LETTER OF RECOMMITMENT TO THE TEN PRINCIPLES OF THE UNGC

I am pleased to confirm that Tongaat Hulett Limited supports the Ten Principles of the United Nations Global Compact (UNGC) on human rights, labour, environment and anti-corruption. With this communication, we express our intent to demonstrate the implementation of these principles. We are committed to making the UN Global Compact and its principles part of the strategy, culture and day-to-day operations of our Company, and to engaging in collaborative projects which advance the broader development goals of the United Nations, particularly the Sustainable Development Goals. Tongaat Hulett Limited will make a clear statement of this commitment to our stakeholders and the public in general.

We recognize that a key requirement for participation in the UN Global Compact is the annual submission of a Communication on Progress (COP) that describes our Company’s efforts to implement the Ten Principles. We support public accountability and transparency, and therefore commit to report on progress within one year of joining the UN Global Compact, and annually thereafter according to the UN Global Compact COP policy. This includes:
• A statement signed by the Chief Executive Officer expressing continued support for the UN Global Compact and renewing our ongoing commitment to the initiative and its principles. This is separate from our initial letter of commitment to join the UN Global Compact.

A description of practical actions (i.e., disclosure of any relevant policies, procedures, activities) that the Company has taken (or plans to undertake) to implement the UN Global Compact principles in each of the four issue areas (human rights, labour, environment, anti-corruption).
• A measurement of outcomes (i.e., the degree to which targets/performance indicators were met, or other qualitative or quantitative measurements of results).

Sincerely yours,

Gavin Hudson
Chief Executive Officer

Written company policy on respecting Human Rights and preventing potential abuses (e.g. in code of conduct)

1. Management responsible for day to day observation of human rights compliance in all activities and continual assessment for opportunities to improve processes in order to prevent human rights risks to people within the business and value chain.
2. Awareness with employees, contractors and service providers.
3. Where relevant the company will conduct awareness and communication campaigns.
4. Employees, contractors and service providers are encouraged to report
any suspected violations of the policy by the company, its representatives or suppliers and service providers to the relevant
executives or senior managers or anonymously through tongaat@tipoffs.com or make a free call to 0800212187
5. The company undertakes to provide for and cooperate in reasonable,
fair and/or equitable remediation where adverse human rights impacts
have been caused by or resulted from its business activities.

Specific progress made in the area of Human Rights in the past reporting period
Investigations, legal cases, rulings, fines and other relevant events related to Human Rights
Periodic review of results by senior management
External audits of Human Rights performance by customers (SMETA audits)

1.Written company policies against employment discrimination
2.Assessment of labour-related risks in the industry sector and country(ies) of operations
3.Collective Bargaining Agreements relevant to the SA context

1.Anonymous tip off line/call center and grievance procedure
2.Awareness raising or training for employees on labour rights and policies
3.Health and safety induction, supply of protective equipment, training, awareness on topics via talks, management walkabout, she committees, ISO 45001 certification, commitment via SHE policies
4.Employment equity policy in place
5.Consultation with employees and other stakeholders: employees have freedom to associate with union of choice and they are allowed on site. Management has Union engagements and consultations as per local laws
6.Human resource policies and procedures supporting the Labour principles- procedures in place

1.Management has records of employment per age,gender, etc
2.Incidents of labour principle violations are reported via anonymous tip off lines and investigated
3.Investigations are resourced according to complexity of the case, insourcing or outsourcing are options available for case managers (HR-reported on iste or Corporate office-reported via call centre)
4.Periodic reviews are conducted

1.Assessment of the environmental footprint and impact of the company in scope 1, 2 and development stages of inclusion of stage 3 (medium to long term plan)
2.Written company policies on environmental issues- Environmental policy is part of the ISO 14001 certification, in addition there are site specific policies aligned to the Corporate policy, there are climate change policies, and sustainability frame work that has strategic environmental objectives until 2025,
3. Policies commit to comply with legal compliance plans, and setting environmental management plans to minimize environmental risks
3.The supplier code of conduct includes environmental compliance
4.Describe specific goals in the area of environmental protection for the upcoming year: TH has targets related to water, energy intensity efficiencies and pollution prevention plans where required by government

1.ISO 14001 certification used to identify, manage and control risks
2.Awareness raising or training of employees on environmental protection and impact of our aspects on the environment
3.Inclusion of employees when conducting risk assessments
4.Initiatives and programmes to reduce water and consumption of resources and recycling of waste materials
5.Embarking on Science Based Targets for energy efficiency maximization
6.Use of internal communication tools to communicate impact of our environmental footprint of products or services
7.Responsibility allocated to the Heads of departments and support resources in form of SHE Managers/country Business Assurance Managers and Business 8.Assurance Manager with SHES Executive and team

1.Incidents reported and investigated on site and then reported according to severity to corporate office, serious incidents reported immediately (Level 2 and 3), Level 1 incidents reported to the SD Toolkit system on a monthly report to the Corporate office
2.Legal compliance matters reported to corporate office and socio - ethics committee and to the corporate risk compliance office
3. Investment in infrastructure to rectify identified areas e.g desludging of sewerage ponds
4. ISO 14001 calls for periodic review of results by senior management of environmental performance, in addition sites have quarterly OPCO meetings where non -compliance are discussed
5. External audits of environmental performance are conducted as part of the ISO 14001, and by the legal advisor that conducts audits on behalf of TH

1. There is a written ant-bribery & corruption policy that includes risk identification and management
2. The company also has a detailed anti-fraud & corruption policy and response plan that details how to manage (investigate and report) cases.
3.. Incidents and suspected cases are reported via the anonymous toll free call centre or email
4. Investigations are followed up with the assistance of various resources such as internal resources from the dedicated forensic team, or outsource experts
5. The company's stance on anti-corruption forms part of the supplier ethics code and is also available on the company website

1. Policies puts responsibility on every employee to report suspicious cases, management roles and responsibilities are also stipulated in the policies
2. Anonymous tip off toll free line/call center or grievance procedures
3. The policy calls for all investigations into the allegations of bribery and corruption to be appropriately resourced with skilled individuals.

1. The company policies have a dual reporting process, internally and to the local police
2. Internal audits are held annually and systems are evaluated for conformance to company policies.
3.A quarterly report is generated by the Head of Forensics on the status of all investigations which is submitted to the Chief Audit Executive.
4. External audits also evaluate adequacy of internal systems to manage the potential risks