Gemtoll SA Company Policies
1. Anti-Bribery and Anti-Money Laundering Policy
Purpose
This policy sets out the Company’s commitment to conducting business ethically, honestly, and in compliance with South African laws prohibiting bribery, corruption, and money laundering.
Scope
Applies to all employees, directors, contractors, agents, and business partners acting on behalf of the Company.
Policy Statement
- The Company prohibits all forms of bribery, facilitation payments, kickbacks, or improper advantages, whether offered or received, in both public and private sectors.
- The Company prohibits the laundering of funds derived from criminal activities.
- Compliance with the Prevention and Combating of Corrupt Activities Act (Act 12 of 2004) and the Financial Intelligence Centre Act (FICA) (Act 38 of 2001) is mandatory.
Key Principles
- Gifts & Hospitality: Only modest, lawful, and infrequent gifts/hospitality are permitted, with prior approval and proper recording.
- Third Parties: Due diligence is required before engaging intermediaries, consultants, or agents.
- Reporting Obligations: All employees must report suspicious activities or suspected bribery to management or the compliance officer immediately.
- Training: Mandatory anti-bribery and AML awareness training will be provided.
- Sanctions: Breach of this policy may result in disciplinary action, dismissal, and/or criminal prosecution.
2. Responsible Minerals Sourcing Policy
Purpose
The Company is committed to sourcing minerals in a manner that does not contribute to conflict, human rights abuses, or environmental harm.
Scope
Applies to procurement and supply chain operations involving minerals, particularly tin, tantalum, tungsten, gold, and other high-risk minerals.
Policy Statement
- The Company will not knowingly source minerals that directly or indirectly finance armed conflict, human rights abuses, or illicit activities.
- We commit to supporting responsible sourcing aligned with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals and relevant provisions of the Mineral and Petroleum Resources Development Act.
Key Principles
- Supplier Due Diligence: Suppliers must provide verifiable information on the origin and chain of custody of minerals.
- Risk Assessment: Regular assessments will be conducted to identify high-risk sources and take mitigation steps.
- Transparency: Supply chain records will be maintained for at least five years and made available to regulators upon request.
- Collaboration: The Company will work with suppliers to improve traceability and ethical standards.
- Termination: Business relationships will be ended if suppliers refuse to address responsible sourcing concerns.
3. Environmental Policy
Purpose
The Company recognises its responsibility to minimise environmental impact and comply with South African environmental laws and international best practices.
Scope
Applies to all operations, facilities, and activities under the Company’s control.
Policy Statement
- The Company will operate in compliance with the National Environmental Management Act (Act 107 of 1998) and other applicable environmental legislation.
- We aim to prevent pollution, reduce waste, conserve resources, and protect biodiversity.
Key Principles
- Compliance: All operations will meet or exceed environmental legal requirements.
- Resource Efficiency: Measures will be implemented to reduce energy, water, and raw material consumption.
- Waste Management: Waste will be minimised, reused, or recycled where possible; hazardous waste will be disposed of responsibly.
- Pollution Prevention: Controls will be in place to prevent emissions, spills, or other harmful discharges.
- Awareness & Training: Employees will receive environmental awareness training relevant to their roles.
- Continuous Improvement: Environmental performance will be reviewed annually, with targets set for improvement.