Anglo American Platinum – Rustenburg Platinum Mines, Rustenburg Process Operations: Regulation 34 Environmental

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Report Prepared for Anglo American Platinum Limited

Report Number 558834

Report Prepared by

November 2020

SRK Consulting: 558834: Rustenburg Process Operations: External Environmental Audit, undertaken during August 2020 Page i

Anglo American Platinum – Rustenburg

Platinum Mines, Process Operations:

Regulation 34 Environmental Audit of 2020 Anglo American Platinum Limited

SRK Consulting (South Africa) (Pty) Ltd 265 Oxford Rd Illovo 2196 Johannesburg South Africa

e-mail: [email protected] website: www.srk.co.za

Tel: +27 (0) 11 441 1111 Fax: +27 (0) 11 880 8086

SRK Project Number 558834

November 2020

Compiled by: Peer Reviewed by:

Ashleigh Maritz Franciska Lake Senior Environmental Scientist Partner

Email: [email protected] Authors: Franciska Lake, Ashleigh Maritz, Kavilan Naidoo

MARA/NKAV/LAKF 558834_RPM_EMPR_Final Reg 34 Audit Report_20201130 November 2020 SRK Consulting: 558834: Rustenburg Process Operations: External Environmental Audit, undertaken during August 2020 Page ii

Executive Summary

SRK Consulting (Pty) Ltd (SRK) was appointed by Rustenburg Platinum Mines Limited (RPM) to conduct the external environmental audit of the commitments contained in the Consolidated Retained Operations Environmental Management Programme (EMPR). The audit was undertaken in accordance with Regulation 34 and Appendix 7 of the National Environmental Management Act (Act 107 of 1998) (NEMA) Environmental Impact Assessment (EIA) Regulations, 2014 (as amended).

The Retained Operations Consolidated EMPr includes the following operations:

 Waterval smelter;  Acid Converting Process (ACP) facilities;  Rustenburg Base Metal Refinery (RBMR); and  Precious Metal Refinery (PMR).

It is SRK’s understanding that the Frank Concentrator has been formally decommissioned under an Environmental Authorisation and that rehabilitation of this facility will take place in the near future in accordance with the environmental commitments contained in the authorisation document and EMP for this facility (not included within the ambit of this audit). With regards to the Western Limb Distribution Center (WLDC), it is assumed that the conditions contained within the Consolidated EMPR (included in Appendix C1) are applicable to this facility as no EMPR amendment/addendum since 2002 was issued directly to this facility.

Audit results

During the audit, the RPM personnel demonstrated a good understanding of the environmental management issues on site and the requirements of the Consolidated EMPR.

Compliance achieved by the RPM operations largely related to the following:

 The combined efforts of and experienced and knowledgeable environmental team comprising of an environmental manager, two environmental coordinators and two environmental officers (who are each responsible for their particular operations) to ensuring compliance to the various environmental permits held by the retained operations  Ongoing monitoring relating to surface water, groundwater and air quality parameters  Ongoing engagement with relevant stakeholders  Having an effective system to record and action incidents as they arise (Enablon) to ensure these are addressed as per an action plan which is generated per incident

The audit results indicated that the non-compliances related to the following:

 Conditions within the EMPr which are either not practical, not relevant or not achievable which would need to be amended through an EMPr amendment process. It is the Auditor’s understanding that the EMPr amendment is planned for 2020/2021  Extension of various monitoring systems to encompass the effects of the Retained Operations on off-site receptors  Several ongoing challenges around overflow of dams and resulting potential pollution to soils and water resources.

Most of the non-compliances noted included conditions which are no longer applicable or practical for the RPM operations to implement. It is SRK’s understanding that the Consolidated EMPr will be amended in the near future (2020/2021) to either amend or remove these conditions. SRK has

attempted to summarise the conditions requiring amendment in a separate memo which will be issued to the RPM Retained operations.

In summary, the audit results indicated the following:

 The retained operations are largely compliant with the conditions contained within the EMPr. A higher level of compliance is attainable subject to the amendment of the EMPr; and  Ongoing efforts by the environmental team will ensure that partial non-compliances are rated as compliant in the next audit.

Executive Summary ...... ii Disclaimer ...... vi List of Abbreviations ...... vii 1 Introduction ...... 1 2 Rustenburg Operations Overview...... 2 2.1 Property description ...... 2 2.2 Physical project description ...... 2 2.2.1 Waterval Smelter and Anglo Converter Plant ...... 8 2.2.2 Rustenburg Base Metal Refineries (RBMR) ...... 8 2.2.3 Precious Metal Refiners (PMR) ...... 9 3 Legislative Requirements ...... 13 4 Audit Objectives ...... 14 5 Environmental audit work programme ...... 14 5.1 Project team ...... 14 5.2 Environmental audit methodology ...... 14 5.3 Statement of SRK Independence ...... 15 5.4 Assumptions, uncertainties or knowledge gaps ...... 16 5.5 Other information requested by the competent authority ...... 16 6 Environmental Audit Results ...... 16 6.1 Overall level of compliance of the Retained Operations ...... 16 6.2 Recommendation for Amendment ...... 17 7 Conclusion ...... 18 8 Declarations ...... 20 8.1 Independent auditor declaration ...... 20 Appendices ...... 21 Appendix A: Independent Environmental Auditors CVs ...... 22 Appendix B: Pre-site audit meeting presentation with notes from the meeting ...... 23 Appendix C: Audit checklists ...... 24 Appendix C1: General EMPr Conditions ...... 25 Appendix C2: RBMR Conditions ...... 75 Appendix C3: Waterval Complex (Smelter and ACP) ...... 90 Appendix C4: PMR ...... 115 Appendix D: List of documents ...... 125

Table 1-1: Retained Operations ...... 1 Table 2-1: Rustenburg Retained Operations ownership details ...... 2 Table 2-2: Overview of the Retained Operations ...... 2 Table 3-1: Legislative requirements for environmental audit ...... 13 Table 5-1: Compliance rating categories and colours ...... 15 Table 6-1: Summary of compliance to the EMPr ...... 16

List of Figures

Figure 2-1: Locality Map of the Retained Operations ...... 7 Figure 2-2: Waterval Smelter Complex Infrastructure map ...... 10 Figure 2-3: Rustenburg Base Metal Refinery Infrastructure Map ...... 11 Figure 2-4: Precious Metal Refinery Infrastructure Map...... 12

The opinions expressed in this Report have been based on the information supplied to SRK Consulting (South Africa) (Pty) Ltd (SRK) by Anglo American Platinum Limited (AAP). The opinions in this Report are provided in response to a specific request from AAP to do so. SRK has exercised all due care in reviewing the supplied information. Whilst SRK has compared key supplied data with expected values, the accuracy of the results and conclusions from the review are entirely reliant on the accuracy and completeness of the supplied data. SRK does not accept responsibility for any errors or omissions in the supplied information and does not accept any consequential liability arising from commercial decisions or actions resulting from them. Opinions presented in this report apply to the site conditions and features as they existed at the time of SRK’s investigations, and those reasonably foreseeable. These opinions do not necessarily apply to conditions and features that may arise after the date of this Report, about which SRK had no prior knowledge nor had the opportunity to evaluate.

AAP Anglo American Platinum Limited ACP Acid Converting Process AEL Atmospheric Emissions Licence AQMP Air Quality Management Plan CEF Community Engagement Forum DHSWS Department of Human Settlement, Water and Sanitation DWS Department of Water and Sanitation EIA Environmental Impact Assessment EMPR Environmental Management Programme IFC International Finance Corporation IWWMP Integrated Waste and Water Management Plan LED Local Economic Development MC Matte Concentrator MoU Memorandum of Understanding NCM Nickel-Copper Matte NEMA National Environmental Management Act NWDEDECT North West Department of Economic Development, Environment, Conservation and Tourism NYDA National Youth Development Agency PGMs Platinum Group Metals PPE Personal Protective Equipment PMR Precious Metals Refinery RBMR Rustenburg Base Metals Refinery RLM Rustenburg Local Municipality RPM Rustenburg Platinum Mines SAPS South African Police Service SA NAAQs South African National Ambient Air Quality Standards SED Social Economic Development SEDA Small Enterprise Development Agency SPA Sale & Purchase Agreement SRK SRK Consulting (Pty) Ltd SRPM Sibanye Rustenburg Platinum Mines (Pty) Ltd UG2 Upper Group 2 VRP Values Recovery Plant WACM Waterval ACP Converter Matte WACS Waterval Amplats Converter Slag

WCM Waterval Converter Matte WLDC Western Limb Distribution Centre WUL Water Use Licence WVS Waterval Smelter

1 Introduction

Rustenburg Platinum Mines (RPM) has mined the Merensky Reef in the Rustenburg area since 1929. Since 1949, mining has been continuous and at an increasing rate until the present day. Mining of the Upper Group 2 (UG2) chromite layer began more recently to replace the declining Merensky reef and could continue for several decades. The Rustenburg Operations consisted of three divisions, namely Mining, Process and Support. The Anglo American Platinum Limited (AAP), Rustenburg Operations which is 100% owned and operated by Rustenburg Platinum Mines (RPM), signed a Sale and Purchase Agreement (SPA) on 8 September 2015, to dispose of a portion of its Rustenburg Retained Process Operations to Sibanye Rustenburg Platinum Mines (Pty) Ltd (SRPM). The SPA entails RPM selling its exploratory, development, mining, concentrating and tailings re-processing portion of the Rustenburg Retained Process Operations (including the associated assets, liabilities and employees) to SRPM. SRK Consulting (South Africa) (Pty) Ltd (SRK) was appointed by AAP: Rustenburg Mines to undertake an external environmental audit of the commitments contained within the Consolidated Retained Operations Environmental Management Programme (EMPR)1. The external audit has been conducted in accordance with Regulation 34 and Appendix 7 of the National Environmental Management Act (Act 107 of 1998) (NEMA) Environmental Impact Assessment (EIA) Regulations, 2014 (as amended). This report will be submitted to North West Department of Economic Development, Environment, Conservation and Tourism (NWDEDECT). To verify the commitments contained within the 2016 Consolidated EMPr, SRK undertook a site audit at the Retained Operations on 3 August and 14 August 2020 and engaged with the onsite time team (refer to section 5.1) responsible for the Rustenburg Base Metal Refinery (RBMR), Precious Metal Refineries (PMR), Waterval Smelter and Acid Converting Process (ACP) facilities. The Retained Operations are included in Table 1-1. Table 1-1: Retained Operations

Operation Status

Waterval Smelter Operational

ACP Operational

RBMR Operational

PMR Operational

Western Limb Distribution Center (WLDC) In use

Frank Concentrator Decommissioned (not yet rehabilitated)

1 Known as the Rustenburg Platinum Mines Limited: Rustenburg Section Retained Operations EMPR, 16 February 2016

for this facility (not included within the ambit of this audit). With regards to the WLDC, it is assumed that the conditions contained within the Consolidated EMPR (included in Appendix C1) are applicable to this facility as no EMPR amendment/addendum since 2002 was issued directly to this facility.

2 Rustenburg Operations Overview

RPM Rustenburg Operations is located in the North West Province, north-east of the towns of Rustenburg and Kroondal. The operational area covers approximately 12.4 km2 and stretches in excess of 9 km from east to west and 9 km from north to south. The operational area, which incorporates the process operations, falls on the farms Paardekraal 279 JQ, and Waterval 303JQ.

2.1 Property description The operational area, which incorporates the process operations, falls on the farms presented in Table 2-1 Table 2-1: Rustenburg Retained Operations ownership details

Asset Farm Portions Owner

PMR Klipfontein 300JQ Portion 4, 5 RPM

Waterval 303JQ Portion 5, 6

RBMR Waterval 303JQ Portion 6, 33, 42 RPM

ACP Waterval 303JQ Portion 14 RPM

Waterval Smelter Waterval 303JQ Portion 9,14,77 RPM

Metallurgical Laboratory Waterval 303JQ Portion 9,14 RPM

Frank Concentrator Waterval 303JQ Portion 10, 13,14,65 RPM

Western Limb Distribution Centre Waterval 303JQ Portion 68 RPM

2.2 Physical project description A description of the Process operations is presented in Table 2-1 while the regional locality of the operations is illustrated in Figure 2-1 and the locality of each operation is illustrated in Figure 2-2, Figure 2-3, Figure 2-4. Table 2-2: Overview of the Retained Operations

Infrastructure Details

Frank Concentrator

Description  The Frank concentrator has been decommissioned and some of the infrastructure is due to be demolished in line with the Rustenburg operation’s closure planning. No date for demolition has been set.

Waterval Smelter Complex and ACP

Process description  The Waterval Smelter receives wet concentrate from SRO concentrators via pipeline and trucks.  The wet concentrate is dried by flash driers to a bone-dry concentrate, which is melted in a furnace. During this process, oxide and silicate minerals (slag) are separated from the sulphide minerals. The sulphide

Infrastructure Details minerals form a matte, which contains minerals such as nickel, copper, cobalt, iron, sulphur and other Platinum Group Metals (PGMs).  The matte undergoes a converting process within the ACP Plant, where excess iron sulphide is removed. The matte is treated and the resultant converter matte is tapped and bottom cast into moulds, slow-cooled and crushed prior to being dispatched to the RBMR.  The oxide and silicate slag is tapped semi-continuously, granulated and treated through the slag mill. Untreated slag is discarded on a mine residue slag stockpile.  Air pollution minimisation at the smelter is achieved through use of the ACP, which refines the furnace product to produce a sulphur-deficient matte known as Waterval Converter Matte (WCM). During the refining process, ACP produces sulphur dioxide emissions which it converts to sulphuric acid in the acid plant. Fugitive emissions from the Smelter are captured and the sulphur dioxide in these emissions is converted to sulphuric acid in the ACP.

Roads, conveyors and  Existing paved roads connecting the Waterval Smelter, ACP Plant and pipelines Waterval slag stockpile are utilised.  Conveyors have been installed that transfer the wet concentrate from the Waterval and Upper Group 2 (UG2) concentrator to the concentrate shed. A number of conveyor systems are utilised during the smelting process.  Pipelines are utilised to transfer converter matte to the ACP plant and matte to the RBMR for further processing.

Water  Potable water is obtained from Rand Water via existing pipelines.  Process water is obtained from the East and West pollution control dams onsite and additional make-up water from Rand Water. Process water is stored in 250 concrete tanks, with the capacity of 5 000 m3.

Electricity  Existing Eskom substation has been constructed and has been upgraded to accommodate the ACP plant, slag cleaning mill, additional slag mills and acid plant.

Pollution control dams, Process Water evaporation dams and  Process water is stored in 250 concrete tanks, with the capacity of 5 000 stormwater dams m3.  Browns and Cloudy Water Tanks are also used for the storage of process water (concrete with the capacity of 3 000 m3). Clean Water  Clean and dirty water separation is undertaken using a series of drains around the complex.  Contact water arising from rainfall is stored in a dam with an engineered liner.

Surface infrastructure A number of administration offices and management offices exist within the and structures smelter complex:  Parking bays for onsite staff and visitors have been constructed.  Change house has been constructed and provides sufficient accommodation and ablution facilities for all employees, visitors, senior officials and management, including female employees and visitors.  A number of workshop facilities are available for engineering services at the Smelter Complex, namely electrical workshop, mechanical and boiler making workshop. The engineering services type workshops are equipped to facilitate routine maintenance and repairs for the smelter complex.

Infrastructure Details  Fuel and oil bays have been constructed. A combined diesel and oil bay has been constructed to ensure ease and speed of filling up machines and vehicles.  There is a store at the Smelter Complex that stores engineering and processing spares. The existing Smelter Complex store is utilised for bulk storage.  Flash drier stack, furnace off-gas stack, main stack - Slag Cleaning Furnace and acid plant stacks.  Workshop where furnaces, flash driers, matte granulating and drying activities occur.  ACP Converter plant that includes slow cooling operations, slag cleaning furnaces and slag mills.  Coal stockpiles for storage of coal used during heating at the flash dryers.  Acid plant with various storage tanks and pipelines is in operation.  Slag stockpile area.

Sewage plant  Sewage is pumped to the Waterval Sewage Plant operated by SRO.

Waste  A waste storage facility has been constructed that stores waste originating from operational activities. All waste is managed and disposed of according to the principles of reuse, reduce or recycle.  The services of a private waste disposal contractor are utilised in the absence of a suitable facility within the area.

Rustenburg Base Metals Refinery

Process description  The crushed matte generated from the ACP Plant is transferred to the Magnetic Concentration Plant at the RBMR.  The magnetic PGM-containing fraction is removed from the matte and sent to the PMR for refining. The resultant matte undergoes sulphuric acid leaching where copper and nickel are extracted. The leach residue also makes up a high-grade PGM concentrate that is transferred to the PMR.  Low grade residues resulting from the process are recycled back to the smelter.

Roads, railways,  A number of paved and unpaved roads are utilised within the RBMR plant conveyors and pipelines area.  Conveyor at Matte Concentrator (MC) plant transport WCM material from a receiving bin to the milling section and another conveyor transport ash from the boilers to an ash silo. No conveyors exist outside the plant area.  Road tankers are used to transport WCM from the Waterval Smelter to the RBMR for further processing.

Water  Potable water is obtained from Rand Water via existing pipelines.  Process water is obtained from the stormwater dams onsite and additional make-up water from Rand Water.

Electricity  Existing Eskom substation has been constructed and is utilised by the RBMR.

Pollution control dams, The dams associated with water management at RBMR are: evaporation dams and  Feed dams. stormwater dams  Effluent dam No. 1.  Effluent Dam No. 2.  Effluent Dam No. 3.  Dam 4S Sodium Sulphate Dam.

Infrastructure Details  Waste Liquor Dam.  Encapsulation Dams were originally constructed in 1997 to contain sludge from Dam 3A and polluted soils in the plant area. The dams are HDPE lined and has a capacity of 8 000 m3. The dams have leakage detection sumps with U24 Geotextile liner.  Stormwater Dam 1.  Stormwater Dam 2.  Stormwater Dam 3A.  Stormwater Dam 3B.  Triangular Dam.

Surface infrastructure  A number of administration offices and management offices exist within and structures RBMR.  Parking bays for onsite staff and visitors has been constructed.  Change house has been constructed and provides sufficient ablutions for all employees, senior officials, management, and visitors.  A number of workshop facilities are available for engineering services at RBMR  Diesel issuing pump and oil stores have been constructed.  There is a store at RBMR that stores engineering and production spares.  Refinery plant and associated stacks.

Sewage plant  Sewage is pumped to the Waterval Sewage Plant operated by SRO.

Waste  A waste storage facility has been constructed that temporarily stores waste originating from operational activities.  All industrial waste is transported by a private waste management company to the central salvage yard from where it is sorted /recycled, sold as scrap or disposed of at a registered landfill site.

Precious Metals Refinery

Process description  The PMR has a 3.5 million Ounces Troy Platinum Equivalent capacity. In addition to platinum the PMR also produces gold and the PGMs rhodium, palladium, ruthenium, iridium, and osmium.  Through a succession of highly selective separation steps, concentrated liquors are produced of each of the individual metals.  After extraction, the concentrated liquor of each individual metal is forwarded to a specific side stream where a final purification is performed before precipitation of a pure salt. The pure salts are then transformed to metal by reduction.  Depending on the grade, solid residues produced by the various processes are recycled internally, transferred back to the smelter or toll-refined. Liquor effluents generated during the separation processes are sent to the Values Recovery Plant (VRP) where some of the volume is reduced by evaporation and the final low PGM values are recovered by means of a series of cementation processes.  After VRP, the acid effluent is neutralised with lime before being stored in the effluent dams. Alkali effluent originating primarily from various caustic scrubbers is also stored in effluent dams. Effluent volumes are currently managed by evaporators. The contents of the dams are recovered and go back to the smelter for re-treating.

Infrastructure Details

Roads, railways,  Existing paved roads connecting the PMR are utilised. A number of paved conveyors and pipelines roads are utilised within the PMR plant area. All access is strictly controlled.  Existing railway lines connect the PMR with the Rustenburg – Pretoria route.  PGM matte is transported via road from the RBMR to the PMR for further processing.

Water  Potable water is obtained from Rand Water via existing pipelines.  Process water is obtained from the stormwater dam’s onsite and additional make-up water from Rand Water.

Electricity  Existing Eskom substation has been constructed and is utilised by the PMR

Pollution control dams,  Effluent Dam 1 has a capacity of 38 200 m3 and comprises a composite evaporation dams and liner of 100 – 300 mm sand bedding and 2000 micron HDPE. stormwater dams  Effluent Dam 2 has a capacity of 41 142 m3 with a composite liner of 100 – 300 mm sand bedding and 2000 micron HDPE.  Effluent Dams 4 and 5 have a capacity of 163 000 m3 excluding 500 mm freeboard and 200 mm storm allowance. The dam wall is 6.3 m in height, has a 4 m crest and consists of compacted clay capped with decomposed inert residential norite.  Effluent Dam 6 East has a capacity of 21 600 m3 and has been constructed with a triple liner system (polypropylene) to enable timely detection of leakage and capturing and removing of leakage through the first and second liner system to prevention linkage reaching the aquifer.  Dam 6 West has a capacity of 31 200 m3 and was constructed with a similar triple liner system as Dam 6 East.  All effluent arisings are handled either internally in the VRP or by reversion to RPM-RS Residues are ultimately returned to process via Waterval Smelter whilst effluent liquors are neutralised and concentrated by evaporation prior to discharge to effluent dams.  Dams 1 – 5 store acidic effluent and dams 6 East and West store alkaline effluent.  A spillway exists between dams 5 and 6 West and between 6 East and 6 West.

Surface infrastructure  A number of administration offices and management offices exist within the and structures smelter complex.  Parking bays for onsite staff and visitors has been constructed.  Change house has been constructed and provides sufficient accommodation and ablutions for all employees, visitors, senior officials and management, and all female employees and visitors.  A number of workshop facilities are available for engineering services at the shaft, namely electrical workshop, mechanical and boiler making workshop. The engineering services type workshops are equipped to facilitate routine maintenance and repairs for the smelter complex.  Fuel and oil bays have been constructed.  Refinery and processing workshops are located within the PMR. A number of stacks release off gas into the atmosphere.

Sewage plant  Sewage is pumped to the Waterval Sewage Plant operated by SRO.

Infrastructure Details

Waste  A waste storage facility has been constructed that stores waste originating from operational activities. The services of a private waste disposal contractor are utilised in the absence of a suitable facility within the area.

Other  Divisional Metallurgical Laboratory.  Western Limb Distribution Centre (WLDC) and associated infrastructure  Explosives area consisting of magazine buildings and blast protection  Laydown area to the west of RBMR

2-1

Figure 2-1: Locality Map of the Retained Operations

2.2.1 Waterval Smelter and Anglo Converter Plant The Waterval Smelter’s (WVS) main function is to smelt platinum-bearing concentrate derived from several of Anglo American Platinum’s mines located in the western bushveld in addition to that produced by SRO itself. Some smelting of concentrate is also periodically undertaken at WVS. Concentrate, which is transported to the WVS, contains PGMs which include platinum, palladium, ruthenium, rhodium, osmium, iridium and also base metals mainly nickel, cobalt and copper. Concentrate is smelted in electric arc furnaces. The furnace product is further refined in either the Pierce-Smith converters or Anglo American Platinum Acid Converter Plant (ACP) to produce a sulphide matte referred to as Waterval Converter Matte (WCM) and Waterval ACP Converter Matte (WACM) respectively. The ACP converts sulphur dioxide emissions to sulphuric acid and captures fugitive emissions from the Smelter. The matte is delivered to Rustenburg Base Metal Refiners for refining via road in sealed containers. The waste product of the smelting process is a slag. The slag is milled and then transported to a concentrator where it is blended with tails and disposed of on a tailings dam. That not disposed of on the tailings dam is milled to produce a product used for sand blasting (see below). The SOx generated during the smelting process are converted to sulphuric acid. All the emissions abatement equipment has a high efficiency, capture of smelter off-gasses is not complete and some gasses and entrained dust is vented to the atmosphere. There is infrastructure associated with the smelter that is not under the smelters control and is currently operated by external parties. This infrastructure includes:

 The “Blastrite” area where slag generated in the smelter is milled to produce a fine material used for sand blasting. Slag that is used by Blastrite is stockpiled to the north of the smelter.  R & J Transport area where transport contractors have a mechanical workshop and service and cleaning bay for their vehicles. Infrastructure relating to the Waterval Smelter Complex is shown in Figure 2-2.

2.2.2 Rustenburg Base Metal Refineries (RBMR) RBMR was commissioned in 1981 and replaced the original hydro metallurgical operation. The original hydro metallurgical operations have been largely demolished, however, some residual infrastructure still remains within the fence at RBMR. WCM is transported to the Matte Concentrator Plant (MC Plant) at the RBMR plant site. The WCM is milled and the matte slurry is passed over wet magnetic separators. The resulting products are a PGM rich magnetic concentrate and a nickel-copper matte (NCM). The PGM rich magnetic concentrate is leached with acid to remove residual base metals. The final PGM concentrate is transported to the Precious Metals Refiners (PMR) via road where the PGMs are separated and refined. The processes in the MC Plant produce concentrated copper nickel solutions. These solutions and the NCM are the principle feed stocks to the RBMR. During the refining of copper and nickel sulphuric acid and sodium hydroxide are used to leach the metals as well as to adjust pH in the process. A by-product of the process is the generation of sodium sulphate. The sodium sulphate solution passes through a crystalliser, with the produced crystals sold. The remaining solution is stored in a series of dams within the footprint of the plant. Infrastructure relating to Rustenburg Base Metal Refineries is shown in Figure 2-3.

2.2.3 Precious Metal Refiners (PMR) Final metal refining is undertaken at PMR. Concentrated feedstock is dissolved using boiling hydrochloric acid and chlorine gas. The metals are then purified with a series of feed preparation and solvent extraction operations. Further purification to 99.9% purity is achieved through calcination and subsequent acid/water washing and, if required, induction melting to produce grain or ingot. The final products of the PMR refining processes are platinum, palladium, rhodium, iridium, ruthenium, gold and osmium. During the process both acidic and alkaline effluents are generated (hydrochloric and sodium hydroxide are used in the extraction process). Prior to disposal the acid effluents are treated with lime to increase the pH. This treatment raised pH, but it also has a significantly increases salinity. After treatment, both the acidic and alkaline effluents are disposed of in evaporation ponds constructed within the plant footprint. Infrastructure relating to PMR is shown in Figure 2-4.

Figure 2-2: Waterval Smelter Complex Infrastructure map

Figure 2-3: Rustenburg Base Metal Refinery Infrastructure Map

Figure 2-4: Precious Metal Refinery Infrastructure Map

3 Legislative Requirements

The Rustenburg Process Operations 2020 external environmental audit has been compiled to fulfil the requirements of Regulation 34 and Appendix 7 of the NEMA 2014 EIA Regulations, as amended. The report has been compiled in accordance with the requirements stipulated in Appendix 7 of the NEMA 2014 EIA Regulations, as amended. Table 3-1 provides a summary of the requirements in terms of Regulation 34 and Appendix 7 and includes section references to this report indicating where the relevant requirements have been addressed. Table 3-1: Legislative requirements for environmental audit

Regulations 34(2)(b) of Appendix 7 of NEMA EIA Regulations Reference in this report NEMA EIA Regulations The environmental audit An environmental audit report must Section 5.1 and Appendix A report must provide verifiable contain findings, in a structured and (a) details of- systematic manner, on- (i) the independent person who (i) the level of prepared the environmental performance against audit report; and and compliance of an (ii) the expertise of independent organization or project person that compiled the with the provisions of environmental audit report the requisite (b) a declaration that the independent Section 8 environmental auditor is independent in a form as authorisation or EMPr may be specified by the competent and, where applicable, authority the closure plan; and (c) an indication of the scope of, and the Section 1 and Section 4 (ii) the ability of the purpose for which, the environmental measures contained in audit report was prepared; the EMPr, and where (d) a description of the methodology Section 5.2 applicable the closure adopted in preparing the plan, to sufficiently environmental audit report; provide for the (e) an indication of the ability of the Section 6 and Appendix C and D avoidance, EMPr, and where applicable, the management and closure plan to- mitigation of (i) sufficiently provide for the environmental impacts avoidance, management and associated with the mitigation of environmental undertaking of the impacts associated with the activity undertaking of the activity on an on-going basis; (ii) sufficiently provide for the avoidance, management and mitigation of environmental impacts associated with the closure of the facility; (iii) ensure compliance with the provisions of environmental authorisation, EMPr, and where applicable, the closure plan (f) a description of any assumptions Section 5.4 made, and any uncertainties or gaps in knowledge; (g) a description of any consultation Section 5.2 process that was undertaken during the course of carrying out the environmental audit report;

Regulations 34(2)(b) of Appendix 7 of NEMA EIA Regulations Reference in this report NEMA EIA Regulations (h) a summary and copies of any Section 5.2 and Section 5.5 comments that were received during any consultation process; and any other information requested by the competent authority (Section 4.5). 4 Audit Objectives

The objectives of this EMPr Environmental Audit Report of Rustenburg process operations approved EMPrs are as follows:

 To meet the requirements of Regulation 34 read together with Appendix 7 of the NEMA EIA Regulations of 2014 (as amended);  To report on the level of compliance with the commitments stipulated in the approved Consolidated EMPr Process Operations EMPr as per the categories provided in Table 3-1;  To report on the extent to which the management and mitigation measures provided for in the Process Operations EMPrs achieve the objectives and outcomes stated in the EMPrs; and  If necessary, to identify the need for any changes to the management and mitigation measures provided in the Consolidated EMPr (where measures may no longer be applicable or require amendment to ensure compliance), to address issues of partial or non-compliance in terms of the EMPrs commitments. 5 Environmental audit work programme

5.1 Project team Details of the SRK team that assisted with the external environmental audit are presented in Table 5.1. Table 5.1: SRK project team

Team Member Role

Mrs Franciska Lake Lead auditor and Reviewer

Mrs Ashleigh Maritz Project manager and reporting

Mr Kavilan Naidoo Assistant auditor and reporting

Please refer to Appendix A for the Curricula Vitae of SRK team.

5.2 Environmental audit methodology To meet the requirements of the environmental audit as stipulated in Regulation 34 and Appendix 7 of the NEMA EIA Regulations (as amended), the following activities were undertaken:  An on-site audit was undertaken by Franciska Lake and Kavilan Naidoo on 3 August and 13 August 2020, to assess the compliance level of the current activities against the management measures stipulated in the Consolidated EMPr; and  As part of the environmental audit process a virtual pre-audit meeting was held on 22 July 2020 via Teams with the following Process Operations Personnel. Refer to Appendix B for the presentation with associated notes captured during the meeting:

o Mr Dustin Van Helsdingen (Environmental Management: Platinum Process Operations) o Ms Boipuso Semenya (Environmental Coordinator, RBMR) o Ms Nongaka Khaas (Environmental Coordinator, PMR)

o Mr Simon Dladla (Environmental Officer for the Waterval Smelter) o Mrs Marietjie Schoeman (Environmental Officer ACP)

The purpose of this meeting was to discuss the approach to the environmental audit and to specify the information needs to assist with verifying the level of compliance relating to the construction, operational and rehabilitation and closure commitments stipulated in the Consolidated EMPr. The information listed in Appendix D was provided by the operations to the auditors for review and verification purposes. This information was comprised of:  Photographs of some observations made during the time of the on-site audit;  Relevant documentation including current monitoring practices and recent monitoring reports; and  Previous external environmental audits. Chapter 7 of this report present Operations’ compliance based on the commitments stipulated in their approved EMPrs. The level of compliance of each commitment assessed (as indicated in Appendix C) was based on the categories described in Table 5-1 below. The categories have been given specific colours for ease of reference. Table 5-1: Compliance rating categories and colours

Category Colour Description

Compliant Where the EMPr management measure was met.

Partially Where implementation or compliance with the EMPr condition is attempted, complaint but not being fully adhered to.

Non-compliant Where the EMPr management measure was not met.

Not This is applied where the EMPr commitments reflects certain requirements or Applicable/Noted actions that are currently not required in terms of the current phase of the operation or may refer to commitments or conditions set out in the relevant documentation which may have implications for the Process Operations in the future but is currently not relevant, e.g. construction or operation activities for activities that have not yet commenced, or closure activities/commitments/conditions. A ‘noted’ comment is included where conditions are statements to be aware of.

If an EMPr commitment was found to be non-compliant, the following details were included in the findings table:  The nature of the EMPr commitment;  Measures implemented to address the non-compliance; and  Practicality of the EMPr commitment.

5.3 Statement of SRK Independence Neither SRK nor any of the authors of this report have any material present or contingent interest in the outcome of this environmental audit, nor do they have any pecuniary or other interest that could be reasonably regarded as being capable of affecting their independence or that of SRK. SRK has no beneficial interest in the outcome of the environmental audit being capable of affecting its independence. SRK’s fee for completing this environmental audit is based on its normal professional daily rates plus reimbursement of incidental expenses. The payment of that professional fee is not contingent upon the outcome of the environmental audit

5.4 Assumptions, uncertainties or knowledge gaps The following assumptions, uncertainties and knowledge gaps are applicable to this Environmental Audit:  The audit was undertaken on the information provided by RPM Retained Operations.  The Retained Operations team indicated to SRK at the time of the audit that full disclosure has been made of all material information and that, to the best of its knowledge and understanding, such information is complete, accurate and true.  In certain instances, findings were verified using information from previous environmental, and water use licence audits.  In certain instances, timelines and footprints were verified using Google Earth.  In certain instances, information could not be verified and was noted as not being assessed.  The environmental audit was undertaken during Covid-19 lockdown level three.

5.5 Other information requested by the competent authority At the time of conducting the Process Operations environmental audit in respect of the commitments pertained in the approved EMPrs, no additional information was requested by the competent authority. 6 Environmental Audit Results

6.1 Overall level of compliance of the Retained Operations The overall level of compliance of the Retained Operations is represented in Table 6-1. The overall level of compliance has been separated according to compliance to the general conditions (or conditions applicable to/common to all of the Retained Operations) as well as compliance to specific conditions associated with each of the Retained Operations. The assessment of the compliance to each EMPr condition has been included in Appendix C. These commitments have been reviewed and assessed according to the assessment methodology contained in Section 5.2. A summary of the overall number of findings is presented in Table 6-1. Based on the findings, RPM are compliant with 471 commitments, partially compliant with 36 conditions, non-compliant with 12 commitments and 85 commitments where either not applicable or noted. Table 6-1: Summary of compliance to the EMPr

Compliance to General EMPr conditions

Number of conditions 245

Compliant 182

Partially compliant 17

Non-compliant 5

Not applicable / noted 41

Nature of the non-compliances observed for General EMPr conditions:

 Several conditions are no longer applicable or practical to implement and therefore an amendment to either rephrase these conditions or to remove these conditions is required. This will assist in addressing these non-compliances.

 Placement of a coal stockpile in an un-authorised area at ACP. It is noted that an action plan has already been put in place as a result of this finding during the site audit and will be rectified.

Compliance to Retained Operations EMPr conditions

RBMR PMR Waterval Complex

Number of 105 84 170 conditions

Compliant 81 76 132

Partially 9 0 10 compliant

Non-compliant 1 0 6

Not applicable / 14 8 22 noted

Nature of the non-compliances observed:

RBMR Condition pertains to the monitoring of off-site noise levels and a non-compliance was awarded as this is not being conducted. No noise issues or complaints were received or noted during the audit.

PMR No non-compliances were observed for the PMR operation during the audit period.

Waterval Three of the non-compliances observed will be addressed through the amendment of the Complex EMPr conditions. An action plan is already in place to address the non-compliance associated with monitoring of volumes and quality of stormwater inflows and discharges from the interception trench systems. The remaining two non-compliances are associated with monitoring of noise impacts and extension of the monitoring programme to include potential new developments around the smelter and the following through on the recommendations of the noise survey conducted at ACP in 2017.

6.2 Recommendation for Amendment As a result of this audit exercise there were several conditions identified which require amendment and these have been communicated to the Retained Operations as part of a separate memorandum. As part of the previous Environmental Audit undertaken by WSP, some of the conditions identified were submitted to the authorities for amendment/removal. Notifications of the amendment were issued to all stakeholders including the NWDEDECT in December 2019 and no response has been received as of yet. It is therefore assumed that these conditions still apply and require amendment. The reasons for amendment include:  EMPr conditions are no longer applicable to the retained operations;  EMPr condition wording is not in line with what is specifically happening on site; and  EMPr condition is not practical to implement.

Of the 604 conditions, RPM are compliant with 471 commitments, partially compliant with 36 conditions, non-compliant with 12 commitments and 85 commitments where either not applicable or noted. A high level of compliance to the EMPr conditions has been achieved and where non-compliances have been noted, the RPM team have action plans in place to address these to ensure that compliance is achieved. This includes the amendment of the EMPr to ensure that conditions are applicable to the operations and are practical to implement to ensure effective management of environmental risks associated with the various operations. RPM has demonstrated that they liaise on a regular basis with the competent and commenting authorities to discuss potential projects, management of impacts and planned changes associated with the operation. This includes projects which do not require environmental authorisation but will add to the management of environmental impacts as well as the current transitioning to the Anglo Social Way 3 which incorporates RPM’s social commitments. It is the independent auditor’s opinion that the consolidated EMPr is sufficient to manage the RPM operations and this will be further enhanced through the amendment of this document.

Prepared by Reviewed by

______Kavilan Naidoo Franciska Lake Environmental Scientist Principal Partner

______Ashleigh Maritz Senior Environmental Scientist

All data used as source material plus the text, tables, figures, and attachments of this document have been reviewed and prepared in accordance with generally accepted professional engineering and environmental practices.

8.1 Independent auditor declaration Appendix 7 of GNR 982 refers to the need for the independent auditor to declare his/her independence of the holder of the EMPR.

NAME OF INDEPENDENT AUDITOR 1: Franciska Lake

NAME OF INDEPENDENT AUDITOR 2: Ashleigh Maritz

NAME OF INDEPENDENT AUDITOR 3: Kavilan Naidoo

UNDERTAKING We, Franciska Lake, Ashleigh Maritz and Kavilan Naidoo the undersigned and duly authorized thereto, by SRK Consulting (Pty) Ltd, have studied Rustenburg Platinum Mines Rustenburg Operations and compared the operations to the approved EMPr and compiled this report to the best of our knowledge.

Signed at Sandton on this the 30 day of November 2020.

SIGNATURES OF INDEPENDENT AUDITORs

______Franciska Lake Partner and Principal Consultant Pr.Sci.Nat

______Ashleigh Maritz Senior Environmental Scientist Pr.Sci.Nat, Registered EAP

______Kavilan Naidoo Environmental Scientist

SIGNED IN LINE WITH THE REQUIREMENTS OF NEMA, GNR 982, APPENDIX 7, AS PUBLISHED UNDER THE NATIONAL ENVIRONMENTAL MANAGEMENT ACT (NO. 107 OF 1998), AS AMENDED.

Appendices

Appendix A: Independent Environmental Auditors CVs

MARA/NKAV/LAKF 558834_RPM_EMPR_Final Reg 34 Audit Report_20201130 November 2020 Resume Franciska Lake Partner

Profession Environmental Scientist Education BSc (Hons), Zoology, University of Johannesburg, 2000 Registrations/ Pr Sci Nat (South Africa), 400248/05 Affiliations Awards None

Specialisation Environmental Impact Assessments, the compilation, implementation and assessing of Environmental Management Programmes and Plans, environmental auditing, site assessments and assessing environmental compliance.

Expertise Franciska Lake has been involved in water management, environmental impact assessments and environmental management programmes for the last 19 years. Her expertise includes:

• water and environmental management for mines and industry • compilation of environmental impact assessments and management programmes, • implementation and assessing of environmental management programmes and Plans, • environmental auditing and site assessments • assessment of environmental compliance. • project management and coordination • compilation and review of technical documentation • consultation with authorities and stakeholders

Employment

2018 – present SRK Consulting (Pty) Ltd, Partner and Consultant, Principal Environmental Scientist, Johannesburg 2007 – 2018 SRK Consulting (Pty) Ltd, Associate Partner and Consultant, Principal Environmental Scientist, Johannesburg 2007 – 2007 Self-employed, Environmental Scientist, South Africa 2004 – 2006 EA&MS, Environmental Scientist, South Africa 2001 – 2004 SRK Consulting (Pty) Ltd, Environmental Scientist, Johannesburg

Publications None

Languages English – read, write, speak Afrikaans – read, write, speak

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Key Experience: Environmental impact assessments and environmental management programmes

Location: Mokopane Project duration & year: 14 Months 2018-2020 Client: Anglo American Platinum Name of Project: Mogalakwena Mine Expansion Project Application for Environmental Authorisation Project Description: Environmental, Waste and Water application for authorisation Job Title and Duties: Project Manager Value of Project: N/A

Location: Limpopo Project duration & year: 3 Months 2019 Client: Platinum Mining Name of Project: Regulation 29 EMPr Amendments Project Description: Regulation 29 EMPr amendments for various projects Job Title and Duties: Project Manager Value of Project: R120 000

Location: Steelpoort Project duration & year: 2 Months 2017 Client: Mining Industry Name of Project: Care and Maintenance Plan Project Description: Development of Care and Maintenance Plan Job Title and Duties: Project Manager Value of Project: R380 000

Location: Steelpoort Project duration & year: 9 Months Client: Modikwa Platinum Mine Name of Project: Community Road Basic Assessment Project Description: Community Road Basic Assessment Job Title and Duties: Project Manager Value of Project: R180 000

Location: Steelpoort Project duration & year: 9 Months Client: Modikwa Platinum Mine Name of Project: North Ventilation Shaft and Crusher Plant Basic Assessment Project Description: North Ventilation Shaft and Crusher Plant Basic Assessment Job Title and Duties: Project Manager Value of Project: R180 000

Location: Polokwane Project duration & year: 2 Months 2016 Client: Polokwane Smelter Name of Project: Regulation 29 EMPr Amendment Project Description: Regulation 29 amendment to the EMPr for Slag 5 Slag Pad Job Title and Duties: Project Manager Value of Project: R120 000

Location: Steelpoort Project duration & year: 2 Years 2013-2015 Client: Modikwa Platinum Mine Name of Project: Modikwa Platinum Mine South 2 Shaft EMPr Amendment Project Description: EIA/EMPr for Modikwa Platinum Mine Waste Rock Dump Job Title and Duties: Project Manager Value of Project: R3 600 000

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Key Experience: Environmental impact assessments and environmental management programmes

Location: Rustenburg Project duration & year: 2010 - 2012 Client: AQPSA Name of Project: Marikana Open Rehabilitation and Tailings Dam EMP Project Description: EIA/EMPr for Marikana Open Rehabilitation and Tailings Dam Job Title and Duties: Project Manager Value of Project: R5 000 000

Location: Rustenburg Project duration & year: 2007 to 2012 Client: AQPSA Name of Project: K6 Shaft EMP Project Description: EIA/EMP for the new K6 Shaft Job Title and Duties: Project Manager Value of Project: R2 300 000

Location: Rustenburg Project duration & year: 2 years.2006-2008 Client: AQPSA Name of Project: K2 Railway Siding EMP Project Description: K2 Railway Siding EMP Job Title and Duties: Project Manager Value of Project: R1 100 000

Key Experience: Environmental management programme audits

Location: Rustenburg, North West Province Project duration & year: 2 weeks (2010) Client: Anglo Platinum Name of Project: Styldrift Mine Project Description: EMP Assessment for Styldrift Mine Job Title and Duties: Project Manager Value of Project: R60 000

Location: Rustenburg, North West Province Project duration & year: 2 weeks (2005,2007,2009) Client: Aquarius Platinum Name of Project: Aquarius Platinum – Kroondal Mine Project Description: EMP Assessment for Kroondal Mine Job Title and Duties: Project Manager Value of Project: R300 000

Location: Mpumalanga Project duration & year: 2 weeks.(2006) Client: Aquarius Platinum Name of Project: Aquarius Platinum – Everest Mine Project Description: EMP Assessment for Everest Mine Job Title and Duties: Project Manager Value of Project: R60 000

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Key Experience: Environmental management programme audits

Project duration & year: 2 weeks (2004) Client: Rustenburg Platinum Mines Name of Project: Rustenburg Platinum Mines – Union Section Project Description: EMP Assessment for Union Mine Job Title and Duties: Project Manager Value of Project: R50 000

Location: Rustenburg, North West Province Project duration & year: 2 weeks (2002) Client: Rustenburg Platinum Mines Name of Project: Rustenburg Platinum Mines – Rustenburg Section Project Description: EMP Assessment for Waterval Mine, PMR, WLTR Job Title and Duties: Project Manager Value of Project: R50 000

Key Experience: Due diligence

Location: South Africa Project duration & year: 2 Months 2017 Client: Mining Industry Name of Project: Environmental Due Diligence Project Description: Mining Environmental Due Diligence Job Title and Duties: Project Scientist – Environmental input

Location: South Africa Project duration & year: 6 Months 2016-2017 Client: Mining Industry Name of Project: Environmental Due Diligence Project Description: Mining Environmental Due Diligence Job Title and Duties: Project Scientist – Environmental input Value of Project: R1 000 000

Key Experience: Waste management

Location: Steelpoort Project duration & year: 6 months.(2015) Client: Modikwa Platinum Mine Name of Project: Modikwa Platinum Mine North 2 Shaft EMP Amendment Project Description: Development of Modikwa Waste Management Plan Job Title and Duties: Project Manager Value of Project: R150 000

Key Experience: Water use licensing

Location: Rustenburg Project duration & year: 2007 - 2010 Client: Anglo Platinum Name of Project: RPM – RS Water Use License Project Description: RPM – RS Water Use License Job Title and Duties: Project assistant Value of Project: Ongoing

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Key Experience: Water use licensing

Project duration & year: 2006 Client: AQPSA Name of Project: Assistance with Kroondal & Marikana Miner Water use License Project Description: Kroondal and Marikana Water Use Licences Job Title and Duties: Project assistant Value of Project: R250 000

Key Experience: General environmental management

Location: Rustenburg Project duration & year: 2 years 2005 - 2007 Client: AQPSA Name of Project: Aquarius Platinum – Kroondal Mine Project Description: General Environmental Management Job Title and Duties: Project Manager Value of Project: R300 000

Location: Marikana Project duration & year: 2 years 2005- 2007 Client: AQPSA Name of Project: Aquarius Platinum – Marikana Mine Project Description: General Environmental Management Job Title and Duties: Project Manager Value of Project: R300 000

Key Experience: Water monitoring & management

Location: Rustenburg Project duration & year: 18 months (2003 – 2004) Client: Anglo Platinum Name of Project: Rustenburg Platinum Mines – Rustenburg Section Project Description: Secondment to Rustenburg Section as Water Manager Job Title and Duties: RRED Water Manager Value of Project: R300 000

Key Experience: Safety and sustainable development concept studies

Location: Thabazimbi Project duration & year: 3 months (2017) Client: Anglo Platinum Name of Project: Rustenburg Platinum Mines – Amandelbult Section Project Description: Concept phase study Job Title and Duties: S&SD Project Manager Value of Project: R400 000

Key Experience: Safety and sustainable development feasibility studies

Location: Burgersfort Project duration & year: 6 months (2016) Client: Anglo Platinum Name of Project: Mototolo Tailings Dam Project Description: Mototolo Tailings Dam Feasibility Study Job Title and Duties: S&SD Project Manager

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Key Experience: Safety and sustainable development feasibility studies

Project duration & year: 6 months (2013) Client: Modikwa Platinum Mine Name of Project: South 2 Shaft Mine Plan Amendments Project Description: FEL 3 SD Feasibility Study Job Title and Duties: S&SD Project Manager

Lakf/Omar SRKZA_JNB_LakeF_Nov_2020.docx_QR November 2020 Resume Ashleigh Maritz Senior Scientist

Profession Environmental Science and Management Education MSc (Biochemistry) Cum Laude, University of Johannesburg, 2007 BSc Honours (Biochemistry) Cum Laude, University of Johannesburg, 2005 BSc (Chemistry and Biochemistry), University of Johannesburg, 2004 Registrations/ Pr.Sci.Nat, SACNASP, 400331/11 Affiliations Member, EAPASA, 2020/547 Member, IAIAsa Member, NACA Awards None

Specialisation Environmental project management; environmental and social impact assessments, due diligence reviews, strategic environmental planning, environmental construction management.

Expertise Ashleigh has 12 years’ experience in the mining, agricultural, water, climate change, energy and infrastructure sectors specialising in environmental impact assessment and management, environmental and social safeguards, due diligence and environmental review. Her core expertise lies in project management of environmental and social impact assessments (within South African and Africa), auditing and due diligence/technical reviews. Ashleigh also has a keen interest in Climate Change and is focussed on developing her expertise in the mitigation and adaptation spheres of this field. Recently, Ashleigh has being involved in mega infrastructure and energy projects and her experience also spans into the mining and governmental sectors in South Africa, Zimbabwe, Malawi, Namibia, Democratic Republic of Congo, Botswana and Zambia. Ashleigh has worked extensively in the Engineering, Procurement, Management and Construction (EPCM) environment and therefore as a thorough understanding of the project life cycle (from concept, pre-feasibility, feasibility and through to implementation) as well as how to provide an interface role between the technical engineering teams and environmental advisors on projects.

Employment

2018 – present SRK Consulting, Senior Environmental Scientist, Illovo, Johannesburg 2011 – 2018 Hatch Africa (Pty) Ltd, Senior Environmental Advisor, Johannesburg 2008 – 2011 SRK Consulting, Environmental Scientist, Johannesburg

Publications Various environmental and social publications and journal articles pertaining to climate change, environmental legislation, social transitioning to mine closure and other publications related to her Masters Dissertation.

Languages English – read, write, speak (excellent) Afrikaans – read, write, speak (good)

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Key Experience: Environmental permitting

Location: Limpopo Province, South Africa Project duration & year: Current Client: Anglo American Platinum – Mogalakwena Mine Name of Project: Mogalakwena Mine DAF Plants Basic Assessment Project Description: Basic Assessment process for the proposed Dissolved Air Floatation Plants Project at Mogalakwena Mine. Job Title and Duties: Project Manager responsible for team coordination and report compilation Value of Project: R 300 000 in fees

Location: Limpopo Province, South Africa Project duration & year: Current Client: Anglo American Platinum – Mogalakwena Mine Name of Project: Integrated Basic Assessment Project at Mogalakwena Mine Project Description: An Integrated Basic Assessment process for several proposed projects at Mogalakwena Mine including projects requiring various environmental authorisations such as Regulation 29 Part 1, Regulation 31 and basic assessment processes. Job Title and Duties: Project Manager responsible for internal team and specialist’s coordination and report compilation Value of Project: R 1.7 million in fees

Location: Limpopo Province, South Africa Project duration & year: 2018 – 2020 Client: Anglo American Platinum – Mogalakwena Mine Name of Project: Mogalakwena Mine Expansion Project Project Description: Environmental assessment process for the proposed Expansion Project at Mogalakwena Mine. The project includes a full Scoping/EIA process together with an extensive public participation exercise, Water Use Licence Applications and Regulation 29 Part 1 amendments for new technologies proposed at the Mogalakwena Mine Job Title and Duties: Environmental Coordinator Value of Project: R 5 million in environmental fees

Location: KZN, South Africa Project duration & year: Two years, 2017-2018 Client: The KwaZulu-Natal Department of Transport Name of Project: Basic Assessment for Borrow Pit Applications within the iLembe District Municipality on Ingonyama Trust Land Project Description: Basic Assessments for the permitting of Job Title and Duties: Environmental Advisor and project manager of the Basic Assessment Process Value of Project: R250 000

Location: Jericho Dam, Amsterdam, Mpumalanga Province, South Africa Project duration & year: One year, 2017-2018 Client: Department of Water and Sanitation Name of Project: Jericho Dam Pump Station Refurbishment Project Description: Environmental permitting for the construction of a new pump station to replace the existing pump station at the Jericho Dam which is a National Key Point. Job Title and Duties: Environmental Advisor and project manager responsible for conducting the Basic Assessment Process. Value of Project: R 216 000 in environmental fees

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Key Experience: Environmental permitting

Location: Western Cape, South Africa Project duration & year: Two years, 2017-2018 Client: Western Cape Government Roads Name of Project: Basic Assessment for the flood damage repairs to structures on the MR309 in Seweweekspoort Pass, Western Cape Project Description: Basic Assessment and Water Use Licence process for the upgrade and repair of 30 storm water management structures along the MR309 road within the Seweweekspoort in the Western Cape. Job Title and Duties: Environmental Advisor and project manager of the Basic Assessment Process Value of Project: R250 000

Location: Welkom and Virginia, Free State Province, South Africa Project duration & year: Two years, 2016-2018 Client: Matjhabeng Local Municipality Name of Project: Wastewater Treatment Works upgrades to the Virginia, Nyakallong and Theronia Works. Project Description: Environmental authorisation processes and three Water Use Licence Applications for required upgrades and repairs to the Virginia, Nyakallong and Theronia Wastewater Treatment Works. Job Title and Duties: Environmental Advisor and project manager responsible for conducting the permitting processes. Value of Project: R 2.5 million in environmental fees

Location: Eastern Cape, South Africa Project duration & year: Eight months, 2016 Client: Amathole District Municipality Name of Project: Xora Rural Water Supply Scheme Project Description: The environmental scope included the compilation and submission of several General Authorisations in terms of the National Water Act of South Africa for stream crossings required by the project. Job Title and Duties: Environmental Assessment Practitioner and Project Manager Value of Project: R 250 000

Location: Limpopo, South Africa Project duration & year: Two months, 2011 Client: De Beers Name of Project: Venetia Project Description: Undertaking of the necessary environmental authorizations for the amendment to the existing EMP in accordance with the MPRDA and NEMA Job Title and Duties: Environmental Scientist assisting with the compilation of the Scoping and EIA reports. Value of Project: R 1 million

Project duration & year: Six months, 2011 Client: Anglo American Inyosi Coal Name of Project: Kriel Colliery EMPR Amendment for Block F Project Description: Environmental Impact Assessment and Environmental Management Programme for the proposed mining activities to take place within Block F on Kriel Colliery in Mpumalanga. Job Title and Duties: Environmental Scientist responsible for the coordination of the public participation component of the EIA/EMP; coordination of specialists; discussions with stakeholders and authorities; Compilation of the NEMA and NEMWA application forms; Compilation of the scoping and EIA/EMP report according to the MPRDA and NEMA requirements. Value of Project: R 1 million

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Key Experience: Environmental permitting

Location: Mpumalanga, South Africa Project duration & year: Six months, 2011 Client: Anglo American Inyosi Coal Name of Project: Kriel Colliery EMPR Amendment for the Open Cast Operations Project Description: Environmental Impact Assessment and Environmental Management Programme for the proposed Open Cast mining activities to take place on Kriel Colliery in Mpumalanga. Job Title and Duties: Environmental Scientist Responsible for the coordination of the public participation component of the EIA/EMP; coordination of specialists; discussions with stakeholders and authorities; Compilation of the NEMA and NEMWA application forms; Compilation of the scoping and EIA/EMP report according to the MPRDA and NEMA requirements. Value of Project: R 1 million

Location: Mpumalanga, South Africa Project duration & year: Six months, 2011 Client: Anglo Coal Name of Project: Kleinkopje EMPR Alignments Project Description: Alignment of the existing approved EMPR documents according to a mine- specific directive sent to the Colliery by Mpumalanga DMR. Job Title and Duties: Environmental Scientist responsible for proposal preparation, client liaison, compilation of the Consolidation report. Value of Project: R 100 000

Location: Mpumalanga, South Africa Project duration & year: 1 year, 2009-2010 Client: Anglo Inyosi Coal Name of Project: Kriel Colliery EMPR Amendment Project Description: Consolidation of existing approved EMPRs and additional EMPR amendments. Job Title and Duties: Environmental Scientist assisting with project Coordination. Assistance with the compilation of the consolidated document Value of Project: R 150 000

Location: Limpopo, South Africa Project duration & year: 1 year, 2009-2010 Client: Messina Platinum Mines Limited Name of Project: Baobab Mining Operation Project Description: Environmental Impact Assessment and Environmental Management Programme for the proposed mining activities to take place on Baobab mine near Lebowakgomo in Limpopo Job Title and Duties: Responsible for the coordination of the public participation component of the EIA/EMP; coordination of specialists; discussions with stakeholders and authorities; compilation of the scoping and EIA/EMP report according to the MPRDA and NEMA requirements. Value of Project: R 1.5 million

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Key Experience: Environmental permitting

Location: Limpopo, South Africa Project duration & year: 1 year, 2009-2010 Client: Messina Platinum Mines Limited Name of Project: Doornvlei Mining Operation Project Description: Environmental Impact Assessment and Environmental Management Programme for the proposed mining activities to take place on Doornvlei mine near Lebowakgomo in Limpopo Job Title and Duties: Responsible for the coordination of the public participation component of the EIA/EMP; coordination of specialists; discussions with stakeholders and authorities; compilation of the scoping and EIA/EMP report according to the MPRDA and NEMA requirements. Value of Project: R 1.5 million

Location: Mpumalanga, South Africa Project duration & year: Three months, 2009 Client: BHP Billiton Energy Coal South Africa Name of Project: Klipspruit Project Description: Consolidation of the three existing EMPRs for the Klipspruit Colliery into a single document as per the directive issued by the DMR. Job Title and Duties: Environmental Scientist Value of Project: R 200 000

Location: Mpumalanga, South Africa Project duration & year: Four months, 2009 Client: Samancor Chrome Name of Project: Samancor Chrome energy recovery project, Witbank, Middelburg and Steelpoort Project Description: Preparation of three separate Environmental Impact Assessments for the installation of two new furnaces at Ferrometals in Witbank, Middelburg Ferrochrome and at Tubatse Ferrochrome. Job Title and Duties: Environmental Scientist assisting the environmental project manager Value of Project: R 200 000

Location: Limpopo, South Africa Project duration & year: Five months, 2008 Client: Messina Platinum Mines Limited Name of Project: Dwaalkop Mining Operation Project Description: Environmental Impact Assessment and Environmental Management Programme for the proposed mining activities to take place on Dwaalkop mine near Lebowakgomo in Limpopo Job Title and Duties: Responsible for the coordination of the public participation component of the EIA/EMP; coordination of specialists; discussions with stakeholders and authorities; compilation of the EIA/EMP report according to the MPRDA requirements. Value of Project: R 900 000

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Key Experience: Environmental permitting

Location: DRC Project duration & year: Eight months, 2008 Client: International Barytex Resources Name of Project: Shituru Copper Project Environmental and Social Impact Assessment Project Description: Compilation of the Environmental and Social Impacts Assessment and the Environmental and Social Management Plan for Shituru Copper mine in the DRC. Job Title and Duties: Environmental Scientist: responsible for client liaison, reporting to the project team in Canada, coordination of specialist studies and reports, compilation of the ESIA, ESMP and Annex IV Report (according to the DRC regulations) Value of Project: R 2 million

Location: Mpumalanga, South Africa Project duration & year: Six months, 2008 Client: Petroline Holdings (Pty) Ltd Name of Project: Petroline Petroleum Pipeline Project Project Description: Environmental Impact Assessment of the South African component to construct and operate a petroleum pipeline between Matola in Mozambique and Kendal in Mpumalanga, South Africa Job Title and Duties: Environmental Scientist: assisted with the report compilation for the Pipeline EIA/EMP report Value of Project: R 2 million

Project duration & year: Eight months, 2008 Client: Sasol Oil (Pty) Ltd Name of Project: Sasol Alrode Basic Assessment Project Description: Basic Assessment for the installation of a new Keropur storage tank at the Sasol Alrode Depot. Job Title and Duties: Project coordinator responsible for data collection, public participation (including liaison with the relevant authorities), client liaison and the basic assessment report compilation Value of Project: R 100 000

Location: North West Province, South Africa Project duration & year: Current Client: Anglo American Platinum - Rustenburg Platinum Mine Retained Operations Name of Project: Environmental Audit and Performance Assessment for the RPM Retained Operations Project Description: Audit of the consolidated Environmental Management Programme Report for submission to the authorities Job Title and Duties: Project Manager responsible for team coordination and report compilation Value of Project: R 70 000 in fees

Location: Gauteng, South Africa Project duration & year: 2020 Client: Nampak Name of Project: Phase 1 Environmental Audit conducted for an industrial property located in the Germiston area of Johannesburg Project Description: Project manager Value of Project: R 50 000 Job Title and Duties: Project manager and auditor

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Key Experience: Environmental permitting

Location: Gauteng, South Africa Project duration & year: 2019 Client: Blend Property Group Name of Project: Phase 1 Environmental Audit conducted for an industrial property located in the Germiston area of Johannesburg Project Description: Project manager Value of Project: R 27 000 Job Title and Duties: Project manager and auditor

Location: Gauteng, South Africa Project duration & year: 1 month, 2018 Client: Shaw Almex Name of Project: Phase 1 Environmental Audit Project Description: Phase 1 Environmental Audit conducted for an industrial property located in the Lea Glen area of Johannesburg Job Title and Duties: Project manager Value of Project: R 26 000

Project duration & year: 1 month, 2018 Client: Valbruna Steel Name of Project: Phase 1 Environmental Audit Project Description: Phase 1 Environmental Audit conducted for an industrial property located in the Modderfontein area of Johannesburg Job Title and Duties: Project manager Value of Project: R 17 000

Key Experience: Environmental due diligence/competent persons reporting

Location: Mpumalanga, South Africa Project duration & year: 2019-current Client: Webber Wentzel Name of Project: Project Armstrong Competent Persons Reporting of various coal assets situated in Mpumalanga Province Project Description: Technical advisory services, including environmental advisory. Due to the confidential nature of the work, the details cannot be disclosed. Job Title and Duties: Environmental Specialist/advisor responsible for the environmental compliance review and inputs to the Competent Persons Report for each asset Value of Project: Confidential

Location: Mpumalanga and Limpopo, South Africa Project duration & year: 2018-2019 Client: Confidential Name of Project: Environmental and Social Competent Persons review Project Description: Review of environmental and social issues, risks and liabilities associated with one platinum asset and two gold assets for a stock exchange. Job Title and Duties: Environmental reviewer responsible for the environmental compliance review and inputs to the Competent Persons Report Value of Project: Confidential

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Key Experience: Environmental due diligence/competent persons reporting

Location: Mpumalanga, South Africa Project duration & year: Six weeks, 2018 Client: Goldman Sachs Name of Project: Goldman Sachs Due Diligence three coal assets in Mpumalanga Province Project Description: Technical advisory services, including environmental advisory. Due to the confidential nature of the work, the details cannot be disclosed. Job Title and Duties: Environmental Advisor responsible for the environmental compliance review, closure cost review and input to the due diligence report Value of Project: Confidential

Project duration & year: Six weeks, 2018 Client: Industrial Development Corporation Name of Project: Due Diligence of a Phosphate mine and plant. Project Description: Technical advisory services, including environmental advisory. Due to the confidential nature of the work, the details cannot be disclosed. Job Title and Duties: Environmental Advisor responsible for the environmental compliance review, closure cost review and inputs to the due diligence report Value of Project: Confidential

Location: Mpumalanga, South Africa Project duration & year: Six weeks, 2017 Client: Standard Bank Name of Project: Project Libra Due Diligence of three coal mines situated in Mpumalanga Province Project Description: Technical advisory services, including environmental advisory. Due to the confidential nature of the work, the details cannot be disclosed. Job Title and Duties: Environmental Advisor responsible for the environmental compliance review, closure cost review and input to the due diligence report Value of Project: Confidential

Key Experience: Strategic environmental reporting and Advisory

Location: DRC and South Africa Project duration & year: 2019 - current Client: Ivanhoe Mines Ltd Name of Project: Scoping and Implementation Support for Ivanhoe Group’s Environmental System Project Description: To provide environmental system scoping and implementation support to the site-based environmental and technical teams at Platreef, Kamoa-Kakula and Kipushi (otherwise known as ‘the Group’). The objective of this project is to assist Ivanhoe with Group-wide standardisation and alignment of environmental reporting methodology and documents; in preparation for the implementation of the IsoMetrix 4 integrated risk management software Job Title and Duties: Project Manager responsible to team coordination, report compilation and client engagement Value of Project: R 600 000 in fees

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Key Experience: Strategic environmental reporting and Advisory

Location: DRC and South Africa Project duration & year: 2018 and 2019 Client: Ivanhoe Mines Ltd Name of Project: Environmental Management Gap Analysis Group Level 2019 Project Description: Gap analysis assessment of the current environmental management and monitoring processes taking place at three of Ivanhoe’s project sites. The overall aim of the exercise was to identify what environmental management gaps exist in each project in terms of environmental monitoring and management, water stewardship reporting and greenhouse gas emissions reporting. The findings of the gap analysis were used to make practical recommendations on how to effectivity fill the identified gaps. In addition, environmental management and monitoring were compared between the three projects to determine where alignment was needed across the operations to prepare for full audit verification of the environmental data in Ivanhoe’s 2020 sustainability report. Job Title and Duties: Project Manager responsible to team coordination, report compilation and client engagement Value of Project: R 400 000 in fees

Location: Uganda Project duration & year: 2019 Client: United Nations Development Programme Name of Project: Uganda Department of Environmental Sector Support Services Strategic Plan Project Description: Uganda has enjoyed an exponential socio-economic transformation over the past two decades due to political stability and support from developing partners and the Ugandan people. Rapid economic growth has, however, had a negative impact on the environment to such an extent that environmental degradation has resulted in a recent decline of this economic growth. The environmental degradation and pollution can be attributed to inadequate environmental governance. While Uganda does have strong environmental institutions in place, as well as good policies, plans and environmental legislation, a lack of funding and resources (including staff) to implement these policies and laws has compromised environmental governance. Therefore, more comprehensive interventions with long-term objectives are required which will guide coordination of the efforts in the environmental sector. To assist in meeting this requirement, SRK and a local Ugandan partner were appointed by the United Nations Development Programme in 2018 to compile a strategic environmental plan for the Ugandan government to guide environment and natural resource management for the next ten years. Job Title and Duties: Project Manager Value of Project: R 400 000 m in environmental fees

Mara/Omar SRKZA_JNB_MaritzA_Oct_2020.docx_QR October 2020 SRK Consulting Page 10 Ashleigh Maritz Senior Scientist

Key Experience: Strategic environmental reporting and Advisory

Location: SADC Member States Project duration & year: 2020 Client: SADC-GMI Name of Project: Southern African Development Community – Lessons Learnt Project Project Description: The Southern African Development Community Groundwater Institute (SADC- GMI) has embarked on a process to capture lessons learned from the World Bank Funded “Sustainable Groundwater Management in SADC Member States project”, which is scheduled to end on the 31st of December 2020 and to develop a new regional groundwater programme. The objectives of the SADC-GMI Lessons Learned Project (LLP) are to firstly develop a background document on the emerging issues and lessons learned from implementation of the Sustainable Groundwater Management (SGM) in SADC Member States Project; and secondly, develop a ten-year (split into two five- year periods) bankable project proposal document for the implementation of a new SADC groundwater programme from 2021. Value of Project: R 1 500 000 in environmental fees

Location: Malawi, Lesotho, Mozambique, Tanzania, Zambia, Eswatini, Angola, DRC, Zimbabwe and South Africa Project duration & year: 2018 – ongoing Client: SADC-GMI Name of Project: SADC-GMI Environmental and Social Safeguard Support Project Project Description: Environmental and Social safeguards review of projects submitted by several SADC member states as part of the SADC Sustainable Groundwater Management Project. Job Title and Duties: Environmental Safeguards specialist Value of Project: R 2 million in environmental fees

Key Experience Environmental Management and Advisory

Location: Polokwane, Limpopo Province, South Africa Project duration & year: 2017 – 2018 Client: Anglo American Platinum Name of Project: SO2 Abatement Plant at Polokwane Smelter Project Description: Management of an external environmental consultant of behalf of Hatch Africa and management of the Environmental Control Officer for the construction phase. The SO2 Abatement Plant was required for the Polokwane Smelter in order to assist the smelter in meeting the 2020 minimum emissions standards in terms of the National Air Quality Management Act. Job Title and Duties: Environmental Manager responsible for managing an external Environmental Assessment Practitioner, managing the ECO during construction, tender evaluation of contractor’s and assistance to the Hatch engineering team during the feasibility and construction phases. Value of Project: R 2 million in environmental fees

Location: Norway Project duration & year: 6 months, 2018 Client: Nordic Mining Name of Project: Engebø Rutile and Garnet Project Project Description: Pre-feasibility and feasibility studies for the proposal rutile and garnet mine in Norway. Job Title and Duties: Environmental advisor responsible for compiling the environmental design criteria to inform the engineering design for the feasibility phase. Value of Project: R 280 000 in environmental fees

Mara/Omar SRKZA_JNB_MaritzA_Oct_2020.docx_QR October 2020 SRK Consulting Page 11 Ashleigh Maritz Senior Scientist

Key Experience Environmental Management and Advisory

Project duration & year: Three years, 2015-2018 Client: Zimbabwe Power Company Name of Project: Hwange Transmission Work Expansion Project Project Description: The Project entails the proposed expansion of the generating capacity of the Hwange thermal power and Kariba hydropower stations to meet the country’s energy demand. A network study undertaken by Hatch Africa (Project Owner’s engineers) identified a number of transmission routes in the national grid that would require upgrading for greater capacity or the installation of new transmission lines. In addition to this, there will also be extensive substation work. The main components of the project included the Hwange-Insukamini (Bulawayo) new 400 kV transmission line, new Hwange sub-station and Insukamini sub-station upgrade; Insukamini-Marvel new 330 kV transmission line and Marvel sub-station upgrade and new Sherwood sub-station, near Kwekwe. Job Title and Duties: Environmental Advisor – management of the local environmental consultant and review of the Environmental and Social Impact Assessment process and reports to IFC/World Bank standards. Value of Project: Confidential

Location: Gauteng Province, South Africa Project duration & year: Two years, 2016-2017 Client: Gauteng Department of Economic Development Name of Project: Gauteng Industrialisation Project – Furniture Manufacturing Hub Project Description: Development of a business case to detail the development of a furniture manufacturing hub in the Roodepoort Industrial area of Johannesburg. The aim of the project was to determine what would be required in order to revitalise the furniture manufacturing industry in Gauteng. Job Title and Duties: Project Manager and study coordinator Value of Project: R225 000

Location: Mpumalanga, South Africa Project duration & year: Two years, 2016-2017 Client: Eskom Name of Project: Eskom Majuba Rail Project Project Description: Environmental compliance for the duration of the construction of the railway line. The contract included but was not limited to ensuring that contractors complied with all relevant health and safety and environmental legislation, EMP requirements, Eskom procedures and protocols and the project schedule. Responsibilities also included application for borrow pit closures, developing and implementing the water sampling requirements for the project, ongoing awareness training and reporting incidents. Job Title and Duties: Environmental Manager responsible for managing the environmental control officer and contractors ECOs on site Value of Project: R 2 million

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Key Experience Environmental Management and Advisory

Project duration & year: Two years, 2015-2017 Client: Eramet South Africa Name of Project: Mukulu Manganese Mine Project Description: Pre-feasibility and feasibility study for the development of a proposed manganese mine, associated rail siding and relocation of Eskom transmission lines near Hotazel in the Northern Cape. The exact details cannot be disclosed due to the project being confidential in nature. The project involved extensive stakeholder engagement, a rail route options analysis (including environmental sensitivity analysis of the various scenarios) as a component of several environmental authorisation processes which were conducted Job Title and Duties: Environmental Advisor responsible for managing the Environmental Assessment Practitioner (GCS) and providing an interface role between the EAP and the engineering team Value of Project: R1.3 million

Location: Northern Cape, South Africa Project duration & year: One year, 2014-2015 Client: Assmang Name of Project: King TFR Mainline Deviation Project Project Description: Review, auditing and signoff of external contractor's audits and management of the Environmental Officer on site for the rail deviation. Job Title and Duties: Environmental Manager responsible for managing the environmental control officer and contractors ECOs on site Value of Project: R 250 000

Location: Eastern Cape, South Africa Project duration & year: Six months, 2015 Client: Municipal Infrastructure Support Agent Name of Project: Nxuba waste management project Project Description: The environmental scope included reviewing and updating the Nxuba Municipality's Integrated Waste Management Plan (IWMP), developing a Status Quo report for the Bedford and Adelaide Waste management sites and compiling a 10-year waste master plan for the Nxuba Municipality. Job Title and Duties: Environmental Advisor responsible for the IWMP update Value of Project: R 200 000

Location: Mpumalanga, South Africa Project duration & year: Six months, 2013 Client: Eskom Holdings SOC Limited Name of Project: Kendal Power Station Integrated Access Control Project Project Description: The project involved the design of an integrated access control system at the main gate of Kendal Power Station. The environmental tasks were limited to the Concept phase of the project and included Environmental sensitivity screening, a preliminary environmental risk assessment as well as a preliminary permitting strategy and Environmental Design Criteria. Job Title and Duties: Environmental Advisor Value of Project: R 100 000

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Key Experience Environmental Management and Advisory

Project duration & year: Two years, 2011-2013 Client: Transnet Name of Project: 16Mtpa Manganese Line expansion project Project Description: Assistance with management of the Environmental Assessment Practitioners conducting the Authorisation Processes for the Rail upgrade, construction of the compilation yard and the development of a manganese export facility within the Coega IDZ. Also carried out the permitting process for numerous borrow pits required along the line in both the Northern Cape and Eastern Cape. Job Title and Duties: Environmental Advisor and project coordinator Value of Project: R1.3 million

Location: South Africa and Mozambique Project duration & year: Six months, 2012 Client: Industrial Development Corporation Name of Project: Masorini Advanced Work for Feasibility Project Description: Project involved environmental input at three locations - two locations being South African based and the other based in Mozambique for the Advanced Work for Feasibility Phase (equated to a phase between Concept and Pre- feasibility). The exact details cannot be disclosed due to the project being confidential in nature. Job Title and Duties: Environmental Advisor Value of Project: R 300 000

Location: Inhambane, Mozambique Project duration & year: Two years, 2011-2012 Client: Rio Tinto Iron and Titanium Name of Project: Mutamba Project Description: This project entails environmental input for three export options and two mining site options within the province of Inhambane in Mozambique. Duties included managing the environmental baseline studies for the pre-feasibility stage together with the Environmental Impact Assessment for the feasibility stage. In addition to this, duties included consultation with the Mozambican authorities as well as the management of the in-country registered consultant (Impacto) who will be carrying out most of the Social related studies. Job Title and Duties: Environmental Advisor Value of Project: R1.3 million

Project duration & year: 16 months, 2009 Client: Chapudi Coal (Pty) Ltd and Kwezi Mining Exploration (Pty) Ltd Name of Project: Chapudi Coal Environmental Baseline Assessment Project Description: Baseline assessment for the proposed Chapudi Coal mine situated at the foot of the Soutpansberg Mountains near Waterpoort in Limpopo. Job Title and Duties: Environmental Scientist responsible for client liaison, proposal preparation, project progress presentations and reporting to the project team, coordination of specialist studies and reports, compilation of the baseline assessment reports. Value of Project: R 1 million

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Key Experience Climate assessment and management

Location: Eastern Cape, South Africa Project duration & year: Current Client: Eastern Cape Department of Economic Development, Environmental Affairs and Tourism (DEDEAT) Name of Project: Mainstreaming Climate Change aspects into Five Department of Economic Development, Environmental Affairs and Tourism Policies Project Description: Reviewing and mainstreaming climate change aspects into selected DEDEAT Policies / Plans. Job Title and Duties: Specialist responsible for the research and compilation of the various reporting deliverables together with other members of the SRK research team Value of Project: R 200 000 in fees

Location: Mpumalanga, South Africa Project duration & year: Current Client: Anglo American Coal Name of Project: SACE Lifex Project Description: Climate assessment for the SACE Lifex Project in support of the pre-feasibility studies and in compliance to the IDM Job Title and Duties: Specialist responsible for the research and compilation of the climate assessment together with other SRK team members Value of Project: R 50 000 in fees

Location: DRC and South Africa Project duration & year: 2018-2019 Client: Ivanhoe Mines Ltd Name of Project: Environmental Management Gap Analysis Group Level 2019 Project Description: A review of the greenhouse gas (GHG) reporting across the three projects using information obtained from publicly availability documentation, information supplied by Ivanhoe and from the interviews conducted on site Job Title and Duties: Specialist responsible for the research and compilation of the report together with other team members Value of Project: R 400 000 in fees (entire reporting component)

Mara/Omar SRKZA_JNB_MaritzA_Oct_2020.docx_QR October 2020 Resume Kavilan Naidoo Environmental Scientist

Profession Environmental Scientist Education BSoc Sci, Geography and Environmental Management, University of Kwa Zulu Natal, 2013 Registrations/ None Affiliations Awards None

Specialisation Environmental impact assessment, monitoring and evaluation, environmental management programme, water use licence applications.

Expertise Kavilan Naidoo has been in the field of environmental science for the past 4 years. His expertise includes:

• project coordination and management of environmental impact assessments, environmental management programmes, water use licence applications; • compilation of technical environmental documents and reports; • environmental control officer duties; • environmental compliance audits.

Employment

2018 – present SRK Consulting (Pty) Ltd, Environmental Scientist, Johannesburg 2016 – 2017 KSEMS Environmental Consulting, Environmental Consultant/ECO, Durban 2015 – 2016 Hazrisk Consulting, Environmental Consultant, Durban 2014 – 2015 Green Grid Energy (Pty) Ltd, Junior Environmental Consultant/ESO

Publications None

Languages English – read, write, speak (Excellent)

Nkav/Omar SRKZA_JNB_NaidooK_Nov_2020.docx_QR November 2020 SRK Consulting Page 2 Kavilan Naidoo Environmental Scientist

Key Experience: Environmental management

Location: Democratic Republic of Congo Project duration & year: 8 Months 2018 - 2019 Client: R&H Rails Name of Project: Reinstatement of the Kipushi Railway Branch Line Project Description: Environmental Pre-feasibility Job Title and Duties: Environmental Assessment Practitioner Value of Project: n/a

Location: Limpopo Project duration & year: 12 Months 2018 - 2019 Client: Anglo American Platinum Name of Project: Mogalakwena Mine Expansion Project Project Description: Environmental Authorisations/Mining Job Title and Duties: Environmental Assessment Practitioner Value of Project: n/a

Location: Richards Bay Project duration & year: 6 months 2017 Client: Transnet Name of Project: Locomotive Diesel Facility Project Description: Railway/ EA Amendment & WULA Job Title and Duties: Project Manager & Lead Consultant Value of Project: n/a

Location: Durban South Project duration & year: 8 months 2017 Client: SANRAL Name of Project: R61 Borrow Pit Project Description: Mining/ Scoping & EIR Job Title and Duties: Project Manager & Lead Consultant Value of Project: n/a

Location: Durban North Project duration & year: 10 months 2017 Client: eThekwini Municipality Name of Project: Oakford Housing Development Project Description: Infrastructure/ Environmental Auditing Job Title and Duties: Environmental Control Officer Value of Project: n/a

Location: Durban North Project duration & year: 6 months 2017 Client: DoT Name of Project: P96 Road Upgrade Project Description: Environmental monitoring Job Title and Duties: Environmental Control Officer Value of Project: n/a

Nkav/Omar SRKZA_JNB_NaidooK_Nov_2020.docx_QR November 2020 SRK Consulting Page 3 Kavilan Naidoo Environmental Scientist

Key Experience: Environmental management

Location: Durban South Project duration & year: 12 months 2017 Client: DoT Name of Project: Umzimkulwana Bridge Project Description: Infrastructure/ WULA Job Title and Duties: Project Manager & Lead Consultant Value of Project: n/a

Location: Durban South Project duration & year: 12 months 2017 Client: DoT Name of Project: P197.3 Culverts Project Description: Infrastructure/ BAR & WULA Job Title and Duties: Project Manager/ Lead Consultant Value of Project: n/a

Location: Durban South Project duration & year: 6 months 2017 Client: Umbumbulu Municipality Name of Project: Umbumbulu MR30 Road Upgrade Project Description: Infrastructure/ BAR & WULA Job Title and Duties: Project Manager/ Lead Consultant Value of Project: n/a

Location: Durban South Project duration & year: 8 months 2017 Client: Ndwedwe Municipality Name of Project: Mahedeni Bridge Project Description: Infrastructure/ BAR & WULA Job Title and Duties: Project Manager/Lead Consultant Value of Project: n/a

Location: Durban South Project duration & year: 10 months 2017 Client: DoT Name of Project: Mangwenya Bridge Project Description: Environmental monitoring Job Title and Duties: Environmental Control Officer Value of Project: n/a

Nkav/Omar SRKZA_JNB_NaidooK_Nov_2020.docx_QR November 2020 SRK Consulting Page 4 Kavilan Naidoo Environmental Scientist

Key Experience: Environmental management

Location: Durban South Project duration & year: 12 months 2017 Client: Private Name of Project: Scottburgh Petrol Filling Station Project Description: Petrol Station/ BAR & WULA Job Title and Duties: Project Manager & Lead Consultant Value of Project: n/a

Location: Newcastle Project duration & year: 6 months 2016 Client: DoT Name of Project: P36-2 Road upgrade Project Description: Environmental monitoring Job Title and Duties: Environmental Control Officer Value of Project: n/a

Location: Estcourt Project duration & year: 12 months 2016 Client: DoT Name of Project: D1252 Road upgrade Project Description: Environmental monitoring Job Title and Duties: Environmental Control Officer Value of Project: n/a

Location: Hillcrest Durban Project duration & year: 4 months 2016 Client: Mr Price Name of Project: Mr Price Warehouse Development Project Description: Infrastructure/ Environmental monitoring Job Title and Duties: Environmental Control Officer Value of Project: n/a

Location: Durban Project duration & year: 4 months 2016 Client: DoT Name of Project: L2980 Road Upgrade Project Description: Infrastructure/ Basic Assessment & WULA Job Title and Duties: Project Manager & Lead Consultant Value of Project: n/a

Location: Harrismith Project duration & year: 18 months 2016 Client: SANRAL Name of Project: N5 Road Upgrade Project Description: Infrastructure/ Environmental Auditing Job Title and Duties: Environmental Control Officer Value of Project: n/a

Nkav/Omar SRKZA_JNB_NaidooK_Nov_2020.docx_QR November 2020 SRK Consulting Page 5 Kavilan Naidoo Environmental Scientist

Key Experience: Environmental management

Location: Durban South Project duration & year: 6 months 2016 Client: DoT Name of Project: P728 Borrow Pit Project Description: Mining/ Basic Assessment & WULA Job Title and Duties: Project Manager & Lead Consultant Value of Project: n/a

Location: Durban South Project duration & year: 6 months 2016 Client: DoT Name of Project: Baboyi Bridge Project Description: Infrastructure/ WULA Job Title and Duties: Project Manager & Lead Consultant Value of Project: n/a

Nkav/Omar SRKZA_JNB_NaidooK_Nov_2020.docx_QR November 2020 SRK Consulting: 558834: Rustenburg Process Operations: External Environmental Audit, undertaken during August 2020 Page 23

Appendix B: Pre-site audit meeting presentation with notes from the meeting

MARA/NKAV/LAKF 558834_RPM_EMPR_Final Reg 34 Audit Report_20201130 November 2020 RPM External EMPr Performance Assessment

Pre-site visit Discussion 22 July 2020 Agenda

01 08h00-08h15: Welcome, safety share and team check-in 02 08h15-09h00: General discussion: Compliance status of the Retained Operations 03 09h00-10h00: Waterval Smelter and ACP discussion 04 10h00-10h30: General overview of the Retained Operations 05 10h30-11h15: RBMP discussion 06 11h15-12h00: PMR discussion 07 12h00-12h30: Meeting close-out 01 Welcome and Team check-in Safety share

RPM EMPR Audit pre-site visit Meeting July 2020 3 General Discussions for the Retained Operations

- Status quo of the operations and battery limits for audit

- Non-compliances noted as per previous EMPr audit (WSP) 02 - Questions based on general EMPr commitments Status quo and battery limits for the audit

Operation Activity Area Comment Smelters Waterval Smelter Included in the EMPr PAR (operational) ACP Included in the EMPr PAR Refineries Rustenburg Base Metals Included in the EMPr PAR Refinery (operational) Precious Metals Refinery Included in the EMPr PAR (operational) Distribution Center Western Limb Distribution Dustin to confirm: It is a warehouse where some of the raw materials are kept. It Center supplies some of the materials used in the processing operations. Dustin would like for us to include this. He mentioned it is not necessary to conduct a site visit here, just look through the conditions. MS comment: Used to be part of the Care and Maintenance Frank Concentrator concentrator and now under ACP. They want (Decommissioned) to demolish this but it has been going on for years. Pilot plant is part of the Frank Concentrator which is operational. Decommissioning was supposed to commence in April however due to Covid this hasn’t go off the ground.

RPM EMPR Audit pre-site visit Meeting July 2020 5 Status of non-compliances identified from previous EMPr PAR (WSP 2019)

Dustin general comment: They are going to be conducting an EMPr amendment to amend all conditions which are not practical as part of the consolidated EMPr.

Commitment Previous auditor comment SRK/RPM comment

EMP audits will be done every 2 years by an external The previous external audit was completed by WSP in 2017 External audits conducted for 2019 by WSP (one for DMR auditor and internally every year. and meets the requirement in terms of this submission and one for NWREAD submission? condition. No evidence of internal audits being undertaken in 2017 or 2018 were provided to the auditor. To date no No proof of internal EMP audits received by SRK. Are there measures have been implemented to rectify the internal any? SD: EMPr internal audit was conducted in May 2020, audits not being undertaken. Annually internal auditing is there is a report for this internal audit. In terms of other considered feasible and practical to be undertaken by RPM. audits there is an internal audit for the WUL and internal ISO14001 audits. They are busy trying to move over to ISO14001:2015. The first stage of this audit has been conducted and the second stage will be conducted in August 2020. ISO14001: this is a site specific audit EMPr: Look at the commitments for every single site WUL audit: Similar approach but all contribute to this in a single meeting. Create awareness regarding the important role the riparian Quarterly awareness campaigns and onsite awareness Proof of the riparian zone talk (March 2020) provided to zone play in stabilising the riverbank, as a viable habitat and campaigns are undertaken with a range of environmental SRK from Waterval Smelter. When is this presented and is natural corridor; address the issue of clearing the riparian topics covered (the latest observed was regarding correct this included in community awareness talks etc for the zone and the law. waste management) - none are related specifically to the retained operations? riparian zone. SRK has received this for Watervaal Smelter where this was The environmental team plan to include the topic in part of the talk topic for the month. It is distributed to all upcoming community programmes. departments within the operations. SD also visited all of the areas and explained this to everyone. There is no plan to include this in community awareness talks. NK stated that in the EMPr amendment, this condition should be removed as it is more relevant to the Sibanya side and not relevant to the operation. Monitoring of the soil during the operational phase must No soil monitoring was undertaken at the Smelter, BMR, or Not considered practical – recommended that this takes occur on a bi-annual basis to determine if further ACP during this audit period. place every two years. contamination is occurring due to Retained Operations Agreenco undertook sampling at PMR (ten samples). A SRK require the report compiled by Agreenco. These needs activities. report has been is compiled but was not provided to the to be included in the EMPr amendment. NK confirmed this auditor. An amendment to reduce the frequency of needs to be amended. In the PMR EMPr (before it was monitoring may be applied for in consultation with the consolidated) states that it needs to be done every two Department, as the majority of the sites are hard surfaced years whereas in the general conditions it states it needs to and within managed areas. be done twice a year, this is causing confusion. SD: There was an amendment process done on this specific item and this is still in progress, SD stated that all of the papers for this specific condition have been sent to the authorities but it is still in progress. SD will check when this was submitted, and he will send the proof. Members of the public to be invited for site visits to the An invitation is not extended to local leadership however, no Not considered practical due to health and safety Retained Operations (six monthly requests to visit the sites has been received, based on the concerns. RPMbasis). EMPR Audit pre-site visit Meeting auditors knowledge. There have beenJuly no 2020 requests to visit the site. SD mentioned 6 that this Questions

1. Confirmation of types of internal and external audits conducted Confirmed in Slide 1

2. Any new developments planned, or any new developments occurred since the last audit? New developments planned: BS: Construction planned for August of the copper debottlenecking plant at RBMR. It will be ringfenced and will be completed in 2021. BS confirmed that this plant did not require environmental authorisation. They did involve NWDEDECT and they visited the site and they have received written documentation that no authorisation will be required. These is also a plan to relocate the taxi drop off area located near to the entrance of the RBMR footprint. The purpose is to limit the interaction of pedestrians and mobile vehicles. Also a proposed relocation of the bulk acid storage tanks (SRK has been appointed to conduct this, the application had not been submitted at the time of this discussion). As part of the preapplication meeting, they want to ask if they can treat this as an emergency process and if they can commence with construction prior to commencing with authorisation. This will only commence in 2022. DV: Recovered concentrate storage shed to be constructed to the north of Waterval Smelter, applications are ongoing. To be located between Frank Concentrator and the Watervaal tailings facility. Purpose of this is as they clean and desilt dams from the process operations, to take this material to the shed before it is reprocessed through a smelter facility. MS: Debottlenecking project and slag furnace cleaning 2 is planned for Smelter (still in PFS A and B). ACP debottlenecking is planned only once Mogalakwena concentrators have been expanded. Slag cleaning furbace 2 (still looking at four different options), very early phases, have not started with applications or anything like that. A few tempory structures between RBMR and 3B PCD dam to assist with desilting. They have received a letter from NWDEDECT that they can continue with this without any formal applications. They did not require any amendments, RO plant planned at RBMR (SRK has been appointed for this) but this is placed on hold for now as they are not sure if the there are listed activities associated with this as the purpose of this plant is to treat potable water before being fed into the boilers to prevent scaling. NWDEDECT has sent the request to national office so waiting for feedback. NK: Plans to reline dams and PMR next year (documentation has been sent). Will remove the solids before they do this.

Any taken place since the last audit: None

3. Any disturbances taken place within sensitive areas? None

4. Status of Frank Concentrator Decommissioning – mentioned in the 2019 audit that there are currently community issues holding this up but this will be solved through a tender process Discussed in slide 1.

5. Any rehabilitation activities taken place since 2019 audit? None. One of the biggest concerns at this stage are the wax and slag stockpiles located to the north of Watervaal Smelter. There is a detailed long-term plan for this. BS: ongoing rehabilitation project going on at ENS, experimental phases. Section at the effluent and sodium plant where they are running a trial for rehabilitation. Appointed Agreenco for this and they are running a trial for a year to establish what plant species can survive and absorb the sodium sulphate in that area. If not successful they will try another method.

6. Topsoil – understanding that there are no topsoil stockpiles available for rehab. Material will need to be bought in. Correct

7. Status: The contractor's area at BMR is being relocated within the BMR boundary; the area was being cleared at the time of the audit - it is within the operations boundary and will be used as a laydown area in the interim. No rehabilitation is planned at this stage. This is where the copper debottlenecking plant. They have been relocated to another contractor laydown area.

8. Based on the contents of the water quality report, all these determinants are monitored except for bacteria (i.e. fecal coliforms). Monitoring is done in accordance to the WUL issued for the operations and is deemed to supersede this condition. It is advised that this condition be aligned with the WUL monitoring requirements by means of an amendment application – is there a plan to amend the WUL? DV: Following the divestment of the mines to Sibanya, a new WUL was issued to the Retained Operations but there were a lot of errors within this WUL, there are still uses that were supposed to be divested to Sibayne and vise versa. Amendments has been submitted (2018/2019) to DWS and still waiting for approval of the new licences. DV has sent the list of amendments to Ashleigh.

9. The collection and sale of firewood must be discouraged. This commitment does not appear in the site induction or appear in any form of training manual for the operations. Not relevant and needs to be removed. Ashleigh to add to the list of conditions not relevant.

10. Status: An AQMP is in place for the Rustenburg Section operations. The plan is being adapted to suite the revised RPM structure (i.e. following the sale of mining operations to Sibanye).SRK have not seen this document. DV suggested they provide us with. Waterval Smelter have applied for postponing and as part of this postponed they need to implement offset project. Busy with the baseline establishment in the host communities. Plan has been submitted to DEFF for approval and no approval has been received as of yet.

11. Confirmation on site Waste Management: Have contracted Riverside for all waste management. Wastes which cannot be recycled are transferred to the Rustenburg Local Municipality (RLM) Landfill site (general waste) or at the Interwaste hazardous waste disposal site. Still using Riverside for all sites for water management. Interwaste is assisting with the waste which needs to be recycled and cannot be sent to the landfill site. They are trying to limit waste to landfill. Drive to zero waste to landfill. 7 12. Any planned retrenchments? None planned

13 Still applicable: Nava Narain is the allocated CED manager responsible for carrying out the objectives of the Anglo social strategy Nava is assisted by community development officers 03 Waterval Smelter and ACP - Overview of key issues - Non-compliances noted as per previous EMPr audit (WSP) General notes Waterval: Waterval is a processing plant and has different activities within the smelter which are interlinked with ACP. Drying and smelting the concentrate. Emissions are issues but they have a licence to guide the monitoring system based on the conmitments within the licence. Generate waste within the plant but doing sorting and recycling. Generate both hazardous and general waste but Mixed slag: nothing happening here. Some of this is sent direct to Blastright. This is the highest conduct monitoring, handling and storage of this but this is a challenge in the plant specifically if they heap of them all. Survey happening monthly around this area to assess what stockpiles are are faced with a new waste. ACP and Waterval share one target of waste. Use water within the smelter priorities for reprocessing. but have a WUL for this and it guides them in terms of what needs to be monitoring. Targets based on water use. Issues include spillages around the plant but due to different reasons but attended to as and when it happents. Have biodiversity within the fenced and outside areas. Footprint is so small so not much in terms of biodiversity but the do monitor vegetation. Have stockpiles issues where they have issues (Dustin mentioned this previously). Memo was drafted for the specific stockpile area which are the specific actions which were drafted. Simon will share this memo. Some of these activities are long term objectives and are interlinked with ACP. Majority of slag goes through ACP. Concentrate (new concentrate) sent to the plant for reprocessing.

Works which are busy being reprocessed back to the plant

Smelter dam (part of Sibanya). Sump area belongs to Waterval (as it enters this dam), they are busy cleaning this sump ACP: Matt coming from Waterval is processed at the converter and the slag is reprocessed at the furnaces and then the matt from the converter goes to RBMR. The acid plants treats the gas from the converter. Contact plant treats gas from the converter at ACP and tower plant treats the gas from Waterval smelter furnaces. Explosion in February and plant was restarted in May. Acid is sold into the market. Have a WUL and AEL for ACP. Environmental incidents: none related to the explosion but with start up they got a complaint from a lady in Kroondal (you could see the emissions from the main stack) but this was addressed with the lady. This was reported to the Boginana municipality.

RPM EMPR Audit pre-site visit Meeting July 2020 9 Status of non-compliances identified from previous EMPr PAR (WSP 2019) Commitment Previous auditor comment RPM comment A flora health risk assessment will also be performed in the area in A flora health specific assessment has not been completed; only This condition is not considered practical as the site has been order to establish if any contamination or stress factors that can the Invasive Alien Plant Study in 2015 by Agreenco. transformed. MS and SD agree this needs to be removed. MS negatively influence the growth of vegetation exist. Although technically non-compliant, due to the transformed nature confirmed that Agreenco order has been raised to do an of the site and the ongoing alien plant control, it is recommended assessment of this however after this assessment it would be that this condition be removed by means of an amendment process better to remove this commitment as most of the area has no in consultation with the Department. plants or vegetation, the assessment will be used to confirm this in montivation to remove this condition. Fauna assessments will be implemented according to the regional A fauna assessment has not been undertaken. This condition is not This condition is not considered practical as the site has been BAP. considered practical as the site has been transformed transformed. This area is used to store silica which is used in the process. They stared to put coal here as well but MS said they are looking at alternative areas. They put it here to have availability. The coal is used by Smelter and ACP. It was a convienent spot and it is still happening. Limiting further habitat destruction, especially in previously The RPM – RS processing operations have been in place since Status of this? undisturbed areas. 1998 (BMR), 1999 (PMR), 2000 (Smelter) and 2001 (ACP). Since establishment, numerous projects have taken place, which have been approved (through various licence amendments/ variation processes). The remainder of the activities are usually limited to the fence line of each operation. However, the auditor noted an area north of the ACP plant, which was disturbed due to the need for additional storage space since the sale of the Waterval Tailings Storage Facility (TSF) to SRPM. The land is currently used for stockpiled slag material as well as haulage roads. The vegetation existing prior to the storage activities is almost completely covered and compacted. This issue was reported in the 2017 WSP audit report. At the time of the audit it could not be confirmed whether the site is situated within the approved Mine Plan. The topography of the site will be regularly inspected for signs of The slag stockpiling to the north of the complex showed signs of Need to confirm this when on site – Fran did you see this area? erosion, ponding, unauthorised dumping and general misuse. erosion and ponding; in addition, the auditors did not observe controls to prevent unauthorised dumping. Dam safety inspections will be undertaken regularly to safeguard Based on verbal communication with the environmental team, an MS spoke to Jan Slabbert and he mentioned that that dam does not against failure. Copies of the report will be kept on file at the external engineer inspects the dams from a safety perspective once require a safety inspection as it does not fall within this category Smelter. every five years. No reports or proof was provided to the (James confirms that the ACP does not trigger this). Jan does a auditor. dam inspection once a year and they have reports for this. This commitment needs to be removed as it is not necessary to do a safety assessment. PMR dams (4 and 5) fall under this safety risk. Simon sent information thorugh. The real-time monitoring of flows and electrical conductivity (EC) Real time monitoring is only provided for the flow volumes. RPM Monthly monitoring is undertaken and and pH in the Klipfontein Spruit will be undertaken upstream, does not conduct real-time monitoring of EC and pH in the real time monitoring of EC and pH is not considered practical opposite and downstream of the Smelter. Compliance with the Klipfonteinspruit. Exceedances have not occurred. MS and SD agreed Water Permits will be monitored and exceedances will be investigated and reported. Monitoring of volumes and qualities of storm water inflows and No evidence was provided by RPM related to the monitoring of This condition is not considered practical discharges from the interception trench systems and the pollution volumes and qualities of stormwater inflows and discharges from for inflows but only discharges (which is control dam will be undertaken regularly. the interception trench systems and the PCDs. There are no not planned). There is a project underway which is manged by planned discharges. Tanya Rademeyer (Internal Anglo water specialist) to put in a flow meter where the water flows into the dam. MS got SHEP on site to assist with a monitor to put in the flow in the trenches but it silted up so much that it did not work. It is cleaned quite often but you still10 get instances where there is silt. There is still budget for next year. Suggested this is removed and there is the same condition in the Status of non-compliances identified from previous EMPr PAR (WSP 2019) continued…

Storm water management strategies will be updated to include Maintenance and cleaning of all storm water systems is not Same as previous comment – job card generated via SAP when the maintenance and cleaning of all storm water systems. referenced within any site procedure. Clean-up activities are it needs to be conducted. only carried out based on visual inspection on an ad hoc basis. The existing groundwater flow and solute transport models for Groundwater monitoring is conducted every quarter however the It is not considered practical to update the site will be updated quarterly using the monitoring groundwater model is not updated every quarter to align with the the groundwater model quarterly. MS did not know when the information quality recorded. groundwater model was updated however she has e-mails stating that it is impossible to updated groundwater quarterly from the groundwater specialist. Continued monitoring will be conducted on all the boreholes for 8 Although groundwater sampling is conducted quarterly, the It is not considered practical to update months of the year, and assessment of the groundwater model groundwater model is not updated quarterly or annually. the groundwater model quarterly. MS did not know when the will be undertaken annually for its incorporation in the annual groundwater model was updated however she has e-mails report to the DWS. stating that it is impossible to updated groundwater quarterly from the groundwater specialist. Extend the existing monitoring programme to include any new The slag stockpiling area is noted as a potential ‘extension’ Noise survey has been done, Simon sent Ashleigh the draft developments that may take place adjacent to the Smelter. however has not been incorporated into the monitoring program. report. It is incorporated in the schedule of noise surveying for The auditor notes that the road leading to the slag stockpiling occupational health and safety. area is travelled by large haulage trucks and is within a kilometre of the Bokamoso community. Noise issues may result warranting noise monitoring. The high noise levels generated at the oxygen plant (at ACP) will The area is incorporated into the occupational hygiene noise SRK has received the environmental noise survey report be investigated further and management plans formulated to assessments however no actions have been taken as yet to conducted by Phuka Tsa Nong in July 2020 for Waterval Smelter reduce these levels. reduce noise levels. (or for noise monitoring points located around ACP and Waterval). No evidence of management plans or mitigation measures in response to the noise impacts? Weekly maintenance must be conducted on the ceramic filters. Weekly maintenance must be conducted on the ceramic filters. It is not considered practical to undertake weekly maintenance. Maintenance is conducted on a ‘as and when’ basis. Simon has sent a weekly report and they look at this daily. This commitment is valid as the work is happening however it is an ongoing process, so change of the word ‘weekly’ to ‘ongoing’ A real-time air quality monitoring system will be put in place in Ambient monitoring stations are in place around the mining and It is not considered practical to monitor SO2 with the HAWK order to determine SO2 concentrations on an on-going basis. A processing areas. The nearest to the Smelting complex include: model HAWK View Software system will be implemented to process Paardekraal, Mfidikwe, Waterval and Hex River. HAWK model is not used. Ambient monitoring is not predictive, it data and predict ground level concentrations of SO2 in the The HAWK model is not considered viable by RPM. The tells you the actual concentrations. MS says that she things they surrounding areas. This system will be implemented by company has been investigating other software to achieve the are fine as they have monitoring and they are looking at a September 2000, and will be used as a pro-active objectives of this commitment. The system was not implemented software for predictive monitoring with head office. Needs to be management tool during Acid Plant shutdowns. in 2000 as required and therefore indicated as a negative amended to state the predicative monitoring is an experimental observation. process which they are looking at with Nishi from Head Office.

RPM EMPR Audit pre-site visit Meeting July 2020 11 Before divested to Sibanya: Initially had an integrated EMPr and Integrated WUl which included the entire Rustenburg Section as well and the concentrators. There were individual EMPrs for the different shafts and other activities. Then Anglo made the decision to divest the shafts and the concentrators to Sibanya and this was followed up by a split in the EMPrs at the time where the activities related to the shafts and concentrators were including on one EMPr and the Retained operations (Waterval, ACP, PMR and RBMR) were consolidated in one EMP. Similar approach taken with the WUL to ensure uses specific to the mine and concentrators were taken over by Sibanya. A lot of errors in the WUL and have submitted amended requests to DWS in conjunction with Sibanaye. Subimitted in 2018, still waiting for this. Had a meeting with DWS late in 2019 to discuss potential design changes to the stormwater dams at RBMR and it was decided that due to the fact that the amended licence has not been issued yet, they will wait for this stormwater design changes to be sent to them so they can incorporate these into the amended licence. This was sent in 2020 and they are still waiting for this approval. Magazines were not retained; they no longer belong to them. They did retain the areas between RBMR and PMR and there are a few areas of land situated around the old shafts (plan to donate this land to the municipality but this is dealt with through the land management team). In the process of getting rid of other portions of land that are just a risk currently. DMR did the EMPr amendments however they had a meeting with DMR and DEDECT and going forward, NW DEDECT will handle all environmental related aspects.

General overview of Retained Operations 04 To be presented by Dustin van Helsdingen 05 RBMR - Overview of key issues - Non-compliances noted as per previous EMPr audit (WSP) Overview of key issues - Boipuso Semenya

Encapsulation dams have been filled so they are not in use anymore. Dam 4S is not in use, have an order number to check the liner for integrity and then they will see if they need to reline and have this dam as a back up. It is currently used as an emergency dam. For instance the Triangular dam overflowed in 2019 and 4S stored some of this overflow. Triangular dam overflowed, there is a report which Boipuso can send.Waste liquid dam is not in use, silted up, discussions to have the silt Want to relocate the taxi drop off point to here. cleaned out and use this dam in the future. Triangular dam has a western and eastern side. Western side was relined in 2017/2018. On the northern side of the plant, dams 1,2 and 3A, there is a project currently for stormwater upgrade where they are redesigning these dams to incorporate silt traps before the effluent/stormwater reaches the dam - still in progress. On 3B, busy desilting the dam to have it relined.

Temporary structure located here where they are treating the silt coming from 3A and 3B. They have confirmed that there is some PGM value into this silt so they are sending it back to the smelter to reprocess and the water is put back in 3B to be reused in the process. Will be completed end of 2021 and the relining will be done in the winter of 2022.

Copper debottlenecking project is happening here.

Existing railway

Bulk acid tanks storing formalin, caustic soda and sulphric acid. Want relocate these to the outside of the plant next to the railway, just outside the boundary. One of these acids gets delivered by rail so they want t have this close to the existing railway.

Brine concentrate feed dam (effluent from the dam is stored here)

Sodium sulphate feed dam (efflutent from the plant is stored here) Rehab testing project – sodium sulphate previously stockpiled in this area has been removed and they are not allowed to stockpile any more sodium sulphate in the plant.

RPM EMPR Audit pre-site visit Meeting July 2020 14 Status of non-compliances identified from previous EMPr PAR (WSP 2019) Commitment Previous auditor comment SRK/RPM comment Inform all staff and contractors that killing No fauna within the fence line was noted during the site walk over. Is this included in the induction presentation to contractors and staff? We have or harming of any animal life in the area No clear reference is made to prohibition of killing of fauna within the site induction. communicated this as a talk topic to site and included this in the induction controlled by Anglo Platinum is material. Training department is busy revising this but they have not finished prohibited. revising the induction pack. Environmental has submitted their material to the training department. Finalise the implementation plan as The installation of scavenging boreholes was investigated historically. The DWS Status of plan? The plan was communicated to DWS,The boreholes are not in agreed with DWS to implement steps as was consulted at the time. Unfortunately, the pumping of the contaminated use anymore, RO plant not in use. Visit from DWS confirmed that boreholes part of groundwater management and underground water did not prove feasible as the salts in the water crystallised within are not in use and this is one of the conditions which Dustin is busy discussing remediation. the pump and piping system which caused ongoing system breakdown. with the DWS to have removed from the WUL. No new plan has been developed or agreed upon with DWS; however, Anglo have focussed on sealing point sources and managing the water balance to prevent spills. Other projects have been undertaken, such as - sealing of various areas, remediation of sumps and relining of dams. Ameliorate soils if contaminated. There is an ongoing amelioration being planned at BMR for an area contaminated Soil specialist been appointed as of yet? This is for the area where the rehab is Amelioration will be done in consultation previously; Boden being done. The consultant appointed is Agreenco so this has been done. with a soil Science undertook an investigation in April 2018, to outline the issue and the way specialist. forward. A Phase 1 study was recommended to be undertaken, however an appointment has not been made for this as yet.

All lined dams will be subjected to a The following lined dams are present at the BMR: Sodium sulphate and brine Status of dam 3a and 3b re-lining? See comments on relining for 3B. 3A is part regular programme of checking and concentrator dams, Effluent Dam No. 1, Effluent Dam No. 2, Effluent Dam No. of the stormwater upgrades mentioned in the previous slide but BS is not sure repairing. 3, Dam 4S Sodium Sulphate Dam, Encapsulation Dams, Stormwater Dam 1, when this will be done. Stormwater Dam 2, Stormwater Dam 3A, Stormwater Dam 3B and Triangular Any formal program for liner inspections in place? Lining inspections are done dam.Based on communication with the environmental coordinator, there is no by SRK once every year or two years report done in 2019. No formal formal program of liner inspections. The Triangular dam was religned in 2018, and programme but it is done. Dam 3a was being re-lined at the time of the audit. Dam 3b is planned to be religned in April/May 2019. Other repairs and maintenance works are done on an ad-hoc basis. Should any erosion gullies form, Erosion was observed at the BMR PCD on the east of the site (E&S Feed Dams). Status of this? It is addressed after each overflow, each dam overflow is logged appropriate remediation will be Due to the regular dam overflows, a number of erosion gullies have developed. No on ENABLON. Incidents are closed out once addressed on ENABLON. Erosion undertaken. remediation measures have been implemented yet. was fixed but BS is not sure if there is a record of this. No other erosion issues were noted during the site walkover. Erosion protection measures were noted at various areas during the site walkover. Contaminated (suspended solids) runoff At all processing operations, stormwater management is in place, the 2018 GN 704 Still taking place? SRK received the Level 3 Incident Report (dated 14 January and seepage should be intercepted and audit report indicates the location of the stormwater runoff infrastructure. The 2020) stating latest incident of overflow (14 January 2020). Several corrective managed to avoid discharge to the following issues are noted during the site walk over: actions proposed. Short term and medium term incidents should have been environment. Regular overflow (onto bare ground) from the BMR PCD located on the east completed by April 2020. What is the status of this? SRK has received the level end of the operation (E&S 3 incident report and there are corrective actions are proposed in this report. Feed Dams). BS confirmed that some of these actions will be moved out due to the lockdown. Some of these tasks have been completed and some have not. Last incident was on 14 January 2020.

Noise levels will be monitored regularly An off-site noise monitoring program is not in place, as a once-off monitoring event Condition not considered practical. both on-site and off-site. indicated that Occupational Hygiene area noise survey received for the Nickel Tank there is no risk of exceedance of noise levels on site. No nuisance issues noted or House at BMR (July 2020) noise related complaints recorded on Enablon. Occupational Hygiene area noise survey received for Material Management at BMR (January 2020) Occupational Hygiene area noise survey received for NCM Laboratory(January 2020) 15 Cumulative noise impact assessment conducted by dBAcoustics in 2008 (very old). Is an update anticipated? BS confirmed that there had been not PMR – final processing site, refine all of the PGMs and send these to the market. No particular issues at this stage. Last year they relined dam 3A

06 PMR - Overview of key issues - Non-compliances noted as per previous EMPr audit (WSP) Overview of key issues - Nongaka Khaas

Not planned for immediate desilting.

Will reline dam 2 last year

Relined dam 1 last year

Relined dam 3A last year

Dam 1 is still empty. In 2020 they are planning to reline dam 2. Dam 2 is full of solids so this will need to be removed. All of the effluent dams contain solids so they clean them out in a phased approach. Dam 4, 5, and 6 are not worrying in terms of the free board, they monitor fre board levels on a daily basis. In Feb they had an incident at dam 3A. Started seeing effluent entering dam 3A, they did not understand where this was coming from, it was full of sewage sludge, it was during heavy rainfall. Dam 3A overflows into 3B which then overflows into the spillway which then goes to the Klipspruit. They pumped out dams 3A and 3B into the RPM sewage system and found that the source of the sewage was the area next to the helipad, when it was raining it travelled in the stormwater trenches and flooded the 3A and 3B dams. This was the only main incident they had. The water they pumped to the STW did not have an impact on the STW.

RPM EMPR Audit pre-site visit Meeting July 2020 17 Status of non-compliances identified from previous EMPr PAR (WSP 2019)

Commitment Previous auditor comment SRK/RPM comment Should soil contamination be discovered, a The recommendations of the Agreenco soil Status of this? NK – refer to previous slides for the discussion on specialist should be contracted to investigate monitoring report (2018 Draft Report; Assessment this. When they looked at the contamination levels in the soils report the contamination and recommend possible of Soil Contamination at the PMR) have not yet it was not at a stage where they needed to discuss with the manners of rehabilitation, if required. These been discussed with the DEA. Once a authorities. The impact levels were minimal so they did not see a recommendations will be discussed with the discussion was held with the DEA the agreed need to discuss with the authorities and this was closed on their Department of Environmental Affairs prior to to recommendations side. SRK has also conducted work at this site and found very little implementation. must be implemented. contamination and is of the view that the levels are not at a level where a remediation order would need to be triggered. There is no risk and therefore there is no requirement to talk to the authorities. PMR needs to inform Agreenco in the future that if any remediation is required they need to make this clear in their reports and then based on the contamination levels. They have recommended that paving is installed in certain areas of the plant where known problem areas are. NK to share this report with SRK. The existing handling procedures for the There are three noted incinerators at the PMR, Status? management of ash should be reviewed and one has been placed on hold (care and No incinerators anymore. They have a thermal beneficiation plant a more detailed sampling campaign should maintenance), one is operational and one new which was installed in 2019. Previously they had a low grade be undertaken to ensure that current one is being installed. The auditor was not incinerator which treated all low grade material. Also had a hig management is presented with an ash management procedure or grade incinerator and the Crawl (treated the organics by the plant). appropriate for guaranteeing the health and sampling campaign. All of this has been decommissioned (low grade incinerator and the safety of workers. Crawl) and replaced with the thermal beneficiation plant. In the AEL they do not have any reference to incinerators so they call them beneficiations. Ash generated goes back into the processing process and NK can share evidence of how this Ash is handled. This action is closed.

RPM EMPR Audit pre-site visit Meeting July 2020 18 07 Close-out discussions Discussion points:

. Date for site visit . Confirmation of site visit arrangements . Any other comments

RPM EMPR Audit pre-site visit Meeting July 2020 20 SRK Consulting: 558834: Rustenburg Process Operations: External Environmental Audit, undertaken during August 2020 Page 24

Appendix C: Audit checklists

Appendix C1: General EMPr Conditions

Conditions Level of Reason for audit finding compliance

1. Legal Requirements EMP audits will be done every 2 years by an external C The previous external audit was conducted for 2019 by WSP. The 2020 external audit was undertaken auditor and internally very year. by SRK consulting. An internal audit was conducted in May 2020, proof of this audit has been provided to the auditor.

The regional officer and the Retained Operations C As indicated in the pre-site visit meeting, the regional officer and the various Retained Operations environmental officer will undertake regular audits on all Environmental Officers conduct internal environmental audits annually. An internal environmental audit areas of the operations. was conducted in May 2020, proof of this audit has been provided to the auditor.

The following additional internal auditing events are noted by the auditor:

 Annual GN704 audit across the operations.  Annual Internal Water Use Licence (WUL) audits.  Internal Atmospheric Emissions Licence (AEL) reviews.  Internal ISO14001 audits.

2. Biodiversity Management Plan – Terrestrial Flora Limiting further habitat destruction, especially in NC No construction activities were taking place at the time of the audit. There are currently no previously undisturbed areas. disturbances taking place within sensitive areas. The RPM processing operations have been in place since 1998 (RBMR), 1999 (PMR), 2000 (Smelter) and 2001 (ACP). Since establishment, numerous projects have taken place, which have been approved (through various licence amendments/ variation processes). The remainder of the activities are usually limited to the fence line of each operation. It was observed in the previous audit and confirmed with the ACP Retained Operations Environmental Officer as part of this assessment that there is an area to the north of ACP where a coal stockpile has been placed. This coal is used within the Smelter and ACP however the stockpile has been placed on bare ground.

Measures implemented to address the non-compliance

The Environmental Officer mentioned that the operations are looking at alternatives as to where the coal stockpile (an action plan has been put in place and was provided to SRK for review) can be placed but at the time of the audit, other than the aforesaid no further measures have been implemented to address the non-compliance. The Auditor was made aware of the discussion which was held between the Environmental Officer and the responsible person for the area and there has been a commitment for the coal to be removed over the next month. An action was raised on Enablon (verified by the Auditor).

Conditions Level of Reason for audit finding compliance

Practicality of the EMPr commitment

The condition is considered practical.

Non-compliance administrative or will have an impact

It is considered that the placement of the coal stockpile on bare ground would have an impact on the environment.

Historical/new non-compliance

Historical as it was identified as part of the previous Environmental audit however an action plan has been developed and the Environmental Officer has indicated that there has been a commitment for the coal to be removed over the next month.

Harvesting of plants, for example for medicinal purposes NA The collection and sale of firewood does not occur at the site. It was noted in the pre-audit meeting and for fire-wood and structural material, has an impact that this condition needs to be removed as part of the EMPr Amendment planned for 2020. on individual species that is separate from the impacts on habitats as a whole. The needs of the local population should be determined in order to evaluate the potential impact they may have on the vegetation natural resource base. This may take the form of a social study, which could provide an opportunity to pre-empt social impacts. It will also enable the equitable utilisation of natural resources under the control of the Retained Operations area, without necessarily having any negative impact on the conservation of biodiversity.

Establishing a fire management plan to minimise the C Signage of ‘no open fires’ is present on site. The employees are aware of the fire emergency effect of uncontrolled fires on natural vegetation. A wild protocols. Employees are aware of the firefighting procedure. This procedure is included in the fire management plan should be developed as prescribed induction. Each operation has an emergency response procedure specific to the operation. The auditor in the National Veld and Forest Fire Act (1998) to reviewed the emergency preparedness and response procedure (RBMR-SHE-SAF-MCOP-0001). minimise the threat associated with fires.

Banks could be stabilised and rehabilitated in high activity C Dam 3B is within the flood line level and within 100m of the river, however the dam was built prior to areas. This will also decrease erosion and reduce the the regulation being promulgated and is included in the WUL. No further construction activities were impact of siltation of river substrates. noted outside of the existing RBMR footprint area during the site audit. The riparian habitat is monitored by Cleanstream Environmental Consultants.

Conditions Level of Reason for audit finding compliance

No development should occur within 30m of the 1:50 year C The Hex river is approximately 2 km to the south west of the Retained Operations. The flood line of the Hex River and its tributaries in Klipfonteinspruit, which is a tributary of the Hex river, passes between the Retained Operations within accordance with the National Water Act (No. 36 of 1998). 30 m of the PMR, RBMR and Smelter. A GN 704 exemption has been included as part of the WUL to take into account the infrastructure which was developed within 30 m of the 1:50 year floodline. Improve solid waste disposal in riparian zones by C No unauthorised dumping was observed the time of the site audits. The facility security is extremely placement of no dumping signs and rehabilitation of strict and thus unauthorised dumping is impossible. ‘No-dump’ signs have not been erected due to affected areas in riparian and in stream zones. theft issues.

Improve overall catchment management. C RPM undertakes annual internal and external WUL audits for the retained operations in line with the requirements of the Rustenburg Section WUL. The latest external WUL audit report was conducted by SRK Consulting and is dated February 2020. The internal WUL audit report, dated May 2020 focussed on the non-compliances raised in the external WUL audit. The commitments of the WUL are aimed at improving and managing impacts on the catchment. In addition to this, RPM have an Integrated Waste and Water Management Plan (IWWMP) (January 2019) to assist in improving and managing impacts on the catchment.

Control the effect of dust and gas emissions by not C Dust monitoring is undertaken on a monthly basis by Aquatico. Dust monitoring reports were made placing roads and infrastructure near sensitive vegetation available to the auditor for review with the most recent report dated May to June 2020. Dust levels communities or plants species and implement strict dust recorded were compliant. No issues relating to dust were recorded at all operations. emission control measures. The effect of dust and gas emissions on plants should be monitored with emphasis on sensitive plants and plant communities.

A monitoring programme will be implemented that will PC An Alien Invasive Plants Management Plan was compiled by Agreenco in March 2018. The report was ensure that all weeds and alien species will be eradicated provided to the Auditor for review. No actions regarding the recommendations contained within this in and around the project area. Monitoring will be done report have been undertaken due to budget constraints. Agreenco completed a biodiversity according to the Biodiversity Action Plan for the region. assessment in 2014-2015, which noted areas of high or low biodiversity importance. The refineries are considered to be of ‘low’ value. The Smelter requires a BAP to be developed. Agreenco have been appointed to conduct the fauna and flora assessment during 1-3 September 2020. At PMR and RBMR specifically, the Retained Operations Environmental Officers expressed concerns about Rock Hyrax (Dassies) which present as a pest on site. The operation is currently exploring options to control this situation and will be contacting a biodiversity specialist to assist. Limit surface soil disturbance and manage erosion C Erosion was not noted during the site audit. The site is largely paved or concreted (hard surfaced) with (especially dirt roads and previously disturbed areas). little to no vegetation or bare soils.

Invasive exotic species listed as Category 1 invasive PC An Alien Invasive Plants Management Plan was compiled by Agreenco in March 2018. The report was species (e.g. Opuntia ficus-indica) will be removed from provided to the Auditor for review. No actions regarding the recommendations contained within this report have been undertaken due to budget constraints. Agreenco completed a biodiversity

Conditions Level of Reason for audit finding compliance

the lease area. assessment in 2014-2015, which noted areas of high or low biodiversity importance. The refineries are considered to be of ‘low’ value. Agreenco have been appointed to conduct the fauna and flora assessment during 1-3 September 2020.

Existing alien invasive, weedy plant species and bush PC An Alien Invasive Plants Management Plan was compiled by Agreenco in March 2018. The report was encroachers will be removed on an on-going basis from provided to the Auditor for review. No actions regarding the recommendations contained within this the Retained Operations area. report have been undertaken due to budget constraints. Agreenco completed a biodiversity assessment in 2014-2015, which noted areas of high or low biodiversity importance. The refineries are considered to be of ‘low’ value. The Smelter requires a BAP to be developed. Newly disturbed areas will be checked for invader/weedy NA Several projects are planned for areas within the Retained Operations areas and along the fence line and bush encroacher seedlings, which will be removed. of RBMR. These areas are already disturbed. No newly disturbed areas were disturbed as part of this audit period.

If any further Category 2 and/or 3 alien invasive plant PC According to the previous audit, RPM completed an Invasive Alien Plant Study in June 2016 during species are identified on the Retained Operations area which no Category 2 or 3 species were identified. An Alien Invasive Plants Management Plan was their spread will be monitored and eradication compiled by Agreenco in March 2018. The report was provided to the Auditor for review. No actions programmes will be initiated where necessary. regarding the recommendations contained within this report have been undertaken due to budget constraints. No Category 2 or 3 species were observed during the site audit.

Natural flora species are not to be used as firewood. NA The collection and sale of firewood does not occur at the operation.

Survey area to identify invader species, as per revised C An Alien Invasive Plants Management Plan was compiled by Agreenco in March 2018. The report was Conservation of Agricultural Resources Act 43, reg 15, provided to the Auditor for review. It was noted that a survey was conducted whereby the full study site 16. was assessed and a recording all listed plant species observed was made.

Unnecessary disturbances of flora must be avoided or C Several projects are planned for areas within the Retained Operations areas and along the fence line minimised. of RBMR. These areas are already disturbed. No newly disturbed areas were disturbed as part of this audit period.

Alien invaders (As per “Conservation of Agricultural PC An Alien Invasive Plants Management Plan was compiled by Agreenco in March 2018. The report was Resources Act”) will be eradicated in and around the provided to the Auditor for review. No actions regarding the recommendations contained within this Retained Operations and their spread prevented during all report have been undertaken due to budget constraints. Agreenco completed a biodiversity phases and after closure and rehabilitation. assessment in 2014-2015, which noted areas of high or low biodiversity importance. The refineries are considered to be of ‘low’ value.

Clearing of vegetation will be limited to the minimum area NA No new construction activities were taking place at the time of the audit. Several projects are planned safe for construction and operation of closure activities. for areas within the Retained Operations areas and along the fence line of RBMR. These areas are already disturbed. There are currently no disturbances taking place within sensitive areas and no clearing of vegetation. Aspects related to closure are not relevant as the operations are not anticipated

Conditions Level of Reason for audit finding compliance

to be decommissioned in the foreseeable future.

3. Biodiversity Management Plan – Terrestrial Fauna Planning of all new developments should be done with an C All new projects go through the ‘Plant Change Notification Procedure’ (latest version 10 dated increased sensitivity regarding shrinking natural areas. 2019/09/27 was provided to the auditor for review) which includes consideration of environmental impacts. Large scale or complex projects may require approval by way of Environmental Impact Assessment. This procedure details the management of risks that result from any change to the environment, person, process, equipment, material or any other substance. Several projects are planned for areas within the Retained Operations areas and along the fence line of RBMR. These areas are already disturbed however, the objectives of the Plant Change Notification Procedure should be considered when undertaking any of the future planned projects.

Management should endeavour to influence or guide the C RPM has a communication, participation and consultation operational procedure which has been local community on the informal settlement issue since provided to the auditor (latest revision date: 2020/06/08). All relevant stakeholders are contacted and these settlements are most probably there because of the communicated with on an on-going basis. No issues regarding settlements were noted for this audit Retained Operations activities. period.

The enormous amount of redundant infrastructure could C Closure of the retained operations is not foreseen and any redundant infrastructure will only be be rehabilitated with good planning, prioritisation and removed during decommissioning. funding, thus increasing the environmental integrity of the Retained Operations area tremendously. The Frank Concentrator is part of the retained operations and although it has its own decommissioning approval from provincial environmental affairs. The facility has not yet been removed and the area rehabilitated. At the time of the audit it was communicated that decommissioning was supposed to have commenced in 2020 but due to the Covid-19 pandemic it is uncertain if this will take place until 2021.

Environmental Officer will take action should man/bird C No conflict noted at the time of the audit. conflicts arise.

Birds will be discouraged from utilising contaminated C No discouragement mechanisms were noted at the RBMR and Smelter/ACP complex pollution control water sources. ponds/dams during the site audit. The PMR has installed bird disruptors on the roofs of the main buildings. No bird deaths reported on the plant or recorded on the incidents register.

Fatalities of birds or any other animals will be investigated NA No noted deaths for this audit period. to ascertain the cause of death.

Reduce surface disturbance that will result in the loss and C All new projects go through the ‘Plant Change Notification Procedure’ (latest version 10 dated fragmentation of sensitive habitats associated with high 2019/09/27 was provided to the auditor for review) which includes consideration of environmental impacts. Large scale or complex projects may require approval by way of Environmental Impact

Conditions Level of Reason for audit finding compliance

faunal diversity. Assessment. This procedure details the management of risks that result from any change to the environment, person, process, equipment, material or any other substance. Several projects are planned for areas within the Retained Operations areas and along the fence line of RBMR. These areas are already disturbed however, the objectives of the Plant Change Notification Procedure should be considered when undertaking any of the future planned project. No construction activities were taking place at the time of the audit. There are currently no disturbances taking place within sensitive areas and no clearing of vegetation has taken place.

Unnecessary disturbances of fauna must be avoided or C At PMR and RBMR specifically, the Retained Operations Officer expressed concerns about Rock minimised. Hyrax (Dassies) which present as a pest on site. The operation is currently exploring options to control this situation and will be consulting with a biodiversity specialist for assistance.

Refrain from building any further in stream dams or weirs; C Since establishment of the facilities, over 15 years ago, no further infrastructure noted within the remove redundant structures to restore the natural river Klipfonteinspruit system. No redundant infrastructure noted within the river requiring removal. continuum.

Create awareness regarding the important role the C SRK reviewed the talk topic compiled to raise awareness regarding the importance of the riparian riparian zone play in stabilising the river bank, as a viable zone. According to the Retained Operations Environmental Officer for Waterval Smelter, this is habitat and natural corridor; address the issue of clearing distributed to all departments within the operations. There is no plan to include this in community the riparian zone and the law. awareness talks. It has been recommended by the Retained Operations Environmental Officer that this condition should be removed as it is more relevant to the Sibanda Operations and not to the Retained Operations.

Ensure compliance of effluents with guidelines and PC Extensive water monitoring is taken at various points across the Retained Operations as demonstrated standards. Inform local communities regarding their in the surface and groundwater monitoring reports. potential contribution to water quality pollution and educate towards sustainable use and conservation. Sampling of surface water and groundwater is conducted by Aquatico. The 2019 IWWMP compiled by Restoration and protection of wetland/marshland areas Aurecon indicated that there are currently 37 active surface water quality monitoring points including within the system. the process water monitoring points. It was detailed in the report that sulphate and the trace heavy metal, nickel, are largely associated with the operations at RBMR and that the highest risks to surface water is the RBMR pollution control dams. According to the 2020 WUL Audit, groundwater monitoring is conducted and results submitted to the Department of Human Settlements, Water and Sanitation (DHSWS) (previously known as the Department of Water and Sanitation -DWS) on a quarterly basis.

At PMR the process water is recycled. Water is processed in a closed system. Monthly sampling frequency applies to the surface water sampling program. Five samples are taken within the Klipfonteinspruit (both up and downstream) to understand the impact from the facility on water quality. The results are submitted to the DHSWS on a quarterly and annual basis.

Conditions Level of Reason for audit finding compliance

The stakeholder engagement department manages communication with stakeholders. A discussed with the Retained Operations Environmental Officer, PMR and RBMR conduct environmental awareness campaigns within local schools and these include awareness on water aspects.

No wetland offset projects noted.

Ensure compliance to water quality guidelines. C Extensive water monitoring is taken at various points across the Retained Operations as demonstrated in the surface and groundwater monitoring reports.

Sampling of surface water and groundwater is conducted by Aquatico. The 2019 IWWMP compiled by Aurecon indicated that there are currently 37 active surface water quality monitoring points including the process water monitoring points. It was detailed in the report that sulphate and the trace heavy metal, nickel, are largely associated with the operations at RBMR and that the highest risks to surface water is the RBMR pollution control dams. According to the 2020 WUL Audit, groundwater monitoring is conducted and results submitted to the DHSWS on a quarterly basis.

Start awareness campaigns on the Retained Operations PC SRK reviewed the talk topic compiled to raise awareness regarding the importance of the riparian zone areas and in the community to inform the people about as well as other awareness campaigns and talk topics. According to the Retained Operations the roles of important species. Environmental Officer for Waterval Smelter, this is distributed to all departments within the operations. There is no plan to include this in community awareness talks. No evidence could be provided at the time of the audit that awareness campaigns focusing on biodiversity and important species are undertaken in the community.

4. Land Management All soil stripped will be stockpiled for use in rehabilitation. NA All retained operations have been in place for in excess of 15 years. No topsoil stockpiles were kept or The chemical and physical properties of the topsoils and maintained and no topsoil balance is kept. There is no planned closure date. subsoils do not differ significantly and they will therefore not be stored separately. As the stockpiles will be in place A decommissioning closure plan was undertaken by SRK in November 2019; the closure materials for at least several years no special measures will be required include 36 624 cubic metres of cover material and 1 069 408 cubic metres of growth media. introduced to preserve the organic content of the soils. The major usage of this material will be in forming No new projects were undertaken in this audit period and therefore no soil was stripped. stormwater control berms.

Conditions Level of Reason for audit finding compliance

Contamination of soil will be prevented through, diversion C According to the 2018 GN 704 audit report the following applies for the Retained Operations: of clean rainfall run-off, collection of dirty water, the bunding of all above ground storage facilities for  Dirty water runoff from within RBMR is collected in a number of trenches which then drains to the hazardous substances such as diesel, oil and chemicals. stormwater dams. The clean water upstream of RBMR is diverted away from RBMR in a number of trenches and pipes into the Klipfonteinspruit on the northern side of RBMR.  At PMR, stormwater runoff is collected in a number of small trenches within or around PMR. Along the eastern and northern boundaries of PMR, there are clean water trenches to collect the stormwater that would otherwise enter the area. The eastern clean water canal is discharged to the stream flowing along the northern boundary of PMR. The southern portion of the PMR site features a clean water cut off berm that discharges water to the west of the site. As this berm runs a distance from the site, a secondary measure is in place to collect and divert water generated between the two structures away from the site.  The ACP plant area drains naturally from north to south. Vertical drains running north to south collect and direct stormwater to a perpendicularly running canal which drains to the ACP dam. The ACP dam has a spillway which will overtop in emergency situations, flowing into the Klipfonteinspruit upstream of the bridge. The internal dirty water system works well and shows signs on good and continual maintenance

Ad-hoc checks are conducted by the environmental officer to identify any spills. Chemicals are stored in a bunded area. Internal monthly inspections are undertaken to identify any issues with the bund walls. The incident procedure in the case of significant spillages is noted as the action plan.

Clean and dirty water separation and compliance with C As above Regulation 704 of the National Water Act will be upheld.

The disturbance of any of the rocky ridge habitats and C The PMR influences two koppies, one inside the fence line and one outside the fence line. Both koppies should be avoided by the proposed infrastructure koppies are not interfered with. The koppie inside of the fence line is located adjacent to office prefabs, and a 200 m buffer zone between these ridges and the therefore employee activity adjacent to the koppie is limited. Operations at the PMR are on-going infrastructure maintained. (since 1999). Based on Google Earth timeline images, no further development within 200 m of the koppie has taken place since the previous audit.

Ameliorate soils if contaminated. Amelioration will be C It is the Auditor’s understanding that the contamination levels within the soils sampled to date are not done in consultation with a soil specialist. at a level where action would need to be undertaken.

Should erosion occur, the eroded areas must be PC Erosion observed at the RBMR dam (E&S feed dams) during the previous audit has been repaired and rehabilitated appropriately. was confirmed during the site audit. Erosion takes place after each overflow and each dam overflow is logged on Enablon. Incidents are closed out once addressed on Enablon. Erosion was fixed (but not revegetated), the Retained Operations Coordinator at RBMR provided photographic evidence that the

Conditions Level of Reason for audit finding compliance

erosion has been repaired.

Contaminated soils from seepage will be remediated on C It is the Auditor’s understanding that the contamination levels within the soils sampled to date are not site. If not, it will be disposed of at a permitted waste at a level where action would need to be undertaken. disposal site. In terms of addressing potential soils contamination on site, there is an ongoing rehabilitation project taking place at E&S area within RBMR but this project is currently in experimental phases. RPM Appointed Agreenco for this study and are running a trial for a year to establish what plant species can survive and absorb the sodium sulphate in that area. If not, successful alternative methods will be investigated and if feasible implemented. The contamination at the silica storage area located at the ACP had been recorded in Enablon and an alternative storage area is being planned.

Rehabilitation will begin as soon as is possible, at all NA It is assumed that this condition pertains to the closure of the operation and since closure is not disturbed areas, affected by the Retained Operations. planned for the foreseeable future it is not relevant at this stage. No new areas were disturbed for this audit period. Ongoing rehabilitation project going on at E&S area within RBMR but this project is currently in experimental phases. RPM Appointed Agreenco for this study and are running a trial for a year to establish what plant species can survive and absorb the sodium sulphate in that area. If not, successful alternative methods will be investigated and if feasible implemented. The contamination at the silica storage area located at the ACP had been recorded in Enablon and an alternative storage area is being planned.

All usable soils will be stripped to a depth of 800mm or NA No soils were required to be stripped for this audit period. Going forward, any new projects to be greater, where possible, excluding at facilities that will conducted will need to take note of this condition. remain post closure such as the tailings dams and waste rock dumps (Seepage will be considered prior to topsoil stripping).

Monitoring of the soil during the operational phase must NC The PMR EMPr (before it was consolidated in 2016) states soil monitoring needs to be conducted occur on a bi-annual basis to determine if further every two years whereas in the general conditions it states it needs to be conducted twice a year, this contamination is occurring due to Retained Operations is causing confusion. An amendment to this specific condition was applied for following the previous activities. audit and submitted to the authorities in December 2019 (proof has been provided to the auditor) but it is still in progress. This condition will be amended in the updated EMPr Amendment planned for 2020/2021. This condition remains non-compliant until the amendment is approved.

Measures implemented to address the non-compliance

Obtained approval of the amendment to this condition from the authorities or undertake an EMPr Amendment to address all conditions which are not practical.

Conditions Level of Reason for audit finding compliance

Practicality of the EMPr commitment

The condition is considered not practical. It is suggested that the frequency of monitoring is agreed with the environmental authority considering that the majority of the sites are hard surfaced. PMR is only required to monitor the soil every two years. This condition should be aligned with the PMR soil monitoring frequencies.

Non-compliance administrative or will have an impact

Administrative, needs to be aligned with the soil monitoring frequencies of PMR.

Historical/new non-compliance

Historical as it was identified as part of the previous Environmental audit.

The RPM-RS Environmental Officers must approve in NC The ‘Plant Change Notification Procedure (version 10.0)’ is applied to all new projects which includes writing any land disturbance that will take place. consideration of the environmental personnel when dealing with operational projects and the environmental manager when dealing with capital expenditure projects. The procedure was provided to the auditors.

It was observed in the previous audit and confirmed with the ACP Retained Operations Environmental Officer as part of this assessment that there is an area to the north of ACP where a coal stockpile has been placed. This coal is used within the Smelter and ACP however the stockpile has been placed on bare ground. The ACP Retained Operations Environmental Officer did not receive or approve the placement of this stockpile because they were not informed about it. The Officer mentioned that there are occasions where environmental incidents occur due to a lack in knowledge from operations staff in what is permitted in terms of environmental management. This action has been recorded on Enablon and the Environmental Officer has had a discussion with the responsible person to have the stockpile removed within the next month.

Measures implemented to address the non-compliance

Conditions Level of Reason for audit finding compliance

Practicality of the EMPr commitment

The condition is considered practical.

Non-compliance administrative or will have an impact

It is considered that the placement of the coal stockpile on bare ground would have an impact on the environment.

Historical/new non-compliance

If soil stockpiles contain white Dolerite, they will be NA No soil stockpiles exist on site, this was confirmed during the site visit. covered with a darker soil to prevent reflection.

Ensure that all stockpiles have protection against erosion NA As above. and dirty water contamination.

Topsoil will be sourced during the operational phase from Noted According to the environmental team, closure material was agreed to be sourced from within the other sources to ensure sufficient quantity for retained area, by means of permitted borrow pits. Closure is not anticipated for at least another 80 rehabilitation on closure. years, and in addition, a high-level estimate of the availability of top soil in the retained area is included in the annual closure liability assessment.

Rehabilitation of completed workings with grasses and NA Rehabilitation and grassing will be undertaken at the processing operations once operations have other vegetation as soon as is practical. ceased. Closure is not foreseen in the near future.

Keep surface disturbance to a minimum and concentrate NA No new areas were disturbed for this audit period. disturbance in already disturbed areas.

Minimise interference with drainage lines, and topography C Based on communication with RPM, no construction has occurred other than what was originally of the area. impacted on during the construction of the operations (for which the relevant environmental approvals have been obtained).

The contractor’s laydown areas will be rehabilitated during C In the case of all the processing operations, the contractor laydown area is permanent and used for the operational phase. It will be landscaped with topsoil on-going maintenance or construction projects, as and when required. As such, no rehabilitation of the contractor areas is foreseen until closure.

Conditions Level of Reason for audit finding compliance

and revegetated. The contractor's area at RBMR is being relocated within the RBMR boundary to allow for the construction of the proposed Copper Debottlenecking Plant. The area was cleared at the time of the audit - it is within the operations boundary and will be used as a laydown area in the interim. No rehabilitation is planned at this stage as the area will be used for the Copper Debottlenecking Plant.

To reduce the dust entrainment, water or an appropriate NA No topsoil is stockpiled onsite. dust suppressant must be sprayed on topsoil stockpiles until such time as the topsoil stockpiles have been revegetated.

All topsoil from the contractor laydown area must be NA Topsoil was not stripped prior to the creation of the contractor laydown areas. Since this condition stripped, removed, stockpiled (as per stockpile storage cannot be complied with, it is suggested that it be amended. guidelines) and re-used to preserve its integrity and seed reserve. Topsoil can be used to rehabilitate disturbed areas.

Topsoil should only be exposed for minimal periods of NA No topsoil is stockpiled onsite time and adequately stockpiled to prevent topsoil loss and run-off. Vegetation clearance must be conducted in phases to reduce the exposed area.

Stormwater run-off control measures must be instituted to NA No topsoil is stockpiled onsite. prevent the loss of topsoil.

Firefighting equipment will be maintained and checked C The fire equipment on site is serviced and maintained as and when required. A random check of fire regularly. equipment was conducted by the auditor. Fire extinguishers checked were within the service period.

Veld fires should be extinguished under the supervision of C Signage of ‘no open fires’ is present on site. The employees are aware of the fire emergency the Retained Operations area’s environmental manager. protocols. Employees are aware of the firefighting procedure. This procedure is included in the induction. Each operation has an emergency response procedure specific to the operation.

All relevant recommendations as specified in the C The only heritage site noted within the fence line, during communication with RPM personnel, is the Archaeology studies will be implemented by the project. graveyard at the Waterval Smelter. The graveyard is fenced off; contact numbers are displayed on the fence for any person intending to gain access to the area.

Maximise the utilisation of the ore processed/refined. C Ore is received from the third party concentrators in Rustenburg as well as RPM operations in Limpopo. Once the concentrate is received by the smelter the concentrate is smelted within smelters. The matte is then processed through the ACP plant, via converters, from where the matte either

Conditions Level of Reason for audit finding compliance

recycles back to the smelters or is transferred across to the refineries. The concentrate is refined as far as practically possible using available viable technologies.

This process does not result in any wastage or losses, as the complete amount of ore is processed and utilised.

The contractor’s laydown area will be rehabilitated during C In the case of all the processing operations, the contractor laydown area is permanent and used for the operational phase. It will be landscaped with topsoil on-going maintenance or construction projects, as and when required. As such, no rehabilitation of the and revegetated. contractor areas is foreseen until closure. The contractor's area at RBMR is being relocated within the RBMR boundary to allow for the construction of the proposed Copper Debottlenecking Plant. The area was cleared at the time of the audit - it is within the operations boundary and will be used as a laydown area in the interim. No rehabilitation is planned at this stage as the area will be used for the Copper Debottlenecking Plant.

The site will be rehabilitated by means of replacing the NA It is assumed that this condition pertains to the closure of the operation which is not planned for the soil stripped and stockpiled during the construction phase. foreseeable future. No rehabilitation has occurred for this audit period and none is planned. An In areas to be rehabilitated to an arable standard soil will ongoing rehabilitation project going on at E&S feed dam area within RBMR but this project is currently be replaced to a minimum depth of 700 mm. In grazing in experimental phases. RPM Appointed Agreenco for this study and are running a trial for a year to areas a minimum of 250 mm will be replaced. establish what plant species can survive and absorb the sodium sulphate in that area. If not, successful alternative methods will be investigated and if feasible implemented. A S&SD specification for rehabilitation (AA SSDG MC001 – Internal draft) was made available to the Auditor for review. This specification applies to the management of all rehabilitation activities across Anglo American (AA) operations, especially those which are associated with the largest risk due to their rehabilitation backlog and surface disturbance. This is not specifically the case for the Retained Operations however it should be considered together with the plans for rehabilitation of the E&S feed dam area and any of the future projects planned at the operations.

Should any erosion gullies form, appropriate remediation C Erosion observed at the RBMR dam (E&S feed dams) during the previous audit has been repaired and will be undertaken. was confirmed during the site audit. Erosion takes place after each overflow and each dam overflow is logged on Enablon. Incidents are closed out once addressed on Enablon. Photographic evidence has been received by the Auditor.

Ameliorate soils if contaminated. A qualified soil scientist C It is the Auditor’s understanding that the contamination levels within the soils sampled to date are not should conduct the assessment. at a level where action would need to be undertaken.

Careful rehabilitation of any site always plays a major role Noted No rehabilitation has occurred for this audit period and none is planned. in ensuring that the greater natural systems and processes are not destroyed. A S&SD specification for rehabilitation (AA SSDG MC001 – Internal draft) was made available to the Auditor for review. This specification applies to the management of all rehabilitation activities across

Conditions Level of Reason for audit finding compliance

Anglo American (AA) operations, especially those which are associated with the largest risk due to their rehabilitation backlog and surface disturbance. This specification considers surface water management and the selection of the appropriate plant species to reintroduce to ensure that the greater natural systems and processes are factored into rehabilitation.

Stockpiles created during the construction phase may not C No stockpiles from construction are present as part of the operations. No new construction activities remain in the operation phase of the project. were taking place at the time of the site audit.

5. Water Management Plan All sewage will be treated at an appropriate treatment C All sewage is directed to the RPM Rustenburg sewage works. No septic tank systems are used on site facility. (based on communication with RPM personnel).

A water management strategy will be put into place and C According to the 2020 RBMR WUL Audit, the water balance is updated by RBMR on a monthly basis. the water balance will be carefully managed. Flow measuring devices are in place to measure flow of water into the authorised Section 21(g) water uses, which provide information for the annual water balance. The operational water balance is updated monthly by each processing operation. Water usage at the PMR is only monitored at the discharge point and at the Rand Water pipeline. Water usage readings are obtained monthly and are available for the audit period. Optimisation takes place where possible/practical.

A draft water management plan (dated August 2020) is in place and the Auditor has received a copy of this plan for review. The operational water balances are updated monthly based on available water meter readings. Where water meters are not available the volume is extrapolated or assumed conservatively.

Monitor the surface and ground water quality upstream C Extensive water monitoring is taken at various points across the Retained Operations as demonstrated and downstream of Retained Operations activities in the surface and groundwater monitoring reports. frequently and implement appropriate measures if required. Sampling of surface water and groundwater is conducted by Aquatico. The 2019 IWWMP compiled by Aurecon indicated that there are currently 37 active surface water quality monitoring points including the process water monitoring points. It was detailed in the report that sulphate and the trace heavy metal, nickel, are largely associated with the operations at RBMR and that the highest risks to surface water is the RBMR pollution control dams. According to the 2020 WUL Audit, groundwater monitoring is conducted and results submitted to the DHSWS on a quarterly basis.

Conditions Level of Reason for audit finding compliance

The results are submitted to the DHSWS on a quarterly and annual basis.

Contaminated (suspended solids) runoff and seepage C Adequate pollution control systems are in place to control runoff and seepage. should be intercepted and managed to avoid discharge to the environment. Due to an extreme rainfall event over several weeks, discharge caused by overflow of effluent water from the Triangular Dam at the E&E plant occurred into channels leading into the Klipfonteinspurit. SRK received the Level 3 Incident Report (dated 14 January 2020) stating latest incident of overflow (14 January 2020) from the RBMR PCD. Several corrective actions are proposed to manage the overflow. Short term and medium-term incidents should have been completed by April 2020. Some of these tasks have been completed and some have not as they are planned for upcoming months (being conducted in a phased approach).

Separate clean and dirty water with drains and bunded C According to the 2018 GN 704 audit report the following applies for the Retained Operations: areas. Recycle the dirty water with in the process water system. All clean water is to be allowed to flow to the  Dirty water runoff from within RBMR is collected in a number of trenches which then drains to the environment. stormwater dams. The clean water upstream of RBMR is diverted away from RBMR in a number of trenches and pipes into the Klipfonteinspruit on the northern side of RBMR.  At PMR, stormwater runoff is collected in a number of small trenches within or around PMR. Along the eastern and northern boundaries of PMR, there are clean water trenches to collect the stormwater that would otherwise enter the area. The eastern clean water canal is discharged to the stream flowing along the northern boundary of PMR. The southern portion of the PMR site features a clean water cut off berm that discharges water to the west of the site. As this berm runs a distance from the site, a secondary measure is in place to collect and divert water generated between the two structures away from the site.  The ACP plant area drains naturally from north to south. Vertical drains running north to south collect and direct stormwater to a perpendicularly running canal which drains to the ACP dam. The ACP dam has a spillway which will overtop in emergency situations, flowing into the Klipfonteinspruit upstream of the bridge. The internal dirty water system works well and shows signs on good and continual maintenance Ad-hoc checks are conducted by the environmental officer to identify any spills. Chemicals are stored in a bunded area. Internal monthly inspections are undertaken to identify any issues with the bund walls. The incident procedure in the case of significant spillages is noted as the action plan.

Water obtained from de-watering will be used in other C The Retained Operations are not undertaking any dewatering however the process water is recycled. processes, where possible. Water is processed in a closed system.

Borehole levels will be monitored regularly. Should that C According to the 2020 WUL Audit groundwater monitoring is conducted and results submitted to the indicated that groundwater quality has been affected, DWS on a quarterly basis. According to the 2019 annual water quality data (Groundwater Complete, appropriate measures will be implemented. If the supply is 2019), all boreholes were compliant with the WUL limits for pH, however majority of the boreholes

Conditions Level of Reason for audit finding compliance

affected, alternative sources of water will be provided, as exceeded the WUL limits for sodium, calcium, magnesium and sulphate. Half the boreholes exceeded appropriate. the WUL limits for chloride. Groundwater abstraction via the boreholes at RBMR has ceased. Sampling of surface water and groundwater is done by Aquatico. The 2019 IWWMP compiled by Aurecon indicated that there are currently 37 active surface water quality monitoring points including the process water monitoring points. It was detailed in the report that Sulphate and the trace heavy metal, nickel, are largely associated with the operations at RBMR. The highest risks to surface water is the RBMR pollution control dams. At PMR the groundwater borehole level is recorded during each monitoring event (quarterly) and included in the monitoring reports.

The groundwater borehole level is recorded during each monitoring event (quarterly) and included in the monitoring reports.

Water quality analyses should include standard major C Based on the contents of the water quality report, all of these determinants are monitored with the anions (sulphates, chlorides, nitrate, alkalinity, ammonia), exception of bacteria (i.e. faecal coliforms). Monitoring is done in accordance to the WUL issued for cations (Na, K Ca, Mg), total dissolved solids, total the operations and is deemed to supersede this condition. It is advised that this condition be aligned suspended solids, conductivity (on-site), pH (on-site) and with the WUL monitoring requirements by means of an amendment application. faecal coliforms. According to the 2019 annual water quality data (Groundwater Complete, 2019), all boreholes were compliant with the WUL limits for pH, however majority of the boreholes exceeded the WUL limits for sodium, calcium, magnesium and sulphate. At PMR, water is only discharged to the river if the quality can be confirmed within discharge limits and within the allowances of the WUL. Sampling is undertaken at the holding dam prior to final discharge.

Use of potable water to be kept to a minimum, by C The process water is recycled. Water is processed in a closed system. recycling.

Monitoring of water quality in boreholes will continue as PC According to the 2020 WUL Audit groundwater monitoring is conducted and results submitted to the part of the Retained Operation’s groundwater monitoring DHSWS on a quarterly basis. According to the 2019 annual water quality data (Groundwater programme, to ensure that any contamination is detected Complete, 2019), all boreholes were compliant with the WUL limits for pH, however majority of the timeously. Appropriate rehabilitation measures will be boreholes exceeded the WUL limits for sodium, calcium, magnesium and sulphate. Half the boreholes taken if the monitoring indicates that unacceptable levels exceeded the WUL limits for chloride. It is understood that the limits specified in the WUL are very of contamination in the groundwater have occurred. stringent and may not be achievable and therefore the WUL may need to be amended to address this. In addition to this, the condition refers to ‘appropriate rehabilitation measures’ which is not specific and needs to be amended. The auditor is aware of the Water Action Plan Phase 2 Concept Study developed by Anglo American and Aurecon in 2015. This plan fits into the overall Anglo American Group Water Strategy and includes possibilities of abstraction of groundwater for remediation purposes. It is the auditor’s understanding that the Retained Operations have in the past investigated methods of abstraction of groundwater for remediation purposes however a partial compliance has

Conditions Level of Reason for audit finding compliance

been awarded as it is not certain if any of these practices are still being implemented. w Various action plans are in place to

Original drainage patterns will be maintained, where C Based on the site walkover, the surrounding drainage patterns remain; the operational areas are fully possible. transformed and operate with closed loop water reticulation systems.

All dams, storm-water drains and diversion trenches will C The GN 704 2018 audit report is comprehensive in its assessment of all Rustenburg Section be designed to manage the 1:50 year storm events. operations and notes that most areas within the various operations have been designed to accommodate 1:50 year storm events.

Energy dissipaters will be constructed at points where C Energy dissipaters were observed within the western channel upstream of Dam 3B for BMR and for there are concentrated discharges of water to the Dams 3A and 3B at PMR. environment that could cause significant erosion and within water channels to slow the speed of water.

The laboratory testing the water samples must have a C The laboratory used (Aquatico) follows the South African Bureau of Standards (SABS) water sampling quality assurance program in place. Proof of this must be methods but analysis is done according to internally developed methods which have been accredited submitted with each set of water sample analyses. to ISO 17025 requirements. The laboratory and methods are also accredited/registered with DWS. The SABS sampling methods and the South African National Accreditation System (SANAS) accredited methods are noted in the annual water quality reports complied by Aquatico.

Regular inspections will be carried out to ensure that C The following inspections are undertaken by RPM: water pollution control structures control structures remain in a sound operation condition. The necessary repairs will  SRK Consulting undertake inspections on the dam liners and pumps. The report recommended the be done where needed. replacement of a liner on RBMR Dams 3A and Dam 1 (last year) with Dam 2 relining being planned for 2021  The environmental team undertake visual inspections  The engineering department conduct ad hoc inspections of the infrastructure. Issues are noted on inspection checklists, depending on the operation being inspected.

Compliance with Regulation 704 (Government Gazette C According to the 2018 GN 704 audit report the following applies for the Retained Operations: 20118, 4 June 1999), under the NWA as well as Regulation 527, Government Gazette No. 7949 April  Dirty water runoff from within RBMR is collected in a number of trenches which then drains to the 2004, under the MPRDA, containing regulations specific stormwater dams. The clean water upstream of RBMR is diverted away from RBMR in a number of to water management. trenches and pipes into the Klipfonteinspruit on the northern side of RBMR.  At PMR, stormwater runoff is collected in a number of small trenches within or around PMR. Along the eastern and northern boundaries of PMR, there are clean water trenches to collect the stormwater that would otherwise enter the area. The eastern clean water canal is discharged to the stream flowing along the northern boundary of PMR. The southern portion of the PMR site features

Conditions Level of Reason for audit finding compliance

a clean water cut off berm that discharges water to the west of the site. As this berm runs a distance from the site, a secondary measure is in place to collect and divert water generated between the two structures away from the site.  The ACP plant area drains naturally from north to south. Vertical drains running north to south collect and direct stormwater to a perpendicularly running canal which drains to the ACP dam. The ACP dam has a spillway which will overtop in emergency situations, flowing into the Klipfonteinspruit upstream of the bridge. The internal dirty water system works well and shows signs on good and continual maintenance Ad-hoc checks are conducted by the environmental officer to identify any spills. Chemicals are stored in a bunded area. Internal monthly inspections are undertaken to identify any issues with the bund walls. The incident procedure in the case of significant spillages is noted as the action plan.

Excess water will be pumped to existing dams use in the C According to the GN 704 audit report, Stormwater generated in the Level 2 area is routed via process. stormwater sumps to either stormwater dam 3A or 3B or to the environment. The flow of water is monitored in both stormwater release channels.

Dirty and clean water will be separated by implementing C The latest GN 704 audit was undertaken in 2018. The report notes all measures in place to separate clean and dirty water systems/structures prior to clean and dirty water on site. The report also provides findings and recommendations which should be construction to prevent pollution of clean water runoff. The resolved by RPM to maintain separation. According to the 2018 GN 704 audit report, Dirty water runoff clean and dirty water systems and structures will be from within RBMR is collected in a number of trenches which then drains to the stormwater dams. The properly designed (according to Regulation 704 of the clean water upstream of RBMR is diverted away from RBMR in a number of trenches and pipes into National Water Act). the Klipfonteinspruit on the northern side of RBMR.

Ensure the establishment of storm water diversion berms C The GN 704 report notes ‘deflection berms’ at the Waterval Smelter complex which are built in around the contractor lay down areas and other potential accordance with the requirements of GN 704 to deflect a 1:100 year storm event. contaminated areas (e.g. diesel storage tanks or refuelling stations). The contractor laydown areas are located within the fence line of the processing operations. No specific berms noted around the contractor laydown areas. The laydown areas are located within the stormwater management zone (i.e. channelled to the existing PCDs) therefore berms are not necessarily required.

The diesel storage tanks are contained within the operations dirty water sections and fitted with a sufficient bund wall (the site itself is trenched/bermed around the perimeter which serves to satisfy this commitment).

All hazardous substances must be stored on an C Chemical storage areas are present on level 1 and 2 at the PMR site. The storage areas were impervious surface in a designated bunded area, able to observed to be in good condition. The storage area is bunded and locked with adequate signage. contain 110% of the total volume of materials stored at

Conditions Level of Reason for audit finding compliance

any given time. Storage areas will be well marked with appropriate signage.

Runoff, which is likely to contain suspended solids and C Silt traps and settling ponds are incorporated into the water management systems onsite. sediment, should be routed through a stilling pond to enable sediment to settle prior to discharge.

Design will minimise footprint size of dirty areas. C The slag stockpiling area to the north of the smelting complex lacks any formal design measure to minimise the footprint, however the area is included in the dirty water area of RPM.

Monitoring of water quality in surface water will be done, C Sampling of surface water and groundwater is done by Aquatico. The 2019 IWWMP compiled by upstream and downstream of Retained Operations Aurecon indicated that there are currently 37 active surface water quality monitoring points including activities. the process water monitoring points. It was detailed in the report that sulphate and the trace heavy metal, nickel, are largely associated with the operations at RBMR. The highest risks to surface water is the RBMR pollution control dams Monthly sampling frequency applies to the surface water sampling program. Five samples are taken within the Klipfonteinspruit (both up and downstream) to understand the impact from the facility on water quality. The results are submitted to the DHSWS on a quarterly and annual basis.

A groundwater sampling plan should be established. C The latest IWWMP compiled by Aurecon (January 2019) forms the groundwater sampling plan which outlines the sampling locations and the frequencies of the sampling events.

Ground and surface water sampling frequency should be C Sampling of surface water and groundwater is done by Aquatico. Surface water is sampled monthly on a quarterly basis for the first year to establish a and groundwater is sampled quarterly. seasonal base case situation, then reassessed to a 6 or 12 monthly interval.

Management will be set in place where necessary to C The environmental team is the management team in place to prevent water pollution an oversee all prevent water pollution. monitoring undertaken. Management measures are in place across the retained operations to prevent dirty water discharge into the environment due to the operations.

6. Visual/Aesthetic Paint buildings and structures with colours that reflect and C The buildings were constructed in excess of 10 years ago. Based on site observations, buildings are complement the natural browns and dark greens of the usually grey in colour with some steel structures. The steel structures are usually not reflective due to surrounding landscape. Avoid pure whites (light colours) the age of the facilities. New buildings constructed for the planned projects (such as the copper and pure blacks. debottlenecking plant) need to comply with this condition.

To reduce the potential of glare external surfaces of C The buildings were constructed in excess of 10 years ago. Based on site observations, buildings are buildings and structures should be articulated or textured usually grey in colour with some steel structures. The steel structures are usually not reflective due to

Conditions Level of Reason for audit finding compliance

to create interplay of light and shade. Avoid shiny or bare the age of the facilities. New buildings constructed for the planned projects (such as the copper metal. debottlenecking plant) need to comply with this condition.

An ecological approach to landscaping is recommended. C Landscaping is an on-going activity and is done to maintain the aesthetic of the sites. The activity does Should plants be introduced into the project, choice not take an ‘ecological’ approach. In general, landscaping is limited to maintenance; annually, should be guided by ecological rather than horticultural indigenous trees are planted on arbour day. The condition is marked compliant as the use of principles. indigenous trees is considered to be ecological.

Appropriate dust control, suppression and rehabilitation C Dust monitoring undertaken on a monthly basis by Aquatico. Most recent report is dated June 2020. methods will be implemented where required and Dust levels recorded were compliant and no dust related issues were observed at the time of the audit. monitoring will take place.

The natural colours of the soils in the area will be NA No new roads were constructed during the audit period. considered if the road surface is to be paved.

Install light fixtures that provide precisely directed NA Commitment refers to shaft complex therefore noted as not applicable.It is recommended that this illumination to reduce light “spillage” beyond the condition be removed by means of an EMPR amendment. immediate surrounds of the shaft complex – this is especially relevant where the edge of the complexes are exposed to residential properties.

Light pollution should be seriously and carefully C The site was visited during the day and therefore it is not possible to verify this condition. Based on considered and kept to a minimum wherever possible as observations, lighting appears to be placed at appropriate positions throughout the Retained light at night travels great distances. Security flood lighting Operations. The facilities are not in close proximity to the N4 and the auditor did not observe any and operational lighting should only be used where complaints about lighting within the incidents summary report provided. absolutely necessary and carefully directed, preferably away from sensitive viewing areas, i.e. the direction of the Magaliesberg and the N4. Wherever possible lights should be directed downwards so as to avoid illuminating the sky.

Keep all unpaved roads moist to prevent dust from C Dust monitoring undertaken on a monthly basis by Aquatico. The most recent report provided to the impairing visibility. auditor was dated May to June 2020. Dust levels recorded were compliant and no dust related issues were observed at the time of the audit.

Local indigenous plants will be preferred, where suitable, NA It is assumed by the auditor that this condition relates to rehabilitation and closure. Rehabilitation was to ensure sustainable growth and performance to reduce not undertaken during the audit period. maintenance requirements.

Conditions Level of Reason for audit finding compliance

Following vegetation, aftercare is generally required until NA Rehabilitation was not undertaken during the audit period. Rehabilitation is required at the effluent dam about 75% of the cover consists of indigenous species. at RBMR and will comply to the requirements within the S&SD specification for rehabilitation (AA SSDG MC001) which was provided to the Auditor.

The collection and sale of firewood must be discouraged. NA The collection and sale of firewood does not occur at the site. It was noted in the pre-audit meeting that this condition is to be removed.

Where the natural vegetation intrudes onto the site it will NA The facilities maintain a firebreak (1 m) for health and safety as well as veld fire reasons. As such, be retained. vegetation around the facility is removed as part of on-going landscaping. It is recommended that this condition be removed by means of an EMPR amendment.

All external surfaces should have a self-generating NA RPM’s area of responsibility ends at the boundary line of its operation fence line. RPM does not vegetation cover compatible with the surrounding monitor grassed areas surrounding its operations (i.e. external surfaces). environment. It is recommended that this condition be removed by means of an EMPR amendment.

7. Noise and Vibration High level of maintenance of all equipment, especially C Area noise assessments have been conducted and noise levels are below the limit of 85 dB. No diesel powered equipment. Regular noise testing will be issues have been raised concerning noise levels. Occupational noise testing is undertaken by the done. occupational department on the mine. The internal occupational hygiene team undertake noise monitoring throughout the site to ensure noise level compliance. An Area noise schedule was provided to the auditor which indicates the different areas that are surveyed at RBMR. Noise surveys for the various areas within PMR and the Waterval Complex have been provided to the Auditor.

Undertake to do noise surveys and implement remedial C Same as above. actions if found to be higher than legally recommended.

Noise can be reduced by ensuring that all machinery and C Same as above. trucks are maintained in good running order.

8. Air Quality Speed limits will be adhered to at all times (40km/h). C The speed limit is included in both the induction and site signage. The speed limit in most plant areas is 20 km/h. The road leading to the Smelter is limited to 30 km/h.

All roads most frequently used should either be tarred or C Roads associated with the refineries are mostly tarred. Areas within the Waterval Smelter complex are mitigation measures to reduce dust to acceptable limits tarred. must be put in place. Generally, a sweeper routinely sweeps the tarred roads within the fence line as well as the tarred road

Conditions Level of Reason for audit finding compliance

leading up to the railroad crossing on the east of the ACP

Dust should be managed by wetting the roads C Generally, a sweeper routinely sweeps the tarred roads within the fence line as well as the tarred road periodically. The frequency of wetting will depend on the leading up to the railroad crossing on the east of the ACP. Additional speed bumps on the tarred roads number and speed of the trucks. The contractor should not deemed necessary as no incidents have occurred and no dust issues have occurred. draw up a schedule for this activity. Speed bumps should be constructed to assist in reducing dust made by speeding vehicles.

An AQMP will be compiled for RPM-RS, containing PC A formalised air quality management plan (AQMP) is not in place for the operations however air quality timeframes and target values for reducing PM10 levels (emissions and dust) is managed and monitored by the various operations in the following manner: and moving towards best practise and international standards.  Comply with national and international standards (International Finance Corporation - IFC) through complying with the requirements in the Atmospheric Emissions Licences (monitoring the objectives of local and international standards)  Have an inventory of existing anticipated source emissions as well as receptors for the life of the Retained Operations  Dust control measures in place  Monitoring of dust and emissions  Conduct Internal AEL compliance reviews to ensure continued compliance and address any areas of non-compliance; and  Adherence to the Anglo American Technical Standards (GTS) for air quality management

According to the latest air quality monitoring report (May-June 2020), PM10 levels are well below the South African National Ambient Air Quality Standards (SA NAAQSs) and international guidelines.

A partial compliance has therefore been allocated to this condition as, while there is no formal plan in place, the objectives of a AQMP are being met by the various activities been undertaken to monitor and manage air quality impacts.

It is suggested that this condition is amended to remove the reference to the AQMP and refer to current monitoring and management practices taking place at the Retained Operations.

Monitor air quality in and around the Retained Operations C Dust monitoring undertaken on a monthly bases by Aquatico. The latest air quality monitoring report area on a monthly basis. was provided to the auditor to review. (May-June 2020). PM10 levels were found to be compliant.

Vehicles will be regularly serviced according to pre- C According to the Retained Operations Environmental Officer, each vehicle, if plant hire or resident planned maintenance programmes. The drivers will be vehicle, is accompanied by a service record (within the contractor file or maintenance department’s

Conditions Level of Reason for audit finding compliance

properly trained. office). the record provides clarity on when the next service is required.

All releases to the environment will be within the legal C Each of the retained operations has an AEL specific to the related operations (ACP and Smelter have requirements as specified in permit requirements etc. a combined AEL). Each of the relevant Environmental Officers monitor for exceedances on real-time stack monitoring equipment. Any dust bucket exceedances would be reported in the monthly reports compiled by Aquatico. No exceedances were noted for the latest dust monitoring records provided (Report dated May-June 2020).

If significant dust impacts are noted, the affected soil C As above. environment should be monitored to determine the extent of the impact on the soil environment and amelioration measures implemented if necessary.

The waste rock dump, tailings dam, topsoil stockpiles and NA No waste rock dumps, tailings dam, or topsoil stockpiles are located onsite. any dirt roads that are used regularly will be watered to minimise dust emissions to within the legal requirements No dust related issues relating to the roads were reported for this audit period. All internal roads are and to prevent dust from impairing on visibility. tarred.

The SO2 emissions must not exceed the permit or the C Ambient SO2 is monitored at eight locations in the study area. According to the Atmospheric Impact legislative values. Report (Airshed, December 2018), During the 2014 to 2017 monitoring period, sampled annual average SO2 concentrations were in compliance with the SA NAAQS at all eight sampling locations. Hourly and daily SO2 concentrations exceeded the SA NAAQS at the Paardekraal sampling location during 2016 but were in compliance with the SA NAAQS during 2014, 2015 and 2017. Sampled hourly and daily SO2 concentrations were in compliance with the SA NAAQS at the other seven sampling locations for the entire period from 2014 to 2017. Based on the 2019 Atmospheric Emissions Survey report compiled by C&M Consulting Engineers, SO2 was below the detection limits at all measured sources within RBMR.

The air quality will be monitored continuously and when C Monthly dust fallout monitoring reports are issued by Aquatico. The dust buckets are located in unacceptable levels are not reached corrective measures strategic locations around the RPM processing operations. will be adopted. In addition, a 24 hourly report is obtained from the eight ambient air quality stations noting exceedances, primarily in relation to SO2 concentrations.

The processing operations stacks are monitored on a real-time basis as well as annual isokinetic monitoring events on stacks.

An online PM10 continuous monitor will be installed on C In-stack monitors detect PM10 concentrations leaving the point source. Ambient air quality stations site and the results will be compared with those from the between the operations detect the ambient PM10 concentration. Measures are applied as per the AEL

Conditions Level of Reason for audit finding compliance

current monitoring methods. If necessary total particulate requirements levels in the air will also be monitored on a continuous basis.

The Anglo Platinum and Regional Air Quality PC A formalised AQMP is not in place for the operations however air quality (emissions and dust) is Management Plans will be made available to the managed and monitored by the various operations in the following manner: authorities and I&APs for their comment and review.  Comply with national and international standards (IFC) through complying with the requirements in the Atmospheric Emissions Licences (monitoring the objectives of local and international standards)  Have an inventory of existing anticipated source emissions as well as receptors for the life of the Retained Operations  Dust control measures in place  Monitoring of dust and emissions  Conduct Internal AEL compliance reviews to ensure continued compliance and address any areas of non-compliance; and  Adherence to the Anglo American Technical Standards (GTS) for air quality management

According to the latest air quality monitoring report (May-June 2020), PM10 levels are well below the South African National Ambient Air Quality Standards (SA NAAQSs) and international guidelines.

It is suggested that this condition is amended to remove the reference to the AQMP and refer to current monitoring and management practices taking place at the Retained Operations.

Anglo Platinum will participate in the drawing of a plan to C It is the Auditor’s understanding, based on discussions with the Environmental Manager for the manage baseline particulates of the region. Platinum Process Operations (Mr Dustin van Helsdingen) that this condition is being implemented in the following manner:

 Being managed as part of the offset plan being implemented as part of the postponements related to Waterval Smelter.  Dust buckets have been installed in the Mfidikwe community for monitoring purposes.  An Ambient station network is installed throughout operating and outside RPM’s operating areas to monitor ambient air quality

Conditions Level of Reason for audit finding compliance

Short- to medium-term (temporary) erosion and dust C Dust monitoring undertaken on a monthly basis by Aquatico. Most recent report is dated May-June control measures include watering, chemical suppression, 2020. Dust levels recorded were compliant indicating that dust control measures are working the construction of windbreaks, and plough ridging. effectively. Various dust control measures are in place at the Retained Operations.

The Air quality framework will be used to draw up detailed NA Since the operation is not in the construction or closure phases it is assumed that this condition will air quality management plans for the project (for all apply to the operations phase as well as for any new projects which are constructed as part of the phases of the project). Retained Operations.

A formalised AQMP is not in place for the operations however air quality (emissions and dust) is managed and monitored by the various operations in the following manner:

 Comply with national and international standards (IFC) through complying with the requirements in the Atmospheric Emissions Licences (monitoring the objectives of local and international standards)  Have an inventory of existing anticipated source emissions as well as receptors for the life of the Retained Operations  Dust control measures in place  Monitoring of dust and emissions  Conduct Internal AEL compliance reviews to ensure continued compliance and address any areas of non-compliance; and  Adherence to the Anglo American Technical Standards (GTS) for air quality management

It is suggested that this condition is amended to remove the reference to the AQMP and refer to current monitoring and management practices taking place at the Retained Operations.

Dust monitoring to be taking place. C Dust monitoring undertaken on a monthly basis by Aquatico. Most recent report is dated May-June 2020. Dust levels recorded were compliant indicating that dust control measures are working effectively.

Anglo Platinum is committed to implement an Air Quality PC A formalised AQMP is not in place for the operations however air quality (emissions and dust) is Management Plan for its operations, which will address managed and monitored by the various operations in the following manner: the following: Objectives for compliance with local and international standards.  Comply with national and international standards (IFC) through complying with the requirements in the Atmospheric Emissions Licences (monitoring the objectives of local and international standards)  Have an inventory of existing anticipated source emissions as well as receptors for the life of the Retained Operations  Dust control measures in place  Monitoring of dust and emissions  Conduct Internal AEL compliance reviews to ensure continued compliance and address any areas of non-compliance; and

Conditions Level of Reason for audit finding compliance

 Adherence to the Anglo American Technical Standards (GTS) for air quality management

According to the latest air quality monitoring report (May-June 2020), PM10 levels are well below the South African National Ambient Air Quality Standards (SA NAAQSs) and international guidelines.

It is suggested that this condition is amended to remove the reference to the AQMP and refer to current monitoring and management practices taking place at the Retained Operations

Anglo Platinum is committed to implement an Air Quality PC As above Management Plan for its operations, which will address the following: An inventory of existing and anticipated sources and receptors of dust for the life of the Retained Operations.

Anglo Platinum is committed to implement an Air Quality PC As Above Management Plan for its operations, which will address the following: Full details of dust control measures during the life of the Retained Operations.

Anglo Platinum is committed to implement an Air Quality PC As Above Management Plan for its operations, which will address the following: Identification and description of appropriate source and receptor based performance criteria that can be demonstrated as being effective.

Anglo Platinum is committed to implement an Air Quality PC As Above Management Plan for its operations, which will address the following: Identification of ambient air-quality thresholds and contingency measures that will be adopted if these are exceeded.

Anglo Platinum is committed to implement an Air Quality PC As Above Management Plan for its operations, which will address the following: A comprehensive monitoring and assessment system.

Conditions Level of Reason for audit finding compliance

A dust fall out monitoring system will be implemented on C Dust monitoring undertaken on a monthly basis by Aquatico. Most recent report is dated May-June the project site. 2020. Dust levels recorded were compliant indicating that dust control measures are working effectively.

9. Waste Management A procedure for the storage, handling and transportation C Waste is managed via waste separation methods at all of the Retained Operations. Riverside is of the different hazardous materials must be drawn up contracted for all waste management. Wastes which cannot be recycled are transferred to the and strictly enforced. Rustenburg Local Municipality (RLM) Landfill site (general waste) or taken to the Interwaste hazardous waste disposal site. Waste storage sites at the Retained Operations were audited and no issues were noted. Skips are used for hazardous waste. Biohazard waste is sent to Athermal for incineration. Medical waste is taken by Buhle Waste. The operations are trying to limit waste to landfill and are aiming for the drive to zero waste to landfill.

Non-recyclable items should be sold to vendors as scrap C As above and items with no value disposed of at an appropriate permitted waste site.

Industrial waste should be routed via the central salvage C As above site for recycling. Industrial waste and domestic waste that cannot be recycled will be disposed of in the permitted non-hazardous waste site.

All waste will be disposed of according to the principles of C As above re-use, reduce or re-cycle. The services of a private waste disposal contractor will be utilized in the absence of a suitable facility within the Retained Operations area.

All waste will be disposed of in an environmentally C As above responsible manner and within the requirements of applicable legislation.

All hazardous waste such as old oil and oil filters, paint C As above tins, chemical waste, grease tins, antifreeze drums and reagents should be disposed of at a registered hazardous waste disposal site.

All Non-hazardous waste to be disposed of in a permitted C As above non-hazardous waste site.

Conditions Level of Reason for audit finding compliance

Any new waste disposal sites must be constructed so as NA According to discussions with the Retained Operations Environmental Officer, no new waste sites are to prevent leachate from reaching the groundwater. planned. All hazardous waste is disposed of via a contractor to the Interwaste Hazardous waste site.

Water spray must be used at waste handling (wash waste NA Waste is not washed of fines at any of the retained operations. Pre-November 2016, waste washing to remove fines). was done at the central salvage yard. Given that the salvage yard is now operated by Sibanye, the washing activity no longer takes place for the purposes of RPM operations. It is recommended that this condition be removed by means of an EMPR amendment.

Hazardous waste will be transported off site to the nearest C Waste is managed via waste separation methods at all of the Retained Operations. Riverside is licensed hazardous waste facility. contracted for all waste management. Wastes which cannot be recycled are transferred to the Rustenburg Local Municipality (RLM) Landfill site (general waste) or taken to the Interwaste hazardous waste disposal site. Waste storage sites at the Retained Operations were audited and no issues were noted. Skips are used for hazardous waste. Biohazard waste is sent to Athermal for incineration. Medical waste is taken by Buhle Waste. The operations are trying to limit waste to landfill and are aiming for the drive to zero waste to landfill.

Indiscriminate dumping, which is likely to be localised and NC The ‘Plant Change Notification Procedure (version 10.0)’ is applied to all new projects which includes infrequent, should be reported to the Retained consideration of the environmental personnel when dealing with operational projects and the Operation’s environmental manager and rectified. environmental manager when dealing with capital expenditure projects. The procedure was provided to the auditors.

Measures implemented to address the non-compliance

Conditions Level of Reason for audit finding compliance

been a commitment for the coal to be removed over the next month. An action was raised on Enablon (verified by the Auditor).

Practicality of the EMPr commitment

The condition is considered practical.

Non-compliance administrative or will have an impact

It is considered that the placement of the coal stockpile on bare ground would have an impact on the environment.

Historical/new non-compliance

Anglo Platinum will develop and adhere to the existing C Waste is managed via waste separation methods at all of the Retained Operations. Riverside is RPM waste management protocol. contracted for all waste management. Wastes which cannot be recycled are transferred to the Rustenburg Local Municipality (RLM) Landfill site (general waste) or taken to the Interwaste hazardous waste disposal site. Waste storage sites at the Retained Operations were audited and no issues were noted. Skips are used for hazardous waste. Biohazard waste is sent to Athermal for incineration. Medical waste is taken by Buhle Waste. The operations are trying to limit waste to landfill and are aiming for the drive to zero waste to landfill.

Ongoing training and protection equipment use by C Site specific induction presentations are presented to new employees and visitors. As part of the site employees. audit, SRK undertook induction as well as Covid-19 training. Refresher inductions are conducted annually. In addition, toolbox talks are held in the different sections, using site specific training material. Several examples of tool box talks were made available to the auditor for review. Training is conducted in line with the Training, Awareness and Competence Procedure (Ref No ACP-ALL-SHE- PRO-0002 – April 2019) which specifies the types and levels of training required for internal staff and external contractors and visitors.

Employees were noted to be using the correct PPE in all areas observed during the site visit. A Personal Protective Equipment (PPE) register is maintained for all staff.

Rehabilitated land will be inspected regularly to ensure NA There are no RPM related rehabilitated areas, therefore this condition is not applicable.

Conditions Level of Reason for audit finding compliance

that further pollution or dumping does not take place.

Borrow pits and non-hazardous waste sites will be NA No borrow pits formed part of this audit. All waste sites are contained within the operations boundary backfilled with waste rock where necessary, landscaped fence line, and therefore this commitment is not considered applicable. The operations do not require with topsoil and re-vegetated. borrow pits therefore it is recommended that this condition is amended.

Any contaminated soils will be removed and disposed of C Waste is managed via waste separation methods at all of the Retained Operations. Riverside is at a permitted hazardous waste site before landscaping contracted for all waste management. Wastes which cannot be recycled are transferred to the and re-vegetating. Rustenburg Local Municipality (RLM) Landfill site (general waste) or taken to the Interwaste hazardous waste disposal site. Waste storage sites at the Retained Operations were audited and no issues were noted. Skips are used for hazardous waste. Biohazard waste is sent to Athermal for incineration. Medical waste is taken by Buhle Waste. The operations are trying to limit waste to landfill and are aiming for the drive to zero waste to landfill.

Minimise waste generation by using non-hazardous C As above material where possible.

Include waste disposal procedures in Contractors Site C Based on discussions between the auditor and the supply chain/procurement department it was Rules. confirmed that certain procedures are incorporated into contracts depending on the nature of the contract. The Retained Operations Environmental Officer confirmed that the waste management procedure is included in the contract for the Waste contractors and that all contractors are required to comply to all site procedures. The Auditor has received the Waste Management Procedure (ACP-ALL- ENV-PRO-0024) for the operations which includes the waste disposal procedure.

According to the contractor’s procedure (ACP-ALLSM-EPR-ENG-STD-006) the contractor will safely manage and supervise its workforce on the Smelter site in accordance with applicable legislation, Smelter procedures and in keeping with Anglo Platinum’s values. Records of all waste being taken off site must be recorded C The original safe disposal certificates are filed at the Environmental Coordinator’s office. The Auditor and kept as evidence. has reviewed a few copies of these certificates for verification that this condition is being complied with.

General waste must be disposed of an approved waste C Waste is managed via waste separation methods at all of the Retained Operations. Riverside is disposal facility which must be made available for all contracted for all waste management. Wastes which cannot be recycled are transferred to the RLM employees to use. Landfill site (general waste) or taken to the Interwaste hazardous waste disposal site. Waste storage sites at the Retained Operations were audited and no issues were noted. Skips are used for hazardous waste. Biohazard waste is sent to Athermal for incineration. Medical waste is taken by Buhle Waste. The operations are trying to limit waste to landfill and are aiming for the drive to zero waste to landfill.

Conditions Level of Reason for audit finding compliance

All waste must be sorted and stored in clearly marked C As above containers.

All existing and new stormwater management C The GN 704 2018 audit report is comprehensive in its assessment of all Rustenburg Section containment facilities will be designed to cater for the 1:50 operations and notes that most areas within the various operations have been designed to year 24-hour storm event. accommodate 1:50 year storm events. Going forward the operation will continue to cater for the 1:50 year 24 hour storm event.

Spillages of oil, grease and hydraulic fluids will be cleaned C Spill kits are present at different locations around the site. Drip trays are also used on site. The red kits up by removing the soil and disposing such soil in a waste represent chemical spill response kits, whereas green represents an oil spill response kit. Each area is receptacle or at a licensed site, or through biological responsible for stocking its own spill kits. A generic inspection checklist is used to monitor the spill kits. treatment. No use of biological treatment applied at the site or noted within Enablon records. No major spills have occurred in the last 6 months

Rubble and industrial waste to be discarded in the C Waste is managed via waste separation methods at all of the Retained Operations. Riverside is permitted non-hazardous waste site. contracted for all waste management. Wastes which cannot be recycled are transferred to the RLM Landfill site (general waste) or taken to the Interwaste hazardous waste disposal site. Waste storage sites at the Retained Operations were audited and no issues were noted. Skips are used for hazardous waste. Biohazard waste is sent to Athermal for incineration. Medical waste is taken by Buhle Waste. The operations are trying to limit waste to landfill and are aiming for the drive to zero waste to landfill.

10. Socio-economic Prophylactics will be provided free of charge to C RPM is required to operate in line with the Anglo American HIV/AIDS policy and workplace employees in order to reduce the risk of spreading programmes where free anti-retrovirals have been provided to their employees since 2002. HIV/AIDS and other sexually transmitted diseases within local communities. Will be in line with Anglo Platinum policies and practices.

Strict penalties will be built into tenders to deal with issues C It is the understanding of the Auditor, based on discussions with the Supply Chain and Procurement such as petty crime, stock theft, fence cutting, representatives, no penalty clause is included in the general terms and conditions which forms the trespassing, the closing of farm gates etc. basic contract. A clause for termination is included to indicate to the supplier that if the supplier is not following the terms and conditions, RPM can give them time to remedy the issues and if they cannot then they will terminate the contract. Specific penalties are included depending on the nature of the contract requested by the end user (RPM person who wants the contract).

Keep a ”Public Complaints Register” each site at all times. C A site complaints register is available at the site entrance. All complaints received are tracked using the Enablon software; the auditor was shown a complaints register dating back to 2010 until current which is recorded on Enablon. RBMR has a communication, participation and consultation operational

Conditions Level of Reason for audit finding compliance

procedure which has been provided to the auditor (latest revision date: 2020/06/08). All relevant stakeholders are contacted and communicated with on an on-going bases. A public participation communication and consultation procedure has been compiled and provided to the Auditor.

First aid station will be available on site, other cases to be C Waterval Smelter has a clinic on site to assist with minor injuries referred to the existing hospital.

Anglo Platinum must advertise all open jobs in the C It is the Auditor’s understanding, based on discussions held with Ms Estie Rupp and Ms Tumi neighbouring communities through established and Mathebula from Supply Chain and Procurement that the following procedures are in place to ensure legitimate community-based employment forums. that jobs are advertised as widely as possible within the direct area surrounding the Retained Operations:

The community-based employment must submit to Anglo C The Retained Operations have a website on the Anglo-American website listed under ‘tools for Platinum their skills audits. These would facilitate an suppliers’ where suppliers can register their entity open, transparent and equitable selection process. This is would decrease the likelihood of conflict arising as well as Based on discussions held between the Auditor and the Senior Social Performance Manager (Process concerns that local people are not provided ample job Division Services), Ms Tumelo Dilotsotlhe, the community-based employment system (known as the opportunities. Page-up system) is currently under review. Previously (up until August 2020) the ‘Page-Up System’ allowed for communities to apply for opportunities within the Retained Operations. If a contractor required specific services then the contractor would independently source and interview people based on the information which was available on the Page-up system. The contractor would then submit a report to the Retained Operations in terms of the number of people employed and the duration thereof.

Conditions Level of Reason for audit finding compliance

This would be reported in terms of the job creation to the community engagement forum (CEF). The CEF is currently under review to align it with the new requirements for establishment of community engagement structures or accountability forums within the area of operation to Version 3 of the Anglo Social Way. As such, RPM are going to introduce to the change as per the new transitional plan on the Anglo Social Way. There are various stakeholders that RPM be meeting with to introduce the changes (including the municipality, the Royal Bafokeng administration and internal stakeholders). A transition plan (that was signed off recently) includes actions in terms of engagements (Requirement 3A).

Hiring locally, making minor adjustments in plans or C Based on discussions held between the Auditor and the Senior Social Performance Manager (Process infrastructure to suit community needs and developing Division Services), Ms Tumelo Dilotsotlhe, the community-based employment system (known as the local suppliers of goods and services increases positive Page-up system) is currently under review. Previously (up until August 2020) the ‘Page-Up System’ impacts at minimal costs to the business, as far as legally allowed for communities to apply for opportunities within the Retained Operations. If a contractor possible. required specific services then the contractor would independently source and interview people based on the information which was available on the Page-up system. The contractor would then submit a report to the Retained Operations in terms of the number of people employed and the duration thereof. This would be reported in terms of the job creation to the CEF. The CEF is currently under review to align it with the new requirements for establishment of community engagement structures or accountability forums within the area of operation to Version 3 of the Anglo Social Way. As such, RPM are going to introduce to the change as per the new transitional plan on the Anglo Social Way. There are various stakeholders that RPM be meeting with to introduce the changes (including the municipality, the Royal Bafokeng administration and internal stakeholders). A transition plan (that was signed off recently) includes actions in terms of engagements (Requirement 3A).

In addition to this, RBMR has a communication, participation and consultation operational procedure which has been provided to the auditor (latest revision date: 2020/06/08). All relevant stakeholders are contacted and communicated with on an on-going bases. A public participation communication and consultation procedure has been compiled and provided to the Auditor.

Anglo Platinum must provide its permanent employees C Based on discussions between the Auditor and the Retained Operations Environmental Officer, AAP with housing facilities in accordance with its current provides housing facilities to its employees in line with the housing policy. housing policy guidelines.

Anglo Platinum Housing Forum may also look into a C No squatting issues noted to warrant development of a policy however based on discussions between possible collaborative provision of housing with the local the auditor and the Senior Social Performance Manager (Mrs Tumelo Dilotsotlhe), in terms of the authorities’ (BPDM and RLM). This would strengthen the Anglo Social Way Version 3, the operations are looking at the issue of possible in-migration into the initiative to address the squatting problem in the study area surrounding the Retained Operations. They have zoomed into one of the specific requirements in terms of Anglo Social Way Version 3 with a particular focus on the informal settlement around RBMR

Conditions Level of Reason for audit finding compliance

area. specifically (Bolana). A study will be carried out to establish what next actions should be taken with regards to Bolana. This study will commence this year (2020) with a request submitted to the PMC (Exco) requesting that the operations conduct an investigation. Following the approval by the PMC they will proceed. This process will formally start in the beginning of 2021. If approval is received then the Retained Operations will procure the services of the service provider so that the work can commence early 2021. This study will consider the views and involvement of various stakeholders including the District and Local Municipality.

Anglo Platinum’s top management (at Board level) needs C Tumelo Dilotsotlhe is the allocated CED manager responsible for carrying out the objectives of the to ensure that its designated community development Anglo social strategy. Tumelo is qualified to fill the role. Tumelo is assisted by community development officers understand and are empowered to implement the officers. company’s approved social responsibility policies and programmes.

It should be incumbent on the designated officers to C RBMR has a communication, participation and consultation operational procedure which has been communicate and ensure the understanding of the provided to the auditor (latest revision date: 2020/06/08). All relevant stakeholders are contacted and relevant policies by the local people. communicated with on an on-going bases. A public participation communication and consultation procedure has been compiled and provided to the Auditor

Since the company will be operating in the area for a long C The process academy has the aim of training youth from the local communities with the intent of period, it is feasible to begin training community members integrating the graduates into Anglo operations. The graduates are provided with certificates to ensure to take on skilled employment in the company or in the that they can search for employment elsewhere, if there is no role available at the Anglo Rustenburg open market. Such training programmes would be a processing operations. There is no clear collaboration with local government. potential area for partnerships with local government. Anglo Platinum can co-ordinate with government skills training or extension programmes to help train the local workforce.

Systematically linking community development with core C Core business operations are focused on the end-product being base and precious metals. The business operations, however, involves integrating retained operations are related to secondary and tertiary mineral processing. The process academy concern for development impact into decision-making opportunities are angled at training community members with the intension of those members processes throughout business operations. becoming part of the core business strategy. The primary mechanism of integrating concern of development impact on the project decisions is the environmental approval process conducted as a legal requirement. The intent is for the project team to present the operations intentions as part of the CEF engagements to ensure the local leadership are fully aware of the company’s intentions.

Encourage newcomers to settle within already developed C RBMR has a communication, participation and consultation operational procedure which has been

Conditions Level of Reason for audit finding compliance

areas by providing pull-factors such as housing, water provided to the auditor (latest revision date: 2020/06/08). All relevant stakeholders are contacted and supply etc so that destruction of undisturbed areas due to communicated with on an on-going bases. squatting does not occur. A public participation communication and consultation procedure has been compiled and provided to the Auditor

During the site audit. there was no evidence of squatting directly adjacent to the processing operations.

The Retained Operation’s will participate in the C A Social Economic Development (SED) roadmap (which is aligned with the SED requirement in the development of the social development plan for the region Anglo Social Way) has been developed for the Rustenburg Operations. This was confirmed through i.e. SMME and large business if economically viable, set discussions between the auditor and the Senior Social Performance Manager (Process Division in place (Will be in line with Anglo Platinum policies and Services), Ms Tumelo Dilotsotlhe. The SED is currently being reviewed to align with the new Anglo- practices). American Social Way, Version 3 which the Auditor has received.

Members of the public to be invited for site visits to the NC There have been no requests by the members of the public to visit the site. RPM has made no Retained Operations (six monthly basis). requests to the public to visit the site. Due to health and safety considerations, this condition is not practical and should be removed.

Measures implemented to address the non-compliance

No measures have been undertaken to date. The condition will be amended as part of the EMPr update scheduled for 2020.

Practicality of the EMPr commitment

The condition is considered not practical due to health and safety concerns.

Non-compliance administrative or will have an impact

This is considered as an administrative non-compliance which will not impact on the environment.

Historical/new non-compliance

Historical as it was identified as part of the previous Environmental audit.

Recreational facilities to be privatised where possible, NA No recreational facilities noted on the site during the site audit. with reduced Project subsidies being offered. Will be in line with Anglo Platinum policies and practices.

Conditions Level of Reason for audit finding compliance

Discussions will be held with the South African Police C A Memorandum of Understanding (MOU) is in place with the South African Police Service (SAPS) in Services regarding the policing of the area and the accordance with RPMs risk assessment report. potential influx of outsiders to the area. Will be in line with Anglo Platinum policies and practices.

Redeployment will be undertaken as far as possible. NA No new projects noted within this audit period which warranted redeployment. Based on discussions Suitable people will be redeployed within Anglo Platinum, held between the Auditor and the Senior Social Performance Manager (Process Division Services), Ms in new projects. Tumelo Dilotsotlhe, the process academy is in place to capacitate employees for employment opportunities beyond those held in Anglo Platinum. If opportunities become available internally, existing employees are considered for these.

No forced retrenchment will take place as far as possible. NA No retrenchments noted for this audit period.

The retrenchment process will be undertaken in NA No retrenchments noted for this audit period. consultation with the various labour unions and employees that will be affected.

No recruitment on site will be allowed. C On site recruitment is not allowed. Employment opportunities are advertised through the correct channels

A liaison officer will be appointed for further C Tumelo Dilotsotlhe is the allocated CED manager responsible for carrying out the objectives of the communication between Mines, Retained Operations the Anglo Social Way. Tumelo is qualified to fill the role. Tumelo is assisted by a team comprising of the municipalities and communities. following staff:

 Stakeholder engagement officer (develops the stakeholder engagement plan)  LED officers (responsible for monitoring the implementation of SED projects  Stakeholder engagement liaison officer (responsible for community liaison)  Assistance from the Anglo Zimele Hub (responsible for implementing youth programmes and socio-economic development programmes)

The municipalities will be invited to visit the site at least C Based on discussions between the Auditor and the Senior Social Performance Manager, regular once per annum. engagements take place with the municipality. Some of these engagements are programme specific – on a weekly basis Mrs Dilotsotlhe reports on the Covid-19 initiatives which AAP are supporting within the municipal area and there is a local command council where Mrs Dilotsotlhe presents a report every Friday. Mrs Dilotsotlhe indicated that the municipality visit the site based on their own requirements and these visits take place on an ad hoc basis mainly to conduct inspections that are programme specific (for example the programme related to the current Covid-19 pandemic where inspections are conducted for compliance to the Regulations). Within the auditing period, the last visit conducted by the municipality was to RBMR to discuss public safety (from the public safety division of the

Conditions Level of Reason for audit finding compliance

municipality).

Anglo Platinum will investigate whether a company policy C No squatting issues noted to warrant development of a policy however based on discussions between on squatting is required. If shown to be necessary, a the auditor and the Senior Social Performance Manager (Mrs Tumelo Dilotsotlhe), in terms of the squatting policy will be developed. Anglo Social Way Version 3, the operations are looking at the issue of possible in-migration into the area surrounding the Retained Operations. They have zoomed into one of the specific requirements in terms of Anglo Social Way Version 3 with a particular focus on the informal settlement around RBMR specifically (Bolana). A study will be carried out to establish what next actions should be taken with regards to Bolana. This study will commence this year (2020) with a request submitted to the PMC (Exco) requesting that the operations conduct an investigation. Following the approval by the PMC they will proceed. This process will formally start in the beginning of 2021. If approval is received then the Retained Operations will procure the services of the service provider so that the work can commence early 2021.

Anglo Platinum will take part in a regional workshop to C RPM take part in regular RLM meetings. Housing is noted as an agenda item. As indicated above, discuss the squatting issues. squatting is not noted as an issue in relation to the processing operations and plans are in place to conduct a study to better understand any issues regarding in-migration specifically in the area surrounding RBMR.

All monitory information, as required by law and the EMP C No formal requests were made by any stakeholders during this audit period. commitments, will be made available to the public on request.

Monitoring data will be made available to any I&AP on C No formal requests were made by any I$As during this audit period. This was confirmed by the records request. checked on Enablon and in the environmental incidents registers.

The issue of upgrading roads will be further discussed NA No roads were planned for upgrade during the audit period. with the provincial administration.

Labour will be retained for the extended operational life of C The Anglo American Rustenburg Section CED is tasked with consulting the Department of labour, with the relevant operations. This will serve to both maximise the assistance of the Human Resources department. In consultation with both the traditional local benefits and to minimise conflict between local leadership (Royal Bafokeng administration) and the department clusters are agreed upon and the communities and the workforce. agreed Cluster 1 communities. There is much debate around the cluster system amongst local leadership. The CED reports that the cluster 1 communities were agreed to. Procurement and employment opportunities are then directed through the relevant cluster (i.e. cluster 1, 2 and/or 3).

Serious consideration will be given to encouraging the C Based on discussions between the Auditor and the Retained Operations Environmental Officer, AAP development of housing in surrounding areas such that provides housing facilities to its employees in line with the housing policy. valuable infrastructure and associated services can

Conditions Level of Reason for audit finding compliance

continue to be used once Retained Operations activities cease.

Labour will be sourced from the nearby formal settlements C The Anglo American Rustenburg Section CED is tasked with consulting the Department of labour, with wherever possible. This will serve to both maximise local the assistance of the Human Resources department. In consultation with both the traditional benefits and to minimise conflict between local leadership (Royal Bafokeng administration) and the department clusters are agreed upon and the communities and the workforce. agreed Cluster 1 communities. There is much debate around the cluster system amongst local leadership. The CED reports that the cluster 1 communities were agreed to. Procurement and employment opportunities are then directed through the relevant cluster (i.e. cluster 1, 2 and/or 3).

The Retained Operations must capture public complaints C A site complaints register is available at the site entrance. All complaints received are tracked using in its EMS. the Enablon software; the auditor received a complaints register dating back to 2010 until current which is recorded on Enablon. RBMR has a communication, participation and consultation operational procedure which has been provided to the auditor (latest revision date: 2020/06/08). All relevant stakeholders are contacted and communicated with on an on-going bases. A public participation communication and consultation procedure has been compiled and provided to the Auditor.

Community development will be in line with Anglo C All community initiatives are aimed at satisfying the objectives of the AAP Social Way policy document. Platinum’s Social Development Programme.

Contractors must be educated about the risk of C It is the Auditor’s understanding, based on discussions held with Ms Estie Rupp and Ms Tumi prostitution and spread of HIV and AIDS. Mathebula from Supply Chain and Procurement that HIV/AIDs awareness is included in all contracts. In addition to this, the Retained Operations host a two day workshop called ‘Responsible Resourcing’ where all aspects regarding contractor management and monitoring are addressed. The operations also undertake audits of potential contractors to ensure that they will be able to comply with the requirements and to provide assistance to the contractors in areas where there are gaps to them being able to achieve this compliance.

Principles of equality, BEE, gender equality and non- C It is the Auditor’s understanding, based on discussions held with Ms Estie Rupp and Ms Tumi discrimination must be implemented. Mathebula from Supply Chain and Procurement that principals of equality, BEE and non-discrimination are included in all contracts. In addition to this, the Retained Operations host a two day workshop called ‘Responsible Resourcing’ where all aspects regarding contractor management and monitoring are addressed. The operations also undertake audits of potential contractors to ensure that they will be able to comply with the requirements and to provide assistance to the contractors in areas where there are gaps to them being able to achieve this compliance.

As part of the Anglo American group of companies, the Retained Operations adhere to the wide range of initiatives which have been developed to promote gender quality as part of Anglo’s commitment to

Conditions Level of Reason for audit finding compliance

human rights. Anglo American Platinum have a Broad Based BEE certificate.

Access to the site must be controlled. C Site access at the processing operations is very strict due to the high value of the smelter matte and RBMR/PMR output. Upon access to the operations, the visitor/employee must go through the relevant induction (including the recent addition of Covid-19 training and screening) and have the correct PPE. Metal detectors are used at each operation to ensure theft is prevented. All equipment entering the site must be accompanied by an equipment register.

Only electrical power will be allowed on site. C No diesel generators were noted at the time of the site audit.

In cases where a majority of employees leave their C Noted by RPM but no outflow noted for the audit period therefore noted as not being applicable. Based allocated housing facilities to stay in informal settlements, on discussions between the auditor and the Senior Social Performance Manager (Mrs Tumelo Anglo Platinum might be expected to understand the Dilotsotlhe), in terms of the Anglo Social Way Version 3, the operations are looking at the issue of social dynamics surrounding the outflow, revise and possible in-migration into the area surrounding the Retained Operations. They have zoomed into one adjust its policies accordingly (Will be done by Housing of the specific requirements in terms of Anglo Social Way Version 3 with a particular focus on the Forum). informal settlement around RBMR specifically (Bolana). A study will be carried out to establish what next actions should be taken with regards to Bolana. This study will commence this year (2020) with a request submitted to the PMC (Exco) requesting that the operations conduct an investigation. Following the approval by the PMC they will proceed. This process will formally start in the beginning of 2021. If approval is received then the Retained Operations will procure the services of the service provider so that the work can commence early 2021.

Educating local people regarding environmental C RBMR has a communication, participation and consultation operational procedure which has been awareness at home will be in line with Anglo Platinum provided to the auditor (latest revision date: 2020/06/08). All relevant stakeholders are contacted and policies and practices. communicated with on an on-going bases. A public participation communication and consultation procedure has been compiled and provided to the Auditor.

Compliance with the Mine safety and Health Act (risk C Based on site observations, employees were observed wearing the relevant PPE. Relevant notice assessment). boards warned of facility dangers. An employee induction or visitors induction is compulsory for all facility employees and visitors. Various risk assessments are conducted including daily work task risk assessments.

Redeployment will be undertaken as far as possible. NA No redeployment or new projects were noted for this audit period Based on discussions held between Suitable people will be redeployed within Anglo Platinum, the Auditor and the Senior Social Performance Manager (Process Division Services), Ms Tumelo in new projects. Dilotsotlhe, the process academy is in place to capacitate employees for employment opportunities beyond those held in Anglo Platinum. If opportunities become available internally, existing employees are considered for these.

Conditions Level of Reason for audit finding compliance

Suitable people will be trained if required to enable NA As above. redeployment within Anglo Platinum.

11. Training and Awareness Training will be targeted to achieve specific outcomes C RBMR has a communication, participation and consultation operational procedure which has been appropriate to the identified target groups and the socio- provided to the auditor (latest revision date: 2020/06/08). All relevant stakeholders are contacted and economic environment of the region. Will be in line with communicated with on an on-going bases. Anglo Platinum policies and practices. A public participation communication and consultation procedure has been compiled and provided to the Auditor.

Site specific induction presentations are presented to new employees and visitors. As part of the site audit, SRK undertook induction as well as Covid-19 training. Refresher inductions are conducted annually. In addition, toolbox talks are held in the different sections, using site specific training material. Several examples of tool box talks were made available to the auditor for review. Training is conducted in line with the Training, Awareness and Competence Procedure (Ref No ACP-ALL-SHE- PRO-0002 – April 2019) which specifies the types and levels of training required for internal staff and external contractors and visitors.

Educating local people regarding environmental C A communication, participation and consultation operational procedure has been provided to the awareness at home will be in line with Anglo Platinum auditor (latest revision date: 2020/06/08). All relevant stakeholders are contacted and communicated policies and practices. with on an on-going bases. A public participation communication and consultation procedure has been compiled and provided to the Auditor. Based on discussions held between the Auditor and the Senior Social Performance Manager (Process Division Services), Ms Tumelo Dilotsotlhe, there are training programmes in place where the emergency preparedness and response teams are trained. This is done through the emergency preparedness and response teams and currently with Covid, there are awareness programmes and community health awareness training. RPM will also be going to schools to conduct the awareness training on Covid-19. In addition to this, environmental awareness campaigns are conducted in the local schools including awareness on water (mainly around PMR and RBMR).

Training initiatives will be jointly identified by employees, C RBMR has a communication, participation and consultation operational procedure which has been local communities, local government agencies and the provided to the auditor (latest revision date: 2020/06/08). All relevant stakeholders are contacted and Project (in line with Anglo Platinum policies and communicated with on an on-going bases. practices). A public participation communication and consultation procedure has been compiled and provided to the Auditor.

The process academy has the aim of training youth from the local communities with the intent of integrating the graduates into Anglo operations. The graduates are provided with certificates to ensure

Conditions Level of Reason for audit finding compliance

that they can search for employment elsewhere, if there is no roles available at the Anglo Rustenburg processing operations. There is no clear collaboration with local government.

Educational programs concerning conservation and the C RBMR has a communication, participation and consultation operational procedure which has been environment should be developed and stressed by provided to the auditor (latest revision date: 2020/06/08). All relevant stakeholders are contacted and Retained Operation’s management on an on-going basis. communicated with on an on-going bases. A public participation communication and consultation procedure has been compiled and provided to the Auditor.

Educate local people regarding environmental awareness C RBMR has a communication, participation and consultation operational procedure which has been at home. provided to the auditor (latest revision date: 2020/06/08). All relevant stakeholders are contacted and communicated with on an on-going bases. A public participation communication and consultation procedure has been compiled and provided to the Auditor. In addition to this, environmental awareness campaigns are conducted in the local schools including awareness on water (mainly around PMR and RBMR).

In addition to this, environmental awareness campaigns are conducted in the local schools including awareness on water (mainly around PMR and RBMR).

Anglo Platinum and legitimately established community- C The Rustenburg Section 2015 Social labour Plan makes reference to ‘Portable Skills Training based development structures (e.g. Photoemit Interventions’. Portable skills can be referred to as those skills that relate to industries outside of the Community Development Committee) must establish mining industry that can be used to improve earning capacity during the life of mine and in the event community development programmes that would provide that downscaling and retrenchments might occur. It should be noted that the Retained Operations are

Conditions Level of Reason for audit finding compliance

alternative livelihood opportunities that would be not required to have an SLP however, according to discussions held between the Auditor and the sustainable well after the closure of the Retained Senior Social Performance Manager (Process Division Services), Ms Tumelo Dilotsotlhe the SLP has Operations. been replaced by an SED roadmap which is aligned with the SED requirement in the Anglo Social Way. This is being reviewed to align with the Anglo Social Way 3. This commitment is one of the programmes within the SED. The SED is broad and also incorporates issues around CSI initiatives and SLP (pooling and sharing agreement with the Kroondale Mine). The process academy falls within in the SED but because there are multi functioning teams, HR are responsible for driving this but for Rustenburg operations, the budget sits with Mrs Dilotsotlhe and the overall coordination of SED is within social performance but there are multiple stakeholders internally. The intent is to capacitate employees for employment opportunity beyond Anglo American. Where there are opportunities internally, they are considered for this.

All community development programmes and projects C RBMR has a communication, participation and consultation operational procedure which has been must be implemented with and through legitimately provided to the auditor (latest revision date: 2020/06/08). All relevant stakeholders are contacted and established community-based development structures communicated with on an on-going bases. (e.g. Phothemfi Community Development Committee). A public participation communication and consultation procedure has been compiled and provided to the Auditor.

A Community Development Committee will be established C Tumelo Dilotsotlhe is the allocated CED manager responsible for carrying out the objectives of the involving community leaders from the nearby towns and Anglo Social Way. Tumelo is qualified to fill the role. Tumelo is assisted by a team comprising of the villages and the Retained Operations. This committee will following staff: be tasked to make recommendations as to the optimal use of development funding. Will be in line with Anglo  Stakeholder engagement officer (develops the stakeholder engagement plan) Platinum policies and practices.  LED officers (responsible for monitoring the implementation of SED projects)  Stakeholder engagement liaison officer (responsible for community liaison)

Assistance from the Anglo Zimele Hub (responsible for implementing youth programmes and socio- economic development programmes) in liaison with the communities.

Ongoing training will be implemented to inform employees C Site specific induction presentations are presented to new employees and visitors. As part of the site of the various procedures on site. audit, SRK undertook induction as well as Covid-19 training. Refresher inductions are conducted annually. In addition, toolbox talks are held in the different sections, using site specific training material. Several examples of tool box talks were made available to the auditor for review. Training is conducted in line with the Training, Awareness and Competence Procedure (Ref No ACP-ALL-SHE- PRO-0002 – April 2019) which specifies the types and levels of training required for internal staff and external contractors and visitors

Employees will be educated by means of existing training C An Environmental Awareness Plan is presented for the Anglo American Group. The plan forms a

Conditions Level of Reason for audit finding compliance

and an Environmental Awareness Plan. guideline for site specific induction presentations.

12. Health and Safety Anglo Platinum may have to expand on its Safety, Health C An annual policy review is completed to effect changes to policies, if required. If no change and Environmental (SHE) policies to accommodate the requirements are noted (i.e. legislative amendments, etc), the policies and procedures will remain new employees and their families. unchanged

If Anglo Platinum has not developed an HIV/AIDS C Anglo American Platinum make a public statement that they recognise that HIV/AIDS has serious management programme, it is highly recommended that medical, social and economic implications for employees and their families, for communities and for one be developed and implemented. Among others, this their company. They manage HIV/AIDS as an integrated response which encompasses prevention programme will assist the management of Anglo Platinum through to care and support. They offer comprehensive health services for HIV/AIDS care and HIV to plan the effective provision of health care generally and prevention to all employees and offer free voluntary counselling and testing (VCT) to all employees in particular to those employees that area HIV/AIDS and contractors. They have an HIV/AIDs strategy (consisting of three pillars: preventative, curative and positive. rehabilitative care) which is described in the Anglo American Integrated Report 2018. The Retained Operations comply to the principles of the Anglo American Platinum HIV/AIDs strategy.

Anglo Platinum is committed to investigating any health NA The Auditor was not made aware of any health claims made to the operations during the audit period. claim resulting from its operations only if it can be proven This was confirmed by a review of the incident register. beyond doubt that an Anglo Platinum operation has affected the health of a person.

Anglo Platinum will collaborate with others with respect to C It is the Auditor’s understanding based on discussions with the various Retained Operations staff that Health Care. This issue will be discussed at the health, together with aspects associated with environment and safety, are discussed at community Community Liaison Meeting. meetings.

All employees will receive the necessary training to C Site specific induction presentations are presented to new employees and visitors. As part of the site undertake their work. audit, SRK undertook induction as well as Covid-19 training. Refresher inductions are conducted annually. In addition, toolbox talks are held in the different sections, using site specific training material. Several examples of tool box talks were made available to the auditor for review. Training is conducted in line with the Training, Awareness and Competence Procedure (Ref No ACP-ALL-SHE- PRO-0002 – April 2019) which specifies the types and levels of training required for internal staff and

Conditions Level of Reason for audit finding compliance

external contractors and visitors.

Employees must be issued with appropriate PPE. C Employees were noted to be using the correct PPE in all areas observed during the site visit. A PPE register is maintained for all staff.

Ensure the appointment of a Safety Officer to NA The RPM Retained Operations are currently in the operational phase. No construction activities were continuously monitor the safety conditions during underway at the time of the audit. construction and closure.

13. Spillages and Incidents Identify potential areas where seepage and spills can C The Retained Operations Environmental Officers are responsible for each of their operations - they are occur into the natural environment. Take necessary responsible for ongoing checks, overseeing any clean-up activities, and educating employees precaution to reduce potential spills and seepage. regarding spill prevention; in accordance with the relevant management plan. Promote improved catchment management.

Should surface or groundwater be contaminated due to C No major spills have occurred in the last 6 months. In February 2020 the PMR site was affected by a an incident or spillage, mitigation and clean up measures spill from the Helipad sewerage pump into Dam 3A. The authorities were notified of the spill (evidence must be implemented immediately. provided to the auditor). The dams were cleaned and the water was pumped to the sewage treatment plant for treatment.

During the site audit no spills were identified. Spill kits are present at different locations around the site. Drip trays are also used on site

If surface water is contaminated by an oil spillage, the C No major spills have occurred in the last 6 months. In February 2020 the PMR site was affected by a surface water must be neutralised as soon as possible. spill from the Helipad sewerage pump into Dam 3A. The authorities were notified of the spill (evidence provided to the auditor). The dams were cleaned and the water was pumped to the sewage treatment plant for treatment.

During the site audit no spills were identified. Spill kits are present at different locations around the site. Drip trays are also used on site

Trucks should not be over-loaded with building rubble, C Security at facility entrances is the only form of monitoring this commitment. The security check is cement, sand borrow material and/or concrete to limit related purely to roadworthiness which incorporates ‘overloading’. In cases were the payload is spillages and incidents. considered dangerous, SANS 10228 applies which is monitored by procurement. In cases were general rubble, sand and other construction materials are transferred to or from site, no standard is applied, only the generic roadworthiness checklist is completed by security.

No incidents related to overloading were recorded on Enablon.

Conditions Level of Reason for audit finding compliance

A trained rapid response team will be on hand, or local C The contact number of a HAZMAT team is included on the facility emergency contact lists. The clean- companies will be contracted, to deal with any harmful up efforts are only outsourced in the case of major spillages. A commercial agreement is in place with spillages. the company.

Spillage and leakage should be avoided at all costs by C The Retained Operations Officers conduct regular site inspections and spot checks for spillages. ensuring that all containers/holding equipment do not leak During the site audit no spills were identified. Spill kits are present at different locations around the and that all lids and caps are tightly shut. site.

The contractor(s) supplying both fuel and lubricants to the C This requirement is included within the standard contractual agreement that is required to be Retained Operations will be required to have a crisis completed by all suppliers. management system in place in order to deal with possible vehicle accidents and/or accidental spillage. This would typically involve emergency teams that would have the capacity to neutralise spills and begin rehabilitation of the affected site(s) within hours.

If a spillage of a hazardous material occurs the resultant C During the site audit no spills were identified. Spill kits are present at different locations around the hazardous waste must be cleaned up using absorbent site. All hazardous waste is disposed of in line with the RPM waste management procedure. According material provided in spill kits on site and disposed of in a to discussions with the Retained Operations Officers, an external contractor removes the waste to the designated hazardous waste bin. licenced Interwaste Holfontein site. Contractors are required to watch a video induction which makes reference to spillages and the clean-up procedure. The procedures are also stored in the safety file.

Spilled material must be cleaned up and disposed of C No major spills have occurred in the last 6 months. In February 2020 the PMR site was affected by a appropriately as soon as practically possible. spill from the Helipad sewerage pump into Dam 3A. The authorities were notified of the spill (evidence provided to the auditor). The dams were cleaned and the water was pumped to the sewage treatment plant for treatment.

During the site audit no spills were identified. Spill kits are present at different locations around the site. A drip trays are also used on site.

During the site audit no spills were identified. Spill kits are present at different locations around the site. All hazardous waste is disposed of in line with the RPM waste management procedure. According to discussions with the Retained Operations Officers, an external contractor removes the waste to the licenced Interwaste Holfontein site.

Spilled hydrocarbons must be disposed of at a designated C No major spills have occurred in the last 6 months. In February 2020 the PMR site was affected by a area. spill from the Helipad sewerage pump into Dam 3A. The authorities were notified of the spill (evidence provided to the auditor). The dams were cleaned and the water was pumped to the sewage treatment

Conditions Level of Reason for audit finding compliance

plant for treatment.

During the site audit no spills were identified. Spill kits are present at different locations around the site. A drip trays are also used on site. During the site audit no spills were identified. Spill kits are present at different locations around the site. All hazardous waste is disposed of in line with the RPM waste management procedure. According to discussions with the Retained Operations Officers, an external contractor removes the waste to the licenced Interwaste Holfontein site.

A rapid response team should be available on 24-hour C The site adheres to both a spill procedure as well as a Mandatory Code of Practice for Emergency notice to deal with hazardous spills. Preparedness and Responses which are compiled for all of the sites. Spills are listed as an emergency response item within the Emergency Preparedness and Response Plan. This plan indicates that and Emergency Response Team with representation for all shifts including day shift is available to assist during emergencies. Contractors must have a spillage handling procedure in C Spillage clean-up measures are included in the full induction and it is touched on during the visitor’s place. induction. Contractors comply with the RPM spillage handling procedures. Incidents are reported to the relevant Retained Operations Officer within RPM depending on where they occur. If any incidents take place which have an impact on the environmental, RPM report these to the relevant environmental authorities. All incidents are captured on Enablon and recorded in an incidents register according to the nature of the incident. The 2019 register and incident summary report was provided to the auditor.

All vehicles will be kept in good working order and drivers C Plant hire and resident vehicles are accompanied by a service record (within the contractor file or will be trained. maintenance department’s office, respectively). The record indicates when the next service is required

Contain and clean up spills and sample affected areas. C No major spills have occurred in the last 6 months. In February 2020 the PMR site was affected by a spill from the Helipad sewerage pump into Dam 3A. The authorities were notified of the spill (evidence provided to the auditor). The dams were cleaned and the water was pumped to the sewage treatment plant for treatment. Anglo Platinum has enlisted the assistance of Agreenco Environmental Projects

Conditions Level of Reason for audit finding compliance

(Pty) Ltd (Agreenco) with conducting a soil contamination assessment of the soils occurring at PMR.

During the site audit no spills were identified. Spill kits are present at different locations around the site. Drip trays are also used on site

Workforce will be made aware of necessity to prevent C Spillage clean-up measures are included in the full induction and it is touched on during the visitor’s spillage/seepages by good house-keeping. Good induction. Ongoing on the job talks and toolbox talks, as well as awareness campaigns are undertaken housekeeping will be required to minimise the risk of to maintain good housekeeping. Evidence of the toolbox talks was provided to the auditor as proof. pollution.

Trucks must not be over-filled at the fuelling depots. Re- C Based on discussions with the various Retained Operations Officers, refuelling activities are fuelling must be supervised. Any spillage or accidental supervised by a ‘responsible person’. Any spillage at the fuelling depot is captured by a sump and discharge of fuel onto the soil or vegetation must be pumped out for transfer to an oil recycling company. No spillages relating to refuelling are recorded on reported to the Retained Operation’s environmental Enablon. manager.

Emergency plans will be put in place for catastrophic C Each operation has an emergency response procedure specific to the operations. The RPM spillages. Emergency preparedness and response procedure (RBMR-SHE-SAF-MCOP-0001 – 2019/08/24) was provided to the auditor.

Rehabilitate any areas damaged by explosions as soon C No blasting is required with the Retained Operations. An explosion at ACP occurred in February 2020 as possible. and plant was restarted in May. No environmental impacts resulted due to the explosion and no rehabilitation was required however the incident was reported to the Bojana Platinum District Municipality. This was confirmed through a review of the Incident Summary Report from Enablon which was provided to the auditor.

Drivers will be trained on how to deal with accidents C According to communication with the Retained Operations Officers, all Drivers transporting dangerous involving ore, concentrate, hydrocarbons and other goods are required to have a valid Professional Driving Permit (PDP). The permit is checked by site potential contaminants. access control upon entry to the operation. Ore incidents are not noted as being relevant to this report.

Contain and clean contaminated areas resulting from C No major spills have occurred in the last 6 months. In February 2020 the PMR site was affected by a spills or failures of piping or storage structures and spill from the Helipad sewerage pump into Dam 3A. The authorities were notified of the spill (evidence sample affected areas. provided to the auditor). The dams were cleaned and the water was pumped to the sewage treatment plant for treatment. The operations have enlisted the assistance of Agreenco Environmental Projects (Pty) Ltd (Agreenco) with conducting a soil contamination assessment of the soils occurring at PMR.

During the site audit no spills were identified. Spill kits are present at different locations around the site. Drip trays are also used on site.

Conditions Level of Reason for audit finding compliance

All chemical spills will be reported to the Retained C Incidents are reported to the relevant Retained Operations Officer within RPM depending on where Operation’s environmental manager and remedial action they occur. If any incidents take place which have an impact on the environmental, RPM report these will be taken. to the relevant environmental authorities. A incidents are captured on Enablon and recorded in an incidents register according to the nature of the incident. The 2019 register and incident summary report was provided to the auditor.

The Retained Operations will implement an emergency C Incidents are reported to the relevant Retained Operations Officer within RPM depending on where management plan to clear up any spillages that occur they occur. If any incidents take place which have an impact on the environmental, RPM report these outside of bunded areas. to the relevant environmental authorities. A incidents are captured on Enablon and recorded in an incidents register according to the nature of the incident. The 2019 register and incident summary report was provided to the auditor.

Regular inspections of equipment and maintenance will C According to discussions with the Retained Operations Officers, a daily pre-use checklist is used to be carried out to prevent equipment leakage and pipeline observe any leakage or other issues. The auditor did not see any documentation pertaining to this. No breakage. equipment leaks or pipeline breakages were observed at the time of the site inspection audit.

Use only one central storage site to store harmful C Due to the nature and locality of the various Retained Operations, it is not practical to have one central substances to minimise the area that could be affected by storage site for harmful substances. All hazardous storage sites within the Retained Operations are spillage. Staff will receive proper training and supervision bunded and lined to prevent impacts to the environment as a result of spillage. Hazardous wastes are to prevent spillage. also removed from the sites regularly by the appointed contractor. Training is conducted in line with the Training, Awareness and Competence Procedure (Ref No ACP-ALL-SHE-PRO-0002 – April 2019) which specifies the types and levels of training required for internal staff and external contractors and visitors.

If spillage occurs, the affected soils will be removed and C No major spills have occurred in the last 6 months. In February 2020 the PMR site was affected by a discarded at an existing local permitted hazardous waste spill from the Helipad sewerage pump into Dam 3A. The authorities were notified of the spill (evidence site. The areas must be landscaped and re-vegetated as provided to the auditor). The dams were cleaned and the water was pumped to the sewage treatment soon as possible. plant for treatment.

During the site audit no spills were identified. Spill kits are present at different locations around the site. A drip trays are also used on site. During the site audit no spills were identified. Spill kits are present at different locations around the site. A hazardous waste is disposed of in line with the RPM waste management procedure. According to discussions with the Retained Operations Officers, an external contractor removes the waste to the licenced Interwaste Holfontein site.

Material Safety Data Sheets will be updated regularly and C MSDS were available for inspection during the site audit. The MSDS are maintained and updated by be available on site. chemical store staff as and when needed.

Conditions Level of Reason for audit finding compliance

All incidents must be reported to the responsible site C Incidents are reported to the relevant Retained Operations Officer within RPM depending on where officer as soon as they occur. they occur. If any incidents take place which have an impact on the environmental, RPM report these to the relevant environmental authorities. All incidents are captured on Enablon and recorded in an incident register according to the nature of the incident. The 2019 register and incident summary report was provided to the auditor.

Appendix C2: RBMR Conditions

EMPr Conditions for RBMR Any spills of hydrocarbons will be cleaned up C Spill kits were identified on site. No spills were reported during the time of the audit. The majority of the immediately. RBMR site is on concrete/hardstanding surface therefore minimising the impact of any potential spills on soils.

Re-vegetate areas prone to erosion, utilising C During the site visit the only area observed to require revegetation was an area near the effluent dam. This indigenous species known to occur in the area as area was impacted on due to an overflow of the dam. Corrective actions are in place to re-vegetate this far as possible. area.

Inform staff, contractors and visitors to remain on C An updated contractors and employees video presentation is being compiled to include this as a topic. roads and pathways to minimise disturbance to Environmental department has submitted their material to the training department. existing and established vegetation.

Any Rare or Red Data species must be removed NA No new areas have been disturbed and no rare or red data species have been identified at the site in this or from the impacted area if required. the previous audit period.

Create an exotic and alien invasive species control PC An Alien Invasive Plants Management Plan was compiled by Agreenco in March 2018. The report was and eradication programme as set in the provided to the Auditor for review. No actions regarding the recommendations contained within this report Biodiversity Action Plan. have been undertaken due to budget constraints. Agreenco completed a biodiversity assessment in 2014- 2015, which noted areas of high or low biodiversity importance.

Vegetation surveys will be carried out from time to PC Alien Invasive Plants management plan was compiled by Agreenco in March 2018. The report was time to assess improvements in vegetation cover provided to the Auditor. No actions have been undertaken due to budget constraints. and species diversity as well as to provide information to properly manage the vegetation.

Visitors and workers will be informed that the killing PC An updated contractors and employees video presentation is being compiled to include this as a topic. of fauna is prohibited within the boundaries of the Environmental department has submitted their material to the training department. area, as well as neighbouring areas.

Inform all staff and contractors that killing or PC An updated contractors and employees video presentation is being compiled to include this as a topic. harming of any animal life in the area controlled by Environmental department has submitted their material to the training department. Anglo Platinum is prohibited.

Relocate any Red Data species if they are seen to NA No new areas have been disturbed and no rare or red data species have been identified at the site in this or be in a location which could be disturbed. the previous audit period.

The pollution of water, soil and vegetation which PC An incident was reported on 14 January 2020, whereby discharge of effluent water from the rainwater dam can cause harm to animal life will be prevented. into a channel leading to the Klipfontein Spruit. Water quality samples were taken and sent to Aquatico

Conditions Level of Reason for audit finding Compliance

Labs for analysis. The incident was rated as minor with a moderate sensitivity rating. the incident was reported to DWS and an acknowledgement E55 was received on 15 January 2020.

Heavy machinery, construction vehicles and C All vehicles and machinery operate within cemented or tarred roads inside the RBMR complex. No areas of equipment will be limited to designated areas and bare soil were observed during the audit access roads and routes to prevent unnecessary damage to soils that will remain after construction. Encourage newcomers to settle within already C RBMR has a communication, participation and consultation operational procedure which has been provided developed areas by providing pull-factors such as to the auditor (latest revision date: 2020/06/08). All relevant stakeholders are contacted and communicated housing, water supply etc so that destruction of with on an on-going bases. undisturbed areas due to squatting does not occur. A public participation communication and consultation procedure has been compiled and provided to the Auditor.

During the site audit. there was no evidence of squatting directly adjacent to the processing operations. Base Metal Contaminated soils are to be C Hyper accumulator plants are currently being trialled at RBMR. rehabilitated via either hyper accumulator growth or encapsulated as excavated and disposed of as hazardous waste. Prevent spillages of oil at compressor during C Ad-hoc checks are conducted by the environmental officer to identify any spills. Chemicals are stored in a maintenance by implementing operational bunded areas. procedures as well as incident reports and visual inspection. Prevent and reduce NAOH spillages by C No spillage of NAOH occurred for the audit period or was observed at the time of the Audit. implementing: Visual inspection; Incident report; and HCS Regulations ER- RL = 2mg/m3. Prevent spillages of diesel at diesel tanks by C Ad-hoc tank inspections are undertaken internally by the engineers. The engineers as well as the implementing operational procedures as well as environmental officer conducts spot checks to identify if there are any leaks or spillages incident reports and visual inspection. Prevent spillages of oil at motor and lorry garage C Spill kits were identified on site. No spills were reported during the time of the audit. The majority of the during maintenance by implementing operational RBMR site located is on concrete/hardstanding surface procedures as well as incident reports and visual inspection. Continuous contact with key stakeholders will be C RBMR has a communication, participation and consultation operational procedure which has been provided maintained in order to prevent illegal land uses on to the auditor (latest revision date: 2020/06/08). All relevant stakeholders are contacted and communicated the area controlled by Anglo Platinum. with on an on-going basis. Heavy machinery, construction vehicles and C No bare soils were identified during the audit. The RMBR site is largely tarred/cemented. All vehicles equipment will be limited to designated areas and operate with the tarred or cemented surfaces

Conditions Level of Reason for audit finding Compliance

access roads and routes to prevent unnecessary damage to soils that will remain after construction. Preventative measures will be put in place to C RBMR has a communication, participation and consultation operational procedure which has been provided prevent the establishment of informal settlements to the auditor (latest revision date: 2020/06/08). No informal settlements are currently found on RBMR land. on land controlled by RBMR/Anglo Platinum. Soils affected by erosion, unauthorised removal, C On 14 January 2020, during heavy rainfall period the Triangular Dam at RBMR overflowed. This incident spills etc. will have their biological activity restored was report to DHSWS and an incident report was compiled. The incident report included costing for when necessary by establishing sustainable remediation of the contaminated soils. The report as well as the proof of the communication of this incident vegetation on them. have been received by the Auditor. It is SRK’s understanding that the erosion caused due to this incident (as well as past incidents) was fixed and the incident was closed out.

In addition to this, RBMR contracted Boden Science to conduct a soil remediation study in February 2018. Based on this, an ongoing rehabilitation project at E&S feed dam area within RBMR is taking place but this project is currently in experimental phases. RPM Appointed Agreenco for this study and are running a trial for a year to establish what plant species can survive and absorb the sodium sulphate in that area. If not, successful alternative methods will be investigated and if feasible implemented. Surfaces of the various facilities to be constructed NA No construction or new projects were undertaken for this audit period. will be lined to prevent potential future soil contamination. Action plans will be in place for dealing with C The incident procedure in the case of significant spillages is noted as the action plan. spillages to ensure the minimal impact on soil. Bunds will be constructed to prevent spills around C Bunds were noted throughout the RMBR site during the site audit. facilities containing hazardous substances. Measures will be put in place whereby leaks in the C Internal monthly inspections are undertaken to identify any issues with the bund walls. bunded areas will be detected. Only designated land uses compatible with current C The land use within the fence line is as per the original approved EMPRs. No closure related actions are operations or the closure vision will be allowed on, taking place on the site to align the site for closure as no closure foreseen. in and around the site. Continuous contact with key stakeholders will be C RBMR has a communication, participation and consultation operational procedure which has been provided maintained in order to prevent illegal land uses and to the auditor (latest revision date: 2020/06/08). No informal settlements are currently found on RBMR land. squatting on the area controlled by Anglo Platinum. Remove all solution within the effluent treatment C According to the GN 704 audit report compiled by Aurecon in 2018, Dams 1 and 3 were lined in 2000. The dam by the 3rd quarter of 1997 due to dams are still in use. compromised liners. The dam must be decommissioned and rehabilitated within two years of solution removal.

Conditions Level of Reason for audit finding Compliance

Rehabilitate rainwater dam 3a by the fourth quarter C Relining of the triangular dam is complete; at the time of the audit, relining was being done at Dam 3A and of 1997. planning was done for the relining of Dam 3B (desilting is currently taking place). Groundwater monitoring must be on-going. The C According to the 2020 WUL Audit groundwater monitoring is conducted and results submitted to the DWS initial groundwater model must be complete by on a quarterly basis. The auditor has also received groundwater monitoring reports where groundwater third quarter 1998. monitoring is conducted by Aquatico. A groundwater model is available and the auditor has received the groundwater model report (RC12004-RSWAPPH1-CS Volumes 2 and 11) which was developed in 2013. This report includes the mining operations and it is not certain if there are plans to revise this in line with the Retained Operations only. Boreholes must be monitored and evaluated for C According to the 2019 annual water quality data (Groundwater Complete, 2019), all boreholes were leaks or seepages on a continual basis. compliant with the WUL limits for pH, however majority of the boreholes exceeded the WUL limits for sodium, calcium, magnesium and sulphate. Half the boreholes exceeded the WUL limits for chloride. Groundwater abstraction via the boreholes at RBMR has ceased. Physical inspection of the rainwater dam for leaks C Ad-hoc internal surface checks are undertaken by the engineers or seepages to ensure to mitigate against chemical contamination of groundwater. Limit Selenium spillages to prevent employee’s C Based on discussions with the Retained Operations Environmental Coordinator, Selenium is used on site. exposure to Selenium compounds and the No reports of spillages in that section have occurred in the audit period. The section is concreted and ties prevention of Surface and Ground water pollution; into the operations water infrastructure by monitoring of incidents and implementation of operational procedures. Implement detailed monitoring of the water balance C According to the 2020 RBMR WUL Audit, Water balance is updated by RBMR on a monthly basis. Flow in order to adhere to the water use license and measuring devices are in place to measure flow of water into the authorised Section 21(g) water uses, other in-house requirements of minimum usage of which provide information for the annual water balance. The site utilises the 'Enablon' software to capture water. DWS water use license; Monitoring of Water and track and incidents or spillages; the incident is tracked through to close-out. Balance; and Incident reports on Spillages. Apply operational procedures (including applicable C Anglo American aims to deliver all work in line with their vision of Zero Harm. This requires addressing the ventilation) to ensure minimal exposure of SHE-related risks derived from their activities, this is achieved by means of occupational hygiene survey employees to welding fumes. which are done internally. Ventilation occurs via windows and doors in the workshops good ventilation was observed in the workshops during the site audit. Ensure prevention of chemical seepage from waste C There is a regulated groundwater monitoring network aimed at detection of dam leakages. Dams are liquor dam by applying borehole monitoring and physically inspected on an approximately monthly basis. physical inspection of the dam. Rehabilitate North site to minimise ground water NA The Retained Operations Environmental Officer is not familiar with a ‘North Site’. It is advised that this and surface water and soil pollution by: condition is removed or made applicable to the RBMR operation. Physical separation of waste and monitoring of

Conditions Level of Reason for audit finding Compliance

ground water and surface water (Klipspruit); and Removal and rework of contaminated soil. Appropriate management of laboratory chemicals C Based on site inspections, acids and other chemicals at the laboratory are generally stored within bunding. by a safety program to avoid any spillages The correct spill kits are available at the facility. Spillage events at the laboratory are included within the and water contamination by: Laboratory Enablon system; no spillages were recorded for this audit period. management plant for removal of laboratory waste by waste service provider; and Incident report on laboratory spillages. Ensure minimisation of sodium sulphate spillages C All spillage incidents are recorded on Enablon. There is a regulated groundwater monitoring and surface by enforcing operational procedures and incident water monitoring network aimed at detection of contamination. reporting. Borehole monitoring and surface water quality to ensure no water contamination. Legislative requirements in terms of water C RBMR approved WUL is audited on an annual basis the most recent being the February 2020 WUL Audit management will be adhered to. audited by SRK Consulting. An internal WUL Audit was undertaken in May 2020. Regular monitoring of the Klipfonteinspruit with C Bi-annual biomonitoring is conducted at the Hex River, Klipgatspruit and Klipfonteinspruit. This long-term surface water and biological monitoring will monitoring programme commenced in 1999. A Biomonitoring report was compiled by Clean Stream in continue to take place to detect any impacts from December 2019. Surface water quality is monitored at 17 monitoring points up and downstream of the Hex RBMR. river, the Klipfonteinspruit, the Dorpspruit and the Paardekraalspruit. The monitoring programme is aligned to the requirements of the WUL. Clean and dirty water systems will be kept C According to the 2018 GN 704 audit report, Dirty water runoff from within RBMR is collected in a number of separate, regularly inspected and maintained so trenches which then drains to the stormwater dams. The clean water upstream of RBMR is diverted away that they meet regulatory requirements. from RBMR in a number of trenches and pipes into the Klipfonteinspruit on the northern side of RBMR. Incidents of spillages out of designated areas will C Spill kits were identified on site. No spills were reported during the time of the audit. The majority of the be recorded and reported, and appropriate RBMR site is on concrete/hardstanding surface remedial measures implemented. The water balance will be updated regularly, and C According to the 2020 RBMR WUL Audit, Water balance is updated by RBMR on a monthly basis. Flow water usage monitored and optimised where measuring devices are in place to measure flow of water into the authorised Section 21(g) water uses, possible. which provide information for the annual water balance. Potable water is supplied to operations from Rand Water and Magalies Water via the Barnardsvlei and Vaalkop pipelines. Since April 2007 extensive work has been undertaken at RBMR to maximise the reuse of water in the plant and minimise the use of Rand Water Water quality and quantity will be determined at its C Sampling of surface water and groundwater is done by Aquatico. The 2019 IWWMP compiled by Aurecon position in accordance with the requirements of the indicated that there are currently 37 active surface water quality monitoring points including the process DWS. water monitoring points. It was detailed in the report that Sulphate and the trace heavy metal, nickel, are largely associated with the operations at RBMR and that the highest risks to surface water is the RBMR pollution control dams. The monitoring programme is aligned with the requirements of the WUL.

Conditions Level of Reason for audit finding Compliance

Existing monitoring programmes will be C Internal and external monitoring programmes are undertaken as per the requirements of the EMPr. maintained. Bunded and sealed areas will be regularly C Internal monthly inspections are undertaken by the engineers and environmental officer to identify any inspected to ensure that no leaks are occurring. issues or leaks with the bund walls. Complete study to ensure that there are no C In 2005 Anglo Platinum Mines, Rustenburg Platinum Mines, Rustenburg Section commenced with a groundwater users around RBMR. process towards establishing an overall groundwater management plan for the entire Rustenburg Section. A Groundwater model report was compiled in August 2013. According to the Retained Operations Environmental Coordinator, a groundwater pollution plume assessment was undertaken for the Rustenburg Section area (before the sale to Sibanye). The assessment included a hydrocensus and the auditor has received the groundwater model report (RC12004-RSWAPPH1-CS Volumes 2 and 11) which was developed in 2013. This report includes the mining operations and it is not certain if there are plans to revise this in line with the Retained Operations only. Discuss the possible remediation steps with DWS NA According to the previous audit findings, he installation of scavenging boreholes was investigated and confirm the declaration of the area. historically. The DHSWS was consulted at the time. The pumping of the contaminated underground water was found to be unfeasible as the salts in the water crystallised within the pump and piping system which caused ongoing system breakdown. Regular monitoring of boreholes and trench PC According to the 2020 WUL Audit groundwater monitoring is conducted and results submitted to the systems will continue with an action plan to DHSWS on a quarterly basis. According to the 2019 annual water quality data (Groundwater Complete, address groundwater contamination where it does 2019), all boreholes were compliant with the WUL limits for pH, however majority of the boreholes occur. exceeded the WUL limits for sodium, calcium, magnesium and sulphate. Half the boreholes exceeded the WUL limits for chloride. It is understood that the limits specified in the WUL are very stringent and may not be achievable and therefore the WUL may need to be amended to address this. In addition to this, the condition refers to ‘appropriate rehabilitation measures’ which is not specific and needs to be amended. The auditor is aware of the Water Action Plan Phase 2 Concept Study developed by Anglo American and Aurecon in 2015. This plan fits into the overall Anglo American Group Water Strategy and includes possibilities of abstraction of groundwater for remediation purposes. It is the auditor’s understanding that the Retained Operations have in the past investigated methods of abstraction of groundwater for remediation purposes however a partial compliance has been awarded as it is not certain if any of these practices are still being implemented. Effluent dam 3 will be cleaned out and the lining C The liner was refurbished/replaced in 2000. Based on SRK Report 267531/3 Effluent Dam 3 has the system of the dam will be replaced. following liner system: “Composite liner of clay in 200mm layers compacted to 98% Proctor density at 0% to 2% of OMC, 2000 micron HDPE liner and GCL Bentofix X2000 and X1000 Finalise the implementation plan as agreed with NA According to the discussions with the Retained Operations Environmental Coordinator, the plan was DWS to implement steps as part of groundwater communicated to DHSWS. The boreholes are not in use anymore and the RO plant not in use. A site visit management and remediation. was conducted by DHSWS to confirm that boreholes are not in use. This is a condition which is currently

Conditions Level of Reason for audit finding Compliance

being discussed with the DHSWS as part of the WUL amendment (recommended that the condition is removed from the WUL and the EMPr condition is aligned to this) . The 3B evaporation dam will be kept as empty as C According to the 2019 IWWMP the inflows into Dam 3B include rainfall directly into the dam, rainfall/runoff possible to minimise the risk of overflow into the from the RBMR complex, MC Plant discharges; wash down from RBMR which enters the dam via trenches clean water system in a high rainfall event by using and the Boiler house and Ash Pond water running past the MC plant into Dam 3B. The 2020 WUL Audit this water. This water will be used before using indicated that the Dam 3B is currently being desilted and the dam is planned to be relined during the dry potable water where the qualities allow. season and after silting has been completed. Leaks from bunded areas will be investigated and C Internal monthly inspections are undertaken by the engineers and environmental officer to identify any these will be addressed as soon as they are issues or leaks with the bund walls. noticed to prevent spread of pollutant leaks. The design implemented will ensure compliance C Dirty water runoff from within RBMR is collected in a number of trenches which then drains to the with Regulation 704. stormwater dams. The clean water upstream of RBMR is diverted away from RBMR in a number of trenches and pipes into the Klipfonteinspruit on the northern side of RBMR. The latest GN 704 audit was undertaken in 2018. The report notes all measures in place to separate clean and dirty water on site. The report also provides findings and recommendations. The audit indicates the intent of RPM to achieve compliance with the regulation, however an action plan to track the findings to close-out has not been developed. All lined dams will be subjected to a regular C Lining inspections conducted by SRK once every year or two years. The most recent report was compiled programme of checking and repairing. in 2019. No formal programme is in place but inspections are conducted therefore the auditor is of the opinion that RBMR are complying to this condition. Based on discussions with the Retained Operations Environmental Officer the following applies with regards to the dams at RBMR:  Encapsulation dams have been filled so they are not in use anymore.  Dam 4S is not in use – an order has been raised to have the liner checked for integrity. This is a backup storage dam. have an order number to check the liner for integrity and then they will see if they need to reline and have this dam as a backup.  Waste liquid dam is not in use, silted up, discussions to have the silt cleaned out and use this dam in the future.  Triangular dam has a western and eastern side. Western side was relined in 2017/2018.  On the northern side of the plant, with reference to Dams 1,2 and 3A, there is a project currently for stormwater upgrade where the dams are being redesigned to incorporate silt traps before the effluent/stormwater reaches the dam - still in progress.  Dam 3B - busy desilting the dam to have it relined. The current water control measures will be PC An incident was reported on 14 January 2020, whereby discharge of effluent water (Triangular Dam) from maintained to ensure that no discharge of the rainwater dam into a channel leading to the Klipfontein Spruit. Water quality samples were taken and contaminated water can occur.

Conditions Level of Reason for audit finding Compliance

sent to Aquatico Labs for analysis. The incident was rated as minor with a moderate sensitivity rating. The incident was reported to DHSWS and an acknowledgement letter was received on 15 January 2020. On the northern side of the plant, with reference to Dams 1,2 and 3A, there is a project currently for stormwater upgrade where the dams are being redesigned to incorporate silt traps before the effluent/stormwater reaches the dam No overflows where observed at the time of the site audit. Implement water saving technologies. Optimise C RMBR is continuously investigating new and emerging technologies and techniques for the efficient use of reuse of process water. water containing waste. To avoid or where not possible, minimise and C The replacement of dam lining systems shows intent and awareness from RPM to reduce/avoid remedy pollution of groundwater during all phases groundwater contamination of the operation. Manage vegetation and stormwater to minimise C The RBMR site is mainly tarred/cemented and does not have vegetation. No erosion was identified at the erosion. Manage dust from residue deposits. time of the site audit. No issues associated with dust were noted at the time of the audit To avoid or where not possible, minimise and C Clean water diversions are in place at each operation to disperse runoff from the mine complex site and remedy pollution of surface water during all phases roads. Dirty stormwater measures are in place at the operations. of the operation. Minimise dirty water areas to reduce the volume of dirty water runoff required to be collected. Minimise development in riparian zones. Manage C Clean water diversions are in place at each operation to disperse runoff from the mine complex site and riparian habitat. To avoid or where not possible, roads. Dirty stormwater measures are in place at the operations. Dam 3B is within the flood line level and minimise and remedy pollution of surface water within 100m of the river, but the dam was built prior to the regulation being promulgated and is included in during all phases of the operation. the WUL. No further construction activities are noted outside of the existing RBMR footprint area. The riparian habitat is monitored by Cleanstream Environmental Biomonitoring programme. Ensuring that an off-site noise monitoring NC No noise issues or complaints were received or noted during the audit. Several on-site noise surveys are programme is in place and that action is taken conducted at RBMR. No off site noise monitoring is being conducted. Conversations with the Retained when there is a problem or nuisance. Operations Environmental Coordinator confirmed that this condition was applicable to the construction phase of the project and was erroneously placed as an operation phase condition. The condition should be removed as, due to the locality of the RBMR operations, there is no impact on the surrounding communities.

Measures implemented to address the non-compliance

A once off assessment was conducted in 2008 but off-site monitoring has not been taking place and no measures have been put in place to address this as it is not practical to implement.

Practicality of the EMPr commitment

Conditions Level of Reason for audit finding Compliance

Not practical as there are no off-site noise exceedance risks.

Non-compliance administrative or will have an impact

Administrative non-compliance as frequent off-site monitoring is not undertaken.

Historical/new non-compliance

Historical as it was identified as part of the previous Environmental audit. Check the alignment of all equipment and measure C The internal occupational hygiene team at RBMR undertake noise monitoring throughout the site to ensure all the motor, fans and pump’s vibration levels and noise level compliance. An Area noise schedule was provided to the auditor which indicates the different do maintenance on the equipment by ensuring that areas that are surveyed at RBMR all equipment is properly aligned. Vehicles exhaust systems will continue to be inspected and maintained to prevent excessive noise. Noise levels will be monitored regularly both on- PC Several on-site noise surveys are conducted at RBMR. No off site noise monitoring is being conducted. site and off-site. Conversations with the Retained Operations Environmental Officer confirmed that this condition was applicable to the construction phase of the project and was erroneously placed as an operation phase condition. The condition should be removed as, due to the locality of the RBMR operations, there is no impact on the surrounding communities. Noise levels will be monitored regularly both on- PC As above site and off-site and where problems are found, appropriate remedial measures will be implemented. Monitor air particulates from the coal stockyard to C The air particulates are monitored by the RPM occupational hygiene team on a monthly basis. No ensure compliance with HCS Regulations: OEL- exceedances were reported. RL = 2mg/m3. The requirements of the Atmospheric Emissions C RBMR has a valid AEL (expires 31 March 2021). The AEL only requires Isokinetic sampling on the BMR License (AEL) conditions with regards to sulphur Boiler facility. The Nickel House and Copper Tank house do not require sampling legally (as per the AEL). dioxide and nitrogen oxide emissions must be According to the Atmospheric Emissions Report (Dated 2019, complied by C&M Consulting Engineers) the adhered to. AEL limits are adhered to by the RBMR. Monitoring and reporting of the results must be C Monitoring is conducted and reporting of the monitoring results are issued to the Environmental Manager undertaken to demonstrate compliance with the for the Process Operations (Mr Dustin van Helsdingen). Isokinetic sampling reports do not get submitted to AEL. the authorities. RPM only submit the quarterly reports to the local municipality that aligns with the postponement application for Waterval Smelter. This condition is marked as compliant as the condition does not specifically mention to whom the results needs to be reported to. The results are reported to the Environmental Manager as stated above.

Conditions Level of Reason for audit finding Compliance

The emissions from the new boiler stack (stack 2) NA It is the Auditor’s understanding that Stack 2 is a standby stack. Monitoring is not done on the standby must be less than 180 mg/Nm3 concurrent with the stacks as it is not required by the AEL. commissioning of the sixth boiler, which was scheduled for January 2003. A review must be undertaken of air abatement C A scrubber is installed to reduce emissions. A standby scrubber fan is also installed that starts up when technology available to reduce the emissions from trips occur. It is SRK’s understanding that a review of this technology is undertaken by the engineering the steam generation plant and the technology department. selection must be concluded by September 2003. The emission from the boiler stacks must be less C According to the atmospheric report (dated 2018) undertaken by Airshed, RBMR currently utilises eight than 100 mg/Nm3 by March 2005 following coal-fired boilers for the generation of high-pressure steam. RBMR also supplies PMR with high pressure commencement in January 2005. steam. The emissions from the boilers are all below detection limits for the auditing period according to the Atmospheric Emissions Survey Report compiled by C&M Consulting Engineers (Dated February 2019). The incinerator is to be decommissioned as no air NA The incinerator is no longer in place. Decommissioning year is unknown. It is advised that this condition be emissions licence is in use for it. By removed as part of an amendment process. decommissioning the plant the possibility of any air emissions is negated. All asbestos cladding is to be removed and NA According to the Last Environmental audit, no asbestos cladding remains at RBMR. Since no asbestos replaced with appropriate cladding. cladding remained, it is recommended that this condition is removed. Sulphuric acid fumes are to be minimised to within C The monitoring of sulphuric acid fumes is the responsibility of the occupational hygiene team. Based on the Hazardous Chemical Substance Regulations verbal communication, fume extraction systems are in place at facilities dealing with the (TWA OEL- RL = 1mg/m Occupational exposure air emission. limits- Recommended limits). Regular monitoring of Sulphuric acid fumes is to be implemented. Formalin fumes are to be minimised to within C The monitoring of fumes is the responsibility of the occupational hygiene team. Based on verbal company guidelines. Regular monitoring of formic communication, fume extraction systems are in place at facilities dealing with the acid fumes is to be implemented. air emission. Operational procedures must be reviewed to NA According to the previous Environmental audit there was a fibreglass workshop at the RBMR many years ensure minimum exposure of employees to ago. The workshop no longer exists as there was no further operational requirement. As and when a fibreglass fibre and minimum fibreglass as fibreglass application is required (i.e. fabrication), the work is outsourced to a specialist company to carry particulates in the air. Fibreglass is to be counted out the works. to be confirmed in accordance with AIA RTNT 1 and If required, extractor fans with filters are to be installed. Strict application and enforcement of existing C According to the internal performance assessment report undertaken in May 2020. The environmental team procedures for SO2 handling in order to mitigate noted that some exceedances in SO2 were recorded at the Smelter (main stack), due to the tower plant environmental impacts. being offline at the ACP. This issue is being addressed through postponement applications.

Conditions Level of Reason for audit finding Compliance

Apply and enforce of existing operational C The monitoring of fumes is the responsibility of the occupational hygiene team. Based on verbal procedures to minimise the emission of formalin to communication, fume extraction systems are in place at facilities dealing with the the air and thus minimise air pollution (Formic acid air emission. TWA OEL-Rl = 9mg/m3). Minimise the emission of chemicals to the C According to the previous external environmental audit undertaken in 2019 and from what could be atmosphere during solvent extraction by enforcing observed by the auditor during the site visit, extraction systems are in place where required. It is the operational procedures. responsibility of the occupational hygiene team to maintain and manage the systems Minimise exposure of employees to hydrogen C As above emissions by implementation of appropriate ventilation. Minimise exposure of employees to arch gases by C As above implementation of appropriate ventilation. Minimise exposure of employees to dust produced C No sand blasting activities occurred during the site audit. from sand blasting by strict application and enforcement of existing operational procedures. Minimise exposure of employees to dust produced NA The previous PAR audit noted that this commitment should no longer be applicable as no carpentry is from carpentry by strict application and undertaken on site. enforcement of existing operational procedures. Dust suppression techniques will be used to C The RBMR site is mainly tarred/cemented and does not have vegetation. No erosion was identified at the prevent the generation of dust when it arises and to time of the site audit. No issues associated with dust were noted at the time of the audit. Monthly dust fall prevent it from occurring. out reports are compiled by Aquatico. The most recent report for June 2020 confirmed that no exceedances have occurred during the monitoring period Air quality monitoring will be conducted on a C Anglo American Platinum operates eight ambient monitoring stations around the WSC, PMR and RBMR continual basis to determine the impact of air operations. Monthly dust fall out reports are compiled by Aquatico. The most recent report for June 2020 pollution on the environment as well as local confirmed that no exceedances have occurred during the monitoring period residents. Regular audits will be undertaken to ensure that C A mass balance is undertaken to ensure the operations remain within the annual emission rates. The AEL the predicted emission reductions are achieved for is based on hourly averages. Internal AEL Compliance audits are conducted by RPM the boiler emissions. Opportunities for emission reduction will be C It is the Auditor’s understanding, based on discussions with the Environmental Coordinator, technology is regularly reviewed. being reviewed continuously. The operation aims to achieve compliance with the requirements of the AEL. Non-compliant incidents will be recorded and made C All incidents are recorded on the Enablon system. No incidents were reported at the time of the audit. available to authorities on a monthly basis. Annual monitoring reports will be produced and C According to discussions held as part of the pre-audit meeting, Isokinetic sampling reports do not get submitted to authorities as per current submitted to the authorities. RPM only submit the quarterly reports to the local municipality that aligns with requirements. the postponement application for Waterval Smelter. The incidents are pulled into a quarterly report which is

Conditions Level of Reason for audit finding Compliance

submitted to the District authority in line with the requirements of the AEL First quarterly report is due July 2020. Non-compliant incidents will be investigated and C All incidents are recorded on the Enablon system and actions generated for the specific person where possible, management plans will be put in responsible. No incidents were reported at the time of the audit place to prevent the recurrence of non- compliances. Workplace air quality will be regularly monitored C Anglo American aims to deliver all work in line with their vision of Zero Harm. This requires addressing the and programmes to manage worker health will SHE-related risks derived from their activities, this is achieved by means of occupational hygiene survey continue to be implemented and updated to ensure which are done internally. Ventilation occurs via windows and doors in the workshops. good ventilation was that safe working conditions are maintained observed in the workshops during the site walkover. Operation site and facilities will be kept orderly at C Waste is managed via waste separation methods. Waste storage site was audited, and no issues were all times. noted. Skips are used for hazardous waste. Biohazard waste is sent for incineration. Medical waste is removed by Buhle Waste. Establish and implement a waste management C Waste is collected and stored correctly and differentiated by colour coded waste receptacles as observed plan to minimise waste production. during the site audit. A waste management procedure is in place with reference number RBMR-SHE-ENV- PRO-0003. The procedure makes reference to the need for correct storage, colour coding system, waste collection and waste disposal No recruitment at the gate will be allowed. C According to the previous environmental audit, policy, employment offerings at the facility gate is not permitted. All employment must be advertised through the correct channels. Depending on skills availability, a local community member or an outsourced individual will be employed to fill the role. This is in line with the recruitment policies observed for other Anglo Platinum operations. Anglo Platinum will have regular meetings with C Tumelo Dilotsotlhe is the allocated CED manager responsible for carrying out the objectives of the Anglo I&AP’s in the area in order to address their issues Social Way. Tumelo is qualified to fill the role. Tumelo is assisted by a team comprising of the following and concerns. staff:

Assistance from the Anglo Zimele Hub (responsible for implementing youth programmes and socio- economic development programmes)

Regular meetings are taking place within the communities as well as with the municipality. Anglo Platinum will participate in a traffic survey NA The previous external environmental audit noted that this condition be removed as part of the amendment which will be conducted together with other larger process as traffic impact assessments are carried out prior to departmental approval of a capital project. companies in the area, the local municipality and the provincial roads department.

Conditions Level of Reason for audit finding Compliance

Procurement of services from local small, medium C Based on discussions held between the Auditor and the Senior Social Performance Manager (Process and micro businesses will be encouraged, where Division Services), Ms Tumelo Dilotsotlhe, the community-based employment system (known as the Page- appropriate. up system) is currently under review. Previously (up until August 2020) the ‘Page-Up System’ allowed for communities to apply for opportunities within the Retained Operations. If a contractor required specific services then the contractor would independently source and interview people based on the information which was available on the Page-up system. The contractor would then submit a report to the Retained Operations in terms of the number of people employed and the duration thereof. This would be reported in terms of the job creation to the community engagement forum (CEF). The CEF is currently under review to align it with the new requirements for establishment of community engagement structures or accountability forums within the area of operation to Version 3 of the Anglo Social Way. As such, RPM are going to introduce to the change as per the new transitional plan on the Anglo Social Way. There are various stakeholders that RPM be meeting with to introduce the changes (including the municipality, the Royal Bafokeng administration and internal stakeholders). A transition plan (that was signed off recently) includes actions in terms of engagements (Requirement 3A).

Training and skill development will be implemented NA The Rustenburg Section 2015 Social labour Plan makes reference to ‘Portable Skills Training for workers in line with the company’s Social and Interventions’. Portable skills can be referred to as those skills that relate to industries outside of the mining Labour Plan. industry that can be used to improve earning capacity during the life of mine and in the event that downscaling and retrenchments might occur. It should be noted that the Retained Operations are not required to have an SLP however, according to discussions held between the Auditor and the Senior Social Performance Manager (Process Division Services), Ms Tumelo Dilotsotlhe the SLP has been replaced by an SED roadmap which is aligned with the SED requirement in the Anglo Social Way. This is being reviewed to align with the Anglo Social Way 3. This commitment is one of the programmes within the SED. The SED is broad and also incorporates issues around CSI initiatives and SLP (pooling and sharing agreement with the Kroondale Mine). The process academy falls within in the SED but because there are multi functioning teams, HR are responsible for driving this but for Rustenburg operations, the budget sits with Mrs Dilotsotlhe and the overall coordination of SED is within social performance but there are multiple stakeholders internally. The intent is to capacitate employees for employment opportunity beyond Anglo American. Where there are opportunities internally, they are considered for this.

Medical facilities, transport of sick personnel and C First aid stations and kits were identified during the site audit basic first aid requirements will be made available to employees on-site. Employees will be encouraged to acquire skills NA No closure is foreseen in the near future. after closure.

Conditions Level of Reason for audit finding Compliance

Socio-economic impacts will be managed in C RPM Retained Operations are no longer required to have an approved SLP however they use the existing accordance with the company’s Social and Labour SLP to forms the basis of its engagements with communities and labour bodies in the region and to Plan. manage socio-economic impacts. The company’s policies with respect to C It is the Auditor’s understanding, based on discussions held with Ms Estie Rupp and Ms Tumi Mathebula procurement with local and BEE targets will be from Supply Chain and Procurement that principals of equality, BEE and non-discrimination are included in monitored and the implementation mechanisms all contracts. changed if required. As part of the Anglo American group of companies, the Retained Operations adhere to the wide range of initiatives which have been developed to promote gender quality as part of Anglo’s commitment to human rights. Anglo American Platinum have a Broad Based BEE certificate

Communication with I&AP’s will take place C A public participation communication and consultation procedure has been compiled and provided to the regularly and in an appropriate manner. Auditor. Tumelo Dilotsotlhe is the allocated CED manager responsible for carrying out the objectives of the Anglo Social Way (which include channels of communication). Tumelo is qualified to fill the role. Tumelo is assisted by a team comprising of the following staff:

Assistance from the Anglo Zimele Hub (responsible for implementing youth programmes and socio- economic development programmes) Regular meetings are taking place within the communities as well as with the municipality. The public participation process will be used to set C A public participation communication and consultation procedure has been compiled and provided to the up formal channels of communication with local Auditor. Tumelo Dilotsotlhe is the allocated CED manager responsible for carrying out the objectives of the communities, representatives, labour unions and Anglo Social Way (which include channels of communication). Tumelo is qualified to fill the role. Tumelo is various I&AP’s and forums to inform them of the assisted by a team comprising of the following staff: recruitment process.  Stakeholder engagement officer (develops the stakeholder engagement plan)  LED officers (responsible for monitoring the implementation of SED projects  Stakeholder engagement liaison officer (responsible for community liaison)

Appendix C3: Waterval Complex (Smelter and ACP)

EMPr Commitment Level of Reason for audit finding compliance Exotic invasive species will be controlled on site. C Waterval Smelter and ACP operational areas of the site are all on hard standing with very little vegetation. Obvious exotic invasive species were not observed during the audit. Vegetation surveys will be carried out regularly PC SRK understands that the last vegetation survey was done in 2015 and further studies have not been to assess improvements in vegetation cover and undertaken. Very little to no vegetation is present in the operational areas. It is recommended that this species diversity as well as provide information management measure be removed based on input and motivation from a biodiversity specialist. The to properly manage the vegetation. specialist study was undertaken between 1-3 September 2020 as confirmed with the Retained Operations Environmental Officer. A flora health risk assessment will also be PC A flora health risk assessment has not been completed. It is understood that a specialist company has been performed in the area in order to establish if any appointed undertake this survey. It is recommended that this management measure be removed based on contamination or stress factors that can input and motivation from a suitable specialist. The specialist study was undertaken between 1-3 September negatively influence the growth of vegetation 2020 as confirmed with the Retained Operations Environmental Officer. exist. Periodic satellite photography surveys must be NC It is not clear as to what the intent of this condition is to the Auditor, however, satellite photography surveys assessed to monitor changes in chlorophyll have not been undertaken, the purpose of this requirement needs to be determined by a specialist and concentrations within the site. recommend if this commitment can be removed through an amendment process.

Measures implemented to address the non-compliance No measures have been undertaken to date. The condition will be amended as part of the EMPr update scheduled for 2020/2021.

Practicality of the EMPr commitment Not practical as there are very little to no vegetation is present in the operational areas

Non-compliance administrative or will have an impact Administrative non-compliance as the origin and purpose of this requirement cannot be determined

Historical/new non-compliance Historical as it was identified as part of the previous Environmental audit. Comprehensive botanical survey will be carried C SRK understands that the last botanical study specific to the ACP operation was done in 2001 and an out in order to ascertain what different types and Invasive Plant Study in 2015. Waterval Smelter and ACP operational areas of the site are all on hard densities of exotic and indigenous species are standing with very little to no vegetation is present. It is recommended that this management measure be found in the area. removed based on input and motivation from a biodiversity specialist. The specialist study was undertaken between 1-3 September 2020 as confirmed with the Retained Operations Environmental Officer. A comprehensive botanical survey will be PC SRK understands that the last botanical study specific to the ACP operation was done in 2001 and an conducted in order to ascertain the plant ecology Invasive Plant Study in 2015. Waterval Smelter and ACP operational areas of the site are all on hard and soil type. standing with very little to no vegetation. It is recommended that this management measure needs to be

EMPr Commitment Level of Reason for audit finding compliance removed based on input and motivation from a suitable specialist. The specialist study was undertaken between 1-3 September 2020 as confirmed with the Retained Operations Environmental Officer. Flora assessments and alien eradication PC It is understood that a specialist company has been appointed to undertake the assessment and develop the programmes will be implemented according to programme. It is recommended that this management measure needs to be removed based on input and the regional BAP. motivation from a suitable specialist. The specialist study was undertaken between 1-3 September 2020 as confirmed with the Retained Operations Environmental Officer. A comprehensive botanical survey was Noted SRK understands that the last botanical study specific to the ACP operation was done in 2001 and an conducted to ascertain: the types of indigenous Invasive Plant Study in 2015. An additional survey will be undertaken between 1-3 September 2020 as vegetation; the numbers and density if confirmed with the Retained Operations Environmental Officer. indigenous plants as well as their dominance and community structures, e.g. riverine, veld, etc.; the disturbance of vegetation, due to the Smelter and farming activities; the presence of invader and exotic species; the presence of rare or exotic species, and to integrate the plant ecology with the soil type. No employees will be allowed to hunt, snare, Noted Small animals were not observed within the operational area during the audit. It is recommended that this trap or kill any small animals in or around the specific condition is included in the site induction and procedures which are currently being revised as site. understood by the Auditor. Any potential spills of contaminants will be C Spill kits are present at different locations around the site. Waterval Smelter and ACP operational areas of restricted with bunding and clean-up the site are all on hard standing. Bunding is in place and is adequate. immediately. Fauna assessments will be implemented C An assessment was undertaken between 1-3 September 2020 as confirmed with the Retained Operations according to the regional BAP. Environmental Officer. Topographical disturbance must be confined to NA No additional buildings or infrastructure have been built during the audit period. areas required for the construction of additional buildings and infrastructure. Where erosion channels form, they must be re- C Erosion channels were not observed during the audit profiled and top-soiled. The cause of erosion must be investigated and addressed. Oils, greases, diesel and other chemicals will be C Storage areas are present Waterval Smelter and ACP. During the site visit, the storage areas were observed stored in the prescribed manner and within to be in good condition. The storage area is bunded and secure. Adequate signage was also observed. bunded areas to prevent soil contamination. If a spillage occurs the spillage will be cleaned C The spill handling procedure was provided to the auditor, and spill kits are available. immediately and the contaminated area will be rehabilitated, as appropriate.

EMPr Commitment Level of Reason for audit finding compliance A rapid response team should be available on C It is understood that a rapid response team is available on a 24-hour basis in line with the Emergency 24-hour notice to deal with hazardous spillages. Response and Preparedness Plan for Waterval/ACP which was provided to the Auditor. External contractors will service all vehicles on a C It is understood that external contractor vehicles are not serviced with the Waterval and ACP areas. regular basis off-site at their designated service facilities. Regular inspections of the foundations and NA It is assumed that this requirement relates to mining operations and not to Waterval Smelter and ACP. It was surrounding geological rock strata will be noted in the previous environmental audit that an annual report on the structural conditions for ACP was undertaken to ensure stability of the supporting undertaken in 2017. fill and strata. If required, remedial measures will be NA It is assumed that this requirement relates to mining operations and not to Waterval Smelter and ACP. It was implemented to reinforce areas of potential noted in the previous environmental audit that an annual report on the structural conditions for ACP was instability. Copies of stability inspection reports undertaken in 2017. will be kept on-site. The topography of the site will be regularly C Small sections of erosion was noted at the slag stockpile to the north of the Smelter. Ponding was not inspected for signs of erosion, ponding, observed during the audit. Access to the area is not restricted and unauthorised dumping was not observed. unauthorised dumping and general misuse. The Environmental Officers undertake regular site inspections. The next inspection scheduled in September 2020. Areas affected by erosion and ponding will be PC The slag stockpiles are not vegetated or profiled as they are reprocessed. re-profiled and re-grassed. Dam safety inspections will be undertaken C Dam safety inspection is undertaken on annual basis with the last dam safety report issued in February 2020. regularly to safeguard against failure. Copies of It is understood by the auditor that the ACP Pollution Control Dam is not a dam with a safety risk and the report will be kept on file at the Smelter. therefore dam safety inspections are not required. This requirement must be removed. If necessary, the vegetation cover in the areas NA Waterval Smelter and ACP operational areas of the site are all on hard standing with very little vegetation. prone to erosion and instability will be During the time of the audit erosion was not observed in the operational areas. maintained by regular watering and seeding. Contamination control structures, such as bunds C It is understood that the Environmental Coordinator does regular inspections. During the site visit it was and retaining walls, around all potential sources noted that bunds and retaining walls were intact. of contamination on the site will be regularly inspected and repaired, if required, to retain their structural integrity. Road, rail and foot access will be controlled and C Access to Waterval Smelter and ACP is controlled and access routes are designated for road, rail and foot limited to designated routes only. access. Soils affected by erosion, unauthorised removal, PC Erosion and unauthorised removal was not observed during the audit. A spillage outside the bunded area spillages, etc. will be restored where necessary. with the dirty areas was noted at the ACP area. Rehabilitation (to a quality approaching ambient employing the principles of BATNEEC) or

EMPr Commitment Level of Reason for audit finding compliance passivation will be conducted in the areas shown to have high levels of contamination. Incident reports will be maintained for chemical C All issues and incidents are logged on the Enablon system and allocated to a responsible person to resolve. spillages as well as any removal and disposal. The system is updated once the issue has been closed out. If there are any changes to current activities C It is understood that there has not been any changes to the current activities. testing of the baseline contamination levels and changes in the physiochemical characteristics of the local soils, both on-site and off-site, will be undertaken as part of Anglo American Platinum’s Rehabilitation Guideline. All chemical spills should be cleaned up C A spill handling procedure is in place and has been provided to the Auditor. Spills are cleaned up in line with immediately to the satisfaction of the the procedure. Spill kits are available on site. Environmental Control Officer by removing the spillage together with the contaminated soil and by disposing of them as hazardous waste. Rehabilitation will be undertaken on areas which NA Soil sampling and analysis have not been undertaken; therefore contamination cannot be assessed. show high levels of contamination. Only authorised land uses will be allowed on C It is assumed that all of the land uses associated with the Waterval Complex and its operations have been Anglo American Platinum property around the authorised in terms of the 2016 Consolidated EMPr. ACP Plant. Continual contact with key stakeholders will be C It is understood that contact with stakeholders is undertaken through the SED team through quarterly maintained in order to prevent illegal land use. meeting Lined facilities will undergo routine checks by C Lining inspections conducted by SRK once every year or two years. No formal programme is in place but ACP, according to DWS regulations. inspections are conducted therefore the auditor is of the opinion that Waterval Complex are complying to this condition. On-going training will be implemented to inform C Site specific induction presentations are presented to new employees and visitors. As part of the site audit, employees of the various procedures on site. SRK undertook induction as well as Covid-19 training. Refresher inductions are conducted annually. In addition, toolbox talks are held in the different sections, using site specific training material. Several examples of tool box talks were made available to the auditor for review. Training is conducted in line with the Training, Awareness and Competence Procedure (Ref No ACP-ALL-SHE-PRO-0002 – April 2019) which specifies the types and levels of training required for internal staff and external contractors and visitors. Employees will be educated by means of C An Environmental Awareness Plan is presented for the Anglo American Group. The plan forms a guideline induction and environmental awareness to make for site specific induction presentations them aware of the necessity to prevent spillages by the implementation of good housekeeping Site specific induction presentations are presented to new employees and visitors. As part of the site audit, practices. SRK undertook induction as well as Covid-19 training. Refresher inductions are conducted annually. In addition, toolbox talks are held in the different sections, using site specific training material. Several examples of tool box talks were made available to the auditor for review. Training is conducted in line with the Training,

EMPr Commitment Level of Reason for audit finding compliance Awareness and Competence Procedure (Ref No ACP-ALL-SHE-PRO-0002 – April 2019) which specifies the types and levels of training required for internal staff and external contractors and visitors. The perimeter fences will be regularly inspected C It is understood that a contracted security company is responsible for conducting routine checks and and maintained to deter unauthorised monitoring. Perimeter fences were observed at the time of the site audit. trespassing in the area. Material Safety Data Sheets will be updated C MSDSs were observed during the site visit. The MSDSs are updated when new products, substances or regularly and be available on site. chemicals requiring an MSDS are brought onto site. The hazardous material coordinator approves new products on site and ensures the MSDS are in place. Erosion will be remediated directly after major C It is the Auditor’s understanding based on conversations with the site personal that monthly inspections are storm events. carried out by the SHE department and daily walkarounds take place at the Waterval Complex. Since these inspections are undertaken on a daily basis, it is assumed aspects such as erosion will be observed daily and not just after major rainfall events. Any spills on roads will be removed. C Areas within the Waterval Smelter complex are on hard standing .A sweeper routinely sweeps the roads within the fence line as well as the tarred road leading up to the railroad crossing on the east of the ACP Implement water saving technologies. Optimise C The 2019 IWWMP notes that water savings initiatives have been facilitated by AAP’s participation in a reuse of process water. program initiated by the Western Limb Producers Forum in 2012 to explore additional opportunities for water conservation and water demand management (WC/WDM), and the development of the Water Action Plan (WAP), Phase 1 (Aurecon, 2013) and Phase 2 (Aurecon, 2015). The WAP and various initiatives and measures implemented and planned are described in Retained Process Operations. To avoid or where not possible, minimise and C The 2018 Regulation 704 audit indicate that the ACP plant area drains naturally from north to south. Vertical remedy pollution of groundwater during all drains running north to south collect and direct stormwater to a perpendicularly running canal which drains to phases of the operation. the ACP dam. The clean and dirty separation is working well and efficiently. The ACP dam is lined with a spillway which will overtop in emergency situations, flowing into the Klipfonteinspruit upstream of the bridge. The slag stockpile area is noted as a point source for potential groundwater pollution and should be investigated. Manage vegetation and stormwater to minimise C Stormwater is managed as described in the sections above. Residue deposits is not placed within the erosion. Manage dust from residue deposits and Waterval Smelter and ACP areas. Erosion were not observed during the audit on roads to minimise sedimentation from dust fallout in surface water resources. To avoid or where not possible, minimise and C Clean water diversions are in place at each operation to disperse runoff from the site and roads. Dirty remedy pollution of surface water during all stormwater measures are in place at the operations. phases of the operation. Minimise dirty water areas to reduce the volume of dirty water runoff required to be collected. Minimise development in riparian zones. C Clean water diversions are in place at each operation to disperse runoff from the site and roads. Dirty Manage riparian habitat. To avoid or where not stormwater measures are in place at the operations. No further construction activities are noted outside of the

EMPr Commitment Level of Reason for audit finding compliance possible, minimise and remedy pollution of existing Waterval Complex footprint area. The riparian habitat is monitored by Cleanstream Environmental surface water during all phases of the operation. Biomonitoring programme. All runoff will be routed via the existing C The 2018 Regulation 704 audit indicate that the ACP plant area drains naturally from north to south. Vertical stormwater system to the pollution control drains running north to south collect and direct stormwater to a perpendicularly running canal which drains to dams. No discharge of water into the the ACP dam. The clean and dirty separation is working well and efficiently. environment will take place. The ACP dam is lined with a spillway which will overtop in emergency situations, flowing into the Klipfonteinspruit upstream of the bridge. Hazardous chemical storage should be done in C Storage areas are present Waterval Smelter and ACP. During the site visit, the storage areas were observed an area that is bunded according to to be in good condition. The storage area is bunded and secure. specifications to contain spillages. Dirty and clean water will be separated by C The 2018 Regulation 704 audit indicate that the ACP plant area drains naturally from north to south. Vertical implementing clean and dirty water drains running north to south collect and direct stormwater to a perpendicularly running canal which drains to systems/structures prior to construction to the ACP dam. The clean and dirty separation is working well and efficiently. prevent pollution of clean water runoff. The The ACP dam is lined with a spillway which will overtop in emergency situations, flowing into the existing dirty and clean water systems will be Klipfonteinspruit upstream of the bridge. maintained. The clean and dirty water systems and structures will be properly designed (according to Regulation 704 of the National Water Act). Ensure that contractors are aware of the C Contractors are required to go through induction which includes reference to the site emergency procedures. procedure to handle emergencies and spillages Contractors are required to comply with the site procedure document (ACP ALLSM-EPR-ENG-STD-006). according to the site ISO14001 system. The water balance will be updated regularly, C The water balance is updated on a monthly basis. Flow measuring devices are in place to measure flow of water usage monitored and optimised, where water into the authorised Section 21(g) water uses, which provide information for the annual water balance possible. This will be done by the addition of water meters and data management system. The real-time monitoring of flows and electrical PC Realtime monitoring is undertaken for flow on the Klipfonteinspruit. EC and pH is not conducted due to theft conductivity (EC) and pH in the Klipfontein of the equipment. This condition requires amendment to indicate that only flow monitoring will be undertaken. Spruit will be undertaken upstream, opposite Annual WUL audits are undertaken and the most recent WUL audit has been made available to the auditor and downstream of the Smelter. Compliance for review. Water quality is also monitored and annual monitoring reports have been provided to SRK as with the Water Permits will be monitored and proof. It is understood by the auditor that exceedances are noted and reported to the DHSWS. exceedances will be investigated and reported. Existing monthly monitoring programme at other C Sampling of surface water and groundwater is conducted by Aquatico. The 2019 IWWMP indicated that sites along the Spruit will be maintained. there are currently 37 active surface water quality monitoring points including the process water monitoring points.

EMPr Commitment Level of Reason for audit finding compliance Monitoring of volumes and qualities of storm NC SRK understands that monitoring of volumes and qualities of stormwater inflows and discharges is not done. water inflows and discharges from the These systems are cleaned regularly however there are still instances where there is silt build-up. This is interception trench systems and the pollution currently being planned by the Group’s lead for process water operations and has been budgeted for 2021. control dam will be undertaken regularly.

Measures implemented to address the non-compliance Monitoring of volumes and quantities of stormwater inflows and discharges is currently being planned by AAP’s group lead for process water operations.

Practicality of the EMPr commitment Practical

Non-compliance administrative or will have an impact May have an impact on managing risk as potential pollution to the environmental will not be able to be assessed.

Historical/new non-compliance Historical non-compliance

A monitoring and management programme for C A monitoring and maintenance programme are in place at ACP - PMO3s, automatic notifications are sent the routine maintenance and cleaning of all when work needs to be undertaken. Waterval Smelter has a cleaning team assigned to undertake routine trenches will be put in place in order to prevent maintenance and cleaning of all trenches. silting of trenches and subsequent contamination. Incidents will be recorded, and reported, if C All issues and incidents are logged on the Enablon system and allocated to a responsible person to resolve. necessary, and files will be kept on-site. The system is updated once the issue has been closed out. Annual reports will be generated that are to C Surface water and groundwater monitoring is undertaken as per WUL requirement. Annual monitoring reports include monitoring results as specified in terms have been provided to SRK as proof. of legal requirements. Storm water management strategies will be C A monitoring and maintenance programme is in place at ACP - PMO3s, automatic notifications are sent when updated to include the maintenance and work needs to be undertaken. Waterval Smelter has a cleaning team assigned to undertake routine cleaning of all storm water systems. maintenance and cleaning of all trenches. Co-operative management between Smelter and C The sharing of infrastructure between Sibanye and RPM is done. Water from the Waterval Concentrator RPM (specifically the Waterval Concentrator) passes through the Waterval Smelter area for storage and reuse. must be implemented to ensure that all water is handled using the best management options available.

EMPr Commitment Level of Reason for audit finding compliance An integrated management system (surface and PC An integrated management system aligned with the WUL is in place for the Process Divisions. Anglo groundwater) must be implemented between the American Platinum does not have a mining division at RPM. Amendment to this condition is required. It is Process and Mining divisions. recommended that this condition is updated. Water management reports must be submitted C An annual water report is compiled and it is the Auditor’s understanding that this is submitted to DHSWS in to DWS annually within three (3) months of the accordance with conditions of the WUL. close of the hydrological year (1 September – 31 August). Accurate up-to-date records of all system C All issues and incidents are logged on the Enablon system and allocated to a responsible person to resolve. malfunctions, and any incidents that cause or The system is updated once the issue has been closed out. may cause water contamination or abnormal consumption must be monitored. If required, future dams, cut-off trenches and NA No new dams, cut-off trenches and other collection structures have been constructed during the auditing any other collection structure will be constructed period to ensure that at least 0.5 meters of freeboard is kept above the maximum water level. Site water management plans must be C The IWWMP was updated in 2019 and provided to the auditor. established. Nitrate, chloride, sodium and sulphate levels C Nitrate, chloride, sodium and sulphate levels are monitored on a monthly basis at selected surface water must be monitored on a monthly basis. monitoring points. A monitoring point must be installed by RPM, NA It is SRK’s understanding that based on the requirements of the detailed IWWMP, monitoring of the Naude downstream of the Naude Dam, before the Dam is not required for the purposes of the retained operations, but rather relates to mining operations. This confluence of the Hex River. commitment must be amended or removed. Should future river diversions be proposed, all NA No new diversions were noted during the audit. associated impacts will be assessed and relevant impact studies will be commissioned. Samples of waste products resulting from the NA It is SRKs understanding from the previous environmental audit that the waste products are no longer operation of the SCF will be analysed annually disposed within the TSF following the sale agreement. The waste material is now stored on the slag to ensure that the potential for leaching of toxic stockpiling area. It is recommended that this condition be amended to reflect the current situation elements from their disposal on the RPM tailings dam is understood. If any traces of leaching are found in the results NA Gypsum disposal was not observed during the time of the audit. from the monitoring programme, alternatives for gypsum disposal from the SCF will be investigated, such as the re-circulation of the gypsum back into the furnace.

EMPr Commitment Level of Reason for audit finding compliance

The existing borehole and groundwater C A monitoring and maintenance programme is in place at ACP - PMO3s, automatic notifications are sent when interception trench systems will be maintained work needs to be undertaken. Waterval Smelter has a cleaning team assigned to undertake routine and extended where necessary. maintenance and cleaning of all trenches.

The borehole and trench system will be C A monitoring and maintenance programme is in place at ACP - PMO3s, automatic notifications are sent when monitored regularly. work needs to be undertaken. Waterval Smelter has a cleaning team assigned to undertake routine maintenance and cleaning of all trenches. The existing groundwater flow and solute NC Groundwater monitoring is undertaken on a quarterly basis, however the groundwater model is not updated transport models for the site will be updated on a quarterly basis. This requirement needs to be revised as a quarterly updating of a groundwater model quarterly using the monitoring information. will not provide meaningful information on which management decision can be made. According to communication received from the geohydrologist who has conducted work at RPM, the groundwater model should be revised every three to five years as it is impractical to revise it over short term periods.

Measures implemented to address the non-compliance No measures have been undertaken to date. The condition will be amended as part of the EMPr update scheduled for 2020.

Practicality of the EMPr commitment Not practical as a quarterly updating of a groundwater model will not provide meaningful information on which management decision can be made

Non-compliance administrative or will have an impact Administrative to change frequency of updating the model

Historical/new non-compliance Historical If required, additional remedial measures will be C Aquatico monitors groundwater quality and water levels on a quarterly basis. It is understood from the implemented. previous environmental audit that RPM installed groundwater scavenging boreholes historically, in an effort to pump and treat groundwater at surface to prevent plume migration. The 2019 WUL audit notes that progress on pollution plume remediation must be indicated. Should significant groundwater contamination be NA It is SRKs understanding that remediation plan has not been developed as significant groundwater identified, then a remediation plan must be contamination has not been identified. developed. The Waterval Smelter site area must focus on C The Retained Operations Environmental Officer does regular inspections, where issues are identified these remedial efforts to improve the water run-off and are addressed. maintenance of the dams, to prevent contaminated waters from entering the groundwater.

EMPr Commitment Level of Reason for audit finding compliance The Waterval Smelter must prevent pollution C Waterval Smelter and ACP operational areas of the site are all on hard standing and where required certain from occurring from point and diffuse areas. areas are bunded Continue with the monitoring of the C The Klipfonteinspruit is monitored on a monthly basis. Klipfonteinspruit to detect any impacts. Limit vehicle and pedestrian access to the C Vehicle and pedestrian access to the Klipfonteinspruit riparian zone is limited riparian zone of the Klipfonteinspruit. If necessary, the Klipfonteinspruit will be fenced C Part of the Waterval Smelter Complex is within the riparian area of the Klipfonteinspruit. SRK understands off to the public and all vehicles. that it has not been deemed necessary to fence of the Klipfonteinspruitt Water management activities will be reported to C An annual WUL audit is undertaken and it is the Auditor’s understanding that the audit is submitted to the DWS in accordance with the water use license. DHSWS All incidents regarding water contamination and C All issues and incidents are logged on the Enablon system and allocated to a responsible person to resolve. abnormal consumption of the plant must be The system is updated once the issue has been closed out. recorded and submitted to the relevant authority. Dirty water and process water will be recycled C The polluted stormwater captured in the process water dams is recycled at all the operations, as far as practically possible. The water balance will be updated regularly, C The Waterval complex stormwater runoff as well as process water overflow is channelled to the Waterval water usage monitored on a daily basis and Complex: ACP PCD or the Waterval Concentrator East PCD depending on the runoff area within the optimised, where possible. operation. Stormwater runoff from the slag/wax stockpile area is channelled to the 250 dam along an earth channel. All water contained within these dams is reused by the complex or transferred to the refineries depending on where the need for process water exists. Incidents will be recorded, and reported, if C All issues and incidents are logged on the Enablon system and allocated to a responsible person to resolve. necessary, and files kept onsite. The system is updated once the issue has been closed out. Surface water samples will be taken from the C The Klipfonteinspruit is monitored on a monthly basis and the results were included in the annual report. Klipfontein Spruit on a monthly basis and included in the annual report. Reporting on groundwater quality conditions will C Groundwater quality conditions are reported to DWS through the annual report to DWS. be included in the annual report to DWS. Samples will be taken in the existing monitoring C Sampling is undertaken according to the existing monitoring programme which includes upgradient and down boreholes in the upgradient and down-gradient gradient points direction from the Waterval Smelter area, collated, integrated and corrective and preventative actions implemented. The water levels of the borehole localities near C Water levels are recorded during quarterly monitoring of the boreholes the Waterval Smelter will be measured on a quarterly basis. To further reduce the risks of groundwater C Spill kits are present at different locations around the site. Waterval Smelter and ACP operational areas of contamination from spills, the transport, storage the site are all on hard standing. Bunding is in place and is adequate.

EMPr Commitment Level of Reason for audit finding compliance and handling of chemicals, fuels and wastes will be in accordance with standard best practice. Items such as fuel, oils, lubricants and detergents will be stored and handled in dedicated, lined and bunded facilities. The bunding will be designed to contain and hold 1.5 times the storage capacity of the facilities. An effluent management plan, outlining C An Effluent Management Plan is in place and addressed the requirements for an effluent management plan. emergency measures, alternatives, rehabilitation as well as awareness training of employees will be commissioned. The Process Division is required to implement a C Biomonitoring is carried out twice a year during the wet and dry season. The Summer 2019 report indicated bio-monitoring programme on the Klipfontein that a long term monitoring programme commenced during December 1999. Spruit by June 2000. This will include, but not be limited to, a fish health assessment index (FHAI) and a fish community integrity index (FCIT), at a downstream monitoring point. The preliminary findings of the report from the C It is SRKs understanding that Groundwater models were developed by RPM in 2006, 2011 and 2013. RPM Institute for Groundwater Studies on the aquifer instituted a pilot project which involved pumping of groundwater from underground and treating the water at underlying the Smelter, is that the groundwater surface to remediate the contamination issues. The project was not successful due to the crystallisation of below the Smelter is contaminated. However, the dissolve solids within the pump and piping systems. The drilled boreholes are incorporated into the some additional boreholes, as recommended in groundwater monitoring program. the IGS report, have been recently drilled but not yet surveyed and digitised. The remainder of the To the north of the Smelter, there is a slag stockpile area as well as the TSF which are both potential boreholes are to be drilled in the near future. contributors to groundwater issues. The TSF is operated and owned by Sibanye (as of November 2016) Contributions to the groundwater contamination by the Smelter operations are undetectable or negligible. This is due to the major source of total dissolved solids (and individual elements) emanating from the north of the Smelter. Continued monitoring will be conducted on all C Groundwater monitoring is undertaken on a quarterly basis however the groundwater model is not assessed the boreholes for 8 months of the year, and annually. According to communication received from the geohydrologist who has conducted work at RPM, assessment of the groundwater model will be the groundwater model should be revised every three to five years as it is impractical to revise it over short undertaken annually for its incorporation in the term periods. According to the 2019 annual water quality data (Groundwater Complete, 2019), all boreholes annual report to the DWS. were compliant with the WUL limits for pH, however majority of the boreholes exceeded the WUL limits for sodium, calcium, magnesium and sulphate. Half the boreholes exceeded the WUL limits for chloride.

EMPr Commitment Level of Reason for audit finding compliance Methods of remediation are being investigated, C A groundwater interception trench in the north which is linked to the Smelter drains is in place. such as groundwater inception trenches in various places. One option is to place a trench along the northern boundary of the Smelter to cut off the movement of dissolved solids emanating from the north of the Smelter. Other cut off trenches could be constructed in places along the northern banks of the Klipfontein Spruit to prevent dissolved solids entering the shallow aquifer. As no legitimate users exist on the Smelter's C Waterval Smelter and ACP operational areas of the site are all on hard standing and where required certain area of responsibility, the Smelter will focus areas are bunded. Regular inspection are undertaken. The slag stockpile to the north of the Smelter requires remediation efforts on continual improvement of appropriate measures to manage potential impacts on the groundwater. the site water run-off, and maintenance of the dams, to prevent polluted waters from entering the groundwater. No brightly coloured paints will be used on C Highly visible structures with bright coloured paint were not observed during the audit. highly visible structures. Visible stack emissions will be reduced as part C Stack emissions are reduced by the ACP which is a major mitigating factor of pollution plumes. of the management of air emissions, in particular, total suspended particulates. Stack emissions must be monitored and C The site has an Atmospheric Emissions Licence, stack emissions and isokinetic sampling is done in line with management, procedures must be implemented the requirements of the licence. The Atmospheric Impact Report for Waterval Complex was provided to the to improve the visual emissions. Auditor for review and indicates the average values for each point source within the complex for the period 2015 to 2017. Visible stack emissions, in particular total NA It is SRK’s understanding that the SCF 2 has not been constructed. suspended particulates, will remain less than 50mg/Nm3 for the SCF2 stack. Dust suppression will be ensured. C Excessive dust was not observed at Waterval Smelter and ACP during the audit. Dust sampling is undertaken by Aquatico on a monthly basis. The dust fallout report for May to June 2020 indicated that dust levels were in compliance with the required limits. Sulphur abatement strategies currently being C The acid plant is an abatement to the sulphur generated at the smelter. This plant is operational. Acid is considered include a changing over from the generated using emissions from the Smelter and ACP operations. The acid is transported off site to a third current converting process to more effective party using vehicles which are considered complaint with SANS 10228. sulphur capturing converting process. This would include a new downstream plant to convert captured sulphur from the new

EMPr Commitment Level of Reason for audit finding compliance converting process, more effectively into acid. Sulphur emissions from the Furnace operations would also be captured more effectively. All issues/complaints will be included within the C Environmental incidents are recorded within the Enablon system and allocated to a responsible individual for existing EMS system. rectification. It is monitored to close-out and records were available to the auditor as proof. A complaints register is available and complaints received are tracked using the Enablon software; A public participation communication and consultation procedure has been compiled and provided to the Auditor. The Engineering and Maintenance Departments C SRK understands that a collection of ‘group governance’ engineering maintenance procedures is compiled by of Waterval Smelter will ensure that plant RPM. If a defect is noted with a plant hire vehicle or equipment it will be removed from site and serviced by equipment complies with manufacturer the plant hire company. RPM vehicles are serviced onsite within controlled workshop areas. Spot checks specifications. were completed by the auditor. According to discussions with the Retained Operations Officers, a daily pre-use checklist is used to observe any leakage or other issues. The auditor did not see any documentation pertaining to this. No equipment leaks or pipeline breakages were observed at the time of the site inspection audit. The Maintenance Department of Waterval C Each vehicle, if plant hire or resident vehicle, is accompanied by a service record (within the contractor file or Smelter will maintain all equipment to prevent maintenance department’s office). the record provides clarity on when the next service is required. increased noise levels. Area noise assessments have been conducted and noise levels are below the limit of 85 dB. No issues have been raised concerning noise levels. Occupational noise testing is undertaken by the occupational department on the mine. The internal occupational hygiene team undertake noise monitoring throughout the site to ensure noise level compliance. An Area noise schedule was provided to the auditor which indicates the different areas that are surveyed at RBMR. Noise surveys for the various areas within PMR and the Waterval Complex have been provided to the Auditor. Noise levels both in and around Waterval C As Above Smelter will monitored as part of the responsibility of the Occupational Hygiene Department and compared to SABS limits for day-time and night-time noise levels. Comprehensive noise monitoring must be undertaken as per the Occupational Hygiene Programme, when action is required appropriate plans must be implemented. Extend the existing monitoring programme to NC Slag is being re processed. The monitoring network has not been extended to include the slag stockpile. include any new developments that may take place adjacent to the Smelter. Measures implemented to address the non-compliance No measures have been undertaken to date.

EMPr Commitment Level of Reason for audit finding compliance Practicality of the EMPr commitment Practical

Non-compliance administrative or will have an impact May have an impact on managing risk as potential pollution to the environmental will not be able to be assessed. Historical/new non-compliance Historical

PPE must be made available to all employees. C Employees were noted to be using the correct PPE in all areas observed during the site visit. It is noted that a PPE register is maintained for all staff. The high noise levels generated at the oxygen NC A environmental noise survey report was undertaken in August 2017. The report concluded that from the 5 plant (at ACP) will be investigated further and selected sampling point only three points complied and two sampling points results were slightly above the management plans formulated to reduce these standard for the day time measurements. All sampling points did not comply with the 35 dBA night time levels. standards. A management plan with mitigation measures has not been developed.

Measures implemented to address the non-compliance No measures have been undertaken to date.

Practicality of the EMPr commitment Practical

Non-compliance administrative or will have an impact May have an impact on managing risk as noise nuisance and impact to the employees and surrounding communities will not be able to be assessed. Historical/new non-compliance Historical Maintenance will be conducted on the SCF and C Engineering procedures are compiled by RPM and include components of the SCF. The occupational related structures on a regular basis to ensure hygiene noise assessments act as confirmatory exercises. that no excessive noise above 85 dB is created Area noise assessments have been conducted and noise levels are below the limit of 85 dB. No issues have from its operation. been raised concerning noise levels. Occupational noise testing is undertaken by the occupational department on the mine. The internal occupational hygiene team undertake noise monitoring throughout the site to ensure noise level compliance. An Area noise schedule was provided to the auditor which indicates the different areas that are surveyed at RBMR. Noise surveys for the various areas within PMR and the Waterval Complex have been provided to the Auditor.

EMPr Commitment Level of Reason for audit finding compliance Vehicle exhaust systems will be inspected and C Each vehicle is monitored by the department and serviced based on the manufacturer service schedule. maintained to prevent excessive noise. According to the Retained Operations Environmental Officer, each vehicle, if plant hire or resident vehicle, is accompanied by a service record (within the contractor file or maintenance department’s office). the record provides clarity on when the next service is required. Monitor noise levels after construction to identify C Comprehensive occupational noise monitoring is undertaken by the Occupational Hygiene team based on a impacts in advance. set program. The environmental team did not note any noise related issues detected by the monitoring events. Vehicles and equipment should undergo regular C It is noted that each vehicle, if plant hire or resident vehicle, is accompanied by a service record (within the inspection in order to ensure that they are in contractor file or maintenance good working order and thus prevent excessive department’s office). the record provides clarity on when the next service is required. Inspections are emissions of noise or fumes. completed prior to usage By the end of Stage B of ACP, the Sulphur C The ACP acid plant achieved the required objective. Isokinetic results for SCF Stack indicate an average Dioxide emission rates will be reduced to less emission rate which is well within the requirements of this commitment. than 20t/day due to increased sulphur fixation. By the end of Stage B of ACP, the Nitrogen C Isokinetic results for SCF Stack indicate an average emission rate which is well within the requirements of Dioxide emission rates including the new acid this commitment. plant will be at an average of 955.3tpa. By the end of Stage B of ACP, particulate C Isokinetic results for SCF Stack indicate an average emission rate which is well within the requirements of emissions will be at an average of 844tpa due to this commitment. the capture and direction of the fugitives from the furnace building to this stack. Appropriate instrumentation for real-time C The ACP stack is continuously monitored. Should a spike in emissions be detected, then the surrounding monitoring will be installed in the converter and land users are notified using an SMS notification system). The Isokinetic sampling/monitoring event is acid plant stacks. The monitoring will be completed once a year to confirm the stack emissions rates. compared in order to ensure compliance with the AEL. This will complement the ambient air quality monitoring and management that is on- going at the existing Smelter. Ground concentrations of Sulphur Dioxide and C Ambient concentrations of SO2 and PM10 are monitored by AAP at eight locations . The Smelter complex dust will be monitored at appropriate locations has a number of fence line live air quality monitoring systems. Dust fallout levels are measured at the along the perimeter of the site. This will be done ambient air quality monitoring stations, located within surrounding areas. Aquatico monitor dust buckets once by fence-line monitoring systems that will also a month and report is submitted to the operations. be on a real-time basis and the results will be compared to acceptable ground level concentration standards. Ground level concentrations of Sulphur Dioxide C Both sulphur dioxide and dust is monitored on a regular basis using personal monitoring devices. The and dust will be regularly monitored inside the monitoring devices detect levels of pollutants throughout the 8-hour shift.

EMPr Commitment Level of Reason for audit finding compliance plant as part of the on-going Occupational Hygiene programme. Ambient monitoring will be extended to include C The ambient stations monitor PM10. PM10 concentrations. Real-time monitoring at the existing off-site C Ambient monitoring stations are in place at the following locations: regional monitoring stations will be maintained - Paardekraal; and the coverage extended if necessary. - Maidique; - Brakspruit; - Wonderkop; - Klipfontein; - Waterval; - Hex River; and - Bergsig. The stations are maintained as required. Relevant sections of the plant will be shut-down C No plant shut downs were reported within this audit period (other than the annual shut down required for if there is a risk of exceedances of the license maintenance purposes) in response to exceedances of the licence requirements. requirements. Regular audits will be undertaken to assess that C Formal internal AEL compliance audits/reviews have been undertaken by RPM. A mass balance is the predicted emission reductions are realised in undertaken to ensure the operations remain within the annual emission rates. The AEL is based on hourly practise. averages. Opportunities for emission reductions will be C Emission reductions are continuously reviewed. It is SRK’s understanding that a project in place as part of continually reviewed. postponement application for Waterval Smelter to reduce emissions and to comply to postponed limits. Non-compliant incidents in terms of legal C The following cases are logged on the Enablon system: requirements or standards will be logged and - If an exceedance of the allowable emissions rate is recorded; records made available to the authorities, on a - If data is indicating a negative value; and quarterly basis. - If a complaint is received. Air quality related monitoring data and incidents information is provided to the District Authority as required by the AEL. The incident relating to the ACP explosion was also reported to the authorities (although it was reported to have no adverse impact on the environment). Annual monitoring reports will be produced and PC Monitoring is conducted and reporting of the monitoring results are issued to the Environmental Manager for submitted to the authorities as per current the Process Operations (Mr Dustin van Helsdingen). Isokinetic sampling reports do not get submitted to the requirements. authorities. RPM only submit the quarterly reports to the local municipality that aligns with the postponement application for Waterval Smelter. This condition is marked as partially compliant as the operations do submit quarterly reports for Waterval Smelter however it needs to be confirmed by the Retained Operations as to why annual reporting is not being undertaken. This condition may need to be amended in line with the current reporting submissions been undertaken by the retained operations.

EMPr Commitment Level of Reason for audit finding compliance Install ceramic filters to capture dust from the off C It is noted in the previous environmental audit that a Ceramic filter is fitted as Modules 1 through to 6, gas stream of the electric furnace. associated with stack ID ‘EF Weekly maintenance must be conducted on the C The Auditor received reports indicating that ceramic filters are checked on a daily basis and the filters are ceramic filters. replaced if needed. Maintenance is conducted on a ‘as and when’ basis and monitoring is ongoing. This commitment is valid as the work is happening however it is an ongoing process – it is therefore recommended that the condition is changed from ‘weekly’ to ‘ongoing’ maintenance. Assess monthly compliance against specified C There is no formal monthly assessment of compliance as this is not required by the AEL; however, there is conditions. Any exceedances will be reported real time monitoring within the stack which is compared to hourly average emissions rates to ensure and appropriate management plans formulated. compliance. In addition to this, internal AEL compliance reviews are conducted. Particulate emissions from SCF2 stack will be NA The SCF2 stack has not been constructed as of yet. This condition therefore does not apply to the audit less than 50mg/Nm3. period. SO2 emissions from SCF2 will be less than 2 NA The SCF2 stack has not been constructed as of yet. This condition therefore does not apply to the audit tonnes per day. period.

The design changes made to SCF2 will be NA The SCF2 stack has not been constructed as of yet. This condition therefore does not apply to the audit tested and evaluated after commissioning. period. Improvements made on SCF2 that can be applied to SCF1 to optimise the availability of SCF1 will be formulated in the form of an implementation plan 6 months after commissioning of SCF2. Align future actions with respect to the National C The ACP facility was constructed in 2001. The operations actions are therefore aligned with national Minimum Emission Standards being developed emissions standards. It is SRK’s understanding that a project in place as part of postponement application by DEAT. for Waterval Smelter to reduce emissions and to comply to postponed limits. Annual ambient air quality results must be PC Monitoring is conducted and reporting of the monitoring results are issued to the Environmental Manager for submitted to the relevant licensing authority. the Process Operations (Mr Dustin van Helsdingen). Isokinetic sampling reports do not get submitted to the authorities. RPM only submit the quarterly reports to the local municipality that aligns with the postponement application for Waterval Smelter. This condition is marked as partially compliant as the operations do submit quarterly reports for Waterval Smelter however it needs to be confirmed by the Retained Operations as to why annual reporting is not being undertaken. This condition may need to be amended in line with the current reporting submissions been undertaken by the retained operations.

Unmeasured emissions of sulphur dioxide must C A mass balance is undertaken to ensure the operations remain within the annual emission rates. The AEL is be calculated through mass balance based on hourly averages. It is SRK’s understanding that the current AEL does not require a mass balance. calculations.

EMPr Commitment Level of Reason for audit finding compliance The availability of all pollution abatement C The maintenance of the baghouse is being undertaken. equipment must be monitored. Air quality monitoring will be conducted on the C Real time monitoring is conducted on the Smelter Main Stack, the SCF Stack, the New Acid Plant Stack and air emissions from the SCF using the in-stack the Flash Dryer Stacks. In addition, the SCF is monitored annually using the isokinetic monitoring exercise. monitors. These results will be included in the RPM only submit the quarterly reports to the local municipality that aligns with the postponement application Air Quality Monitoring Report currently compiled for Waterval Smelter. and presented to the relevant licensing authority on a quarterly basis. If the monitoring equipment detects a reduction C The scrubbing system is maintained throughout the year during the annual routine maintenance. Monitoring in the scrubbing efficiency, power supply to the of performance flow is undertaken monthly at the gas plant. furnace will be reduced and maintenance performed on the scrubbing system. Monitoring equipment will be inspected on a regular basis. The scrubbing equipment will be maintained in C The AEL requires routine maintenance to ensure efficiency which is conducted by the site engineers using order to ensure alignment with the AEL. set procedures. There is no formal audit/monitoring report produced, only raw data which is compared to AEL limits to ensure no exceedances. A summary is submitted to OBSCO with relation to the main and ACP stacks. Should there be any spikes these are explained (i.e. reasons provided). For ACP, annual shutdowns caters for maintenance as well as ad hoc maintenance done. The emissions from the SCF will be included in C A 2018 atmospheric Impact Report compiled by Airshed included modelling study which included point the air quality modelling studies at Waterval source emissions from the Flash Dryers and the SCF.. A copy of this report was provided to the auditor. Smelter in order to ensure pro-active air quality management, based on modelling results. Potential dust sources such as dirt roads, C Excessive dust was not observed during the site visit. Dust suppression is undertaken. As far as can be exposed topography, soil stockpiles, rubble determine no dust related complaints have been received during the auditing period. heaps and embankments will be watered at suitable intervals to contain dust. Where appropriate, vegetation will be re- N/A Waterval Smelter and ACP operational areas of the site are all on hard standing with very little exposed established on exposed surfaces as soon as areas to re-establish vegetation. possible. Ambient air quality in terms of sulphur dioxide C Ambient monitoring stations are in place at the following locations: concentrations, in the vicinity of the Smelter will - Paardekraal; be monitored using accredited monitoring - Mfidikwe; stations. - Brakspruit; - Wonderkop; - Klipfontein; - Waterval;

EMPr Commitment Level of Reason for audit finding compliance - Hex River; and - Bergsig.

A real-time air quality monitoring system will be NC It is not considered practical to monitor SO2 with the HAWK model and the put in place in order to determine SO2 HAWK model is not used on site. Ambient monitoring is conducted but this is not predictive. RPM are busy concentrations on an on-going basis. A HAWK investigating predictive software together with the organisation’s Air Quality specialist. It is recommended that View Software system will be implemented to this condition is amended to state the predicative monitoring is an experimental process which is currently process data and predict ground level under investigation. concentrations of SO2 in the surrounding areas. This system will be implemented by September Measures implemented to address the non-compliance 2000 and will be used as a pro-active RPM are busy investigating predictive software together with the organisation’s Air Quality specialist. It is management tool during Acid Plant shutdowns. recommended that this condition is amended to state the predicative monitoring is an experimental process which is currently under investigation

Practicality of the EMPr commitment Practical

Non-compliance administrative or will have an impact Administrative – change in details of predictive methods to be used once confirmed.

Historical/new non-compliance Historical Waterval Smelter will monitor emissions of C A mass balance is undertaken to ensure the operations remain within the annual emission rates. The AEL is sulphur dioxide and dust on a continuous basis, based on hourly averages. Continuous monitoring is done at all stacks but not for all covered (e.g. dust not from the Acid Plant stack and the Main Stack. continuously monitored at the acid plant stack) However annual isokinetic sampling covers all source Unmeasured emissions of sulphur dioxide emissions. (fugitive emissions) will be calculated through The scrubbing system is maintained throughout the year during the annual routine maintenance. Monitoring mass balance calculations. The availability of all of performance flow is undertaken monthly at the gas plant. pollution abatement equipment will be monitored. As soon as the SCF2 comes on line and Barren NA The SCF2 stack has not been constructed as of yet. This condition therefore does not apply to the audit Floatation tails are period. generated for co-disposal with the Waterval concentrator tails on the Paardekraal tailings dam, a sample of the blended waste must be collected and analysed for the following: pH, EC alkalinity; cations – Ca, Mg, K and Na; anions –

EMPr Commitment Level of Reason for audit finding compliance

SO4, Cl, NO3 and F; SAAR leachable metals; and water leachable metals. No recruitment will be allowed on site. C According to Anglo American recruitment policy, employment offerings at the facility gate is not permitted. All employment must be advertised through the correct channels. The Waterval Smelter must capture all public C A complaints register is available and complaints received are tracked using the Enablon software; A public complaints in its EMS and close out. participation communication and consultation procedure has been compiled and provided to the Auditor. Procurement of services from local small, C It is the Auditor’s understanding, based on discussions held with Ms Estie Rupp and Ms Tumi Mathebula medium and micro businesses will be from Supply Chain and Procurement that the following procedures are in place to ensure that jobs are encouraged, where appropriate. advertised as widely as possible within the direct area surrounding the Retained Operations and are communicated to all of the SMMEs:

 The Retained Operations issue an expression of interest for all potential opportunities/ services required by the operations  The Retained Operations have a website on the Anglo-American website listed under ‘tools for suppliers’ where suppliers can register their entity  The Retained Operations also have local databases of their doorstep communities and make use of SEDA (small enterprise development agency), the NYDA (National Youth Development Agency) and the LED offices at the local municipality to post potential opportunities  The operations also compile an expression of interest questionnaire which is sent to current supplies who are Black-owned within the host community area. They send these questionaries’ to their database, NYDA, SEDA, North-West development corporation and to the business forums. The Retained Operations have a website on the Anglo-American website listed under ‘tools for suppliers’ where suppliers can register their entity. Local infrastructure such as roads, bridges and C All infrastructure maintenance is undertaken by the general Maintenance Department. The roads are shared storm water systems will be maintained and by Sibanye and RPM operations. upgraded if necessary. Training and skill development will be NA The Rustenburg Section 2015 Social labour Plan makes reference to ‘Portable Skills Training Interventions’. implemented for workers in line with the Portable skills can be referred to as those skills that relate to industries outside of the mining industry that can company’s Social and Labour Plan. be used to improve earning capacity during the life of mine and in the event that downscaling and retrenchments might occur. It should be noted that the Retained Operations are not required to have an SLP however, according to discussions held between the Auditor and the Senior Social Performance Manager (Process Division Services), Ms Tumelo Dilotsotlhe the SLP has been replaced by an SED roadmap which is aligned with the SED requirement in the Anglo Social Way. This is being reviewed to align with the Anglo Social Way 3. This commitment is one of the programmes within the SED. The SED is broad and also incorporates issues around CSI initiatives and SLP (pooling and sharing agreement with the Kroondale Mine). The process academy falls within in the SED but because there are multi functioning teams, HR are responsible for driving this but for Rustenburg operations, the budget sits with Mrs Dilotsotlhe and the overall

EMPr Commitment Level of Reason for audit finding compliance coordination of SED is within social performance but there are multiple stakeholders internally. The intent is to capacitate employees for employment opportunity beyond Anglo American. Where there are opportunities internally, they are considered for this. Security will be maintained. C Access to Waterval Smelter is restricted with security searches conducted on entering and leaving the site, and an induction completed prior to being allowed access. Medical facilities, transport of sick personnel and C First aid stations and kits are available at each of the retained operations. The Platinum Health care facility basic first aid requirements will be made will be contacted in the case of an emergency available to employees on site. Employees will be encouraged to acquire skills NA No closure is planned at this stage. after plant closure. Maintenance and capital expenditure projects are on-going in an effort to maintain the processing operations and extend the life of the operations as far as possible. Socio-economic impacts will be managed in NA The Rustenburg Section 2015 Social labour Plan makes reference to ‘Portable Skills Training Interventions’. accordance with the company’s Social and Portable skills can be referred to as those skills that relate to industries outside of the mining industry that can Labour Plan. be used to improve earning capacity during the life of mine and in the event that downscaling and retrenchments might occur. It should be noted that the Retained Operations are not required to have an SLP however, according to discussions held between the Auditor and the Senior Social Performance Manager (Process Division Services), Ms Tumelo Dilotsotlhe the SLP has been replaced by an SED roadmap which is aligned with the SED requirement in the Anglo Social Way. This is being reviewed to align with the Anglo Social Way 3. This commitment is one of the programmes within the SED. The SED is broad and also incorporates issues around CSI initiatives and SLP (pooling and sharing agreement with the Kroondale Mine). The process academy falls within in the SED but because there are multi functioning teams, HR are responsible for driving this but for Rustenburg operations, the budget sits with Mrs Dilotsotlhe and the overall coordination of SED is within social performance but there are multiple stakeholders internally. The intent is to capacitate employees for employment opportunity beyond Anglo American. Where there are opportunities internally, they are considered for this.

Assistance from the Anglo Zimele Hub (responsible for implementing youth programmes and socio-economic development programmes)

EMPr Commitment Level of Reason for audit finding compliance Regular meetings are taking place within the communities as well as with the municipality. Continue with the environmental forum that was C As Above. established during the construction phase, and any other forum, if necessary to maintain the I&AP process. Complete incident complaint forms on the C A complaints register is available and complaints received are tracked using the Enablon software; A public receipt of a formal environmental complaint and participation communication and consultation procedure has been compiled and provided to the Auditor. provide feedback to the complainant. Maintain the reductions in health risks achieved C The Occupational Hygiene Department undertake on-going monitoring programmes on air quality, noise and by the ACP project in collaboration with the working conditions. In the case of the ACP project, the reduction on air quality issues is noted as the most Occupational Hygiene Department. significant of the environmental aspects. Carry out a health risk assessment for Sulphur C It is understood by the Auditor that risk assessments were undertaken during the environmental approval Dioxide and particulates. process. Carry out risk assessment for the storage of C It is understood that a risk assessment for the storage of Sulphuric Acid is in place. Sulphuric Acid, and design and construct adequate measures (management and engineering) to ensure the safety of the staff and neighbouring communities in the event of a catastrophic event. Carry out accident risk assessments if there is C No equipment or operations at the ACP are deemed to present an unacceptable risk to staff or the public. any cause for concern that the equipment or operations at the ACP may represent an unacceptable risk to the safety and health of the staff or neighbouring communities. The Waterval Smelter must make all efforts to C It is the Auditor’s understanding, based on discussions held with Ms Estie Rupp and Ms Tumi Mathebula obtain services and consumables from local from Supply Chain and Procurement that the following procedures are in place to ensure that jobs are entrepreneurs, where possible. advertised as widely as possible within the direct area surrounding the Retained Operations:

EMPr Commitment Level of Reason for audit finding compliance

The operations also compile an expression of interest questionnaire which is sent to current supplies who are Black-owned within the host community area. They send these questionaries’ to their database, NYDA, SEDA, the North-west development corporation and to the business forums. The Waterval Smelter will ensure that an C A corporate level HIV/AIDS strategy is in place. Voluntary testing and counselling is made available to all HIV/AIDS strategy is in place and effectively Anglo American employees. The RPM health services developed and maintain the HIV/AIDS programme. implemented. The Smelter hosts an Operation HIV/Aids Committee tasked with carrying out the objectives of the strategy. In extreme cases, employees will be referred to the Platinum Health care facility. Training and skills development programmes will C Each of the processing operations has a Career Development Plan (CDP) and Identification of Training be implemented. Needs procedure which determines the training provided to employees. Training is provided to process academy students according to operational skill requirements. The relevant documents were available to the auditor as proof In accordance with the current practice of C The RPM CEF (under review to be aligned with the Anglo Social Way 3) is tasked with ensuring that a link is Waterval Smelter, regular communication and maintained between the Smelter and the local communities. Regular meetings are held via various feedback networks will be maintained through mechanisms where information is transferred liaison with the public. RPM has a communication, participation and consultation operational procedure which has been provided to the auditor (latest revision date: 2020/06/08). All relevant stakeholders are contacted and communicated with on an on-going basis Waterval Smelter will strive to maintain the C The facility is operated in line with the AEL and undertake internal AEL compliance assessments to strive for proposed levels of SO2 and particulate compliance to the AEL thereby reducing the health risks associated with the operation of the operation. emissions thereby ensuring that there are no additive health risks associated with the operation of the SCF. To avoid any potential conflicts will local C Any contractors required within the complex are provided a space within the complex to use for temporary communities and undue stress on limited site establishment. The contractors area is inspected by the environmental officer during site walkovers. resources locally, dedicated areas will be made Only temporary infrastructure is erected at the camp. available onsite for contractors to establish their own infrastructure. Infrastructure will include buildings for administration, security, stores, parking, and vehicle servicing and maintenance. The public participation process will be used to C The public participation process takes place on a project by project basis in line with the legislative set up formal channels of communications, requirements for public participation. As part of the process employment opportunities, if available, are representatives, labour unions, various communicated during engagement sessions. All interested and affected parties are notified of the project and interested and affected parties and forums. invited to form part of the public participation process These channels will be used to inform the public

EMPr Commitment Level of Reason for audit finding compliance of the motivation, the technical and environmental aspects of the project, socio- economic benefits, labour recruitment policies, planning and scheduling for the project. Informal trespassing will be prohibited and C Fencing is in place around the Smelting complex however, the slag stockpile area is not well monitored and controlled using perimeter fencing not access controlled Maintenance of all machinery related to the SCF C The scrubbing system is maintained throughout the year during the annual routine maintenance. Monitoring will be conducted as per the normal of performance flow is undertaken monthly at the gas plant. maintenance procedures and schedules for the Smelter operations in order to ensure that the equipment continues to perform the function it was designed for. Inspections will be carried out in accordance C A collection of ‘group governance’ engineering maintenance procedures is compiled by RPM. These are with the legal requirements where applicable. considered comprehensive enough to satisfy the requirements of this condition.

According to discussions with the Retained Operations Officers, a daily pre-use checklist is used to observe any leakage or other issues. The auditor did not see any documentation pertaining to this. No equipment leaks or pipeline breakages were observed at the time of the site inspection audit. All environmental monitoring equipment will be C Calibration of environmental equipment is undertaken as and when necessary. checked and calibrated as if required by legal standards.

Appendix C4: PMR

Conditions Level of Reason for audit finding Compliance EMPr Conditions for Precious Metals Ref. (PMR) Vegetation should be re-established on exposed C The operational areas of the site are all hard surfaced. During the audit some grassed areas were surfaces as soon as possible. observed on the outside of the operation (mainly at level 0 and by the canteen/office area in level 1). No exposed surfaces were identified at the time of the audit. Fauna and flora assessments and alien eradication C The BAP indicates that the PMR site is largely transformed and that there is no effect on flora noted as a programmes will be implemented according to the result. There are no concerns regarding alien invasive plants at PMR. The site is largely hard surface with regional BAP. little to no vegetation. During the site inspection, the environmental officer did express concerns about Rock Hyrax (Dassies) which present as a pest on site. The operation is currently exploring options to control this situation. Sustainable erosion control measures (for wind and NA No construction activities were undertaken during audit period. water) will be implemented and maintained where necessary in areas disturbed by the construction operations or the existing erosion control measures will be maintained. The soils removed during the construction phases NA No construction activities were undertaken during audit period. should be relocated to their designated sites as soon as possible to prevent loss to surface water runoff. A fire action plan must be in place and all firefighting C The fire equipment on site is serviced and maintained as and when required. A random check of fire equipment will be well maintained. equipment was conducted by the auditor. Fire extinguishers checked were within the service period. No open fires will be permitted on site. C Signage of no open fires is present on site. The employees are aware of the fire emergency protocols. Current strategies and emergency response C Employees are aware of the firefighting procedure. This procedure is included in the induction associated with veld fires will be in place. programme. All contractors and employees will be informed of the C Employees are aware of the firefighting procedure. This procedure is included in the induction firefighting strategy. Soil sampling and analysis in the vicinity of PMR C During the site audit, it was confirmed to SRK that Agreenco is in the process of undertaking soil samples should be undertaken every two years to ensure that and an analysis for this year (2020) soil contamination does not occur. Should soil contamination be discovered, a specialist NA The contamination levels are not high and discussion with the authority is not required at this time. SRK should be contracted to investigate the contamination has conducted sampling at the site and found very little evidence of contamination and is of the opinion and recommend possible manners of rehabilitation, if that the contamination levels are not at a level where remediation is required. SRK has suggested that required. These recommendations will be discussed RPM inform Agreenco to make recommendations in their upcoming assessment if and where remediation with the Department of Environmental Affairs prior to is required. implementation. Oils, greases, diesel and other (hazardous) chemicals C Chemical storage areas are present on level 1 and 2 of the site. During the site visit, the storage areas will be stored in the prescribed manner and within were observed to be in good condition. The storage area is bunded and secure. Adequate signage was bunded areas to prevent soil contamination. also observed.

Conditions Level of Reason for audit finding Compliance Material Safety Data Sheets will be updated regularly C MSDS were available for inspection during the site audit. The MSDS are maintained and updated by and be available on site. chemical store staff. If a spillage occurs the spillage will be cleaned C According to discussions held with the PMR environmental officer, no major spills have occurred in the immediately and the contaminated area will be last 6 months. In February 2020, there was a spill from the Helipad sewerage pump which entered Dam rehabilitated, as appropriate. A rapid response team 3A through the stormwater canals during a heavy rainfall event. The authorities were notified of the spill is available on 24-hour notice to deal with hazardous and SRK has received evidence of this notification. During the site audit no spills were identified. Spill kits spillages. are present at different locations around the site. Drip trays are also used on site. The site adheres to both a spill procedure as well as a Mandatory Code of Practice for Emergency Preparedness and Responses which are compiled for all of the sites. Spills are listed as an emergency response item within the Emergency Preparedness and Response Plan. This plan indicates that and Emergency Response Team with representation for all shifts including day shift is available to assist during emergencies. Ensure that contractors are aware of the procedure to C Contractors are required to watch an induction video induction which makes reference to spillages and handle emergencies and spillages according to the the clean-up procedure. The procedures are also kept on record in the safety file. site ISO14001 system. Dirty and clean water will be separated by C There are clean and dirty water separation systems in place on site. According to the environmental implementing clean and dirty water coordinator, no pipe leaks have been reported in the last few years. Stormwater canals and trenches are systems/structures prior to construction to prevent inspected by engineers on site. The facility is operating according to GN R704 general compliance as pollution of clean water runoff. The existing dirty and noted in the 2018 audit report; a few observations requiring attention were made (mainly around dam clean water systems will be kept separate, regularly maintenance). Many of these actions have since been addressed or are in the process of being inspected and maintained. The clean and dirty water addressed specifically around dam maintenance aspects. The stormwater canals are inspected systems and structures will be properly designed biannually (external) or fortnightly (internal) and after rain events and repaired and desilted, if required. All (according to Regulation 704 of the National Water water containment dams are lined. Act). All runoff will be routed via the existing stormwater C Water is only discharged to the river if the quality can be confirmed within discharge limits and within the system to the pollution control dams. No discharge of allowances of the WUL. Sampling is undertaken at the holding dam prior to final discharge. The WUL water into the environment will take place. allows for discharge to the environment and since this condition states that 'no discharge' will take place, it is recommended that it is amended in line with the WUL requirements. Lined facilities will undergo routine checks, according C Internal dam inspections are undertaken by the engineers once a month according to the environmental to relevant DWS regulations. officer. External dam inspections are undertaken every 2 years. A stormwater interception trench should be C The stormwater management plan for the site clearly indicates clean water diversion channels to the established upslope (south) of the site. The trench will south and the south east of the site. The stormwater flowing from the south towards the site is assumed be bunded on the downslope side and water collected clean and diverted to the river. in the trench should be pumped to the effluent dams. Effluent dam safety inspections must be undertaken C Internal dam inspections are undertaken by the engineers once a month according to the environmental by the resident engineers as well as the approved officer and copies are included in the EO file on site according to the Environmental Officer. External dam professional engineer on a regular basis to safeguard inspections are undertaken every 2 years.

Conditions Level of Reason for audit finding Compliance against failure. A copy of such inspections must be kept on site. The Code of Practices for Effluent Dams that are C The environmental officer indicated that the PMR Code of Practice document refers to the management adopted on-site includes emergency response of effluent dams. SRK have not seen this document. Dam inspections are undertaken to mitigate these procedures in the case of a flood and these should be risks. implemented to minimise danger to safety and prevent adverse impacts on the environment. Incident and management measures taken should be C A complaint and incident register is located on site and on Enablon. Employees are aware of the recorded and where required, immediately reported to procedure. Incidents and proposed management/mitigation measures have been included in the latest the DWS. Records should be kept on-site, and the annual integrated water monitoring report (September 2019-August 2019) provided to the auditor. information included in the annual water monitoring report submitted to the DWS. Water usage should be monitored by the existing C A water meter is installed and measures water from Rand Water. Readings are taken once a month. water meters and data management systems, with new meters being installed as they are required. The surface water monitoring programme should be C The occupational hygiene department undertakes the monitoring once a month. Surface water monitoring maintained throughout the operation of PMR and is conducted monthly and ground water on a quarterly basis. Water quality reports are submitted quarterly these values should be analysed to ensure to DHSWS. This information been included in the latest annual integrated water monitoring report compliance with the water use license. This (September 2018-August 2019 provided to the auditor. information should be included in the annual water monitoring report submitted to DWS. Utility water should be recycled as much as the water C The process water is recycled. Water is processed in a closed system. quality permits. Any water that cannot be recycled within the PMR should either be routed to another process use within Rustenburg Section or it will be stored within a dam at PMR. Periodic audits of the stormwater system should be C Stormwater system audits forms part of the WUL audits. The stormwater systems are also checked by the undertaken by the engineering department to check engineers on site. the integrity of the storm water system and check the silt levels. The silt from within the stormwater system should be C Stormwater channels were inspected during the audit. The channels were found to be well maintained collected if the silt is impeding the flow or workings of and free of silt and vegetation. the system. The sump should be cleaned after every storm in C The sumps are inspected daily and cleaned when required. excess of 10mm. Monitoring of volumes and qualities of stormwater C Stormwater runoff is collected in a number of small trenches within or around PMR. Along the eastern and inflows and discharges from the interception trench northern boundaries of PMR, there are clean water trenches to collect the stormwater that would

Conditions Level of Reason for audit finding Compliance systems and the stormwater dam (Dam 3) should be otherwise enter the area. The eastern clean water canal is discharged to the stream flowing along the undertaken as and when required. northern boundary of PMR. Stormwater discharges are monitored and the flow of water is monitored, in both stormwater release channels, to ensure the data is made available to the DHSWS. Stormwater inflows are monitored by means of automatic level monitoring. The level of the stormwater dam should be kept as C The water level in the dam is level controlled by using water as a supplementary feed to brine low as possible. concentrator or directly to polluted water dams or process and to water the garden surrounding the PMR operation. A monitoring and management programme for the C Stormwater channels were inspected during the audit. The channels were found to be well maintained routine maintenance and cleaning of all trenches and free of silt and vegetation. The PMR canals are inspected biannually (external) or fortnightly (internal) should be implemented to prevent the silting of and after rain events and repaired and desilted if required. trenches and subsequent contamination. The site should be regularly inspected for signs of C No unauthorised dumping was observed the time of the site audits. The facility security is extremely strict erosion, ponding, unauthorised dumping and general and thus unauthorised dumping is not likely to happen at PMR. misuse. Construction of two continuous monitoring points C According to the GN 704 audit report, stormwater generated in the Level 2 area is routed via stormwater (measuring flow and EC) at the storm water channel sumps to either stormwater dam 3A or 3B or to the environment. The flow of water and EC is monitored in discharge points i.e. (a) between the NW sump and both stormwater release channels. This was confirmed by the environmental officer during the site audit. Klipfontien Spruit and (b) between Dam 3 and the Klipfontein Spruit. PMR to implement a two-stage calcium removal C The GN 704 report indicates that all effluent arisings are handled either internally in the Values Recovery process with intermediate solids filtration to provide a Plant or by reversion to RPMR. Residues are ultimately returned to process via Waterval Smelter whilst calcium-free feed liquor to the effluent evaporation effluent liquors are neutralised and concentrated by evaporation prior to discharge to effluent dams. plants. The water balance will be updated regularly, water C The operational water balance is updated monthly by each processing operation. Water usage at the usage monitored on a daily basis and optimised, PMR is only monitored at the discharge point and at the Rand Water pipeline. Water usage readings are where possible. obtained monthly (not daily). Optimisation takes place where possible/practical. Annual reports will be generated that are to include C Monitoring is undertaken as per WUL requirements. Monitoring reports have been provided to SRK as monitoring results as specified in terms of legal proof. requirements. Surface water samples will be taken from the C Monthly sampling frequency applies to the surface water sampling program. Five samples are taken Klipfontein Spruit on a monthly basis and included in within the Klipfontein Spruit (both up and downstream) to understand the impact from the facility on water the annual report. quality. The results are submitted to the DWS on a quarterly and annual basis Reporting on groundwater quality conditions will be C Groundwater sampling is undertaken on a quarterly basis. These results are included within the quarterly included in the annual report to DWS. and annual DHSWS submissions. Groundwater monitoring reports were provided to SRK for review. Groundwater quality conditions have been included in the latest annual integrated water monitoring report (September 2018-August 2019) provided to the auditor.

Conditions Level of Reason for audit finding Compliance Samples will be taken in the existing monitoring C According to the 2020 WUL audit report, groundwater abstraction via the boreholes at RBMR has ceased. boreholes in the up-gradient and down-gradient DWS deregistered the two boreholes in May 2019. direction from the PMR area, collated, integrated and corrective and preventative actions implemented. The water levels of the borehole localities near the C The groundwater borehole level is recorded during each monitoring event (quarterly) and included in the PMR will be measured on a quarterly basis and monitoring reports. included in the groundwater database. Appropriate groundwater remediation measures will C RPM completed a pilot scavenging borehole project which was not successful . No further remediation be implemented pending the outcome of the test work measures have been implemented. currently being conducted at the RBMR. Based on external studies conducted after the failure of the RBMR test work done, it was concluded that the focus will be on point sources (preventing spills and new impacts on groundwater) as well as the water balance to minimise risk of dams overflowing. Reduce the amount of water used per ounce of PGM C According to the environmental officer, water targets are in place to achieve an overall reduction in usage. and Au produced. Reuse is seen as a primary means instead of using additional potable water from the Rand Water supply. Indigenous trees or shrubs should be planted along C Indigenous trees were planted in level 0 and level 1 the Bleskop/Rustenburg road to assist in shielding the site from public view Vehicle exhaust systems should be maintained to C Vehicles are maintained off-site. prevent excessive noise. Area noise levels will be conducted annually as per C Area noise assessments have been conducted and noise levels are below the limit of 85 dB. No issues the legal requirements. Current noise monitoring will have been raised concerning noise levels. Occupational noise testing is undertaken by the occupational apply. department on the mine. Comprehensive noise monitoring must be undertaken C Area noise assessments have been conducted and noise levels are below the limit of 85 dB. No issues as per the Occupational Hygiene have been raised concerning noise levels. Occupational noise testing is undertaken by the occupational Programme, when action is required appropriate hygiene department on the mine. plans must be implemented. PMR has identified the need for regular in-stack and C Stack sampling is done annually by 'Future projects". The 2019 Emission Testing Report (Dated 18-31 ambient sampling. October 2019) was provided to the Auditor for review. Vehicles and equipment should undergo regular C It is the Auditor’s understanding that each vehicle is accompanied by a daily inspection checklist. A inspection in order to ensure that they are in good sample checklist was made available to the Auditor. working order and thus prevent excessive emissions of noise or fumes. Systems should be in place to eliminate the visible C A scrubber system (operating fluid is 3N NaOH) is in place for Draught columns 1, 2 and 3. ammonium chloride plume from the main stack. Additional investigations will be conducted to more C Isokinetic sampling was done in 2019. No exceedances were noted report to be provided. accurately quantify the emissions of hydrogen

Conditions Level of Reason for audit finding Compliance chloride and assess appropriate remedial action as required. Ammonium chloride abatement equipment will be C According to the site engineer the ammonium chloride abatement equipment has been installed and is installed by the end of 2008. operational. Assess monthly compliance against specified C Isokinetic sampling was done in 2019. No exceedances were noted report to be provided conditions. Any exceedances will be reported, and appropriate management plans formulated. Apply for a new Registration Certificate to DEA as C PMR has a valid AEL, the 2018 amended AEL was received by the Auditor. part of the APPA (NEMAQA) project. The prescribed format will be used for the application. Align future actions with respect to the National C According to the environmental officer, the emissions limits are below the limits prescribed under the Minimum Emission Standards being developed by existing plant section of NEM:AQA Sub-category 4.17. As such, the facility is aligned with respect to the DEA. need to comply with new facility standards by 2020. RBMR supply steam to PMR and should commit to C A Howden Wet Scrubbing system is installed at the RBMR boiler site, as per AEL reference investigate and implement strategies to reduce BPDM/RBMR/AEL1.1/March2016. The AEL Particulate Matter limit is 100 mg/Nm3. Which is in line with current TSP emissions from the boiler plant. The the requirements of this commitment. future boiler installation at RBMR that will supply PMR with additional steam should have emission abatement equipment to reduce the TSP to less that 100mg/Nm3 for the air emissions from the boiler stack. This abatement equipment should be commissioned concurrently with the boiler. The monitoring of ambient PM10 concentrations C Dust monitoring undertaken on a monthly basis by Aquatico. Dust monitoring reports were made available should continue and these results should be reported to the auditor for review with the most recent report dated May to June 2020. Dust levels recorded were to key stakeholders. compliant. No issues relating to dust were recorded at all operations. It is assumed that the air quality monitoring results are included in the quarterly reports submitted to the municipality. Sampling and analysis of the emissions from stack C The environmental team indicated that isokinetic sampling is undertaken. The Auditor has received the 584 should be undertaken yearly in order to monitor Final Isokinetic sampling report dated 18-31 October 2019 which includes sampling and analysis of these emissions and confirm that they do not pose a emissions from stack 584. significant health risk to potentially sensitive receptor areas (residential). Modelling should be undertaken if it is shown that the emissions have significantly changed. The existing handling procedures for the management C PMR has decommissioned their incinerators and replaced these with the thermal beneficiation plant. They of ash should be reviewed and a more detailed have a thermal beneficiation plant which was installed in 2019. Previously, a low-grade incinerator treated sampling campaign should be undertaken to ensure all low-grade material. PMR also had a high-grade incinerator and the Crawl (treated the organics by the plant). All of this has been decommissioned (low grade incinerator and the Crawl) and replaced with the

Conditions Level of Reason for audit finding Compliance that current management is appropriate for thermal beneficiation plant. The environmental officer mentioned that ash generated goes back into the guaranteeing the health and safety of workers. processing process. The auditor has received the ash handling procedure (handling and sampling of incinerator ash).

Investigations should be undertaken to investigate the NA The previous audit findings indicate that the AEL does not require this to be undertaken. This was suitability and applicability of continuous sampling of confirmed with the environmental officer. This condition it is therefore deemed not applicable. It is the incinerator emissions from stack 584 for dioxins recommended that this condition be removed as part of an amendment application. and furans. Appropriate abatement technology should be installed C It is the Auditor’s understanding that this abatement technology is installed. Based on the Emissions in order to reduce the dioxin and furan emissions from survey it was noted that Stack 584 emissions were below detection limits. Based on the findings of the stack 584 in order to comply with both facets of the previous environmental audit (and confirmed by the Auditor with the Environmental Officer), it was noted Scheduled Process Permit guidelines, i.e. source- that demisters were installed with the purpose of reducing dioxin and furan emissions along with the based and ground-level concentrations. muffler off-gas quench column, the muffler absorber, Muffler Wet gas eliminator, Pyromet quench column, venture scrubber, Pyromet wash tower, Pyromet draught conditioner, off-gas after burner and material afterburner. PMR should ensure an update of its Scheduled NA According to the environmental officer (and as confirmed in the AEL for PMR), there are no boilers on site Process Permit before the commissioning of boilers 7 and therefore this condition is not applicable. and 8. An additional chlorine scrubber must be installed in C Numerous scrubbers are in place according to the latest AEL. There is no need for additional scrubbers at parallel with the existing unit and must be designed this stage. such that it will be available at all times. The Air Quality Modelling currently undertaken to NA The air quality modelling event took place around the approval date of the PMR facility. This component predict the future air emissions from PMR should of the commitment is thus complete and no longer relevant to the audit period. It was confirmed that a include an Air Quality Management Plan that is in AQMP has not been developed for the Rustenburg Operations. accordance with the regional framework development The findings from the previous audit have recommended that this condition be removed as part of an for the Rustenburg Section. amendment application. Vapour emissions should be controlled by ensuring C Vapour release is considered as part of the operation fugitive emissions inventory. The Scrub Column, that operating procedures are adhered to. with operating fluid 3 N NaOH, is the primary mitigation against vapour release. Vapours resulting from spillages is controlled using the spill clean-up or emergency response procedures. All hazardous waste will be disposed of at a C RPM, which is part of Anglo also shares and is working towards the goal of zero waste to landfill. There registered waste disposal facility and by authorised are 2 salvage yards at RPM (level 1 and 2) waste is sorted at the salvage yard and is then collected by personnel. Interwaste. A thermal is a company that is contracted for the incineration of waste Waste removal bins should be placed around the NA No construction activities were undertaken for this audit period. construction areas to prevent littering and disposed of at the existing facilities in line with the site waste management plan. A waste segregation and minimisation programme C The waste management procedure is included in the induction and can also be found on Enablon. should be compiled and form part of a continuous

Conditions Level of Reason for audit finding Compliance process to improve PMR’s environmental performance. A technology review should be undertaken to assess C The PMR's projects team is managing the installation of the new incinerator. It is assumed that the design what alternative technologies are available for waste team considered the latest available alternative technologies and is implementing the most appropriate incineration. The options should be reviewed to one. determine whether these technologies are suitable in terms of financial, logistical and environmental issues. The future options for the storage or treatment of the C The effluent from the PMR facility is stored in approved storage facilities which have the capacity to store effluent should be reviewed in consideration of the effluent produced at the facility. The water is then cycled back into the PMR or routed to the Smelter. minimising the potential risks to interested and affected parties. Should PMR intend to re-commission the existing Noted There is no sewage plant on site. The sewage is pumped to the sewage treatment plant at RBMR. sewage plant, the appropriate permits will be applied for. On-going training will be implemented to inform C Environmental talks are given via toolbox talks and also via inductions. SRK has reviewed examples of employees of the various procedures on-site. the toolbox talks given on site. The PMR will ensure that an HIV/AIDS strategy is in C A corporate level HIV/AIDS strategy is in place. Voluntary testing and counselling is made available to all place and effectively implemented at the PMR. Anglo American employees. The RPM health services developed and maintain the HIV/AIDS programme. The PMR hosts an Operation HIV/Aids Committee tasked with carrying out the objectives of the strategy. In extreme cases, employees will be referred to the Platinum Health care facility. Training and skills development programmes will be C If there is a change in the procedure a targeted training session is hosted to ensure awareness of the implemented. On-going training will be implemented amendment. In addition, there is compulsory training in terms of Section 55 of the MPRDA which to inform employees of the various procedures on employees must attend. site. Employees will be educated by means of existing training and an Environmental Awareness Plan. Training will encourage employees to enquire skills usable after closure. Security will be maintained. C The previous audit indicated that Security at the PMR is dependent on the Level of the operation being entered. In general security procedures are comprehensive as a result of the nature of the site as experienced by the auditor during the site visit. Numerous security procedures are in place to effectively manage the operations security personnel. Some of the income obtained from the increased C The environmental officer confirmed that this commitment is managed by the CED who allocates funds to production of PGM’s should be used to further local projects based on prior engagement and agreement. A social development in accordance with Anglo American development plan has been developed. Platinum’s current social development initiatives. All issues/complaints will be included within the C All issues and incidents are logged on the Enablon system and allocated to a responsible person to existing EMS system. resolve. The system is updated once the issue has been closed out.

Conditions Level of Reason for audit finding Compliance The wearing of PPE should be enforced in the C A PPE register is maintained by each operation, per section as well as at the main security gate, with relevant areas and personnel that work in these areas regards to visitors. This was verified by the auditor during the site visit. should be trained in the correct manner to handle the substances. PMR should participate in the formulation of C The PMR, Operational Procedure, Fire–Fighting / Emergency Drill and Instruction, applies to evacuation evacuation procedures for the plant and surrounding requirements. communities. Although the procedure does not consider the surrounding communities, the environmental officer confirmed that the emergency services team includes contact with a task team in the community; any major event is communicated through to the relevant community and appropriate action (evacuation if necessary) can be implemented. Non-compliant incidents should be recorded in the C Incidents are recorded on the Enablon system. All air quality related issues fall under the jurisdiction of incident register and these should be made available the district municipality; reporting is therefore undertaken as per the requirements of the AEL. to the authorities within the monthly air monitoring reports submitted to the DEA. Incident complaint forms should be completed upon C Environmental complaints are dealt with similarly to incidents. Records are captured on Enablon. the receipt of a formal environmental complaint and Responses to the complainants are done either verbally, telephonically or by email. No complaints were feedback should be provided as soon as possible to noted by the PMR environmental officer for this audit period. the complainant. These records should be kept on site in a complaints register. The EMS will be updated annually. C The EMS is updated only if an update is deemed necessary for a particular section. Procedures are updated to align the EMS. The historical record of any document changes made are indicated within each procedure External audits of the EMP will be undertaken once C The previous audit report was undertaken and completed by WSP in 2019. every two years The PMR must capture all public complaints in its C Environmental complaints are dealt with similarly to incidents. Records are captured on Enablon. EMS and close out. Responses to the complainants are done either verbally, telephonically or by email. No complaints were noted by the PMR environmental officer for this audit period. Reduce the amount of energy used per oz of PGM C According to the environmental officer, current measures are in place to reduce energy consumption and Au produced. includes the replacement of all fluorescent tubes on site with energy savers Promote environmental awareness as per resource C Environmental talks are given via toolbox talks and also via inductions. SRK has reviewed examples of conservation procedure. the toolbox talks given on site.

Appendix D: List of documents

1. General documents (relevant to all retained operations)

Documents/Reports  Anglo American HIV/AIDS Policy (June 2015)  Consolidated Environmental Management Programme – External Audit Report (Dated December 2019), compiled by WSP  Consolidated Environmental Management Programme – External Audit Report (Dated June 2019), compiled by WSP  Consolidated Environmental Management Programme – External Audit Report (Dated April 2019), compiled by WSP  Limited Legal Compliance Audit: Certain mining rights held by Rustenburg Mines Limited and Bokoni Platinum Mines Limited (Dated 24 April 2019), compiled by Webber Wentzel  Rustenburg Base Metals Refiners: Plant Change Notification Procedure (RRBMR-ALL-ENG-PRO- 0001) (Dated 27 September 2018)  APP Rustenburg Mine and Integrated Water & Waste Management Plan Annual Update (503378) (Dated 11 January 2019), compiled by Aurecon  Rustenburg Platinum Mine External Audit Report: GN 704 Audit Report for RPM Rustenburg Operations (503378) (Dated 16 November 2018), compiled by Aurecon  Anglo American Platinum Rustenburg Operation, External Water Use Licence Audit (555016) (Dated February 2020), compiled by SRK Consulting  Anglo American Platinum: Hex River Catchment Biomonitoring Programme (AAPL/B/19) (Dated November 2019), compiled by Clean Stream Biological Services  Anglo Platinum Rustenburg Process Division: Toxicity Test Report (AQS-ARP-A-20_TOX) (Dated 28 June 2020), compiled by Aquatico Scientific Services  Anglo American Platinum: Rustenburg Process Division Annual DWS Compliance Report, September 2017 to August 2018 (APPD/ACR/2018/WR), compiled by Aquatico Scientific Services  Anglo American Platinum Rustenburg Process Division: Annual Integrated Surface and Groundwater Quality, Biomonitoring and Toxicity Testing Assessment Report, Vol 1, September 2018 to August 2019 (APPD/AR1.1/2019/WR), compiled by Aquatico Scientific Services  Anglo American Rustenburg Section – Water Action Plan Phase 1 Baseline Study: Groundwater Model Report (RC12004-RSWAPPH1-CS Volume 2 and 11) (Dated 14 August 2013)  Rustenburg Process Operations, Internal Water Use Licence Audit (Dated 18 and 19 May 2020)  Rustenburg Process Operations, Internal Performance Assessment Report (Dated 18 and 19 May 2020)  Rustenburg Process Operations – Rehabilitation, Decommissioning Closure Plan, 2019 (543759/Rustenburg Process 2019) (Dated November 2019), compiled by SRK Consulting  EMPr Consolidation Environmental Authorisation from the Department of Mineral Resources (Dated 27 March 2017)  Rustenburg Platinum Mines Limited: Rustenburg Section Retained Operations EMPr, Consolidated Environmental Management Programme (Dated 16 February 2016), compiled by WSP  Rustenburg Section Water Action Plan Phase 2 Concept Study (FEL1) Main Report (RC12007- RSWAPPH2-CS Vol2) (Dated 13 February 2015)  Monthly dust fallout monitoring reports (Dec 2019 – Jan 2020, Jan 2020-Feb 2020, Feb 2020 – March 2020 and May 2020-Jun 2020), compiled by Aquatico Scientific (Pty) Ltd  S&SD Group Specification for Rehabilitation (AA SSDG MC001) (Dated February 2019)  Anglo American: Extract from training, awareness and competence procedure (ACP-ALL-SHE-PRO- 0002) (Dated April 2019)  Anglo American: Covid-19 bio-hazardous waste  Surface and Groundwater monitoring Quarterly Water Quality Report (December 2019 - February 2020), compiled by Aquatico Scientific (Pty) Ltd  Surface and Groundwater monitoring Quarterly Water Quality Report (March 2020-May 2020), compiled by Aquatico Scientific (Pty) Ltd  Water Quality Monitoring Report (January 2020), compiled by Aquatico Scientific (Pty) Ltd

 Water Quality Monitoring Report (February 2020), compiled by Aquatico Scientific (Pty) Ltd  Water Quality Monitoring Report (March 2020), compiled by Aquatico Scientific (Pty) Ltd  Water Quality Monitoring Report (April 2020), compiled by Aquatico Scientific (Pty) Ltd  Water Quality Monitoring Report (May 2020), compiled by Aquatico Scientific (Pty) Ltd  Water Quality Monitoring Report (June 2020), compiled by Aquatico Scientific (Pty) Ltd  Water Management Plan, AAP Rustenburg S&R South Africa (Dated August 2020), compiled by Tania Rademeyer

E-mail communication  Steenkamp, Gerhard. “Re: EMPR Requirement: Practicality of quarterly groundwater model updates” Message to Marietjie Schoeman and Dustin van Helsdingen. May 2018. E-mail  Kumari, Pravesh. “Re: Closure Plan and proof of financial provisions for Rustenburg” Message to Boipuso Semenya. 16 July 2020. E-mail  Kumari, Pravesh. “Re: Rehabilitation Specifications” Message to Boipuso Semenya. 28 July 2020. E- mail

2. Base Metals Refinery (RBMR)  RBMR, Internal Atmospheric Emissions Licence Compliance Review (Dated 18 and 19 May 2020)  Approved RRBMR Air Emissions License (AEL), (reference number BPDM/RBMR/AEL1.1/March2016)  Environmental Noise Impact Report: Cumulative noise impact associated with the Base Metals Refinery Plant (Dated 29 April 2008), compiled by dBAcoustics  Investigation on discharge of effluent water from the rainwater dam into a channel leading to the Klipfonteinspruit (Dated 14 January 2020), compiled by Boipuso Semenya  Area noise survey schedule – occupational hygiene  Occupational Hygiene Noise Survey Material Management (Dated January 2020), compiled by M Keyizana  Occupational Hygiene Noise Survey NCM Laboratory (Dated January 2020), compiled by M Keyizana  Occupational Hygiene Noise Survey Nickel Tank House Area (Dated July 2020), compiled by L Visagie  External ISO 14001 audit (Dated 28/09/2019)  Rustenburg Base Metals Refiners: Communication, Participation and Consultation (RRBMR-SHE- SAF-PRO-0018) (Dated 8 June 2020), compiled by Sareena Maharajh  Rustenburg Base Metals Refiners: Emergency Preparedness and Response (RRBMR-SHE-SAF- MCOP-0001) (Dated 6 August 2019), compiled by Z Selenati-Dreyer  Rustenburg Base Metals Refiners, Plant Change Notification Procedure (RRBMR-ALL-ENG-PRO- 0001) (Dated 27 September 2018), compiled by E Engelbrecht  Internal Assurance Report: SHE Way Self-Assessment (Dated 14-18 October 2019)  Anglo American Platinum Rustenburg Operations: Base Metal Refinery (RBMR) Invasive Alien Plants Management plan (2018), compiled by Agreenco.  Assessment of contaminants in the soil of RBMR, portion of D-Section (Dated September 2017), compiled by Agreenco  Atmospheric Emissions Survey Report (Dated 25 February 2019), compiled by C&M Consulting Engineers (Reference 392/18)  RBMR Soil Contamination Remediation (Dated 28 February 2018), compiled by Boden Science

Communication  DWS Acknowledgement of receipt of the notification of Environmental Incident and Potential Occurrences of other incidents letter (28 January 2020)

3. Precious metals refinery

 Rustenburg Platinum Mines Precious Metals Refiners 2019 Isokinetic Sampling Report (Dated 18-31 October 2019), complied by Future Projects  PMR, Internal Atmospheric Emissions Licence Compliance Review (Dated 18 and 19 May 2020)  Atmospheric Emissions Licence, 2018 – Issued by the Bojanala Platinum District Municipality, Health and Environmental Services.  Noise survey: Area 706 signed off report (March 2020)  Noise survey: Area 806 signed off report (March 2020)  Noise survey: Area 929 signed off report (March 2020)  Noise survey: Area 934 signed off report (March 2020)  Noise survey: Level 3 signed off report (March 2020)  Noise survey: Security Main Gate signed off report (March 2020)  Noise survey: VRP signed off report (March 2020)  Noise survey: Walkways signed off report (March 2020)

4. Smelter and ACP  Waste Management Report – ACP WVS July 2020 (Excel Spreadsheet)  Various examples of safe disposal certificates  Waterval Smelter AEL, 2016, Issued by the Bojanala Platinum District Municipality  Waterval Smelter Emission Survey (Dated 3 February 2020), compiled by C&M Consulting Engineers (Report reference 244/19rev1)  Waterval 2019 Isokinetic Stack Sampling, annual NAEIS and general air quality reporting (Dated 15 October 2019), compiled by Dustin van Helsdingen  ACP Plant 2019 Isokinetic Sampling Report (Dated 19 August 2019), compiled by Future Projects.  Atmospheric Impact Report: Waterval Smelter Complex (Dated December 2018), compiled by Airshed Planning Processionals  Ambient Air Quality Monitoring – Annual Report for Rustenburg (Dated 2019), compiled by Argos Scientific  Ambient Air Quality Monitoring – Annual Report for Rustenburg (Dated 2018), compiled by Argos Scientific  Waterval Smelter: Emergency Preparedness and Response (WSM-ALL-SHE-COP-0001) (Dated May 2020), compiled by the drafting committee  Anglo American, Spill Handling Procedure (ACP Operation) (ACP-ALL-ENV-PRO-0023) – (Dated August 2017)  Anglo American, Spill Handling Procedure (Waterval Smelter) (WSM-ALL-ENV-PRO-0023) – (Dated August February 2018)  Waterval Smelter Complex, Atmospheric Emissions Licence Compliance Review (Dated 31 May 2019)  ACP Operations: Emergency Preparedness and Response (ACP-ALL-SHE-COP-0001) (Dated June 2020) signed off by Miranda Melk  Record of the coal storage incident (Event ID: IN.00233339) – Coal storage at silica yard  Record of Coal Storage at the silica yard action plan (Action Plan ID AP.00802237)  2020 ACP SHE Water Balance (Excel spreadsheet)  Platinum Environmental – Incidents, Hazards and Grievances 2019 and 2020 (Excel spreadsheet)  Environmental Noise Survey Report for Anglo Waterval – Anglo Converter Plant (ACP) (ACP ENVN- 01/082017) (Dated August 2017), complied by Phuka Tsa Nong  Waterval Smelter Safety Talk Topic, Riparian Zone, hearing loss and TB awareness (Dated March 2020)  SHE Talk Topics (HIV/Aids, Riparian Zones, Risk Management and Safety) (Dated December 2-8 2019)

 SHE Talk Topics (Causes of conflict, men’s health awareness, energy saving this winter) (Dated 22- 28 June 2020)  SHE Talk Topics (Zero Harm, responsible use of respirators, water management) (Dated 13-19 January 2020)  Talk Topics, say no to plastic (Dated 29 June – 5 July 2020)  Memo on Waterval Amplats Converter Slag (WACS) storage (August 2018)  Anglo American Platinum Rustenburg Operations: Invasive Alien Plant Study (Dated 2015), complied by Agreenco

MARA/NKAV/LAKF 558834_RPM_EMPR_Final Reg 34 Audit Report_20201130 November 2020