Exxaro Resources Limited
Environmental, social and governance report for the year ended 31 December 2024 

Upholding and respecting human rights

The mining industry faces increasing scrutiny for its role in resource extraction, climate change and impacts on indigenous peoples. By upholding human rights through robust policies, legal compliance, stakeholder engagement and contributions to community wellbeing, Exxaro supports a fairer, more equitable society while safeguarding our social licence to operate and ensuring mutual long-term success.

  Why this matters Our response
Honouring human rights Respecting the fundamental and universal human rights and freedoms of every person is a key aspect of corporate social responsibility.

We champion fundamental human rights, including the basic freedoms of dignity, fairness, equality and respect for our employees, communities and other stakeholders.

Partnering for sustainable community development

Employees, communities and suppliers

We ensure human rights are respected across all our stakeholder groups by driving responsible business practices across our organisation and supply chain. We address all human rights concerns related to our business and respond promptly to grievances.

Government and regulators

Engagements with the DMRE, DoH and DoE ensure compliance with the regulations that protect community and worker rights.

Industry alliances

Through the Minerals Council, we work with industry peers to promote responsible practices and address key human rights concerns within the mining sector.

Global frameworks

As a signatory of the UNGC, we align our practices with universal human rights principles and leverage the framework to guide responsible business conduct.

Research and education institutions

Collaborations with universities support research and innovative projects that empower communities and protect their natural resources.

Showcasing respect for human rights in action

Access to clean water, education and economic opportunities are fundamental human rights that drive sustainable community development.

At Tshikondeni, Exxaro engaged extensively with the community to identify priority needs, ensuring that its initiatives deliver meaningful and lasting impact. Through this process, the focus shifted from the initial plan for an ESD and skills development centre to addressing a more urgent need for potable water, alongside skills development and agricultural support.

To meet the community's immediate water needs, Exxaro launched a sand water extraction project, breaking ground in January 2025. At the same time, recognising the importance of skills development in the area, we funded an NPO computer literacy programme for school children and unemployed youth. Additionally, eight local farmers received support through infrastructure, agricultural training and market access facilitation in partnership with Tiger Brands.

These initiatives empower communities, enhance livelihoods and uphold the fundamental right to sustainable resources.

Our human rights management approach at a glance

We are committed to respecting and protecting the human rights of people, in line with our purpose.

Exxaro's human rights policy supports the objectives of our Sustainable Growth and Impact, Social Impact and DEI strategies and our management approach ensures:

Accountability and responsibility

The SERC oversees the group's activities and output as a responsible corporate citizen, including the protection of human rights, on behalf of the board. The RBR committee is responsible for risk and compliance oversight, while the remuneration committee focuses on fair and responsible remuneration within the group. The executive committee ensures the implementation of our human rights policy.

Regulatory compliance

At a minimum, we uphold the human rights set out in legislation, including the South African Constitution, the BCEA and the Labour Relations Act.

Beyond compliance

We align our processes with the following guidance:

  • The Minerals Council South Africa's Human Rights Framework, which outlines management practices for South African mining companies
  • The UN Guiding Principles on Business and Human Rights
  • The International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work, which guides us in upholding basic human values
  • The Organisation for Economic Co‑operation and Development (OECD) Guidelines for Multinational Enterprises, which set standards for responsible business conduct
  • The UNGC principles, addressing human rights, labour, environmental and anti-corruption standards

Recognising that potential for adverse human rights impacts, we are committed to conduct regular due diligence reviews to identify, prevent and mitigate such risks across our operations. This process assesses actual and potential human rights impacts, integrates and acts upon findings, tracks responses and communicates how impacts are addressed.

We are committed to:
Preventing discrimination, harassment and racism
Regularly reviewing our human rights processes and policies
Providing secure whistleblower channels through our fraud and ethics hotline
Encouraging open and honest communication between employees and supervisors
CENNERGI

Cennergi ensures human rights considerations are adequately managed and addressed through human resources policies and a code of conduct and grievance procedure aligned with South African human rights legislation.

Cennergi is also committed to the IFC's Performance Standard 2 on labour and working conditions, which requires companies to treat their workers fairly, provide safe and healthy working conditions, avoid using child or forced labour and identify related risks in their primary supply chain.

Employees can report human rights violations to supervisors, line managers, the people and performance department or anonymously through Exxaro's fraud and ethics hotline.

Volunteerism initiatives

Our employees actively participate in social responsibility initiatives. We have established food gardens in schools and, to ensure sustainability, provided training to employees. Furthermore, through our PIT symposium, a fundraising concert raised R21 000 for the Zodwa School for children living with disabilities. This amount was matched by Exxaro, resulting in a total donation of R100 000.

Prevention and mitigation

We address key human rights issues in the following areas:

Governance and ethics

Our board oversees the management of reputational impacts across the following dimensions:

  • Economic: ensuring economic transformation while preventing, detecting and responding to fraud and corruption
  • Social: protecting public health and safety, consumer rights and community development, alongside universal human rights
  • Environmental: safeguarding the natural environment
  • Governance: ensuring Exxaro remains ethical and compliant

We prioritise human rights protection throughout our value chain, favouring contractors and suppliers that align with our values as outlined in our supplier code of conduct. Ethics awareness is promoted through our Mining with Morals theme, a strategic initiative that shapes our ethical culture, mitigates ethical risks and protects Exxaro's reputation.

Fraud and ethics hotline

Equal opportunities/ non-discrimination and transformation

Our DEI strategy protects employees' human rights by preventing discrimination, harassment and racism. It aligns with the South African Constitution and other national legislation, the National Gender Policy Framework and the UN Convention on the Elimination of all Forms of Discrimination against Women. We provide training for leaders and employees on critical topics such as gender equity and identity, LGBTQIA+ inclusion, racial equity, disability competence and creating an inclusive culture.

Our DEI strategy

Human rights in the workplace

Exxaro strictly prohibits forced or compulsory labour and does not employ individuals under the legal minimum age of 18, adhering to ILO conventions on child labour. We support legitimate workplace apprenticeships, internships and similar initiatives in full compliance with applicable laws. To safeguard employees' physical and mental health, we enforce reasonable working hours, leave and holidays, aligned with ILO conventions. Disciplinary and grievance mechanisms are transparent and ensure fair treatment when required.

Maintaining sound employee relations

Security

Our response to protest actions is guided by the Regulation of Gatherings Act, 1993 (Act 205 of 1993), stakeholder management policy, human rights policy and our security strategy, which aligns with the Voluntary Principles on Security and Human Rights. To uphold human rights in security practices, we conduct ongoing training that includes induction programmes, security personal training and refresher courses to ensure employees and security teams are equipped with an understanding of human rights principles and our stance against discrimination.

Freedom of association and the right to collective bargaining

We respect the right of employees to form or join labour unions without fear of reprisal, intimidation or harassment. We foster constructive dialogue with legally recognised union representatives freely chosen by our employees. We engage in good faith with these representatives to build trust and maintain positive labour relations.

Maintaining sound employee relations

Safety and health in the work environment

We uphold the highest safety standards and strive for zero harm in all workplaces through rigorous management systems, protocols and dedicated safety programmes at each operation.

Environmental management and conservation

To safeguard the environment and support community resilience, we prioritise early mine closure planning and rehabilitation throughout the lifecycle of operations. Our mineral succession planning programme addresses mine closure impacts by supporting black emerging farmers with access to resources that enable them to commercialise their businesses. The programme ensures a positive legacy through secondary economic activities in areas where Exxaro (previously Kumba and Iscor) has operated mines. Support focuses on funding, market access, inputs, machinery and training for sustainability. This approach aligns with our commitments to responsible mining, decarbonisation and climate change mitigation.

Integrating mine closure and rehabilitation

Respect for all communities

Communities have a fundamental right to access quality water, affordable electricity and protection from noise, air pollution and hazardous materials. As a responsible corporate citizen, we uphold the cultural values of local communities, including traditional authorities in host communities. Our efforts focus on advancing self-sufficiency, sustainability and protecting health, safety and the natural environment. When resettlement is necessary, we follow the DMRE's mine community resettlement guidelines. For non-mining-related resettlements, we are guided by the IFC's Performance Standard 5 and the Minerals Council's Human Rights Framework to ensure ethical and equitable practices.

Building sustainable communities

Children's rights

Exxaro believes that every child has the right to access education and be treated in a manner that considers their age. Our 2024 social investment strategy prioritised human capital development, focusing on ECD, whole school development, skills development, and agricultural and entrepreneurial skills. Our ECD programmes are designed to ensure children are school-ready and have the opportunity to thrive. Recognising the importance of quality education beyond early childhood, Exxaro, also through our Grootegeluk and Matla SLPs, committed to improving school infrastructure. These infrastructure projects, identified through stakeholder engagement, create conducive learning environments for students and teachers, promoting equal access to education.

Monitoring, measuring and reporting

In 2024, the strategic resilience and governance function completed an internal due diligence analysis to reinforce alignment with Exxaro's Sustainable Growth and Impact strategy.

The analysis focused on:

  • Evaluating our governance processes, policies and operating practices for compliance with national regulations and international standards, accompanied by actionable recommendations
  • Identifying and assessing actual and potential human rights impacts and risks across operations and communities
  • Ensuring alignment with the United Nations Guiding Principles on Business and Human Rights and the FTSE Russell indicators on human rights, while promoting positive relationships with host communities

The analysis highlighted several strengths, including Exxaro's human rights policy, which aligns with both local industry standards and international best practice. Key highlights included:

  • Conducting annual independent compliance audits at all operations, covering environmental management, water use, air quality, SLPs, health and safety, with oversight from the combined assurance forum
  • Subscription to the Minerals Council South Africa's human rights framework, reinforcing industry best practice, including respect for all communities and supply chain responsibility
  • Robust governance structures, including board policy approval, oversight by two board committees and an internal escalation process for complaints received from the South African Human Rights Commission

The findings, consisting mainly of process improvements, were presented to the SERC on 22 October 2024 and incorporated into ongoing governance processes to enhance accountability and reinforce our commitment to honouring human rights.

How we performed

      2024 2023 2022
Human rights grievances lodged against Exxaro     None None None
Employees participating in DEI courses such as workplace harassment and diversity and inclusion     136 196 None
Fraud and ethics allegations reported     252 191 213
Allegations reported via the fraud and ethics hotline     220 164 186
Percentage of allegations resulting in disciplinary inquiries     4% 23% 20%
Disciplinary hearings concluded     5 22 42
Cases brought before the Council of Conciliation, Mediation and Arbitration (CCMA)     4 2 None

Of the five disciplinary hearings concluded in 2024, four ended with a verdict of guilty (2023: 19), while one resulted in a not-guilty verdict (2023: one).

With regard to CCMA cases, the Commissioner decided in favour of Exxaro twice (2023: once) and there was no instance where the matter was resolved through a mutual agreement (2023: once). Two other matters lodged with the CCMA in 2024 are still outstanding.

Improving our performance

The due diligence conducted identified process improvements and operational challenges requiring management action. Key areas for improvement include:

  • Aligning policies with Exxaro's new organisational structure, following the 2023/2024 operational effectiveness process
  • Developing a formal communication plan to ensure all stakeholders, including suppliers, fully understand Exxaro's human rights commitments and grievance procedures
  • Enhancing the supplier code of conduct to formalise and align grievance mechanisms across all operations

In addition, a recommendation was made to expand Exxaro's policy commitment on child labour to include broader children's rights, aligning with our Sustainable Growth and Impact strategy.

These enhancements will strengthen Exxaro's human rights management approach, ensuring compliance, transparency and meaningful engagement with all stakeholders.

Our primary focus in 2025 will be:

  • Ensuring that our human rights processes are aligned to the UNGC on Human Rights, meet legal requirements and promote positive community relations
  • To continue addressing the fundamental human rights issues in our communities, such as access to potable clean water, good quality education and decent work