Governance and assurance

This chapter presents a portfolio of statements from relevant internal and external stakeholders. These statements relate primarily to our governance and risk management processes, Highlights our management of relevant and material issues and the Actions taken to address recommendations reporting process. This “mission-guided” approach to assurance from the Multi-Stakeholder Forum include: extends beyond the more traditional territory of verifying the accuracy of specific performance data. Instead, it empowers ŠŠRecognising that the first and second different stakeholders to comment in their areas of expertise on party statements are not technically how well we are managing and reporting on issues identified assurance statements as being “relevant and material” by stakeholders (p8). ŠŠEnsuring all statements consistently specify dates and locations of completion Statements presented in this chapter should be read alongside and include signatures from each the questions, voices, case studies and interviews with key respective organisation stakeholders presented throughout this report. Together, these viewpoints provide a unique and collective insight into how ŠŠUsing an additional non “big four” well we are responding to, managing and reporting on issues organisation to provide assurance and recommendations on our Kimberley identified as important by our stakeholders. Process compliance. The Government The Multi-Stakeholder Forum has been instrumental in Diamond Office of the United Kingdom shaping the content of this chapter. In particular, we have was seen as more appropriate given its followed recommendations from the Multi-Stakeholder role as a stakeholder in and enforcer of Forum to rename this chapter “Governance and assurance” in the Kimberley Process order to reflect the broad coverage of statements contained ŠŠPlacing emphasis on performance with herein. This also reflects our intent to recognise the difference respect to “relevant and material issues” between those statements prepared by De Beers Internal rather than the standard assurance of Audit and Maplecroft (i.e. as first and second party statements specific performance data on governance and reporting), and those prepared by ŠŠBalancing both positive and negative independent third parties. stakeholder viewpoints and discussing dilemmas throughout the report

97 The number of workbooks submitted to Société Générale de Surveillance (SGS) for their review of the De Beers Best Practice Principles Assurance Programme

96 De Beers Family of Companies Report to Society 2008 Analysing diamonds using ultraviolet light

De Beers Internal Audit (first party) on governance, risk p98 management and selected material issues

Maplecroft (second party) on the reporting process, p100 Guide to our portfolio the AA 1000 principles and recommendations of governance and SGS (third party) on the BPP Assurance Programme p102 assurance statements including key findings and recommendations Government Diamond Office (third party) on Kimberley p103 Process compliance at DTC (now renamed De Beers UK Ltd)

De Beers Family of Companies 97 Report to Society 2008 On internal Statement from De Beers Internal Audit on selected material issues including internal auditing, the Best Practice Principles, the audit and risk Assurance Programme for the Principles, the Kimberley Process and management anti-money laundering processes

De Beers Internal Audit (DBIA) is an Risk-based internal auditing The DBIA annual audit report to the independent, objective assurance and DBIA follows a prescriptive, documented risk- DBsa Audit Committee, which was consulting activity designed to add value based audit methodology that culminates submitted in February 2009, included the and improve the operations of the in its annual report on risk management, following opinion: De Beers Family of Companies. DBIA has the internal control environment and been mandated by the Audit Committee, governance to the Audit Committee. The “I can confirm that in my opinion the a sub-committee of the Board of De Beers audit plan is derived from the De Beers internal controls are adequate to ensure Société Anonyme (DBsa), to ensure that the Enterprise Risk Management system. DBIA that the financial records may be relied major risks facing the Family of Companies consults on and assists with the facilitation on for preparing the reports to directors are identified and given appropriate audit of risk management workshops at all levels and shareholders, and for maintaining focus. Risk management, internal control to ensure a complete and appropriate risk accountability for assets and liabilities. and governance processes are systematically management system. reviewed to help the Family of Companies In my opinion, in all material instances, accomplish its objectives. DBIA submits an The risk management process collates assets are adequately protected and used annual audit report to the Audit Committee information from value centres and offices as intended with appropriate authorisation on the status of governance, internal control globally to business units and ultimately and all significant business risks have been and the appropriateness of risk management. to enterprise level. Audit work includes identified and appropriate mitigating a thorough review of internal systems, strategies are in place. All DBIA reviews are performed in accordance procedures and programmes of work for with the International Standards for the each business function and area of major No matters have come to my attention during Professional Practice of Internal Auditing, as business risk. DBIA also collates and reviews the year ended 31 December 2008 that prescribed by the Institute of Internal Auditors reports from managers on the integrity of indicate any breakdown of such magnitude (IIA). Our Quality Assurance and Improvement internal controls, the safeguarding of assets has occurred in the functioning of these Programme (introduced in line with IIA and risk management, as well as ethical, social internal controls, procedures and systems of Standards 1300) found DBIA to be “generally and environmental matters. It also considers the Group, which in my opinion, would affect compliant” with the IIA Standards, the highest reports produced by external assurance the fairness of presentation of such reporting, rating on the degree of conformity scale. providers. These include audit coverage by and therefore financial decisions based Diamond Security, Aon Risk Management, thereon. It must be noted that the extent to Société Générale de Surveillance (SGS), which sales in 2009 will be affected as a result Deloitte & Touche and others. of the global economic crisis and recession is not yet known. Mitigating responses include restructuring plans and steps to ensure access to ongoing funding of operations. I share management’s view that the Group has sufficient resources to remain in business for the foreseeable future.”

98 De Beers Family of Companies Report to Society 2008 Governance and assurance

Best Practice Principles Note on Kimberley Implementation of the In 2008 the scope of DBIA’s review of the Process compliance Anti-Money Laundering Policy Best Practice Principles (BPP) Assurance The Kimberley Process is a joint government, In 2006, De Beers developed and Programme was focused on ensuring that diamond industry and civil society initiative communicated a policy on Anti-Money the programme continued to be supported that requires participants to certify diamond Laundering and Combating the Financing of by good governance. The scope also shipments are conflict free. Compliance with Terrorism. The policy reflects the deep-seated provided for detailed, on-site verification the Kimberley Process is a legal requirement commitment of the Family of Companies to reviews of 20 BPP workbooks to supplement for participating countries. maintaining the continued confidence of its the review work conducted by SGS. The stakeholders and the integrity of its product. specific objective of the reviews was to verify A review of fact-finding reports, issued by responses within the BPP workbooks. No independent auditors, confirms that relevant DBIA’s 2008 review of the implementation and material breaches were identified during such business units comply with the requirement progress of the policy found that all business reviews and all improvement opportunities for De Beers to have its compliance with the units, applicable group functions, and shared have been agreed with management. Kimberley Process externally assessed. services have implemented the policy.

The scope of the 2009 review, which is These reviews sought to assess Good progress has been made on the currently in progress, will provide for a De Beers compliance with respect to introduction of the required background desktop review to ensure that due diligence the Kimberley Process Certification checks on customers and suppliers. has been applied in the completion of all Scheme on the international trade in rough De Beers UK and De Beers Marine Namibia BPP workbooks submitted to SGS. It will diamonds, in accordance with European are implementing processes to further also continue to include the verification of Council Regulation (EC) No 1574/2005. enhance these checks. All staff affected by submitted workbooks. The assessments related to the period the policy have received relevant training. commencing 1 January 2008, and ending 31 DBCM’s Voorspoed mine has recently been Assurance Programme December 2008. opened and a schedule has been developed for the Principles for full implementation of the policy. DBIA participates on the Principles Committee The major Kimberley Process compliance to ensure good governance directs the criteria are also reviewed as part of the third Assurance Programme for the Principles, and party verified BPP Assurance Programme. to ensure the integrity of the development No material breaches or instances of non- process. DBIA consulted on risk identification compliance with the Kimberley Process were and assessment, and also ensured alignment identified in the 2008 BPP assurance cycle. with and integration into the existing Enterprise Risk Management process.

Phillip Barton

Group Manager, DBIA De Beers Corporate Headquarters Johannesburg, South Africa 2 April 2009

De Beers Family of Companies 99 Report to Society 2008 On reporting Statement from Maplecroft on the reporting process, including the reporting methodology, the AA 1000 Principles and recommendations for future reporting

maplecroft

Background Methodology Materiality This report presents a coherent framework This statement is intended to provide insight Maplecroft worked closely with De Beers for identifying issues relevant and material into the reporting process. Maplecroft to include as much relevant quantitative to stakeholders. Maplecroft can verify that professionals involved in the reporting data as possible. Maplecroft is satisfied that the Diamond Dialogues and the Multi- process are experts in their respective the Report to Society 2008 offers a more Stakeholder Forum were critical in identifying disciplines and are trained auditors in comprehensive and more robust set of data and prioritising most of the issues presented accordance with the ISO 14001 and SA 8000 than the Report to Society 2007. in this report. Questions posed to De Beers standards. Maplecroft recognises that it is not at these events were answered frankly and an independent party. The validity of the original data was not transparently. Our work with De Beers supports checked at source by Maplecroft. Maplecroft the accuracy of relevant statements presented Maplecroft has worked with the Family worked closely with relevant De Beers in this report, most notably the answers of Companies since 2000. We have been discipline experts in the compilation, provided in the “questions from stakeholders” involved in data collection and analysis, the analysis and review of this data across the panels. Specific quotes and questions from the development of the BPPs, the APPs and in economic, ethical, employee, community Multi-Stakeholder Forum have been accurately the production of the Report to Stakeholders and environmental domains. We also carried reproduced within this report. 2005/6 and the Report to Society 2007, out rigorous peer review within Maplecroft as well as the Operating and Financial to ensure the accurate and comprehensive Our role in the reporting process enables us Review 2006 and 2007. Both the Report representation of original data. Any anomalies to confirm that De Beers reports on issues that to Stakeholders 2005/6 and the Report to or gaps in data that could not be resolved previous assurance statements and reviews Society 2007 won sustainability reporting by Maplecroft were referred back to relevant identified as needing to be addressed. This awards from the Association of Chartered employees within De Beers for clarification. includes progress reporting on beneficiation, Certified Accountants (ACCA) South Africa. contributions to development, and actions Maplecroft also advised on the development Maplecroft supplemented primary data with to reduce greenhouse gas emissions and of policies on anti-corruption, political extensive interviews, as well as the review adapt to climate change. A number of key donations, security services and human of a range of documents, articles, agendas, events during 2008 have implications for rights, and draft guidelines on stakeholder minutes and presentations. Maplecroft was certain issues of interest to stakeholders. engagement. De Beers has contracted given a high degree of access to discipline These include the sale of Williamson Maplecroft to assist in the production of experts for the purpose of information Diamonds Limited, which changed the its Report to Society for the 2008 and 2009 gathering, clarification and review. We also focus of De Beers activities to empower local reporting cycles. prepared drafts of all text and worked closely artisanal miners (p75). Likewise, the global with discipline experts in the refinement of economic downturn has placed greater This statement is an account of: report content to ensure the information focus on possible mitigating actions, as presented is fair, accurate and in line with the well as consequences for contributions to ƒƒ Our experience of compiling content, expectations of stakeholders. In response to government revenues (p19), beneficiation checking and processing data, and writing stakeholder feedback, Maplecroft worked partnerships (p27), conflict sensitivity (p35), and designing this report with De Beers to present information in new consumer expectations (p42), the ongoing ƒƒ Our coordination and facilitation of the and innovative ways in order to improve provision of anti-retroviral treatment to Multi-Stakeholder Forum and the Diamond accessibility, ease of review and sign-posting. retrenched employees (p58), retrenchments Dialogues in London, as well as the writing Examples include the use of navigation (p66) and social investment activities (p81). of reports summarising discussions at panels at the start of each chapter, as well each event. This statement also confirms as free-standing “feature” pages that focus Completeness the accuracy of questions explored by the on specific issues of interest to stakeholders Our inspection of documents and enquiry of Multi-Stakeholder Forum and included in within each chapter. discipline experts did not identify any material this report shortfalls with respect to completeness of ƒƒ Our experience of engagement with All work completed by Maplecroft is informed reporting. Our enquiry found De Beers to discipline experts, the APP team, the by best practice initiatives and standards. support the need for greater transparency in its Principles Committee and other relevant This includes the United Nations Millennium disclosures. De Beers was proactive in seeking De Beers employees, both in person and Development Goals, the United Nations comment on, and promoting discussion of, through telephone interviews and Global Compact, the Global Reporting potentially difficult issues. This is reflected in other correspondence Initiative (GRI) G3 Guidelines and the AA 1000 this report, which includes frank discussion of a assurance standard. range of challenges and dilemmas, including:

AA 1000 principles ƒƒ Impacts of the global economy (p2, p27) ƒƒ Contractor fatalities (p48) We believe De Beers has made significant ƒƒ Improving HIV/Aids management (p58) progress with respect to being fully compliant ƒƒ Employee retrenchments (p66) with the AA 1000 principles of materiality, ƒƒ Water scarcity and use (p91) completeness and responsiveness. ƒƒ Energy security and climate change (p92)

100 De Beers Family of Companies Report to Society 2008 Governance and assurance

Responsiveness Recommendations Role of discipline Principals This principle requires De Beers to We have been impressed by the degree demonstrate how it is responding to Key areas for improvement: to which discipline Principals have made stakeholder concerns and interests. themselves available during the reporting Corporate Social process. The rigour of sign-off has been notable, De Beers has honoured its commitment Investment expenditure with Principals and experts demonstrating to engage the Multi-Stakeholder Forum Data on Corporate Social Investment (CSI) and a strong desire to ensure the highest levels in future reporting cycles, and participant expenditure on Social and Labour Plans (SLPs) of accuracy and to ensure a comprehensive recommendations have significantly in South Africa could be better aligned. This and meaningful account of their activities. influenced the content and form of this would help demonstrate that SLP expenditure We look forward to continued high levels of report. Examples can be found in a significant is increasingly taking the place of voluntary engagement in future reporting cycles. shift in focus towards the impact of the CSI disbursements. It would also better explain global economic downturn on the Family that despite a fall in CSI spending in South Best Practice Principles of Companies, increased use of “summary” Africa, net spending on social and labour issues De Beers has made considerable advances information in the introduction and feature (i.e. including SLPs) is increasing. Reporting in accounting for its ethical and social pages of each chapter, and an estimated 10% could also benefit from more detailed performance over the years and has required reduction in the overall length of the report. explanation as to the relationship between CSI high standards of those with whom it works at The fact that the Multi-Stakeholder Forum and and SLP spending, and the role of SLPs in the all stages of the diamond pipeline. It is critical the Diamond Dialogues were attended by wider social investment strategy. that the current economic situation is not former participants suggests that stakeholders allowed to undermine the important progress continue to find these engagements Online content made and that documentation about BPP constructive and worthwhile. Whilst De Beers has made efforts to transfer assessments and actions is kept up. ”static” text online, the company should further There is still room for improvement in terms explore synergies offered by increased reliance Future reports of responding to stakeholder suggestions on online content to complement material in relating to the identification of clear, the report. This will enable De Beers to respond We recommend that future reports should quantitative performance targets. The better to stakeholder requests for more also look to address the following: identification of Group targets for each succinct and accessible report content, whilst of the discipline areas would do much to also offering parallel online reporting that ƒƒ Quantitative targets that are meaningful enhance benchmarking, comparability and satisfies as fully as possible the requirements and measurable, particularly with respect measurability of performance. It would of the GRI G3 guidelines. Experience from the to the effectiveness of sustainability actions also enable the Family of Companies to 2007 reporting cycle suggests that using this and/or efficiencies demonstrate more tangibly its commitment approach would improve the likelihood of a ƒƒ Long-term milestones and targets, to concrete improvement. Our inspection GRI A+ rating, as it would allow for ongoing particularly in relation to climate change, of agendas, briefing materials and minutes performance updates and the presentation carbon emissions and water prepared for the Principles Committee and of information in a form that is closely aligned ƒƒ Forward-looking scenario planning to ECOHS Committee enables us to confirm with the GRI structure. understand and manage future risks and that a number of material sustainability challenges in partnership with stakeholders issues and risks are being tracked by the Ethnicity ƒƒ Enhanced content on anti-corruption risks, Family of Companies. These activities suggest Whilst the identification of the ethnicity of training and scenarios as well as practices De Beers is committed to continuous employees is a legal requirement in certain undertaken by different functional areas improvement in managing its sustainability locations (e.g. South Africa), it has posed ƒƒ Further analysis of the development impact risks and responsibilities and in contributing to challenges in terms of processing employee of social investment projects and SLPs sustainable development. data from De Beers operations in the United Kingdom. A significant number of employees We believe this report presents a relevant The De Beers statement that it has applied the in the United Kingdom declined to identify and complete statement of the sustainability GRI G3 guidelines at level A+ is fairly stated. their ethnicity. Because relevant data were performance of the Family of Companies. We understand this report will be submitted dependent upon the ethnic identity of This report will be used as the 2008 to the GRI for checking. respondents, this meant a significant number Communication on Progress for the United of employees were excluded from analysed Nations Global Compact. results. Maplecroft recommends that data Find out more templates issued in the United Kingdom www.maplecroft.com remove references to ethnicity as they are of limited relevance and are likely to reduce the www.global-risks.com accuracy of analysed data. Professor Alyson Warhurst Dr Kevin Franklin Gus Macfarlane

Maplecroft, United Kingdom, 14 April 2009

De Beers Family of Companies 101 Report to Society 2008 On the BPP Statement from SGS on the De Beers Group 2008 cycle of the De Beers Best Practice Principles (BPPs), including scope, work Assurance undertaken, the BPP programme, verification methodology, key Programme findings and recommendations

Appointment of SGS Work undertaken on De Beers As in the last cycle, briefing of all assessors Following a tender process beginning in Group facilities was undertaken to ensure that any changes April 2003, SGS was invited to present their 97 workbooks were submitted across all to questions and interpretation were proposal and following responses to additional eligible De Beers facilities covering 74 of their fully understood and a standard breach information were advised of their selection as own facilities and 23 contractors. classification table was drawn up and the verification partner in July 2003. circulated. This was reviewed during the Workbooks were not submitted for two course of the year as queries were raised and SGS is the world’s largest independent facilities as these had had recent visits the distribution of this table was controlled verification and certification organisation and following up on previous issues. through the BPP extranet. has no commercial interests. As part of this contract SGS has undertaken not to provide Full reviews were conducted and completed Key findings any consultancy or related services to any during the cycle and 10 verification visits The majority of workbooks were received parties involved in the BPP programme so were undertaken during this cycle including within the required timescales. A small as to ensure that this strict independence is three visits to contractors. In addition, a number of contractor workbooks were maintained at all times. follow-up visit was undertaken at one facility received rather late and had to be actively at which Major Infringements had been chased, but communication around Scope of work found in the 2007 cycle. anticipated delivery dates was maintained so The scope of work undertaken by SGS as the as to ensure that reviews could still be fully BPP verifier for the 2008 cycle comprised The BPP programme completed as required. the following: The BPPs follow major international standards for Corporate Social Responsibility (CSR) and Further improvement to the completion and ƒƒ Desktop review of a sample of the business partner evaluation and follow all level of detail contained in the workbooks workbooks submitted by DTC Sightholders national and international legal requirements. was demonstrated with the majority of and all those submitted by the De Beers ratings confirmed by the SGS review. Family of Companies. This process verifies The compliance process requires an in-depth that all required workbooks have been evaluation and the investment of resources Most infringements in the De Beers-owned submitted; that all questions have been to complete self-audits. In the case of the facilities found in the course of previous answered; that the responses to the De Beers Family of Companies this has cycles have been rectified with evidence questions support the compliance status included submission for contractors, regardless of implementation verified either on site declared in each case and to test that of the level of business represented by or through the workbooks. Some issues conclusion by requesting supporting De Beers, at an earlier stage than is required remain outstanding, however, including final evidence on a random number of questions. for Sightholders. De Beers has set itself a verification of corrective actions for a Major ƒƒ Verification visits on up to 10% of the high level of commitment and expectation Infringement which has been outstanding declared facilities to check that the of compliance. since 2006. original first party assessments have been undertaken thoroughly both by discussing Verification methodology The verification visits confirmed the majority this with the assessor and by seeking The verification process is undertaken in of findings from the first party reviews. first-hand evidence of compliance with the three stages: issues concerned. Overall summary ƒƒ An extraordinary audit to review allegations ƒƒ In the country of operation, workbooks are There were no Material Breaches identified of serious breaches at one of the reviewed by a qualified Social Accountability during first or third party assessments. Sightholder’s facilities. auditor, cross-trained in Environmental ƒƒ Provision of information relating to the Management and briefed on the One facility was found to still have a Major compliance status of Sightholders’ and requirements of the BPPs. Infringement in relation to business issues De Beers’ facilities and details of any ƒƒ Local reviews are then submitted to a and in particular to the need to go beyond significant issues. This information central review point where these are cross- local legal requirements in relation to Anti- is provided in accordance with the checked to ensure consistency by country Money Laundering (AML) compliance. An confidentiality requirements set out in the and key points. improvement plan has been developed but revised Supplier of Choice Ombudsman ƒƒ A sample of 10% of facilities is selected evidence of completion is still awaited. Terms of Reference. centrally for onsite verification to check the effectiveness of the first party assessments A further 11 facilities had Minor and to evaluate at first hand the situation Infringements. Corrective Action Plans have on the ground. been received for all infringements and are in the process of completion and review.

102 De Beers Family of Companies Report to Society 2008 Governance and assurance

This is an improvement since the 2007 cycle, Recommendations made include: especially as the majority of infringements relate to new facilities opened in the last 12 ƒƒ The need to ensure that workbooks are months. The majority of infringements relate based on full assessments rather than to central policies and procedures not having documentary review so as to ensure that been fully implemented at new operational underlying issues are discovered and centres and the corrective actions are reported on. reasonably straightforward. ƒƒ Focusing on underlying issues in the Improvement Opportunities identified to Recommendations effect significant improvement in meeting for improvement their compliance objectives. During the assessment process open ƒƒ Identification of best practice operations, communication was maintained with as highlighted through the business unit Effie Marinos the De Beers compliance team and a reports and dissemination of their approach number of recommendations were made to promote learning between sites. SGS United Kingdom Ltd for improvements. 16 February 2009

On Kimberley Statement from the United Kingdom Government Diamond Office on compliance with the Kimberley Process at DTC (now renamed De Beers Process compliance UK Limited)

The Kimberley Process (KP) was set up in Participants in the KP are not allowed to trade The GDO has a close working relationship January 2003 to combat the trade in illicit in rough diamonds with non participants, with all actors in the rough diamond industry, “conflict” diamonds. and each shipment of rough diamonds including DTC. Since the beginning of must be accompanied by a valid KP the KP, the GDO has undertaken over 35 Based on a collaborative approach between certificate detailing the carat weight, value, independent inspections of DTC shipments governments, the rough diamond industry destination address and custom codes for to ensure compliance with the KP. and NGOs, the Kimberley Process seeks to the shipment. Rough diamond shipments are remove these diamonds from the legitimate routinely checked by participants to ensure Additionally, as part of its commitment to trade by imposing common standards compliance with the KP. industry self regulation, DTC is subject to on producer and trader nations and the an annual audit by independent auditors to worldwide rough diamond industry. The Government Diamond Office (GDO) is ensure continued compliance with the KP responsible for implementing the KP in the and the industry system of warranties. The The KP is currently made up of 49 United Kingdom. We work closely with the GDO works closely with DTC’s independent participating members, representing 75 international community, other government auditors to this end. countries (the European Union (EU) as one departments, civil society and the rough participant). It includes all the major traders diamond industry to ensure the requirements and producers and is estimated to cover of the KP are met by the United Kingdom. more than 99% of the world’s trade in rough diamonds. DTC (now renamed De Beers UK Limited) is one of the principal importers and exporters Dev Shah of rough diamonds into and out of the UK. In 2008 the GDO issued over 1,000 KP Government Diamond Office certificates to accompany DTC exports of Foreign and Commonwealth Office rough diamonds to destinations outside of London, United Kingdom the EU. 13 January 2009

De Beers Family of Companies 103 Report to Society 2008 Further information

Extended contacts Environmental information Acronyms

Angola Luxembourg Printed on Revive 50:50 made from 25% de-inked AP Assurance Programme De Beers Angola De Beers Société post consumer waste, 25% pre-consumer waste APPs Assurance Programme for the Principles Holdings Anonyme and 50% virgin fibre. All pulps are Elemental Caixa Postal nº 4031 BP591, L-2014 Chlorine Free and the manufacturing mill is ISO ART Anti-Retroviral Treatment Luanda Luxembourg 14001 certified. Use of the Forest Stewardship BEE Black Economic Empowerment Tel: +244 (0) 222 63 8800 Tel: +352 (0) 264 8711 Council (FSC) logo identifies products that contain Fax: +244 (0) 222 63 8801 Fax: +352 (0) 264 871 303 wood from well-managed forests certified in BPPs De Beers Best Practice Principles accordance with FSC rules. Botswana Namibia DBCM De Beers Consolidated Mines De Beers Botswana De Beers Namibia DBDJ De Beers Diamond Jewellers Private Bag 00380 PO Box 23132 Gaborone Windhoek, 9000 DBIA De Beers Internal Audit Tel: +267 (0) 390 2991 Tel: +264 (0) 61 204 3444 DDI Diamond Development Initiative Fax: +267 (0) 390 2990 Fax: +264 (0) 61 204 3445 DTC Diamond Trading Company De Beers Prospecting Namdeb Botswana PO Box 1906 Acknowledgments DTCB Diamond Trading Company Botswana PO Box 404331 Windhoek, 9000 Prepared and produced by the De Beers Family ECOHS Environment, Community, Occupational Gaborone Tel: +264 (0) 61 204 3333 of Companies in partnership with Maplecroft. Hygiene, Health and Safety Tel: +267 (0) 391 9962 Fax: +264 (0) 61 204 3334 Design: Maplecroft Printing: Taylor Bloxham Fax: +267 (0) 395 9106 HDN Historically Disadvantaged Namibian © De Beers UK Limited 2009. All rights reserved. HDSA Historically Disadvantaged South African Debswana Diamond Namibia Diamond De Beers UK Limited is a company incorporated Company Trading Company KPCS Kimberley Process Certification Scheme in England and Wales with registered number PO Box 329, Gaborone PO Box 23316 2054170 and registered office 17 Charterhouse LTIFR Tel: +267 (0) 361 4200 Windhoek, 9000 Lost Time Injury Frequency Rate Street, London, EC1N 6RA. De Beers™, A Diamond Fax: +267 (0) 395 Tel: +264 (0) 61 204 3222 LTISR is Forever™, DTC™, ™ and Forevermark™ are used Lost Time Injury Severity Rate 2941/6110 Fax: +264 (0) 61 204 3263 under licence by De Beers UK Ltd. MCDP Mwadui Community Diamond Partnership Diamond Trading South Africa NDTC Namibia Diamond Trading Company Company Botswana De Beers Consolidated Private Bag 0074 Mines NIHL Noise Induced Hearing Loss Gaborone PO Box 616 NWT Northwest Territories (Canada) Tel: +267 (0) 364 9000 Kimberley, 8300 Fax: +267 (0) 364 9999 Tel: +27 (0) 53 839 4111 OIFR Occupational Illness Frequency Rate Fax: +27 (0) 53 839 4210 SASA South African Sea Areas Canada United Kingdom SEAT Socio-Economic Assessment Toolbox De Beers Canada De Beers UK Ltd Toronto Office, Suite 300 17 Charterhouse Street SHE Safety, Health and Environment 65 Overlea Boulevard London, ECIN 6RA SLP Social and Labour Plan Toronto, M4H 1P1 Tel: +44 (0) 20 7404 4444 Ontario Fax: +44 (0) 20 7831 0663 VCT Voluntary Counselling and Testing Tel: +1 (0) 416 645 1710 Fax: +1 (0) 416 429 2462

India De Beers India Advanced Business Centre 83 Maker Chambers VI Nariman Point, 400 021 Mumbai Tel: +91 (0) 22 2283 2971/27 Fax: +91 (0) 22 2283 2823

104 De Beers Family of Companies Report to Society 2008 Whistle blowing hotline

Any person wishing to use our whistle blowing hotline may do so in the following manner.

By telephone In writing Email, website and fax

By telephone to the applicable tip-off In writing with details regarding the background Written disclosures may also be submitted via: anonymous country toll free number: and history of the information being disclosed, giving names, dates and places where possible. Email De Beers - South Africa 0800 003 518 [email protected] Disclosures made in writing should be posted to: De Beers - Namibia 0800 003 518 or 061-309058 South Africa (FreePost) Website De Beers - Botswana 71119753 (Mascom) KZN 138, www.tip-offs.com Umhlanga Rocks De Beers - United Kingdom 0808 234 2168 4320, Fax South Africa De Beers - Canada 18664511590 (South Africa) 0800 00 77 88 De Beers - Israel 1809455111 (International) +27 (0) 31 560-7395 Other countries (postage not paid) De Beers - Japan 00531270008 KZN 774, De Beers - Belgium 080075977 Umhlanga Rocks 4320, De Beers - Angola +27 (0) 31 571 5772 South Africa De Beers - DRC +27 (0) 31 571 5773 De Beers - Tanzania +27 (0) 31 571 5774 De Beers - India +27 (0) 31 571 5775 De Beers - China +27 (0) 31 571 5776

Our Principles

Three guiding Principles define the way we do business, inform our understanding of what is right and wrong, and describe what is important to us. These are supported by an extended set of specific Principles that cover the economic, ethics, employees, community and environment aspects of our activities.

Sustainable development Diamond dreams Accountability and through partnership and development “living up to diamonds” The Family of Companies is committed to We will work to address the poverty and socio- The Principles Assurance Programme translates operating in accordance with national legislation economic deprivation that affects many of the our Principles into practice and provides and towards the goal of sustainable development. communities where we operate. We will work a framework for measuring continuous This means ensuring that we consider and take with governments to help realise their long-term improvement in performance over time. Through responsibility for the longer term economic, visions and, through education, training and peer review across the Family of Companies, social and environmental implications of the shared decision making, to ensure the success we will help each other achieve this goal. The decisions we make today – not only for our own of programmes that help build the capabilities implementation, monitoring and reporting business but also for the broader societies in of their citizens. In particular, we will partner of these Principles through the Assurance which we operate. We will work with our partners with our stakeholders to address the priority Programme, including a willingness to open in government to ensure that diamonds, a finite of HIV/Aids. We will also work meticulously up our performance to third party scrutiny, will resource, are transformed into economic wealth through the Kimberley Process, the industry’s ensure that our stakeholders are able to rely on and improved quality of life and wellbeing for all system of warranties, and our Principles to ensure our high standards and know that we are “living those stakeholders touched by our business along conflict diamonds are eliminated from world up to diamonds”. the diamond pipeline. diamond flows.

De Beers Family of Companies 105 Report to Society 2008