A revised Code of Ethics for the Group
In 2011, the Gold Fields legal team revised the Group Code of Ethics (2007). This was carried out to ensure
Gold Fields alignment with the recommendations of the King III Report on Corporate Governance – as well as
evolving international best practice. This includes, for example:
- US legislation, such as the Sarbanes-Oxley Act (2002), the Dodd-Frank Act (2010) and the Foreign
Corrupt Practices Act (FCPA, 1977) – as well as UK legislation, such as the Bribery Act (2010)
- The OECD Convention on Combating Bribery of Foreign Public Officials in International Business
Transactions (1997)
- The UN Convention against Corruption (2003)
- South Africa’s Prevention of Corrupt Activities Act (2004)
Furthermore, it was to ensure continued compliance with all relevant national and international legal
requirements applicable to Gold Fields.
Under the latest version of the Code, facilitation payments are prohibited, regardless of whether it is legal or
deemed to be ‘accepted practice’ in a particular country or not. Facilitation payments involve the payment of
small sums to officials to obtain routine services to which Gold Fields would otherwise be legally entitled. This
approach goes beyond FCPA guidelines, which permit facilitation payments of up to US$250.
The updated Code also prohibits contributions to political parties, either in cash or in kind, unless specifically
approved by the Gold Fields Board of Directors. This is the first time that the prohibition of facilitation payments
and political contributions has been written into Gold Fields policy, and represents a further step in promoting a
zero tolerance approach to corruption and bribery.
In addition, other important areas covered in the updated Code include:
- Conflicts of interest
- Confidential information
- Gifts and business courtesies
- Entertainment and hospitality
- Share dealings
The roll-out of the updated Code to employees commenced in 2011 and will be completed this year. New
employees will sign the Code and receive related training during induction. Existing employees sign the updated
Code during the roll-out programme and will receive refresher training as required. Every employee has received
a copy of the Code, which has been translated into seven languages. It is also available on the Group’s Intranet
and website.
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