Exxaro Resources limited
Environmental, social and governance report 2021

Human rights

Human rights are the basic rights and freedoms that protect us all. They are based on dignity, fairness, equality, and respect. These rights empower and enable employees to speak up and challenge unfairness within the workplace, and other stakeholders to hold Exxaro accountable for the impact of its operations should they infringe on these rights.

We uphold our licence to operate through our commitment to the South African Constitution, the 10 UNGC principles and other guiding frameworks, ensuring we respect the human rights of our employees, communities and other stakeholders.

Respecting the human rights of our workforce and those who may be affected by our operations


We recognise that our operations could negatively impact human rights. As such, we are implementing a human rights framework. We will be reviewing and updating policies to align with the UNGC guiding principles on business and human rights, and the Organisation for Economic Co-operation and Development policies, among others. We are also developing a monitoring and evaluation tool to continuously track our progress on compliance.

We are committed to:

  • Aligning our business practices and strategy with the 10 UNGC principles
  • Protecting the human rights of our people and communities
  • Complying with legal and regulatory requirements
  • Training our employees in human rights
  • Preventing discrimination, harassment and racism
  • Regularly reviewing our human rights processes and policies
  • Providing a flow of information that promotes business sustainability through the ethics hotline
  • Encouraging open and honest communication between employees and supervisors

Cennergi has human resources policies that ensure human rights considerations are adequately managed and addressed. Our approach to promoting and protecting human rights is guided by our code of conduct and grievance procedure, aligned with South African human rights legislation.

We also commit to the IFC's PS2: Labour and Working Conditions, which requires companies to treat their workers fairly, provide safe and healthy working conditions, avoid the use of child or forced labour, and identify related risks in their primary supply chain.

Should our employees feel that their human rights have been violated, they can report this to supervisors or line managers, the human resources department or anonymously through the Exxaro fraud and ethics hotline.

Accountability and responsibility

Our board is ultimately accountable for guaranteeing human rights. The executive head: human resources is responsible for implementing and overseeing human rights throughout the organisation.


We made significant progress in reviewing our human rights policies and processes during the year. We featured in the July 2021 Vigeo Eiris ranking of the 100 best emerging market performers for our approach and ongoing dedication to social responsibility. We ranked third in the Transparency and Corporate Reporting: South Africa 2020 report among 100 South African companies under scrutiny for transparency and implementation of anti-corruption programmes. Of the 26 cases of corruption reported against employees in 2021 (2020: 69), these resulted in further action such as disciplinary inquiries, registering cases with the SAPS and arrests. All disciplinary enquiries completed have returned a guilty verdict and resulted in nine cases of dismissal. One case of dismissal has been taken to the CCMA and the Commissioner ruled in Exxaro's favour.

 We also fulfilled our annual obligations as a signatory to UNGC since 2007. Our annual UNGC communication on progress is available on our website and provides further detail on topics discussed below.

Labour and human rights

Exxaro has a labour and human rights policy that documents the company's position and intent regarding the protection of the human rights of employees and people within the company's sphere of influence in the communities in which it operates.

We reviewed human rights policies to ensure alignment with the South African Constitution and compliance with labour laws

We continue observing employees' rights to freedom of association – 5 180 (76.9%) of our 6 745 employees are unionised

We comply with all International Labour Organization codes

Child and forced labour

We do not tolerate or condone child labour and forced or compulsory labour, and are aligned with the Basic Conditions of Employment Act and the South African Constitution in this regard.


Our induction programmes educate employees about human rights and our position against discrimination. We train our security personnel in human rights aspects relevant to each operation. We also conduct refresher courses that include human rights issues.

Diversity and inclusion

Our policies and structures that prevent discrimination, harassment and racism protect employees' human rights. Our diversity and inclusion strategy aligns Exxaro with the South African Constitution and other legislation, the National Gender Policy Framework and the UN Convention on the Elimination of all Forms of Discrimination against Women.

Guiding body engagement

To align and strengthen our human rights protection mechanisms, we engage with the Minerals Council, which has a guiding framework for the mining industry, and the UNGC.

Human rights framework and due diligence review

We are developing a framework to guide our approach to human rights issues, guided by the Minerals Council's proposed industry framework, drawing mainly from the UNGC guiding principles on human rights. The Minerals Council has identified seven human rights priority areas for the South African mining industry:

  • Environmental management and conservation, including climate change
  • Health and safety
  • Governance and ethics
  • Security and human rights
  • Transformation
  • Human rights in the workplace
  • Land use and resettlements

Due diligence review

To inform the framework and obtain insights on effective human rights practices, we conducted a due diligence review of our human rights performance in 2021.

The review included:

  • Consulting with the Minerals Council, UNGC and industry peers
  • Extracting indicators from the Corporate Human Rights Benchmark tool to perform an internal gap analysis
  • Engaging with internal Exxaro functional champions to assess existing policies and procedures to identify areas of opportunity and improvement

The Corporate Human Rights Benchmark assesses and ranks companies on their human rights performance in line with the UNGC's guiding principles on business and human rights. Based on Corporate Human Rights Benchmark indicators, the internal gap analysis presented an opportunity to highlight emerging good practices that could be used to address gaps in current practice.

The gap analysis involved engagements with our stakeholder affairs, sustainability, human resources, company secretary, governance and ethics, risk, supply chain, finance and tax departments. The project team extracted and allocated indicators to the different functions. Engagements with functional representatives involved deliberations on the function's level of compliance, based on the selected indicators.

We will use an independent consultant to assess the internal gap analysis. Further, rigorous community interviews will assess actual and potential human rights impacts to inform the framework design. Once the framework is complete, it will allow us to specify formal remedies to address human rights complaints and grievances.

Ethics hotline

The Exxaro ethics hotline aims to enhance an honest work ethic, and provide employees and third parties with a mechanism to bring any unethical business practices to management's attention. It is an essential line of defence, providing a flow of information that promotes business sustainability by helping to identify and rectify problems before they become more prominent, more costly or damage our reputation. The hotline operates 24 hours a day, 365 days a year. Our independent forensic department receives a regular analysis of the calls and launches objective investigations, which are tabled at regular management ethics committee meetings.


We encourage open and honest communication between employees and supervisors. Exxaro's employment contracts advise employees of their rights to lodge a grievance if they are dissatisfied, and we have a grievance procedure. Anyone who feels that their rights have been infringed has a right to lodge a grievance without fear of victimisation.

No human rights-related grievances were lodged against Exxaro in 2021.


In 2022, we aim to further define what human rights means to Exxaro in relation to our Sustainable Growth and Impact strategy, and align all company policies to be human rights-sensitive. We will also progress the design and implementation of our human rights framework.

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Appendix A: Criteria