GHSE-PI IDITS AND INSPECTIONS. _ iB GEITA GOLD MINE HSE & TRAINING DEPARTMENT PROCEDURE No. GHSE-PRO-04001 AUDITS AND INSPECTIONS FUNCTION NAME POSITION SIGNATURE DATE Drafted ‘Andy Witcomb | Manager HSE & Training | 12/03/2016 Reviewed __| Herbert Cawood | Manager Engineering and 12/03/2016 liability > Approved | Terry Mulpeter__ | Managing Director 3 fl lf 12/03/2016 Doe. No: GHSE-PRO-04001 AUDITS AND INSPECTIONS Date of Most Recent Review: 1203/16 Page 1 of 16 Date Created: 12/03/16 Rev: Ot(GHSE-PRO-04001 AUDITS AND INSPECTIONS REVISION HISTORY This procedure must not be modified or altered unless authorized by the process. ‘owner. Revi Date Nature of Amendment No. Approved 4 12/03/2016 _| New procedure oe. No: GHSE-PRO-04004 AUDITS AND INSPECTIONS Date Created 12/0316 Rev OF Date of Most Recent Review 12/0316 Page 2 of 16(GHSE-PO-04001 AUDITS AND INSPECTIONS Contents PURPOSE sn . SCOPE AND APPLICABILITY REFERENCE DOCUMENTS ...... DEFINITIONS REQUIREMENT se Sul External Audit. . 5.1.1 Before Audit S11 Summary oe 5.1.12 Notification of Ault. 5.1.13. Appointment of Responsible Person. canner S.L14 Contractual Atrangements... 5.1.15 Audit Schedule and Team... 6 5.1.16 Technical Preparation for Audit 8 S.LLT Logistics - coe 5.12 During Audit a ssi 8 5.12.1 Summary - - 8 5.12.2 Induction and PPE..n.srne 8 5.123. Infroduction to Managing Director. 8 5.1.24 — Kick-Of Meeting. S125 Gul 5.1.26 Audit nn seen 5.1.2.7 Feedback of Interim Findings 5.1.2.8 — Corrective Actions for Interiin Findings... $1.29 Close-Out S13 After Audit S131 Summary oe i" 5.132 Debriefing, - 8 S133 Audit Repot.. . . B S134 — Comective Action Plan. 13 51.3.3 Payment of Invoices or Audit Fee a1 5.2 Internal Audit onan alt 52.1 Before Audit 4 5.2.2 During Audit 5.2.30 After Audit... 6, RESPONSIBILITY .. 7. RECORDS .. Doc No. GHSE-PRO-O4001 AUDITS AND INSPECTIONS Date Created: 1203116 Rav. OF ‘Date of Mest Recent Review 1202/18 Page 3 of 16(GHSE.PRO-04001 AUDITS AND INSPECTIONS, 1. PURPOSE Geita Gold Mining Limited (GGM) is periodically subject to audits and inspections (hereafter collectively referred to as audits) by external agencies such as: * National, zonal and regional government agencies wishing to evaluate GGM's compliance with Tanzania law and other commitments * Contactors appointed to assess GGM's compliance against external standards and international norms, e.g. OSHAS18001, iS014001, International Cyanide Management Code AngloGold Ashanti (AGA) Group and Continental Africa Region (CAR) * Insurance underwriters appointed to evaluate the risk of insurance claims posed by GGMM's operations In addition, GGM undertakes periodic internal audits. This procedure lays out the requirements for management of the extemal audit process, to ensure: * Outstanding findings and corrective actions from previous audits are minimized © The audit runs smoothly + The auditors are supplied with the information they require © Negative findings are minimized ‘* As many findings as possible are negated during the course of the audit by immediate corrective action The procedure addressed preparation and execution of the audit, as well as follow- up actions. 2, SCOPE AND APPLICABILITY This procedure applies to all audits that take place at Geita Gold Mine, irrespective of: «The subject of the audit © Whether it is an intemal or external audit 3. REFERENCE DOCUMENTS None 4. DEFINITIONS For the purposes of this procedure, the definitions shown in Table 1 are adopted. Where there are references to the male gender in this document, they shall be understood to also refer to the female gender. Doc. No: GHSE-PRO-04001 AUDITS AND INSPECTIONS Date Costes: 12/086 Rev. OF Date of Mast Recent Review. 1203116 Page 4 of 16GHSE-PRO-p400% AUDITS AND INSPECTIONS, Table 1 — Definitions Term Definition ‘Audit Guide A knowledgeable GGM employee who is appointed to guide auditors around Geita Gold Mine and other associated sites, and to facilitate their access to locations, persons, documentation or other resources. ‘Auditor ‘A person appointed by an extemal agency to undertake an audit. Close-out Meeting A meeting held at the conclusion of an audit to present interim findings and recommendations arising from the aut to site personnel, in advance of a formal report, Departmental Guide External Audit or External Inspection A knowledgeable GGM employee or contractor employee who is appointed to guide auditors around areas under the control of that depariment or contractor. ‘A process whereby an external agency visits Geita Gold Mine to gather evidence of systems, records, performance or physical conditions, in order to evaluate how well GGM complies with its own documented systems or the requirements of external agencies, For the purpose of this document, the collective term ‘external audit’ is adopted to denote both extemal audit and exiernal inspection. Formal Report ‘An official report issued by an external agency, documenting the audit process, findings and recommendations, as appropriate. HOD Internal Audit or Internal Inspection The head of department of any GGM department. or his appointed deputy. A process whereby experienced GGM personne! gather evidence of systems, records, performance or physical conditions, in order to evaluate how well GGM complies with its own documented systems or the requirements of external agencies. Kick-off Meeting A meeting held at the commencement of an audit to ensure all relevant parties are aware of the context, purpose, scope and personnel involved in an audit. Managing Director The Managing Director of GGM, or his appointed deputy. Responsible Person A senior GGM employee who is appointed to arrange, facilitate and oversee all aspects of an audit oe. Ne: GHSE-PRO-04001 AUDITS AND INSPECTIONS Dale Crested: (2103/16 Rev OF Date of Most Recent Review: 120316 Page 5 of 18§. REQUIREMENT 5.1 External Audit This section describes the process to be followed for an external audit. Section 5.2 describes the process to be followed for an internal audit. 5.1.1 Before Audit 5.1.1.2 Summary Figure 1 illustrates the process to be followed before an audit. 5.1.1.2 Notification of Audit Upon notification of the requirement for an audit from an external agency, the HOD that receives the notification shalt notify the GGM management team and Managing Director of the dates and other details of the audi, including scope and any known focus areas. For planned audits, the relevant GGM department shall seek to agree a schedule with the relevant external agency as far in advance of the audit as possible. 5.1.1.3 Appointment of Responsible Person The Managing Director and/or GGM management team shall appoint a Responsible Person to arrange, facilitate and oversee each audit. The Responsible Person shall be accountable for execution of the requirements of this procedure. 5.1.1.4 Contractual Arrangements The Responsible Person shall coordinate all contractual arrangements or fee payments in respect of the audit. In the case of an audit by a government agency, the Responsible Person shall confirm in advance the projected fees for the audit, or the published schedule of fee tates, and advise the GGM finance team. S.LL5 Audit Schedule and Team The Responsible Person shall: * Develop a detailed audit schedule in collaboration with the auditor(s) and abtain approval of the GGM management team. * Appoint a knowledgeable Audit Guide to guide auditors around GGM sites and facilitate their access to locations, persons, documentation or other resources. * Send the above information to all relevant GGM employees and contractors. « Send Outlook meeting requests for kick-off and close-out meetings. ¢ Update all relevant parties regarding any relevant changes to any of the above information, as they occur. Doc. No: GHSE-PRO-04001 AUDITS AND INSPECTIONS Date Crested: 120916 Rev. 01 Date of Mest Recent Reviow: 12036 Page 6 of 6001 AUDITS. Figure? Process to be Followed Before an External Audit [Process Flowchart for External Audit Before Ault he 7 tanaging Directors} pasconstle Posion | us) cou) | Covenants Borg f esto at ae or Paes wor] racer sommnemate|_| | Sete nee looms wcepall | Srsensneanne “nomoune sapere wsetemsores [| | eam O58 epi n eos esuel ineaute Patentamt rover trang se |, | fos an me sc ote seston ‘ergs agents co apa comane Prrceutoromane| | | Potente var scree T Saar) | aaa | Fonlogeie dooce Pecan coenng rocenaton Doc. No: GHSE-PRO-04001 AUDITS AND INSPECTIONS Dee Craled: “2036 Rev: OF Dale of Most Recent Review: 120316 Page 7 of 16GHSE-PRO-04001 AUDITS AND INSPECTIONS 5.1.1.6 Technical Preparation for Audit In preparation for the audit, the Responsible Person shall: * Review status of findings and corrective actions arising from previous audits. * Conduct an internal mini-audit against the scope to identify deficiencies and corrective actions. * Brief the GGM management team on audit purpose and scope * Present the results of the review and mini-audit to the GGM management team for decision-making and instruction. Update corrective action plans with additional actions arising from the GGM management team review and distribute for action to relevant parties. * Track status of corrective and preparatory actions and periodically update the GGM management team 5.1.1.7 Logistics The Responsible Person shall make logistical arrangements as far in advance of the audit as possible, including transport, accommodation, meals and PPE (footwear sizes) if needed. He shall then make final checks on logistics in the final two weeks before the arrival of the auditor(s). 5.1.2, During Audit 5.1.2.1 Summary Figure 2 illustrates the process to be followed during an external audit. 5.1.2.2 induction and PPE The Responsible Person shall arrange a visitor's induction for the auditor(s). This level of induction is sufficient as GGM staff shail guide the auditors at all times. The auditor(s) shall be provided with PPE appropriate to the areas to be visited. 5.1.2.3 __ Introduction to Managing Director After the auditor(s) arrives at site, the Responsible Person shall arrange to introduce the auditor(s) to the Managing Director. 5.1.2.4 Kick-Off Meeting The Responsible Person shall arrange a kick-off meeting at the commencement of the audit, involving the Managing Director and relevant HODS, GGM employees and contractors, to: Make introductions * Allow the auditor() to explain the purpose, scope and focus areas of the audit * Provide background information to the auditor(s) ‘Doc. No: GHSE-PRO-04001 AUDITS AND INSPECTIONS Date Crested: 12/0876 Rev: oF Date of Most Recent Review 12/0316 Page 8 of 161 UOT NB, Figure 2 Process to be Followed During an External Audit Process Flowchart for External Audit — During Aucit ‘Managing Dreclor andl ‘Management Team | Responsible Person: uti) Guidets) Departments Being ‘Aucited Provide vers snucon ane PRE ‘nwroeucon Managing Oecar scot mosting —erauclons. pee and eeope, LaNHBIOUT HloPaUONGneron, roWeRE Be EME SLBL 1 Voss nae ee otc tape te cas putes yor saen os ocaion. i possibie thay ee rane etna | | [macoerant aro Pron umn Sentara FP] ty st ae = Trmanepesae] | [Sore ae ceca on aaa P| Stems viet cn wr meron >| | pas ss a ‘cogs out neaeg = pesenttion of ngs reco sneatons, sormmtnents (Doe. No: CHSE-PRO-04001 AUDITS AND INSPECTIONS Date of Mast Recent Reviews 12103716 Page 9018 Dato Created: 120318 Rev: 01(GHSE-PRO-04001 AUIDITS AND INSPECTIONS If appropriate, the Responsible Person shall make an opening presentation to: * Orient auditors and provide them with background information about GGM's operations + Present a summary of progress against previous audit findings, thereby demonstrating GGM commitment and minimizing queries during the audit 5.1.25 Guides An Audit Guide shail accompany the auditor(s) at all times by. The Audit Guide shalt facilitate access of the auditor(s) to locations, persons, documentation or other resources, as identified by the auditor(s). jf an audit team splits up in order to visit more than one area in parallel, the Responsible Person shall provide additional persons to support the Audit Guide. A Departmental Guide shall also accompany the auditor(s) throughout the visit to that department. The Departmental Guide is a senior representative of the department being visited who has sufficient knowledge and expertise to provide meaningful input to the visit. During visits to contractor areas, a senior representative of the contractor shall join the above persons. 5.1.2.6 Audit Upon arrival at a particular area or department, the Audit Guide shall introduce the auditor(s) to the HOD responsible for the area. The HOD shall: «Explain the principle operations and layout of the department + Provide or arrange any preliminary information requested by the auditor(s) «Introduce the Departmental Guide 5.1.2.7 Feedback of interim Findings The Audit Guide and Departmental Guide shall take notes of findings as they arise, so that: * HODs and the Managing Director are made aware of significant findings Findings can be acted upon in a timely manner and, if possible, addressed before the audit close out-meeting Any other problems arising from the audit or differences of opinion between GGM and the auditor(s) can be discussed by the GGM management team and a course of action can be determined At the conclusion of the audit of a particular area or department, the Audit Guide and Departmental Guide shall arrange a very short meeting between the auditor(s) and the HOD, when the auditor(s) can summarize key findings for the benefit of the HOD. The Responsible Person shall pravide a daily brief repost (verbal or e-mail) to the Managing Director on any issues of findings Doe. No: GHSE-PRO-04001 AUDITS AND INSPECTIONS Date Crested: 12108/16 Rev. OF Date of Most Recont Review: 12/0316 Page 10 cf 15(GHSE-PRO-04001 AUDITS AND :NSPEGTION: 5.1.2.8 Corrective Actions for Interim Findings If interim feedback from the auditor(s) indicates the presence of non-conformances of deficiencies, the HOD shall make every effort possible to address and correct, such conditions immediately. The HOD shall update the Responsible Person on the progress of correcting non- conformances or deficiencies. When advised that a non-conformance or deficiency has been corrected, the Responsible Person shall convey that information to the auditor at a suitable time, so that auditor has the opportunity (if he wishes) to: * Re-inspect the non-conformance or deficiency «Remove the non-conformance or deficiency from the findings to be presented in the close-out meeting or the formal report The Responsible Person shall make every reasonable effort to encourage the auditor(s) to adopt the above approach 5.1.2.9 Close-Out At the conclusion of physical inspections by the auditor(s), the Responsible Person shall arrange a short close-out briefing meeting with the Managing Director, prior to a formal close out meeting. Where the audit involves government agencies, this may not be possible. However, the Responsible Person shall make every reasonable effort to encourage the auditor(s) to participate in such a meeting. ‘Thereafter, a close-out meeting shall be held, at which the auditor(s) shall present interim findings and recommendations arising from the audit to site personnel, in advance of a formal report. The following persons shall be present at the close out meeting «= Auditor(s) = Managing Director + Responsible Person © Audit Guide * Relevant HODs © Other relevant GGM staff © Representatives of relevant contractors The Responsible Person shall request an electronic copy of any presentation made by the aucitor(s) at the close out meeting. 5.1.3 After Audit 5.1.3.1 Summary Figure 3 illustrates the process to be followed after an external audit. Doe. No: GHSE-PRO-04001 AUDITS AND INSPECTIONS Date Crested: 1200/16 Rev: 01 Dale of most Recent Review: 12037%6 Page 11 of 18GHSE.PRO-04007 AUDITS AND INSPEGTIO! Figure3 Process to be Followed After an External Audit [Process Flowchart for &xtemal Audit ~ After Audit Managing Diroctor and ‘Deparments Seing Management Team | Responsible Person Auits(s) Guides} ments ene muct Diabla su aura aust reper bet Rancora| management eam Pens innate aeons Rewow era a0 ope ad nity ary Lats rt av op Response Pern a —— ‘rst tae er manger tam ‘Prepare came etn pln Selmi convcioe {| wots nesutarce of lactone aur *leorectve aon | —— | Bn ‘esierer krperentaton ct eanesive action tr ap pate range tr saya | ‘fsices or aut feo Dee No: GHSE-PRO-04001 AUDITS AND INSPECTIONS Date of Most Recent Review: 1202/18, Page 1201 18 Date Cresied: 12/006 Rev: Ot‘GHSE-PRO-04001 AUDITS AND INSPECTIONS 5.1.3.2 De-briefing immediately after the conclusion of the audit, the Responsible Person shall arrange a de-briefing meeting with the Managing Director, all HODS and representatives of relevant contractors. The group shall identify and assign responsibility for any immediate actions in tespect of the audit findings or recommednations, pending receipt of the formal report. The Responsible Person shail distribute to all relevant GGM staff and contractors an electronic copy of any presentation made by the auditor(s) at the close out meeting. 5.1.3.3 Audit Report The Responsible Person shall correspond with the auditor(s) to obtain an electronic copy of the draft audit report as soon as possible after the audit, and distribute the report to relevant GGM employees and contractors. If factual inaccuracies in the draft report are identified, the Responsible Person shail advise the auditor(s) so that corrections can be included in the final report. The Responsible Person shall distribute the finalized audit repart to relevant GGM employees and contractors. 5.1.3.4 Corrective Action Plan Upon receipt of the draft audit report, the Responsible Person shall arrange and oversee preparation of a draft corrective action plan. The plan shall be based on the GGM audit corrective action plan template and must address underlying causes of findings. The plan shall contain the following information as a minimum: © GGM Department or contractor * Area + Finding * Underlying cause * Cottective action(s) for each finding * Corrective action(s) for each underlying cause «Responsible person for each corrective action «Completion date for each corrective action The Responsible Person shall distribute the draft corrective action plan for comment and then finalize it. Where required, the Responsible Person shall submit the corrective action plan to the auditor(s) for review. He shall address any requirements or recommendations. from the auditor(s) before finalizing the corrective action pian. Where applicable, the Responsible Person shall obtain formal confirmation that the auditor(s) accept the corrective action plan. ‘The Responsible Person shalt subsequently maintain the corrective action plan and track the status and progress of corrective actions. ‘Boe. No: GHSE-PRO-04001 AUDITS AND INSPECTIONS: Date Crested: 120316 Rav: Ot Dale of Most Rocont Review. (203/16 Page 190f 16GHSE.PRO-96901 AUDITS AND INSPECTIONS 5.1.3.5 Payment of invoices or Audit Fees Where applicable, the Responsible Person shall facilitate timely submission of invoices or audit fees for GGM's account in respect of the audit, and ensure they are entered into the GGM financial system in accordance with GGM_ financial procedures, 5.2 Internal Audit This section describes the process to be followed for an internal audit. 5.2.1 Before Audit The HOD of the GGM department accountable for undertaking an internal audit shall appoint a Responsible Petson to arrange, facilitate and oversee each audit. The Responsibie Person shall be accountable for execution of the requirements of this procedure. The Responsible Person shall notify relevant HODs of: * The outline audit schedule e His role as the Responsible Person The above actions shall take place no less than four weeks prior to the commencement of the internal audit, to provide HODs with the opportunity to prepare for the audit and to close out as many outstanding actions as possible prior to the audit. The Responsible Person shall subsequently: * Develop an audit plan, including scope, focus areas, methodology, audit criteria and resources required. * Develop a detailed audit schedule and obtain approval of the GGM management team. Appoint a team of personnel with relevant technical knowledge and ‘experience to undertake the audit. * Send Outlook meeting requests for kick-off and close-out meetings. In preparation for the audit, the Responsible Person and the audit team shall. * Request updates of the status of findings and corrective actions arising from previous audits, and use them to update existing corrective action plans + Brief the GGM management team on audit purpose and scope, as well as the current status of corrective actions. The above activities shall take place mo less than one week prior to the commencement of the internal audit, to provide HODs with the opportunity to close out as many outstanding actions as possible prior to the audit. Dae. No: GHSE-PRO-04001 AUDITS AND INSPECTIONS Date Crested: 1203/16 Rev. oF Date of Most Recent Review: 1203/16 Page 14 of 16(GHSE-PRO-04001 AUDITS AND INSPECTION: 5. The auditor shall undertake the audit in accordance with the audit plan, accompanied by a Departmental Guide. The Departmental Guide shall take notes of findings as they arise, so that: 2 During Audit © HODs are made aware of findings * Findings can be acted upon in a timely manner and, if possible, addressed before the audit close out-meeting if interim feedback from an auditor indicates the presence of non-conformances or deficiencies, the HOD shalt make every effort possible to address and correct such conditions prior to the conclusion of the audit. The HOD shall update the auditor on the progress of correcting non-conformances or deficiencies. The auditor shall then re-inspect the non-conformance or deficiency. if he is satisfied that the non-conformance has been satisfactorily addressed, he shail remove the non-conformance or deficiency from the findings of the audit 5.2.3 After Audit The auditors shalt compile a report on findings of the audit. The Responsible Person: shall make a presentation of the findings at a de-briefing meeting with the Managing Director, all HODS and representatives of relevant contractors. The group shall: Identify and assign responsibility for any immediate actions or recommendations in respect of the audit findings, pending receipt of the final report. + Identify any factual errors that require correction of any Therafter, the report shall be finalized and distributed to relevant GGM employees and contractors. HODs shall submit proposed corrective actions to the auditors for incorporation in a corrective action plan. The plan shall be based on the GGM audit corrective action plan template and must address underlying causes of findings. The plan shall contain the following information as a minimum: * GGM Department or contractor * Area + Finding «Underlying cause * Corrective action(s) for each finding * Corrective action(s) for each underlying cause + Responsible person for each corrective action * Completion date for each corrective action The Responsible Person shall distribute the draft corrective action plan for comment and then finalize it Doc. No:_GHSE-PRO-04001 AUDITS AND INSPECTIONS Date Creatas: 120316 Rev: OF Date of Mest Recent Reviow: 12003726 Page 15 of 16(GHSE.PRO.04001 AUDITS AND INSPECTIONS The Responsible Person shall subsequently maintain the corrective action plan and track the status and progress of corrective actions. 6. RESPONSIBILITY Responsibilities in respect of this procedure are as shown in Table 2. Table 2— Responsibilities in Respect of this Procedure Role Responsibilities Managing Director |» Hosts audit * Provides direction in response to audit findings GGM «Host auditor(s) in their areas of responsibility Management * Address interim findings during audit Team/HODs «Review findings «Manage corrective actions relating to their areas of Tesponsibility Responsible «Arrange, facilitate and oversee all aspects of an audit Person Audit Guide * Guide auditor(s) around GGM sites +Facilitate auditor's access to locations, persons, documentation or other resources Deparimental “Guide auditors around areas under the control of their Guide department or contractor ‘GGM and Participate in audit as required contractor employees oe —_ 7. RECORDS The Responsible Person shall ensure that all electronic records and documents generated by the implementation of this procedure are stored in an appropriate location on the GGM computer network, All paper records shall be stored in an appropriate filing system. The Responsible Person shall ensure that records and record-keeping comply with: = GGM Document Control and Records Procedure * The requirements of relevant external certification processes, e.g. OSHAS18001, ISO14001, Intemational Cyanide Management Code. Doc. No: GHSE-PRO-04001 AUDITS AND INSPECTIONS ‘Date Crested: 1203118 Rev: OF Date of fost Recent Review 1203116 Page 16 of 16