Political activity and government interaction
|The Code applies to me.|
|Gold Fields Tip-offs Hotline: 1888 611 1848 (USA)|
Irrespective of which jurisdiction we operate or explore in, we are adamant and clear on our approach to corporate political activity, Gold Fields will not:
- take part directly in any party political activity without the approval of the Gold Fields Limited Board; and
- under any circumstances make any political contributions whether as cash or in kind.
It is clear that employees have the right to take part as individuals in political activity, within the ambit of applicable laws in every jurisdiction in which we have a presence. Employees who do so must ensure it is clear that it is in their personal capacity and not representing Gold Fields.
Although we do not directly take part in political activity, we do engage in policy debate on subjects of legitimate concern or importance to Gold Fields, our employees and the communities where we operate and which we impact in various ways.
You should ALWAYS:
- be clear that your personal political views and actions are not representative of those of Gold Fields;
- let your Manager know if your political activities or those of an immediate family member may result in or appear to be a conflict of interest or create an appearance of improprietary (see Conflicts of Interest);
- in the case of government interaction, complete the External Interaction and Commitments Register especially if they relate to government policy or legal and regulatory changes being proposed; and
- consult the Gold Fields Limited Anti-Bribery and Corruption Policy.
You should NEVER:
- Use Gold Fields time, property or equipment to carry out or support your personal political activities – do so in your own time and with your own resources.
No, if you did it would be deemed a political contribution which would contravene our Code. You can attend as an individual but you must not use Gold Fields assets or funds, nor provide Gold Fields branded items for such an event. If you think your involvement may cause a conflict of interest, speak to your VP: Head of Legal or VP: Group Compliance.
Our Region has given science and education materials and surplus Gold Fields equipment to local governments. Are these allowed?
Yes, if provided for in your Corporate Social Investment (CSI) policy. In kind contributions to schools or local governments are part of ensuring sustainable communities on the basis of shared value. Part of the Company’s CSI spend is allowed by the Code. Because they may be subject to local regulations, you should always get clarity from your VP: Head of Legal or VP: Head of Sustainability in your Region. Donations should always be made directly to the school or governmental body rather than to any individual working for either the school or governmental body. A written record should also be kept by the Sustainable Development Manager and be reported to Regional Exco on a quarterly basis.