Conflicts of interest
|The Code applies to me.|
|Gold Fields Tip-offs Hotline: 0800 10987 (Ghana)|
Avoid placing yourself in a position where personal interests may, or may appear to be, in conflict with those of Gold Fields.
What is a conflict of interest?
A conflict between your own interests and those of Gold Fields could arise in a number of situations including the following:
- Where you have or acquire an interest in any entity which is not owned or controlled by Gold Fields, including, without limitation, by being a shareholder, member or director, owner or partner or family trust. This does not apply to investments in shares which are listed on a registered stock exchange, unless your decision to acquire them was influenced by insider information, as described in the Group Share Dealing and Market Abuse Policy
- Doing business on behalf of Gold Fields with any current or potential third parties of Gold Fields in which you, your spouse or immediate family member has an interest of any nature whatsoever
- Accepting personal favours or any form of preferential treatment from any third parties of Gold Fields
- Entering into any agreement, arrangement or understanding with any third party to the detriment of Gold Fields
- Contracting with any third party of Gold Fields in your private capacity or other than as a representative of Gold Fields
- Engaging in activities in your private capacity or other than as a representative of Gold Fields which may impact adversely on your ability to fulfil your obligations to Gold Fields whether as an employee, officer or director, with integrity and in the best interests of Gold Fields
- When you, or one of your family members, receive improper personal benefits as a result of your position in Gold Fields
- Being involved directly or indirectly in the engagement, management or suspension of business parties to the benefit of yourself or in which you have an interest or which are controlled by you or for which your relatives work in high management positions.
DECLARE CONFLICT OF INTEREST
You should discuss and get approval for such a situation or any relationship which may give rise to such a situation with your Regional VP: Head of Legal or VP: Group Compliance before taking further action.
The Regional VP: Head of Legal is required to keep and maintain a Conflicts of Interest Register containing a written record of any such declared conflicts of interest and to make this register available to the Gold Fields EVP: Group General Counsel or Audit Committee when requested.
Prior written approval is required from your Regional EVP, and any of the persons defined as Management of this Code, for any transaction with Gold Fields which may result in the receipt of a direct or indirect benefit for you or your immediate family. Details must also be recorded in the Conflicts of Interest Register to be maintained by the VP: Head of Legal at each of the Operations within the Gold Fields Group or the VP: Group Compliance Officer at Corporate Office.
If you become aware of or suspect the existence of a conflict of interest, which has not been disclosed, you must report it to the Regional VP: Head of Legal, VP: Group Compliance or EVP: Group General Counsel.
WHAT ABOUT WORK OUTSIDE OF GOLD FIELDS
No employee of Gold Fields is permitted to hold a position or engage in work in their personal capacity for remuneration, other than at Gold Fields, unless express written approval is given by the Regional EVP and any one of those persons defined as Manager of this Code. In the case of Corporate employees and Gold Fields Exco members in relation to outside employment, permission will be required from the CEO and CFO. In this regard, limited time devoted to community, charitable work (for no remuneration) or representation on industry-related bodies benefiting Gold Fields will be allowed. The written approval should be captured in the Conflicts of Interest Register.
Unless the current employment policies prohibit this, relatives may work in the same operating unit. However, there should be no direct reporting lines between relatives and no relative must be involved in the hiring or supervising of the individual and must in no way affect the terms or conditions of employment, or influence the management of the relative. The individual should disclose that their relative is an employee of the operation or department.
You need to disclose your spouse’s position to your Manager on your employment or when the company your spouse is a director of tenders or is doing work for Gold Fields, so that any potential or actual conflicts can be noted and considered. You should also disclose this in the Conflicts of Interest Register. You are not allowed to be involved in the selection process, the management of the contract or whether your spouse’s business contract is to be terminated.