NUM SUBMISSION ON THE MINE HEALTH AND SAFETY AMENDMENT BILL [BILL 54 OF 2008]

PRESENTED TO THE PORTFOLIO COMMITTEE ON MINERALS AND ENERGY

08 AUGUST 2008

CONTACT NUM PARLIAMENTARY OFFICE 0214617049

1 Table of Contents:

1. Introduction……………………………………………………………………………………………………. 3 2. Performance of the Mining Industry……………………………………………….. ………………………3 3. Summary – Fatalities and Injuries in South African Mines…………………………………………….. 6 4. Specific Comments…………………………………………………………………………………………… 9 4.1 CLAUSE 2: PROPOSED AMENDMENT OF SECTION 2A OF ACT 29 OF 1996...... 10 4.2 SECTION 20 OF ACT 29 OF 1996: EMPLOYEE MAY DISPUTE FINDING OF UNFITNESS TO PERFORM WORK...... 10 5 SECTION 23 OF ACT 29 OF 1996: EMPLOYEES’ RIGHT TO LEAVE DANGEROUS WORKING PLACE...... 11 6 CLAUSES 15, 21 AND 22: REPLACEMENT OF LABOUR COURT WITH APPROPRIATE COURT11 7 CLAUSE 16: SUBSTITUTION OF SECTION 55C OF ACT 29 OF 1996...... 12 8 CLAUSE 18: DELETION OF SECTIONS 55E TO 55H...... 12 9 SECTION 72: INQUIRY RECORDS AND REPORTS...... 13 10 CRIMINAL PROSECUTIONS FOR NEGLIGENT CAUSING OF DEATH, INJURY, ILLNESS OR ENDANGERMENT BY THE EMPLOYER...... 14 11 NEW SECTION 86A: IMPUTATION OF CRIMINAL LIABILITY...... 17 12 86A IMPUTATION OF CRIMINAL LIABILITY...... 17 13 SECTION 98: REGULATIONS...... 17 14 CLAUSE 31: PROPOSED NEW SCHEDULE 8...... 18 15. CONCLUSION,...... 20

2 1. INTRODUCTION.

We appreciate this opportunity to address this portfolio committee on our submission on Mine Health and Safety Amendment Bill no. B54---2008.

The National Union of Mineworkers (NUM) organizes and is a representative union in Mining, Energy and Construction sectors of our economy. Since its inception in 1982, NUM have been in the forefront in struggles waged by the Working Class against the oppression and exploitation of man by man. In this regard, we have not only fought against poor working conditions for our members in the mines but have vigorously raised matters pertaining to bad health and safety conditions under which our members work in this industry.

We have condemned and mourned the preventable deaths of workers in the mines. These accidents and fatalities occur at the height of industry’s pursuit of production targets to maximize profits.

We will not only demonstrate the gravity of this situation but will submit formidable recommendations for the consideration of this house.

1 PERFOMANCE OF THE MINING INDUSTRY:

Mining played a pivotal role in the development of the South African economy since the discovery of minerals in the 18th century. It provided the original impetus for the extensive infrastructure that currently sustains South Africa’s more economically important secondary and tertiary economic sectors. Mining and quarrying GDP contribution has been 6.7% in 2003; 6.3% in 2004 and 6.2% in 2005. Taking into account the multiplier effects, the overall contribution of mining to GDP came closer to 16%, while both directly and indirectly, mining contributed an estimated 25% to total employment in the country. The latest reports reveal that South African mining sector indirectly contributed 7% of gross domestic product (GDP) in 2006; in the same year the industry as a whole contributed 18.4% of GDP. During the years 2002 to 2008 over the April month, a substantial increase in production is registered. However, these increases in mineral production and sales over the years

3 can be associated with a high-level of accidents and fatalities in South African mines.

The two tables below illustrate the physical volumes of production in South African mines.

4 Sales An increase of 24.4% of the total seasonally adjusted value of mineral sales was registered for the three months ended April 2008 compared with the previous three months. The increase is attributed to the sale in non-gold minerals that reached 25.3% to R12 881, 8 million and 19.9% to 1 881, 0 million increase in gold.

The tables below illustrate the total value of mineral sales

5 2. Summary – Fatality and Injury in South African Mines:

The year 2007 turned-out to be the worst year for safety in the South African mining industry particularly for workers; the families that loose their loved ones in senseless mine accidents that could be prevented; and the society at large. An increase in mine fatalities that were reported, are 200 in year 2006 to 220 in year 2007 - a 10% increase year on year! This happened despite the fact that an agreement was reached in 2005 between the Employers, DME and Labour to implement new fatality milestones based on the annual fatality rates of Australia, the USA and Canada. The Gold mining industry alone contributed 52% of the total fatalities from 114 in year 2006 to 115 in year 2007 actual deaths. The Coal mining sector registered a drop of 25% from 20 in year 2006 to 15 in year 2007 actual deaths; the Platinum mining industry registered a substantial increase of 27.27% fatalities bringing the actual deaths figure to 53 in year 2007 from 40 in the previous year. With the contribution of other sectors 220 fatalities were registered in all mines in South Africa.

The two graphs below illustrate trends of fatalities and injuries in mines from year 2000 – 2008. To note, is the unavailability of information on the number/statistics of accidents and injuries in 2002 despite now being August 2008.

The amendments on the Mine Health and Safety Bill should provide that the Inspector General must publish statistics on fatalities and accidents in mines on monthly basis that will also be available to the public. It is a course for concern that there is no information available on fatalities and accidents for year 2008 considering that we are past the first half the year.

Number of injury rates per million hours worked 2000 - 2008 Year Gold Coal Platinum Other No. Injuries 2000 8.46 1.68 3.24 2.59 4733 2001 8.35 1.56 4.07 2.87 4728 2002 8.32 1.59 3.19 2.37 4461 2003 7.70 1.75 3.00 1.83 4301 2004 7.37 1.81 2.91 1.88 4268 2005 6.85 1.48 3.54 1.62 3985 2006 7.02 2.05 3.75 1.30 4159 2007 6.67 1.44 3.05 1.09 3867 2008*

6 In terms of classifying fatality and accident trends in South African mines, a sharp rise (66.7%) in fatalities classified as general have been reported including gassings, slipping and falling, fall of material, rolling rocks and explosives. In 2007, significant contributors include falling of material/rolling rock [25%], manual handlings of material [23%], slipping and falling [23%] – all of these could be prevented by mining companies channelling more investments in safety measures including training in detecting risky situations.

In contrast, we notice that natural disasters are not registered as major contributors to accidents – giving us an impression that it is man-made accidents that continue to slaughter workers in the South African mines. The graph below illustrates contributors to accidents in 2007.

2.1 Accidents class contribution

04 General accidents 2007 Struck by ventilation door Inundation/drowning 2% Struck by any object 1% manual handling 9% Fall of material/rolling Splinters rock 4% 25% Dust, gas and fumes 2% Burning and scalding Fatality rates2% per million hours worked 2000 - 2008 Manual handling of material Year Gold Coal Platinum Other 23% No. of Fatalities 2000 0.41 0.25 0.23 0.26 285 2001 0.45 0.17 0.25 0.28 288 2002Slipping and0.44 falling 0.2Falling in/from 0.26 Manual handling of 0.3 290 23% 5% mineral 2003 0.37 0.21 0.24 4% 0.25 270 2004 0.28 0.19 0.21 0.31 246 2005 0.30 0.13 0.15 0.17 202 2006 0.35 0.16 0.11 0.13 200 2007 0.34 0.12 0.14 0.17 220 2008*

2.2 International Benchmarking:

7 The graphs below illustrate the progress made in the global mining sector on safety record from 1993 to 2003. South Africa still records the highest fatality rates.

With regards to fatality injury frequency rates (FIFR – the number of fatal injuries per one million hours worked) South Africa‘s fatality record was disproportionately high in 2002 compared to other countries including Chile, Canada and Mexico. This is a problematic trend which the South African government along with the mining industry should endeavour to curb. Particular Attention must be paid to the levels of investments by the Industry on Health and Safety. This must be counterpoised proportionately to the revenue and profits posted annually by the Industry.

Despite some progress made in preventing fatal injury and unnecessary accidents in mines since the 18th Century, there is still a long way for the South African mining industry to achieve zero fatality rate in the mining industry.

The table below illustrates the rates of fatalities is South African mines in comparison to other mining countries:

Source: Pricehousewater Coopers, 2003

3. SPECIFIC COMMENTS ON THE BILL:

8 The National Union of Mineworkers (the NUM) has considered the Mine Health and Safety Amendment Bill (as introduced in the National Assembly by the Minister of Minerals and Energy [B54 - 2008]). Our comments on the Bill are set out below.

1.1 Clause 2: Proposed amendment of section 2A of Act 29 of 1996

The NUM believes that the appointment of a chief executive officer by the employer should not be discretionary but should be mandatory as is the current position under the Act.

The NUM therefore proposes the following amendment to clause 2 -

1.1.1 Section 2A of the principal Act is hereby amended by the addition of the following subsection:

"(6)(a) [The employer may appoint a chief executive officer.]

(b) An employer [who appoints a person under paragraph (a)] must inform the Chief Inspector of Mines in writing within seven days of [such appointment] appointing or replacing the chief executive officer.

(c) The information to the Chief Inspector of Mines must include-

(i) the name of [a person so appointed] the chief executive officer ; and

(ii) [the nature of such a person's function; and]

(iii) the names of persons who are managers under the supervision of the chief executive officer."

1.2 Section 20 of Act 29 of 1996: Employee may dispute finding of unfitness to perform work

1.2.1 Workers who are declared unfit to perform particular categories of work by an employer are vulnerable to dismissal and this hampers their capacity to exercise their rights and to lodge appeals against findings of unfitness under the Act.

1.2.2 The NUM proposes that employers be prohibited from dismissing an employee while an appeal against the employer's decision is being

9 processed. The NUM therefore proposes the following amendment to section 20-

Insert the following subsections in section 20-

( 7) An employee who is entitled to appeal in terms of subsection (1)(a) may not be dismissed by reason of that employee's unfitness to perform any category of work until the appeal process in terms of this section has been exhausted.

(8) A dismissal in breach of subsection (7), is unlawful and constitutes an automatically unfair dismissal as contemplated by section 187 of the Labour Relations Act, 1995.

2 Section 23 of Act 29 of 1996: Employees’ right to leave dangerous working place

2.1 The employees’ right to leave dangerous working places is of fundamental importance to protecting the lives of mineworkers and improving health and safety in the mining industry. However, the absence of a uniform minimum framework for determining procedures to exercise the right at mine level has undermined the exercise of the right by mineworkers.

2.2 This can be remedied by the Minister determining a set of minimum requirements for procedures to exercise the right to withdraw from dangerous working places.

2.3 The NUM therefore proposes the following amendment to section 23-

Insert the following subsections in section 23-

(4) The Minister, by notice in the Gazette, must determine minimum requirements for the procedures contemplated in subsection (2).

(5) Any procedure determined in terms of subsection (2) must comply with the minimum requirements contemplated in subsection (4).

3 Clauses 15, 21 and 22: Replacement of Labour Court with appropriate court

The NUM believes that the Labour Court should be retained as the court with exclusive jurisdiction regarding disputes arising from the interpretation or

10 application of the Act. The amendments proposed by the Bill to replace references to the Labour Court with the “appropriate court” may have been informed by the assumption that the Labour Court was to be abolished as a specialist court. This is not the case and all references to the Labour Court in the Act should be retained.

4 Clause 16: Substitution of section 55C of Act 29 of 1996

4.1 Presently many mines spend large sums of money hiring senior lawyers to represent them at inquiries and inquests. Often their purpose is simply to obstruct the inquiry. Unions and employees do not have equivalent resources and it is therefore appropriate that their representation be subsidised in this manner. Presently, NUM shop stewards often appear in inquiries unassisted against senior lawyers hired by the employer.

4.2 The NUM believes that the purposes of the Act will be promoted if trade unions are also assisted in providing health and safety training to shop stewards, safety stewards, members and officials.

4.3 NUM therefore proposes the following amendment to the proposed new section 55C:

Insert the following subsection in the new section 55C-

(3) The purposes for which money may be used in terms of subsection (2) include-

(a) health and safety training by registered trade unions of their members, officials and office-bearers; and

(b) representation of employees in inquests and inquiries in terms of this Act.

5 Clause 18: Deletion of sections 55E to 55H

5.1 The NUM strongly opposes the repeal of section 55E which deals with the determination of an employer’s liability for administrative fines in terms of the Act. Put simply, the effect of section 55E is as follows –

11 5.1.1 the Inspectorate is required to adduce evidence that an act or omission by an employer resulted in a failure by an employer to comply with a duty under Chapter 2 of the Act;

5.1.2 once evidence of such a failure is presented, an administrative fine can only be imposed if the employer is unable to show that the steps that it in fact took satisfies the requirement to take reasonable care (i.e. that the employer was not negligent).

5.2 If section 55E is repealed, the Inspectorate will only be able to impose a fine if the Inspectorate can itself prove that what the employer did, did not meet the standard of reasonableness. This is an impossible evidential burden.

5.3 By way of illustration, take a situation where there are several different technologies available to deal with a particular health and safety problem but the employer took a decision to use an inappropriate technology.

5.3.1 If section 55E is repealed, an administrative penalty can only be imposed if the Inspectorate presents evidence concerning the technologies that were available to the employer and is then able to demonstrate that the decision by the employer to use the technology it in fact used was unreasonable.

5.3.2 On the other hand, section 55E requires the employer to present the considerations that it went through when deciding to use the one technology and not the others. These considerations would have been recorded by the mine as part of its risk assessment process and the obligation to show what considerations were taken into account places no undue burden on the employer.

5.4 The Constitutional Court has accepted that an obligation to present evidence of the steps taken to comply with a statutory duty in this manner is appropriate in both civil and criminal proceedings.

5.5 In our view the repeal of section 55E will render the system of administrative fines under the MHSA unworkable. The section should therefore be retained.

5.6 Clause 26: Proposed amendment of section 91 of Act 29 of 1996

12 The proposed amendment to subsection (1) of section 91 of the principal Act limits unnecessarily the sanctions that a court may impose for an offence under the Act. The NUM therefore proposes that paragraph (1)(c) be amended by deleting the phrase "and is liable to a fine as may be prescribed".

6 Section 72: Inquiry records and reports

6.1 The NUM believes that a link should be drawn between the provisions of the MHSA and the Compensation for Occupational Injuries and Diseases Act 130 of 1993 (COIDA) in order to eliminate the duplication of proceedings and expedite the payment of compensation for accidents and occurrences resulting in death, injury or illness.

6.2 The NUM therefore proposes the following amendment to section 72:

Insert the following new subsection in section 72-

(4)(a) For purposes of this subsection, “COIDA” means the Compensation for Occupational Injuries and Diseases Act, 1993 (Act 130 of 1993).

(b) If the person presiding at an inquiry finds that the death, injury or occupational disease of an employee was due to the negligence of any person contemplated in section 56(1)(a)-(e) of COIDA, the person presiding at the inquiry must submit a copy of the report and the record of the inquiry to the commissioner referred to in section 1 of COIDA.

(c) The submission of a copy of the report and the record of the inquiry in terms of paragraph (b) must be deemed to be an application for increased compensation in terms of section 56(3)(a) of COIDA in respect of the employee contemplated in paragraph (b).

(d) The finding of negligence contemplated in paragraph (a) must be deemed to be the finding of the Director-General that the accident or occupational disease was due to negligence as contemplated in section 56(4)(a) of COIDA.

13 7 Criminal prosecutions for negligent causing of death, injury, illness or endangerment by the employer

7.1 The NUM has grave concerns regarding the state’s failure to institute prosecutions against employers and senior managers with direct statutory responsibilities to ensure that a mine is operated in a healthy and safe manner who have been found negligent in a range of accident inquiries and inquests.

7.2 The most startling current examples of this are:

7.2.1 the Beatrix Mine accidents of 15 May 2000 and 8 May 2001 both of which involved methane explosions and resulted in the deaths of 7 and then 13 workers. In the section 65 inquiries into these accidents, the presiding officers found in both cases that the mine had been negligent and recommended that the mine, the mine manager and identified senior officials be charged with culpable homicide.

7.2.2 the Northern Platinum Mine fire of 20 September 2004 which resulted in the death of 9 mineworkers. The presiding officer in the inquest found the mine to have been negligent and recommended that it be charged with culpable homicide.

7.3 In none of these cases have prosecutions been instituted to date.

7.4 In our view, the successful prosecution of employers and senior managers with direct statutory responsibilities to ensure that a mine is operated in a healthy and safe manner will have a fundamental impact on health and safety at mines.

7.5 On this basis we propose the following amendments to section 86-

Insert the following subsections in section 86

(3) In any prosecution of an employer or a person contemplated by section 2A, 3 or 4 of the Act for an offence in terms of subsection (1) or for culpable homicide, proof that the act or omission of the accused caused death, serious injury or serious illness constitutes

14 sufficient proof of the offence, unless evidence is adduced that the accused was not negligent.

(4) An employer commits an offence if the employer has failed to comply with a duty in terms of Chapter 2 and as a result –

8 an employee dies, is injured or becomes ill; or

9 the health and safety of an employee was seriously endangered.

(5) In any prosecution in terms of sub-section (4) –

9.1 it is not a defence that the employee’s death, injury, illness or endangerment was caused by the act or omission of any individual;

9.2 proof that the death, injury or illness was due to the employer’s failure to comply with a duty in terms of Chapter 2 or any act or omission by the em- ployer is sufficient proof of the offence, unless evidence is adduced that the employer did what was reasonably practicable or took reasonable steps to comply with the relevant duty.

9.3 The proposed new section 87(3) creates an evidential burden in respect of prosecutions of employers and senior managers who have direct statutory responsibilities to ensure that a mine is operated in a healthy and safe manner.

9.4 The Constitutional Court has held an evidentiary burden which requires an accused to present evidence of the steps he or she took to comply with statutory duties can be justified (S v Manamela 2000 (3) SA (1) (CC)).

9.5 The high level of accident and disease in the mines coupled with the necessity of enforcing the statutory framework constitute an adequate justification for including such a provision in the Act.

9.6 Prosecution of corporate employers is currently governed by section 332 of the Criminal Procedure Act.1 The approach of this section for imposing criminal liability on corporations is based on ‘derivative’ liability whereby the conduct of the agent or employee of the corporation is imputed to the corporation.2 This approach is limiting, in that it fails to recognise direct or

1 Act 51 of 1997. 2 Jonathan Burchell Principles of Criminal Law 3rd (2005) at 563.

15 collective corporate liability independent of misconduct on the part of an individual. It has been criticised by a number of criminal law experts as limiting the ability to prosecute negligent corporations and is out of step with other jurisdictions.3

9.7 A large number of jurisdictions around the world including Australasia,4 Canada and parts of Europe have all recognised the collective liability of corporations for their failure to implement adequate systems and controls.5 For instance, new legislation has recently been enacted in the United Kingdom6 to create the offence of corporate manslaughter. This offence recognises that an organisation will be criminally liable if the way in which its activities are managed or organised by its senior management causes a person’s death.

9.8 The creation of such an offence recognises that it is the failure of the employer’s health and safety systems that is the predominant cause of major accidents in the industry. However, the fact that criminal law takes account of “last straw” causality has the effect that management are not held to account for the failures of their systems.

9.9 The inclusion of the proposed new provision is consistent with the report of the Leon Commission.

10 New section 86A: Imputation of criminal liability

The NUM proposes that the following new section 86A be included in the MHSA. The proposed new clause is a standard provision dealing with the employer’s liability for conduct that it permits. A similar provision is found in section 37 of the Occupational Health and Safety Act, 1993. In the NUM’s view such a provision was inadvertently omitted from the MHSA and should be remedied at this stage.

Insert the following new section 86A:

3 Ibid. 4 See Part 2.5 of Criminal Code Act 1995 (CTH) and Occupational Health and Safety Amendment (Workplace Deaths) Bill 2005 (NSW), assented on 15 June 2005. 5 See Ireland Law Reform Commission Consultation Paper on Corporate Killing (LRC CP 26 – 2003) available at http://www.lawreform.ie/files/6%20Oct%20Final%20CP.pdf 6 Corporate Manslaughter and Corporate Homicide Act 2007 (c. 19), effective 6 April 2008.

16 86A Imputation of criminal liability

(1) If an employee does or omits to do any act which it would have been an offence in terms of this Act for the employer of that employee to do or omit to do, that employer is guilty of the offence if the act or omission fell within the scope of employment or authority of the employee and the employer –

(a) connived at or permitted the act or omission; or

(b) did not take all reasonable steps to prevent the act or omission the offence.

(2) For the purposes of sub-section (1), the fact that a person issued instructions prohibiting an act or omission is not in itself sufficient proof that the person took all reasonable steps to prevent the act or omission.

11 Section 98: Regulations

The NUM believes that regulations should be promulgated in respect of mine rescue services in order to ensure a high standard of service across the mining industry. NUM therefore proposes the following amendment to section 98:

Insert a new paragraph 98(zP) as follows-

(zP) minimum standards for the establishment, functioning, training, equipping and staffing of rescue services at mines and reporting by employers in respect of rescue services.

12 Clause 31: Proposed new schedule 8

12.1 The Bill proposes a maximum penalty for criminal offences of R500 000 and R1 million in the case of administrative fines. It is obvious that this is an inadequate deterrent for large mining employers with multi-billion rand operations.

12.2 The NUM therefore proposes that the maximum fine that can be imposed upon an employer for either an administrative penalty or on conviction of the employer for an offence involving the negligent causing of death, injury,

17 illness or serious endangerment should be the greater of R 1 million or 10% of the employer’s turn-over.

12.3 We point out that the latter figure is the maximum penalty that maybe imposed under the Competition Act. It is clearly appropriate that a similar penalty should be capable of being imposed for breaches of law that involve the loss of life or the threat of a loss of life. Such a penalty would in the NUM’s view create a real incentive for mines to improve their health and safety performance. Presently, the maximum fines that can be imposed upon employers for health and safety violations are merely a “slap on the wrist” for major mining employers.

12.4 We also point out that several offences under Chapter 2 of the MHSA have been omitted from the proposed new schedule 8.

12.5 The NUM therefore proposes the following additional amendments to Tables 1 and 2 in the proposed new schedule 8:

12.5.1 Table 1

MAXIMUM FINES OR PERIOD OF IMPRISONMENT THAT CAN BE IMPOSED FOR OFFENCES OF THE ACT

Column 2 Column 1 Maximum fine and term of Section under which convicted imprisonment 2 R1 000 000 or 5 yrs imprisonment 2A R1 000 000 or 5 yrs imprisonment 3 R1 000 000 or 5 yrs imprisonment 5 R1 000 000 or 5 yrs imprisonment 6 R1 000 000 or 5 yrs imprisonment 7(1) R1 000 000 or 5 yrs imprisonment 10 R1 000 000 or 5 yrs imprisonment 11 R1 000 000 or 5 yrs imprisonment 15 R500 000 or 5 yrs imprisonment 16 R500 000 or 5 yrs imprisonment 21(1), (3) or (4) R500 000 or 5 yrs imprisonment 22 R200 000 or 2 yrs imprisonment

18 Column 2 Column 1 Maximum fine and term of Section under which convicted imprisonment 24 R500 000 or 5 yrs imprisonment 52 R200 000 or 2 yrs imprisonment 53 R200 000 or 2 yrs imprisonment 62 R200 000 or 2 yrs imprisonment 66(3) R200 000 or 2 yrs imprisonment 70 R200 000 or 2 yrs imprisonment 71 R200 000 or 2 yrs imprisonment 84 R200 000 or 2 yrs imprisonment 85 R200 000 or 2 yrs imprisonment 86, 86A R300 000 or 3 yrs imprisonment 87, 88, 89, 90 R50 000 or 6 months imprisonment 88 R300 000 or 3 yrs Imprisonment

In respect of any offence in which an employer is convicted, whether under this statute or any other law, for negligently causing the death, injury of ill-health or serious endangerment of an employee, the maximum fine that may be imposed is the greater of –

(a) R1 000 000; or

(b) 10% of the employer’s turnover.

12.5.2 Table 2

MAXIMUM FINES THAT CAN BE IMPOSED FOR CONTRAVENTIONS OF THE ACT AS CONTEMPLATED IN SECTION 55B

The maximum fine that can be imposed in terms of section 55B may not exceed an amount of R1 000 000 or 10% of the employer’s turnover, whichever is the greater.

19 14. In conclusion, the NUM is of a firm view that the above comments on this Bill, will enable this honourable parliamentary committee to have frank deliberations and through its decisions assist the country to stop this carnage in our Mining Industry. As demonstrated by means of comparison with other countries, we are not calling for impossible actions by the Employers in this Industry, when we call for them to be compelled to invest more resources in the field of Health and Safety. Further more, we want them to take full responsibility for their negligent actions that cost our member’s lives and result to untold suffering by their dependant families.

WE THANK YOU.

______

Frans Baleni General Secretary National Union of Mineworkers

Date:

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