|The Code applies to me.|
Every employee, director and officer of Gold Fields accepts that any breach of this Code by them exposes them to the risk of disciplinary action, which could result in the termination of employment or office on the basis set out in the Gold Fields disciplinary codes and procedures.
In addition, certain transgressions may also be criminal in nature and could expose the perpetrator to criminal prosecution. Gold Fields will not hesitate to press charges in such an event.
The Code and Group policies and procedures are aimed at preventing and detecting improper and illegal activities. As a Gold Fields employee you are required and encouraged to report any breaches or suspected breaches of this Code and Group policies or procedures – details of which can be requested from the Regional VP: Head of Legal or VP: Group Compliance.
It is incumbent on all of us to be intolerant of misconduct, fraud and unethical behaviour. If you become aware of any such behaviour, you are required to report it. This can be done through a variety of channels and further detail is provided.
Gold Fields protects the anonymity of people who report behaviour that is inconsistent with our Code. We will not tolerate any form of victimisation or retaliation against those who report Code violations. By the same token, making untrue reports with the intention of harming another person will be regarded as a serious and potentially dismissable offence.
HOW TO SPEAK UP
How to speak up
|You can report violations of the Code to the people listed under 'Who do I report to?' below or to the following toll free numbers below. If you become
aware of behaviour by any member of the Board or Exco which is
inconsistent with the Code, you are required to report it to the CEO, CFO, EVP: Group General Counsel or the Audit Committee, either directly or through the Hotline.
South Africa: 0800 203 711
Ghana: 0800 10987
Peru: 0800 54 760
Australia: 1800 623 245
USA: 1 888 611 1848
Chile: 800 914 279
If there is no particular telephone number for the jurisdiction that you are based in, email email@example.com.
All calls to these numbers are made to an independent third party with specialist knowledge and experience in dealing with calls of this nature and all information will be treated as strictly confidential. The anonymity of all callers is guaranteed.
WHO DO I REPORT TO?
‘Manager’ is defined as one of the designated local management contacts for you to report concerns to, unless otherwise specifically stated in the Code.
|Work location||Who to contact|
|Regional office, development project or exploration site||
|Corporate Office and all other office locations||
Should your concern be related to any of the Regional Exco or Gold Fields Exco members, then you should either contact the CEO, CFO, EVP: Group General Counsel or Head of Internal Audit. Members of the Audit Committee will in these instances be informed of the concern raised.
If it is not possible or advisable for some reason to report a concern or complaint to a Manager, you should then promptly contact the EVP: Group General Counsel or the VP: Group Compliance, or report the matter anonymously through the Hotline.
|Gold Fields will not tolerate any acts of retaliation or victimisation
against anyone who comes forward and reports violations of
any of the principles set out in the Code.
If you report a violation of this Code or any concern in good faith, or are involved in an investigation of an ethics and compliance matter – you are doing so in accordance with the provisions of this Code. Under no circumstances will Gold Fields tolerate any retaliation against you. We believe acts of retaliation are themselves acts of misconduct which, if proven, could result in disciplinary action and even dismissal.
Retaliation can take many forms, from subtle actions like being ignored to more blatant actions such as being unfairly dismissed. Bullying with the aim of stopping you from reporting a breach of this Code is also retaliation. All claims of retaliation are taken seriously and will be investigated thoroughly and where appropriate, action will be taken.
If you think you or anyone else is the victim of retaliation, you are urged to report it – either via the Hotline or to your VP: Head of Legal, Regional Head of HR or the EVP: Group General Counsel.
Our Hotline and reporting procedures create an anonymous and confidential environment for employees to make such reports. The procedures in place in this regard govern the reporting and investigation of alleged and improper or illegal activities at Gold Fields, as well as the protection given to our employees who report them.
Any complaints or reports of threats, interference, reprisal, retaliation or intimidation against those who report, or disclose possible improper or illegal activities will be investigated and acted upon immediately. Employees who come forward to report any potential or illegal activities will be protected.
Confidentiality is maintained to the fullest extent possible. All reports will be investigated appropriately using all necessary policies and procedures.
It is a breach of this Code not to investigate a violation or suspected violation which an employee has reported, or to refuse to co-operate with the investigation of any potential violation.
I am anxious to use the Hotline about a matter I am concerned about. My Manager has asked me to do something I know is possibly fraudulent but he is threatening to force me to act in conflict with the policies and procedures of the company.
It is important that you share what is possibly a serious matter. All calls to the Hotline are guaranteed to be confidential so your anonymity is protected. However if anyone were to retaliate against you, you should report this issue promptly. Gold Fields does not tolerate any form of retaliation against people who report violations of the Code, and swift action will be taken against those involved.
If you are ever unsure of how to act or react in a particular situation, consult the Regional VP: Head of Legal in your Region, the EVP: Group General Counsel or the Hotline.