Accurate and complete information, records, reporting and accounting

The Code applies to me.    
Gold Fields Tip-offs Hotline: 0800 203 711 (RSA)
The snapshot

At Gold Fields we record and report both financial and non-financial company information honestly, accurately and objectively. Any information Gold Fields employees create should accurately reflect all transactions and events. This includes sustainable development and HR information, and financial data.

Falsifying records or misrepresenting facts and information can never be justified or excused. Gold Fields has a zero-tolerance approach to fraud.


The detail
It is essential to record and report financial and non-financial information honestly, accurately and objectively because it:
  • protects Gold Fields’ credibility and reputation;
  • meets our legal and regulatory obligations;
  • ensures we meet our responsibility to shareholders and other external stakeholders; and
  • informs and supports our business decisions and actions.

Any information you create for Gold Fields must accurately reflect transactions and events. This includes information in paper form, or electronic documents, emails or other media which should be created, retained and destroyed in line with applicable law, Gold Fields data privacy rules and IT Policy procedures. Any information you create or receive while employed by or working for Gold Fields belong to Gold Fields. It has to be managed and protected properly.

Gold Fields does not condone failure to keep accurate and complete records, falsification of information or the creation of misleading information. It may constitute fraud or a breach of a human right and may result in civil or criminal liability for Gold Fields.

PAYMENT ERRORS

Any overpayment or payment of monies made to you or any third party in error or to which you or any third party are not entitled, must be reported to your Line Manager without delay. In addition:

  • Payment errors to employees or third parties must be reported without delay to your Manager. These payments could be reflected on a payslip, bank record or any other form.
  • Taking advantage of payment errors or not reporting them is regarded as a serious and dismissable offence.
  • If there is difficulty in understanding payment advices, please seek the advice of your Manager.
  • If you are entrusted with authorising or implementing payments, and are found to have wrongfully authorised or implemented payment you will be guilty of misconduct and it could be a potentially dismissable offence.
  • Aiding and abetting a payment error to an employee or third party is a serious and potentially dismissable offence.
  • Receiving any money, benefit or advantage from any person in exchange for facilitating a payment error, likewise, is a serious, potentially dismissable offence.

ALWAYS/NEVER

You should ALWAYS:

  • ensure all transactions are properly authorised and recorded accurately;
  • make sure you have complied with the Group Fields Group ABC Policy;
  • ensure all counterparties are appropriately on-boarded onto the Gold Fields systems and they are authorised. This includes customers, suppliers, agents, professional advisers, JV partners and any other business partner;
  • consider and follow the Gold Fields Approval Framework;
  • co-operate fully with Internal Audit, Group Compliance and external auditors providing them with accurate information;
  • complete and approve expense claims in accordance with the Approvals Framework; and
  • report any concerns or irregularities in respect of accounting, auditing or internal controls matters.

Financial officers, managers and those responsible for financial and management reports have additional responsibilities to establish and maintain proper controls to ensure financial and management reports are accurate, complete, objective, clear and understandable, and are finalised timeously.


You should NEVER:

  • make deliberate, false or misleading entries in a report, document, record or expense claim;
  • falsify any document or record, whether it is financial or non-financial;
  • dispose, sell, and transfer any company assets without the proper documentation and authorisation; and
  • obstruct or influence due process being followed within the jurisdiction of any regulator including but not limited to the concealment or destruction of Gold Fields information.

If at any time you are concerned about the validity of any information whether financial or non-financial or you are asked to prepare misleading or false information you need to raise the concern immediately.

Talk to the VP: Head of Finance in your Region or the CFO if you are not sure how to record something accurately or if you have any concerns that something has not been recorded properly then you should inform the CFO immediately. If you feel concerned about anything and would prefer to discuss the position confidentially, contact the Gold Fields Tip-offs Hotline.