Non-Conformance Handling Policy

Non-Conformance Handling Policy

Purpose

The purpose of this policy is to ensure that all non-conformances (NCs) identified across operations, safety, quality, environmental, or compliance areas are effectively reported, investigated, and resolved to prevent recurrence and maintain operational excellence.

Scope

This policy applies to all departments, personnel, contractors, and suppliers at Mototolo Platinum Mine, and includes all activities where compliance with policies, procedures, standards, and legal requirements must be maintained.

Definition of Non-Conformance

A non-conformance refers to any deviation from:

• Approved operational procedures or safety protocols

• Regulatory, legal, or industry standards

• Internal quality and HSE requirements

• Customer or contractual specifications

Examples of Non-Conformance

• Use of incorrect materials or fuel grade (e.g., non-50PPM diesel)

• Failure to follow PPE requirements or safety signage

• Put

• Incomplete or falsified documentation (e.g., CoA/CoQ)

• Approximately

Responsibilities

• All Employees: Must report NCs immediately upon discovery.

• Supervisors/Managers: Responsible for documenting, escalating, and initiating containment actions.

• Quality, Safety & Compliance Teams: Lead investigations, root cause analysis, and corrective/preventive actions (CAPA).

• Vendors/Suppliers: Must comply with corrective action requests and demonstrate preventive measures.

Non-Conformance Handling Procedure

1. Detection & Reporting

   • NCs are reported using a standard Non-Conformance Report (NCR) form.

   • Reports must include date, description, location, individuals involved, and immediate risks.

2. Contingent name

   • Immediate actions are taken to isolate or stop the issue from progressing or impacting other operations.

3. Investigation & Root Cause Analysis

   • Conducted by responsible department with support from Compliance or HSE Teams.

   • Tools such as 5-Whys or Fishbone Diagrams may be used.

4. Corrective Action

   • Action plan established with timelines, responsibilities, and resource allocation.

   • Implemented and documented in NCR log.

5. Verification & Closure

   • Follow-up audits or checks to ensure effectiveness of the corrective action.

   • NCR officially closed with approval from Quality/Compliance Manager.

6. Recording & Review

   • All NCs logged and tracked for trend analysis and management review.

   • Repeated NCs may trigger escalated disciplinary or vendor suspension procedures.

Escalation Criteria

• Minor NCs: Isolated incidents with minimal risk—handled at departmental level.

• Major NCs: Repeated or high-risk deviations—reported to the General Manager and Valterra Platinum Compliance Office.

• Critical NCs: Incidents involving safety violations, environmental harm, or regulatory breaches—require immediate executive intervention and possible external reporting.

Policy Enforcement

Failure to report or address NCs may result in:

• Disciplinary action (employees)

• Suspension or termination of contract (suppliers)

• Regulatory penalties (if unreported breaches occur)