In 2005, AngloGold Ashanti’s Executive Committee adopted a policy on dealing with conflict’s of interest at work and implemented guidelines for employees on how to manage conflicts if and when they arise. This policy was revised, reviewed and approved by Exco on 18 April 2006 and significant changes include: introducing a threshold value in which an employee, or an associated person, has an interest in an entity that does business with the company and the addition of a ‘reasonableness’ standard when not certain of the interest the employee may hold indirectly through mutual funds or where the employee was uncertain of the interest held by close friends and family.
The policy was communicated via a formal briefing to all relevant employees and is part of the induction of all new employees, who are in turn required to complete and return declaration forms. Where an employee discloses a conflict of interest, then management is required to take steps to ensure that the company’s interests are not brought into question as a result of the conflict, by ensuring that the employee has played or plays no part in a decision whether to do business with that entity.
The categories of employees required to disclose conflicts of interest are:
Says Bobby Barua, Compliance Manager at AngloGold Ashanti, based in Johannesburg, “The policy has been adopted by AngloGold Ashanti in accordance with sound corporate governance principles and to facilitate the commercial transactions of the company in a manner that ensures and supports the integrity and fairness of the company’s contract and tender processes. As such, the policy applies to temporary, part-time and full-time employees, who have either actual, potential or perceived conflicts of interest between their personal interest and the interests of the company. The policy is applicable globally. The policy not only protects the company’s interests but also serves the interests of employees by ensuring that their interests remain open and transparent to the company.”
In 2007, three of the most significant conflicts of interest were self-declared by employees:
Concludes Barua, “We are trying to create a situation where employees become aware of potential conflicts of interest and declare them so that the appropriate action can be taken in advance of any actual conflict of interest arising”.
AngloGold Ashanti Annual Report 2007 – Report to Society