SAMCODES ESG Working Group

Thank you for taking the time to provide the Working Group with feedback on our first Consultation Document. The responses to this will help ensure that updates to the SAMESG Guideline and integration of ESG considerations into the SAMCODES delivers what stakeholders expect of it.

If you would like to be added to our stakeholder database, please send an email to : Sam@saimm.co.za

Your information will not be shared publicly and will only be used to contact you regarding this Working Group and its activities.

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* 1. What is your primary role in CPR / MRR reporting?

Lead Competent Person responsible the Mineral Resource / Mineral Reserves of a Mineral Company

Competent Person for a Mineral Company contributing to Mineral Resource / Mineral Reserves estimation and reporting of a company

Competent Person for a Consultancy Company responsible for Competent Persons reports and / or Audits of Mineral Resource and Mineral Reserve estimates

Mineral Resource / Mineral Reserve industry specialist involved in reviewing and/or adjudicating annual Mineral Resource and Mineral Reserve statements and/or CPRs (including JSE Readers and Squirrel panels; past and present)

ESG specialist and/or responsible for Annual Sustainability /ESG reporting of a Mineral Company

ESG specialist in a Consultancy Company reponsible for preparation of Annual Sustainability or the Sustainability compontent of Integrated Reports on behalf of a Mineral Company

None of the above

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* 2. Should updated ESG guidance for inclusion in CPR / MRR reports be prescriptive (strict minimum requirements) or guided (process driven)?

Prescriptive i.e. a strict set of minimum disclosure requirements is provided

Guided i.e. the process to obtain and disclose applicable information is described with each author deciding best how to follow the process.

Both - a set of minimum disclosure requirements is provided which is supported by guidance on how to interpret and address the requirements and the process to follow to achieve this.

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* 3. Should the Competent Person be able to proceed without an ESG subject matter expert contributing to the CPR / MRR report?

Yes

Please provide a reason for your response

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* 4. Should the Competent Person be expected to take responsibility for determining ESG materiality / salience / judgement when deciding on what must be included in CPR / MRR reports?

Yes

Please provide a reason for your response

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* 5. What other South African centric reporting requirements should be considered, or referenced where relevant, in CPR / MRR reporting, other than: Mining Charter III, Social and Labour Plan, Environmental Management Programme Report, Rehabilitation Trust Funds, Corporate Social Investment / Responsibility, BEEE, Latent and Residual Liabilities?

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* 6. Would you like to see examples of leading practice of ESG disclosures be provided as part of the updated ESG guidance?

Yes

Please provide a reason for your response

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* 7. Can you provide examples or references of what you consider current Industry best / leading practice in ESG disclosure for CPR / MRR reports (e.g. case studies)?

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* 8. How would you like to be engaged in the ESG guidance update, to provide your opinion and inputs on draft guidance? Please select all that apply.

Surveys / questionnaires

Webinars

Virtual roundtable sessions

I will comment on a draft once it is available

Regular updates in the GSSA and / or SAIMM newsletters

Emails sent to a distribution list that includes persons who have specifically registered to receive these updates

Other suggestions

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* 9. Which of the format options list below would you prefer for the updated ESG disclosure requirements and guidance?

The current format of a standalone ESG Guideline

Inclusion of ESG clauses directly (and only) into the text of the SAMCODES as well as Table 1 where appropriate (e.g. as PERC has done in their latest update)

Inclusion of ESG clauses directly into the Codes and Table 1 to specify the minimum reporting requirements, supported by an updated guideance document that assists authors of public reports to meet the reporting expectations

I have no preference on which format is adopted

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* 10. What do you consider the significant pitfalls in ESG disclosures in CPR / MRR reports?

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* 11. Should the SAMCODES definitions be updated to include an additional definition for ESG as it relates to Mineral Reporting?

No - the current Modifying Factors definition is sufficient

Yes - ESG is a concept that is an expansion of the current Modifying Factors definition which includes environmental, social and governmental considerations and further clarity on this concept and the implications for Mineral Reporting is required in a seperate / additional definition

Yes - The current Modifying Factors definition should rather be updated to provide definitive detail on ESG (or ESG-related disclosures) as a concept

ii and iii - The existing Moifying Factors definition requires update / revision AND a definition of ESG is also required

Other

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* 12. In your view, what are the top 3 ‘pivotal ESG criteria’ to be considered as a minimum when publicly reporting MRR information / estimates? Please select a maximum of 3.

Legal Compliance and entitlement

ESG licences and permits required for RPEEE

Climate-related risks

Water management and security impact on LoM and RPEEE

Environmentally sensitive areas impacting on RPEEE

Environmental management systems

Energy management and decarbonisation

Host community relations and expectations impacting on RPEEE and LoM

Planned and unplanned mine closure management and financial provision

Rehabilitation plans and provisions

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* 13. What if any ESG criteria do you already report/disclose in your company CPR/MRR documents? List the top themes/criteria? Please select a maximum of 3.

Legal Compliance and entitlement

ESG licences and permits required for RPEEE

Climate-related risks

Water management and security impact on LoM and RPEEE

Environmentally sensitive areas impacting on RPEEE

Environmental management systems

Energy management and decarbonisation

Host community relations and expectations impacting on RPEEE and LoM

Planned and unplanned mine closure management and financial provision

Rehabilitation plans and provisions

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* 14. Can you outline the overall capability your company has for incorporating consideration of ESG criteria into the Mineral Resource and Mineral Reserve reporting process?

We do not have any dedicated E,S or G subject matter experts. The Competent Person is responsible for all aspects of the report.

External E, S and G advisors are contracted to provide the necessary inputs (either in conjunction with or addition to contracted Competent Persons)

Internal E,S and G subject matter experts provide inputs where required

Internal E, S and G subject matter experts provide input, however they are not adequately resourced to provide the input required

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* 15. Do you perceive any significant risks arising from this initiative relevant to your company?

No. Integration of ESG into Mineral Reports is essential and our company has fully embraced this already.

Yes. Our company does not have the human or financial resources required to address additional ESG requirements in Mineral Reporting deliverables.

Yes. Mineral Reports are likely to increase in length and users of the reports may not be willing to read such long reports.

Other