Management approaches

Gold Fields' sustainable economic performance is critical to the value creation of the Company. Our financial and operational performance largely determines the profitability of the Company, which is essential for its future growth and long-term sustainability. It is also critical in sharing the wealth of mining with our key stakeholders, including our employees, business partners, host communities, governments and capital providers.

An important partner and stakeholder are the communities that host our operations. Without their support, managing mines becomes a lot more difficult – indeed, communities can stop operations and in many developing countries they do so if they believe they are not receiving their fair share of the wealth or that mining damages their livelihoods or environments

As such community value creation is a critical component of our direct and indirect economic impact. Directly, through the employment of community members in our workforce, procurement from host community enterprises, and investment in community projects in the areas of skills development, education, health and infrastructure development. Indirectly, as host community employees, contractors and firms create economic wealth, skills and further jobs in these communities.

Economic performance

The three pillars of the Gold Fields strategy are critical in achieving our economic performance:

• Maximising potential from current assets through people and innovation
• Building on our leading commitment to ESG
• Grow the value and quality of our portfolio of assets

These are outlined in detail in the Integrated Annual Report (IAR). The highest level of responsibility for economic performance lies with the Board of Directors, which approves the strategic direction for the Company’s economic performance. The strategy is developed by the executive leadership team with implementation by the regional offices and the various operations.

The operational and financial performance of the Company is presented on a quarterly basis to shareholders and other stakeholders at quarterly results presentations. Annually, the IAR provides an overview of all aspects of Gold Fields’ economic performance. The Board – representing shareholders – evaluates the economic performance of management.

STAKEHOLDER VALUE CREATION

We cultivate mutually beneficial relationships with our stakeholders to strengthen our reputation and social licence to operate and deliver enduring value where we operate.

We recognise the importance of strong community relations to our social licence to operate. We are committed to avoid and prevent, minimise, mitigate and/or remedy the negative impacts of our operations on host communities and other stakeholders, while also delivering enduring social and economic well-being. Through meaningful engagement founded on mutual respect and trust, continual improvement of our social performance and our commitment to create and share value, we seek to create enduring value beyond mining.

Guiding our Community Relations approach

Gold Fields' approach to creating positive community value creation and community relations comprises the following:

• An informed understanding of our operating contexts, stakeholder priorities and associated risks obtained through baseline studies, impact and risk assessments and stakeholder engagement
• Active management of environmental and socio-economic impacts and risks of our operations through implementation of management strategies and plans
• Building relationships with our stakeholders through open, transparent and constructive engagements
• Meaningful social investment to address the priority needs of our host communities in the areas of infrastructure development, economic diversification, education and skills development, health and wellbeing, and environment and conservation
• Formalised partnerships with governments (national, regional and local), NGOs, donors and other stakeholders
• Creating shared value through host community procurement, host community employment and public infrastructure development

In keeping with Gold Fields guidance, all of our operations and projects implement environmental and social impact assessments and management plans as required. Consistent practices across all our sites include ongoing, planned community engagements, formal grievance management, social risk assessments and socio-economic development and shared value programmes.

Our approach to community relations and stakeholder engagement is guided and informed by country-specific regulations and guidelines, the external standards, guides and codes we have adopted, our internal policies and guidelines and commitments as well as the industrial forums we participate in.

OUR SOCIETY AND COMMUNITY CHARTER - OUR COMMITMENTS TO OUR COMMUNITIES AND GOVERNMENTS

Our charter commits us to:

• Build strong relationships with key stakeholders, based on trust and open, honest and frequent engagement
• Create and deliver enduring value in collaboration with - and for - our host communities and governments in line with our ESG Priorities and 2030 targets
• Monitor and measure our performance against our commitments to create enduring value, build relations and trust and reduce our impact on the environment
• Strive to reach a better understanding of the underlying concerns and aspirations of our host communities, the issues associated with our business and to co-create and deliver the right commitments to secure and maintain our social licence to operate.

Each region is implementing Government and Community Action Plans, aligned to Group guidance, ensuring delivery of these commitments.

Shared Value

Shared Value is created when companies take a proactive role in simultaneously addressing business and social needs. Shared Value goes beyond mitigating the potential harm in a company’s value chain – it is about identifying new opportunities for economic success by incorporating social priorities into business strategy and working collaboratively with multiple stakeholders to find solutions to various socio-economic and environmental issues. A key component of this approach is to ensure that the value created is shared by the business and the community.

Our Shared Value approach is based on four key pillars:

1

Strategic interventions, to proactively address socio-economic challenges

2

Integration to proactively address socio-economic challenges

3

Participation in collaborative action with other stakeholders

4

Transparency regarding Gold Fields’ economic contributions to its host societies in line with World Gold Council guidelines

We currently have several Shared Value projects in our regions, including our Host Community Procurement and Job Creation programmes with the goal of increasing the proportion of sustainable host community procurement and jobs. Each region is implementing plans, aligned to Group guidance, that include targets for host community procurement and employment.

HOW WE CREATE VALUE FOR OUR COMMUNITIES

Fit-for-purpose community relations teams are in place in all our operating Regions. These teams collaborate with other business functions as well as our trusts and foundations to deliver community impact, often in partnership with governments, NGOs, donors and peers. Investments are funded through the operations budgeted expenditure.

We have incentivised our management teams via ESG targets since 2017, including host community value creation. This has gained further traction with the launch of our 2030 ESG targets, which are linked to performance scorecards for all Group and regional management teams.

Our regions conduct regular independent assessments to measure the strength of our relationships with host communities, the social return on investment by our community projects and the shared value we create

Our performance is reported in our Integrated Annual Report, Report to Stakeholders and in our full-year and interim results releases, which are publically available.

Gold Fields has a Social Performance Framework which requires our operations to assess the baseline social context, engage and build relationships, create and share value, management impacts, measure delivery and action improvement to align delivery with commitments. We actively identify, map and engage with stakeholder representatives, including host communities and governments, on a regular basis – both formally and informally.

Our engagement is guided and informed by the external standards, guides and codes we have adopted, our internal policies and guidelines and commitments as well as the industrial forums we participate in:

All of our operations are required to implement culturally appropriate stakeholder engagement plans for all stages of the life-of-mine.

All mines and projects have established mechanisms through which communities can voice their grievances and concerns about the company and have these issues assessed and resolved within a specified period.

Our Regions conduct regular independent assessments to measure the strength of our relationships with host communities.

Our community engagement trends and focus is reported in our Integrated Annual Report and Report to Stakeholders which are publicly available.

Our Occupational Health and Safety Policy Statement was updated in 2021 and our Group Safety Strategy was updated and approved by the Board in 2019. Gold Fields strives for zero harm to our workforce. Our value is: "If we cannot mine safely, we will not mine". We aim to eliminate the potential for incidents, injury and ill health at the workplace and strive to minimise hazards in the working environment.

Several core beliefs are enshrined in our approach to the management of safety, including:

• Leadership is responsible and accountable for health and safety performance
• Living our values is fundamental to our safety and health performance
• All employees should return home safe and healthy every day
• Prevention is better than cure and therefore risk management is a key component of all systems
• All injuries and incidents are preventable and rely on good leadership, practical systems and positive employee behaviours
• The management of safety should be integrated seamlessly into all activities
• The right to say "no".

Given these beliefs, the key philosophies prevalent in our approach to safety are centred on:

• Safety performance forms a fundamental component of performance management and talent development through the monitoring of appropriate indicators
• The delivery of the required performance is not only systematic but requires developing leadership and a culture that enables the performance
• Risk assessment and the deployment of appropriate controls is a fundamental approach to the elimination of incidents and is therefore required to be a core competency throughout the workforce
• The application of the hierarchy of controls is particularly relevant to our business and provides the foundation for delivering a hazard- and impact-free workplace
• The elimination of incidents is a process of continual learning and drives continual improvement of our systems, practices and process
• Employees are encouraged to report injuries, incidents and hazards to support the process of continual improvement
• Absolute attention should be applied to the verification and maintenance of critical controls
• There is no tension between safety and production and our workforce must be empowered to "Stop, Think, Fix, Verify and Continue".

Our overriding strategic goal is focussed on eliminating material unwanted events, fatalities, serious potential incidents, health risk exposures and those injuries and illnesses that are serious enough to be life-changing. Where we have achieved the elimination of the abovementioned injuries and events, our focus remains on maintaining this result.

In addition, we apply the appropriate level of resources to a lower order priority in achieving continual improvement in the elimination injuries of lower significance (restricted work, medically treated and minor injuries) at our operations. To achieve the goal, the key strategic objectives are as follows:

• Develop a culture of safety leadership throughout the organisation and firmly embed safety management as a line management responsibility
• Provide appropriate mechanisms to engage our workforce on safety and health and equip them with the necessary skills to achieve safe outcomes consistently
• Ensure the deployment of fit for purpose management systems that are aligned to a critical control management approach and are certified to the ISO 45001 standard.

The actions supporting these strategic objectives have been categorised into safety leadership, safe behaviour and safety systems.

Gold Fields’ zero harm Safety Strategy focuses on three key, mutually supportive and comprehensive programmes:

• Courageous Safety Leadership (CSL), is about motivating employees to display leadership
• The Vital Behaviours programme seeks to influence employees to make the right choices
• The Critical Control Management (CCM) approach within our safety systems

The CSL programme equips our employees with practical tools to become safety leaders, while also fostering an environment in which individuals feel empowered to speak out about unsafe behaviours. Improvements to our leading indicators are a positive sign of potential improvement. Over 5,800 employees attended CSL training in 2021 – exceeding our target of 4,500 people – despite continued Covid-19 restrictions. To date, over 16,000 people have been trained.

The Vital Behaviours programme in Australia, which is being rolled out to our other regions, is a bottom-up behavioural programme that supports improvement in health and safety outcomes via safe production. It empowers workers to identify and resolve workplace health and safety issues and hazards, supported and enabled via management commitment. It includes "Opinion Leaders" who represent workers and actively influence adoption and application of Vital Behaviours. CCM is a key tool used by Gold Fields to prevent incidents that have the potential to severely injure our people. We follow the approach outlined by the ICMM, and have learnt much from – and, we believe, contributed to – the efforts of our peers in the ICMM. CCM is a practical method of improving managerial control over rare but potentially catastrophic events – called material unwanted events (MUEs) – by focusing on critical controls. The first step is to identify controls for each MUE, in particular those controls that will prevent the event from occurring or mitigate the consequences. The absence or failure of a critical control will significantly increase the risk of an MUE occurring, despite the existence of other controls. We provide a level of external assurance over the critical controls in place for specific MUEs.

All Gold Fields managed sites have an occupational health and safety management system that is certified to ISO 45001. The certified management system includes the following components:

• Each site maintains, with annual reviews of completeness and compliance, a legal register
• Hazard and incident management processes. Incident management software is used to record investigations and manage corrective actions, including improvements to systems to prevent recurrence
• Training records
• Incidents and near misses are discussed by site and regional leadership teams and shared across the group.

Each site provides workers with access to medical and health services including:

• Health monitoring of workers in higher risk occupations, including diesel particulate matter (DPM), respirable silica dust, noise and radon gas
• Wellness support, including, as appropriate, HIV counselling and testing
• Each site maintains confidential medical records for workers compensation.

Each site communicates with its workforce on occupational health and safety through:

• Pre-shift meetings, toolbox (safety) meetings, health and safety committee meetings, incident investigations, risk assessments and audits
• Health and safety representatives and Health and Safety Committees comprising management and the workforce Health and safety representatives and Health and Safety Committees comprising management and the workforce

All sites provide occupational health and safety training, based on a training needs analysis, in work time, including:

• General and site specific inductions, hazard identification and risk assessment training, incident reporting and investigation
• Job-related skills training in specific job procedures and production processes
• Critical hazard (high risk) activities, e.g. confined space, isolation, working at height
• Licence and authority training, e.g. isolation officer, electrician, crane operator
• Statutory positions, e.g. registered manager, health and safety representative, explosives.

Business partners working on Gold Fields sites are required to demonstrate compliance to Gold Fields policies and standards. The health and safety systems of all major service suppliers are evaluated in the tendering process to ensure consistency with Gold Fields’ health and safety requirements and values and are audited.

We have established regional environmental, health and safety (EHS) scorecards to improve performance at an operational level. These scorecards include leading and lagging key performance indicators (KPIs), along with Group-wide and regional KPIs.

The Group Code of Conduct (the Code) binds all Company directors, employees and third parties and clearly articulates Gold Fields' policy with respect to – among other things – the absolute prohibition of facilitation payments and political contributions. In addition, the Code of Conduct has stringent requirements re the declaration of any potential, actual or perceived conflict of interest, as well as disclosure for the remediation of any risk, nature and extent of allowable donations and sponsorships, under the ambit of gift, hospitality and entertainment requirements. The Code also recognises that, and hence allows for the Group to engage and interact with external stakeholders.

Government entities, regulators and other authorities are some of the key defined stakeholder groupings Gold Fields frequently interacts with. These interactions are either indirect, through the respective Chambers of Mines or direct, with departments in government in the various operating jurisdictions or during on-site regulator reviews/ inspections. The focus is inter alia to partake in policy development or material regulatory change, engage on licensing and/or reporting requirements and pro-active partnership development between the Group and Government.

As such, the Code requires that all interactions are recorded via an External interaction and Commitment Register. The construct of the Register enables the regional legal team to assess and analyse information to give effect to the stated approach purpose. Apart from the Code's requirements re interactions, business rules have also been drafted. During the latter part of 2018, the recording of interactions with all defined external stakeholder grouping has become a requirement.

APPROACH PURPOSE

• Creating a systemic view of all interactions across the Group's operating jurisdiction in order to pro-active manage any actual, potential or perceived ABC risk, reputation risk and the risk of association.
• Ensuring only mandated employees engage and interact specifically with government entities and/or public officials, as well as other defined external stakeholders.
• Facilitating a structured engagement approach when dealing with issues effecting the industry.

MECHANISMS

Training

An eLearning program to assess the employees understanding of the Code re interaction with government.

Solutions

• Meta data analysis is conducted on a quarterly basis to determine trends and enhance the interpretation and application value of the Code's requirements.
• A data analytic tool enables management and other internal stakeholders to unpack identified trends and enhance the interpretation and application value of the Code of Conduct’s, and more specifically external engagement requirements. The analysis outcome is reported to the Audit Committee on a quarterly basis.
• Structured Internal Audit reviews
• A dedicated Gateway has been scoped, designed and implemented to act as a centre of excellence for employees to further contextualise the requirements and its application.

Reporting

• Via a monthly Compliance Update, Executive Vice Presidents are kept up to date re the outcome of the trend analysis exercise per country, as well as concerns raised by the Group Compliance Office. An aggregate overview is reported to the Group Audit Committee on a quarterly basis.

Cryptic Results

• During 2021, 2 727 external engagements have been recorded. 1 077 related to interactions with government and related entities. The majority of interactions were held with national government (43%), followed by interactions with host governments (16%), territorial government (25%) and Regulators (16%). The three key interaction themes related to regulator reviews/ authorisation, coordinate, partner and share, and community relations matters. Under the ambit of COVID-19 movement restrictions, 57% of interactions were remotely.

Environment

Gold Fields is committed to responsible stewardship of natural resources and the environment for present and future generations. We aim to operate in an innovative manner that minimises or mitigates adverse impacts and maximises positive impacts of an environmental and socio-economic nature.

Our approach to environmental stewardship is guided by the precautionary approach and informed by several external standards as well as local legislation, supported by internal policies and priorities. Additional local priorities are identified through stakeholder consultation. We have established, implemented, integrate and maintain internationally recognised and externally certified environmental management systems (EMSs). These ensure consideration of environmental issues in business strategies and initiatives, a framework for setting environmental objectives, continual improvement of the environmental management system and environmental performance and prevention of pollution. Each of the Group's operations are certified to ISO 14001(2015), including our newest operation, Gruyere, which started production in mid-2019. All of our eligible operations are fully compliant with the International Cyanide Management Code. Gold Fields does not use mercury for the beneficiation of gold or in any of its processes.

External initiatives			Internal guidelines, policies and documents			Industrial forums and working groups
Regulatory requirements, and obligations relating to industry rules, codes and standards to which we subscribe, that relate to our environmental aspects and impacts including: Local legislation ISO 14001(2015) environmental management standard The 10 Principles and 8 Position Statements of the International Council on Mining and Metals (ICMM) The UN Global Compact International Cyanide Management Code CDP: Water Disclosure Project			Group Sustainable Development Policy Group Environmental Policy (updated January 2021) Group Climate Change Policy Statement Taskforce on Climate Related Financial Disclosures (TCFD) Group Biodiversity Guideline Group Environmental Incident Classification and Reporting Guideline			ICMM Biodiversity Working Group Gold Fields Environment Working Group

Internally, Gold Fields has implemented policy statements and five Group-level guidelines, which reflect our environmental priorities. These concern energy and carbon management, water management, tailings management, biodiversity and integrated mine closure. A summary of the Group guidelines can be found on the Gold Fields website at www.goldfields.com>sustainability.These guidelines set out the systems and processes necessary to ensure the application of consistently good environmental management practices across the Group while allowing a degree of adaptation to local circumstances.

Accountability for implementing our Group Policy Statement: Environment, and associated guidelines lies with the General Manager and / or VP Operations in control of the site, with guidance and support from the Sustainable Development team.

Gold Fields track regulatory changes which enables the operations to respond (externally to the Regulator and internally regarding the control environment) to the changes. In addition, it also allows for the consideration of applicable/ existing controls in order to manage control effectiveness.

We continue to evaluate performance through internal assessment processes, such as environmental management system audits, in which opportunities for improvement are identified and implemented. This is complimented through internal audit reviews of key aspects of environmental management such as waste management. Our material non-financial disclosures are assured independently on an annual basis.

Results of our performance are reported through disclosures such as the TCFD, CDP:Water report, as well as through ESG assessments such as DJSI. These assessments and outcomes are publically available.

Gold Fields requires consideration of sustainability aspects in Environmental and Social Impact Assessments (ESIAs) which are conducted on all new projects. Environmental Management Programmes (EMPs) are then developed after the EIA has been approved stating how the project will comply with the conditions of the environmental authorisation. Gold Fields have developed standards for investment projects for Concept, PreFeasibility and Feasibility Studies, which include sustainability requirements for environmental and water stewardship, climate and energy, mine closure, tailings management, social and community.

Gold Fields has a strong commitment to biodiversity and protected areas. We are aligned with the ICMM Position Statement for Mining and Protected Areas. Our commitment is contained in the Environmental Policy and supported through our Mine Closure Guideline and Biodiversity Guideline.

Environmental Incidents

Gold Fields reports environmental incidents using a level 1 (most minor) to 5 (most severe) scale. Level 3 and above environmental incidents are reported externally, through our Integrated Annual Report.

No Level 3 – 5 incidents remains a key environmental target included in our Group Environmental Policy Statement, and our mines have been making good progress with a renewed focus on environmental management, as well as greater integration of these issues into operational management and community engagement. A clear benefit of achieving zero Level 3 – 5 incidents is improved relations with those communities adjacent to our operations.

Level	Description	Impact
Levels 1 and 2	Minor incidents or non-conformances	Negligible or short-term limited impact.
Level 3	Limited non-conformance or non-compliance	Ongoing but limited environmental impact.
Level 4 and 5	Major non-conformances or non-compliances	Long-term environmental harm, with operation-threatening implications

Our Group Sustainable Development Manager is the responsible Group lead for environmental stewardship, with all regions and operations having environmental managers and teams to support this function.

BIODIVERSITY

Our Group Biodiversity Guideline, updated in 2019, ensures that we address potentially adverse impacts on biodiversity on our mine properties through the application of mitigation measures and integrated land management practices. Our guideline is applicable to all Gold Fields managed exploration and operations. This includes land and land impacted by Gold Fields’ activities, and encompasses all phases of the mining life cycle.

We commit to contribute to the conservation of biodiversity, and specifically:

• Neither mine or explore in World Heritage sites, and design and operate our mines in a manner which does not compromise the biodiversity value of any protected area
• Assess and address risks and impacts to biodiversity and ecosystem services by implementing the mitigation hierarchy
• Achieving no net loss of biodiversity for all new projects or major expansions on existing sites

As members of the ICMM we are committed to abiding by the ICMM’s 10 principles and their associated Performance Expectations. ICMM’s Principle 7 requires that members contribute to the conservation of biodiversity and integrated approaches to land-use planning.

Our Gold Fields Biodiversity Guideline has the following management principles:

• Reduce the negative and increase the positive impact of the Company’s activities on biodiversity.
• Adopt an ecosystem approach, in which land, water and living resources are managed in an integrated manner that promotes conservation and sustainable use in an equitable way.
• Adopt the mitigation hierarchy approach towards the management of biodiversity related risks at each stage of the mine lifecycle. The mitigation hierarchy is a framework for managing potential impacts to biodiversity and involves a sequence of actions including avoid, minimise, restore and offset.
• All new projects and major expansions of existing sites shall strive towards achieving no net loss of significant biodiversity where biodiversity presents a significant risk and / or opportunity to the Company.
• Adopt a precautionary approach towards biodiversity management: i) take preventive action in the face of uncertainty; ii) shift the burden of proof to the proponents of an activity; iii) explore a range of alternatives to actions; and iv) increase stakeholder engagement in decision making
• Engage with stakeholders to complement our scientific determination of biodiversity values and to inform biodiversity management, especially in relation to the site’s biodiversity related closure objectives.
• Collaborate and engage in biodiversity partnerships where relevant to further biodiversity understanding, accountability and responsibility, and address biodiversity management challenges over the Life of Mine.
• Develop objectives and targets for biodiversity that deliver a self-sustaining ecosystem that will be viable post-closure without ongoing management intervention.
• Align climate change mitigation and adaptation or resilience efforts with biodiversity mitigation measures to increase the effectiveness of both, whilst considering the potential impacts of climate change on the Company’s biodiversity management activities.

Our Group Biodiversity Guideline is applicable to all Gold Fields managed exploration and operations. This includes land and land impacted by Gold Fields’ activities and encompasses all phases of the mining life cycle. Our scope of the no net loss commitment is company wide scope and is applicable to new Projects and major expansions. Through our Group Policy Statement: Environment, our commitment to protection and enhancement of biodiversity end ecosystems is applicable to everyone working for, on behalf of, and third parties to Gold Fields. Accountability for implementing our Group Biodiversity Guideline lies with the General Manager and / or VP Operations in control of the site, with guidance and support from the Sustainable Development team.

During the 2021 reporting year, we did not identify any significant direct impacts (measured) on biodiversity resulting from our operations’ activities. In some instances, this is attributable to application of the mitigation hierarchy and other environmental management mitigation and management efforts. We continue to report on the status of our biodiversity protection efforts of the short-tailed chinchilla at our Salares Norte Project and mine construction.

Waste and Effluents

Water and waste are proactively managed to reduce potential environmental and socio-economic impacts and realise potential opportunities at all eight of our managed operations.

We commit to sustainable use of resources, responsible management of waste streams and effectively manage water, and apply strong and transparent water governance to achieve responsible and sustainable water use in a collaborative manner.

The most significant waste materials produced by our operations are tailings, waste rock, chemical waste and hydrocarbon waste. By carefully managing our waste generated by our operations and consequent TSFs, we minimise the environmental and potential social impact.

We manage waste in accordance with a waste management hierarchy through which we aim to prevent or reduce waste generation. Where we do generate waste, we aim to reuse, recycle or treat waste prior to disposal.

Gold Fields does not import, export or transport any waste deemed hazardous under the terms of the Basel Convention Annex I, II, III, and VIII.

Integrated Mine Closure and Rehabilitation

Sustainable and integrated mine closure remains one of Gold Fields’ five key sustainability focus areas. Through the careful planning of mine closure and progressive rehabilitation, we are able to

• Reduce our environmental impact
• Reduce social and community impact
• Optimise financial liabilities
• Build credibility with our stakeholders
• Enhance our asset’s value

Our mine closure is guided and informed the external standards, guides and codes we have adopted, our internal policies and guidelines and commitments as well as the industrial forums we participate in.

External initiatives			Internal guidelines, policies and documents			Industrial forums and working groups
ICMM: Integrated Mine Closure and Land Rehabilitation ICMM Integrated Mine Closure: Good Practice Guide Local legislation ISO 14001(2015) environmental management standard International Cyanide Management Code Our closure liability estimates are managed in accordance with: International Finance Reporting Standards (IFRS) International Audit Standards (IAS) 37 Sarbanes Oxley Act of 2002 (SOX)			Integrated Mine Closure Planning Guideline Group Closure Cost Estimate Guidance and Process Framework Group Sustainable Development Policy Group Environmental Policy Group Climate Change Policy Statement Group Water Stewardship Policy Statement Group water management guideline Utilisation of the Nevada Standardized Reclamation Cost Estimator tool			ICMM Mine Closure Working Group Gold Fields Integrated Mine Closure Steering Committee Gold Fields Integrated Mine Closure Working Group.

All Gold Fields operations have Mine Closure Plans that are regularly updated with independent experts supporting the updates. An important component of our Mine Closure Plans is Stakeholder Engagement.

All operations have also determined their closure liability for disturbance or liabilities ‘to date’ in line with international financial reporting standards. These liabilities are reviewed and revised annually and are independently assessed. Gold Fields report their closure liability publically, and identify reasons for material changes on an annual basis. We utilise the Nevada Standardised Reclamation Cost Estimator (SRCE) tool for all operations’ closure liability estimates.

Our Mine Closure Plans and Closure Liability estimates are guided through the Group Mine Closure Management Guideline and Group Closure Cost Estimate Guidance. As we aim to integrate mine closure planning through our business, and optimise our liabilities through progressive closure and rehabilitation, we have set ourselves targets through our Regional scorecards which are assessed on an annual basis (as a minimum). Our Group Sustainable Development Manager is the responsible Group lead for mine closure, with all regions and operations having an environmental and mine closure lead.

This comprises Gold Fields’ approach to employment or job creation, including recruitment, onboarding, development, retention, our working conditions and related practices. Gold Fields’ abides by the principles of the International Labour Organisation.

Approach details

Our approach to employment considers, but is not limited to:

• New employee hires and employee turnover
• Employee onboarding
• Employee technical and leadership development
• Talent Management of full-time employees
• Benefits provided to full-time employees
• Parental leave
• Flexible work arrangements

At Gold Fields we track the age, gender, nationality, diversity, disability, localisation, host community and employment equity status (in South Africa) of our employees and new hires as part of our strategy to attract a diverse range of qualified employees. This ensures, that we not only have the best talent but also helps to ensure that we implement inclusive recruitment practices based on age, gender, nationality, diversity, disability, localisation, host community and Employment Equity Status (in South Africa). This enables us to implement talent strategies that allow us to make the best use of available talent in the regions in which we operate.

We also have diversity targets for female representation. These targets can be found in our group and regional scorecards and in our long-term incentive schemes for our management employees. Our turnover rates are key indicators of employee satisfaction and engagement. Changes in local market conditions as relates to our reward philosophy is a key indicator in the management of our human capital.

The benefits that Gold Fields provides to employees are governed by the local legislation in the countries in which we operate but as an organisation we include flexible work, health care, life insurance, disability cover, maternity leave, options for parental leave from annual leave or parental leave benefits, retirement provision and other benefits that employees may opt to select from.

Approach purpose

Gold Fields’ will ensure that we abide by the all the local legislation in the countries in which we operate but will also ensure that our employment practices are based on the principles of the International Labour Organisation (ILO). We seek to ensure that we offer fair employment practices, use advanced metrics to ensure that we have inclusive recruitment practices and constantly strive to create an environment where all employees can have a great career in mining.

Approach components

The responsibility for employment resides with the Human Resource teams and Executive teams in the Regions with accountability for senior appointments resting with the EVP People and Organisational Effectiveness. Execution and oversight are enabled via a Recruitment system which systemically records, analyses and reports on the number of positions advertised, recruited and placed and is being embedded in each region.

Mechanisms

The Group recruitment and selection policy outlines the recruitment practises for Gold Fields, and this is further supported by regional recruitment policies where local legislation has specific requirements. Appointments into roles is approved as per the Gold Fields approvals framework, with employment decisions requiring a formal process of approval. Recruitment statistics and turnover data are collated and reported.

Benefits are reviewed periodically in line with local requirements and international best practice and all employment policies and procedures are subject to internal and external audit requirements.

Maternity leave in all regions and paternity leave (where provided in line with local legislation) is tracked and recorded along with other leave types.

Gold Fields endeavours to engage with our contactor workforce in relation to matters relating to safety and health. We also seek to work with our largest contractor mining partners, where we can, specifically to engage on working practices.

We participate in global industry assessments to benchmark ourselves on elements such as gender diversity.

Results

During 2021, turnover in Gold Fields was at 6%. Our engagement surveys show that we have high levels of engagement in our workforce and have shown a steady increase year-on-year from 2018-2021 in these engagement levels. Gold Fields’ employees have the full range benefits in line with legislative requirements in the regions that we operate in.

Parental leave is applied as per local legislation but if this is not a leave entitlement employees can opt to take annual leave for parental leave purposes.

Gold Fields is committed to responsible water stewardship – both for the benefit of host communities and for our own operations. Clean water is a basic human right, a resource that is becoming increasingly scarce and vital to our processing activities. Our approach to managing our impact is essential to maintaining our licence to operate. Through careful management, we are able to reduce our environmental impact through responsible use, storage and release of water, while also reducing our costs, thereby benefitting all stakeholders.

Our water management plans are guided and informed by the external standards, guides and codes we have adopted, our internal policies and guidelines and commitments as well as the industrial forums we participate in.

External documents			Internal guidelines, policies and documents			Industrial forums and working groups
ICMM Water Position Statement and Reporting Guideline ISO certifications			Group Sustainable Development Policy Group Environmental Policy Group Climate Change Policy Statement Group ESG Charte Group Water Charter Group water management guideline, updated in line with the ICMM Water Position Statement Reporting Guideline and other best practices Group Water Strategy			International Council on Mining and Metals Minerals Council of South Africa Minerals Commission, Ghana Chamber of Minerals and Energy of Western Australia

As part of the launch of our 2030 ESG targets in 2021, we set two overriding water management targets: reducing our freshwater usage by 45% from a 2018 baseline and recycling and reusing at least 80% of the water we use. These long-term targets have been translated into annual targets.

We also continued implementing the Group’s 2020 – 2025 Water Stewardship Strategy, which is supported by detailed regional water management plans. Our strategy comprises the following key pillars:

• Security of supply: We focus on understanding and securing water resources for the life-of-mine, as well as embedding water planning into operational management and updating water security risk profiles to support the sourcing of water.
• Water efficiency: It is necessary to continually reduce demand for freshwater and optimise the use of water resources due to potential water supply shortfalls and competition from communities. Our operations continued to make good progress to reduce freshwater withdrawal in 2021.
• Catchment area management: It is critical that Gold Fields manages external water risks to the business and our stakeholders in the water catchment areas in which we operate. While our initial assessments indicate that our operations do not have significant negative impacts on these stakeholders, we are implementing formal water stewardship partnerships with stakeholders in their catchments. We hope to complete these, where applicable, by 2025.

This comprises Gold Fields’ approach to employment or job creation, including recruitment, onboarding, development, retention, our employment conditions and related practices. Gold Fields’ abides by the principles of the International Labour Organisation, UNGC and jurisdictional legislation. In 2021, we launched our Company’s purpose – to create enduring value beyond mining and a revised purpose statement and refreshed our Values.

Approach details

Our approach to employment considers, but is not limited to:

• New employee hires and employee turnover
• Employee onboarding
• Employee technical and leadership development
• Talent Management of full-time employees
• Reward and Benefits provided to full-time employees
• Employment conditions and practices
• International labour standards and applicable legislation in the countries in which we operate. There is a range of legislated benefits including insurances, leave entitlements, access to assistance programmes and others that are managed in each region.
• Ensuring no child labour at any of our operations
• Ensuring we do not have or support any forced compulsory labour
• Driving diversity and inclusion in the workplace
• Ensuring equal pay for equal work and tracking gender or other biases in reward.
• Tracking, monitoring and creating awareness around discrimination, bullying, harassment and sexual harassment
• Focus on employment where possible from our host communities

At Gold Fields we track the age, gender, nationality, diversity, disability, in-country and host community employment, and Employment Equity Status (in South Africa) of our employees and new hires as part of our strategy to attract and retain a diverse range of qualified employees. This ensures, that we not only have the best talent but also helps to ensure that we implement inclusive recruitment practices based on age and gender and implement talent strategies to ensure that we make the best use of available talent in the regions in which we operate. Turnover rates and market conditions are key indicators of employee satisfaction in the management of our human capital.

The reward and benefits that Gold Fields provides to employees is governed by the relevant local legislation. The benefits we provide as an organisation include: health care, life insurance, disability cover, maternity leave, parental leave, annual leave, sick leave, study leave, retirement provision and other benefits that employees may opt to select.

Approach purpose

Gold Fields’ is committed to abide by local legislation in the countries in which we operate but will also ensure that our employment practices are based on the principles of the International Labour Organisation (ILO). We seek to ensure that we offer fair employment practices, use advanced metrics to ensure that we have inclusive practices and strive to create and foster a supportive and understanding environment in which all individuals realise their maximum potential within the organisation. Culture is the foundation that enables us to deliver against our People strategy.

Approach components

The responsibility for employment resides with the Human Resource and Executive (Exco) teams in the Regions. Accountability for Regional Exco appointments resides with the EVP People and Organisational Effectiveness and Chief Executive Officer. Execution and oversight are enabled via a recruitment system which systemically records, analyses and reports on positions advertised, recruited and placed.

Mechanisms

Group Recruitment and Selection policy outlines the recruitment policy for Gold Fields, and this is supported by regional recruitment policies where local legislation has specific requirements. Appointments is approved as per the Gold Fields approvals framework, with employment decisions requiring a formal process of approval. Recruitment statistics and turnover data are collated and reported quarterly.

Benefits are reviewed periodically in line with local requirements and international best practice and all employment policies and procedures are subject to internal and external auditing.

Maternity leave and paternity leave (where provided in line with local legislation) is tracked and recorded along with other leave types.

Gold Fields engages with our contactor workforce in relation to matters relating to safety and health. We also work with our local communities with respect to community employment and other matters of strategic importance to the business.

Gold Fields undertakes a range of skills development, technical training, leadership and management training to ensure that we upskill our workforce. Training ranges from on site training in our training centres in Ghana and South Deep, eLearning training, and working with service providers to provide specialised training. Training includes onboarding, legal, health and safety, technical, key projects or initiatives in the business. We also have a strong focus on diversity and inclusion training.

Results

During 2021, average voluntary turnover in Gold Fields was low at 4% (this excludes retirement, terminations and retrenchments). We monitor our turnover rate, and conduct detailed climate surveys every 2 years and check in surveys annually to monitor how employees feel about working for Gold Fields. The results help us focus on initiatives to drive employee engagement annually.

Employees are required to give notice on termination of employment which is typically 30 days but can be longer for some leadership roles ranging from 60 days for senior management, 6 to 12 months for executives.

Gold Fields’ employees have the full range of benefits in line with legislative requirements in the regions that we operate. Although benefits vary between locations, typical benefits for full time employees include vacation, maternity and paternity leave, flexible work, sick leave, medical support, pensions and life insurance, long service awards as well as healthcare services. Part-time employees are not eligible for the same benefits or annual incentives. All employees have access to Employee Assistance Programmes that are designed to assist leaders and employees to manage personal and work related issues. In some regions benefits are superior and include Company accommodation or housing allowance, meals, interest free loans, educational assistance. Parental leave is applied as per local legislation

Mining and processing of gold is an energy intensive process, exacerbated by changing ore geology, declining grades, longer hauling distances and increasing mine depths requiring additional cooling and ventilation infrastructure. Adapting to the adverse impacts of climate change are material for virtually every country and company across the world, given the disruptive nature of the physical risks across our operations and critical supply chain. The management of energy use and spend is vital given our exposure to external energy price volatilities. Managing energy usage enables us to reduce our carbon footprint, thereby reducing our contribution to the impacts of climate change.

Thus, energy use and building climate resilience have been identified as one of Gold Fields’ top five sustainability priorities until 2020. As the mining gets more difficult, energy demand also rises. In our quest for energy security, we assess feasibility for low carbon energy sources, particularly gas, solar and wind. These energy sources enable us to meet multiple objectives: securing supply, reducing carbon emission and optimizing energy costs. Through energy efficiency initiatives, we aim to improve our energy productivity, we have since updated our energy and carbon management guideline to align with the global energy management system standard, ISO 50001, aiming for full alignment by 2020 at our operations. We seek to embed our 3/19/2020 Management approaches | Sustainability | Gold Fields https://www.goldfields.com/management-approaches.php 16/24 strategies in projects – new projects, stay in business and life extension type. We achieve this by including energy deliverables in the study standards.

On climate change, we conduct vulnerability and risk assessments to understand the risks, develop and implement mitigation actions through partnerships and review adequacy of controls every 5-years.

Our approach to managing energy consumption, costs and building climate change resilience is guided and informed by external standards, guides and codes we have adopted, our internal policies and guidelines and commitments as well as the industrial forums we participate in. Many of these forums provide platforms through which effectiveness of our programmes and initiatives are benchmarked.

External documents			Internal guidelines, policies and documents			Industrial forums and working groups
ISO 50001 Recommendations of the Taskforce on Climate Financial Disclosure (TCFD)			Group Climate Change Policy Group Energy and Carbon Management Guideline			Energy Intensive Users Group Minerals Council (South Africa) Chamber of Mines Chamber of Commerce

Climate change affects the availability of natural resources, with availability and infrastructure of water and energy most affected, owing to:

• The impact of extreme weather events on our operations, supply chain and host communities, including severe rain or snow fall, severe winds, extreme temperatures and prolonged drought; and
• An increasing number of climate-related regulations, carbon emissions taxes, stringent water regulations, the impact of new technologies and standards, as well as investor perception.

During 2017, the Board adopted an updated Group Climate Change Policy, which advances and communicates a balanced mitigation and adaptation approach to achieving our climate change objectives. The policy contains a set of commitments that include:

• Conducting climate change vulnerability assessments utilising Group risk guidelines and International Council on Mining and Metals (ICMM) tools and guidelines
• Annual reporting and disclosure via a number of reporting frameworks including the Water
• Disclosure Project (WDP) , TCFD and the Dow Jones Sustainability Index
• Mitigating the effects of climate change by increasingly investing in renewable energy and low-carbon energy sources, energy efficiency initiatives and water use optimisation initiatives
• Supporting research, development and innovation to assist our operations to cope with climate change
• Factoring in a regional carbon price for both costing and as a potential revenue streams
• Participating in various industry forums, including the ICMM climate change and Group energy working group, stakeholder and NGO engagements

Business impact on the climate, and companies’ ability to withstand climate change, are issues of increasing global importance, and vital to our stakeholders. In 2018, Gold Fields became the second Johannesburg Stock Exchange Limited (JSE)-listed company in South Africa (and the first mining company) to publicly back the United Nations (UN)-endorsed recommendations of the TCFD. The recommendations have been adopted by many national financial regulators.

Our policy with regards to Indigenous People is captured in our Community Policy. Gold Fields seeks to develop mutually beneficial relationships with key stakeholders, including Indigenous Peoples, wherever we operate.

We support the definitions of Indigenous Peoples provided by the International Finance Corporation Performance Standard 7, as well as the definition provided by the International Council on Mining and Metals, as defined in article 1 of the International Labour Organisation’s Indigenous and Tribal Peoples Convention (ILO 169).

We recognize that Indigenous People often have cultural characteristics, governance structures and ways of integrating and decision making that sets them apart from non-indigenous population. This requires engagement in ways that are culturally appropriate, paying special attention to the capacities, rights and interests of Indigenous Peoples, within the broader context of community engagement.

To attain this vision we are committed to the following principles:

• Respecting local traditions, rights, interests, cultures, perspectives and special connections to lands and waters of surrounding communities;
• Adopting and applying culturally appropriate engagement and consultation processes that ensure meaningful and fair participation of Indigenous Peoples;
• Timely and ongoing engagement through appropriate systems that provide for dialogue, understanding views and understanding our impacts on those around us in accordance with our values and the UN Guiding Principles on Business and Human Rights;
• Working to obtain consent of surrounding communities, using appropriate mediation and capacity building processes where necessary, for new projects and changes to existing projects, including where projects are located on lands traditionally owned by or under customary use of Indigenous Peoples and are likely to have significant adverse impacts on Indigenous Peoples;
• Stipulating that suppliers and contractors conduct themselves in accordance with Gold Fields policies, standards and guidelines.

Gold Fields Community Relations Standard 7 provides guidance on the Company’s approach to engaging with and respecting the rights and interests of Indigenous Peoples. This is outlined in detail in the Gold Fields Community Relations Handbook. Our guidance is based on international good practice principles that include the International Finance Corporation (IFC) Performance Standards, Equator Principles and AA1000 Stakeholder Engagement Principles, ICMM Mining Principles 3, 9 and 10, our vision, values and group policies as well as our commitment to being a trusted and valued mining partner to our key stakeholders.

Two of the most important outcomes when dealing with Indigenous Peoples are Free, Prior and Informed Consent (FPIC) and formal agreements with Indigenous Peoples. These are enabled by:

• Baseline studies, conducted by appropriately skilled and experienced practitioners, of Indigenous communities including socio-economic conditions, land use practices, rights, interests, connections to land and water, decision making and conflict resolution practices
• Preparation of a stakeholder engagement plan for all stages of the life of mine

Gold Fields Community Relations guidance and standards are equally applicable to Indigenous Peoples (cross reference to Community Relations and Creating Shared Value).

Introduction

We recognise the importance of solid community relations to our social licence to operate. We are committed to avoiding, where possible, or minimising and managing, the negative impacts of our operations on communities, while also maximising the positive benefits. Through active stakeholder engagement and our Shared Value development approach, our focus goes beyond spending to extend to the positive social and economic impacts that its social investments can deliver.

Guiding our Community Relations/Our Approach

Gold Fields’ approach to creating positive community relations comprises the following:

• an informed understanding of our operating contexts, stakeholder priorities and associated
• active management of environmental and social risks and impacts
• building relationships with our stakeholders through open and honest engagements
• meaningful social investment to address the needs of our host communities
• creating shared value through host community procurement and host community employment

Our approach to community relations and stakeholder engagement is guided and informed by the external standards, guides and codes we have adopted, our internal policies and guidelines and commitments as well as the industrial forums we participate in.

External documents			Internal guidelines, policies and documents			Industrial forums and working groups
ICMM Indigenous Peoples and Mining Position Statement UN Global Compact Universal Declaration of Human Rights United Nations Guiding Principles on Business and Human Rights Extractive Industry Transparency Initiative World Gold Council Global Reporting Initiative IFC Performance Standards			Group Sustainable Development Policy Stakeholder Relations and Engagement Policy Community Policy Statement Group Human Rights Policy Community Relations and Stakeholder Engagement Guideline Community Relations and Stakeholder Engagement Handbook			International Council on Mining & Metals Minerals Council of South Africa Business Leadership South Africa Ghana Chamber of Mines Chamber of Minerals and Energy of Western Australia Gold Industry Group of Western Australia Sociedad Nacional de Minería, Petróleo y Energía (SNMPE), Peru Consejo Minero de Chile Sociedad Nacional de Minería, Chile Gold Fields Stakeholder Relations Working Group

Our performance in community relations and social investment is subject to independent measurement by external assessors.

Partnering to protect the industry/Enhancing the industry’s reputation.

Given the socio-economic and at times political pressures the mining industry faces, several industry organisations, of which Gold Fields is a member, have started communication campaigns aimed at improving the image and reputation of mining.

These include the International Council on Mining and Metals (ICMM) and mining industry associations in countries where we operate. The ICMM’s work can be found at www.miningwithprinciples.com.

Gold Fields is working with these organisations to provide relevant material – mostly relating to community investment initiatives and other ESG work, particularly on renewable energy and water.

Gold Fields has a Community Relations and Stakeholder Engagement Guideline based on international good practice principles that include the International Finance Corporation (IFC) Performance Standards, Equator Principles and AA1000 Stakeholder Engagement Principles.

These are outlined in detail in the Gold Fields Community Relations Handbook. This Guideline is also aligned to the ICMM Mining Principles 3, 9 and 10, our vision, values and group policies as well as our commitment to being a trusted and valued mining partner to our key stakeholders. The implementation of the nine Community Relations Standards, which guide our interactions with communities as well as other key stakeholders, are key to achieving this commitment. The nine standards are covered at a high level in this guideline and are described in more detail in the Group Community Relations Handbook.

Our Society and Community Charter – our commitments to our stakeholders

Our charter commits to:

• Building strong relationships with key stakeholders, based on trust and open, honest and frequent engagement
• Leaving an enduring, positive legacy for host communities and work with our stakeholders to promote sustainable development and to create Shared Value
• Monitoring and measuring our performance against our commitments
• Striving to reach a better understanding of the underlying concerns and aspirations of our host communities and to co-create and deliver the right commitments to secure and maintain our social licence to operate.

Building Relationships through Engagement

We understand that stakeholders are an integral part of our business – representing a wide range of interests that both influence and are impacted by our operations. Consistent with our values of Integrity, Respect and Responsibility, we develop relationships with our stakeholders built on open, transparent and constructive engagement. This engagement allows for participative and informed decision making, by balancing the interests, needs and expectations of our stakeholders with the best interests of Gold Fields.

We actively identify and regularly engage with the representatives of the following stakeholders in a formal and informal manner:

• Employees;
• Host Communities;
• Financial market participants (shareholders, investors, capital providers and analysts);
• Governments (national, regional and local) and Regulators;
• Industry associations and mining peers;
• Media;
• Non-governmental and community-based organisations;
• Organised labour;
• Third Parties (business partners, contractors and suppliers); and
• Traditional authorities

During 2020, we reviewed and updated our Stakeholder Relationship and Engagement Policy to be inclusive of our material business-wide stakeholders (the policy is aligned with ICMM’s Mining Principles and King IV). The Group External Interaction and Commitment Register (EICR) system, is used to record and report engagements with all stakeholders from 2019.

Operations also regularly publish and distribute communication materials to stakeholders, keeping them informed about our community relations activities and initiatives. Gold Fields also uses its Group and Regional social media platforms to communicate both with employees and communities as well as the wider public.

All Regions have societal acceptance charters aligned to the Group Charter. Annual community action plans and government action plans are in place to deliver the charter commitments.

Summaries of the engagements held by each region in 2020 are available at www.goldfields.com/investors.

Understanding our grievance mechanisms

We are committed to timeously and effectively addressing community issues and concerns. To this end, all our operations have established mechanisms through which stakeholders can share their grievances about Gold Fields, its actions or the behaviour of its employees on social, environmental and human rights issues. We use a three-order system. The first order is where complaints can be resolved between ourselves and the complainant in a timely manner. Grievances are escalated to the second order when time is needed to investigate and resolve the claim. Mediation by a third party, usually from the local community, may be involved. A grievances is escalated to the third order when it cannot be resolved by the parties involved and is forwarded for legal action.

Our operations have self-assessed their grievance management practices against the UN Guiding Principles on Business and Human Rights effectiveness criteria.

Shared Value

Shared Value is created when companies take a proactive role in simultaneously addressing business and social needs. Shared Value goes beyond mitigating the potential harm in a company’s value chain – it is about identifying new opportunities for economic success by incorporating social priorities into business strategy and working collaboratively with multiple stakeholders to find solutions to various socio-economic and environmental issues. A key component of this approach is to ensure that the value created is shared by the business and the community.

Our Shared Value approach is based on four key pillars:

1

Strategic interventions, to proactively address socio-economic challenges

2

Integration to proactively address socio-economic challenges

3

Participation in collaborative action with other stakeholders

4

Transparency regarding Gold Fields’ economic contributions to its host societies in line with World Gold Council guidelines

The imposition of penalties, sanctions and/ or fines, due to non-compliance to laws, regulations, and adopted rules, codes and standards, as well as to international declaration, convention, and/or treaties, can substantially affect Gold Fields's reputation and the behaviour of investors. In addition, the nature and extent of fines can also have a negative financial impact and remediation of actions required by Regulators can have an effect on operational efficiency and progress.

Gold Fields has established a risk-based Group Compliance Framework to provide high levels of assurance for regulatory compliance. This framework forms an integral part of the Group Governance and Compliance Framework. In terms of the Compliance Framework, Gold Fields:

• Ensures ethical and professional conduct via a comprehensive Group Code of Conduct, supplemented by a Group Policy Register.
• Scans the regulatory environment to identify current and upcoming regulatory changes. This is to ensure a frequent review of the recorded control environments re changes, in order to confirm control design and operating effectiveness. As example, in 2021, as part of screening of the external landscape, 236 COVID-19 and related changes have been identified as applicable, assessed and controls were implemented. These changes represented 46% of all identified regulatory changes during 2021.
• Identifies and consistently reviews all statutes, and adopted rules, codes and standards in its operating jurisdictions and assesses the exposure to non-compliance and subsequent regulatory risks.
• Ensures the alignment of the internal control environments to defined and prioritised statutory requirements.
• Conducts annual reviews by Internal Audit to assess that appropriateness and design/ operating effectiveness of implemented control measures.

APPROACH PURPOSE

• Pro-active response to regulatory changes
• Ensuring controls are aligned to statutory requirements as well as to adopted and applicable rules, codes and standards
• Maintenance of the control environments, where control mapping focuses on the mitigation of inherent risk exposure.
• Assessment of risk exposure and a risk-based approach to mitigate the exposure to non-compliance (internal) and regulatory (external) risk

Mechanisms

Solutions

• A published Management Guideline in relation to the Governance & Compliance Framework contextualises re Framework, as well as the required engagement by all role-players to actively manage any actual or potential risk of non-compliance exposure.
• An interactive Group Governance & Compliance Portal enables execution and oversight, which systemically record, analyse and report on the level of compliance in the Group, across an array of governance and compliance criterion, in line with the adopted risk-based approach.
• During 2021, the fit-for-purpose Data Protection and Privacy Gateway on the Portal was extended to accommodate the implementation of data protection and privacy legislation in South Africa. This Gateway acts as a single source of trust for referencing mapped data flows in the organisation, as well as the drafted control frameworks to mitigate any actual or potential non-compliance exposure.
• The annual Group Compliance Plan is project managed by the in-country legal teams per operating jurisdiction. Meta data analysis is conducted for each phase of the plan to determine trends, gaps and enhance the interpretation and application value of the guidance offer to the business.
• Structured Internal Audit (IA) reviews
• Data analytic tools enable management and other internal stakeholders to unpack identified trends and enhance the interpretation and application value. The analysis outcome is also reported to the Audit Committee on a quarterly basis.

Reporting

• Via a monthly Compliance Update, Executive Vice Presidents are kept up to date re the state of compliance. An aggregate overview is reported to the Group Audit Committee on a quarterly basis.

Cryptic Results

Although no sanctions have been imposed as a result of non-compliance with any international declaration, convention, and/or treaty, nor have cases been brought against the Group through the use of international dispute mechanisms or national dispute mechanisms supervised by government authorities, the below penalties, sanctions and/or fines were recorded in the operating countries:

Group-wide, 52 regulator findings have been reported and 20 penalties, sanctions and/or fines, totalling USD31.3m.

Labour and Management Relations

This covers Gold Fields consultative practices with employees and their representatives, including our approach to communicating significant operational changes. Gold Fields’ approach to consultation is aligned to international norms and standards. We have a large unionized workforce in South Africa, with smaller unionisation in Peru and very small pockets of unionised employees in Australia. Collective bargaining therefore plays an important role in our consultation practices.

Approach details

• Gold Fields recognises employee’s right to freedom of association and employees are therefore free to join a union of their choice
• Gold Fields has policies in place to recognize and engage with organised labour once a certain threshold is achieved in membership
• Interactions with organised labour is through formal and informal decision making forums depending on the decision required
• We consider organised labour as a key stakeholder in our business as they form part of decisions around the safety and health of our employees
• Consultation practices are in place to ensure that we engage employees before making specific decisions, particularly if they include substantial operational changes
• Meaningful consultation includes the timely provision of all information needed to make an informed decision by employees or their representatives. In the case of any potential restructuring Gold Fields makes every effort to explain to the affected parties the impact of the changes, and give an opportunity to jointly find alternative solutions to avoid or mitigate any potential negative impacts. This engagement is done in order to ensure good employee relations and a positive work climate. It also supports our social licence to operate
• Tracking and monitoring any potential strikes or lockouts by employees

Approach purpose

• Fair and transparent process of engagement to ensure the needs of organised labour are considered and addressed
• Ensure facilitation of resolution of key business issues jointly between management and organised labour where required
• Recognition of shop stewards or representatives of organised labour on our operations
• Facilitating a structured engagement approach to ensure that all issues raised are dealt with in a timely and professional manner
• Engagement with employees to advise on Group/Region strategy and performance

Mechanisms

• Formal engagement forums some of which are mandated by legislation
• Formal processes by which to lodge and address grievances and issues with management and the organisation
• Formal processes and procedures for negotiating wages (collective bargaining)

During 2016 the Group reviewed and updated the Code of Ethics, and launched a revised Code of Conduct (the Code) in 12/2016. The Code applies to all directors, employees (all categories) and third parties, and the nature and extent of the design is to cover all business and operational activities in the Group's end-to-end value chain.

The Code was approved by the Board and each board member, Exco member and employee, has signed an acceptance declaration to commit to embedding the intent, principles and requirements of the CoC in everyday business and, more importantly, in terms of how business is conducted, and how we engage with all our stakeholders, internally and externally. During 2019, business also commenced with a process to require third parties to sign a Certification, denoting their commitment to adhere to the principles of the Code.

In addition, a Group Policy Register is published on the Group's interactive Group Governance and Compliance Portal. This Register records all the Group, regional and operation specific policies, statements, and frameworks across all the portfolios, and facilitates the alignment between these three policy levels, thus ensuring Group policy principles prevail.

Approach purpose

• Inclusivity.
• Recording and trend analysis of filed declarations, required in terms of the Code.
• Conduct and ethical behaviour awareness and attestation across the Group.
• Alignment of the Code it related internal requirements recorded in Policy.

Mechanisms

Training

Internally

• All Board and Exco members have received a personalised copy of the Code, prior to the completion of their acceptance and commitment declarations.
• A Group-wide eLearning training programme was launched in 12/2017. Following a review of the programme and its content, amendments were made, and an updated eLearning programme will be launched in 2022 for completion by all new employees.
• In addition, high-risk exposure portfolios, i.e. finance, procurement, stakeholder engagement, etc. have received more in-depth training, with a specific focus on anti-bribery and corruption, as a defined element of the Code.
• As part of the eLearning programme, there is a defined focus on corruption and bribery. In addition to the programme, anti-corruption training, under the ambit of and within the outline of key identified legal framework across the world, i.e. the Foreign Corrupt Practices Act (“FCPA”), has been initiated at senior levels of management, defined portfolios (i.e. finance, procurement, community relations, etc.). FCPA-training has been completed for all D band job levels and above, as well as for Board and the Executive Committee.
• Although the requirements of the Code of Conduct and the ABC Policy are made applicable to contractors and suppliers, given the nature, extent and location, formal training sessions are not conducted. They are, however, furnished with a copy of the Code of Conduct, are required to sign the Group's Suppliers' Code of Conduct Certification and via the normal contractual management cycle, contract managers ensure awareness of the Code of Conduct.

Externally

• Although the requirements of the Code of Conduct and the ABC Policy are made applicable to contractors and suppliers, given the nature, extent and location, formal training sessions are not conducted. They are, however, furnished with a copy of the Code of Conduct, and are required to sign the Group's Suppliers' Code of Conduct Certification and via the normal contractual management cycle, contract managers ensure awareness of the Code of Conduct.
• A contractual requirement to adhere to the values and principles of the Code is included in all the agreements with third parties.

Solutions

• Implementation of a Group Whistle-blowing Policy.
• An Interpretational Decision Tree re the application of key Code requirements, scoped and designed for the in-country legal teams to facilitate application, interpretation and professional guidance, is maintained.
• A Code of Conduct Gateway is scoped, designed and implemented to act as a centre of excellence for employees to further contextualise the Code and its application.
• A data analytic tool enables management and other internal stakeholders to unpack identified trends and enhance the interpretation and application value of the Code's requirements. The analysis outcome is also reported to the Audit Committee on a quarterly basis.
• A structured Internal Audit review is conducted on an annual basis.

Advice & Guidance

• Gold Fields has specific procedures in place to deal with any actual or potential corruption incident. Any employee found to involved in corruption is managed through the Gold Fields disciplinary policies in the regions and if found guilty, disciplinary action is taken which could result in dismissal.
• International and local external legal counsel are consulted for sound boarding and guidance purposes, where required.
• The in-country legal teams take responsibility and are the regional custodians of the Code. They are thus the first port of call regarding advice. Significant matters are escalated to the Executive Vice-President: Group Head of Legal and Compliance. Note that a defined escalation and approval framework forms part of the Code.
• Re escalation, internal and external issues, depending on their severity, can also be escalated through the management structures, as defined in the Code. In addition, concerns about unethical and/or unlawful behaviour by external stakeholders may be raised through interactions between them and our operational procurement and contract management teams.
• The referenced Interpretational Decision Tree serves a guidance tool purpose for dealing with stakeholder enquiries. In addition, the ample real life business examples offer excellent guidance re stakeholders with questions.
• Meta data analysis is conducted on a monthly basis per operating jurisdictions to determine trends and enhance the interpretation and application value of the Code, during the furnishing of advice and guidance. Also, annual and where necessary, ad hoc reviews are conducted by Internal Audit and the Group Compliance Office.
• With reference to anti-corruption, the Group is involved in presentations on anti-corruption legislation with mining industry bodies, together with invited guests from government.

Reporting

• The Code enables the reporting of concerns about unethical or unlawful behaviour, and organisational integrity via an array of reporting channels. The most prominent avenues are the certified tip-offs line (External Whistleblowing Hotline Service Provider Standard EO1.1.1 ), escalation to management and the Whistle-blowing Policy procedure. Re the tip-offs line, internal and external stakeholders have access to this line, which is independently operated and managed by an external entity. The line is operated in English and Spanish for the operating activities in Peru and Chile. Confidentiality is guaranteed and the investigation process are recorded and approved by the Audit Committee. In addition, stakeholders are constantly reminded via email, flyers and posters that any concern can be recorded anonymously.
• Via a monthly Compliance Update, Executive Vice Presidents are kept up to date re the outcome of the trend analysis exercise per country, as well as concerns raised by the Group Compliance Office. An aggregate overview is reported to the Group Audit Committee on a quarterly basis.

Gold Fields recognises its responsibility to secure its people and assets. This requires particular attention in higher-risk operating environments, areas of relatively weak governance and areas affected by illegal mining.

Furthermore, as a producer of an inherently high-value and easily transportable product, there are obvious risks around the transfer of gold between our mining operations and the refineries where it is processed.

Nonetheless, professional and effective security provision (particularly where this involves the actual or potential use of physical force) should not compromise the human rights of others.

Primary security at our operations is provided through the Company’s protection services department and private contracted service providers.

All security personnel receive human rights training during induction based on local legal requirements as well as national and international human rights best practice.

An assessment was carried out in 2017 of gaps between Gold Fields’ current practices and the requirements of the Voluntary Principles on Security and Human Rights (VPSHR).

No material risks were identified, however, the identified gaps were closed out during 2018.

Alignment to the VPSHR continued to be monitored during 2019., including undertaking a review of the West Africa region’s progress by the Americas region and corporate Sustainable Development. It served also as an opportunity to share learnings, experiences and good practices between the two regions.