving overall sustainability performance (i.e., not just the reporting side of things). Thus, its always a pleasure to identify the handful of reports that stand out amongst the crowd, ultimately setting benchmarks for others to follow.
Inasmuch as the following pages are NOT an award, it is a pleasure to read company reports that identify our research as a form of recognition. However, one must be careful to note that inclusion in our ranking is not by any means intended as said recognition. In fact, we have been clear in our repeated assertion that our ranking system is a complete red herring, in that a report can be excellent regardless of whether or not its authors have ticked the vast majority of the GRIs boxes. Should anyone wish to cite this research report as another form of Reporting Award vis--vis the awards issued by Ernst & Young and/or the ACCA then it must be noted that only the following eight reports can be perceived as indicators of excellence in reporting. Over the past three years weve been clear that a GRI compliance score approaching 100% should NEVER be viewed as a demonstration of excellence in reporting, but rather a demonstration of the perceived relevance of the GRI Guidelines by a specific reporting entity. In fact, one must be cautious in noting that both Impahla Clothing and Little Eden rank within the top 20, based on GRI compliance. Some of the reports that score high in our monitoring scale are ultimately rubbish, in that they do little to provide a meaningful discussion of their ability to monitor and/or manage their most material risks, opportunities and/or impacts. Similarly, some companies that are yet to apply the GRI Guidelines, or that opt not to apply the guidelines, produce reports that provide excellent coverage of their Most Material Issues, and generally offer an excellent overview of their sustainability performance and outlook. Granted, Sasols 2011 report, complete with its online supporting documentation, is by far one of the most useful examples of reporting excellence, but their near 100% compliance score is not proof that the GRI Guidelines lead to excellence in reporting. As we noted last year, Sasols adoption of the Guidelines as with other leading companies should be viewed as evidence that the Guidelines ought to be considered relevant and useful to reporting entities of all shapes and sizes, and therefore should not be overlooked by anyone seeking to produce a meaningful sustainability (or integrated annual) report. That having been said, our team of dedicated researchers are in a unique position to offer a form of recognition that is uncommon within any of the awards process were aware of. The team reviewed through more than 400 integrated annual, annual and/or sustainability reports often embarking on seemingly endless quests to find referenced online supporting information to assess the levels of GRI compliance of each and every reporting entity in South Africa. In doing so, the team has identified the reports they believe to be THE most useful examples of successful reporting procedures, inasmuch as theyve been able to identify pitfalls that all reporters should ultimately seek to avoid. As such, the team has selected the reports that they believe represent excellence, and have offered their own comments regarding the strengths and weaknesses of their personal favourites. The following is our research teams explanation of why they chose each of their top reports.
Authors Note: As always, Ive recused myself from the our personal favourites process, opting not to pick my own favourites, due to my level of engagement with a number of reporters. Of course, readers are encouraged to go to our website (www.iras.co.za) to download copies of the latest versions of the reports I have written or assured. 37

Purple Frog Communications specialise in design and production for print, web design and all areas of creative consultancy and development. We provide a full service, taking your project from initial concept right through to completion. Our core offering includes:

integrated annual reports, sustainability reports, financial advertising,

web design, corporate identity and branding, corporate brochures, magazine adverts, newsletters, signage, billboards, banners, exhibition stands and corporate gifts.

Email: info@purplefrog.co.za Telephone: (011) 462 7242 www.purplefrog.co.za

conceptualise

actualise

realise

| Our Personal Favourites continued

Anglo American Plc
Anglo American Plc has a vast number of operations reaching to all corners of the globe. This could make reporting very difficult, yet their Sustainable Development Report is so eloquent that a huge volume of information has been made completely digestible. Right at the start the reader gets a full summary of the operations (mine locations, use of the minerals mined, number of people involved and profit generated), a fantastic base to anchor the rest of the report. Throughout the report the sections are clear and organised and data is usefully summarised at the end. Despite the size of operations, the report manages to remain concise; an important trait in a world where people have less time to do more work.

Lonmin Plc
Lonmin are clear leaders in reporting, having produced sustainability reports for the last 13 years. This is evidenced by their very thorough and well laid out Sustainable Development Report for 2011. The report is clear, simple and easy to read as well as being so thorough that very little is left unanswered. Having said this, the report does not solely (and soullessly) follow the GRI guidelines. There are more initiatives that the group engages with than just those required by the GRI. This shows the group is both fully involved with, and openly reporting on, matters that are material to themselves rather than just ticking the required boxes.

Julias #1
Sustainability issues are addressed throughout the report and both the Chairman and the Chief Executive discuss material sustainability issues. The graphs and data summaries on the outside edges of pages ensure that data facts stand out and make the report more immediately interesting. The summary of data at the end of the report is a very useful reference for when a reader is quickly looking for figures. The lifecycle of a mine is described upfront, making readers aware of the processes and impacts involved with mining and how the group approaches these. That the report is printed on environmentally conscious paper shows that sustainability is important to the group at many levels. The maps present locations clearly. All too often maps are either absent, or are not clearly presented. The photographs give a good visual description of what operations involve and add a personal touch. The captions usefully highlight their relevance to the group. The report is clearly laid out with good spacing and headings and is therefore attractive and accessible to readers. The report is clearly written with good simple English, so it is easily understandable. The definitions of indicators at the end of the report describe explicitly how calculations were done. The numerous footnotes to graphs and tables clarify points so the report can be completely understood. The stakeholder section could be more thorough and include the topics raised by each stakeholder and how the group has responded to each of these. Operations are large and it is sometimes difficult to collate data from such dispersed subsidiaries. Although efforts have been started to collect and bring data together, care should be taken that all data is presented for all operations in all countries. The habitats surrounding operations and how they are impacted should be more fully described. Data on employees and employee turnover should be clearly divided by type, diversity, gender and region. There were some cases where attaching values to graphs would add to their usefulness. For example the water, energy and emissions graphs could either have the 2011 values included, or a reference to where the actual values are stated at the back of the report.

Julias #2
The operations of the group including locations and subsidiaries involved are all described succinctly right at the start. The report is well designed with good clear headings, useful summaries in bullet points at the start of sections, all making for an easily digestible report. Major headings are repeated at the top of pages so the reader knows where in the report they are. The graphs are simple; axes and legends are labelled and headings explain what the graph is about. The GRI indicators that are discussed in a section are listed at the end of that section, making for easy referencing. It is a pleasure to know the activities and locations of the group and its subsidiaries within the first two pages. This sets the scene for the rest of the report. It is surprising how often companies do not describe their business upfront. The photographs give the reader a good sense of what the operations involve and add a personal touch. Importantly, they have captions, which adds significantly to their relevance and interest. Contact details for someone specifically involved with the report, including an email address and phone number, are given on the very first page. Referencing in the GRI table is not always correct. The scope and boundary of the report (Our Approach to Sustainability Reporting) could be closer to the start of the report, perhaps before the CEOs statement, rather than on page 11. The most senior decision maker in the organisation is the Chairman. GRI indicator 1.1 commonly references a review done by someone other than the Chairman, which is incorrect according to the guidelines. Even though the Sustainable Development Report (SDR) should be read in conjunction with the Annual Report and Accounts, a summarised Chairmans letter could be included in the SDR. A map would add significantly to the first two pages where the operations are outlined. URLs should be written out underneath links (this was a web-based report) for readers who have printed versions.

O O O O O O

O O O O O

38

Illovo Sugar
Having to plough through hundreds of reports annually it is always refreshing to come across a report that is easy to read, tells a story and leaves me feeling more educated about an aspect of business or production in South Africa. The Illovo report was one such report. I now have a thorough understanding of the South African sugar industry, the macroeconomic forces that influence it, the agricultural practices involved, the vulnerability to climate change and the opportunities for expansion into renewable fuels. The report is both visually stimulating and factually informative. The layout makes it easily navigable and appealing to all potential readers.

Grindrod
As a transportation company with various divisions operating across the globe, Grindrod has compiled a clear and cohesive report, which successfully integrates all aspects of economic, social and environmental performance and aligns these to their strategy. From the very start of the report the reader is informed of who the company is, what they do and what they stand for thus making it accessible to any stakeholder or interested party. I believe that a well-structured report implies that the organisation is also well run and thus is a powerful tool for communicating the brand and ethos of an organisation to external stakeholders. Grindrod is one of my favorite reports as it is excellently compiled, clearly separates different divisions (whilst including consistent data for each) and tells the story of who the company is.

Laurens #1
The Illovo report is a comprehensive report that is easily read and understandable by stakeholders; from both a design and content perspective it is excellent. A clear Scope of report section on the inside front cover immediately lets readers know what to expect in the report and why certain aspects have or have not been included. Key features such as cane production, sugar production and revenue are provided on page one immediately giving the reader an overview of the successes and drawbacks of the reporting period. These are presented with up and down arrows and percentages, which makes performance obvious. A double page spread on strategic and operational accountability clearly summarises the business profile of each country of operation and outlines aspects such as their objectives and performance providing the reader with a clear overview of operations. Illovos diagrammatic cane sugar sustainability model makes the operations understandable to all readers of the report, and thus makes the report more meaningful. The group risk management committee is accountable for sustainability and there is a clear description of how this is managed at a board level, thus reinforcing their assertion that sustainability and integrated reporting is a core element of their business. The key risk matrix provides a transparent account of the risks to the business and links to material issues. Clearly presented and informative. Reporting on climate change risks and opportunities is presented in a way that is both relevant and informative. The discussion surrounding the value added statement is clear and explains the content of the statement in a useful manner, however CSI should be included. A fold-out index on the inside front cover is a good design element as it is useful as a page marker and makes the report immediately easily navigable. The report has two scopes, which is unnecessary and creates repetition throughout the report. It conveys the impression that sustainability is not fully integrated. Remember that integrated does not mean combined. As the report is built upon over the years, one could hope to see an improvement in comparability of data. A suggestion for companies starting reporting with little year on year comparable data is to include external comparability by linking your stats to those of other companies within your industry locally and/or internationally (i.e., whos the best in the world in the agricultural sector, per indicator, and where does Illovo sit relative to their benchmark?). Reporting on stakeholder engagement can be improved by including more detail on the frequency of interactions and the issues raised by stakeholders. Sweeping generalisations are included throughout the report without substantiating the assertions made.

Laurens #2
Right from the start of the report the reader knows exactly who the company is and what they can expect the report to contain. For visually stimulated readers the provision of a map that clearly depicts the geographic spread of operations and customers not only shows the extent of the operations, but also makes it more interesting to read. The inclusion of a one-page company history Grindrod history provides a context to where the company has come from and how it has grown, and adds an element of interest to the standard report format. Highlights are blocked according to different aspects of the business (environmental, economic, non-financial, financial etc.) and are provided upfront giving the reader an overview of the successes of the year in an integrated manner. Sustainability reviews and highlights are included for each of the divisions (Divisional Reviews), reflecting that sustainability is integrated into reporting and not just discussed as a side line issue. This reinforces Grindrods assertion that sustainability is a core element of their business. The language used in the report makes it more readable, thereby making the report easily understandable to anyone unfamiliar with the specific activities of the company. Detailed quantitative environmental data is provided and clearly presented in a well-mapped table making it easy to compare assessments of environmental indicators. The group highlights are colorfully presented at the start of the report with a good balance of financial and non-financial achievements, again reflecting the integrated nature of the report. A fold-out index on the inside front cover is a good design element as it is useful as a page marker and makes the report easily navigable. As a practical tip, if using abbreviations in the GRI table please include a key of what these mean. For example, is NR = Not Reported, or NR = Not Required? References to documents found online should have a direct URL as opposed to simply www.grindrod.co.za. Environmental performance data would be complemented with graphs to show trends. Although the sustainability section has a scope, there would be merit in including a scope / boundary section at the start of the whole Integrated Annual Report. Disclosures on management approach need to be more explicit for solid level B compliance. Management approaches should leave the reader feeling that the company has defined policies, measurement processes and has shown that controls or audits are in place.

O O O O O

O O

O O

39

| Our Personal Favourites continued

Sasol
Over the course of this project I reviewed over 100 reports and Sasols certainly stood out as my top report. The overall impression I got from reading this report was the overwhelming investment that Sasol has placed on being a leader in the realm of sustainability. What I found most impressive was the ease in which I was able to understand the content. For someone like myself, lacking a background in this field, the report is written in such a way that makes it understandable and meaningful to someone less familiar with the nature of their operations. The report is second to none in its ability to cover most (99.6%) of GRI guidelines while covering the material in a way that still tells their story without simply box-ticking the various indicators. Overall this report shows that Sasol doesnt simply report on sustainability, but that it is indeed embedded in their everyday operations.

Sappi
Sappis report probably did the best job of any in reporting on quantitative data that is related specifically to the requirements of the GRI. Their report was broken down into main components and addressed every indicator that was material to them. One thing I really liked about Sappis report was how they clearly explained the significance of certain sustainability issues and how that significance changed across the globe. Sappi has an extensive global footprint and did a great job of explaining where certain sustainability issues may be more relevant in different regions. A true sign of a well-written report is the degree to which information is understandable and meaningful. Sappi does an excellent job at presenting complex sustainability initiatives in a way that someone less familiar with the nature of their operations can understand.

Matts #1
The online case studies serve as reminders and proof of what Sasol is actually doing to address all of the sustainability measures that they mention in the report. The GRI index is very useful ast whenever information is not immediately available via the hard copies of the two reports, a direct URL to the supplemental online information is provided. The report provides a comprehensive overview of the companys operations and how sustainability is integrated in every aspect from top to bottom in their integrated business model. Sasol does a very good job of explaining why certain GRI indicators are not material to their business. Pictures in the report provide a contextual view into the working environment of the company as well as being relevant to the information being discussed in each section. Graphs and charts are used in both reports to help make quantitative information more meaningful and understandable. The content in this report is easy to understand for someone that might be less familiar with the operations of the company. This report does an incredible job in its ability to substantiate qualitative assertions with quantitative data. The PDF version of the report should provide hyper-links to the online content. While money spent on social investment and donations is addressed, the value added statement should have this information as well. The stakeholder engagement section could include some specific topics rather than just referencing other locations of the report. The chairmans statement in both the integrated report and the sustainable development report are the same, a different statement with more emphasis on sustainability would be appropriate in the sustainable development report.

Matts #2
Sappi does a great job at displaying relevant quantitative data in a way that makes it meaningful and comparable to data from different reporting periods. The online sustainability report provides excellent disclosure on managements various approaches to reporting on all GRI indicators. The report is very well laid out with each main sustainability category having its own section. The chairmans report is very well written and goes into significant detail towards the companys views on sustainability. The extent of the sustainability report shows that significant time and energy is invested into reporting on all types of relevant information for stakeholders. The report uses charts in both the integrated and sustainability report that compliment the information and makes the data more meaningful. When its relevant, the sustainability report clarifies how certain performance indicators differ on a regional level. Sappis stakeholder engagement section Our impact on the world around us is very well put together and contains a significant amount of quantitative data that relates to each group of stakeholders. Without a hard copy of the sustainability report, it is a very tedious process cross referencing between the GRI index and the sustainability report online which is broken into a number of PDF files. These should be consolidated into one single file. Some graphs in the sustainability report are very tough to read because of the large amount of information in a small space. There is scope for a chairmans/CEOs letter in the sustainability report. Some explanations (such as the health and safety topics covered in labour agreements) could be beefed up as to why they are not reported on.

O O O O

O O O O

40

Woolworths
This report demonstrates how a company may move forward on a sustainability journey. Its the best example of walking the talk, and how a companys efforts in its Good Business Journey can evolve into a learning process in which innovation, commitment and continuous improvement are essential pillars. Also, the report effectively describes how high-level commitment to sustainability can translate into company strategies and day-to-day activities. Reading the report had such an impact on me that after reading it, I have started to look for Woolworths initiatives in my daily life.

Astrapak
This report is one of the best examples of acquiring an integrated and strategic approach towards sustainability at the beginning stages of a sustainability journey. The report was written in such a way that it clearly explains the business case for sustainability in the organisation. It makes the reader believe that Astrapak is committed to its slogan of Seeing Beyond. One of the most important factors that kept this report at the top of my favourites is the inclusion of a meaningful sustainability discussion in the Chief Financial Officers report. It suggests that there is an agreement about the meaning of sustainability from different points of view within the company, and that investing in the sustainability of the environment and society is considered as an essential element for the sustainability of the business.

Taherehs #1
Integration of sustainability throughout the organisation from high-level decision making to day-to-day activities is well demonstrated in the report. It makes the reader believe that sustainability is the way that the organisation does its business. The report explains the companys sustainability journey very well. It provides good information about what has been achieved, what its current position is, and what its plan for the future is. Engagement with stakeholders and how the company is trying to build a win-win interaction with its stakeholders based on common understanding of current and future situations is well described. Very good use of tables in various sections of the report. The tables are easy to understand without overloading the reader with useless information. The depiction of the CSI strategy is well-structured and suggests that it is based on both international goals and national needs. Effective case studies are included in various sections. These help the reader learn more about the companys challenges and achievements. In general the report is very well written and laid out. It is easy to find what you are looking for, as the report provides information in a gentle and rational flow. The multi-dimensional nature of environmental aspects with which the company is dealing, is explained well in specific sections. Although stakeholder engagement is discussed well in the report, the basis of stakeholder identification is not mentioned. This point should not be undermined since it reflects the reason behind such engagement and the values and rationale on which interactions are based. The GRI index includes good cross referencing to different reports. It might be improved by providing page numbers which helps the reader to find desired information more easily. Woolworths approach towards Human Rights issues needs to be explained more explicitly and supported by factual data and information. Related indicators are only addressed in the GRI index in the report.

Taherehs #2
Statements from the highest governance bodies of the organisation reflect leadership support for integration of sustainability throughout the business. The importance of sustainability to the company is well explained in the report. It helps the reader understand their business case for sustainability. The Chief Financial Officers report discusses material sustainability issues. It reflects the fact that sustainability discussions are not restricted to specific departments in the organisation and allocation of time, budget and human capital to move forward on this journey is supported as essential to the business. The report provides the reader with a comprehensive market review around all material issues, helping the reader gain an understanding of the external context in which the organisation is operating. Very good use of tables in the stakeholder and risk review sections. The tables are both meaningful and easy to understand. Its obvious that Astrapak considered the GRI guidelines in preparing the report (although its not a GRI report), which appears to have led to a well-structured report. Topics progress from one to the next in a logical and integrated manner. The strategic approach of the company towards sustainability might be supported by reporting explicitly about the sustainability implementation plan and the relevant KPIs Astrapak has developed. Since employees and their well-being and development are clearly stated in various sections of the report as one pillar of the organisations sustainability agenda, the reader expects to find more facts and figures (i.e., data trends) supporting specific assertions in this regard. The role of the companys products in achieving its sustainability agenda is explained in the Our role in sustainability section, but the reader may expect to find more comprehensive and supporting discussions and facts in subsequent sections about plans, procedures and projects in place for the company to have more sustainable products: including environmental and product responsibility related topics. Contact details for questions regarding the report or its contents need to be explicitly stated. A person to contact and either a phone number or e-mail address should be included.

O O O

O O O

41

Engage strategically! AA1000SES

Report effectively! AA1000APS

Assure with meaning! AA1000AS

Since 1995, AccountAbility has been a global provider of innovative solutions to critical challenges in corporate responsibility and sustainable development. With offices in London, Washington, New York, So Paulo, Zurich, Dubai and Riyadh, AccountAbility is the benchmark standard for stakeholder engagement and reporting.

Abertina Khumalo and her family of 23 orphaned grandchildren and great grandchildren, were among the recipients of IRASs 2010 Making Reporting Matter clothing drive. Attendees of our report launch participated in our bring a shirt take a shirt campaign, ultimately helping us take a trailer filled with clothes to Hlabisa in northern KZN.

To inquire about our standards, or our Certified Sustainability Assurance Practitioner qualification, email us at:

Hlabisa is home to one of Cotlands most important community-based HIV-AIDS projects, due to an HIV-infection rate that is well above 60%.

info@accountability.org www.accountability.org
42

| Why Report According to GRI?

Why Report According to GRI?

Lessons Learned from Leading Reporters, on Why GRI?
For three years, the annual publication of the King III & GRI+ series of annual reviews of sustainability reporting in South Africa have been dominated by one opinion that of Michael H. Rea although last years report included an extremely useful opinion piece written in partnership with Jonathon Hanks and Nicola Robbins from Incite Sustainability. Those casual discussions written to offer an opinion regarding what is happening, and what ought to happen, but excluded a wider set of opinions. Granted, my ego asserts that the one opinion should suffice, but reason may dictate a need for more input from others. The following pages summarise a set of interviews with persons responsible for the sustainability reports of some of South Africas leading reporters, with the sole intention of attempting to help new reporters seek guidance from the gurus of reporting (i.e., those who have been producing reports for their companies year after year).
CAUTION

What the Da Vinci Code is to Christianity, so is the GRI to sustainability.

For better or worse, the GRI has created a framework, or protocol, that can be decrypted for the masses, so that people can understand what is or is not material, and thus what must be measured and reported by an organisation of any shape or size. However, one must consider that its the responsibility of the author to educate the readership. Readers of the report must be informed about how it is meant to be read, how the GRI is being applied, and where to find supplemental information not contained within the report. A challenge for reporting is really to find ways to quantify and assess a companys reputation relative to an array of key stakeholders, such as employees, suppliers and customers. Adhering to the GRI Guidelines doesnt create a mechanism for reporting or testing the degree to which the company is viewed as meeting stakeholder expectations and/or acting in a responsible manner. However, there must be some way to avoid reports being written in the absence of some sense of neutrality, or balance between the good, bad and/or ugly during the reporting period. As an outsider albeit a reasonably well-informed author of our own report reading the reports of several of the Top 20 Companies makes you question how a company that is deemed to over-remunerate its directors, and to perpetually flout governance and competition law, can be scoring over 80% in terms of the GRI indicators.
NOTE

hey tend not to be qualified to do the work required to assess T social, environmental and/or governance performance; and, hey are inherently trained to look backwards not forward, T which is whats needed in sustainability reporting. To date, I can only recall one fund manager who has ever called and asked for clarification about something contained within the report. Thus, the big question will be whether or not the investors take ESG issues and/or the Principles for Responsible Investing (PRI) more seriously. However, the Code for Responsible Investing in South Africa came into effect late last year, requiring investors to report back on how they are applying ESG considerations when making investment decisions.

Perhaps the GRIs day in the sun is yet to come.

Many of the current reporting awards have become meaningless, simply because what is deemed excellence in one process can be deemed only OK in another. Rather what is required is identifying real leadership in corporate accountability and transparency.

Nerine Botes-Schoeman
(African Rainbow Minerals)
African Rainbow Minerals (ARM) first started applying the GRI Guidelines as from their 2010 Sustainable Development Report (SDR), primarily because it was the standard of the day for reporting compliance. Not only was the GRI recommended by the King Code of Corporate Governance, but it was also the de facto standard recognised by the ICMM. At the time, we were considering joining the International Council on Metals and Mining (ICMM) which we have since done which requires that we produce a report that meets the GRIs Application Level A+ requirements. In fairness, we were coming at this cold, and in the absence of a framework, it was useful to apply the GRI as a framework for reporting, and we continue to apply the guidelines because they give us structure for year-on-year comparisons. Its that whole thing about what you dont measure, you cannot manage. By applying the guidelines, we were able to identify gaps in our own systems which allowed us to determine if the gaps were reasonable, or if there were specific areas where we needed to implement change. Once you have a document, its much easier for you to determine the where to next. By preparing and publishing the reports,

The views expressed within the following pages must be understood to be the opinions of the individuals commenting: not necessarily the companies they work for. In some cases, the individual has worked and thus reported for more than one company, thereby bringing to the discussion a set of experiences that exceed the confines of their current employer.

Andrew Johnston
(Altron)
About eight years ago, the wheel was turning to the extent where there was an identified need for integrated reporting in a corporate context, but particularly with respect to what is relevant, or material, within Altron. As we started to look around at how others were reporting, there was really only one place to go: the GRI. In fact, its not as if we had a choice, but rather where else could one look to find a credible database to compare your reports to others. However, it should be noted that its difficult to measure yourself against a consistent/credible database, due to the way in which sustainability reporting needs to be interpreted, or de-coded, for each company.

One must remember that this document (i.e., our annual review of GRI-based sustainability reporting in South Africa) is an assessment of a reports compliance with the guidelines. It is not assurance, but simply an evaluation of whether or not reasonable responses to the GRI indicators have been provided by the reporting entity. We do not attempt to offer some sort of normative evaluation of whether the company is doing the right things.

With respect to assurance, Ive got a fundamental problem with external auditors getting involved, for the following reasons: heir indemnity insurance policies rule out an effective opinion, T ultimately resulting in meaningless assurance statements that seem to do little more than protect the auditors from any form of recourse;
44

weve been able to move beyond reporting for compliance, to reporting as part of the overall management of our SD performance. Its all about continuous improvement. Applicability is perhaps the biggest challenge. Youre sitting with having to align materiality at the framework level. Ultimately, you find yourself running around, chasing numbers, trying to give answers to indicators that have been deemed material by others, but are not necessarily pertinent to our organisation. Ultimately, each organisation needs to apply the principal of materiality relative to themselves, and determine what information ought to be collated and reported upon. Otherwise, this tends to become yet another tick-box exercise. This year, weve seen an increase in the number of queries, from institutional investors primarily from overseas about information contained within our SDR, specifically our policies and procedures to manage specific issues. There is clearly an increase in requests for SD information, and it is unlikely that the demand for this information will wane. At the end of the day, the value of assurance is in the checking of the integrity of our own reporting, and adherence to our own standards and definitions. Assurance also helps to educate people within the organisation about how data collection, collation and reporting systems could be improved, but more importantly about how the reporting is relevant in the bigger picture of ARM and its key stakeholders. By going through the assurance process on-site, the management team at a mine becomes much more aware of why ARM reports, and why their information must be accurate and auditable. Prior to their big incident in the Gulf of Mexico, BP was a GRI A+ assured company, yet the question then gets raised about whether they were reporting in the true spirit of materiality. Ultimately, it would be useful for the process of applying the Guidelines to become simpler for lack of a better term and to make it much easier to apply the principal of materiality in a way that adds value not only to companies such as ARM, but to the widest possible array of stakeholders. When one looks at the various standards out there GRI, Global Compact, ICMM, King III, Mining Charter, JSE SRI Index, etc. the challenge is in creating a report that complies with the GRI, but also provides one set of information that satisfies all of the standards in one go. This can be rather cumbersome when also trying to produce a report that is readable. Perhaps, the JSE could work with the GRI to provide an SRIspecific GRI Sector Supplement that would help simplify things into one framework for reporting in South Africa.

Steve Bullock

(Anglo American Platinum)

Internally, we dont over-emphasise the GRI Guidelines. Rather, we focus on materiality. The GRI only comes in at the end of our overall reporting process, just as the report starts to come together, and the guidelines are simply a reference point, not a driving force, for our reporting. In truth, there are many, many people involved in our annual reporting, in a process that spans roughly six months of every year, and while the core team pulling the report together uses the GRI as a framework, the vast majority of the contributors to the report dont even consider the guidelines. They simply provide data and information against a set of criteria provided to them, albeit defined by the GRI definitions. Ultimately, the GRI Guidelines are the only real option, for the following reasons: They have managed to build critical mass in terms of the number of companies that have applied them to their reports; he Guidelines provide useful definitions to ensure that T everyone knows what is reasonably expected; The Guidelines provide the guidance people need to not only produce a comparable report, but to establish a reporting process, from determining the scope and boundaries of the report, to applying the principle of materiality to determining what should be reported upon; and, The Guidelines give you the structure required so that you can go into an HR Director or anyone else within the business and explain exactly what they should be reporting upon, and how. When you look at what we do within Anglo American Platinum, with respect to the checking of numbers and assertions within the report, you see how reporting has become an excellent indicator of the extent to which our Board and Executives take reporting seriously. The report isnt written in their absence, rather with their active involvement throughout a highly structured process. Our reporting process starts with a scoping meeting in July, establishing the framework of the next report based on guidance that comes from Anglo American plc. Our data management systems perpetually collect and collate the data we need, and the assurance process begins towards the end of our third quarter. However, the real work the under pressure work happens in the period between our year end (31 December) and when our report is signed off a mere 28 working days later. It may seem absurd to try to publish annual and sustainable development reports only four weeks after the year end, but in our experience weve noted that the pressure of such a tight
45

ENVIRONMENTAL & SUSTAINABILITY SOLUTIONS

Internationally certified by the Global Reporting Initiative (GRI) (sustainability reporting training) and licensed by AccountAbility (assurance)
Training courses GRI certified course on Sustainability Reporting GRI Performance Indicators RI certified advanced courses on Materiality G and Stakeholder Engagement anaging the assurance process of your M sustainability report Introduction to climate change Sustainability/Integrated Reporting onsulting on and writing of sustainability/ C integrated reports eview and level check of sustainability/ R integrated reports Assurance of sustainability/integrated reports Consulting services Environmental management accounting Material flow cost accounting Environmental cost assessment and modelling Resource efficiency and cleaner production Carbon footprinting

Contact details www.envsustsol.co.za | envsustsol@mweb.co.za or 082 395 7582 (Seakle) | 082 882 7700 (Maryna)
ESS is a GRI Certified Training Partner in South Africa

LEADERS IN SUSTAINABILITY ACCOUNTING

| Why report according to GrI continued

deadline increases the collective attention to detail within our reports. It means that we must be well-prepared to tell the stories that need to occur, and that our data management policies and procedures continue to support our reporting objectives. Ultimately, any organisation can formulate what it believes is material, but an effective reporting process must include engagement with stakeholders to ensure that their assessment is consistent with the companys. Over the past couple of years, Anglo American Platinum has begun to engage more proactively up front in the reporting process, to determine if what we believe is material is what our key stakeholders would expect to see within our reports. When one tracks the hits we get on our website, theres definitely been an increase on the number of page impressions for specific elements/data contained within our sustainability reports. The Scandinavian states pension funds are requiring that ESG considerations are applied to investment decisions, which has resulted in an uptake in reviewing sustainability reports, but a wider array of stakeholders are now looking at data, and are obviously much more aware of what we do. However, we have noted that while industry bodies are looking for specific data such as carbon emissions, the biggest number of requests for our sustainability report is from academics conducting research, essentially using Anglo American Platinum as a benchmark for comparisons. Perhaps its interesting to note that there were only a handful of shareholders who attended the last Anglo American Platinum AGM, and while we might question why there are so few, the conclusion is that there are so many channels for engagement throughout the year, that they dont actually need to attend the AGM. However, it should be noted that weve been at this for many years, and sustainability reporting is now well entrenched within business strategy. Its not that we believe that this is a good thing to do, but rather that one can no longer separate what we do from what people expect of us. allow for the best possibility for true comparability: against ourselves (year-on-year), our South African peers and colleagues, as well as our global competitors. However, in order to make the Guidelines reasonably relevant to all of our business units, across all of the countries in which we operate, weve had to Sasolise them. In doing so, weve attempted to write them in our own Sasol language, and to clarify them in terms of what must be included, or excluded, when provided with data and/or explanations. When one assesses the GRI Compliance Score reported within this report by the IRAS team, it must be understood that Sasol is not in the business of ticking boxes. Yes, we have scored 99.6% in terms of compliance to the Guidelines, but this was not a quick process, and not a stunt pulled to impress researchers and analysts. Rather, it was a multi-year evolution of our data management systems and controls, perpetually seeking to ensure that each indicator has been adapted to our reporting needs. An emerging trend is the fact that analysts are telling us that they are using the data that we provide in our reports, even though its not always as comparable is it could be. The degree to which the current version of the GRI Guidelines allows for interpretation amongst reporters is something that creates problems. For example, when we report our safety trends in terms of Total Recordable Frequency Rate, there is no guarantee that other companies are interpreting recordable and/or injury in the same way we do. Thus, neither we nor the analysts are yet in a position to place much stock in comparisons of safety rates across all companies: only the ones we know to be truly comparable. This is something the GRI and its stakeholders are trying to fix with the forthcoming G4. With respect to assurance, it should be noted that the value of assurance does not come from the statement we include in our report. Although a statement is important to include, the real value comes from the management report we get from our assurance provider. In fairness, analysts are not yet asking about assurance. Rather, there has only been one question from an analyst in the Netherlands about our assurance processes, but thats not why we undertake assurance. Through the third eye view, our assurers identify process improvement opportunities that ultimately enable us to strengthen our data management policies, procedures and systems, including our internal controls, which ultimately improves the quality of the data we present to our stakeholder.
NOTE

The following question and answer section has been compiled using responses offered by other leading reporters: HB(AA) KI(SB) Hermien Botes (Anglo American) Karin Ireton (Standard Bank)

NM(AGA) Nilesh Moodley (AngloGold Ashanti)

Why did you/your company decide to adopt the GRI Guidelines for your reporting (compliance, only game in town, globally respected guidelines, etc.)?
HB(AA): A ll ICMM companies have committed to GRI A+ reporting. We would probably follow them anyway. Theyre not perfect, but they represent the most credible and widely used option. B ecause it is a universal framework that has credibility. We all need to focus on systematic, credible data. Leading companies may go beyond GRI, but the core and essence must remain GRI, as otherwise the approach is too much like BS and too little like systematic management data. Even as we move into the integrated reporting phase the core of the sustainability piece will remain GRI (even as it evolves), because the absence of a universal framework is not better reporting, but a resurgence of PR.

KI(SB):

Stiaan Wandrag
(Sasol)
In 2000, Sasol became one of the first three early adopters to publish a report aligned to the GRI Guidelines (alongside Eskom and SAB). Its not that we werent always reporting, but rather that we were reporting (from the mid-90s) as per what we determined to be relevant and important. The Guidelines therefore helped us establish a better framework for reporting, as well as a structure for data capture and management systems, and has offered process improvement with every new version of the Guidelines. By reporting against a common framework, our GRI-based reports

NM(AGA): ngloGold Ashanti has adopted sustainability A reporting practices since 2003. The Guidelines: nsure that informed sustainability considerations E are factored into every business decision made within the company; ecure and maintain our legal and social licence to S operate; anage the organisations reputation and develop M trust with all stakeholders; dentify key trends in the industry, anticipate I the impacts on AGAs business and proactively manage our response to the benefit of our employees, shareholders, social partners and stakeholders, positioning the company as a preferred operator; mplement a sustainable model for mining, which I addresses past activities both positive and negative, as well as current and future trends;

46

ranslate sustainability risks and opportunities into T financial benefits for the company.

What benefits do you/your company get from reporting in a manner aligned to the GRI Guidelines?
HB(AA): C omparability between companies and within same company over years. T he GRI forces transparency (principle of completeness). H elps make the case for what to report internally. Otherwise, the choice would be too open to manipulation. R eporting according to GRI gives a practical perspective on the application of the guidelines and therefore the ability to influence future iterations. T he benefits of a disciplined and widely agreed framework that enables one to improve the management of issues by elevating key data for management purposes and then report them succinctly and clearly for the wider group of stakeholders to share your thinking. T he biggest value for companies comes from the systematic application of disciplined thinking and approaches to eliciting and documenting management information that is essential for making key decisions (whether those be strategic/directional or about prioritisation of effort and capacity and the allocation of financial resources) and then acting on it. Any company that had good GRI reporting and treated it properly in this context has extracted significant value from it. That is why we bother. It is not about an externally facing report that needs to look pretty to be read. Its about treating sustainability issues with the same maturity that one treats other issues (such as financial management). Only when one has gone through several cycles of effective sustainability reporting is there any depth to the indicators and the supporting data is one truly able to understand the strategic implications of what underpins the data.

History shows that sustainable development programmes resulting from collaboration between industry and government are generally preferable, from a share price perspective, to programmes developed through isolated efforts. An example of this is how the International Council for Mining and Metals (ICMM) requires mining companies to report at a GRI A+ level. Increasing awareness and knowledge of sustainable practices: There are a predefined set of reporting indicators which allows for understanding of sustainability issues through the reporting process, especially if these indicators were previously never thought of as being sustainability indicators.

KI(SB):

What, if any, challenges do you/your company face when reporting in a manner aligned to the GRI Guidelines?
HB(AA): S ome of the indicators are not meaningful from a management perspective and require adjustment. The GRIs core principle materiality, but external pressures are such that sometimes more is more. The risk is chasing indicators without any actual management value. N one but we would get challenges if we didnt align to GRI which at this moment presents the best available set of universal sustainability reporting guidelines.

KI(SB):

NM(AGA): n instances the data reported is not available at the I correct level of granularity required for GRI reporting. This necessitates a cross-functional link along many different departments/regions/countries and sites. While this does have the benefit of focusing sustainability as a linkage, rather than as a separate function of the business, there are systematic challenges at an operational level that are encountered when managing this change.

NM(AGA): Industry self-regulation: GRI provides a standard platform for reporting which allows the industry to make comparisons within mining and sustainability reporting. Also, when industry and government/ regulatory bodies share expertise regarding the application of sustainable development best practices, practical and cost-effective self-regulatory programmes and/or legislation will often result.

What, if any, new trends are you experiencing with respect to your sustainability/integrated reporting (e.g., are analysts starting to pay attention to data within your reports if so, who)?
HB(AA): T here is broader mainstream interest in these reports both from within companies (SD and SD reporting is no longer a greeny fringe department; it is either taken seriously or at least seen to be topical).
47

| Why report according to GrI continued

This means that other departments are also getting more involved. KI(SB): W e continue to get management value and the quality of the SD reporting has made the concept of integrated reporting easier. senior focus than a report writer. Thus, less use of 3rd party PR consultants to write reports, and greater internal control, or ownership, of the words, data and strategic implications. NM(AGA): verall, there are many great benefits from the GRI O style of reporting that has penetrated through to many company strategies and serves as drivers for more sustainable practices, by highlighting the gaps in current unsustainable practices. However, ideally, I would like to see companies taking more cognisance of the fact that the GRI, while useful, is only one possible option for reporting, and that the company starts developing more focused reporting mechanisms to be useful and unique to their own company. I would like to see more focus on getting the actual ambit of sustainability reporting right within a company, before the implementation of newer and better frameworks. For example, the Integrated report provides much value in the evolution of sustainability reporting, by encouraging the company to think and to address issues with consideration of both financial and sustainability information in an integrated way. The problem however, is that if one takes into consideration that historically, reporting on sustainability issues should have provided that catalyst towards integrated reporting anyway, then the move to an integrated report as a separate report is a little like viewing the emperors new clothes and heralding the new innovation that should have been in existence anyway. S ustainability reporting was first touted as being both forward and backward looking, taking into consideration the needs of the present and future, addressing stakeholder needs and taking into consideration economic, environmental and social concerns. Why then is there such a disconnect between the financial report and sustainability that a new set of clothes (i.e., the integrated report) is needed? If a report was already addressing economic concerns adequately the integration of this would be tacitly implied. My question in essence would be Why is sustainability reporting not already integrated reporting? and the answer to that will provide, hopefully, a way of addressing the guiding steps to true sustainable reporting integration within a company.

Next Generation Consultants is specialist management consultancy that has extensive experience in sustainable management, development and reporting. We work with organisations to develop, implement and report on their value-creating strategies and business models to ensure the future sustainability of their businesses.
Our services include:

NM(AGA): ue to the nature of mining and its interleaved D connection with our natural resources and communities, there is always a high amount of scrutiny from NGOs, analysts, students, etc., regarding our sustainability practices. Communication with regard to these practices internally and externally has increased year-on-year.

What, if any, value do you and/or your company gain from seeking independent third party assurance?
HB(AA): T hey help identify data reporting gaps, and add a degree of integrity to the process. We use the ICMM Assurance Protocol in which our materiality process is assured that forces us to take quite a robust approach. T he typical value of a 3rd party giving you a grilling on anything. It makes you question some of your own assumptions, assertions and truths, and does have credibility with audit committees.

KI(SB):

Strategy Development, benchmarking, and performance review Operational Implementation and integration Stakeholder Engagement and management Human Rights Impact Assessments and due diligence Supply Chain Development, review and reporting Life cycle analysis and value chain assessments Sustainability and Integrated Reporting Training in Reporting, Strategy Setting, Materiality, Indicator Development, Stakeholder Engagement and Management Review of reports and stakeholder panels for reporting insight and feedback Contact Reana Rossouw on +27 11 258 8616 Email: rrossouw@nextgeneration.co.za Web: www.nextgeneration.co.za

NM(AGA): etting an assurance statement from a credible G source does leave investors with a higher level of confidence in the reports that are produced.

What, if anything, would you like to see happen within the reporting space?
HB(AA): F ormalisation of environmental accounting and other metrics to aid comparability. M ore honest reporting. The same mindset as in financial reporting, whereby withholding relevant (good or bad) information from decision makers would be considered wholly unacceptable and unethical. G reater links being made between SD and business impacts. G reater links being made between SD and community/environmental impact (not just CSI spend, for e.g., but the impact of that spend). L ess PR, more reporting, more maturity in use of the materiality focus, and the so what piece being used better by companies. This requires more
48

KI(SB):

| The JSEs Role in Encouraging Effective Reporting

The JSEs Role in Encouraging Effective Reporting

NOTE

The following pages are the result of an interview with Corli le Roux, the JSEs Head of SRI Index and Sustainability (Strategy and Public Policy Division). Launched in 2004, the JSE Socially Responsible Investment (SRI) Index the first emerging market non-financial index has become somewhat of a talking point for many within the integrated reporting space. Initially established in response to debate about the overall sustainability of business, in its current context, the aim of the Index was to measure leading JSE-listed companies against a series of reasonable social, environmental and governance metrics. However, it appears that the Index has grown to become a driving force behind a compliance tail wagging a progressive dog. Recently, the questions were posed regarding not only the effectiveness of the Index, but also the possibility that it may be perceived as having limited at best impact on investment decisions. For some, the question is less about the role of the Index, and possibly more about whether it is required. It is less about whether companies are capable of meeting the JSEs expectations, and more about whether or not investors and analysts really care. However, a deeper understanding of South Africas reporting climate, including the emergence of a compliance-driven trend towards performance improvement, suggests that our collective interpretation of the Index has been misguided. Over the past few years, there has been measured improvement in not only the number of GRI-based reports, but also in the overall quality of reports being produced. Reports at first unnecessarily lengthy (e.g., the >400 page tomes produced by the likes of Absa and Gold Fields) have become more reader friendly, much lighter to carry, and frequently more robust in terms of the data that stakeholders might deem useful and/or relevant. The reports have become the outputs of an annual process, rather than an end-of-year exercise, and ultimately have become management tools for change within the organisations they are meant to represent. Although there are a number of reasons for driving this change, one would be remiss to ignore the significant role the JSEs SRI Index has played. Year after year, companies have submitted information to EIRIS the JSEs research partner in the Index and argue vociferously if there is any misinterpretation of the information provided, particularly as a result of EIRISs almost exclusive reliance on publicly available information: policies, procedures and reports to stakeholders. Because the Index

parallels the GRI Guidelines in many respects, the quality of companies reports have improved. The evolution of the Index towards measuring actual performance, rather than mere policy statements written in PR-speak replete with hollow and unsubstantiated assertion, has essentially forced companies to fear being ignored by the Index. As a result, we have borne witness to the way in which compliance can not only change what companies say about the way they do business: but the actual way in which they do it. By forcing companies to report more effectively, and to make more of their policies and procedure documents public, the Index has re-shaped the corporate hand of compliance into a fist for effective change. By seemingly punching above their moral weight, companies have begun to identify not only the areas in which improvement is required, but also the potential benefits of doing so. They have stepped up to new challenges, and have benefitted from training their systems to create at least the mechanisms for attempting to act more responsibly and thus more sustainably. Their reports have become better targeted, and as a result, better written, ensuring that they no longer focus solely on the shareholder. They now speak to employees, customers, government, unions, and even management: the people who stand the most to gain from reading, interpreting and using annual reports to effect positive change within the business. While the JSE may not necessarily have intended for enhanced sustainability reporting to be a significant spin-off benefit from the Index, transparency and accountability were always among the desired benefits. However, the Index continues to be a misunderstood arrow within the quiver of responsible business. Far too frequently, companies interpret the SRI Index as an end rather than a means. Its viewed as a goal post, if not the scoring mechanism against which companies measure their responsibility. Errantly, its seen as the objective, rather than the guide. In a recent interview with Corli, I was reminded that the JSEs intention was never to create some irrelevant pseudo-award process, but rather to inform discussion, debate and progress. Our role isnt to make a judgment call about whether or not a company is good or bad, or responsible or irresponsible, but to help create an environment where investors or potential investors are able to make well-informed decisions about whether an investment will be able to generate a sustainable return.
50

The JSEs role is thus to put the sustainability agenda on the table, and to help identify key issues that need to be addressed, but the SRI Index should not be where companies should stop. The SRI index, through the approach that has been taken hybrid legislation + an index recognising leadership in socially responsible business practices has been able to inform the extent to which companies are willing to share information and engage society. To effect change, the JSE has opted for a thought leadership role rather than a regulatory/enforcement one, noting that South African companies are taking sustainability issues seriously, and that they want to understand how they can enhance their value proposition. As Corli noted, The JSE holds the enviable position of being able to facilitate engagements that might not otherwise take place, and that convening power is what wed like to leverage in the future, and we were aware of the fact that detailed requirements about GRI reporting and/or King compliance would not achieve any measure of sustainability. Its the JSEs position that companies must undergo their own process of determining what is material to them, what they ought to report, and thus what will help create a sustained and responsible return for their shareholders. Regulation isnt the right way to affect sustainability. Facilitating the discussion and making recommendations is what will affect positive change, and the Index is but one mechanism for informing discussion. Thus, the real value is not necessarily in the index itself, but rather in the conversations that have resulted from, and around, the index between the JSE and companies, as much as between the JSE and investors and this is the key point that must be taken up as the index continues to evolve. However, one mustnt neglect noting that the JSEs own annual reports have yet to meet their own recommendations. For the fourth consecutive year, our research has noted that the JSE has not yet responded to their own by way of King III recommendations for integrated reporting in accordance with the GRI Guidelines. Measured amongst the 363 companies reviewed, the JSEs most recent report ranks 170th, but noting that our GRI Compliance Score is almost meaningless is shockingly close to being GRI-compliant, if only theyd bothered to look. With a score of 29.2%, the JSE at least quantitatively has exceeded the minimum benchmark for GRI compliance, yet has repeatedly claimed that there has been no need to apply the Guidelines as of yet.

With respect, Corli has clearly stated the following,

The JSEs revised sustainability strategy is still being developed. We need to define what sustainability forces/issues will impact our business, our clients businesses and what the JSE needs to do in order to adapt and to facilitate the ability of others to adapt. Our approach has been to take a step back and consider what our impacts and risks are before actually settling on a process for reporting. We havent reported according to the GRI because we havent felt that weve done enough to actually apply the guidelines. Apparently, the challenge resides in the unique position of the JSE as a potent intermediary. In order to report effectively, the JSE must first find the correct balance between the inward and outward focus, looking not only at how the JSE remains sustainable, but how it can influence the sustainability of others. Ultimately, the sustainability of the JSE is inextricably linked to the sustainability of its constituent companies, and thus of the markets. Although still somewhat disappointing for someone such as myself, someone who was first introduced to the JSE when I managed KPMGs assurance process of the first SRI Index, the logic in the JSEs argument is neither flawed, nor entirely their own. The likes of Sasol and Anglo American Platinum have invested years to establish meaningful sustainability policies, procedures and systems, while operating in industries that are much more at the forefront of sustainability leadership (for obvious reasons). Moreover, neither company has yet been quoted saying anything other than they are still learning, changing and enhancing their reporting systems. Thus, it is perhaps the more prudent view that the JSE could be given at least one more chance to start walking its own talk.

member living next to a mine. Thus, reporting must continue to evolve in a manner that can help redefine wealth, measure progress, and manage risk. The journey should not be pushed towards a framework that ultimately constrains business, or establishes a one-size-fits-all template for reporting, but rather encourages processes for the natural evolution of reporting. Ultimately, IR should help companies report less, but provide better detail around what is actually material. It should not become a compliance-based approach, or a tick-box exercise. The risk is whether or not investors will ultimately have access to the information required to fully understand how value is created and/or protected. In this regard, the JSE remains committed to ensuring that the engagement occurs.

In her own words, this is what Corli believes companies can expect from the JSE in the next while:
The JSE will be rolling out a number of strategic initiatives that will demonstrate its commitment to advancing the sustainability agenda, both in terms of the JSEs own position on sustainability and how the JSE wishes to inform the space. Were not yet ready to disclose the detail, but there will definitely be more discussion and engagement with people throughout the investment value chain, ultimately to inform how the JSE repositions itself as a mechanism for effective change. The SRI index is set to undergo significant change over the next five years, starting with a publication expected later in this year, and the JSE is looking at other product lines including the carbon off-set project, in partnership with BUSA (set for outcomes to start in the next couple of months) that the JSE is preparing to roll out to meet the needs identified by its many stakeholders.

Nonetheless, the JSE will continue to inform reporting.

The fact that the discussion about integrated reporting is occurring on the global scale that it has, is not without the obvious links to the way in which the world has become in many respects one inter-connected market. The travails of Europe impede progress in China, just as unemployment in the US has deleterious impacts on the strength of the Rand. Investors, regardless of where they reside, have become much better connected to their investments, and are instantaneously connected to matters that could potentially affect how companies manage intrinsic and/or explicit wealth. Technology is connecting not only the institutional investor and the CEO, but also the small-scale investor and the community
51

Graphics
Est. 1982

Bastion

blue chip partner of choice for

D FOCUSEANN UAL REPO RT 201 1

INTE GRA TED

PRET ORIA PORT LAND CEME NT

integrated annual and sustainability reporting

COM PANY LIMI TED INTE GRAT

Inte grat

UAL ED ANN REPO RT 2011

ed annu al repo rt 2011

Au

The Bidvest
ANNUAL

Group Limited
ATED REpoRT

2011

INTEGR

The Bidvest Group Limited AnnuAL Ted reporT inTeGrA

THE POWER

OF MANY

+
great team service expertise

+
resourceful innovation

2011

DISCLOSURE

Eskom Holding

Shift perfo

rmance, grow

winning formula
31 March 2012

for the year

sustainably Integrated Report ended 31 March 2012

s SOC Limited Integrated Report for the year ended

integrated reporting formula

2011 report annual review Integrated 1: Integrated Volume

bility Sustaina ugh thro sibility Respon

Integrated annual report 2011

Barloworld Limite d integ rated annu al repor t 2011

For 30 years Bastion Graphics has consistently set the service standard in corporate reporting, as testi ed by the numerous awards our clients win. Our integrated / investor suitcase consists of gap analysis, peer group assessments, report structuring for GRI and King, writing skills, design, nancial adverts, analyst presentations and web design.

Bastion Graphics specialists in corporate reporting since 1982

Contact: adele@bastion.bz Tel: +27 11 7785800

.beyond
Welcome to possib ility
ber 2011 ber 2011 31 Decem 31 Decem Limited year ended ted Report MTN Group y Report for the MTN Group Integra g Sustainabilit complementin report Detailed

Benefits of GRI-Based Reporting in the NGO Sector: A Call to Action!

Benefits of GRI-Based Reporting in the NGO sector: A Call to Action!

educ atio n

Annual Financial Statements

for the year ended 31 March 2012

integrated annual report 2011

Written by IRAS Designed by Studio 5 Not assured 1st Report

For those still struggling to come to grips with integrated reporting, there may be little solace emanating from the fact that three charities produce GRI-based integrated reports, summarily proving that reporting is not the assumed playground of the big and wealthy companies. Granted, all three report are in one way or another linked to the experience statement of Integrated Reporting & Assurance Services (IRAS), but each has independent of each other adopted the principles associated with transparency and accountability to a whole new level. Of the above, Cotlands is the longest-serving NGO representative (the other two are 1st time reporters), but the lessons of each organisation are equally important, as are the experiences of the specialist consultants donating their time to assist worthy causes.

Written by Little Eden Designed by Studio 5 Assured by IRAS 1st Report

Donating ones time, skills and experience to an organisation such as Little Eden is both a challenge and a gift. On the one hand, its very difficult to put together a report for an organisation that is doing such amazing work for people who offer help to people who desperately need good care. Its difficult to work with some of the pictures, and to read some of the stories about how hard it is for Little Eden to get the funding they need to offer the care they do. But on the other hand, such a project is a welcome relief from corporate tedium. Big companies are very strict about what can or cannot be done with their reports. They have strict style guidelines, and dont allow designers to be as creative as they would like, whereas a Little Eden is much more open to style recommendations that take their words and turn them into their story. Working with an organisation such as Little Eden is great for me, as a designer, but also for a company like Studio 5, because it makes us all feel as if were not just working a job, but making a difference. In a way, we hope that by giving of ourselves, or our abilities, those within Little Eden will know that we respect and value them.
54

Written by Cotlands Designed by HKLM Assured by KPMG 8th Report

In the words of Jackie (CEO) at Cotlands,

Producing GRI-based integrated reports has been a very good learning process about what stakeholders primarily donors are interested in, and thus what we need to monitor, measure and report on. The reports have helped us move from collecting meaningless data to focus our attention on what is important to us, and have helped us improve the quality of the services we provide. In order to produce meaningful reports, Cotlands has had to improve our monitoring and evaluation (M&E) processes, and thats the reason why you report. Its not about giving meaningless data, but rather about focusing on what you need to do throughout the year in order to be able to report back to stakeholders at the end of the year about what you have achieved. Reporting is about creating systems and controls that allow you to manage many things within the organisation, including some things that may not seem as obvious as others. Last year we had an undiagnosed water leak that cost us, and thus our donors, thousands of Rands, and it might have continued to go unnoticed if we werent measuring and monitoring our environmental performance (even if the environmental issues are not necessarily material to Cotlands).

In the words of Alinda (designer) at Studio 5,

Little Eden is a heart-warming organisation. To think of what they do, the unimaginable challenges they face, the things we dont even know exist. The people who need 24 hour care from teeth to toes: not just physical but also mental/emotional care! The wonderful people working at Little Eden need to be cherished and appreciated!

NGOs need to consider ethical fundraising, and to disclose who the top donors are, which ensures that fundraising occurs in a manner consistent with societal expectations. Cotlands doesnt have a particular problem if the likes of British American Tobacco (BAT) wants to donate money, but it is a reasonable expectation that Cotlands would disclose where its money is coming from, simply because other donors may have concerns about a BAT-like company.

These included: Identifying additional monitoring and evaluation data management systems required to generate the information required to produce a meaningful report; Gaining a clearer picture of the challenges SMYLe has faced in overcoming objections to providing funding (e.g., that a music programme is a nice to have, even if SMYLe is more of an education project than an arts and culture one); Identifying additional financial control procedures required to maximise the auditability of our financial records (e.g., forcing all of our community-based suppliers to receive electronic banking payments, rather than cash); Recognising the need to employ full-time support staff regardless of the cost to manage fundraising and administrative support; and, Accepting that the sustainability of SMYLe cannot be indefinitely, and inextricably, linked to the sustainability of IRAS. Although not an appropriate venue to discuss the merits of IRASs role in SMYLe, it cannot go unsaid that SMYLe is at the heart of IRAS, and thus our commitment to offering management and thus reporting support to SMYLe is foregone conclusion. SMYLe provides IRAS with a meaningful platform for our team to learn how to write integrated annual reports: a prerequisite skill for anyone wishing to assure reports (i.e., you cant meaningfully assure a report unless youve actually written one). SMYLe allows us to test theories about the applicability of the GRI Guidelines, and offers a low-risk case study in which reporting boundaries can be pushed.

For me to give and expect nothing back, to sow into the lives of children who may never get the same opportunities I have, and to positively influence generations to come, there is no greater reward. I believe that all who are in a position to receive should freely give in love.

In the future
It is the collective hope of all three current NGO reporters that more charities will produce meaningful integrated annual reports. However, were all aware of the inherent limitations of charities time, access to non-core skills and available cash that will restrict further growth in this sector, unless others come to the party.

In the words of Lucy (CEO) at Little Eden,

Little Eden adopted the GRI Guidelines almost exclusively because they offer an internationally recognised system of reporting. They encompass a wide range of reporting parameters and encourage NGOs to take a fresh look at what they need to be reporting on. Often what we see as ordinary, or not necessary, is very relevant to the reader and needs to be highlighted. It encourages openness and transparency: absolute essentials in the NGO arena. Being internationally accepted, an Annual Report based on such guidelines assists NGOs with fundraising in both local and international arenas. It provides assurance to funders, backed by a body of verifiable data. Little Eden wants to be best in class, and a role model for other NGOs, encouraging them to be open and accountable to funders and the public for their activities. Ultimately, all NGOs should adopt an open reporting structure based on the GRI Guidelines, while corporate and/or large individual funders should place more emphasis on the notion of sustainability of the NGO before committing resources to what often appear to be lost causes. We most certainly intend to use our report as part and parcel of our fund raising activities. We envisage that it will be of significant importance, especially in individual funding applications to corporates and larger individual donors. A hidden benefit is that we have become much more aware of previous shortcomings (e.g., not monitoring service activities and utilities). These were merely taken for granted. We are now aware and monitor such data, which we believe will give management a better handle on what is actually happening. Moreover, we believe that now people have seen our report external stakeholders and the management team within Little Eden there will be no fear about how the next report will be produced. Rather, the team is excited about being able to produce an even better report next year. With respect to SMYLe (the Soweto Marimba Youth League), I can assure you that even with 13 years experience in sustainability reporting and assurance, there were a number of lessons learned from the process of developing SMYLes first report.

Please help!
For all those recognised as Other Sustainability Reporting Practitioners whether included in IRASs database of Other SRPs or not this is your opportunity to make a meaningful difference in the lives of those much less fortunate than we are. As an author, you could write a report. As a designer, you could turn words into effective stories. As an assurance provider, you could provide credibility to the information contained within the report. The truth is, time is the greatest gift were all offered, and thus the greatest gift we can share with others. Our time is limited ultimately to an extent that well only come to appreciate when its up and its value is embodied within the skills and talents weve accumulated thus far. Sure, you could donate a Rand or two, but the value of your time will always be greater than the cash you might be able to give. Moreover, the offering of time is not a zero sum game. Rather, the giving of time will benefit YOU the donor as much, if not more, than those you might assume to be helping. As Alinda of Studio 5 so poignantly stated, it makes us all feel as if were not just working a job, but making a difference.

In the words of Cyril (designer) at Studio 5,

But if anyone has the worlds goods and sees his brother in need, yet closes his heart against him, how does Gods love abide in him? (1 John 3:17) Ive often wondered how my God-given skills and abilities as a graphic designer can make a difference in society, and touch the lives of people who are less fortunate than I am, particularly given that design is an intangible gift that one often forgets can be donated. Perhaps its no coincidence that the SMYLe annual report and CD design project landed on my desk, as this was the perfect opportunity for me to give. In most cases, a pro bono job can have lesser creative restrictions than a paying one. As with many of these assignments, the SMYLe report was a designers dream job, as I was able to freely express myself creatively through layout, typography, concept development and building a relationship with my client and enjoy it!
55

Pick a charity! Write their next annual report! Design it in the most effective way! Assure it!
There are ways for all of us as reporting practitioners to put our talents to good work, and I trust that the 5th edition to this annual review of GRI-based reports (next year) will include far more reports from within the NGO sector.

| Getting the Data Right

Community members in the Zandspruijt Informal Settlement (ZIS) were the recipients of IRASs 2011 Making Reporting Matter blanket drive. Attendees of our report launch brought warm blankets that were distributed to community leaders in ZIS, a community rocked by service delivery protests and xenophobic attacks.

Getting the Data Right

If reporters repeatedly state that one of the primary benefits of the GRI Guidelines is comparability, then one might assume that companies at least those that have been applying the Guidelines for a few years now would have figured out how to collect, collate and report key sustainability data in a consistent and comparable manner. However, the current evidence suggests that very few companies (even those obtaining independent third party assurance over core indicators) are paying close enough attention to their reports to ensure that the data is accurate, consistent, complete and reliable (the fundamental quartet of assurance tests). Perhaps the best example can be drawn from safety statistics (specifically, Lost Time Injury Frequency Rate). In order for data to be truly comparable, companies must choose to use a similar calculation methodology. In doing so, the reporting entity must determine the following: What constitutes an injury, and will injury rates include such things as workplace associated illnesses (e.g., does the company report all injuries/illnesses, or merely those injuries that require significant medical attention and/or result in lost time)? Will safety be reported in terms of a Lost Time Injury Frequency Rate, or LTIFR, Recordable Case Rate, or a Total Recordable Case Rate? Will the frequency rate be calculated relative to 1 000 000 person hours worked, or 200 000 hours, noting that 200 000 is roughly equal to 100 person years (i.e., 100 employees working a standard 40-hour week for 50 weeks of the year)? In short, it must be remembered that in order to report effectively, one must a) have data; b) ensure that the data is accurate; and, c) ensure that the data is comparable. Unfortunately, our review of the data contained within the most recent reports for companies in the Energy & Natural Resources, Metals & Mining and Banking & Financial Services sectors has essentially confirmed one of Sasols concerns about the current state of reporting in South Africa: the data isnt comparable. One quick glance at the graph using available LTIFR data begs obvious questions, such as How the heck has FirstRand, Standard Bank and Absa become more dangerous than 10 companies most of us would deem high risk, including Sasol, Anglo American plc and Eskom? In fairness, the answer is imbedded in the following tables, populated using the information contained within the reports we reviewed. Firstly, it should be noted that very few of the non-mining companies provided adequate data to make a comparison (i.e., an actual LTIFR). While 21 of the 24 Metals & Mining companies provided rates (and/or the data to generate frequency rates), only Sasol within the Energy & Natural Resources sector (1 of 4 companies) provided adequate information, as did only 7 of the 14 Banking & Financial Services companies. Granted, it might make sense given the nature of mining as a dangerous activity but perhaps the available data hints that the Chamber of Mines needs to redirect at least some of the negative criticism on to other industries.

NOTES

Lost Time Injury Frequency Rate is calculated by dividing the number of lost time injuries (i.e., LTIs, those that result in the loss of at least one shift starting with the day following the day the injury occurred) by the total number of person hours worked, divided by 200 000, in accordance with our primary school math rules about BEDMAS (brackets before exponents, division, multiplication, addition and subtraction). Thus LTIFR = # of LTIs (# of Hours Worked 200 000)
NOTE: All of the Lost Time Injury Frequency Rates in the graph have been normalised to a standard of injuries per 200 000 person hours worked.

58

Reporting Entity (Company Name) Energy and Natural Resources Sasol Ltd Sappi Ltd Europe North America Southern Africa Mondi Ltd Eskom Holdings Banking & Financial Services African Bank Investments Sanlam Ltd Standard Bank Group Ltd Nedbank Group Ltd Absa Group Ltd Liberty Holdings Ltd Brimstone Investment Corp Santam Ltd MMI Holdings Ltd Investec Sasfin Holdings Ltd FirstRand Ltd Efficient Group Finbond Group Ltd Metals & Mining Gold Fields Ltd Lonmin African Rainbow Minerals (ARM) Xstrata South Africa Anglo American plc Anglo American Platinum Ltd Kumba Iron Ore Ltd Northam Platinum Ltd Harmony Gold Merafe Resources Ltd AngloGold Ashanti Ltd Exxaro Resources Ltd Impala Platinum Evraz Highveld Steel & Vanadium Royal Bafokeng Platinum Ltd ArcelorMittal South Africa Ltd DRD Gold Ltd Aquarius Platinum Ltd Witwatersrand Consolidated Gold Wesizwe Platinum Ltd Assore Ltd Eastern Platinum Ltd Keaton Energy Holdings Ltd Richards Bay Minerals

Total number of employees LA1 32 735 14 862 6 025 2 224 6 378 41 400 41 778 LA1 15 281 11 643 52 127 28 494 39 659 8 523 3 350 Not Reported 15 644 Not Reported 583 34 612 81 459 LA1 46 378 37 360 28 704 13 777 146 303 58 541 11 898 10 096 39 440 12 955 61 242 10 513 36 119 2 386 7 942 9 430 6 875 10 024 18 42 17 430 3 220 257 2 400

Hours worked (reported) Not Reported Not Reported Not Reported Not Reported Not Reported Not Reported Not Reported Not Reported Not Reported Not Reported Not Reported Not Reported Not Reported Not Reported Not Reported Not Reported Not Reported Not Reported Not Reported Not Reported Not Reported Not Reported Not Reported Not Reported 54 485 152 Not Reported Not Reported Not Reported Not Reported Not Reported Not Reported Not Reported Not Reported Not Reported Not Reported Not Reported Not Reported Not Reported Not Reported Not Reported Not Reported Not Reported Not Reported 862,705 Not Reported

Hours worked (calculated) 59 708 640 27 108 288 10 989 600 4 056 576 11 633 472 75 513 600 76 203 072 27 872 544 21 236 832 95 079 648 51 973 056 72 338 016 15 545 952 6 110 400 Not Possible 28 534 656 Not Possible 1 063 392 63 132 288 147 744 837 216 84 593 472 68 144,640 52 356 096 25 129 248 266 856 672 106 778 784 21 701 952 18 415 104 71 938 560 23 629 920 111 705 408 19 175 712 65 881 056 4 352 064 14 486 208 17 200 320 12 540 000 18 283 776 32 832 76 608 33 472 224 5 873 280 468 768 4 377 600

Number of lost time injures LA7 379 Not Reported Not clearly reported 25 Not Reported Not Reported Not Reported LA7 20 Not Reported 289 77 Not Reported Not Reported Not Reported Not Reported 30 Not Reported Not Reported 216 0 Not Reported LA7 Not Reported 419 109 84 Not Reported 12 17 Not Reported Not Reported Not Reported Not Reported Not Reported Not Reported 20 Not Reported 56 Not Reported Not Reported 0 0 71 Not Reported Not Reported 12

LTIFR/ DTIFR/TRIR (reported) LA7 0.37 0.87 70.00 0.96 0.55 0.92 0.47 LA7 Not Reported Not Reported Not Reported Not Reported 0.55 Not Reported Not Reported Not Reported Not Reported Not Reported Not Reported Not Reported 0.00 Not Reported LA7 0.94 0.94 0.43 0.31 0.64 1.27 0.08 0.65 0.33 0.25 0.25 0.20 0.99 1.57 0.90 1.24 3.27 0.50 Not Reported 0.00 Not Reported 0.66 Not Reported 0.28

LTIFR/ DTIFR/TRIR (calculated) 1.27 Not Possible 1.27 1.23 Not Possible Not Possible Not Possible 0.14 Not Possible 0.61 0.30 Not Possible Not Possible Not Possible Not Possible 0.21 Not Possible Not Possible 0.68 0.00 Not Possible Not Possible 1.23 0.42 0.67 Not Possible 0.02 0.16 Not Possible Not Possible Not Possible Not Possible Not Possible Not Possible 0.92 Not Possible 0.65 Not Possible Not Possible 0.00 0.00 0.44 Not Possible Not Possible 0.55

Which rate? RCR LTIFR LTIFR LTIFR LTIFR TRCR LTIFR Not Reported Not Reported Not Reported Not Reported DFIR Not Reported Not Reported Not Reported Not Reported Not Reported Not Reported Not Reported Not Reported Not Reported LTIFR LTIFR LTIFR LTIFR LTIFR LTIFR LTIFR LTIFR LTIFR LTIFR LTIFR LTIFR LTIFR LTIFR LTIFR LTIFR LTIFR DIFR Not Reported LTIFR LTIFR LTIFR Not Reported LTIFR

Per 200 000 or 1 000 000 person hours? LA7 200 000 200 000 200 000 200 000 200 000 200 000 200 000 LA7 Not Reported Not Reported Not Reported Not Reported Not Reported Not Reported Not Reported Not Reported Not Reported Not Reported Not Reported Not Reported Not Reported Not Reported LA7 1 000 000 1 000 000 200 000 1 000 000 200 000 200 000 200 000 200 000 1 000 000 1 000 000 1 000 000 200 000 1 000 000 1 000 000 200 000 1 000 000 1 000 000 200 000 Not Reported Not Reported 200 000 1 000 000 Not Reported Not Reported

59

| Getting the data right continued

The over-arching problem with the data we extracted from the reports is that its neither complete nor consistent and certainly not comparable! In the case of Sappi, comparability even within the company is impossible due to the lack of consistency in the way data is reported within the Safety Performance section of their online sustainability report (http://www.sappi.com/group/Sustainability/ SDR11_People.pdf p.13). While the LTIFR is presented in a consistent manner for Europe and North America (setting aside an obvious typographical error suggesting an LTIFR of 70.00) with the number of employees and the number of LTIs given the information for Southern Africa is inexplicably split for employees and contractors, rather than a combined LTIFR, which one is led to assume is the corporate standard for the other territories. Further complicating matters is the fact that a user of their report isnt given enough information to do Sappis work for them, and use the base data to calculate the LTIFR. In their Our Diverse Workforce section (p.5), the numbers of employees are given relative to the three main geographical areas, but there is no breakdown of staff in terms of those that are permanent and those that are contractors, thus eliminating the possibility of calculating the rate on their behalf (as was done for their European operations). in an injury). Thus, to reduce the potential for a fatality to occur, companies must manage the factors that can lead to incidents and/or accidents.

Enlightened Energy
Enlightened Energy provides clean and sustainable
energy solutions throughout Africa.
To facilitate a new enlightened renewable energy paradigm, shaped by a green economy which combines sound economics with respect for the earth and its people. Our services are driven by solutions conceived using the knowledge and expertise of local people, applied to local conditions.

1 10

Fatal Accidents

Serious Accidents

30

Accidents

600

Incidents

Finance and Investment

Clean energy project development & finance International climate finance Mitigation and adaptation finance

So what?
Perhaps this tirade appears misguided and/or superfluous, but it wouldnt be if investors and analysts were actually using integrated annual reports (or sustainability reports in conjunction with annual reports). The fact is that in an environment where the safety of workers is a significant bone of contention between companies and their unions and government, particularly in the case of mining companies safety is not a nice to report, but clear indicator of potential impacts on financial performance. In the mining sector, government particularly the Department of Mineral Resources (DMR) has escalated the frequency at which they are issuing Section 54 notices that shut down mines in the event of a safety incident (injury or significant near miss). In doing so, they burden the affected company with paying wages without the ability to generate income through mining activities, and therefore expose the mine to a significant component of the true cost of safety. Thus, any analyst worth their salt would undertake to understand the Bird Pyramid (see image at right). In overly simplistic terms, Frank Bird argued in 1969 that fatal accidents are far less frequent than serious and non-serious injuries, and much less frequent than incidents we might refer to as near misses (i.e., those that could have but didnt result
60

Energy and Carbon Management

Energy/GHG assessment & GHG monitoring, reporting an verification (MRV) GHG-emissions reduction action plan design & implementation Carbon tax value at risk Mitigation and adaptation program design & evaluation

Although Susan Shabangu Minister of Mineral Resources has been quoted as saying that we should not attribute a value to safety, the fact is that in business, all impacts and affects are calculated in terms of cost, and ultimately in terms of shareholder wealth. Thus, it should be a reasonable reporting expectation that companies place greater attention on not only reporting data, but reporting the right data. However, it appears as if too few companies value the role effective sustainability data management systems play within reporting, inasmuch as they have not accepted that assurance is not about obtaining a GRI +, or a poorly worded assurance statement to fill two more pages of the report, but about using the reporting process as a mechanism for continuous improvement. In the future, one would hope to see significant improvement in the reporting of meaningful data by all companies, adhering to one of our most important golden rules of effective reporting: Let the data tell the story! Rather than write a report using ill-informed assumptions about performance, adding in data as/when it becomes available at the end of the reporting period, companies must start to monitor key sustainability indicator data throughout the year, and use it as the foundation for telling relevant stories. Trends and anomalies in data must be identified and explained, and where possible conduct meaningful benchmarking exercises to confirm or refute management assertions of performance excellence (vis--vis the effective example Sasol continues to set).

Trade and Market Analysis

Clean energy product imports & integration Market/trade analysis on the effects of low carbon regulation on cross border trade

Contact us:
Kimberly van Niekerk +27 (0) 82 853 6533 kvanniekerk@enlenergy.com www.enlenergy.com

| The Push Towards More Effective Carbon Disclosure

The Push Towards More Effective Carbon Disclosure

NOTE

This section has been written in partnership with Juanique Pretorius of Global Carbon Exchange (GCX). GCX is an end-to-end sustainability consultancy and training provider, with services spanning strategy + policy; measuring + monitoring; process optimisation; reporting + communication; and sustainability software. www.globalcarbonexchange.com

For those recently relocated from a Sterkfontein cave, carbon disclosure is the practice by which companies measure their impact on global warming or the deleterious impacts associated with increases in the Earths atmospheric temperature through the calculation of tonnes of carbon dioxide equivalents. The practice of disclosing carbon emissions is effectively managed by the Carbon Disclosure Project, or CDP, and is a voluntary set of principles by which companies are encouraged to measure, monitor and report the total volume of carbon they emit into the atmosphere as a direct, or indirect, result of their activities. Nobody demands that we measure such things at least not yet but experience is dictating that carbon disclosure, particularly in an economy befuddled with rapidly expanding energy prices, is less about appearing to do a good thing and more about making a business more cost effective, and thus more sustainable, while at least pretending to care about the future of our planet.

To anyone following trends in sustainability reporting in South Africa, theres no surprise in the statement that there has been a rapid rise of carbon disclosure in South Africa over the past few years. However, theres an abundance of speculation around whats driving the reporting of energy consumption and its resulting emissions. Be it corporate conscience, pending carbon taxation, energy efficiency and cost reduction or simple box ticking, theres no one answer for all companies. However, the process has been set in motion and South Africas participation in the Carbon Disclosure Project (CDP) is to be applauded. Of 3 700 of the worlds largest corporations surveyed in 60 countries by the CDP, South Africa boasts the second highest response rate. In 2011, 83 out of 100 top JSE companies responded to the Carbon Disclosure Project. According to their website, the CDP is an independent not-forprofit organisation working to drive greenhouse gas emissions reduction and sustainable water use by business and cities. The CDP has challenged global corporations to measure and report their carbon emissions. The initiative aims to encourage an integration of climate change related aspects into their business strategy.

CO2e Emissions per company

Company Eskom Sasol Anglo American plc ArcelorMittal Xstrata South Africa Merafe Resources Gold Fields Anglo American Platinum AngloGold Ashanti Impala Platinum Richards Bay Minerals Harmony Gold Exxaro Resources Assore Lonmin Kumba Iron Ore DRD Gold Northam Platinum Aquarius Platinum Royal Bafokeng Platinum Absa Group FirstRand Nedbank Group Standard Bank Group Eastern Platinum African Bank Investments Sanlam Liberty MMI Tonnes CO2e 230 300 000 74 836 000 18 800 000 15 450 000 9 300 000 7 380 840 6 600 000 6 022 000 4 445 000 4 023 000 3 850 000 3 715 000 2 484 000 2 020 999 1 648 343 910 000 691 138 635 468 399 044 295 801 359 038 280 665 163 518 160 190 151 532 98 783 50 281 47 422 36 295

Background
A recent publication by Ceres, Oxfam and Calvert Investments offers guidance for companies and investors on the disclosure and management of climate impacts. The report states that virtually every sector of the economy faces risks from the short- and longterm physical effects of climate change impacts across the entire business value chain, from raw materials through to the end users. In terms of auditing, materiality has become part of the fabric of sustainable business. The financial team has invited non-financial data into its camp, to prove equity in regards to the role it plays in the integrated overview of the companys performance. Sources suggest that information is material if its omission or misstatement could influence the economic decision of users taken on the basis of the financial statements. Materiality is dependent on the size of the item or error judged in the particular circumstances of its omission or misstatement. Therefore, materiality draws a boundary or threshold as opposed to being primarily indicative of the qualitative characteristic information is said to require, if it is to provide value. Stellenbosch Universitys Corporate School of Governance, UNEP and Deloitte recently teamed up to explore The Future of Corporate Reporting. In the report, UNEP Director Sylvie Lemmet introduces the importance of extra-financial measurement and accountability.
62

Given that this is a journey within a context of many competing socioeconomic challenges, there is no doubt that an 83% response rate by leading South African companies must be applauded.
Water and Environmental Affairs Minister Edna Molewa

20 companies from the combined Metals & Mining and Energy & Natural Resources sectors, nine companies in the Banking & Financial Services sector provided comparable data for carbon emissions.

According to Sylvie, the UN Conference on Sustainable Development (Rio+20) provided an unparalleled opportunity to globally transform the current economic paradigm into a model focused on enhancing human well-being, while valuing planetary boundaries and environmental confines. She explained that in order to facilitate this transformation, we need to measure what matters, so that we are able to understand whether we are making progress.

In essence, the challenge lies in shifting the way progress is perceived, business is done, and financial decisions are made in order to prioritise social and environmental considerations. Clearly, carbon meets the materiality test, and is becoming another factor within a more holistic calculation of the true cost of doing business, and reporting in accordance with the CDP is an important aspect of the accounting of tomorrow. For those that have already embarked on a journey towards effective carbon disclosure, reporting in accordance with the CDPs requirements leads to a number of benefits, not least of which are: Increased awareness of greenhouse gas emissions hot spots so that they can begin to reduce them; Gaining an understanding of the risks from climate change and water scarcity; Creating opportunities to generate revenue from sustainable products and services; Identifying ways to future-proof business from climate change and water scarcity impacts; and, Identifying ways to cut energy consumption costs through improved efficiencies.

Investment consultancy Mercer for example, reported that in order for institutional investors to manage climate related portfolio risk, a shift of 40% in their portfolios is required into climate-sensitive assets (with added emphasis placed on those able to adapt to a low-carbon environment). Meanwhile, the CDP has launched Carbon Action, driven by a group of leading investors aimed at encouraging their portfolio companies to invest in emissions reduction activities with an agreeable payback period. Accountancy SA points out that Climate change issues appear to be increasingly integrated in companies governance activities. Recently, many South African companies have set voluntary GHG-emissions reduction targets. In 2011, 31 companies set performance targets relating to GHG-emissions reduction while 22 others committed to developing such targets. Theres also a notable trend towards integration of climate change practices into governance strategies with a Board Committee or executive body elected to be responsible. In addition, twenty per cent of companies incentivise management if climate change goals are achieved.

Reporting st@rts here!

Configure Implement Support REPORT

SAs Supportive Policies

In terms of legislation, South Africas National Climate Change Response Policy embodies governments commitment to addressing climate change, while serving as a roadmap for effective response and transition. Government has stated that it cannot win the battle without the support of business and as a result, welcomes the commitment shown by South African corporate participants who understand the need to manage reputational risk, especially with regard to investors and consumers, as well as with regard to their goods and services. It also reaffirms that South Africa is capable of playing a leading role on the continent and among emerging economies in contributing to and benefitting from opportunities to mitigate and adapt to climate change. Minister Edna Molewa, MP for Water and Environmental Affairs commented on last years fifth Carbon Disclosure Report, saying it illuminates business commitment to achieving disclosure of their carbon footprint and pro-actively working towards its reduction. She explained that as the quality and scope of data improves, so do their rankings of strategic importance in context to being able to identify risks and opportunities, all signs of the progressive significance that companies are attaching to the impacts of climate change. The setting of targets and implementation of actions to progress against these targets, as well as the further premium that needs
63

Sustainability Data Toolkit

Reporting st@rts here!
SD Toolkit strives to make the sustainability reporting process practical, educational, as simple as possible and cost effective.

The Investors Perspective: Risk and Reputation

A Carbon Disclosure Project report Climate Resilient Stock Exchanges: Beyond the Disclosure Tipping Point explains that after a decade of experience, the CDP and its partners offer to partner with exchanges to improve the transparency of systemic risk for investors, and to reduce exchanges vulnerability in a changing landscape of risk. This is where King III becomes relevant, in the context of its code application on an apply or explain basis, requiring management to explain how its principles were applied, or if not, why not. The 2011 CDP Report was published on behalf of 551 investors with assets of US$71 trillion. Paul Simpson, CEO of the CDP explains that corporations, investors and governments are faced with either having to aggressively compete for finite resources, or to advance toward an enabling economy where sustainable, profitable growth can be achieved whilst reducing reliance on increasingly scarce materials. Paul explains that Managing carbon emissions and protecting the business from climate change impacts is fundamental to achieving sustainable and strong shareholder returns.

R Easy and accurate information collation Automatic BBBEE scorecard production R Full R CSI project management Unlimited users @ no extra cost R Full R audit trail and audit history Reports R at the touch of a button
Web: www.sdtoolkit.com Email: info@sdtoolkit.com Tel: 011 679 5597

| The push Towards more effective carbon disclosure continued

SOUTH AFRICAS NATIONAL FINANCIAL DAILY Acknowledging that communication has become critical to connecting people and doing business today, BusinessReport, with its readers, is daily readership of the most appropriate business and financial title, reaching by far the widest audience of shareholders and stakeholders, for whom your statement will be most relevant.
to be placed on measurement and verification, are areas in which companies can apply greater effort to entrench their capability in leading the way while at the same time sustaining their businesses. Based on the evolution of the process, the 2011 CDP report highlights that the next step in the journey is to encourage companies to move beyond identifying risks to risk mitigation. This includes strategic priorities and plans of implementation to incorporate identified opportunities. EN20), with a remarkably high degree of uptake among the 129 GRI-based reporters.
Indicator Uptake Rate GRI G3 Indicator EN16: otal direct and indirect T greenhouse gas emissions by weight. EN17: ther relevant indirect O greenhouse gas emissions by weight. EN18: nitiatives to reduce I greenhouse gas emissions and reductions achieved. EN19: missions of ozone-depleting E substances by weight. EN20: Ox, SOx and other N significant air emissions by type and weight. GRI Non-GRI All

935 000

61.7%

10.9%

28.8%

34.8%

3.2%

14.3%

How Much Carbon are we Emitting?

Although the information is far from comprehensive, due to the number of companies yet to disclose their carbon, this years review of GRI-based Annual, Integrated Annual and/or Sustainability reports identified a significant shift towards much more effective disclosure. Firstly, it should be noted that as a result of activities of the GRI-based reporters we reviewed in the Metals & Mining, Energy & Natural Resources and Banking & Financial Services sectors, a total of 395 154 357 tonnes of CO2e had been pumped into the atmosphere (see the table above). However, Eskom is responsible for a mind-numbing 58.3% of this carbon, while Sasol is responsible for 18.9%. Sadly, the available data does not yet include Sasols key competitors BP, Engen, Shell and Total (amongst others) and it is highly probable that the vast majority of Eskoms carbon has been double counted (in that all of the other 28 companies would report their carbon emissions resulting from their use of Eskoms electricity), but the data offers us an important baseline for future comparability, particularly in terms of who cares, or whos thinking strategically enough to prepare for a move towards a utopian model of a low carbon economy. In fairness, 29 is not actually the number of companies who reported their carbon, not even within the three sectors we specifically focused on. Rather, this is the number of companies within those sectors that provided comparable data. In some instances, like in the case of Sappi, meaningful carbon emission data is reported, but in a format that is only really relevant to a specific industry (i.e., Pulp & Paper). In other cases, companies opted to normalise their emissions by offering a tonnes per employee figure (or tonnes per employee hour worked), but then didnt provide the number of employees, thus making it impossible to determine the total carbon emitted. Nonetheless we were able to calculate surprising uptake rates for the set of GRI indicators pertaining to emissions (EN16 to
64

41.4% 21.9%

5.5% 0.9%

18.2% 8.3%

BusinessReport circulates daily within 4leading newspaper titles, The Star, Pretoria News, Cape Times and The Mercury,
and makes business news and reviews more relevant to more people in the South African economy. It is the best read (and most read business and financial daily newspaper in South Africa). By publishing your results in BusinessReport, of the almost you will reach more than readers of daily financial publications. Can your company afford not to be seen in he biggest daily financial publication in South Africa?

27.0%

0.9%

10.1%

Of the five emissions indicators, EN16 is the most pertinent, due to its general coverage in terms of CDP. Thus, it should be of little surprise that 85 of the 128 GRI-based reporting entities (66.4%) offered at least a guess at their total carbon emissions, while a further 29 companies reported a total CO2e figure, despite not applying the GRI Guidelines. The indicator uptake rate for EN16 amongst all reports was relatively high, at 28.8%, the 14th most widely reported performance indicator, and the second only to EN28 amongst the 30 environmental performance indicators.
NOTE

1.65 million

56%

EN28: Monetary value of significant fines and total number of non-monetary sanctions for non-compliance with environmental laws and regulations. The only other performance indicators with higher uptake rates were EC1, EC3, EC8, LA8, LA11, EC6, LA1, LA13, EC7, LA7, LA4 and SO8. (Please refer to Appendix IV for an explanation of each indicator.)

For your one stop communication solution, please contact Rudolph le Roux: (011) 639-7100 or rudolph.leroux@inl.co.za

At the risk of choosing sides, it may be worth noting that a few companies have set the bar for others to follow in terms of their carbon disclosures. For anyone starting out on the same path, or looking to improve their measurement and/or reporting, it might be worthwhile looking at the following companies reports: Altron A lthough a relatively new entrant in the CDP space (1st full submission), Altron has implemented a comprehensive carbon measurement toolkit, and has had their submission verified and assured. They have not yet set targets, but have stated commitments to do so. T hey have been reporting on CDP for five years and somehow manage to continuously improve their disclosure scores. They have implemented considerable reduction activities and are committed to their targets.

For those that have yet to join the throngs of companies doing the right thing, the following is a set of basic steps required to disclose ones carbon footprint, and thus to embark on creating carbon efficiencies. Sign up to the CDP, if for no other reason than to set an annual monitoring target for reporting against efficiency improvements. Establish systems for collecting Scope 1 and 2 emissions data, particularly fuels (e.g., diesel, petrol, coal, LPG, etc.) and electricity consumption data, as well as flight data for Scope 3 emissions. Establish a system to convert energy consumption data to tonnes of carbon dioxide equivalents (CO2e), using widely available carbon conversion factors for each type of energy used (or flight route flown). Ensure that data is verified, either by an internal resource (e.g., Internal Audit) or by a third party. Complete a submission to the CDP for review and publication, noting that an errant submission is far better than no submission, as any identified errors would merely allow for continuous learning and process improvement.

Clicks

Massmart eporting on CDP for four years and verifying their R reports. Perhaps more so than any other company, Massmart is achieving real reductions, especially in logistics, and are very humble (i.e., not riding the greenwash bandwagon). Oceana Group T hey have been reporting voluntarily for three years, and verifying their reports annually. They have set t argets and have aligned their strategies to meet their targets.

If all else fails hire a consultant!

As with most things in the realm of sustainability reporting, the tasks in and of themselves are not overly complicated and/or impossible to learn. Rather, the challenge within companies tends to be finding the time. Thus, there is an array of highly efficient carbon management specialists who can quickly, accurately and effectively complete a carbon footprint for any company (although the scope of the exercise would obviously differ with the size, complexity and/or nature of various businesses). For a list of experienced CDP practitioners in your area, refer to the IRAS database of Other Reporting Practitioners located at the back of this report, or on their website: www.iras.co.za.

The Basics of Carbon Disclosure

To date, there has been no documented case of a company attempting to measure yet unable to report its carbon emissions, and the only possible scenario under which a company might fail to do so is if theyve got one foot firmly entrenched in a liquidation grave. Even in the absence of effective environmental monitoring systems, or a dedicated environmental department, the information needed to produce a carbon footprint is almost always available via the GL (the General Ledger found in the Accountants office). Failing to produce a carbon footprint would be tantamount to determining how much money is currently spent on energy electricity, fuels, etc. and would signal a far gloomier forecast than the companys inability to reduce its carbon footprint: it would suggest that the company is on the brink of not having ANY footprint.

65

Integrated reporting
y bilit ainalting t Sus onsu c
Performance on indicators

Cre

ati desvity a ign nd

Con c des eptua ign l Pho t direograp ctio hic n Sty ling
DT P an

An n sta ual fi tem na en ncia ts l

F typ inan es cia ett l ing

one report, one palette

The way it used to be ...
Annual reports have always been tough to produce on time. The companys copy, investor relations input, agency management and design have to come together. But at least the formula used to be clear. The Companys Act, JSE requirements and GAAP were established protocols offering a clear formula. Besides, financial issues, being the bread and butter of your business, are the bread and butter of your report.

l eria Mat ues ss i se pon Res ategy str e anc form rs Per dicato in

Commentary on performance

Governance aspects

pr Ana es ly en st tat ion s

ma

no Res un ult ce s me nts

t gi llin er Pu geth to

t jec ent Pro gem na ma

n Tra n tio sla

assurance prep

Sty

ling

ffic ent Tra gem na

Pro ofr

t men age h Manpproac a

Our team offers leading companies the complete integrated annual report from cover to cover, from analyst presentation to detailed website. Our clients are among the best and our track record is solid this is what we do. Our business and sustainability expertise ...
If you want an integrated annual report, you need an integrated annual reporting team a palette of skills and experience found especially in Trialogue and GroundPepper. Our core expertise is sustainability reporting against King III and the GRI, and we do this with a strong background in business and management accounting. We talk the language of the CEO, not the activist.

ea din g

... has changed

With King III, the annual reporting world just became a lot more complex. Now, non-financial issues need to be integrated into company strategy and reporting. Corporate risks, legal demands and international standards pile on pressure. More complex, yes. And readers of your report can take in only so much. They still want to read a clear message that shows confidence in your companys long-term future.

... delivers cover to cover

Ingredients: ops reviews, accounts, stakeholder concerns, legal and regulatory risks Basic mix: material issues, folding in management, performance and commentary Underlined by: GRI tables, application of King III, preparation for assurance Delivered: print and web reports, results and analyst presentations Framed: winner of the 2011 Ernst & Young Excellence in Sustainability Reporting Awards*
* Reporting for Bidvest

CAPE TOWN OFFICE Block M, Greenford Office Park Punters Way Kenilworth, 7708 Tel: 021 671 1640 info@trialogue.co.za

JOHANNESBURG OFFICE 26 Baker Street Rosebank, 2196 Tel: 011 026 1308 www.trialogue.co.za

| Appendices

Appendix I: Inventory of South African GRI Reports

CFS Consolidated Financial Statements SDR Sustainable Development Report (+13) 2012 GRI Compliance Score (%) (+12) 2011 GRI Compliance Score (%) (+11) 2010 GRI Compliance Score (%) CGR Corporate Governance Report

(+13) 2012 GRI Compliance Rank

(+12) 2011 GRI Compliance Rank

Company Absa Group Adcock Ingram Adcorp AECI Afgri African Bank African Oxygen African Rainbow Minerals Altech Allied Technologies Altron Allied Electronics Anglo American plc Anglo Gold Ashanti Anglo American Platinum Aquarius Platinum Arcelor Mittal Aspen Pharmacare Assore Astral Foods Austro Group AVI Avusa Barloworld Basil Read Bidvest Blue Label Telecoms Brimstone Buildmax Business Connexion Cargo Carriers Clicks Group

Assured by PwC/EY Deloitte KPMG SustainabilityServices.co.za SustainabilityServices.co.za PKF SustainabilityServices.co.za PwC EY PwC

Type of assurance ISAE 3000 + AA1000 ISAE 3000 ISAE 3000 AA1000 Type I AA1000 Type II ISAE 3000 AA1000 Type II ISAE 3000 ISAE 3000 ISAE 3000

Year 2011 2011 2012 2011 2011 2011 2011 2011 2012 2012 2011 2011 2011 2011 2011 2011 2011 2011

X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X

B+ NC(B) ND ND C B+ ND A+ B+

ND

ND

72.3 43.5 44.7

60.2 31.1 24.4 43.3 50.0 61.8 61.4 82.3 68.1 68.9 86.6 85.0 83.5 56.3 54.3 64.2 42.9 37.4 15.7 18.9 30.3 61.0 41.3 61.0 54.3 58.7 18.5 33.5 15.4 36.2

59.4 37.8 31.1 44.9 39.0 47.2 73.2 65.0 43.3 54.3 83.1 85.8 89.4 48.8 44.9 53.5 36.6 39.4 24.8 35.4 31.1 82.7 32.7 59.8 48.0 24.8 27.2 38.6 22.4 48.4

33 99 94 86 40 13 126 7 27 16 11 24 10 57 49 50 87 66 121 135 46 4 81 48 98 47 113 141 101 114

40 116 148 81 67 32 33 13 26 24 7 8 9 50 57 30 83 99 282 224 118 36 88 37 58 42 229 110 286 103

NC ND ND ND B+ B B+ A+ A+ A+ C NC(B) C ND NC ND ND ND ND ND C A+ A+ A+ ND ND

47.0 69.2 84.6 37.5 90.9 75.9 81.8 88.5 77.5 88.5 58.5 64.4 62.5 46.6 54.2 38.3 36.4 66.4

X X X X X

B+ A+ A+ A+ NC(C) ND NC(B) C ND

PKF

ISAE 3000

2011 2011 2011

X X X X X

C+ ND NC(C) A+ NC(C) ND C+ ND C NC(C) C B+ NC B+ C+ NC ND ND B+ C+

Deloitte Deloitte PwC

ISAE 3000 ISAE 3000 ISAE 3000

2011 2011 2011 2011 2011 2011 2011 2012 2011

94.1 49.0 65.6 43.9 66.4 39.5 34.4 42.3

ND

ND

ND

39.5

68

(+11) 2010 GRI Compliance Rank 33 96 136 71 90 65 19 27 76 44 10 5 3 62 72 50 102 87 208 105 137 11 121 32 64 205 180 92 255 63

IAR Integrated Annual Report

(+13) 2012 Application Level

(+12) 2011 Application Level

(+11) 2010 Application Level

SR Sustainability Report

AR Annual Report

Web supported

Other

CFS Consolidated Financial Statements

SDR Sustainable Development Report

(+13) 2012 GRI Compliance Score (%)

(+12) 2011 GRI Compliance Score (%)

(+11) 2010 GRI Compliance Score (%)

CGR Corporate Governance Report

(+13) 2012 GRI Compliance Rank

(+12) 2011 GRI Compliance Rank

Company Comair Consolidated Infrastructure Group Cotlands Country Bird Delta EMD Denel Digicore Discovery Health Distell Distribution & Warehousing Network DRD Gold Eastern Platinum Efficient Group Eqstra Eskom Esorfranki Evraz Highveld Steel & Vanadium Exxarro Finbond FirstRand Group Foschini Gijima Gold Fields Grindrod Group Five Harmony Gold Holdsport Howden Africa Hudaco Industries Hyprop Investments Iliad Africa Illovo Sugar Impahla Clothing Impala Platinum

Assured by PKF PKF KPMG

Type of assurance ISAE 3000 ISAE 3000 ISAE 3000

Year 2011 2011 2011 2011 2011 2011

X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X

C+ NC(C+) ND ND ND ND C+ B NC(C) A NC(C) NC(B) C+ ND B+ C NC(C) B+ C ND ND NC(B) A+ B+ ND B+ ND C NC(C) ND NC(C) B+ ND B+ A+ B+ B+ B+ NC NC NC ND ND C A+ ND ND B+ B+ ND ND B+ ND ND C B+ B+ NC B+ ND B+ C C C B C C B+ B+

56.9 33.2 52.2 31.6 39.1 49.8 44.7 52.6 53.8 81.8 60.5 45.5 39.5 48.2 66.8 50.6 69.6 72.7 39.5 41.1 70.4 37.9 96.0 73.9 69.2 75.1 36.8 40.3 30.0 40.3 33.6 73.5 89.3 70.8

29.5 17.3 55.5 18.1 19.3 57.9 22.0 56.3 33.9 37.8 65.0 33.1 17.7 48.0 63.0 24.4 74.4 70.1 16.9 40.6 83.5 50.4 94.9 68.9 61.0 81.9 42.1 27.2 21.7 43.7 53.5 90.6 61.4

32.3 54.3 24.4 16.9 32.7 55.9 37.4 52.8 59.1 20.5 49.6 60.2 28.7 74.8 72.0 19.7 46.9 40.9 26.0 64.6 68.9 60.2 83.5 22.0 33.9 28.0 33.1 32.3 67.7 76.4

61 144 72 153 118 77 95 70 67 17 54 92 115 84 45 74 39 32 116 106 37 124 2 30 41 28 133 111 159 112 143 31 8 36

121 254 53 239 220 44 179 51 109 98 29 111 247 72 31 149 19 22 266 90 10 65 2 25 38 14 86 129 187 79 59 5 34

PKF

ISAE 3000

2011 2011 2011 2011 2011 2010

PKF KPMG

ISAE 3000 ISAE 3000 + AA1000

2011 2011 2012 2012 2011

PwC

ISAE 3000

2011 2012 2011 2011 2011

Maplecroft/KPMG Deloitte PwC PwC

ISAE 3000 + AA1000 ISAE 3000 ISAE 3000 ISAE 3000

2011 2011 2011 2011 2012 2011 2011 2011 2011

SustainabilityServices.co.za KPMG

AA1000 Type I ISAE 3000

2012 2012 2011

69

(+11) 2010 GRI Compliance Rank 128 45 216 343 123 41 98 51 37 280 61 31 164 17 20 293 67 83 194 28 24 30 9 260 111 173 118 126 25 15

IAR Integrated Annual Report

(+13) 2012 Application Level

(+12) 2011 Application Level

(+11) 2010 Application Level

SR Sustainability Report

AR Annual Report

Web supported

Other

| appendix I: Inventory of South african GrI reports continued

CFS Consolidated Financial Statements SDR Sustainable Development Report (+13) 2012 GRI Compliance Score (%) (+12) 2011 GRI Compliance Score (%) (+11) 2010 GRI Compliance Score (%) CGR Corporate Governance Report

(+13) 2012 GRI Compliance Rank

(+12) 2011 GRI Compliance Rank

Company Imperial Investec JD Group KayDav Keaton Energy Kumba Iron Ore Liberty Group* Life Healthcare Little Eden Lonmin Massmart Medi-Clinic Media24 Merafe Resources Metair Investments MMI Holdings Mondi Morvest Mpact MTN MultiChoice Murray & Roberts Nampak Naspers Nedbank Netcare Northam Platinum Omnia Onelogix Phumelela Gaming & Leisure Pretoria Portland Cement Primeserv PSV Rainbow Chicken Redefine Properties

Assured by

Type of assurance

Year 2011 2011 2011

X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X 70 X X X X X X X X X X

X X

C NC(B) ND C+ NC(C)

NC B C C B+

C B

56.5 42.7 70.4 29.6

59.1 55.5 70.9 11.0 39.8 57.5 76.8 37.0 93.3 82.7 52.8 27.2 61.4 20.1 15.0

55.9 59.1 37.8 16.1 29.9 70.5

62 100 38 163 119 12 35 128 20

41 54 20 375 93 45 17 102 3 11 60 130 35 211 300

PKF PwC PwC SustainabilityServices.co.za KPMG

ISAE 3000 ISAE 3000 ISAE 3000 + AA1000 Non-aligned ISAE 3000

2011 2011 2011 2011 2011 2012 2011 2011 2011 2011

ND B+

39.1 87.7 71.9 37.2 79.1

NC(A+) C+ B+ ND B+

X X

NC(A+) A+ ND NC(C) NC(C) B+ C+ ND ND ND B+

B+ ND ND C B+

94.1 79.1 62.1 54.9 74.7 45.5 49.4 81.0 46.2 48.6

85.4 73.6 52.4 38.2 84.6 21.3

5 21 51 64 29 93 79 18 89 83

SustainabilityServices.co.za SustainabilityServices.co.za ERM PKF

AA1000 Type II AA1000 Type I ISAE 3000 ISAE 3000

2011 2011 2011 2011 2011 2011 2011 2011

X X

C B+ C+ C NC(B) ND NC ND C NC A+ B+ NC ND NC C+ C C ND C C A+ C+ ND

67.6 49.4 52.6 58.5 50.6 78.7 76.7 79.8 44.7 41.5 84.6 54.9 46.2 59.7

81.9 39.4 55.9 57.5 37.0 67.3 41.7 81.9 49.2 38.6 52.0 57.1 22.4 18.5 55.5 22.4

31.9 29.9 58.3 59.1 37.0 69.3 50.4 64.2 44.5 23.6 23.6 65.7 33.1 21.7 50.8

44 80 71 58 75 23 25 19 96 105 14 65 90 55 73 102

15 94 52 46 100 28 87 16 69 95 63 48 173 233 55 175

NC(C) B+ C NC(C)

Deloitte

ISAE 3000

2011 2011 2011

KPMG / Deloitte ERM

ISAE 3000 + AA1000 AA1000 Type II

2011 2011 2011 2011 2011 2011

X X

A+ B B+ NC(C) C C

Deloitte SustainabilityServices.co.za

ISAE 3000 Non-aligned

2011 2011 2011 2011 2011

C+ ND C+

ND ND

NC

ND

51.8 42.3

(+11) 2010 GRI Compliance Rank 42 34 97 352 152 21 6 18 53 93 8 270 131 151 38 36 100 23 58 29 73 231 233 26 119 263 55

IAR Integrated Annual Report

(+13) 2012 Application Level

(+12) 2011 Application Level

(+11) 2010 Application Level

SR Sustainability Report

AR Annual Report

Web supported

Other

CFS Consolidated Financial Statements

SDR Sustainable Development Report

(+13) 2012 GRI Compliance Score (%)

(+12) 2011 GRI Compliance Score (%)

(+11) 2010 GRI Compliance Score (%)

CGR Corporate Governance Report

(+13) 2012 GRI Compliance Rank

(+12) 2011 GRI Compliance Rank

Company Reunert Richards Bay Minerals Royal Bafokeng Platinum Sanlam Santam Sappi Sasfin Sasol Silverbridge Soweto Marimba Youth League Standard Bank Stefanutti Stocks Sun International Telkom Tongaat Hulett Top Fix Holdings Transnet Truworths Umgeni Water Value Group Verimark Vodacom Wesizwe Platinum Wilderness Wilson Bayly Homes-Ovcon Witwatersrand Consolidated Gold Woolworths Workforce Xstrata South Africa

Assured by

Type of assurance

Year 2011 2011

X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X

X X

ND NC(C) B+ B+ B

ND B+ B+ B A A+ B ND A A+

48.2 36.8 68.0 82.6 62.1 93.3 41.9 99.6 22.9 55.7

45.3 57.1 60.6 52.8 87.4 21.7 99.6 18.9 76.4 29.1 43.7 35.4 57.5 14.6 37.0 42.5 52.0 12.2 49.2 28.3 24.0 31.5 22.0 58.7 19.3 68.1

33.5

85 134 43

77 49 39 61 6 190 1 228 18 124 80 107 47 307 101 84 64 352 70 125 159 115 184 43 222 27

PwC EY

ISAE 3000 ISAE 3000

2011 2011 2011 2011 2011

57.9 39.4 79.5 25.2 94.9 21.3 79.1 31.1 42.9 42.9 43.7 23.6 54.3 46.1 50.4 26.4 18.5 43.7 33.9 37.8 22.4 54.3 24.8

15 52 6 103 1 210 63 22 125 26 68 42 164 60 129 53 88 120 59 82 3 91 69 34 130 9

X X

A C A+ NC(C) C

PwC

ISAE 3000

2011 2011 2011

KPMG SustainabilityServices.co.za Nkonki SustainabilityServices.co.za

AA1000 Type II AA1000 Type II ISAE 3000 AA1000 Type I

2011 2011 2011 2011 2012 2011 2011 2011 2011 2011 2011 2011 2011

X X X

B+ C B+ C+ B+ NC(C)

B+ C+ ND C+ ND ND NC

B+

79.1 37.9 76.3

ND

53.4 68.8 29.6

X X

C ND NC(B) C ND

ND ND C

58.1 37.2 62.1 46.6 39.1

NC(B) NC(C) B+ C C

58.5 49.0 94.9 46.2 53.0

SustainabilityServices.co.za

Non-aligned

2011 2011 2011

EY SustainabilityServices.co.za

ISAE 3000 AA1000 Type II

2011 2011 2010

NC(B+) ND NC(C) B+ B+

72.3 37.2 88.9

71

(+11) 2010 GRI Compliance Rank 115 39 86 13 201 1 276 14 135 77 78 74 229 47 69 57 190 325 75 112 95 250 46 206

IAR Integrated Annual Report

(+13) 2012 Application Level

(+12) 2011 Application Level

(+11) 2010 Application Level

SR Sustainability Report

AR Annual Report

Web supported

Other

Appendix II: Index of Non-GRI-Based Reporting Companies

Company 1Time Holdings Ltd Accentuate Ltd Acucap Properties Ltd Adapt IT Holdings Ltd Adrenna Property Group Limited ADvTECH Africa Cellular Towers African and Overseas Enterprises African Brick Centre Ltd African Dawn Capital Ltd African Media Entertainment Afrimat Ltd Afrocentric AH-Vest Ltd Alert Steel Holdings Ltd Alexander Forbes Amalgamated Appliance Holdings Ltd Amalgamated Electronic Corporation Ltd Andulela Investment Holdings Ltd Ansys Ltd ARB Holdings Ltd Argent Industrial Ltd Astrapak Ltd Aveng Ltd Awethu Breweries Ltd B&W Instrumentation & Electrical Ltd Bauba Platinum Ltd Beige Holdings Ltd Bell Equipment Ltd Bioscience Brands Ltd BK one Blue Financial Services Bowler Metcalf Ltd Brait S.A. Brikor Ltd BSI Steel Ltd Cadiz Holdings Ltd Cafca Ltd Calgro M3 Holdings Ltd Capevin Investments Ltd Capital & Counties Properties Capital Property Fund Rank 333 233 261 107 245 205 251 239 323 288 324 151 199 257 273 165 169 227 252 228 166 258 154 108 359 131 206 160 186 229 262 253 215 181 230 195 231 278 172 342 216 291 Company Capitec Bank Holdings Ltd Cashbuild Ltd Caxton CTP Ltd Central Rand Gold Ltd Ceramic Industries Ltd Chamber of Mines Chemical Specialities Ltd Chrometco Ltd City Lodge Hotels Ltd Clientele Ltd Clover Industries Ltd Coal of Africa Ltd Combined Motor Holdings Ltd Compu Clearing Outsourcing Ltd Conduit Capital Ltd Control Instruments Group ConvergeNet Holdings Ltd Coronation Fund Managers Ltd Crookes Brothers Ltd Cullinan Holdings Curro Holdings Ltd Datacentrix Holdings Ltd Datatec Ltd Diamondcorp Dipula Income Fund Ltd Don Group Ltd Dorbyl Ltd ELB Group Ltd Ellies Holdings Ltd Emira Property Fund EOH Holdings Ltd Erbacon Investment Holdings Ltd Excellerate Holdings Ltd Fairvest Property Holdings Famous Brands Ltd Firestone Energy Ltd First Uranium Corporation Foneworx Holdings Ltd Foord Compass Ltd Fortress Income Fund Ltd Fountainhead Property Trust Gold One International Ltd Rank 122 306 211 217 137 355 145 334 167 237 146 222 249 269 263 147 301 234 264 218 178 240 182 296 279 343 307 292 308 235 173 219 325 293 250 360 241 220 362 328 200 274 Company Goliath Gold Mining Ltd Gooderson Leisure Corporation Grand Parade Investments Ltd Growthpoint Properties Ltd Hardware Warehouse Ltd Hosken Consolidated Investments Ltd Hospitality Property Fund Huge Group Ltd Hulamin Ltd Hwange Colliery Ltd Ideco Group Ltd IFA Hotels and Resorts Imuniti Independent Power Southern Africa (IPSA Group) Indequity Group Ltd Industrial Development Corporation (IDC) Infrasors Holdings Ltd Ingenuity Property Investments Ltd Insimbi Refractory and Alloys Supplies Ltd Intertrading Ltd Interwaste Holdings Ltd Invicta Holdings Ltd Iquad Group Ltd ISA Holdings Ltd Italtile Ltd Jasco Electronics Holdings John Daniel Holdings Ltd JSE Ltd Jubilee Platinum Kagiso Media Ltd Kelly Group Ltd Kibo Mining KWV Holdings Ltd Labat Africa Ltd Lewis Group Ltd Litha Healthcare Group Ltd London Finance & Investment Group Masonite Africa Ltd Mazor Group Ltd Mercantile Bank Holdings Ltd Metmar Ltd Metrofile Holdings Ltd Rank 297 309 212 139 318 157 123 280 110 254 361 223 311 319 320 201 275 335 187 344 282 224 302 310 207 202 329 170 259 184 174 350 265 321 127 176 347 152 185 198 246 283

72

Company Micromega Holdings Ltd Mine Waste Solutions Ltd Miranda Mineral Holdings Mix Telematics Ltd Money Web Holdings Ltd Mr Price Group Ltd Mustek Ltd Mvelaphanda Group Ltd Mvelaserve Ltd Net 1 UEPS Technologies Inc New Africa Investments Ltd New Corpcapital Ltd Nictus Beperk Nutritional Holdings Nu-World Holdings Ltd Oasis Crescent Property Fund Oceana Group Ltd Octodec Investments Ltd O-Line Holdings Ltd Optimum Coal Holdings Ltd Orion Real Estate Ltd Palabora Mining Company Pallinghurst Resources Ltd Pan African Resource PBT Group Ltd Peregrine Holdings Ltd Petmin Ltd Pick n Pay Pinnacle Technology Holdings Ltd Pioneer Foods Group Ltd Platfields Ltd Poynting Holdings Ltd Premium Properties Ltd Protech Khuthele Holdings Ltd PSG Group Limited Purple Capital Ltd Putprop Ltd Quantum Property Group Ltd Racec Group Ltd Rand Merchant Insurance Holdings Limited Randgold & Exploration Company Ltd Rare Holdings Ltd

Rank 158 363 330 213 348 140 214 303 191 326 336 357 345 203 208 349 97 192 136 56 337 109 312 155 315 138 221 132 242 179 238 289 338 183 281 276 266 304 270 188 271 305

Company Raubex Group Ltd RBA Holdings Ltd Real Africa Holdings Ltd Rebosis Property Fund Ltd RECM & Calibre Ltd Reinet Investments Remgro Ltd Resilient Property Income Fund Ltd Resource Generation Ltd Rex Trueform Clothing Company Ltd RGT SMART Market Intelligence Ltd Richards Bay Coal Terminals RMB Holdings Ltd Rockwell Diamonds Incorporated Rolfes Technology Holdings Ltd SA Corporate Real Estate Fund SA French Ltd Sable Holdings Ltd Sabvest Ltd Sacoil Holdings Ltd Santova Logistics Ltd Sanyati Holdings Ltd Sea Kay Holdings Ltd Seardel Investment Corporation Ltd Securedata Holdings Ltd Sekunjalo Investments Ltd Sentula Mining Ltd Senwes Sephaku Holdings Ltd Shoprite Holdings Ltd Simmer & Jack Mines Ltd Skinwell Holdings Ltd South Ocean Holdings Ltd Southern Electricity Company (SELCo) Sovereign Food Investments Ltd Spanjaard Ltd Spar Group Ltd Spur Corporation Ltd Steinhoff International Holdings Stella Vista Technologies Ltd Stratcorp Ltd Super Group Ltd

Rank 189 225 339 255 352 313 76 284 331 247 267 148 180 353 142 168 340 351 285 341 256 243 356 332 346 190 104 177 196 294 286 295 161 268 175 260 162 232 78 358 204 156

Company Sycom Property Fund Taste Holdings Ltd Telemasters Holdings Ltd Thabex Ltd Tiger Brands Ltd Total Client Services Ltd Tradehold Ltd Trans Hex Group Ltd Transpaco Ltd Trematon Capital Investments Ltd Trencor Ltd Trustco Group Holdings Ltd Ububele Holdings Ltd Village Main Reef Gold Mining Company Vividend Income Fund Ltd Vukile Property Fund Ltd Vunani Property Investment Fund Ltd W G Wearne Ltd Wescoal Holdings Ltd William Tell Holdings Ltd Winhold Ltd York Timber Holdings Ltd ZCI Ltd Zeder Investments Ltd Zurich Insurance Company SA

Rank 314 193 322 316 117 287 327 150 149 354 248 298 299 197 226 209 317 290 272 300 171 194 236 277 244

73

Governance, Commitments & Engagement (10 Indicators)

Commitment to External Initiatives (3 Indicators)

Management Approach Disclosures (6 Indicators)

Emissions, Effluent & Waste (10 Indicators)

Labour/Management Relations (2 Indicators)

Investment & Procurement Practices (3 Indicators)

Occupational Health & Safety (4 Indicators)

Diversity & Equal Opportunity (2 Indicators)

Indirect Economic Aspects (2 Indicators)

Stakeholder Engagement (4 Indicators)

Economic Performance (4 Indicators)

Organisational Profile (10 Indicators)

Strategy & Analysis (2 Indicators)

Scope & Boundary (7 Indicators)

Products & Services (2 Indicators)

Training & Education (3 Indicators)

GRI Content Index (1 Indicator)

Market Presence (3 Indicators)

Non-discrimination (1 Indicator)

Freedom of Association (1 Indicator)

Report Profile (4 Indicators)

Employment (3 Indicators)

Forced Labour (1 Indicator)

Biodiversity (5 Indicators)

Child Labour (1 Indicator)

Public Policy (2 Indicators)

Customer Privacy (1 Indicator)

Compliance (1 Indicator)

Community (1 Indicator)

Assurance (1 Indicator)

Materials (2 Indicators)

Energy (5 Indicators)

Water (3 Indicators)

Transport (1 Indicator)

A reasonable response = 2 of 2 A partial response = 1 of 2 No response = 0 of 2

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Sasol Gold Fields Wilderness Barloworld* Lonmin Sappi African Rainbow Minerals Impahla Clothing Xstrata South Africa Anglo American Platinum Anglo American plc Kumba Iron Ore African Bank Phumelela Gaming & Leisure Sanlam Altron Distribution & Warehousing Network Mondi Northam Platinum Little Eden Massmart Standard Bank Nedbank Anglo Gold Ashanti Netcare Sun International Altech Harmony Gold Merafe Resources Grindrod

A+ A+ B+ A+ A A+ ND B+ A+ A+ B+ C B+ B+ A B+ B+ B+ ND B+ A+ A+ B B+ B+ B+ B+ B+

99.6 99.6 94.9 96.0 94.9 64.6 94.9 24.0

94.1 61.0 82.7 93.3 87.4 79.5 90.9 82.3 65.0 89.3 90.6 67.7 88.9 68.1

NC(A+) 94.1 93.3 85.4

88.5 83.5 89.4 88.5 86.6 83.1

NC(A+) 87.7 57.5

84.6 61.8 47.2 84.6 52.0 23.6 82.6 60.6 57.9 81.8 68.9 54.3 81.8 37.8 52.8 81.0 79.1

79.8 81.9 64.2 79.1 82.7 73.6 79.1 76.4 79.1 78.7 67.3 69.3 77.5 85.0 85.8 76.7 41.7 50.4 76.3 43.7 42.9 75.9 68.1 43.3 75.1 81.9 83.5 74.7 61.4 84.6 73.9 68.9 68.9

74

Overall (1 Indicator)

Corruption (3 Indicators)

Compliance (1 Indicator)

Compliance (1 Indicator)

GRI application level

*With apologies, our assessment of Barloworlds report in 2011 did not include web-based information.

Security Practices (1 Indicator)

Indigenous Rights (1 Indicator)

Anti-Competitive Behaviour (1 Indicator)

Customer Health & Safety (2 Indicators)

Product & Service Labelling (3 Indicators)

Marketing & Communications (2 Indicators)

Appendix III: Our Ranking of GRI Compliance

GRI +13 Compliance Score (%) GRI +12 Compliance Score (%) GRI +11 Compliance Score (%)

Profile Disclosures

Economic

Environment

Labour

Human Rights

Social

Product Responsibility

Profile Disclosures Governance, Commitments & Engagement (10 Indicators)

Economic

Environment

Labour

Human Rights

Social

Product Responsibility

Commitment to External Initiatives (3 Indicators)

Management Approach Disclosures (6 Indicators)

Emissions, Effluent & Waste (10 Indicators)

Labour/Management Relations (2 Indicators)

Investment & Procurement Practices (3 Indicators)

Occupational Health & Safety (4 Indicators)

Diversity & Equal Opportunity (2 Indicators)

Indirect Economic Aspects (2 Indicators)

Stakeholder Engagement (4 Indicators)

Economic Performance (4 Indicators)

Organisational Profile (10 Indicators)

Strategy & Analysis (2 Indicators)

Scope & Boundary (7 Indicators)

Products & Services (2 Indicators)

Training & Education (3 Indicators)

GRI Content Index (1 Indicator)

Market Presence (3 Indicators)

Non-discrimination (1 Indicator)

Freedom of Association (1 Indicator)

Security Practices (1 Indicator)

Indigenous Rights (1 Indicator)

Anti-Competitive Behaviour (1 Indicator)

Customer Health & Safety (2 Indicators)

Product & Service Labelling (3 Indicators)

Marketing & Communications (2 Indicators)

GRI +13 Compliance Score (%)

GRI +12 Compliance Score (%)

GRI +11 Compliance Score (%)

Report Profile (4 Indicators)

Employment (3 Indicators)

Forced Labour (1 Indicator)

Biodiversity (5 Indicators)

Child Labour (1 Indicator)

Public Policy (2 Indicators)

Customer Privacy (1 Indicator)

Compliance (1 Indicator)

Community (1 Indicator)

Assurance (1 Indicator)

Materials (2 Indicators)

Energy (5 Indicators)

Water (3 Indicators)

Transport (1 Indicator)

A reasonable response = 2 of 2 A partial response = 1 of 2 No response = 0 of 2

31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 Illovo Sugar Exxarro Absa Group Woolworths Liberty Impala Platinum Foschini JD Group Evraz Highveld Steel & Vanadium Afgri Group Five Tongaat Hulett Royal Bafokeng Platinum MTN Eskom Avusa Brimstone Bidvest Arcelor Mittal Aspen Pharmacare Mediclinic Santam Umgeni Water DRD Gold PSV Holdings Optimum Coal Aquarius Platinum Nampak Vodacom Transnet

B+ B+ B+ B+ B+ ND ND NC(C) C ND B+ B+ NC(B) B+ NC(C) ND ND ND NC(B) NC(C) B NC(B) NC(C) C+ NC(C) C NC(B) C

73.5 53.5 32.3 72.7 70.1 72.0 72.3 60.2 59.4 71.9 76.8 70.5 70.8 61.4 76.4 70.4 83.5 40.9 70.4 70.9 37.8 69.6 74.4 74.8 69.2 50.0 39.0 69.2 61.0 60.2 68.8 57.5 43.7 68.0 57.1

NC(B+) 72.3 58.7 54.3

67.6 81.9 31.9 66.8 63.0 60.2 66.4 30.3 31.1 66.4 58.7 24.8 65.6 61.0 59.8 64.4 54.3 44.9 62.5 64.2 53.5 62.1 52.8 52.4 62.1 52.8 39.4 62.1 52.0 50.4 60.5 65.0 59.1 59.7 18.5 21.7 59.3 22.8

58.5 56.3 48.8 58.5 57.5 59.1 58.5 49.2 43.7 58.1 37.0 54.3

75

Overall (1 Indicator)

Corruption (3 Indicators)

Compliance (1 Indicator)

Compliance (1 Indicator)

GRI application level

| appendix III: Our ranking of GrI compliance continued

Profile Disclosures Governance, Commitments & Engagement (10 Indicators) Economic Environment Labour Human Rights Social Product Responsibility

Commitment to External Initiatives (3 Indicators)

Management Approach Disclosures (6 Indicators)

Emissions, Effluent & Waste (10 Indicators)

Labour/Management Relations (2 Indicators)

Investment & Procurement Practices (3 Indicators)

Occupational Health & Safety (4 Indicators)

Diversity & Equal Opportunity (2 Indicators)

Indirect Economic Aspects (2 Indicators)

Stakeholder Engagement (4 Indicators)

Economic Performance (4 Indicators)

Organisational Profile (10 Indicators)

Strategy & Analysis (2 Indicators)

Scope & Boundary (7 Indicators)

Products & Services (2 Indicators)

Training & Education (3 Indicators)

GRI Content Index (1 Indicator)

Market Presence (3 Indicators)

Non-discrimination (1 Indicator)

Freedom of Association (1 Indicator)

Security Practices (1 Indicator)

Indigenous Rights (1 Indicator)

Anti-Competitive Behaviour (1 Indicator)

Customer Health & Safety (2 Indicators)

Product & Service Labelling (3 Indicators)

Marketing & Communications (2 Indicators)

GRI +13 Compliance Score (%)

GRI +12 Compliance Score (%)

GRI +11 Compliance Score (%)

Report Profile (4 Indicators)

Employment (3 Indicators)

Forced Labour (1 Indicator)

Biodiversity (5 Indicators)

Child Labour (1 Indicator)

Public Policy (2 Indicators)

Customer Privacy (1 Indicator)

Compliance (1 Indicator)

Community (1 Indicator)

Assurance (1 Indicator)

Materials (2 Indicators)

Energy (5 Indicators)

Water (3 Indicators)

Transport (1 Indicator)

A reasonable response = 2 of 2 A partial response = 1 of 2 No response = 0 of 2

61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 77 78 79 80 81 82 83 84 85 86 87 88 89 90 Comair Imperial Soweto Marimba Youth League Media24 Pretoria Portland Cement Astral Foods Distell Telkom Witwatersrand Consolidated Gold Discovery Murray & Roberts Cotlands Rainbow Chicken Esorfranki Naspers Remgro Denel Steinhoff International MMI MultiChoice Basil Read Wesizwe Platinum Mpact Eqstra Reunert AECI Assore Value Group Morvest Primeserv C C C

C+

56.9 29.5 32.3 56.5 59.1 55.9 55.7

NC(C) C+ ND NC(C) C+ C B B+ ND ND C NC(C) ND

54.9 27.2 38.2 54.9 57.1 65.7 54.2 37.4 39.4 53.8 33.9 37.4 53.4 35.4 42.9 53.0 22.0 22.4 52.6 56.3 55.9 52.6 55.9 58.3 52.2 55.5 54.3 51.8 55.5 50.8 50.6 24.4 28.7 50.6 37.0 37.0 50.2 22.0 32.3 49.8 57.9 49.4 15.0

49.8 38.6 47.2 NC(C) NC(C) NC(C) C ND ND ND C C C+ ND 49.4 39.4 29.9 49.0 41.3 32.7 49.0 28.3 33.9 48.6

48.2 48.0 49.6 48.2 45.3 33.5 47.0 43.3 44.9 46.6 42.9 36.6 46.6 46.2 26.4

46.2 22.4 33.1

76

Overall (1 Indicator)

Corruption (3 Indicators)

Compliance (1 Indicator)

Compliance (1 Indicator)

GRI application level

Profile Disclosures Governance, Commitments & Engagement (10 Indicators)

Economic

Environment

Labour

Human Rights

Social

Product Responsibility

Commitment to External Initiatives (3 Indicators)

Management Approach Disclosures (6 Indicators)

Emissions, Effluent & Waste (10 Indicators)

Labour/Management Relations (2 Indicators)

Investment & Procurement Practices (3 Indicators)

Occupational Health & Safety (4 Indicators)

Diversity & Equal Opportunity (2 Indicators)

Indirect Economic Aspects (2 Indicators)

Stakeholder Engagement (4 Indicators)

Economic Performance (4 Indicators)

Organisational Profile (10 Indicators)

Strategy & Analysis (2 Indicators)

Scope & Boundary (7 Indicators)

Products & Services (2 Indicators)

Training & Education (3 Indicators)

GRI Content Index (1 Indicator)

Market Presence (3 Indicators)

Non-discrimination (1 Indicator)

Freedom of Association (1 Indicator)

Security Practices (1 Indicator)

Indigenous Rights (1 Indicator)

Anti-Competitive Behaviour (1 Indicator)

Customer Health & Safety (2 Indicators)

Product & Service Labelling (3 Indicators)

Marketing & Communications (2 Indicators)

GRI +13 Compliance Score (%)

GRI +12 Compliance Score (%)

GRI +11 Compliance Score (%)

Report Profile (4 Indicators)

Employment (3 Indicators)

Forced Labour (1 Indicator)

Biodiversity (5 Indicators)

Child Labour (1 Indicator)

Public Policy (2 Indicators)

Customer Privacy (1 Indicator)

Compliance (1 Indicator)

Community (1 Indicator)

Assurance (1 Indicator)

Materials (2 Indicators)

Energy (5 Indicators)

Water (3 Indicators)

Transport (1 Indicator)

A reasonable response = 2 of 2 A partial response = 1 of 2 No response = 0 of 2

91 92 93 94 95 96 97 98 99 Wilson Bayly Homes-Ovcon Eastern Platinum Metair Investments Adcorp Digicore Omnia Oceana Group Blue Label Telecoms Adcock Ingram C

46.2 31.5 37.8 45.5 33.1

NC(B) C+ ND C+ NC(C) C+ NC(B) NC(B) C ND C C ND

45.5 20.1 21.3 44.7 24.4 31.1 44.7 22.0 32.7 44.7 49.2 44.5 44.3 52.4 54.7 43.9 54.3 48.0 43.5 31.1 37.8 42.7 55.5 59.1 42.3 15.4 22.4 42.3 22.4

100 Investec 101 Cargo Carriers 102 Redefine Properties 103 Sasfin 104 Sentula Mining 105 OneLogix 106 FirstRand Group 107 Adapt IT 108 Aveng 109 Palabora Mining Company 110 Hulamin 111 Howden Africa 112 Hyprop Investments 113 Buildmax 114 Clicks Group 115 Efficient Group 116 Finbond 117 Tiger Brands 118 Delta EMD 119 Keaton Energy 120 Verimark

41.9 21.7 25.2 41.9 40.6 28.0 41.5 38.6 23.6 41.1 40.6 46.9 41.1 26.0 22.4 41.1 40.9 42.5 41.1 35.8 42.9 40.7 46.5 39.0

C ND C ND C+ C ND NC(C) ND

40.3 42.1 22.0 40.3 21.7 28.0 39.5 18.5 27.2 39.5 36.2 48.4 39.5 17.7 20.5 39.5 16.9 19.7 39.5 21.7 31.9 39.1 19.3 16.9 39.1 39.8 29.9 39.1 12.2 18.5

77

Overall (1 Indicator)

Corruption (3 Indicators)

Compliance (1 Indicator)

Compliance (1 Indicator)

GRI application level

| appendix III: Our ranking of GrI compliance continued

Profile Disclosures Governance, Commitments & Engagement (10 Indicators) Economic Environment Labour Human Rights Social Product Responsibility

Commitment to External Initiatives (3 Indicators)

Management Approach Disclosures (6 Indicators)

Emissions, Effluent & Waste (10 Indicators)

Labour/Management Relations (2 Indicators)

Investment & Procurement Practices (3 Indicators)

Occupational Health & Safety (4 Indicators)

Diversity & Equal Opportunity (2 Indicators)

Indirect Economic Aspects (2 Indicators)

Stakeholder Engagement (4 Indicators)

Economic Performance (4 Indicators)

Organisational Profile (10 Indicators)

Strategy & Analysis (2 Indicators)

Scope & Boundary (7 Indicators)

Products & Services (2 Indicators)

Training & Education (3 Indicators)

GRI Content Index (1 Indicator)

Market Presence (3 Indicators)

Non-discrimination (1 Indicator)

Freedom of Association (1 Indicator)

Security Practices (1 Indicator)

Indigenous Rights (1 Indicator)

Anti-Competitive Behaviour (1 Indicator)

Customer Health & Safety (2 Indicators)

Product & Service Labelling (3 Indicators)

Marketing & Communications (2 Indicators)

GRI +13 Compliance Score (%)

GRI +12 Compliance Score (%)

GRI +11 Compliance Score (%)

Report Profile (4 Indicators)

Employment (3 Indicators)

Forced Labour (1 Indicator)

Biodiversity (5 Indicators)

Child Labour (1 Indicator)

Public Policy (2 Indicators)

Customer Privacy (1 Indicator)

Compliance (1 Indicator)

Community (1 Indicator)

Assurance (1 Indicator)

Materials (2 Indicators)

Energy (5 Indicators)

Water (3 Indicators)

Transport (1 Indicator)

A reasonable response = 2 of 2 A partial response = 1 of 2 No response = 0 of 2

121 Austro Group 122 Capitec Bank 123 Hospitality Property Fund 124 Gijima 125 Stefanutti Stocks 126 African Oxygen 127 Lewis Group 128 Life Healthcare 129 Truworths 130 Workforce 131 B&W Instrumentation & Electrical 132 Pick n Pay 133 Holdsport 134 Richards Bay Minerals 135 AVI 136 O-Line 137 Ceramic Industries 138 Peregrine 139 Growthpoint Properties 140 Mr Price Group 141 Business Connexion 142 Rolfes Technology 143 Iliad Africa 144 Consolidated Infrastructure Group 145 Chemical Specialities 146 Clover Industries 147 Control Instruments Group 148 Richards Bay Coal Terminals 149 Transpaco 150 Trans Hex Group

C+

38.3 15.7 24.8 38.3 35.4 28.0 38.3 24.4 28.0

NC(B) C ND ND ND NC(C)

37.9 50.4 26.0 37.9 29.1 31.1 37.5 61.4 73.2 37.5 26.8 27.2 37.2 37.0

37.2 42.5 46.1 37.2 19.3 24.8 37.2 25.2 32.7 37.2 30.3 40.6

ND NC(C) ND

36.8 36.8 36.4 18.9 35.4 36.4 27.2 28.0 36.0 26.0 33.9 35.6 12.2 26.4 35.2 38.2 30.3 34.8 26.8 33.1

NC(C) NC(C)

34.4 33.5 38.6 34.4 24.0 28.0 33.6 43.7 33.1 33.2 21.3 22.0 33.2 29.1 30.7 33.2 20.1 17.7 32.8 44.5 32.8 17.3 28.0 32.4 29.9 25.2

NC(C+) 33.2 17.3

Overall (1 Indicator)

Corruption (3 Indicators)

Compliance (1 Indicator)

78

Compliance (1 Indicator)

GRI application level

Profile Disclosures Governance, Commitments & Engagement (10 Indicators)

Economic

Environment

Labour

Human Rights

Social

Product Responsibility

Commitment to External Initiatives (3 Indicators)

Management Approach Disclosures (6 Indicators)

Emissions, Effluent & Waste (10 Indicators)

Labour/Management Relations (2 Indicators)

Investment & Procurement Practices (3 Indicators)

Occupational Health & Safety (4 Indicators)

Diversity & Equal Opportunity (2 Indicators)

Indirect Economic Aspects (2 Indicators)

Stakeholder Engagement (4 Indicators)

Economic Performance (4 Indicators)

Organisational Profile (10 Indicators)

Strategy & Analysis (2 Indicators)

Scope & Boundary (7 Indicators)

Products & Services (2 Indicators)

Training & Education (3 Indicators)

GRI Content Index (1 Indicator)

Market Presence (3 Indicators)

Non-discrimination (1 Indicator)

Freedom of Association (1 Indicator)

Security Practices (1 Indicator)

Indigenous Rights (1 Indicator)

Anti-Competitive Behaviour (1 Indicator)

Customer Health & Safety (2 Indicators)

Product & Service Labelling (3 Indicators)

Marketing & Communications (2 Indicators)

GRI +13 Compliance Score (%)

GRI +12 Compliance Score (%)

GRI +11 Compliance Score (%)

Report Profile (4 Indicators)

Employment (3 Indicators)

Forced Labour (1 Indicator)

Biodiversity (5 Indicators)

Child Labour (1 Indicator)

Public Policy (2 Indicators)

Customer Privacy (1 Indicator)

Compliance (1 Indicator)

Community (1 Indicator)

Assurance (1 Indicator)

Materials (2 Indicators)

Energy (5 Indicators)

Water (3 Indicators)

Transport (1 Indicator)

A reasonable response = 2 of 2 A partial response = 1 of 2 No response = 0 of 2

151 Afrimat 152 Masonite Africa 153 Country Bird 154 Astrapak 155 Pan African Resource 156 Super Group 157 Hosken Consolidated Investments 158 Micromega 159 Hudaco Industries 160 Beige 161 South Ocean 162 Spar Group 163 KayDav 164 Top Fix Holdings 165 Alexander Forbes 166 ARB 167 City Lodge Hotels 168 SA Corporate Real Estate Fund 169 Amalgamated Appliance Holdings 170 JSE 171 Winhold 172 Calgro M3 173 EOH 174 Kelly Group 175 Sovereign Food Investments 176 Litha Healthcare Group 177 Senwes 178 Curro Holdings 179 Pioneer Foods Group 180 RMB

32.0 28.0 29.1 32.0 16.1 22.0 ND 31.6 18.1 24.4 31.6 31.9 28.7 30.8 23.2 23.6 30.8 17.3 29.1 30.4 18.9 18.9 30.4 17.3 26.8 NC(C) 30.0 27.2 33.9 30.0 17.7 24.0 30.0 24.8 30.7 30.0 31.5 36.6 C+ NC(C) 29.6 11.0 16.1 29.6 14.6 23.6 29.6 26.0 33.1 29.6 28.0 29.1 29.6 22.0 33.5 29.6 22.4 28.0 29.2 20.9 27.6 29.2 24.4 37.0 28.5 19.7 18.9 28.1 17.3 20.9 28.1 18.5 22.8 28.1 29.1 32.3 28.1 24.0 21.3

27.3 27.3 27.6 24.0 27.3 20.1 51.2

27.7 13.0 27.7 35.8

Overall (1 Indicator)

Corruption (3 Indicators)

Compliance (1 Indicator)

79

Compliance (1 Indicator)

GRI application level

| appendix III: Our ranking of GrI compliance continued

Profile Disclosures Governance, Commitments & Engagement (10 Indicators) Economic Environment Labour Human Rights Social Product Responsibility

Commitment to External Initiatives (3 Indicators)

Management Approach Disclosures (6 Indicators)

Emissions, Effluent & Waste (10 Indicators)

Labour/Management Relations (2 Indicators)

Investment & Procurement Practices (3 Indicators)

Occupational Health & Safety (4 Indicators)

Diversity & Equal Opportunity (2 Indicators)

Indirect Economic Aspects (2 Indicators)

Stakeholder Engagement (4 Indicators)

Economic Performance (4 Indicators)

Organisational Profile (10 Indicators)

Strategy & Analysis (2 Indicators)

Scope & Boundary (7 Indicators)

Products & Services (2 Indicators)

Training & Education (3 Indicators)

GRI Content Index (1 Indicator)

Market Presence (3 Indicators)

Non-discrimination (1 Indicator)

Freedom of Association (1 Indicator)

Security Practices (1 Indicator)

Indigenous Rights (1 Indicator)

Anti-Competitive Behaviour (1 Indicator)

Customer Health & Safety (2 Indicators)

Product & Service Labelling (3 Indicators)

Marketing & Communications (2 Indicators)

GRI +13 Compliance Score (%)

GRI +12 Compliance Score (%)

GRI +11 Compliance Score (%)

Report Profile (4 Indicators)

Employment (3 Indicators)

Forced Labour (1 Indicator)

Biodiversity (5 Indicators)

Child Labour (1 Indicator)

Public Policy (2 Indicators)

Customer Privacy (1 Indicator)

Compliance (1 Indicator)

Community (1 Indicator)

Assurance (1 Indicator)

Materials (2 Indicators)

Energy (5 Indicators)

Water (3 Indicators)

Transport (1 Indicator)

A reasonable response = 2 of 2 A partial response = 1 of 2 No response = 0 of 2

181 Brait SA 182 Datatec 183 Protech Khuthele 184 Kagiso Media 185 Mazor Group 186 Bell Equipment 187 Insimbi Refractory and Alloys Supplies 188 Rand Merchant Insurance 189 Raubex Group 190 Sekunjalo Investments 191 Mvelaserve 192 Octodec Investments 193 Taste 194 York Timber 195 BSI Steel 196 Sephaku 197 Village Main Reef Gold Mining Company 198 Mercantile Bank 199 Afrocentric 200 Fountainhead Property Trust 201 Industrial Development Corporation (IDC) 202 Jasco Electronics 203 Nutritional Holdings 204 Stratcorp 205 ADvTECH 206 Bauba Platinum 207 Italtile 208 Nu-World 209 Vukile Property Fund 210 Silverbridge

26.9 25.2 40.9 26.9 21.7 29.5 26.9 22.4 30.3 26.5 20.1 23.2 26.1 18.1 25.2 25.7 16.9 30.3 25.7 11.0 20.1 25.7

25.7 17.3 24.4 25.7 25.2 24.8 25.3

25.3 14.6 16.9 25.3 25.6 24.0 25.3 23.2 36.6 24.9 20.9 21.3 24.9 16.1 11.0 24.9 13.8 19.7 24.5 24.4 31.5 24.1 24.1 24.1 18.5 40.2 24.1 24.8 32.7 24.1 24.0 29.1

23.7 14.6 18.9 23.3 22.4 30.3 23.3 13.0

23.3 24.8 26.8 23.3 18.1 20.5 23.3 17.3 15.4

NC(C)

22.9 18.9 21.3

80

Overall (1 Indicator)

Corruption (3 Indicators)

Compliance (1 Indicator)

Compliance (1 Indicator)

GRI application level

Profile Disclosures Governance, Commitments & Engagement (10 Indicators)

Economic

Environment

Labour

Human Rights

Social

Product Responsibility

Commitment to External Initiatives (3 Indicators)

Management Approach Disclosures (6 Indicators)

Emissions, Effluent & Waste (10 Indicators)

Labour/Management Relations (2 Indicators)

Investment & Procurement Practices (3 Indicators)

Occupational Health & Safety (4 Indicators)

Diversity & Equal Opportunity (2 Indicators)

Indirect Economic Aspects (2 Indicators)

Stakeholder Engagement (4 Indicators)

Economic Performance (4 Indicators)

Organisational Profile (10 Indicators)

Strategy & Analysis (2 Indicators)

Scope & Boundary (7 Indicators)

Products & Services (2 Indicators)

Training & Education (3 Indicators)

GRI Content Index (1 Indicator)

Market Presence (3 Indicators)

Non-discrimination (1 Indicator)

Freedom of Association (1 Indicator)

Security Practices (1 Indicator)

Indigenous Rights (1 Indicator)

Anti-Competitive Behaviour (1 Indicator)

Customer Health & Safety (2 Indicators)

Product & Service Labelling (3 Indicators)

Marketing & Communications (2 Indicators)

GRI +13 Compliance Score (%)

GRI +12 Compliance Score (%)

GRI +11 Compliance Score (%)

Report Profile (4 Indicators)

Employment (3 Indicators)

Forced Labour (1 Indicator)

Biodiversity (5 Indicators)

Child Labour (1 Indicator)

Public Policy (2 Indicators)

Customer Privacy (1 Indicator)

Compliance (1 Indicator)

Community (1 Indicator)

Assurance (1 Indicator)

Materials (2 Indicators)

Energy (5 Indicators)

Water (3 Indicators)

Transport (1 Indicator)

A reasonable response = 2 of 2 A partial response = 1 of 2 No response = 0 of 2

211 Caxton CTP 212 Grand Parade Investments 213 Mix Telematics 214 Mustek 215 Bowler Metcalf 216 Capital & Counties Properties 217 Central Rand Gold 218 Cullinan 219 Erbacon Investment 220 Foneworx 221 Petmin 222 Coal of Africa 223 IFA Hotels and Resorts 224 Invicta 225 RBA 226 Vividend Income Fund 227 Amalgamated Electronic Corporation 228 Ansys 229 Bioscience Brands 230 Brikor 231 Cadiz Holdings 232 Spur Corporation 233 Accentuate 234 Coronation Fund Managers 235 Emira Property Fund 236 ZCI 237 Clientele 238 Platfields 239 African and Overseas Enterprises 240 Datacentrix

22.5 18.1 34.6 22.5 20.1 22.8 22.5 19.3 21.3 22.5 24.0 27.2 22.1 22.1 9.8 19.7

22.1 26.4 27.2 22.1 17.3 20.1 22.1 20.9 24.0 22.1 19.7 20.1 22.1 26.0 27.6 21.7 22.4 25.6 21.7 11.4 23.6 21.7 16.5 21.7 21.7 20.1 21.7 21.7

21.3 17.3 21.3 21.3 21.7 30.3 21.3 15.0 17.3 21.3 23.2 25.6 21.3 22.8 30.7 21.3 16.5 24.8 20.9 18.1 22.0 20.9 20.9 29.1 20.9 22.0 24.0 20.9 20.6

20.6 20.1 29.1 20.2 20.1 26.4 20.2 17.3 22.4

81

Overall (1 Indicator)

Corruption (3 Indicators)

Compliance (1 Indicator)

Compliance (1 Indicator)

GRI application level

| appendix III: Our ranking of GrI compliance continued

Profile Disclosures Governance, Commitments & Engagement (10 Indicators) Economic Environment Labour Human Rights Social Product Responsibility

Commitment to External Initiatives (3 Indicators)

Management Approach Disclosures (6 Indicators)

Emissions, Effluent & Waste (10 Indicators)

Labour/Management Relations (2 Indicators)

Investment & Procurement Practices (3 Indicators)

Occupational Health & Safety (4 Indicators)

Diversity & Equal Opportunity (2 Indicators)

Indirect Economic Aspects (2 Indicators)

Stakeholder Engagement (4 Indicators)

Economic Performance (4 Indicators)

Organisational Profile (10 Indicators)

Strategy & Analysis (2 Indicators)

Scope & Boundary (7 Indicators)

Products & Services (2 Indicators)

Training & Education (3 Indicators)

GRI Content Index (1 Indicator)

Market Presence (3 Indicators)

Non-discrimination (1 Indicator)

Freedom of Association (1 Indicator)

Security Practices (1 Indicator)

Indigenous Rights (1 Indicator)

Anti-Competitive Behaviour (1 Indicator)

Customer Health & Safety (2 Indicators)

Product & Service Labelling (3 Indicators)

Marketing & Communications (2 Indicators)

GRI +13 Compliance Score (%)

GRI +12 Compliance Score (%)

GRI +11 Compliance Score (%)

Report Profile (4 Indicators)

Employment (3 Indicators)

Forced Labour (1 Indicator)

Biodiversity (5 Indicators)

Child Labour (1 Indicator)

Public Policy (2 Indicators)

Customer Privacy (1 Indicator)

Compliance (1 Indicator)

Community (1 Indicator)

Assurance (1 Indicator)

Materials (2 Indicators)

Energy (5 Indicators)

Water (3 Indicators)

Transport (1 Indicator)

A reasonable response = 2 of 2 A partial response = 1 of 2 No response = 0 of 2

241 First Uranium Corporation 242 Pinnacle Technology 243 Sanyati 244 Zurich Insurance Company SA 245 Adrenna Property Group 246 Metmar 247 Rex Trueform Clothing Company 248 Trencor 249 Combined Motor Holdings 250 Famous Brands 251 Africa Cellular Towers 252 Andulela Investment 253 Blue Financial Services 254 Hwange Colliery 255 Rebosis Property Fund 256 Santova Logistics 257 AH-Vest 258 Argent Industrial 259 Jubilee Platinum 260 Spanjaard 261 Acucap Properties 262 BK one 263 Conduit Capital 264 Crookes Brothers 265 KWV 266 Putprop 267 RGT SMART Market Intelligence 268 Southern Electricity Company (SELCo) 269 Compu Clearing Outsourcing 270 Racec Group

20.2 18.1 24.0 20.2 20.7 17.3 20.2 20.5 26.8 20.2 20.9 23.6 19.8 14.2 18.5 19.8 22.0 18.5 19.8 24.0 30.7 19.8 16.9 21.7 19.4 16.1 25.6 19.4 17.3 22.4 19.0 18.1 19.3 19.0 9.8 11.4 19.0 15.0 33.5 19.0 13.0 19.0 19.0 17.3 23.2 18.6 27.2 19.3 18.6 14.6 23.6 18.6 16.5 18.6 10.6 20.1 18.2 13.4 22.0 18.2 18.2 13.0 15.4 18.2 31.5 26.0 18.2 18.2 13.0 17.3 18.2 15.7 18.2 13.0 23.6 17.8 17.7 18.9 17.8 18.5 18.5

Overall (1 Indicator)

Corruption (3 Indicators)

Compliance (1 Indicator)

82

Compliance (1 Indicator)

GRI application level

Profile Disclosures Governance, Commitments & Engagement (10 Indicators)

Economic

Environment

Labour

Human Rights

Social

Product Responsibility

Commitment to External Initiatives (3 Indicators)

Management Approach Disclosures (6 Indicators)

Emissions, Effluent & Waste (10 Indicators)

Labour/Management Relations (2 Indicators)

Investment & Procurement Practices (3 Indicators)

Occupational Health & Safety (4 Indicators)

Diversity & Equal Opportunity (2 Indicators)

Indirect Economic Aspects (2 Indicators)

Stakeholder Engagement (4 Indicators)

Economic Performance (4 Indicators)

Organisational Profile (10 Indicators)

Strategy & Analysis (2 Indicators)

Scope & Boundary (7 Indicators)

Products & Services (2 Indicators)

Training & Education (3 Indicators)

GRI Content Index (1 Indicator)

Market Presence (3 Indicators)

Non-discrimination (1 Indicator)

Freedom of Association (1 Indicator)

Security Practices (1 Indicator)

Indigenous Rights (1 Indicator)

Anti-Competitive Behaviour (1 Indicator)

Customer Health & Safety (2 Indicators)

Product & Service Labelling (3 Indicators)

Marketing & Communications (2 Indicators)

GRI +13 Compliance Score (%)

GRI +12 Compliance Score (%)

GRI +11 Compliance Score (%)

Report Profile (4 Indicators)

Employment (3 Indicators)

Forced Labour (1 Indicator)

Biodiversity (5 Indicators)

Child Labour (1 Indicator)

Public Policy (2 Indicators)

Customer Privacy (1 Indicator)

Compliance (1 Indicator)

Community (1 Indicator)

Assurance (1 Indicator)

Materials (2 Indicators)

Energy (5 Indicators)

Water (3 Indicators)

Transport (1 Indicator)

A reasonable response = 2 of 2 A partial response = 1 of 2 No response = 0 of 2

271 Randgold & Exploration Company 272 Wescoal 273 Alert Steel 274 Gold One International 275 Infrasors 276 Purple Capital 277 Zeder Investments 278 Cafca 279 Dipula Income Fund 280 Huge Group 281 PSG Group 282 Interwaste 283 Metrofile 284 Resilient Property Income Fund 285 Sabvest 286 Simmer & Jack Mines 287 Total Client Services 288 African Dawn Capital 289 Poynting 290 W G Wearne 291 Capital Property Fund 292 ELB Group 293 Fairvest Property Holdings 294 Shoprite 295 Skinwell 296 Diamondcorp 297 Goliath Gold Mining 298 Trustco Group 299 Ububele 300 William Tell

17.8 12.2 16.1 17.8 16.1 20.1 17.4 15.0 22.8 17.4 16.5 18.9 17.4 23.2 24.8 17.4 15.0 16.5 17.4 14.6 13.4 17.0 17.3 17.0 17.0 18.5 13.8 17.0 17.7 19.3 16.6 11.8 16.5 16.6 22.4 24.8 16.6 11.8 18.1 16.6 18.1 23.6 16.6 22.4 38.2 16.6 24.0 18.1 16.2 12.2 15.4 16.2 11.4 19.7 16.2 16.9 26.8 15.8 11.8 15.8 13.8 17.3 15.8 12.2 15.8 50.0 34.6 15.8 18.5 19.3 15.4 12.6 15.4 10.6 15.4 12.6 19.7 15.4 16.9 20.5 15.4 16.5 21.7

Overall (1 Indicator)

Corruption (3 Indicators)

Compliance (1 Indicator)

83

Compliance (1 Indicator)

GRI application level

| appendix III: Our ranking of GrI compliance continued

Profile Disclosures Governance, Commitments & Engagement (10 Indicators) Economic Environment Labour Human Rights Social Product Responsibility

Commitment to External Initiatives (3 Indicators)

Management Approach Disclosures (6 Indicators)

Emissions, Effluent & Waste (10 Indicators)

Labour/Management Relations (2 Indicators)

Investment & Procurement Practices (3 Indicators)

Occupational Health & Safety (4 Indicators)

Diversity & Equal Opportunity (2 Indicators)

Indirect Economic Aspects (2 Indicators)

Stakeholder Engagement (4 Indicators)

Economic Performance (4 Indicators)

Organisational Profile (10 Indicators)

Strategy & Analysis (2 Indicators)

Scope & Boundary (7 Indicators)

Products & Services (2 Indicators)

Training & Education (3 Indicators)

GRI Content Index (1 Indicator)

Market Presence (3 Indicators)

Non-discrimination (1 Indicator)

Freedom of Association (1 Indicator)

Security Practices (1 Indicator)

Indigenous Rights (1 Indicator)

Anti-Competitive Behaviour (1 Indicator)

Customer Health & Safety (2 Indicators)

Product & Service Labelling (3 Indicators)

Marketing & Communications (2 Indicators)

GRI +13 Compliance Score (%)

GRI +12 Compliance Score (%)

GRI +11 Compliance Score (%)

Report Profile (4 Indicators)

Employment (3 Indicators)

Forced Labour (1 Indicator)

Biodiversity (5 Indicators)

Child Labour (1 Indicator)

Public Policy (2 Indicators)

Customer Privacy (1 Indicator)

Compliance (1 Indicator)

Community (1 Indicator)

Assurance (1 Indicator)

Materials (2 Indicators)

Energy (5 Indicators)

Water (3 Indicators)

Transport (1 Indicator)

A reasonable response = 2 of 2 A partial response = 1 of 2 No response = 0 of 2

301 ConvergeNet 302 Iquad Group 303 Mvelaphanda Group 304 Quantum Property Group 305 Rare 306 Cashbuild 307 Dorbyl 308 Ellies 309 Gooderson Leisure Corporation 310 ISA 311 Imuniti 312 Pallinghurst Resources 313 Reinet Investments 314 Sycom Property Fund 315 PBT Group 316 Thabex 317 Vunani Property Investment Fund 318 Hardware Warehouse 319 Independent Power Southern Africa (IPSA Group) 320 Indequity Group 321 Labat Africa 322 Telemasters 323 African Brick Centre 324 African Media Entertainment 325 Excellerate 326 Net 1 UEPS Technologies 327 Tradehold 328 Fortress Income Fund 329 John Daniel Holdings 330 Miranda Mineral Holdings

15.0 15.0 21.7 15.0 21.7 23.2 15.0 20.9 26.0 15.0 20.5 19.7 15.0 17.3 22.8 14.6 18.5 30.7 14.6 12.6 15.7 14.6 20.5 17.7 14.6 18.9 20.5 14.6 20.5 24.0 14.6 15.0 16.1 14.6 9.8

14.6 10.6 22.0 14.6 10.6 22.4 14.2 13.8 14.2 15.4 14.2 13.0 16.5 13.8 15.0 15.0 13.8 12.6 13.8 11.8 16.9 13.8 13.8 18.1 13.8 14.2 19.7 13.4 14.2 18.9 13.4 13.8 19.3 13.4 18.9 24.4 13.4 11.0 14.6 13.4 14.2 19.7 13.0 11.8 13.0 13.0 12.6 13.0 14.2 21.7

Overall (1 Indicator)

Corruption (3 Indicators)

Compliance (1 Indicator)

84

Compliance (1 Indicator)

GRI application level

Profile Disclosures Governance, Commitments & Engagement (10 Indicators)

Economic

Environment

Labour

Human Rights

Social

Product Responsibility

Commitment to External Initiatives (3 Indicators)

Management Approach Disclosures (6 Indicators)

Emissions, Effluent & Waste (10 Indicators)

Labour/Management Relations (2 Indicators)

Investment & Procurement Practices (3 Indicators)

Occupational Health & Safety (4 Indicators)

Diversity & Equal Opportunity (2 Indicators)

Indirect Economic Aspects (2 Indicators)

Stakeholder Engagement (4 Indicators)

Economic Performance (4 Indicators)

Organisational Profile (10 Indicators)

Strategy & Analysis (2 Indicators)

Scope & Boundary (7 Indicators)

Products & Services (2 Indicators)

Training & Education (3 Indicators)

GRI Content Index (1 Indicator)

Market Presence (3 Indicators)

Non-discrimination (1 Indicator)

Freedom of Association (1 Indicator)

Security Practices (1 Indicator)

Indigenous Rights (1 Indicator)

Anti-Competitive Behaviour (1 Indicator)

Customer Health & Safety (2 Indicators)

Product & Service Labelling (3 Indicators)

Marketing & Communications (2 Indicators)

GRI +13 Compliance Score (%)

GRI +12 Compliance Score (%)

GRI +11 Compliance Score (%)

Report Profile (4 Indicators)

Employment (3 Indicators)

Forced Labour (1 Indicator)

Biodiversity (5 Indicators)

Child Labour (1 Indicator)

Public Policy (2 Indicators)

Customer Privacy (1 Indicator)

Compliance (1 Indicator)

Community (1 Indicator)

Assurance (1 Indicator)

Materials (2 Indicators)

Energy (5 Indicators)

Water (3 Indicators)

Transport (1 Indicator)

A reasonable response = 2 of 2 A partial response = 1 of 2 No response = 0 of 2

331 Resource Generation 332 Seardel Investment Corporation 333 1Time 334 Chrometco 335 Ingenuity Property Investments 336 New Africa Investments 337 Orion Real Estate 338 Premium Properties 339 Real Africa Holdings 340 SA French 341 Sacoil 342 Capevin Investments 343 Don Group 344 Intertrading 345 Nictus Beperk 346 Securedata 347 London Finance & Investment Group 348 Money Web 349 Oasis Crescent Property Fund 350 Kibo Mining 351 Sable 352 RECM & Calibre 353 Rockwell Diamonds 354 Trematon Capital Investments 355 Chamber of Mines 356 Sea Kay 357 New Corpcapital 358 Stella Vista Technologies 359 Awethu Breweries 360 Firestone Energy 361 Ideco Group 362 Foord Compass 363 Mine Waste Solutions

13.0 13.0

13.0 19.7 18.9 12.6 18.9 22.8 12.6 15.0 17.7 12.6 13.8 15.0 12.6 18.1

12.6 12.2 17.7 12.6 15.7 18.5 12.6 12.6 15.7 12.6 13.0 21.7 12.6 12.6 14.6 12.3 11.8 16.5 12.3 15.0 20.5 12.3 14.8 16.5 12.3 11.8 18.1 12.3 20.5 21.3

11.9 10.6 11.9 15.4 16.5

11.9 10.2 22.4 11.5 11.1 13.8 11.1

11.5 15.4 18.5 9.8 15.7

11.1 11.4 15.4 10.7 10.2 32.3 10.7 16.5 27.2 17.7 10.3 13.4 14.6 10.3 9.9 11.0 15.0 9.5 13.0

8.7 11.0 19.3 7.9 11.0 24.0 5.9

85

Overall (1 Indicator)

Corruption (3 Indicators)

Compliance (1 Indicator)

Compliance (1 Indicator)

GRI application level

Non-responses

Non-responses

Full Responses

Full Responses

Appendix IV: Responses per GRI Indicator

GRI-Based Reports GRI+13 Score (%) GRI+12 Score (%)

Non-GRI Reports GRI+13 Score (%) 56,2 54,9 97,9 90,0 91,7 71,7 90,9 69,8 86,6 58,9 17,0 85,3 21,1 98,5 36,0 34,5 33,4 23,6 20,2 8,3 8,9 26,0 0,0 14,0 98,5 97,2 96,4 34,5 26,2 65,3 GRI+12 Score (%) 56,8 49,1 95,0 75,9 95,5 68,7 82,5 64,9 64,7 70,9 11,8 62,2 38,9 97,6 51,7 35,1 18,3 2,9 7,4 3,8 5,7 6,5 0,7 1,7 66,4 91,8 92,8 48,1 37,0 31,2

Partial Responses

STANDARD DISCLOSURES PART I: Profile Disclosures

1. Strategy and Analysis 1.1 1.2 2.1 2.2 2.3 2.4 2.5 2.6 2.7 2.8 2.9 2.10 3.1 3.2 3.3 3.4 3.5 3.6 3.7 3.8 3.9 3.10 3.11 3.12 Statement from the most senior decision-maker of the organisation Description of key impacts, risks, and opportunities. Name of the organisation. Primary brands, products, and/or services. Operational structure of the organisation, including main divisions, operating companies, subsidiaries, and joint ventures. Location of organisations headquarters. Number of countries where the organisation operates, and names of countries with either major operations or that are specifically relevant to the sustainability issues covered in the report. Nature of ownership and legal form. Markets served (including geographic breakdown, sectors served, and types of customers/beneficiaries). Scale of the reporting organisation. Significant changes during the reporting period regarding size, structure, or ownership. Awards received in the reporting period. Reporting period (e.g., fiscal/calendar year) for information provided. Date of most recent previous report (if any). Reporting cycle (annual, biennial, etc.) Contact point for questions regarding the report or its contents. Process for defining report content. Boundary of the report (e.g., countries, divisions, subsidiaries, leased facilities, joint ventures, suppliers). See GRI Boundary Protocol for further guidance. State any specific limitations on the scope or boundary of the report (see completeness principle for explanation of scope). Basis for reporting on joint ventures, subsidiaries, leased facilities, outsourced operations, and other entities that can significantly affect comparability from period to period and/or between organisations. Data measurement techniques and the bases of calculations, including assumptions and techniques underlying estimations applied to the compilation of the Indicators and other information in the report. Explain any decisions not to apply, or to substantially diverge from, the GRI Indicator Protocols. Explanation of the effect of any re-statements of information provided in earlier reports, and the reasons for such re-statement (e.g., mergers/acquisitions, change of base years/periods, nature of business, measurement methods). Significant changes from previous reporting periods in the scope, boundary, or measurement methods applied in the report. Table identifying the location of the Standard Disclosures in the report. 99 104 128 128 122 124 115 124 115 122 113 104 109 74 126 108 106 115 101 102 67 84 98 95 110 28 22 0 0 6 4 13 4 12 6 11 9 19 37 0 9 20 10 13 18 26 22 14 26 3 1 2 0 0 0 0 0 0 1 0 4 15 0 17 2 11 2 3 14 8 35 22 16 7 15 88,3 89,8 100,0 100,0 97,7 98,4 94,9 98,4 94,5 97,7 92,6 84,8 92,6 72,3 98,4 87,9 90,6 93,8 84,0 86,7 62,5 74,2 82,0 84,4 87,1 91,0 89,5 100,0 99,0 94,0 98,0 95,0 91,0 92,5 95,0 87,5 76,5 86,0 73,0 100,0 76,5 93,0 73,5 60,0 53,0 60,5 61,0 53,5 78,5 74,0 65 85 235 227 205 210 151 203 142 182 137 39 167 31 231 58 54 72 54 43 15 18 59 0 29 134 88 0 6 13 11 35 21 44 43 3 2 67 37 1 53 54 13 3 9 9 6 4 0 8 36 62 0 2 17 14 49 11 49 10 95 194 1 167 3 124 127 150 178 183 211 211 172 235 198

2. Organisational Profile 100,0 100,0

3. Report Parameters

3.13 Policy and current practice with regard to seeking external assurance for the report. 4. Governance, Commitments, and Engagement 4.1 4.2 4.3 4.4 4.5 4.6 Governance structure of the organisation, including committees under the highest governance body responsible for specific tasks, such as setting strategy or organisational oversight. Indicate whether the Chair of the highest governance body is also an executive officer. For organisations that have a unitary board structure, state the number of members of the highest governance body that are independent and/or non-executive members. Mechanisms for shareholders and employees to provide recommendations or direction to the highest governance body. Linkage between compensation for members of the highest governance body, senior managers, and executives (including departure arrangements), and the organisations performance (including social and environmental performance). Processes in place for the highest governance body to ensure conflicts of interest are avoided.

128 125 125 97 41 109

0 2 3 29 63 8

0 1 0 2 24 11

100,0 98,4 98,8 87,1 56,6 88,3

92,0 96,0 94,5 83,5 64,5

229 227 223 55 7

Partial Responses 5 3 7 52 109 13

1 5 5 128 119 75

72,0 147

86

GRI-Based Reports Non-responses Full Responses Full Responses GRI+13 Score (%) GRI+12 Score (%)

Non-GRI Reports Non-responses GRI+13 Score (%) 33,0 43,0 62,8 32,3 27,4 63,0 22,3 50,6 15,5 33,2 14,0 25,5 12,1 14,9 1,9 8,1 2,3 43,2 4,3 42,8 0,4 0,2 20,9 21,3 35,7 10,9 2,1 1,3 6,6 8,3 GRI+12 Score (%) 40,1 47,1 20,5 21,9 43,2 34,9 13,2 17,5 4,1 23,8 3,4 4,3 4,3 3,9 1,0 2,2 0,9 56,7 3,1 53,8 1,7 0,9 21,6 25,9 35,4 14,2 2,2 3,8 5,7 2,2

Partial Responses

STANDARD DISCLOSURES PART I: Profile Disclosures continued

4. Governance, Commitments, and Engagement continued 4.7 4.8 4.9 4.10 4.11 4.12 4.13 Process for determining the qualifications and expertise of the members of the highest governance body for guiding the organisations strategy on economic, environmental, and social topics. Internally developed statements of mission or values, codes of conduct, and principles relevant to economic, environmental, and social performance and the status of their implementation. Procedures of the highest governance body for overseeing the organisations identification and management of economic, environmental, and social performance, including relevant risks and opportunities, and adherence or compliance with internationally agreed standards, codes of conduct, and principles. Processes for evaluating the highest governance bodys own performance, particularly with respect to economic, environmental, and social performance. Explanation of whether and how the precautionary approach or principle is addressed by the organisation. Externally developed economic, environmental, and social charters, principles, or other initiatives to which the organisation subscribes or endorses. Memberships in associations (such as industry associations) and/or national/international advocacy organisations in which the organisation: * Has positions in governance bodies; * Participates in projects or committees; * Provides substantive funding beyond routine membership dues; or * Views membership as strategic. List of stakeholder groups engaged by the organisation. Basis for identification and selection of stakeholders with whom to engage. Approaches to stakeholder engagement, including frequency of engagement by type and by stakeholder group. Key topics and concerns that have been raised through stakeholder engagement, and how the organisation has responded to those key topics and concerns, including through its reporting. Description Disclosure on Management Approach for Economic Indicators Disclosure on Management Approach for Environmental Indicators Disclosure on Management Approach for Labour Indicators Disclosure on Management Approach for Human Rights Indicators Disclosure on Management Approach for Social Indicators Disclosure on Management Approach for Product Responsibility Indicators 75 54 61 33 38 36 32 40 46 28 52 29 21 34 21 67 38 63 71,1 57,8 65,6 36,7 50,0 39,5 50,0 51,0 50,5 30,0 35,5 35,0 30 8 13 1 4 0 60 41 44 7 30 11 145 186 178 227 201 224 34 64 114 52 76 85 81 55 9 57 14 31 13 9 5 19 38 12 58,2 71,5 92,6 62,9 64,8 78,5 60,5 76,5 76,5 61,0 77,0 89,0 16 49 114 43 51 109 123 104 67 66 27 78 96 82 54 126 157 48

94 117 71 69 67

3 6 18 48 22

31 5 39 11 39

74,6 93,8 62,5 72,7 60,9

76,5 87,5 57,5 72,5 58,0

46 109 30 45 22

Partial Responses 13 20 13 66 22 73 2 13 0 1 22 22 26 7 4 6 7 15

176 106 192 124 191

4.14 4.15 4.16 4.17

STANDARD DISCLOSURES PART II: Disclosures on Management Approach (DMAs)

G3 DMA DMA EC DMA EN DMA LA DMA HR DMA SO DMA PR Economic EC1 EC2 EC3 EC4 EC5 EC6 EC7 EC8 Direct economic value generated and distributed, including revenues, operating costs, employee compensation, donations and other community investments, retained earnings, and payments to capital providers and governments. Financial implications and other risks and opportunities for the organisations activities due to climate change. Coverage of the organisations defined benefit plan obligations. Significant financial assistance received from government. Range of ratios of standard entry level wage compared to local minimum wage at significant locations of operation. Policy, practices, and proportion of spending on locally-based suppliers at significant locations of operation. Procedures for local hiring and proportion of senior management hired from the local community at significant locations of operation. Development and impact of infrastructure investments and services provided primarily for public benefit through commercial, in-kind, or pro bono engagement. 106 72 100 69 21 73 56 95 54 35 21 63 67 87 20 9 4 9 13 35 27 9 30 20 26 24 27 2 47 24 50 94 20 45 24 44 73 81 41 34 90,6 59,8 79,7 57,4 21,5 70,7 54,3 77,7 53,9 35,2 26,6 58,6 62,9 85,5 56,5 80,5 47,5 26,0 80,0 72,5 93,5 59,5 41,5 34,0 58,5 56,5 65 9 94 1 0 38 39 71 22 3 0 12 12 97 224 128 234 234 175 174 138 206 228 229 216 208

STANDARD DISCLOSURES PART III: Performance Indicators

EC9 Understanding and describing significant indirect economic impacts, including the extent of impacts. Environmental EN1 EN2 EN3 EN4 Materials used by weight or volume. Percentage of materials used that are recycled input materials. Direct energy consumption by primary energy source. Indirect energy consumption by primary source.

| appendix IV: responses per GrI indicator continued

GRI-Based Reports Non-responses Full Responses Full Responses GRI+13 Score (%) GRI+12 Score (%) Non-GRI Reports Non-responses GRI+13 Score (%) 5,3 8,1 10,2 6,6 1,3 3,2 4,0 1,9 3,6 3,2 0,2 10,9 3,2 5,5 0,9 0,9 1,3 5,7 3,2 0,4 0,2 9,1 0,4 6,0 3,4 2,3 18,3 7,7 3,6 11,9 0,9 5,5 14,5 26,6 GRI+12 Score (%) 6,2 9,2 4,3 3,3 0,7 3,3 1,5 2,4 1,5 6,2 0,3 3,3 1,5 8,9 0,7 0,5 0,7 5,1 5,5 0,5 0,5 10,1 1,4 5,3 1,2 1,2 23,6 5,5 8,2 10,4 0,5 5,5 15,8 30,7

Partial Responses

STANDARD DISCLOSURES PART III: Performance Indicators continued

Environmental EN5 EN6 EN7 EN8 EN9 EN10 EN11 EN12 EN13 EN14 EN15 EN16 EN17 EN18 EN19 EN20 EN21 EN22 EN23 EN24 EN25 EN26 EN27 EN28 EN29 Energy saved due to conservation and efficiency improvements. Initiatives to provide energy-efficient or renewable energy based products and services, and reductions in energy requirements as a result of these initiatives. Initiatives to reduce indirect energy consumption and reductions achieved. Total water withdrawal by source. Water sources significantly affected by withdrawal of water. Percentage and total volume of water recycled and reused. Location and size of land owned, leased, managed in, or adjacent to, protected areas and areas of high biodiversity value outside protected areas. Description of significant impacts of activities, products, and services on biodiversity in protected areas and areas of high biodiversity value outside protected areas. Habitats protected or restored. Strategies, current actions, and future plans for managing impacts on biodiversity. Number of IUCN Red List species and national conservation list species with habitats in areas affected by operations, by level of extinction risk. Total direct and indirect greenhouse gas emissions by weight. Other relevant indirect greenhouse gas emissions by weight. Initiatives to reduce greenhouse gas emissions and reductions achieved. Emissions of ozone-depleting substances by weight. NOx, SOx, and other significant air emissions by type and weight. Total water discharge by quality and destination. Total weight of waste by type and disposal method. Total number and volume of significant spills. Weight of transported, imported, exported, or treated waste deemed hazardous under the terms of the Basel Convention Annex I, II, III, and VIII, and percentage of transported waste shipped internationally. Identity, size, protected status, and biodiversity value of water bodies and related habitats significantly affected by the reporting organisations discharges of water and runoff. Initiatives to mitigate environmental impacts of products and services, and extent of impact mitigation. Percentage of products sold and their packaging materials that are reclaimed by category. Monetary value of significant fines and total number of non-monetary sanctions for non-compliance with environmental laws and regulations. Significant environmental impacts of transporting products and other goods and materials used for the organisations operations, and transporting members of the workforce. 31 30 34 49 36 28 51 37 30 44 24 73 42 39 26 31 20 39 52 21 21 42 20 88 28 25 50 38 57 88 37 26 64 95 20 35 39 39 13 20 11 14 17 6 8 12 5 28 4 7 19 32 13 11 12 29 12 8 16 9 67 49 8 6 9 28 43 15 77 63 55 40 79 80 66 77 81 78 96 43 81 61 98 90 89 57 63 96 95 57 96 32 84 94 11 41 63 34 82 74 21 18 32,0 37,1 41,8 53,5 33,2 29,7 44,1 34,4 30,1 36,7 21,9 61,7 34,8 41,4 21,9 27,0 23,0 43,0 45,7 20,7 21,1 44,1 20,3 71,9 28,1 23,0 65,2 48,8 47,7 71,1 32,4 31,3 66,8 80,1 51,5 46,5 56,5 61,0 32,0 32,0 48,5 43,5 33,0 39,5 27,5 67,0 43,0 61,0 25,5 32,0 31,0 49,0 59,0 30,5 22,5 56,0 25,5 67,0 27,0 22,0 78,0 55,5 43,0 74,5 36,5 44,5 78,0 87,5 8 9 8 6 2 2 7 4 6 6 0 22 7 7 2 1 2 7 5 0 0 13 1 12 6 4 13 2 8 21 1 3 15 44 9 20 32 19 2 11 5 1 5 3 1 7 1 12 0 2 2 13 5 2 1 17 0 4 4 3 60 32 1 14 2 20 38 37 218 206 195 210 231 222 223 230 224 226 234 206 227 216 233 232 231 215 225 233 234 205 234 219 225 228 162 201 226 200 232 212 182 154

EN30 Total environmental protection expenditures and investments by type. Social: Labour Practices and Decent Work LA1 LA2 LA3 LA4 LA5 LA6 LA7 LA8 Total workforce by employment type, employment contract, and region. Total number and rate of employee turnover by age group, gender, and region. Benefits provided to full-time employees that are not provided to temporary or part-time employees, by major operations. Percentage of employees covered by collective bargaining agreements. Minimum notice periods regarding significant operational changes, including whether it is specified in collective agreements. Percentage of total workforce represented in formal joint management-worker health and safety committees that help monitor and advise on occupational health and safety programmes. Rates of injury, occupational diseases, lost days, and absenteeism, and number of work-related fatalities by region. Education, training, counselling, prevention, and risk-control programmes in place to assist workforce members, their families, or community members regarding serious diseases.

88

Partial Responses

GRI-Based Reports Non-responses Full Responses Full Responses GRI+13 Score (%) GRI+12 Score (%)

Non-GRI Reports Non-responses GRI+13 Score (%) 0,0 9,1 22,3 7,9 18,7 1,9 0,9 0,6 0,6 4,7 2,1 4,3 3,8 0,0 2,8 17,0 3,2 1,9 5,1 4,0 7,7 4,9 11,7 4,3 1,9 1,1 1,3 3,0 1,3 0,9 0,2 3,0 GRI+12 Score (%) 1,7 12,8 36,5 7,5 23,6 1,2 1,4 1,5 1,5 8,4 7,2 3,4 2,9 0,2 2,2 14,2 4,6 3,8 9,6 0,5 4,1 4,5 6,0 3,6 2,4 2,2 1,9 6,0 2,1 2,2 1,4 3,1

Partial Responses

STANDARD DISCLOSURES PART III: Performance Indicators continued

Social: Labour Practices and Decent Work continued LA9 LA10 LA11 LA12 LA13 Health and safety topics covered in formal agreements with trade unions. Average hours of training per year per employee by employee category. Programmes for skills management and lifelong learning that support the continued employability of employees and assist them in managing career endings. Percentage of employees receiving regular performance and career development reviews. Composition of governance bodies and breakdown of employees per category according to gender, age group, minority group membership, and other indicators of diversity. LA14 Ratio of basic salary of men to women by employee category. Social: Human Rights HR1 HR2 HR3 Percentage and total number of significant investment agreements that include human rights clauses or that have undergone human rights screening. Percentage of significant suppliers and contractors that have undergone screening on human rights and actions taken. Total hours of employee training on policies and procedures concerning aspects of human rights that are relevant to operations, including the percentage of employees trained. HR4 Total number of incidents of discrimination and actions taken. HR5 Operations identified in which the right to exercise freedom of association and collective bargaining may be at significant risk, and actions taken to support these rights. HR6 Operations identified as having significant risk for incidents of child labour, and measures taken to contribute to the elimination of child labour. HR7 Operations identified as having significant risk for incidents of forced or compulsory labour, and measures to contribute to the elimination of forced or compulsory labour. HR8 Percentage of security personnel trained in the organisations policies or procedures concerning aspects of human rights that are relevant to operations. HR9 Total number of incidents of violations involving rights of indigenous people and actions taken. Social: Society SO1 Nature, scope, and effectiveness of any programmes and practices that assess and manage the impacts of operations on communities, including entering, operating, and exiting. SO2 Percentage and total number of business units analysed for risks related to corruption. SO3 Percentage of employees trained in organisations anti-corruption policies and procedures. SO4 Actions taken in response to incidents of corruption. SO5 Public policy positions and participation in public policy development and lobbying. SO6 Total value of financial and in-kind contributions to political parties, politicians, and related institutions by country. SO7 Total number of legal actions for anti-competitive behaviour, anti-trust, and monopoly practices and their outcomes. SO8 Monetary value of significant fines and total number of non-monetary sanctions for non-compliance with laws and regulations. Social: Product Responsibility PR1 PR2 PR3 PR4 PR5 PR6 PR7 PR8 PR9 Life cycle stages in which health and safety impacts of products and services are assessed for improvement, and percentage of significant products and services categories subject to such procedures. Total number of incidents of non-compliance with regulations and voluntary codes concerning health and safety impacts of products and services during their life cycle, by type of outcomes. Type of product and service information required by procedures, and percentage of significant products and services subject to such information requirements. Total number of incidents of non-compliance with regulations and voluntary codes concerning product and service information and labelling, by type of outcomes. Practices related to customer satisfaction, including results of surveys measuring customer satisfaction. Programmes for adherence to laws, standards, and voluntary codes related to marketing communications, including advertising, promotion, and sponsorship. Total number of incidents of non-compliance with regulations and voluntary codes concerning marketing communications, including advertising, promotion, and sponsorship by type of outcomes. Total number of substantiated complaints regarding breaches of customer privacy and losses of customer data. Monetary value of significant fines for non-compliance with laws and regulations concerning the provision and use of products and services. 17 30 83 40 53 44 12 16 14 72 56 70 65 29 48 13 61 11 23 52 3 16 22 14 7 7 6 7 5 3 98 37 34 65 23 81 100 90 100 49 65 52 56 94 77 18,4 47,3 69,1 40,2 61,7 35,5 15,6 21,1 16,4 59,0 46,5 57,0 53,5 24,6 38,7 26,5 59,0 81,5 50,5 77,5 30,0 18,5 18,0 21,0 49,0 57,0 54,5 49,0 18,5 30,5 0 3 42 10 12 3 1 1 1 9 3 8 7 0 5 0 37 21 17 64 3 2 1 1 4 4 4 4 0 3 235 195 172 208 159 229 232 233 233 222 228 223 224 235 227

34 36 34 70 51 67 62 82

56 16 20 8 6 5 6 9

38 76 74 50 71 56 60 37

48,4 34,4 34,4 57,8 42,2 54,3 50,8 67,6

55,5 45,5 37,0 53,5 41,5 57,5 46,0 54,0

18 6 2 12 9 18 11 27

Partial Responses 44 3 5 0 1 0 1 1 4 1 1 0 8 0 0 1 0

173 226 228 223 225 217 223 207

41 56 42 46 41 48 54 50 70

18 5 10 9 23 5 3 6 4

69 67 76 73 64 75 71 72 54

39,1 45,7 36,7 39,5 41,0 39,5 43,4 41,4 56,3

39,0 37,0 35,5 35,5 50,5 46,0 34,5 36,0 43,5

8 4 2 3 3 3 2 0 7

223 230 232 232 224 232 233 234 228

89

www.sake24.com sake@sake24.com epos: 011 713 9000 Johannesburg 012 424 6000 Pretoria 021 406 2121 d Kaapsta 041 503 6111 Port Elizabeth 051 4047600 Bloemfontein

AMPS 2011 AB NAVORSING

Steeds die beste manier om invloedryke beleggers te bereik

Navorsing deur AMPS 2011 AB toon dat Afrikaanssprekendes die Suid-Afrikaanse ekonomie se sleutelspelers is en een van die belangrikste plaaslike beleggingsegmente verteenwoordig. Hulle is voorts toekomsgerig en verbind tot die land se welvaart. Hierdie faktore is belangrik in die debat rondom die veranderende vereistes vir finansile verslagdoening. Een van di veranderinge is die voorgestelde JSE-regulasie dat maatskappye vanaf Januarie 2013 nie meer hul resultate in twee tale in die gedrukte media hoef aan te kondig nie. Die navorsing het bevind dat Afrikaanssprekende Suid-Afrikaners, waarvan 72% in die LSM 8-, 9- en 10-kategorie val, sewe keer meer geneig is om in die aandelemark te bel as die gemiddelde Suid-Afrikaner. Trouens, een uit elke vier beleggers op die JSE is Afrikaanssprekend. Boonop verkies 71% van beleggers om in hul moedertaal te lees. Sake24 in Beeld bereik die meeste Afrikaanssprekende beleggers. In moeilike ekonomiese omstandig hede is dit te verstane dat maatskappye hul nakomingskoste wil verminder. Maar dit moet nie doeltreffende kommunikasie met bestaande aandeelhouers, moont like beleggers en ander belanghebbers in die wiele ry nie. Gegewende verske ie plaasli ke en internasionale gebeure, waarvan die wreld se belangrikste maatskappye betrokke is, is die nasionale en internasionale tendens om meer inligting beskikbaar te maak nie minder nie. Afrikaansspre-

* 25 snels groeiende ekonomie

4Argentini 4Brasili 4Chili 4China en Hongkong 4Colombia 4Tsjeggiese Republiek 4Egipte 4Ghana 4Indi 4Kazakstan 4Korea 4Maleisi 4Mexiko 4Nigeri 4Pole 4Katar 4Rusland 4Saoedi-Arabi 4Suid-Afrika 4Thailand 4Turkye 4Oekrane 4Verenigde Arabiese Emirate 4Vitnam

kendes het massiewe koopkrag van meer as R300 miljard wat jaarliks bestee word n derde van SuidAfrika se verbruikersbesteding. Hulle maak slegs 14% van die bevolking uit, maar hulle verteenwoordig 21% van die waarde. Uiteindelik gaan effektiewe kommunikasie nie oor die nakoming van minimumvereistes nie. Die belang rikste is om die mense wat jou besigheid laat floreer, te bereik en sodoende die hoogste opbrengs op jou belegg ing te verseker.

90

Appendix V: Useful Contacts and Links

NOTE

The cost of producing this report is borne by IRAS, both in terms of opportunity cost of six months of dedicated resources working flat-out to analyse over 400 reports, and in terms of the cash we spend on this publication. Studio 5, our primary partner in this project, provided their expertise in report design to help us get this report to you: our valued clients, colleagues and peers. The following is a list of known sustainability reporting practitioners operating in the SA market, including 24 companies that have opted to support IRAS in our dogged attempt to help inform the discussion around sustainability/integrated reporting and assurance.
Authorship Assurance Advisory

Anyone seeking guidance and/or support with authorship, assurance, advisory, report design and/or layout, training, database and/or CDP services is encouraged to use the ads in this report, and the following table, to identify service providers who would be best poised to tender for services. The cost of our launch event, and the printing of the 800 copies of this report, is borne by our peers who purchase ad space, and we thank each and every one of them for sharing the journey with us. Interestingly, this years Other SRPs database consists of 59 service providers (up from 50 in 2011, and 25 in our 2010 report). Once again, we opted to provide additional service providers, including data systems developers and Carbon Disclosure Project (CDP) specialists.

Please note that this list represents the knowledge at-hand, as of 30 June 2012. Please contact Thembi (thembi@iras.co.za), if we have overlooked any other unknown. Please forward their details to so that they can be added to the database on our website. For access to a searchable database of the SRP Network, to search our database of reports, or to download additional resource materials, go to our website at www.iras.co.za. For information about AccountAbility, including their AA1000AS Assurance Standard, or their AA1000SES Stakeholder Engagement Standard, go to their website at www.accountability.org. For information about the Global Reporting Initiative, including their GRI G3 Guidelines, go to their website at www.globalreporting.org.

Gauteng

Western Cape X X X X X

Data systems

Training

CDP services

Design/ layout

Organisation Integrated Reporting & Assurance Services AH Communications Assuredex Bastion Graphics BDO South Africa Corporate Leap Credit360 Earth.inc environment + sustainability Enlightened Energy Environmental & Sustainability Solutions Envisage Investor & Corporate Relations Global Carbon Exchange Grant Thornton HKLM Incite Sustainability ITB Media Maxx Corporate Communications Next Generation Consultants PE International PKF Consulting Purple Frog Communications Russell & Associates SD Toolkit Studio 5 Trialogue Ultra Litho

Contact person Michael H. Rea Anne Heath Kopano Xaba

Email address michael@csap.co.za anneh@ahcomm.co.za kopano@empowerdex.com adele@bastion.bz uvaneck@bdo.co.za andrew@corporateleap.com iain.mcghee@credit360.com thomas@earthinc.co.za kvanniekerk@enlenergy.com envsustsol@mweb.co.za michele@envisagesa.co.za kevinj@globalcarbonexchange.com jbrice@gt.co.za jleuner@hklmgroup.com jon@incite.co.za rosalie@itbmedia.co.za berdine@maxx.co.za rrossouw@nextgeneration.co.za m.reichardt@pe-international.com claire.jennings@pkf.co.za patricia@purplefrog.co.za charmane@rair.co.za mark.becking@sdtoolkit.com glenn@studio5.co.za rob@trialogue.co.za colinf@ultra-litho.co.za

X X X X X

X X X X X X X X X X X X

X X X X X X X X X X X X X X X X X X X X X X X X

Adele Lotter Ursula van Eck Andrew Bromley Iain McGhee X X X X X Thomas van Viegen Kimberly van Niekerk Seakle Godschalk Michle Mackey X X Kevin James James Brice Julia Leuner X Jon Hanks Rosalie Pike Berdine Bosman X Reana Rossouw X X Markus Reichardt Claire Jennings Patricia Utton Charmane Russell Mark Becking Glenn OHearne Rob Worthington-Smith Colin Finck 91

X X X X X X X X X X X X X X X X X X X

X X X X X X X X X X X X X X X X X X X X X X X X X X X

KZN

| appendix V: Useful contacts and Links continued

Authorship

Assurance

Advisory

Gauteng

Western Cape X X X X X X X X X X X X X X X

Data systems

Training

CDP services

Design/ layout

Organisation Accenture Agartis Consulting Alternative Prosperity Aprio Communications Camco Global Carbon Calculated Clova Editing Ink Deloitte Environmental Resources Management (ERM) EY Climate Change & Sustainability Fleishman Hillard Green Grass Designs Greymatter & Finch HG Strategic Communications Icologie Ince.Motiv Keyter Rech Investor Solutions KPMG Sustainability Services Page Break Communicators Promethium Carbon PwC Sustainability Solutions Route 2 Sustainability Solo Graphics SRK Consulting TWC WSP Environment & Energy Independent SRPs:

Contact person Dr Grant Hatch Thomas McLachlan Trevor Chandler Julian Gwillim Santhuri Naicker

Email address Grant.hatch@accenture.com Thomas@agartis.co.za trevor@chandlerconsulting.co.za Julian@aprio.co.za Santhuri.naicker@camcoglobal.com alex@carboncalculated.co.za roses@worldonline.co.za ddutoit@iafrica.com nleriche@deloitte.co.za Simon.Clarke@erm.com jeremy.grist@za.ey.com lani.botha@fleishman.co.za Ria@greengrassdesign.co.za adriana@greymatterfinch.com h.geldenhuys@iafrica.com Andy.le.may@icologie.com LindaB@ince.co.za vrech@kris.co.za shireen.naidoo@kpmg.co.za clive.lotter@gmail.com harmke@promethium.co.za alison.ramsden@za.pwc.com timb@route2sustainability.com debbiesn@telkomsa.net dgibson@srk.co.za antoinette@twc.co.za helen.hulett@wspgroup.co.za keelingb@mweb.co.za dansonnenberg@gmail.com venpill@iafrica.com Jeremy@ideas21.co.za gerbek@unisa.ac.za robzipplies@gmail.com

X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X

X X

X X X X

Alex Hetherington Mike Rose Deirdre du Toit

X X X X X X X X X X X X X X X X X

X X X

Nina le Riche Simon Clarke Jeremy Grist Lani Botha Ria Kraftt

X X X

Adriana de Roock Heidi Geldenhuys Andy le May Linda Buchler Vanessa Rech X Shireen Naidoo Clive Lotter Harmke Immink Alison Ramsden Tim Barker Debbie Snoek X Don Gibson Antoinette Thamm X Helen Hulett Brian Keeling Dan Sonnenberg X Dr. Ven Pillay Jeremy Wakeford Karien Gerber Rob Zipplies

X X

X X

X X X X X X X X

X X

92

KZN X X

Moving Forward
Dear Reader,
For the fourth consecutive year, the better part of the past six months has been dedicated to compiling what I believe has become required reading for anyone producing a sustainability report, or advising companies in that pursuit. The process has been neither cheap nor easy, but it has been an education for all of us involved, and impossible to complete if not for the support offered by our team and project partners. No fewer than 2 000 hours were invested into this project by Lauren, Julia, Matt, Tahereh, Thembi and myself. Additional countless hours were invested by Mandy and her team at Studio 5, our dedicated design partners, Jason and his colleagues at Ultra Litho Printers, and Juanique and Anna at Global Carbon Exchange (GCX). It is our collective hope that this report will be a useful resource in your reporting journey, and that you will offer feedback if you have identified any errors, omissions, or improvement opportunities for future lapses in judgement regarding how best to spend our free time. We also hope that this report will attract project opportunities to our team: IRAS for advisory, authorship and/or assurance services; GCX for carbon footprint and/or CDP services; Studio 5 for report design services; and Ultra Litho for printing and binding services. Ultimately, our ability to continue to provide this report as a free service to our clients, colleagues and peers is dependent upon our own ability to attract customers, and we hope that potential clients will understand the value of what each of us learns through our investment in this project. Its important to note that this project serves as training and development for all of us, but particularly the researchers (Lauren, Julia, Matt and Tahereh). Although the pay sucks, the knowledge gained through the experience is invaluable and sets these researchers streaks ahead of almost anyone else attempting to support companies in their reporting quest. As we put final pen to paper on this report, it is my hope that the following will result from this project: Companies will know to contact us if they need authorship, assurance and/or advisory services. Future sustainability report authors, advisors and/or assurance providers will know to contact us for training and development, particularly our twice-annual Certified Sustainability Assurance Provider (CSAP) courses. Recent university grads preferably at the Masters level from English-speaking countries outside South Africa will know to contact us if they wish to participate in next years research project. The folks at the GRI and AccountAbility will use this report to help raise awareness of the benefits of GRI-based reporting and assurance throughout their global sphere of influence. Ultimately, our goal is to be the #1 Sustainability Assurance Provider in South Africa, seeking not to be the least expensive assurance provider, but the most cost effective, efficient and value-adding assurer to more companies than any of our peers. In doing so, we hope to be able to assist a maximum number of companies improve their integrated sustainability reporting processes and outcomes, while continuing to support our charitable efforts: particularly the Soweto Marimba Youth League (SMYLe) and the Orlando Childrens Home. Ours is a company that is still relatively new (in our 4th year), small (a team of four full-timers and a network of associated professionals), and committed to serving our clients with a value proposition based on our motto:

Them that cant do, teach. Only them that can and DO should consult!
We produce our own sustainability report (albeit very late this time around); we contribute to socioeconomic development in under-privileged communities; we offer guidance to others seeking to join the sustainability reporting and assurance space; we teach what we can, when we can; and, we offer pro bono services to worthy clients. In short, we do our best to lead by example, and we hope that you will contact us if theres any way that we can be of service. We look forward to interacting with you again next year, if not sooner. Sincerely, Michael H. Rea michael@iras.co.za / www.iras.co.za / www.smyle.co.za

The story of value, the value of story.

Every enterprise has a story to tell. A story of how they create and preserve value, and how they intend to keep doing so. The story of value is the story of our times. We help blue-chip companies, entrepreneurial businesses and visionary individuals tell their stories to the people who keep them in business. We are known for our critical thinking, creativity and craftsmanship in producing work that is distinctive from concept to completion. Credible and compelling communication engages the minds and opens the hearts of even the most sceptical stakeholders. For the value of story is timeless.

+27 [ 0 ] 11 268 3900 | INFO@STUDIO5.CO.ZA | STUDIO5.CO.ZA

TELLING VALUE