Use of information
|The Code applies to me.|
|Gold Fields Tip-offs Hotline: 0800 547 60 (Peru)|
In accordance with its Disclosure Policy, applicable legislation and rules and regulations of the stock exchanges on which it is listed, Gold Fields is committed to the timely disclosure of information to its shareholders and the public which is full, fair and accurate. The policy is also very clear on who can speak on behalf of the Company or any of its subsidiaries and operation
KEEPING GOLDS FIELDS' INFORMATION CONFIDENTIAL
You are required to treat all information to which you are or become privy to by virtue of your position in Gold Fields including, without limitation, information pertaining to Gold Fields which is not in the public domain, in the strictest confidence. This obligation of confidentiality continues to bind you even after your tenure at Gold Fields.
Confidential information about Gold Fields, its operations, activities and properties may not be revealed to a third party of Gold Fields without the prior authorisation of your VP: Head of Legal who may, in turn, require guidance from the Gold Fields EVP: Group General Counsel.
You will not disclose or use such information for any purpose whatsoever other than the business purpose for which it was disclosed to you in the fulfilment of your duties to and position at Gold Fields.
If you are ever uncertain as to whether or not information is confidential or the purpose for which any information may be used, you must seek the advice of your VP: Head of Legal or, ultimately, the Gold Fields EVP: Group General Counsel.
SPEAKING AND PRESENTING INFORMATION PUBLICLY
You are not permitted to speak, lecture or present on the affairs of, or on matters or subjects relating to Gold Fields without the prior written consent of the appropriate member of your Regional Exco or of the Gold Fields Exco before such a lecture or presentation. This is also applicable once your employment with Gold Fields has come to an end, or if you are speaking, lecturing or presenting at your own cost.
You must record the details in the Conference and Public Address Register together with the confirmation of the approval obtained from a Regional Exco member or a Gold Fields Exco member.
Gold Fields respects the privacy of all of its employees and third parties. All personal data must be handled responsibly by every employee and in compliance with all applicable privacy laws. Employees who handle the personal data of others must:
- always act in accordance with applicable laws and regulations;
- always act in accordance with the Gold Fields Group IT Policy;
- always take any relevant contractual obligations into account;
- collect, use and process such information only for legitimate business purposes;
- limit access to the information to those who have a legitimate business purpose and are authorised to see the information; and
- take care to prevent unauthorised disclosure. Should you have any concern regarding your personal data on any devices, you should contact the IT department or your Manager.
Gold Fields expects its employees to exercise absolute discretion and responsibility at all times when using online communication, including emails, social media or other forms of communication. You should always use the best judgement and understand the Disclosure Policy and Group IT Policy (which includes the use of social media and the internet) and any future policy introduced in this regard. Use of online communication that is negative or of a discriminatory nature and affects Gold Fields’ reputation will not be tolerated and could result in disciplinary action taken against you.
Give the information back to a senior member of HR immediately and report your discovery and actions to the Compliance Officer or member of your legal team. Protecting confidentiality and private information is the personal responsibility of each Gold Fields employee. The individual who left the documentation on the photocopier will also need to be spoken to.