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SPRING 2010

MINING

The revised Mining Charter 2010


The long-awaited review of the Broad-Based Socio-Economic Empowerment Charter for the South African Mining and Minerals Industry (Revised Charter) was released by the Minister on 13 September 2010. The intention behind the Revised Charter was to clarify certain ambiguities and uncertainties which existed under the original 2002 Mining Charter (2002 Charter) and to provide more specific targets than the 2002 Charter had done, the 2002 Charter having been a more policy orientated document. The second preliminary issue is the following: What is the impact However, the Revised Charter has in some instances given rise to more questions than answers. The first issue is the relationship between the 2002 Charter and the Revised Charter. Does the Revised Charter replace the 2002 Charter or must the Revised Charter be read in conjunction with the 2002 Charter? The title of the Revised Charter specifically records that it is an "Amendment of the ....(2002 Charter)" as opposed to an Amended Charter. This thinking is confirmed in the Preamble to the Revised Charter which records that "...amendments are made to the Mining of the Revised Charter on the Codes of Good Practice for the Mining Industry (Code)? The simple truth is that by and large the provisions of the Code have been ignored by stakeholders in the mining industry. Inelegant drafting and the dubious legal validity of the Code did little to promote the aims of the 2002 Charter. However, the Code remains on the statute books as delegated legislation. It has not been amended to reflect the provisions of the Revised Charter and as such is likely to continue to be ignored. If the Code has any relevance at all, it is likely to be in regard to the general principles espoused therein. It is hoped that the Code Charter of 2002 in order to streamline and expedite attainment of its objectives." These statements indicate that it would be necessary to consider the 2002 Charter and the Revised Charter together in order to ascertain one's obligations. However, a comparative review of the Revised Charter and the 2002 Charter leaves one in little doubt that the Revised Charter was in fact intended to replace the 2002 Charter and not merely to amend same.

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will be wholly re-written in due course to be, in fact, a proper code of good practice in accordance with international standards.

There are however a number of aspects to the Revised Charter which we believe may inhibit deal-making within this sector. These aspects include:

The third preliminary issue is: To what extent is the Revised Charter a product of the consensual agreements recorded in the Stakeholders' Declaration on Strategy for the Sustainable Growth and Meaningful Transformation of South Africa's Mining Industry which was signed on 30 June 2010 by the Department of Mineral Resources, National Union of Mine Workers, Solidarity, UASA - The Union, the South African Mineral Development Association and the Chamber of Mines of South Africa (Declaration). In answer to this question, we include in this comparative analysis a summary of the most pertinent aspects of the Declaration. What is apparent from this comparison is the fact that while the Department of Mineral Resources seeks the co-operation of stakeholders, it is not averse to adopting a coercive stance when it comes to empowerment within the mining industry. * BEE beneficiaries are required to have full shareholder rights. This may conflict with the Companies Act in certain deal structures as a company can only issue shares that are fully paid up and this may also limit structuring flexibility. Possibly one of the biggest surprises was the fact that the Revised Charter, despite the consensual nature of the Declaration, seemingly provides that non-compliance with the provisions of the Revised Charter will amount to a breach of the MPRDA that may result in the suspension or cancellation of a holder's prospecting or mining rights under section 47. Added to this is the fact that the Minister will have the power to amend the 2002 Charter without consultation and will therefore have a wide discretion to impose more onerous obligations on the industry in the future. Not only does this perpetuate regulatory uncertainty in the South African mining industry but renders it more likely that the Revised Charter, as delegated legislation, will be challenged as being unconstitutional. However, the wording of the Revised Charter stipulates that "Non compliance with the provisions of the Charter and the MPRDA shall render the mining company in breach of the MPRDA ..." . Therefore, if the holder must be in breach of both the Revised Charter and the MPRDA before the right can be revoked, then this provision would be more acceptable.
Allan Reid, Director

Deal participants will be required to engage with financiers in order to determine the percentage of cash flow to be used to service the funding of the structure and the amount to be paid to BEE beneficiaries (barring any unfavourable market conditions). There is therefore a requirement that a percentage of cash flow must be paid to the BEE Shareholder prior to finance having been repaid, thereby extending the funding term and the financier's risk. This may result in financiers being less enthusiastic to conclude BEE transactions.

We include below a summary of the most important provisions of the Revised Charter and, for comparative purposes, the corresponding provisions of the 2002 Charter, the Declaration and the Code.

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THE REVISED MINING CHARTER How does it affect you? A comparative analysis
THE REVISED CHARTER 2010 THE STAKEHOLDERS DECLARATION THE 2002 CHARTER THE CODE OF GOOD PRACTICE

OBJECTIVES
The Revised Charter
* Dealt with in Item 1 of the Revised Charter. * Seeks to (a) promote equitable access to mineral resources; (b) substantially and meaningfully expand opportunities for HDSA to enter and benefit from the mining and minerals industry; (c) utilise and expand the existing skills base for the empowerment of HDSA and to serve the community; (d) promote employment and advance the social and economic welfare of mine communities and major labour sending areas; (e) promote beneficiation; and (f) promote sustainable development and growth of the mining industry.

The Declaration
* Dealt with in Part 1 of the Declaration. * Objectives include to promote investment, enhance competitiveness, drive transformation, remove barriers to sustainable growth and transformation and commit to effective implementation strategy.

The 2002 Charter


* Dealt with in Item 3 of the 2002 Charter. * Includes empowerment, transformation and the promotion of beneficiation. No reference to competitiveness and sustainability.

The Code
* Dealt with in the Purpose of the Code. * Includes facilitation of the implementation of broad based socio-economic aspects of the 2002 Charter to give effect to section 100 (1)(b) of the MPRDA.

OWNERSHIP
The Revised Charter
* Dealt with in Item 2.1 of the Revised Charter. While HDSA ownership of 26% remains unchanged and is required to be achieved by March 2015, a new definition of HDSA has been introduced which includes the phrase "..which should be representative of the demographics of the country." Precisely what is meant by this phrase is not clear. Does this entail that a holder's HDSA participation should include all demographically represented groups or, for example, that

The Declaration
* Dealt with in Part 12 of the Declaration. * Minimum target of 26% HDSA ownership by 2014. Meaningful participation includes that BEE transactions will be concluded with clearly identified beneficiaries (BEE entrepreneurs, workers and communities).

The 2002 Charter


* Dealt with under Item 4.7 of the 2002 Charter. Provides for 2 ownership targets of 15% within 5 years and 26% within 10 years of 1 May 2004.

The Code
* Dealt with under Item 2.1 of the Code. * Requires 26% HDSA voting rights by 2014 plus 26% HDSA economic interest (on a modified flow through principle) by 2014 plus a net HDSA value of 26% by 2014. Net value defined so as to exclude value of interest still burdened by loans after 2 years.

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The Revised Charter


South African Chinese persons, although being classified as HDSAs, may not exceed 2 or 3% of a holder's HDSA grouping? Or is it a mechanism intended to limit the number of white women which can be included for HDSA purposes? The intention here is unclear. * Although the Revised Charter does contain a limited degree of flexibility as regards ownership in that it states that ownership shall vest within agreed timeframes "taking into account market conditions", the March 2015 date for achievement of 26% HDSA ownership is hard-coded. There is no applicable weighting to this criterion in the scorecard. A holder will either have met the target or will have failed to do so. * "Effective ownership" is defined as "the meaningful participation of HDSAs in the ownership, voting rights, economic interest and management control of mining companies". * Requires a minimum target of 26% "meaningful economic participation" (as defined)1 and 26% full shareholder rights for HDSA by March 2015. * The value of beneficiation, as provided for by Section 26 of the MPRDA and "elaborated in the mineral beneficiation framework", can be offset to a maximum of 11% of ownership target. * Continuing consequences of all previous deals concluded prior to 1 May 2004 can be included in calculating such credits/offsets in terms of market share as measured by attributable units of production.
1

The Declaration
* Barring unfavourable market conditions, some cash-flow to service the funding structure, the remaining cash-flow to be paid to the BEE beneficiaries. * Ownership must vest within agreed time-frames of the BEE transactional structure (taking into account the prevailing market conditions). * BEE participant shall have full shareholder rights, eg full participation at annual general meetings and exercise of voting rights, regardless of legal form of instruments used.

The 2002 Charter

The Code

Incudes key attributes such as (a) BEE beneficiaries must be clearly identifiable in the form of BEE entrepreneurs, workers (including ESOPs) and communities, (b) barring unfavourable conditions, a portion of cash flow should be used to service the funding structure and a portion should flow to the BEE partner, (c) BEE partner should have full shareholder rights, full participation at AGMs, exercise of voting rights, regardless of legal form and (d) ownership should vest within time-frames, agreed with the BEE entity, taking into account market conditions.

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PROCUREMENT AND ENTERPRISE DEVELOPMENT


The Revised Charter
* Dealt with in Item 2.2 of the Revised Charter. These targets are exclusive of non-discretionary procurement spend (expenditure that cannot be influenced by a mining company, such as procurement from the public sector and public enterprises). These targets are high, given that the exact manner in which such procurement is to be measured is not clear. There is, for example, no inclusion of the measurement provisions of the Code 500 which allows procurement from certain BEE entities to be measured at 120% of procurement spend. * While the ramp up over five years is welcomed, the ability of BEE entities to supply requisite goods and services of quality at competitive prices in accordance with demand is questionable, given the specialized nature of mining. * BEE entity = entity with 25% + 1 vote of share capital owned by HDSAs under flow-through principle. * Procure a minimum of 40% of capital goods from BEE entities by March 2015 (Scorecard requires 5% by March 2011, 10% by March 2012, 20% by March 2013, 30% by March 2014 and 40% by March 2015). * Procure 70% of services from BEE entities by March 2015 (Scorecard requires 10% by March 2011, 15% by March 2012, 25% by March 2013, 40% by March 2014 and 50% by March 2015).

The Declaration
* Dealt with in Part 11 of the Declaration. * Promotes adherence to fundamental principles of enterprise development, irrespective of mining companies' turn-over; agrees to develop mechanisms for multi-national suppliers of capital goods to the mining industry to contribute towards social development. * No targets set.

The 2002 Charter


* Dealt with in Item 4.6 of the 2002 Charter. * Companies undertake to give HDSAs preferred supplier status; commit to a progression of procurement over 3 - 5 year time-frame; no specific targets set.

The Code
* Dealt with in Item 2.5 of the Code. * Establishes preferential score-card of purchasers of goods and services from BEE compliant suppliers. * Score-card requires, within a 6 - 10 year target, 30% BEE procurement spend for capital goods; 70% BEE procurement spend on services; 30% procurement spend on consumables; 20% procurement spend from local SMME's and 20% procurement spend from suppliers that are more than 50% black owned or suppliers that are more than 30% black woman owned.

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The Revised Charter


* Procure 50% of consumer goods from BEE entities by March 2015 (Scorecard requires 30% by March 2011, 40% by March 2012, 50% by March 2013, 60% by March 2014 and 70% by March 2015). * In addition, "multinational suppliers" must contribute 0.5% of procurement spend by SA mining companies to a "social development fund." Precisely what this fund is, who will benefit therefrom and who will administer this fund remains to be clarified. The weighting of this item is 3% in the mining company's scorecard, yet it is the supplier who must make this contribution, not the mining company. How then can the mining company meet its obligations and what will the position be where no procurement is made from such multinational suppliers? One fears that the mining company will merely have to lose the 3% from its scorecard.

The Declaration

The 2002 Charter

The Code

BENEFICIATION
The Revised Charter
* Dealt with in Item 2.3 of the Revised Charter. The only off-set allowed against the ownership target is that for beneficiation, to a maximum of 11%. Whilst this is to be welcomed, the entire issue of beneficiation remains somewhat clouded. The Charter refers to the "mineral beneficiation framework". This was not mentioned in the Minister's speech or, as far as we can ascertain, anywhere else. We believe that this may be a framework

The Declaration
* Dealt with in Part 5 of the Declaration. * Records the stakeholder agreement to support local beneficiation, consider establishing a national beneficiation agency, procure the support of international partners to facilitate skills and technology transfer for local beneficiation. * No targets reflected.

The 2002 Charter


* Dealt with in Item 4.8 of the 2002 Charter through general statements. * No targets set. * Allows for beneficiation off-sets against HDSA ownership commitments without details as to how this is to be achieved.

The Code
* Set a compliance target of 42% of annual production measured from the refined stage.

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The Revised Charter


to replace the long-awaited Beneficiation Bill which never saw the light of day and which has been scrapped. The entire mechanism in terms whereof beneficiation is to be measured and calculated requires urgent clarification. In addition, companies which already undertake beneficiation may be prejudiced in that the measurement for this item is the "additional production volume contributory to local value addition beyond the base-line". If a company already has a high base-line and is already beneficiating most of its product in South Africa, it may be difficult to achieve significant additional production volumes of beneficiation.

The Declaration
* "Beneficiation" is defined as the transformation of a mineral (or a combination of minerals) to a higher value product, which can either be consumed locally or exported. The term is often used interchangeably with "mineral value-addition" or "downstream beneficiation." Mining companies may offset the value of the level of beneficiation achieved by the company against a portion of its HDSA ownership requirements not exceeding 11%. Compliance target is any additional production volume of local value addition over and above the base-line. Determination is unclear. "Mineral beneficiation framework" is awaited.

The 2002 Charter

The Code

EMPLOYMENT EQUITY
The Revised Charter
* Dealt with in Item 2.4 of the Revised Charter. * By March 2015, achieve a minimum of 40% HDSA demographic representation at each of executive management (board) level and senior management (EXCO) level (Scorecard requires both levels at 20% by March 2011, 25% by March 2012, 30% by March 2013, 35% by March 2014 and 40% by March 2015), middle management level (Scorecard requires 30% by March 2011, 35% by March 2012 and 40% by March 2013), junior management level (40% by March 2011 and beyond) and core and critical skills (Scorecard requires 15% by March

The Declaration
* Dealt with in Part 8 of the Declaration. * Stakeholders undertake to create an environment to promote and encourage diversity to retain an increase of requisite skills. * Minimum target of 40% by 2014 in all of top management (board); senior management (EXCO); core and critical skills; middle management, and junior management.

The 2002 Charter


* Dealt with in Item 4.2 of the 2002 Charter. Companies to aspire to 40% HDSA participation in management within 5 years; companies to focus overseas placement and/or training programmes on HDSA's. Identification of talent pool and fast tracking and ensuring inclusiveness and advancement of woman. No measurement of management control.

The Code
* Dealt with in Items 2.2 and 2.3 of the Code. Provides management control score card in respect of board participation and 40% representivity of HDSA's on executive committee. Also provides employment equity score card requiring compliance target of 40% in top management, senior management, middle management, junior management and woman in mining (10%).

* *

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The Revised Charter


2011, 20% by March 2012, 30% by March 2013, 35% by March 2014 and 40% by March 2015). * However, each level has its own weighting. Many companies, particularly junior miners and prospecting companies, have only two of these levels, alternatively the distinction between levels is blurred. How the scorecard will affect such companies is unclear. Also, there is no indication as to what is meant by "core and critical skills" or whether "demographic representation" must be also be applied within each level. These aspects too require clarification. * In addition, existing talent pools mining companies must be identified and fast-tracked to ensure high level operational exposure in terms of career path programmes.

The Declaration

The 2002 Charter

The Code

HUMAN RESOURCE DEVELOPMENT


The Revised Charter
* Dealt with in Item 2.5 of the Revised Charter. * Invest a percentage of annual payroll (Scorecard requires 3% by March 2011, 3.5% by March 2012, 4% by March 2013, 4.5% by March 2014 and 5% by March 2015); in essential skills development activities reflective of the demographics, but excluding the mandatory skills levy, including support for South African based research and development initiatives intended to develop solutions in exploration, mining, processing, technology efficiency (energy and water use in mining), beneficiation as well as environmental conservation and rehabilitation. * Weighting very high at 25%.

The Declaration
* Dealt with in Part 7 of the Declaration. * Provides for the conduct of at least two skills audits by 2014 and assessment of institutional and organisational absorptive capacity by December 2010. * Invest an incremental percentage of annual payroll in skills development activities from 3% in 2010 to 5% in 2014. * Ensure effective spend of mandatory skills levy.

The 2002 Charter


* Dealt with by Item 4.1 of the 2002 Charter. * Provides for education, training and scholarships to up-skill HDSA employees to provide HDSA employees with skills required by the mining industry.

The Code
* Dealt with in Item 2.4 of the Code. * Provides for measurement through the score card, through a 100% compliance of skills development expenditure, learning programmes and functionally literate and numerate programmes.

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MINE COMMUNITY DEVELOPMENT


The Revised Charter
* Dealt with in Item 2.6 of the Revised Charter. * Must invest in ethnographic community consultative and collaborative processes consistent with international best practices in terms of rules of engagement and guidelines prior to the implementation/development of mining projects. * Must conduct an assessment to determine the developmental needs in collaboration with mining community development in line with IDP's, the cost of which should be proportionate to the size of the investment. * Projects will be fully detailed in mine's social and labour plan following consultation, assessment and implementation. * Scorecard compliance = upto-date project implementation, scored heavily at 15%.

The Declaration
* Dealt with in Part 9 of the Declaration. * Provides for developing guidelines and adherence to community consultation processes. * Intention to develop a partnership approach towards mine community and major labour-sending areas, development and consider regional (social) developments funds for effective implementation of social and labour plans. * Implement and monitor social labour plan undertakings.

The 2002 Charter


* Dealt with in Item 4.4 of the 2002 Charter. * Stakeholders undertake to cooperate in the formulation of integrated development plans for communities where mining takes place and for major labour-sending areas, with special emphasis on development of infrastructure.

The Code
* Dealt with in Item 2.6 of the Code. Creates target of 1% of net profit after tax to develop mine community and rural development elements.

HOUSING AND LIVING CONDITIONS


The Revised Charter
* Dealt with in Item 2.7 of the Revised Charter. * Convert or upgrade all hostels into family units by March 2015. * Attain the occupancy rate of one person per room by March 2015. * Both require compliance (from base-line at March 2011) of 25% by March 2012, 50% by March 2013, 75% by March 2014 and 100% by March 2015). * Facilitate home ownership options for all mine employees in consultation with organised labour by 2014. (Not scored).

The Declaration
* Dealt with in Part 10 of the Declaration. * Attain occupancy rate of 1 person per room by 2014. * Upgrade or convert hostels into family units by 2014. * Promote home ownership options and provide balanced nutrition.

The 2002 Charter


* Dealt with in Item 4.5 of the 2002 Charter. * Establishes measures for improving housing, including upgrade of hostels, conversion of hostels to family units and promotion of home ownership options; establishes measures for improving nutrition of mine employees.

The Code
* Dealt with under Item 2.8 of the Code. * Establishes a score card which does not reflect the general principles. * Deals with upgrading housing and equitable and sustainable proper nutrition, food and water. * 100% of all hostels to be upgraded to single accommodation and/or converted into housing units by 2014.

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SUSTAINABLE DEVELOPMENT AND GROWTH OF THE MINING INDUSTRY


The Revised Charter
* Dealt with in Item 2.8 of the Revised Charter.

The Declaration
* Dealt with in Part 4 of the Declaration.

The 2002 Charter


* Not dealt with in the 2002 Charter.

The Code
* Not dealt with in the Code.

* Declares intention to develop * Sustainable development regional approaches to defined as the integration environmental impacts, of social, economic and particularly acid mine environmental factors into drainage. planning, implementation and decision-making to * Research on mine closure and ensure that the mineral mining legacies, establish a resources development serves task team to accelerate present and future generations. prospecting investment, adopt * Mining company must an integrated development implement elements of approach through pooling of resources, work towards a sustainable development "Mining Vision 2030." commitments included in the "Stakeholders' Declaration on Strategy for the sustainable growth and meaningful transformation of South Africa's Mining Industry of 30 June 2010 and in compliance with all relevant legislation", as follows: * Improvement of the industry's environmental management by: implementing environmental management systems that focus on continuous improvement to review, prevent, mitigate adverse environmental impact; undertake continuous rehabilitation on land disturbed or occupied by mining operations in accordance with appropriate regulatory commitments; provide for the safe storage and disposal of residual waste and process residues; design and plan all operations so that adequate resources are available to meet the closure requirements of all operations. (The above being scored by progress achieved against approved EMPs. Weighting 12%).

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The Revised Charter


* Improvement of the industry's health and safety performance by: implementing a management system focused on continuous improvement of all aspects of operations that have a significant impact on the health and safety of employees, contractors and communities where mining takes place; providing all employees with health and safety training and require employees of contractors to have undergone such training; implement regular health surveillance and risk-based monitoring of employees. (the above being scored by progress achieved against commitments "in the tripartite action plan on health and safety." (Weighting 12%). * Stakeholders undertake to enhance the capacity and skills in relevant South African research and development facilities in order to ensure quality, quick turn around, cost effectiveness and integrity of such facilities. To this extent, mining companies are required to utilise South African based facilities for the analysis of samples across the mining value chain. (The above being scored by "percentage of samples in SA facilities". Base-line established at March 2011. Thereafter 25% by March 2012, 50% by March 2013, 75% by March 2014 and 100% by March 2015).

The Declaration

The 2002 Charter

The Code

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REPORTING (MONITORING AND EVALUATION)


The Revised Charter
* Dealt with in Item 2.9 of the Revised Charter. * Revised score-card is applicable. * Must report level of compliance with the Revised Charter annually, as provided for by Section 28(2)(c) of the MPRDA in accordance with Reporting Template. * DMR shall monitor and evaluate, taking into account the impact of material constraints which may result in not achieving set targets.

The Declaration
* Dealt with in Part 13 of the Declaration. * Confirms adherence to effective implementation of agreed strategy. * Comply with annual progress reporting requirements. * Monitor and take into account the impact of constraints beyond the stakeholder's control which may result in not achieving set targets.

The 2002 Charter


* Dealt with in Item 4.14 of the 2002 Charter. * Companies undertake to report on an annual basis. * Stakeholders agree to participation in annual forums for monitoring implementation, developing new strategies, government/industry interaction; developing strategies for intervention; exchanging experiences, problems and solutions. * Arriving at joint decisions; reviewing the 2002 Charter.

The Code
* Monitoring and evaluation of the various items under the Code is done through the Code score-cards.

NON COMPLIANCE
The Revised Charter
* Dealt with in Item 3 of the Revised Charter. * Non-compliance with the provisions of the Charter and the MPRDA shall render the mining company in breach of the MPRDA and subject to the provisions of Section 47 read in conjunction with Sections 98 and 99 of the Act. (This provision could be open to legal challenge as unconstitutional. Also flaunts the consensual nature of the Declaration).

The Declaration
* Dealt with in Part 6 of the Declaration. * Reflects stakeholder agreement to strengthen MPRDA architecture to improve efficiency and effectiveness by 2011. * Strengthen enforcement, monitoring and evaluation. * Streamline administrative processes and eliminate inconsistent application of regulatory frame-work. * Harmonise with other related legislation; finalise 2002 Charter review by August 2010; explore single authority for environmental regulation; transparent compliance; and message the positive regulatory framework to promote South Africa as an investment destination.

The 2002 Charter


* Dealt with under Item 4.13 of the 2002 Charter. * Merely states that the regulatory frame-work and industry agreements shall strive to facilitate the objects of the 2002 Charter.

The Code
* Not dealt with under the Code.

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INNOVATION
The Revised Charter
* Not dealt with in the Revised Charter except as an adjunct to Human Resource Development.

The Declaration
* Dealt with in Part 3 of the Declaration. * Stakeholder agreement to assess current research and development, resuscitate and research development culture in the mining industry, and strengthen partnerships with research institutions.

The 2002 Charter


* Not dealt with in the 2002 Charter.

The Code
* Not dealt with in the Code.

INFRASTRUCTURE
The Revised Charter
* Not dealt with in the Revised Charter.

The Declaration
* Dealt with in Part 2 of the Declaration. * Provides for the identification, evaluation and engagement with national stakeholders regarding critical infrastructure such as rail, ports, electricity and water supply.

The 2002 Charter


* Not dealt with in the 2002 Charter.

The Code
* Not dealt with in the Code.

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CONTACT US
For further information about our Mining and Minerals services, please contact any of the directors listed below.
Ian Hayes Charles Ancer

Director National Practice Head: Corporate and Commercial T +27 (0)11 290 7121 E ian.hayes@dlacdh.com
Joz Coetzer

Director Corporate and Commercial T +27 (0)11 286 1313 E charles.ancer@dlacdh.com

Willem Jacobs

Director National Practice Head: Finance, Projects and Banking T +27 (0)11 290 7109 E joz.coetzer@dlacdh.com

Director Corporate and Commercial T +27 (0)11 290 7125 E willem.jacobs@dlacdh.com

Mondo Ntlha

Banzi Malinga

Director National Practice Head: Competition T +27 (0)11 290 7128 E mondo.ntlha@dlacdh.com
Terry Winstanley

Director Corporate and Commercial T +27 (0)11 286 1192 E banzi.malinga@dlacdh.com

Allan Reid

Director National Practice Head: Environmental T +27 (0)21 481 6332 E terry.winstanley@dlacdh.com

Director Corporate and Commercial Sector Head: Mining and Minerals T +27 (0)11 290 7171 E allan.reid@dlacdh.com

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