Creating Value with the Future in Mind - Anglo American South Africa

Our approach governance and management for sustainable development
Two dedicated business integrity
managers, who operate within a
broader risk management and
business assurance team, oversee
implementation of the policy by
working with senior managers in our
business units and corporate functions
and assisting them in putting in place
adequate procedures for managing
corruption risks.
Corruption risk assessments are
an essential aspect of the Group’s
procedures. The Group’s business
units and corporate functions are
required to periodically conduct
corruption risk assessments using an
internally developed risk assessment
tool. Through a series of questions, the
tool assesses the internal and external
risks associated with the location and
nature of an operation and the internal
controls in place to manage the
identified risks. When a risk is
determined to be unacceptably
high, an action plan is developed to
strengthen the internal controls to
manage the risk.
In line with our commitment to high
standards of business assurance, the
risk assessment process and action
planning are audited annually by our
internal audit team.
The adequacy of our policy and
procedures are under continual review
to provide reasonable assurance that
we consistently meet our commitment
to tackling corruption in all its forms,
and remaining in full compliance with
all relevant anti-corruption legislation,
including the UK Bribery Act which
came into force in July 2011.
Anti-corruption communication
and awareness
The key aspects of our business
integrity policy are included in
our induction programmes across
the Group.
We provide specific business integrity
training to all employees who may be
exposed to corruption risks owing to
the nature of their work. This includes
an online training course and a
three-hour workshop, both of which
are designed to raise awareness of our
business integrity policy and provide
employees with the opportunity to
discuss and apply the performance
standards to business integrity
dilemmas that they may face. By the
end of 2012, more than 3,500
Significant
progress has
been made
integrating
sustainability
factors into
the decisionmaking,
planning
and
development
process for
major capital
projects.
employees, including senior managers
of business units and corporate
functions, had taken part in over
180 training sessions (1) and more than
2,800 employees had completed the
online refresher course. During the
training, participants are advised
of where to go for advice and how
to report any business integrity
concerns, including through our
whistleblowing system.
Facilitating whistleblowing
Our employees are required to report
any breaches, or potential breaches,
of our Business Integrity Policy. Our
independently managed SpeakUp
facility is a confidential and secure
way for our employees, contractors,
suppliers, business partners and
other external stakeholders to report
concerns about conduct that is
contrary to our values and integrity
standards. SpeakUp is available
24 hours a day, seven days a week
and provides telephone, email and
website contacts in the regions in
which Anglo American operates.
We do not tolerate any form of
retaliation against employees raising
concerns in good faith. Any allegations
of harassment or intimidation by others
as a result of contacting SpeakUp
is investigated and, if required,
appropriate disciplinary action is taken,
which can include dismissal of those
responsible for reprisals.
During 2012, we received 285 alerts
(2011: 299). Every alert is evaluated
and, where appropriate, investigated.
The largest proportion of reports in
2012 related to human resource issues
(138), followed by a range of other
matters including procurement,
accounting, and health and safety. In
total, 195 alerts were closed following
investigation, of which 55 resulted in
management action. Disciplinary
proceedings, including termination,
are instituted where employees are
found to have behaved contrary to
our principles. In 2012 there were
no criminal cases regarding bribery
brought against Anglo American or
any of its employees.
(1)
These statistics reflect training sessions facilitated by
the Group’s business integrity managers only. Some
employees may have attended sessions more than
once. A number of business units have conducted their
own workshops using dedicated trainers, resulting in
an additional 1,000 employees and contractors having
been trained.
Integrating sustainability
into our wider business
To help embed sustainability
requirements into our business
processes and decision-making we
established a sustainability integration
team in 2010.
Sustainability considerations now
play a bigger role in strategic planning
and due diligence processes for
mergers and acquisitions, as well as
business improvement processes and
reviews at operations. However, the
most significant progress has been
integrating sustainability factors
into the decision-making, planning
and development process for major
capital projects.
Last year, we reported for the first
time on our Sustainability Valuation
Approach (SVA), a robust
methodology which applies a
financial and non-financial value to
the sustainability drivers that could
impact on the successful delivery of
major projects. By understanding,
characterising and then factoring in the
value of sustainability considerations
early on in a project’s development, we
gain a better understanding of how the
sustainability factors impact on the
project’s outcomes in the long term.
(See case study on page 10.)
In 2012, we moved from the concept
and pilot phase to embedding the
SVA into our project evaluation
process. The new process will be
mandatory for all business units from
the end of the first quarter of 2013.
Group sustainability representatives
take part in multi-disciplinary
acquisition and investment reviews
across the project development life
cycle, providing information to assist
in investment decision-making.
During 2012, the Group completed
65 reviews.
20 Anglo American plc Sustainable Development Report 2012