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Anti-Corruption & Transparency of Payments to Governments

Paladin is committed to conducting its business in accordance with applicable laws, rules and regulations and the highest standards of business ethics, and to full and accurate disclosure in compliance with applicable laws, rules and regulations. The Company honours the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (OECD Convention) and takes a zero tolerance approach to any forms of corruption or bribery

APPROACH AND PERFORMANCE

Rankings in the 2015 Transparency International’s Corruption Perceptions Index [56] again highlighted that Paladin needs a sound approach to managing risks related to corruption, bribery and unethical or unlawful conduct in Malawi and Namibia. The Index ranks 175 countries and territories based on how corrupt their public sector is perceived to be, and assigns scores on a scale of 0 (highly corrupt) to 100 (very clean), with Namibia (LHM) achieving a score of 53 (rank 45 out of 175) and Malawi (KM) a score of 31 (rank 112 out of 175).

The Company operates under a Code of Business Conduct and Ethics as well as a separate Code of Conduct for its Directors [57]. An Anti-Bribery and Corruption (ABC) Compliance Guide provides practical advice on ethical business conduct for Paladin Directors, employees and third parties. In addition, the Company’s Whistleblower Policy and procedure facilitates disclosure of any alleged corrupt practices as discussed under Our People in this Report. Any changes to the Codes and Policies are considered by the Board.

Paladin’s Compliance Committee, trained by external legal counsel, operates under a documented Charter [58] and is tasked with the oversight and implementation of the Company’s ABC compliance regime (as documented in Paladin’s ABC Compliance Guide) and to address employee’s or representative’s concerns. The Compliance Committee reports to the Audit Committee on a quarterly basis and provides an Annual Report to the Board. The Compliance Committee also oversees the Company’s internal ABC training.   

Corruption risks identified by Paladin are included in the Corporate Risk Assessment Register. No specific corruption risk assessments were conducted during the reporting period.

Anti-Corruption Communication and Training

Training on ABC continued across the Paladin Group during the reporting period. The number of Board members and personnel trained in ABC and the total number of hours of training per employee category at LHM and KM are shown in Table 28 and Table 29, respectively.  

In addition to employees, Paladin business partners such as suppliers, consultants, contracting companies, Government officials and Non-Government Organisations were also included in Paladin Policy training, which included ABC Compliance. Many of LHM and KM suppliers located in South Africa and Malawi (around 70 by the end of the reporting period) received the training on Paladin’s Policies and Codes. Further training to more business partners is planned to be conducted during the next reporting period.

Table 28. LHM Anti-Corruption Communication and Training

LHM

Type

LHUPL Board
Number %

Senior
Management[59]
Number %

Management[60]
Number %

Professional[61]
Number %

Skilled[62]
Number %

Unskilled[63]
Number %

FY 15/16 14/15 15/16 14/15 15/16 14/15 15/16 14/15 15/16 14/15 15/16 14/15

Total

0

0 0 10 5 19 17 29 132 124 0 162

Communication

0
(0)

0
(0)

0
(0)

7
(70)
5
(28)
14
(74)

17
(59)

26
(90)
132
(87)
124
(100)

0
(0)

162
(100)

# Training

0
(0)

0
(0)
0
(0)

7
(70)

5
(28)
14(74) 17 (59) 26 (90) 132 (87) 124 (100) 0
(0)
162 (100)

Training Hours

0

0 0 3 40 6 136 9 1,056 53

0

74
                           

Table 29. KM Anti-Corruption Communication and Training

KM

Type

PAL Board Number
(%)

Senior Management Number
(%)

Management

Number
(%)

Professional

Number
(%)

Skilled

Number
(%)

Unskilled

Number (%)

FY

15/16

14/15

15/16

14/15

15/16

14/15

15/16

14/15

15/16

14/15

15/16

14/15

Total

4

4

3

5

2

10

1

10

9

147

9

64

Communication

4

(100)

4
(100)

3

(100)

5

(100)

2

(18)

8

(80)

1

(10)

8

(80)

9

(17)

132

(90)

9

(9)

58

(90)

# Training

4

(100)

4

(100)

0

(0)

5

(100)

2

(18)

8

(80)

1

(10)

8

(80))

9

(17)

132

(90)

9

(9)

58

(90)

Training Hours

4

2

0

3

2

4

1

4

9

66

9

29

Incidents of Corruption

During the reporting period, there were no cases of fraudulent activities were confirmed at KM. Congruent with Paladin’s zero tolerance policy, any confirmed incidents of corrupt practices will result in dismissal. There were no incidents of corrupt practices identified at LHM during the reporting period.

It should be noted that none of the confirmed incidents of corruption involved any business partners and as such, there were no contracts that had to be terminated by Paladin or that could not be renewed. Paladin also reports that there were no public legal cases regarding corruption brought against the Company or any of its employees during the reporting period.

TRANSPARENT DISCLOSURE OF PAYMENTS TO GOVERNMENT

Paladin supports the Extractive Industries Transparency Initiative (EITI) and has registered as an EITI Supporting Company [64] in line with the Company’s commitment to combat corruption and bribery, respect human rights, apply its corporate values of honesty and integrity, and to contribute to the local economies of host countries.

While neither LHUPL nor PAL made any direct or indirect political contributions, Paladin contributed significantly to the economies in its countries of operation through a variety of Government taxes. The contributions are detailed in Figure 2 for Namibia and Figure 3 for Malawi.

Figure 2. Payments to the Namibian Government for the year ended 30 June 2016

 

Figure 3. Payments to the Malawi Governments for the year ended 30 June 2016

 


[56] The Corruption Perceptions Index ranks countries and territories based on how corrupt their public sector is perceived to be. A country or territory’s score indicates the perceived level of public sector corruption on a scale of 0 (highly corrupt) to 100 (very clean). A country or territory's rank indicates its position relative to the other countries and territories in the index. For further information, and to see the 2015 Index, please go to: http://www.transparency.org/cpi2015/results.
[57] To view any of Paladin’s Policies and Codes of Conduct please go to: http://www.paladinenergy.com.au/corporate-governance
[58] To view any of Paladin’s Committees’ charters please go to: http://www.paladinenergy.com.au/corporate-governance
[59] Senior Management: Heads of Department, General Managers and above.
[60] Management: Employees with Management, Superintendent roles and appropriate Principal roles (i.e. those who manage a team).
[61] Professional: Employees who are degree qualified and not included in the Senior Management and Management categories.
[62] Skilled: Employees with trade certificates, supervisors and those with roles requiring a specific experience level.
[63] Unskilled: Employees with all other roles.
[64] The EITI is a global initiative to improve governance in resource-rich countries through the verification and full publication of company payments and Government revenues from oil, gas and mining.

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