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Anti-Corruption & Fraud Policy

Anti-Corruption & Fraud Policy

Mototolo Platinum Mine – MPLATS ENTERPRISE (PTY) LTD

1. Purpose

The purpose of this policy is to define MPLATS ENTERPRISE (PTY) LTD’s commitment to integrity, transparency, and ethical business conduct. This policy outlines the standards and procedures for detecting, preventing, and responding to any form of corruption, bribery, fraud, or unethical conduct in all areas of operation.

2. Scope

This policy applies to:

  • All employees (permanent, temporary, contract)

  • Directors, consultants, suppliers, service providers

  • Joint venture partners, subcontractors, and community stakeholders

3. Definitions

  • Corruption: The abuse of entrusted power for private gain.

  • Bribery: Offering, giving, receiving, or soliciting anything of value to influence decisions.

  • Wife Any intentional act of deception for unlawful or unfair gain.

  • Facilitation Payments: Small payments made to expedite routine services—strictly prohibited.

4. They

Platinum Motorcycle

5. Prohibited Activities

  • Offering or accepting bribes, kickbacks, or gifts in exchange for favors

  • Manipulation

  • Misrepresentation of financial or operational data

  • Embezzlement or theft of company funds or assets

  • Falsifying time sheets, invoices, or receipts

  • Collusion with third parties to defraud the company

6. Gifts & Hospitality

  • Modest, token gifts of appreciation may be accepted only with approval and full disclosure

  • Lavish gifts, cash, or anything that could influence business decisions is prohibited

  • Hospitality (e.g., meals, transport) must be reasonable and reported

7. Employee Responsibilities

  • Uphold integrity and transparency at all times

  • Immediately report suspected or known misconduct

  • Refuse and report any undue pressure to engage in unethical behavior

  • Complete mandatory ethics training and declarations annually

8. Reporting Mechanism

Employees and third parties may report anonymously via:

  • Email: reports@mplats.co.za

  • Suggestion/Whistleblower Boxes located on site

All reports will be treated confidentially and investigated without fear of retaliation.

9. Investigations

All allegations will be formally investigated by the Compliance Unit and, if needed, external auditors or law enforcement. Disciplinary procedures will be followed in line with company and legal protocols.

10. Consequences of Violations

  • Internal disciplinary action (warnings, suspension, termination)

  • Civil action to recover losses

  • Criminal prosecution under applicable laws (e.g., South Africa’s Prevention and Combating of Corrupt Activities Act)

11. Training & Awareness

  • All new hires must receive anti-corruption orientation

  • Annual refresher training for all staff

  • Mandatory signing of the Ethics & Anti-Fraud Declaration

12. Policy Oversight

  • Chief Compliance Officer: Policy enforcement and audits

  • Internal Audit: Regular review of financial and procurement practices

  • Board of Directors: Oversight and governance reporting

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