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Although the Group Five 2014 Integrated Annual Report and the Supplementary Section of the report are not compliant with GRI G4, both documents include relevant aspects of the disclosures, as detailed below:
GENERAL STANDARD DISCLOSURES
INDICATOR NUMBER DISCLOSURE WHERE THIS APPEARS IN GROUP FIVE’S REPORTING
STRATEGY & ANALYSIS
G4-1 CEO Letter Supplementary Section of the report pages 4 – 5
G4-2 Key impacts, risks, and opportunities
Integrated Annual Report pages 26 – 59
ORGANISATIONAL PROFILE
G4-3 Organisation name Integrated Annual Report and Supplementary Section of the report front pages
G4-4 Primary brands, products, and services
Integrated Annual Report pages 10 – 11 and 116 – 118
G4-5 Headquarters location Integrated Annual Report and Supplementary Section of the report back pages
G4-6 Where the organisation operates
Integrated Annual Report page 8 and Supplementary Section of the report pages 6 – 7
G4-7 Nature of ownership and legal form
Integrated Annual Report pages 166 – 168
G4-8 Markets served Integrated Annual Report page 28 – 33 and pages 8 – 21 of Supplementary Section of the report
G4-9 Scale of the organisation Integrated Annual Report pages 4 – 9 and 60 – 87
G4-10 Total number of employees by type
Supplementary Section of the report pages 84, 110 – 113
G4-11 Collective bargaining agreements
The percentage of total employees is not reported.
G4-12 Supply chain description Although the supply chain is discussed in the Supplementary Section of the report on pages 41 and 114 the supply chain is not discussed in detail.
G4-13 Organisational changes during the reporting period
Integrated Annual Report pages 13, 60 – 85
G4-14 Precautionary principle Supplementary Section of the report pages 40 – 46
G4-15 External charters, principles, or other initiatives
The group adheres to a number of external charters and principles, such as the Green Building Council in South Africa and the Carbon Disclosure Project. Refer to the CDP report.
G4-16 Membership associations Supplementary Section of the report page 34
GLOBAL REPORTING INITIATIVE (GRI) G4 DISCLOSURE INDEX
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GENERAL STANDARD DISCLOSURES – CONTINUED
INDICATOR NUMBER DISCLOSURE WHERE THIS APPEARS IN GROUP FIVE’S REPORTING
IDENTIFIED MATERIAL ASPECTS & BOUNDARIES
G4-17 Entities included in financial statements
Integrated Annual Report pages 161 – 163 and Supplementary Section of the report pages 16 – 18
G4-18 Process for defining report boundaries and content
Integrated Annual Report page 2
G4-19 Material aspects included in the report
Integrated Annual Report pages 18 – 23, 28 – 58
G4-20 Descriptions of material aspect boundaries within the organisation
Integrated Annual Report pages 28 – 58
G4-21 Descriptions of material aspect boundaries outside the organisation
Stakeholders and their issues was provided in the Integrated Annual Report pages 18 – 23
G4-22 Restatements There were no restatements
G4-23 Changes from previous reports in terms of scope and/or boundaries
N/a – this is the company’s first report under GRI’s G4 guidelines
STAKEHOLDER ENGAGEMENT
G4-24 Stakeholder groups Integrated Annual Report page 19
G4-25 How stakeholders were identified
Integrated Annual Report pages 18 – 19
G4-26 Approach to stakeholder engagement
Integrated Annual Report pages 18 – 23
G4-27 Topics raised during stakeholder engagements
Integrated Annual Report pages 18 – 23
REPORT PROFILE
G4-28 Reporting period Integrated Annual Report page 2
G4-29 Date of most recent report The previous report was published on 2 August 2013
G4-30 Reporting cycle Annual
G4-31 Report contact Inegrated Annual Report page 2
G4-32 “In accordance” option, GRI Index and report assurance
Group Five reported in line with a number of G4 guidelines
G4-33 Policy regarding report assurance
Integrated Annual Report pages 90 – 95
GOVERNANCE
G4-34 Governance structure of the organisation
Supplementary Section of the report pages 48 – 75
ETHICS & INTEGRITY
G4-56 Code of conduct Supplementary Section of the report pages 32 – 33
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SPECIFIC STANDARD DISCLOSURES AND SECTOR DISCLOSURES
INDICATOR NUMBER INDICATOR NAME DETAILED DESCRIPTION
PAGES WHERE CERTAIN ASPECTS ARE REPORTED AGAINST
ECONOMIC CATEGORY
Economic performance
G4-EC1 Economic value Direct economic value generated: − Revenues
Economic value distributed: − Operating costs − Employee wages and benefits − Payments to providers of capital − Payments to government (by country) − Community investments
Economic value retained (calculated as ‘Direct economic value generated’ less ‘Economic value distributed’)
b. To better assess local economic impacts, report EVG&D separately at counwtry, regional, or market levels, where significant. Report the criteria used for defining significance.
Integrated Annual Report page 97
G4-EC2 Climate change risks
Risks and opportunities posed by climate change that have the potential to generate substantive changes in operations, revenue, or expenditure, including:
A description of the risk or opportunity and its classification as either physical, regulatory, or other
A description of the impact associated with the risk or opportunity
The financial implications of the risk or opportunity before action is taken
The methods used to manage the risk or opportunity
The costs of actions taken to manage the risk or opportunity
Supplementary Section of the report page 128 and Carbon Disclosure Project report
G4-EC3 Benefit plan coverage
a. Where the plan’s liabilities are met by the organisation’s general resources, report the estimated value of those liabilities.
b. Where a separate fund exists to pay the plan’s pension liabilities, report:
The extent to which the scheme’s liabilities are estimated to be covered by the assets that have been set aside to meet them
The basis on which that estimate has been arrived at
When that estimate was made
c. Where a fund set up to pay the plan’s pension liabilities is not fully covered, explain the strategy, if any, adopted by the employer to work towards full coverage, and the time scale, if any, by which the employer hopes to achieve full coverage.
d. Percentage of salary contributed by employee or employer.
e. Level of participation in retirement plans (such as participation in mandatory or voluntary schemes, regional or country-based schemes, or those with financial impact).
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SPECIFIC STANDARD DISCLOSURES AND SECTOR DISCLOSURES CONTINUED
INDICATOR NUMBER INDICATOR NAME DETAILED DESCRIPTION
PAGES WHERE CERTAIN ASPECTS ARE REPORTED AGAINST
G4-EC4 Financial assistance from the government
a. Total monetary value of financial assistance received by the organisation from governments during the reporting period, including, as a minimum:
Tax relief and tax credits Subsidies Investment grants, research and development
grants, and other relevant types of grants Awards Royalty holidays Financial assistance from Export Credit
Agencies (ECAs) Financial incentives Other financial benefits received or receivable
from any government for any operation
b. Information above by country.c. Whether, and the extent to which, the government
is present in the shareholding structure.
Group Five does not provide financial assitance to governments outside of normal taxes, as outlined in the Integrated Annual Report page 97
Market presence
Indirect economic impacts
G4-EC7 Infrastructure investments
a. Extent of development of significant infrastructure investments and services supported.
b. Current or expected impacts on communities and local economies. Report positive and negative impacts, where relevant.
c. Whether these investments and services are commercial, in-kind, or pro bono engagements.
Integrated Annual Report pages 4 – 9, Supplementary Section of the report pages 118 – 119
Indirect economic impacts
G4-EC9 Local suppliers a. Percentage of the procurement budget used for significant locations of operation spent on suppliers local to that operation (such as percentage of products and services purchased locally).
b. Report the organisation’s geographical definition of ‘local’.
c. Report the definition used for ‘significant locations of operation’.
Supplementary Section of the report pages 114 – 117
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SPECIFIC STANDARD DISCLOSURES AND SECTOR DISCLOSURES CONTINUED
INDICATOR NUMBER INDICATOR NAME DETAILED DESCRIPTION
PAGES WHERE CERTAIN ASPECTS ARE REPORTED AGAINST
ENVIRONMENTAL CATEGORY
G4-EN3 Energy consumption (Scope 1 + 2)
a. Total fuel consumption from nonrenewable sources in joules or multiples, including fuel types used.
b. Total fuel consumption from renewable fuel sources in joules or multiples, including fuel types used.
c. Report in joules, watt-hours or multiples, the total: Electricity consumption Heating consumption Cooling consumption Steam consumption
d. In joules, watt-hours or multiples, the total: Electricity sold Heating sold Cooling sold Steam sold.
e. Total energy consumption in joules or multiples.f. Standards, methodologies, and assumptions used.g. Source of the conversion factors used.
Supplementary Section of the report pages 124 – 129 and Carbon Disclosure Project Report
G4-EN4 Energy consumption (Scope 3)
a. Energy consumed outside of the organisation, in joules or multiples.
b. Standards, methodologies, and assumptions used.c. Source of the conversion factors used.
Supplementary Section of the report pages 124 – 129 and Carbon Disclosure Project Report
G4-EN5 Energy intensity a. Energy intensity ratio.b. Organisation-specific metric (the ratio
denominator) chosen to calculate the ratio.c. Types of energy included in the intensity ratio: fuel,
electricity, heating, cooling, steam, or all.d. Whether the ratio uses energy consumed within the
organisation, outside of it or both.
Supplementary Section of the report pages 124 – 129 and Carbon Disclosure Project Report
G4-EN6 Energy reductions a. Amount of reductions in energy consumption achieved as a direct result of conservation and efficiency initiatives, in joules or multiples.
b. Types of energy included in the reductions: fuel, electricity, heating, cooling, and steam.
c. Basis for calculating reductions in energy consumption such as base year or baseline, and the rationale for choosing it.
d. Standards, methodologies, and assumptions used.
Supplementary Section of the report pages 124 – 129 and Carbon Disclosure Project Report
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SPECIFIC STANDARD DISCLOSURES AND SECTOR DISCLOSURES CONTINUED
INDICATOR NUMBER INDICATOR NAME DETAILED DESCRIPTION
PAGES WHERE CERTAIN ASPECTS ARE REPORTED AGAINST
ENVIRONMENTAL CATEGORY CONTINUED
G4-EN7 Energy reductions in products and services
a. Reductions in the energy requirements of sold products and services achieved during the reporting period, in joules or multiples.
b. Basis for calculating reductions in energy consumption such as base year or baseline, and the rationale for choosing it.
c. Report standards, methodologies, and assumptions used.
Water
Three indicators fall under this aspect. If aspect is considered material, at least one needs to be reported
G4-EN8 Water withdrawals by source
a. Total volume of water withdrawn from the following sources:
Surface water, including water from wetlands, rivers, lakes, and oceans
Ground water Rainwater collected directly and stored by the
organisation Waste water from another organisation Municipal water supplies or other water
utilities.
b. Report standards, methodologies, and assumptions used.
Supplementary Section of the report page 128 and Carbon Disclosure Project Report
G4-EN9 Water sources affected by withdrawals
a. Total number of water sources significantly affected by withdrawal by type
Size of water source Whether or not the source is designated as a
protected area (nationally or internationally) Biodiversity value (such as species diversity and
endemism, total number of protected species) Value or importance of water source to local
communities and indigenous peoples.b. Standards, methodologies, and
assumptions used.
G4-EN10 Water recycled and reused
a. Total volume of water recycled and reused by the organisation.
b. Total volume of water recycled and reused as a percentage of the total water withdrawal reported under Indicator G4-EN8.
c. Standards, methodologies, and assumptions used.
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INDICATOR NUMBER INDICATOR NAME DETAILED DESCRIPTION
PAGES WHERE CERTAIN ASPECTS ARE REPORTED AGAINST
ENVIRONMENTAL CATEGORY CONTINUED
Emissions
Seven indicators fall under this aspect, if it is considered to be material at least one must be disclosed
G4-EN15 GHG emissions (Scope 1)
a. Gross direct (Scope 1) GHG emissions in metric tons of CO2 equivalent, independent of any GHG trades, such as purchases, sales, or transfers of offsets or allowances.
b. Gases included in the calculation (whether CO2, CH4, N
2O, HFCs, PFCs, SF6, NF3, or all).c. Biogenic CO2 emissions in metric tons of CO2
equivalent separately from the gross direct (Scope 1) GHG emissions.
d. Chosen base year, the rationale for choosing the base year, emissions in the base year, and the context for any significant changes in emissions that triggered recalculations of base year emissions.
e. Standards, methodologies, and assumptions used.f. Source of the emission factors used and the global
warming potential (GWP) rates used or a reference to the GWP source.
g. Chosen consolidation approach for emissions (equity share, financial control, operational control).
G4-EN16 GHG emissions (Scope 2)
a. Gross energy indirect (Scope 2) GHG emissions in metric tons of CO2 equivalent, independent of any GHG trades, such as purchases, sales, or transfers of offsets or allowances.
b. Gases included in the calculation, if available.c. Chosen base year, the rationale for choosing the
base year, emissions in the base year, and the context for any significant changes in emissions that triggered recalculations of base year emissions.
d. Standards, methodologies, and assumptions used.e. Source of the emission factors used and the global
warming potential (GWP) rates used or a reference to the GWP source, if available.
f. Chosen consolidation approach for emissions (equity share, financial control, operational control).
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SPECIFIC STANDARD DISCLOSURES AND SECTOR DISCLOSURES CONTINUED
INDICATOR NUMBER INDICATOR NAME DETAILED DESCRIPTION
PAGES WHERE CERTAIN ASPECTS ARE REPORTED AGAINST
ENVIRONMENTAL CATEGORY CONTINUED
Emissions continued
G4-EN17 GHG emissions (Scope 3)
a. Gross other indirect (Scope 3) GHG emissions in metric tons of CO2 equivalent, excluding indirect emissions from the generation of purchased or acquired electricity, heating, cooling, and steam consumed by the organisation (these indirect emissions are reported in Indicator G4-EN16). Exclude any GHG trades, such as purchases, sales, or transfers of offsets or allowances.
b. Gases included in the calculation, if available.c. Biogenic CO2 emissions in metric tons of CO2
equivalent separately from the gross other indirect (Scope 3) GHG emissions.
d. Other indirect (Scope 3) emissions categories and activities included in the calculation.
e. Chosen base year, the rationale for choosing the base year, emissions in the base year, and the context for any significant changes in emissions that triggered recalculations of base year emissions.
f. Standards, methodologies, and assumptions used.g. Source of the emission factors used and the global
warming potential (GWP) rates used or a reference to the GWP source, if available.
G4-EN18 GHG emissions intensity
a. GHG emissions intensity ratio.b. Organisation-specific metric (the ratio
denominator) chosen to calculate the ratio.c. Types of GHG emissions included in the intensity
ratio: direct (Scope 1), energy indirect (Scope 2), other indirect (Scope 3).
d. Gases included in the calculation.
G4-EN19 Reduction of GHG emissions
a. Amount of GHG emissions reductions achieved as a direct result of initiatives to reduce emissions, in metric tons of CO2 equivalent.
b. Gases included in the calculation (whether CO2, CH4, N2O, HFCs, PFCs, SF6, NF3, or all).
c. Chosen base year or baseline and the rationale for choosing it.
d. Standards, methodologies, and assumptions used.e. Whether the reductions in GHG emissions occurred
in direct (Scope 1), energy indirect (Scope 2), or other indirect (Scope 3) emissions.
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INDICATOR NUMBER INDICATOR NAME DETAILED DESCRIPTION
PAGES WHERE CERTAIN ASPECTS ARE REPORTED AGAINST
ENVIRONMENTAL CATEGORY CONTINUED
Emissions continued
G4-EN21 NOx, SOx and other emissions
a. Amount of significant air emissions, in kilograms or multiples for each of the following:
NOx SOx Persistent organic pollutants (POP) Volatile organic compounds (VOC) Hazardous air pollutants (HAP) Particulate matter (PM) Other standard categories of air emissions
identified in relevant regulations.
b. Standards, methodologies, and assumptions used.c. Source of the emission factors used.
Effluents and waste
Five indicators fall under this aspect, if it is considered to be material at least one must be disclosed
G4-EN22 Water discharge a. Total volume of planned and unplanned water discharges by:
Destination Quality of the water including treatment
method Whether it was reused by another organisation.
b. Standards, methodologies, and assumptions used.”
G4-EN23 Waste by type and disposal method
a. Total weight of hazardous and nonhazardous waste, by the following disposal methods:
Reuse Recycling Composting Recovery, including energy recovery Incineration (mass burn) Deep well injection Landfill On-site storage Other (to be specified by the organisation)
b. How the waste disposal method has been determined:
Disposed of directly by the organisation or otherwise directly confirmed
Information provided by the waste disposal contractor
Organisational defaults of the waste disposal contractor”
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INDICATOR NUMBER INDICATOR NAME DETAILED DESCRIPTION
PAGES WHERE CERTAIN ASPECTS ARE REPORTED AGAINST
ENVIRONMENTAL CATEGORY CONTINUED
Effluents and waste continued
G4-EN24 Significant spills a. Total number and total volume of recorded significant spills.
b. For spills that were reported in the organisation’s financial statements, report the additional following information for each such spill:
Location of spill Volume of spill Material of spill, categorized by:
− Oil spills (soil or water surfaces) − Fuel spills (soil or water surfaces) − Spills of wastes (soil or water surfaces) − Spills of chemicals (mostly soil or water
surfaces) − Other (to be specified by the organisation)
c. Impacts of significant spills.
G4-EN25 Hazardous waste a. Total weight for each of the following: Hazardous waste transported Hazardous waste imported Hazardous waste exported Hazardous waste treated.
b. Percentage of hazardous waste shipped internationally.
G4-EN26 Biodiversity affected by runoff
Water bodies and related habitats that are significantly affected by water discharges based on the criteria described in the Compilation section below, adding information on:
Size of water body and related habitat Whether the water body and related habitat
is designated as a protected area (nationally or internationally)
Biodiversity value (such as total number of protected species).
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INDICATOR NUMBER INDICATOR NAME DETAILED DESCRIPTION
PAGES WHERE CERTAIN ASPECTS ARE REPORTED AGAINST
ENVIRONMENTAL CATEGORY CONTINUED
Compliance continued
One indicator falls under this aspect as detailed below. If aspect is considered material, this needs to be reported
G4-EN29 Environmental fines and sanctions
a. Significant fines and non-monetary sanctions in terms of:
Total monetary value of significant fines Total number of non-monetary sanctions Cases brought through dispute resolution
mechanisms.b. Where organisations have not identified any
noncompliance with laws or regulations, a brief statement of this fact is sufficient.
SOCIAL : LABOUR PRACTICES & DECENT WORK
Employment
G4-LA2 Benefits provided to full-time employees
a. Benefits which are standard for full-time employees of the organisation but are not provided to temporary or part-time employees, by significant locations of operation. These include, as a minimum:
Life insurance Health care Disability and invalidity coverage Parental leave Retirement provision Stock ownership Others.
b. Definition used for ‘significant locations of operation’.
Supplementary Section of the report pages 81 – 82
Aspect - Labour/management relations
G4-LA4 Notice periods regarding operational changes
a. Minimum number of weeks’ notice typically provided to employees and their elected representatives prior to the implementation of significant operational changes that could substantially affect them.
b. For organisations with collective bargaining agreements, report whether the notice period and provisions for consultation and negotiation are specified in collective agreements.
Supplementary Section of the report page 87
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INDICATOR NUMBER INDICATOR NAME DETAILED DESCRIPTION
PAGES WHERE CERTAIN ASPECTS ARE REPORTED AGAINST
SOCIAL: LABOUR PRACTICES & DECENT WORK CONTINUED
Occupational health and safety continued
Four indicators are included under this aspect, at least one of which must be disclosed if aspect is considered material
G4-LA5 Workforce represented in health and safety committees
a. Level at which each formal joint management-worker health and safety committee typically operates within the organisation.
b. Percentage of the total workforce represented in formal joint management-worker health and safety committees.
Supplementary Section of the report page 101
G4-LA6 Rates of injury, occupational disease, lost days, absenteeism, and work-related fatalities
a. Types of injury, injury rate (IR), occupational diseases rate (ODR), lost day rate (LDR), absentee rate (AR), and work-related fatalities, for the total workforce (that is, total employees plus supervised workers), by:
Region Gender
b. Types of injury, injury rate (IR), occupational diseases rate (ODR), lost day rate (LDR), absentee rate (AR), and work-related fatalities for independent contractors working on-site to whom the organisation is liable for the general safety of the working environment, by:
Region Gender
c. System of rules applied in recording and reporting accident statistics.
Supplementary Section of the report pages 88 – 101
G4-LA7 Workers with high incidence risk of diseases
Whether there are workers who are involved in occupational activities who have a high incidence or high risk of specific diseases.
Supplementary Section of the report pages 88 – 93
Training and education
G4-LA9 Average hours of training for employees
Average hours of training that the organisation’s employees have undertaken during the reporting period, by:
Gender Employee category.
Supplementary Section of the report page 103
G4-LA10 Programs for skills management managing career endings
a. Type and scope of programs implemented and assistance provided to upgrade employee skills.
b. Transition assistance programs provided to facilitate continued employability and the management of career endings resulting from retirement or termination of employment.
Supplementary Section of the report page 108
G4-LA11 Employees receiving performance and career development reviews
Percentage of total employees by gender and by employee category who received a regular performance and career development review during the reporting period.
Supplementary Section of the report page 83
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SOCIAL: LABOUR PRACTICES & DECENT WORK CONTINUED
Diversity and equal opportunity
G4-LA12 Composition of governance bodies and employees
a. Percentage of individuals within the organisation’s governance bodies in each of the following diversity categories:
Gender Age group: under 30 years old, 30 – 50 years
old, over 50 years old Minority groups Other indicators of diversity, where relevant
b. Percentage of employees per employee category in each of the following diversity categories:
Gender Age group: under 30 years old, 30 – 50 years
old, over 50 years old Minority groups Other indicators of diversity, where relevant.
Supplementary Section of the report pages 112 – 113
SOCIAL: SOCIETY
Local communities
G4-SO1 Local community engagement, impact assessments and development programs
Percentage of operations with implemented local community engagement, impact assessments, and development programs, including the use of:
Social impact assessments, including gender impact assessments, based on participatory processes
Environmental impact assessments and ongoing monitoring
Public disclosure of results of environmental and social impact assessments
Local community development programs based on local communities’ needs
Stakeholder engagement plans based on stakeholder mapping
Broad-based local community consultation committees and processes that include vulnerable groups
Works councils, occupational health and safety committees and other employee representation bodies to deal with impacts
Formal local community grievance processes.
Supplementary Section of the report pages 118 – 119
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SPECIFIC STANDARD DISCLOSURES AND SECTOR DISCLOSURES CONTINUED
INDICATOR NUMBER INDICATOR NAME DETAILED DESCRIPTION
PAGES WHERE CERTAIN ASPECTS ARE REPORTED AGAINST
SOCIAL : SOCIETY CONTINUED
Anti-corruption
G4-SO4 Communications and training on anti-corruption
a. Total number and percentage of governance body members that the organisation’s anti-corruption policies and procedures have been communicated to, broken down by region.
b. Total number and percentage of employees that the organisation’s anti-corruption policies and procedures have been communicated to, broken down by employee category and region.
c. Total number and percentage of business partners that the organisation’s anti-corruption policies and procedures have been communicated to, broken down by type of business partner and region.
d. Total number and percentage of governance body members that have received training on anti-corruption, broken down by region.
e. Total number and percentage of employees that have received training on anti-corruption, broken down by employee category and region.
Supplementary Section of the report pages 38 – 39 (limited disclosure)
G4-SO5 Confirmed incidents of corruption
a. Total number and nature of confirmed incidents of corruption.
b. Total number of confirmed incidents in which employees were dismissed or disciplined for corruption.
c. Total number of confirmed incidents when contracts with business partners were terminated or not renewed due to violations related to corruption.
d. Public legal cases regarding corruption brought against the organisation or its employees during the reporting period and the outcomes of such cases.
Supplementary Section of the report page 33 (limited disclosure)
The group did not have public legal cases during the year
Public policy
One indicator is included under this aspect, which must be disclosed if aspect is consdered material
G4-SO6 Political contributions
a. Total monetary value of financial and in-kind political contributions made directly and indirectly by the organisation by country and recipient/beneficiary.
b. How the monetary value of in-kind contributions was estimated, if applicable.
The group does not make any political contributions
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SOCIAL : SOCIETY
Anti-competitive behaviour
G4-SO7 Anti-competitive behaviour
a. Total number of legal actions pending or completed during the reporting period regarding anti-competitive behaviour and violations of anti-trust and monopoly legislation in which the organisation has been identified as a participant.
b. Main outcomes of completed legal actions, including any decisions or judgments.”
Integrated Annual Report pages 82 – 83 and Supplementary Section of the report pages 38 and 45
Compliance
G4-SO8 Fines for non-compliance with laws
a. Significant fines and non-monetary sanctions in terms of:
Total monetary value of significant fines Total number of non-monetary sanctions Cases brought through dispute resolution
mechanisms
b. If the organisation has not identified any non-compliance with laws or regulations, a brief statement of this fact is sufficient.
c. Context against which significant fines and non-monetary sanctions were incurred.
The group did not have fines during the year