Acting in a fair and ethical manner

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

What's required of you?

In pursuing these principles, Gold Fields requires its employees, officers and directors alike to adhere to and be bound by the Code and to uphold the following standards:

  • Always behaving in a way which is beyond reproach and of a professional nature when representing Gold Fields
  • Committing to delivering results in a safe manner in specific areas of responsibility and in so doing ensuring a safer environment for all fellow employees, contractors and communities to work in
  • Acting with integrity in all dealings with fellow employees, officers or directors, communities, advisers, suppliers, customers, shareholders, government officials and representatives, and other stakeholders
  • Complying with the Internal Approval Framework, Group Compliance Framework and risk management policies of Gold Fields as amended from time to time
  • Recognising conflicts of interest when they arise and dealing with them in the manner required by this Code
  • Not using corporate information for any purpose other than that for which it was intended, and maintaining the confidentiality of that information even after your employment with Gold Fields has ended
  • Refraining from engaging in practices or pursuing private interests which could conflict with those of Gold Fields or which could result in Gold Fields suffering loss or damage as a result, other than on the basis permitted in this Code
  • Adherence to the Gold Fields Group IT Policy
  • Refraining from any behaviour or activity with criminal intent that may result in financial loss or prejudice to the Gold Fields Group

Members of the Board and of Exco are urged, where appropriate, to take independent professional advice at Gold Fields’ cost on any areas of concern to them in the fulfilment of their obligation to be bound by the standards and principles contained in the Code.

COMPLIANCE WITH LAWS, RULES AND REGULATIONS

A key part of achieving a sustainable mining company is the compliance of every employee to laws, regulations, standards and directives in all the jurisdictions in which we have a presence. Every employee has a responsibility to comply with laws and regulations.

The legal and regulatory environment is an ever changing one which can lead to complex matters. In order to manage this effectively and efficiently, and enhance risk mitigation strategies, Gold Fields has established a risk-based Group compliance programme to provide the highest levels of assurance for regulatory compliance. In terms of the programme, Gold Fields:

  • identifies and consistently reviews all statutes in its operating jurisdictions and assesses the exposure to non-compliance and regulatory risks;
  • ensures that the internal control environment is aligned to prioritised risk encompassed in statutory requirements; and
  • conducts reviews by Internal Audit to assess that appropriate measures are implemented and that controls are effective to mitigate and manage risk. A Group Compliance Index has been developed to accommodate changes within the business, applicable statutes, as well as compliance and regulatory risks. The programme and associated internal controls will be assured by management, Internal Audit and external assurers on an annual basis.

The requirements of the Sarbanes-Oxley Act of 2002, the United States Foreign Corrupt Practices Act, and where applicable, the Dodd-Frank Wall Street Reform and Consumer Protection Act, and the rules of all the stock exchanges on which the shares of Gold Fields are listed must be adhered to, including the following:

  • that Gold Fields discloses in its Form 20-F, filed with the United States Securities and Exchange Commission, the adoption of its Code or any amendments to this Code for all its employees, officers and directors;
  • that Gold Fields discloses promptly and publicly any waivers of the Code by the Gold Fields Audit Committee for directors or members of the Gold Fields Exco; and
  • that the Code be posted on Gold Fields’ website, with reference in the Form 20-F to the Gold Fields internet address. Alternatively, that Gold Fields undertakes in the Form 20-F that it will make a copy of this Code available to any person who requests it.