Our ethics, as codified in AngloGold Ashanti’s Code of Business Principles
and Ethics, provide the guidelines for employees to align their conduct
and business practices with our values. The most obvious example of
these guidelines is our policies, including policies relating to anti-bribery
and anti-corruption and conflicts of interest.
Alongside these policies are a number of procedures and guidelines that guide our day-to-
day conduct. However, it is not enough to simply publish policies, we need to embed our
ethics in every business decision we take. To support the principles they uphold becoming
our conduct, we need to build the capacity of employees to understand the policies so they
can deliver against our values. Capacity building requires clear and consistent communication
using various platforms throughout our global organisation to reach every employee – whether
they work at a desk, or at the mine face. With capacity building comes reporting – employees
must have the ability to report contraventions of the policies, both through discussion or via
anonymous whistleblowing mechanisms. There must also be strong and reliable disciplinary
measures in place to hold individuals to account, regardless of their seniority.
A ROBUST APPROACH TO ANTI-CORRUPTION
Accountability means delivering on our commitments and being responsible for our actions. Our
company is subject to anti-corruption legislation in every jurisdiction in which we operate. Risk
of corruption arises in areas of the world where the perception of corruption is high, particularly
where governmental structures at a national or local level are insufficiently robust and where there
is a limited pool of potential suppliers. The high value of our product, gold, also increases the risk.
Corruption may impose additional costs on the business in the supply of goods and services and
in extreme cases may result in employees being exposed to health or safety risks.
A number of policies and initiatives exist to ensure that our values and approach to anti-
corruption are put into practice, and that risks associated with non-compliance are managed
effectively. These include conflict of interest registries, gift registries, due diligence processes
for agents and key suppliers, as well as the requirement to document interactions with
government. Anti-corruption measures have been put in place globally, as we do not believe
that only developing regions might be at risk.
One important aspect of our governance framework is the Serious Concerns Committee (SCC).
This is an internal oversight governance committee established in 2013 with the mandate from
the Board to review allegations and investigations of unethical behaviour concerning senior-
level employees across the group. The committee comprises senior management from Human
Resources, Legal, Finance, Group Compliance and Group Internal Audit. The principle underlying
the formation of the SCC is that all individuals are accountable for violations of the Code of Business
Principles and Ethics, or any other related policy violations, regardless of seniority or position.
Anti-bribery and anti-corruption training is undertaken at all levels and in all operating jurisdictions
through a combination of video, online and face-to-face training. In some instances, training
programmes have been extended to third parties, to assist in creating an environment where
corruption is not tolerated. In Tanzania, for example, anti-bribery and anti-corruption training is
undertaken together with government officials, the national prosecuting authority, employees
and, where relevant, community members. Due diligence of suppliers and intermediaries is
also undertaken to ensure the organisation has insight into its business partners. Procurement
processes require declarations of government interest in suppliers and combined assurance
processes aim to bring to light instances of non-compliance. We also operate an anonymous
tip-off line and website, where either employees or third parties can report incidences of corrupt
or unethical practice. In 2015, the organisation plans to continue to deliver targeted training
and develop the capacity of sites.
ETHICS AS THE EMBODIMENT OF OUR VALUES
123
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tip-offs registered in 2014,
of which
related to allegations
of corruption
PERFORMANCE
SNAPSHOT
Challenges
In 2014, AngloGold Ashanti
conducted an Employee
Engagement Survey. From the
results we understood that,
while employees identified with
our values, they also raised
concerns as to whether the Code
of Business Principles and Ethics
was consistently being applied
and complied with, and whether
individuals were being held to
account. On the basis of this
feedback, AngloGold Ashanti has
undertaken several initiatives
with the objective of closing any
real or perceived gaps between
our values and our ethics.
Training materials are being
developed that will work towards
modifying employee behaviours
that are counter to our values. A
revision of the Code of Business
Principles and Ethics is underway
to make it easier to understand
and to align key ethical policies
to our values more directly.
Simultaneously, we are working
to communicate whistleblowing
outcomes to employees to
ensure they understand that each
incident is investigated.
ANNUAL SUSTAINABLE DEVELOPMENT REPORT SUMMARY
2014
6