Integrated Annual Report

Transcription

1 2013 Tongaat Hulett Integrated Annual Report Global Reporting Initiative (GRI) G3 Content Assessment = No concerns; = Opportunity for improvement; NC = Not Covered STANDARD DISCLOSURES PART I: Profile Disclosures 1. Strategy and Analysis Profile Disclosure A 1.1 Statement from the most senior decision-maker of the organization 12, 13 Chairman's statement No concerns. The Chairman and the CEO discusses key sustainability priorities; targets that were set and if they have been achieved; targets that have been set for the future; and any achievements or failures during the reporting period. Global trends are also discussed where appropriate as well as the sustainability of Tongaat Hulett as a business, including social, environmental and economic issues. 1.2 Description of key impacts, risks, and opportunities. 27 Strategy and analysis; Key Opportunity for improvement. The 'Strategy and Analysis" section provides an overview of TH's impacts, risks and opportunities impact on sustainability in the agriculture and agri-processing sector in the SADC. This includes a short, high-level description of "key impacts, risks and opportunities" and also lists some of the impacts of sustainability on TH's business, such as climate change. 2. Organizational Profile Profile Disclosure 2.1 Name of the organization. 28, 29 Organisational profile No concerns. Tongaat Hulett Limited (Previously known as The Tongaat-Hulett Group Limited). 2.2 Primary brands, products, and/or services. 27, 28 Tongaat Hulett and its strategic positioning; Organisational profile No concerns. The company is an agricultural and agri-processing business, which includes integrated components of land and property development. With its established and growing operations, it has considerable expertise in downstream agricultural products, biofuel production and electricity generation. 2.3 Operational structure of the organization, including main divisions, operating companies, subsidiaries, and joint ventures. 4, 11, 28 Tongaat Hulett and its strategic positioning; Organisational profile Opportunity for improvement. 2.4 Location of organization's headquarters. 29 Organisational profile No concerns. Amanzimnyama, Tongaat, KwaZulu-Natal. 2.5 Number of countries where the organization operates, and names of countries with either major operations or that are specifically relevant to the sustainability issues covered in the report. 1 Scope and boundaries of report No concerns. This report covers all of Tongaat Hulett s operations in Botswana, Namibia, Mozambique, South Africa, Swaziland and Zimbabwe. 2.6 Nature of ownership and legal form. 28 Organisational profile No concerns. TH explicitly states that they are primary listed on the JSE and are secondary listed on London Stock Exchange. 2.7 Markets served (including geographic breakdown, sectors served, and types of customers/beneficiaries). 4, 27, 28 Tongaat Hulett and its strategic positioning; Strategy and analysis; Organisational profile 2.8 Scale of the reporting organization. 19, 29, 48 CEO's review; Organisational profile; Value Added Analysis No concerns. Tongaat Hulett has a significant presence in agriculture and agri-processing sectors in the Southern African Development Community (SADC). The markets served by the organisation are outlined in the operational overview in the strategic positioning section of the report. No concerns. This indicator is partly reported, more than employees, working in 27 locations in 6 SADC countries. Revenue is given as well as total sugar production. TH has 27 sites throughout the SADC region. 2.9 Significant changes during the reporting period regarding size, structure, or ownership. 29 Organisational profile No concerns. During the reporting period there were no significant changes in the size, structure or ownership of the company Awards received in the reporting period. 28, 29 External recognition No concerns. Various accolades have been listed. 3. Report Parameters Profile Disclosure 3.1 Reporting period (e.g., fiscal/calendar year) for information provided. 27 Reporting boundaries No concerns. 12 months ended 31 March Date of most recent previous report (if any). 27 Reporting boundaries No concerns. 1 April 2011 to 31 March Reporting cycle (annual, biennial, etc.) 27 Strategy and analysis No concerns. Integrated Annual Report 3.4 Contact point for questions regarding the report or its contents. 46 Request for feedback No concerns. The contact given is Corporate Affairs - sustainability@tongaat.com Tongaat Hulett Final Report - GRI G3 Gap Analysis - VK - 27 June v2.xls 1 of 7

2 3.5 Process for defining report content. 27 Reporting boundaries No concerns. The report has been prepared in accordance with the Global Reporting Initiative (GRI) and considers key themes of Environmental Stewardship, Social Stewardship and Economic Sustainability. 3.6 Boundary of the report (e.g., countries, divisions, subsidiaries, leased facilities, joint ventures, suppliers). See GRI Boundary Protocol for further guidance. 3.7 State any specific limitations on the scope or boundary of the report (see completeness principle for explanation of scope). 27 Reporting boundaries No concerns. The report covers the starch, land conversion and developments, animal feeds and the sugar operations in South Africa, Mozambique, Zimbabwe, Botswana, Namibia and Swaziland. 1, 27 Scope and boundary; Reporting boundaries Opportunity for improvement. Tongaat Hulett states that the report covers all Tongaat Hulett's operations in Botswana, Namibia, Mozambique, South Africa, Swaziland and Zimbabwe for the 12 months ended 31 March 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 organizations. 3.9 Data measurement techniques and the bases of calculations, including assumptions and techniques underlying estimations applied to the compilation of the s and other information in the report. Explain any decisions not to apply, or to substantially diverge from, the GRI 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. 1, 27 Scope and boundary; Reporting boundaries No concerns. Tongaat Hulett states their operations that are covered in the report and which countries these operations are located in the report, for comparability data. 30 Carbon Opportunity for improvement. Data has been provided for the past three years 27 Reporting boundaries No concerns. The report states "There have been no re-statements of any data previously reported by Tongaat Hulett." 29 Organisational profile No concerns. TH explicitly states that there were no significant changes in the size, structure or ownership of the company Table identifying the location of the Standard Disclosures in the report. Online GRI index No concerns. The report provides a specific hyperlink indicating where the GRI index can be downloaded on the Tongaat Hulett website Policy and current practice with regard to seeking external assurance for the report. 47 Independent assurance statement No concerns. The report has been independently assured by Integrated Reporting & Assurance Services (IRAS). 4. Governance, Commitments, and Engagement Profile Disclosure 4.1 Governance structure of the organization, including committees under the highest governance body responsible for specific tasks, such as setting strategy or organizational oversight. 48, Board and Committee Composition; Board Committee Structures and Responsibility No concerns. The report provides an outline of the governance structure of the organization in a table, including committees under the highest governance body responsible for specific tasks, such as setting strategy or organizational oversight. The composition and mandate of the committees has been described, including any direct responsibility for economic, social and environmental performance of such committees. 4.2 Indicate whether the Chair of the highest governance body is also an executive officer. 48 Board Composition No concerns. TH has an independent Non-Executive Chairman, J B Magwaza. 4.3 For organizations that have a unitary board structure, state the number of members of the highest governance body that are independent and/or non-executive members. 48 Board Composition No concerns. Tongaat Hulett has a unitary board structure, which at 31 March 2013 comprised nine non-executive and three executive directors, drawn from a broad spectrum of the business community. 4.4 Mechanisms for shareholders and employees to provide recommendations or direction to the highest governance body. 4.5 Linkage between compensation for members of the highest governance body, senior managers, and executives (including departure arrangements), and the organization's performance (including social and environmental performance). 4.6 Processes in place for the highest governance body to ensure conflicts of interest are avoided. 4.7 Process for determining the qualifications and expertise of the members of the highest governance body for guiding the organization's strategy on economic, environmental, and social topics. 41, 59 Stakeholder engagement and ; Relationship with shareholders 55, 57, 58 Remuneration committee; Executive remuneration; Nonexecutive directors' remuneration No concerns. Opportunity for improvement. The remuneration policy is briefly outlined, stating that "as a general principle, good performers are remunerated in line with the market median, with high achievers and exceptional performers being rewarded towards the market upper quartile". 49 Board Evaluation No concerns. 56, Nomination committee; Directorate No concerns. This committee s terms of reference ensure that, for board appointments, a rigorous, fair and open nomination and appointment process is established which will provide a balance of appropriate skills, knowledge and experience in the boardroom and support strong corporate performance. 4.8 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. 39, 57 Human rights No concerns. Tongaat Hulett has incorporated human rights principles in its practices, and operates within a Code of Business Conduct and Ethics, which supports its commitment to a policy of fair dealing, honesty and integrity in the conduct of its business.this is approved by the board, communicated and distributed to all employees across all levels in the company. Tongaat Hulett Final Report - GRI G3 Gap Analysis - VK - 27 June v2.xls 2 of 7

3 4.9 Procedures of the highest governance body for overseeing the organization's identification and 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 body's 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 organization. 53, Risk, SHE, Social & Ethics Committee; Risk process No concerns. The Risk, SHE, Social & Ethics Committee are tasked with overseeing the of economic, social and environmental performance by the board, including risks and opportunities that the company faces. 49 Board evaluation No concerns. A formal self-evaluation process is described Risk process No concerns. The risk process has been outlined. The precautionary approach applies to the organisations of risk. Precaution may be defined as "caution in advance". The precautionary approach states if an action or policy has a suspected risk of causing harm to the public or to the environment, in the absence of scientific consensus that the action or policy is harmful, the burden of proof that it is not harmful falls on those taking the action. The principle implies that there is a social responsibility to protect the public from exposure to harm, when scientific investigation has found a plausible risk. The Rio Declaration notes: "In order to protect the environment, the precautionary approach shall be widely applied by States according to their capabilities. Where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing costeffective measures to prevent environmental degradation." 4.12 Externally developed economic, environmental, and social charters, principles, or other initiatives to which the organization subscribes or endorses. 27, 30, 39 Strategy and analysis; Carbon ; Human Rights No concerns. United Nations (UN) Global Compact, Carbon Disclosure Project (CDP). Tongaat Hulett is a signatory to the Universal Declaration of Human Rights Memberships in associations (such as industry associations) and/or national/international 33, 44 Promoting sustainable advocacy organizations in which the organization: * Has positions in governance bodies; * Participates in projects or committees; * Provides substantive funding beyond routine membership dues; or * Views membership as strategic. agriculture; Food security 4.14 List of stakeholder groups engaged by the organization. 35, Social performance - Business approach; Stakeholder engagement and social innovation 4.15 Basis for identification and selection of stakeholders with whom to engage Stakeholder engagement and No concerns. The company has various memberships such as the South African Sugar Association, South African Sugarcane Research Institute, principal member of the World Wildlife fund and is looking at the operational and reputational challenges that face businesses in the food sector. No concerns. Each stakeholder group has been listed and discussed. Key stakeholders related to SHE matters have also been listed separately in the 'social performance' reporting section. No concerns. Stakeholder are identified according to their impact / significance / influence on the business, as well as those impacted by the companies operations 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 organization has responded to those key topics and concerns, including through its reporting. 34, Environmental compliance; Stakeholder engagement and 34, Environmental compliance; Stakeholder engagement and No concerns. Approaches for engaging each stakeholder group are clearly articulated. Opportunity for improvement. The section of the report devoted to stakeholder engagement does provide an overview of the main areas of discussion and interest. The established community liaison forums between Tongaat Hulett and interested parties continue to address environmental related complaints. STANDARD DISCLOSURES PART II: Disclosures on Management Approach (DMAs) G3 DMA DMA EC Disclosure on Management Approach EC 42 Economic sustainability - Business approach to empowerment and Opportunity for improvement. An overview of the policy and motivation related to social economic performance is given, however, is lacking an overview of how often and in what format measurement, monitoring and reporting occurs. DMA EN Disclosure on Management Approach EN 29, 34 Environmental stewardship - Business Approach; Third party certifications A high level overview of environmental is given. DMA LA Disclosure on Management Approach LA 34-35, 38 Social performance - Business An overview of SHE is provided. This is managed by the Tongaat Hulett Risk, approach; Employment equity SHE, Social and Ethics Committee oversees the performance of the company against set SHE and targets and objectives, which are detailed in the business s SHE plan. Progress on SHE plans and performance is monitored by the Chief Executive Officer and senior through the various SHE Executive Steering Committees and established reporting systems. DMA HR Disclosure on Management Approach HR 39 Human rights Opportunity for improvement. An overview of the policy related to Human rights is provided, and it's formalisation through the code of ethics. Relationship with unions is described. DMA SO Disclosure on Management Approach SO 53 Risk, SHE, Social & Ethics Opportunity for improvement. Management of Societal aspects, such as corruption are overseen Committee by the Risk, SHE, Social & Ethics Committee. DMA PR Disclosure on Management Approach PR 45 Product responsibility - Business approach Opportunity for improvement. A brief overview of the approach is given. STANDARD DISCLOSURES PART III: s Tongaat Hulett Final Report - GRI G3 Gap Analysis - VK - 27 June v2.xls 3 of 7

4 Economic EC1 EC2 Direct economic value generated and distributed, including revenues, operating costs, 48 Value added statement No concerns. Tongaat Hulett provides a value added statement indicating where their wealth has employee compensation, donations and other community investments, retained earnings, been distributed to. and payments to capital providers and governments. Financial implications and other risks and opportunities for the organization's activities due to climate change Climate change Opportunity for improvement. Tongaat Hulett identifies that climate change will impact the availability of clean water. EC3 Coverage of the organization's defined benefit plan obligations , 103 Post-retirement benefit No concerns. obligations ; Retirement benefits EC4 Significant financial assistance received from government. EC5 Range of ratios of standard entry level wage compared to local minimum wage at significant locations of operation. 18 Chief executive's review Opportunity for improvement. "The recent minimum wage increase in South Africa for agricultural employees, and the 18 percent increase in wages during the 2012/13 years for Zimbabwean agricultural employees is contributing to a reduction in the wage gap. The company has concluded its wage negotiations for the 2013/14 year with increases of 9,04 percent, 8,5 percent and 6,6 percent being concluded in Mozambique, South Africa (sugar milling operations) and Zimbabwe respectively." EC6 EC7 Policy, practices, and proportion of spending on locally-based suppliers at significant locations of operation. Procedures for local hiring and proportion of senior hired from the local community at significant locations of operation. 42 Preferential Procurement In South Africa 38 Employment equity and No concerns. Preferential procurement data and policies are outlined for South African operations. Opportunity for improvement. The report states that the overall proportion of black representation in as at 31 March 2013 was 61.2% percent of permanent staff at this level. EC8 Development and impact of infrastructure investments and services provided primarily for public benefit through commercial, in-kind, or pro bono engagement , 40-42, 43 Biodiversity and land ; Stakeholder engagement and social innovation; Socio-economic development No concerns. In support of government s agricultural and rural development goals and objectives currently unproductive agricultural land is being rehabilitated and in the process creating new employment, housing, social, recreational and commercial opportunities as well as the associated new capital investment. These development opportunities will be facilitated as an integral component of the growth of sustainable cities premised on appropriate densities, public transportation, mixed and multi uses and integration of surrounding communities. EC9 Understanding and describing significant indirect economic impacts, including the extent of impacts. 27, Strategy and analysis; Stakeholder engagement and No concerns. Tongaat Hulett has a significant presence in agriculture and agri-processing sectors in the Southern African Development Community (SADC). The business works with communities, Governments and other partners to meet some of SADC s pressing challenges including job creation, food security, rural development and the provision of renewable energy. Environmental EN1 Materials used by weight or volume. EN2 Percentage of materials used that are recycled input materials. EN3 Direct energy consumption by primary energy source. 31 Energy Opportunity for improvement. The report states that bagasse, coal, wood and gas are used. EN4 Indirect energy consumption by primary source. 31 Energy No concerns. Electricity used is tabulated with 3 years comparable data. EN5 Energy saved due to conservation and efficiency improvements. 31 Energy No concerns. Energy efficiency improvements are discussed. An example of reductions achieved is the 20% reduction on electricity at Meadowdale office. EN6 Initiatives to provide energy-efficient or renewable energy based products and services, 29-30, 31 Climate change; Energy Opportunity for improvement. The report states that the company is working to improve the and reductions in energy requirements as a result of these initiatives. energy efficiency of it's operations, such as switching to greener fuels Energy efficiency projects are listed. Furthermore, the mills have also supplied renewable electricity to supply power to run the mills for many years. Data is provided on the amount of electricity generated, however, there is no data on the reductions achieved as a result of these initiatives. EN7 Initiatives to reduce indirect energy consumption and reductions achieved. 31 Energy Opportunity for improvement. A list of initiatives to reduce indirect energy use has been given. The extent to which indirect energy use has been reduced during the reporting period for use of energy-intensive materials, subcontracted production, business-related travel and employee commuting will in future be reported. Tongaat Hulett Final Report - GRI G3 Gap Analysis - VK - 27 June v2.xls 4 of 7

5 EN8 Total water withdrawal by source. 29, 32 Sustainability s; Water resource Opportunity for improvement. Most of the sugarcane cultivated in South Africa is dependent on natural rainfall while operations in Mozambique, Swaziland and Zimbabwe, practice large-scale irrigation via purpose-built canal systems with water being extracted from rivers. Volumes of municipal water used and volumes supplied to municipality is as potable water is provided. EN9 Water sources significantly affected by withdrawal of water. 32 Water resource Opportunity for improvement. Tongaat Hulett engages with the Council for Scientific and Industrial Research (CSIR) to identify future rainfall patterns and water scarcity due to the evolving impact of climate change. In future, the company will report on water sources significantly affected by the withdrawal of water, especially since large scale irrigation is used in Mozambique, Swaziland and Zimbabwe. EN10 Percentage and total volume of water recycled and reused. 32, 33 Water resource ; Effluent Opportunity for improvement. This has been partially reported. The report provides information on the volume of purified at various mills and supplied to local Municipalities as potable water. EN11 Location and size of land owned, leased, managed in, or adjacent to, protected areas and 31 Biodiversity and land Needs improvement. This indicator is not explicitly stated as per the requirements of this areas of high biodiversity value outside protected areas. indicator. EN12 Description of significant impacts of activities, products, and services on biodiversity in 32 Biodiversity and land No concerns. The company states that it works closely with communities, authorities and Non- protected areas and areas of high biodiversity value outside protected areas. Governmental organisations in its land. EN13 Habitats protected or restored Biodiversity and land No concerns hectares of land being rehabilitated into natural habitat. EN14 Strategies, current actions, and future plans for managing impacts on biodiversity Biodiversity and land No concerns. The reports states that hectares of land are being rehabilitated into natural habitat. Communities, NGOs and authorities are consulted. EN15 Number of IUCN Red List species and national conservation list species with habitats in areas affected by operations, by level of extinction risk. EN16 Total direct and indirect greenhouse gas emissions by weight. 30 Carbon No concerns. Scope 1 and 2 emissions are tabulated with three years comparative data. EN17 Other relevant indirect greenhouse gas emissions by weight. 30 Carbon No concerns. Scope 3 emissions are tabulated with three years comparative data. EN18 Initiatives to reduce greenhouse gas emissions and reductions achieved Climate change Opportunity for improvement. The report states that the company is committed to lowering greenhouse gas emissions associated with the distribution of its products. EN19 Emissions of ozone-depleting substances by weight. EN20 NOx, SOx, and other significant air emissions by type and weight. 31 Air quality Opportunity for improvement. Emissions of SO2 and particulates are monitored. No qualitative data has been given. EN21 Total water discharge by quality and destination. 33 Effluent Opportunity for improvement. Tongaat Hulett reports a 'Zero Effluent' philosophy, describing how discharges are in accordance with environmental requirements. EN22 Total weight of waste by type and disposal method. 33 Waste Opportunity for improvement. Weight of waste types are provided, in future the company will include the disposal method used aside for recycling. EN23 Total number and volume of significant spills. 34 Environmental compliance No concerns. In Maidstone an irrigation pipe burst. The remedial actions implemented included clean-up and remediation of area affected together with a repair of the pipeline. EN24 EN25 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 organization's discharges of water and runoff. 33 Waste Opportunity for improvement. Quantity of hazardous waste is provided, and in future will include details relating to transport, treatment etc. EN26 Initiatives to mitigate environmental impacts of products and services, and extent of impact mitigation. 30, Carbon ; Biodiversity and land Opportunity for improvement. Scope 3 emissions are offset by a company based in Durban and rehabilitation of land that is unproductive to agriculture. Other efforts to mitigate other environmental impacts have not been explicitly discussed. EN27 EN28 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 noncompliance 34 Environmental compliance No concerns. There were no material incidents, fines or non-monetary sanctions for non- with environmental laws and regulations. compliance with applicable environmental regulations during the year under review. EN29 Significant environmental impacts of transporting products and other goods and materials used for the organization's operations, and transporting members of the workforce. EN30 Total environmental protection expenditures and investments by type Promoting sustainable agriculture Opportunity for improvement. Reporting on this indicator includes a discussion of TH's sustainable agricultural practices - which is related to prevention. No costs are given. Social: Labour Practices and Decent Work Tongaat Hulett Final Report - GRI G3 Gap Analysis - VK - 27 June v2.xls 5 of 7

6 LA1 Total workforce by employment type, employment contract, and region. 29, 38 Sustainability s; Employment equity and LA2 Total number and rate of employee turnover by age group, gender, and region. 38 Employment equity and Opportunity for improvement. Total workforce is given yet this could be improved by tabulating according to type, contract and region. Opportunity for improvement. Employee turnover is given as a total percentage, however not broken down according to age group, gender, and region. LA3 Benefits provided to full-time employees that are not provided to temporary or part-time employees, by major operations. LA4 Percentage of employees covered by collective bargaining agreements. 40 Human rights; Freedom of association and collective bargaining No concerns. There are recognition agreements with12 different unions as at 31 March 2013 and approximately 74 percent of permanent employees are members of unions. Unions formally recognised are listed. LA5 LA6 LA7 Minimum notice period's regarding significant operational changes, including whether it is specified in collective agreements. Percentage of total workforce represented in formal joint -worker health and safety committees that help monitor and advise on occupational health and safety programs. Rates of injury, occupational diseases, lost days, and absenteeism, and number of workrelated fatalities by region. N/A N/A This indicator is not covered in the report. 40 Freedom of association and collective bargaining 29, 30, 35 Organisational profile; Achievements; Safety No concerns. The trade unions represent the employees interest in also areas of health and safety. No concerns. Achieved an LTIFR of 0,09 per hours worked, three fatalities. Analysis of fatality trends and the interventions being implemented has been provided. LA8 Education, training, counselling, prevention, and risk-control programs in place to assist workforce members, their families, or community members regarding serious diseases. 36, 37, 40-42, 43 Health - HIV and AIDS, Malaria, Occupational health; Stakeholder Engagement And Social Innovation; Socioeconomic development No concerns. Assessments and education programmes are conducted. LA9 Health and safety topics covered in formal agreements with trade unions. 42 Stakeholder engagement Opportunity for improvement. Managers in all company operations interact with trade unions on relevant employment issues. This includes health and safety. LA10 Average hours of training per year per employee by employee category. 39 Formal training programs Opportunity for improvement. LA11 Programs for skills and lifelong learning that support the continued employability of employees and assist them in managing career endings. 37, 38 Human capital - Talent and people development; Existing skills; Employment equity and No concerns. Specific programmes are outlined. No specific mention is made regarding the link to managing career endings. LA12 Percentage of employees receiving regular performance and career development reviews. 37 Human capital - Talent and people development Opportunity for improvement. The report states "Competency gaps and individual training and development needs are being identified and action plans developed to address these needs". LA13 Composition of governance bodies and breakdown of employees per category according 38 Employment equity and Opportunity for improvement. Employment equity data is provided for South African operations to gender, age group, minority group membership, and other indicators of diversity. only. LA14 Ratio of basic salary of men to women by employee category. Social: Human Rights HR1 Percentage and total number of significant investment agreements that include human N/A N/A This indicator is not covered in the report. NC rights clauses or that have undergone human rights screening. HR2 Percentage of significant suppliers and contractors that have undergone screening on human rights and actions taken. HR3 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. N/A N/A This indicator is not covered in the report. NC 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. 40 Freedom of association and collective bargaining No concerns. Tongaat Hulett employees have the right to freedom of association. This right is also entrenched in the company s code of ethics, business principles and policies. There were industrial action incidents that resulted in 6 days lost. The financial cost impact was R7.9m. HR6 Operations identified as having significant risk for incidents of child labour, and measures taken to contribute to the elimination of child labour. 40 Child labour, forced and compulsory labour No concerns. Tongaat Hulett does not make use of child labour and does not tolerate the inhumane treatment of employees, including any form of illegal forced labour, physical punishment or other abuse. Tongaat Hulett Final Report - GRI G3 Gap Analysis - VK - 27 June v2.xls 6 of 7

7 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. 40 Child labour, forced and compulsory labour No concerns. Tongaat Hulett does not make use of child labour and does not tolerate the inhumane treatment of employees, including any form of illegal forced labour, physical punishment or other abuse. HR8 HR9 Social: Society SO1 Percentage of security personnel trained in the organization's policies or procedures concerning aspects of human rights that are relevant to operations. Total number of incidents of violations involving rights of indigenous people and actions N/A N/A This indicator is not covered in the report. NC taken. Nature, scope, and effectiveness of any programs and practices that assess and manage the impacts of operations on communities, including entering, operating, and exiting. 19, 4 Chief Executive's Review; Opportunity for improvement. Tongaat Hulett has a significant community impact and is Tongaat Hulett and its Strategic dedicated to small-scale farmer development and other aspects of SED focus. Positioning SO2 Percentage and total number of business units analysed for risks related to corruption. SO3 Percentage of employees trained in organization's anti-corruption policies and procedures. 40 Anti-bribery and corruption Opportunity for improvement. A statement is made about how upholding the core values actively works to prevent bribery and corruption, and that there are procedures in place regarding gifts and donations. SO4 Actions taken in response to incidents of corruption. 40 Anti-bribery and corruption; Code of Business conduct and Ethics No concerns. The policy relating to corruption is stated: "Employees of Tongaat Hulett who do not comply with the company s Code of Ethics policy face disciplinary action, including dismissal or termination of their contract." 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 N/A N/A This indicator was not covered in the report. NC practices and their outcomes. SO8 Monetary value of significant fines and total number of non-monetary sanctions for noncompliance with laws and regulations. N/A N/A This indicator was not covered in the report. NC Social: Product Responsibility PR1 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. 36, 45 Food safety; Customer health and safety No concerns. On-going attention is paid to the requirements of ISO 9001, the Hazard Analysis Critical Control Point system (HACCP) and ISO 22000, in terms of quality and food safety standards at all operations. PR2 PR3 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. 45 Product Responsibility - Customer Health and Safety No concerns. The company complies with all relevant safety, health, environmental and quality legislation in each of the countries of operation as well as striving for implementation of industry best practice. 45 Product and service labelling No concerns. All products carry product labels describing information about the product, in compliance with the respective country legislation and labelling regulations. PR4 Total number of incidents of non-compliance with regulations and voluntary codes concerning product and service information and labelling, by type of outcomes. 45 Product and service labelling No concerns. All products carry product labels describing information about the product, in compliance with the respective country legislation and labelling regulations. PR5 PR6 PR7 PR8 PR9 Practices related to customer satisfaction, including results of surveys measuring customer satisfaction. Programs 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. 42 Stakeholder engagement and Needs improvement. The reports states that Tongaat Hulett is in regular contact with its largest customers to ensure exceptional customer service levels and hat it seeks to work together with these stakeholders on areas of mutual concern. 45 Marketing products responsibly No concerns. N/A N/A This indicator was not covered in the report. NC Tongaat Hulett Final Report - GRI G3 Gap Analysis - VK - 27 June v2.xls 7 of 7