Integrated Annual Review 2012 Annual Financial Report 2012 Mineral Resources and Mineral Reserves Regional overview  

7.3.1 Compliance

We will not engage in any activities that undermine the legitimate business environment in any form – including bribery and corruption.

All of our directors and employees are bound to adhere to our updated Code of Ethics (p58). The Group-wide rollout of the Code – including formal training sessions – was completed in 2012, to ensure common ethical standards across all of our regions. The Code articulates Gold Fields policy with respect to an array of issues – ranging from facilitation payments through to political contributions. It is binding on every employee, officer and director of any entity that is owned or controlled by Gold Fields.

Stamping gold at the Rand Refinery, South Africa

The Code is supported by an implementation framework, with defined responsibilities and reporting processes – as well as an anonymous whistle-blowing hotline managed by Deloitte. Any breach of the Code will result in disciplinary action, which may lead to dismissal. Should the breach be criminal, we will pursue prosecution of the employee concerned.

Since the Code was launched, we have experienced a marked increase in proactive queries from employees to ensure that their proposed course of action is compliant with its terms – reflecting heightened awareness of the need to apply strong ethical standards. Training on the Code will take place on an annual basis, with plans for additional, targeted training for those in high-risk roles.

Online ethics_24102011/coe_english.pdf