ENVIRONMENTAL POLICY AND COMMITMENT
Environmental management at all the group’s operations is largely governed by its environmental policy, which sets out the company’s broad commitment to sound environmental management, as well as its Safety, Health and Environment Group Standards. In addition, compliance with legal requirements, especially the provisions of the Mineral and Petroleum Resources Development Act (MPRDA) No. 28 of 2002, forms the cornerstone of environmental management and the company’s corporate charter pledges this commitment. In order to put into effect the policy commitments, various site-specific implementation tools have been developed.

GENERAL ENVIRONMENTAL MANAGEMENT
The group has existing environmental management programmes (EMPs) for its operations that were approved in terms of the Minerals Act (No 50 of 1991). EMPs are revised continuously to ensure that they are still in line with current prospecting and mining operations and are aligned with the requirements of the MPRDA. Of note is the approval of the Saxendrift Operations amended EMP, with specific conditions related to financial provision which are being addressed. About 40% of the prospecting EMPs compiled during 2007 and 2008 were approved by DME and other EMPs are still awaiting approvals. An environmental implementation system has been developed and provides for regular monitoring of the activities that have potential environmental impacts. A newly developed Safety, Health and Environment Group Standards (SHEGS) protocol sets standards and minimum requirements for risk assessment, projects, resources, personnel, operational activities, medicals, contractor management, emergency preparedness, incident investigation, reporting, performance and compliance auditing.

EXTERNAL ENVIRONMENTAL PERFORMANCE AUDITING
Environmental assessment performances audits, both regular internal and biannual external audits are undertaken to assess companies’ compliance with environmental management commitments set out in the EMPs as well as to determine the relevance of the EMPs in relation to the current mining operations and general environmental legislation compliance. Inherent in the audited environmental components are aspects related to: integration of the corrective actions into daily operations and identification of areas of improvement. The key audit findings highlight that there is improvement on integration of EMP requirements during planning of operational activities. However, there is a need for an improved document control system. To achieve implementation and monitoring commitments, an environmental committee, comprising employees at all levels, was established in the Lower Orange surrounding communities. For any changes to the mining operations and introduction of new mining equipment, environmental impact assessments are done and communicated to relevant authorities and stakeholders. Such an assessment has just been completed for the introduction of marine equipment called “Aquawalker” in Hondeklip Bay Sea Concession 7(a).

WASTE MANAGEMENT
Waste management audits were conducted for Richtersveld Operations in December 2007. General waste is disposed of in mine licensed general waste disposal sites. Hazardous waste that is produced by the group is in the form of used lubrication oil, oil filters, oily rags and batteries. Used batteries are generally collected and disposed of by suppliers of new batteries. There is lack of an integrated waste management system with a determined “cradle to grave” approach. As part of the implementation of the corrective actions, a comprehensive waste management plan which focuses on waste minimisation, recycling and disposal will thus be compiled. Any hydrocarbon rehabilitation/soil remediation is done in line with Department of Water Affairs and Forestry minimum requirements, thus ensuring that there is no water pollution and that the soils are re-used for rehabilitation of mining disturbed areas. Ferrosilicon, the heavy-medium separation material used in the company’s extraction plants, is an inert substance and poses no threat to the environment. Losses thereof are, nevertheless, limited and closely monitored.

STAKEHOLDER ENGAGEMENT
Stakeholder engagement is undertaken at all mining and prospecting operations as part of the environmental impact assessment process and through the implementation of the mine’s corporate social investment initiatives. Key stakeholder concerns relates to rehabilitation, biodiversity management, energy use and water management. There are key developmental strategies to address these aspects. An integrated water and waste management plan as well as a rehabilitation strategy has been developed for the Lower Orange River (LOR) Operations. Water recycling strategies with a target of at least 70% are being implemented. Annual energy consumption strategies are being looked at to ensure that energy efficiency is improved by at least 10%. In line with the mine’s broader communication strategy, operations adopt site-specific environmental communication tools. A recently launched town-cleaning project, involving local schoolchildren at LOR, is an example of an outcome of a site-specific communication which allows for the co-operative interaction that best addresses stakeholder environmental needs. South African Heritage Resources Agency and McGregor Museum visited Bloeddrif petroglyphs to ensure that there is a partnership between the mine and these authorities in the management of these petroglyphs.