Background

As a committed corporate citizen of Lesotho, Letšeng Diamonds Pty (Ltd) (the Company) whole-heartedly adopts and embraces the principles of Corporate Social Responsibility and Investment (CSRI), addressing the company’s overall response to economic, social and environmental considerations and in addition to its regular business activities. Accordingly, the Company strives to establish strong relationships with local communities, the nation and other stakeholders through a strong and effective Corporate Social Responsibility and Investment (CSI) strategy as an integral part of its mining business strategy.

Scope

The purpose of this policy is to formalise the CSRI strategy of the Company in line with the Company’s strategic intent, and relevant mining legislation including the Mining Agreement. The Company is committed to being a responsible corporate citizen having clear corporate values, recognising the interest of the communities, being transparent and following relevant corporate governance practices. The Company takes a broader view of its role in the society and therefore realises the importance of socio-economic development, ethics, safety, health, environmental management, human rights and economic development and fair labour practices.

 CSRI Focus Areas

With this policy, the Company commits to the public to assist in the implementation of key areas as identified below, to result in sustainable economic community projects that would remain even after the lifespan of the mine.

Investment in Education
Education is important in the development of any society. The Company recognises the critical role that education will play in the transformation of Lesotho. The Company, in accordance with section 9(i) of the Mining Agreement will contribute to education in the areas relevant to the development of the natural resources of Lesotho through the Company’s scholarship programme. The scholarship programme will be for the benefit of Lesotho nationals at the university level including technical training where necessary. The Company intends to support the development of educational infrastructures such as school buildings and furnishings.

Development of Sustainable SMME (Small, Medium and Micro Enterprise)
The Company has been involved in the area of socio-economic development throughout its life cycle. Some of the areas that the Company will continue to invest in include job creation, the elimination or eradication of poverty, and community safety. In the area of socio-economic development, the Company will identify and focus on areas of need in line with the Mining Agreement while ensuring the development of the small to medium businesses in both the mining communities and the nation at large. Should the opportunity exist, the Company may also partner with other stakeholders including non-governmental organisations that are participating and are active in socio-economic development.

Community Health
Lesotho is faced with multiple health challenges that range from, but are not limited to, high rates of child mortality, tuberculosis, poor nutrition, inadequate hygiene and the high prevalence rate of HIV/Aids. This has affected all developmental areas of the country including human resources. The Company commits to invest in the uplifting of Community Health services and facilities based on specific community health needs.

Infrastructure
The Company prefers to invest in the development of community facilities by means of providing pro bono infrastructure for the community benefit. The infrastructural needs of the communities that would ensure and support sustainable development initiatives will be given attention. All the infrastructural projects will be handed over to the relevant community authority for its management and maintenance going forward.

Regional and Environmental Initiatives
The Company will support community-based environmental projects which will be owned by the communities themselves. The aim of the projects will be to protect and improve the environment within the communities.

Other areas
The Company will support other areas such as emergency donations and sporting sponsorships. Consideration will be given to support projects that are linked to meeting or exceeding the requirements of the Mining Agreement and relevant legislation in Lesotho.

Budget

The Company will have a CSRI budget to support all approved projects. The Letšeng Diamonds Board shall allocate for CSRI, an amount being equal to 1% of the dividends declared annually to the CSRI Sub-committee, however, the 1% is to be a guideline as flexibility is necessary. The Company’s CSRI budget will be based on the profitability or financial performance of the Company. Funds obtained from external parties may be utilised to increase the scope and strengthen the impact of the Company’s CSRI programmes, on condition that such funds align with the Policy focus areas outlined.

Responsibility

• The CSRI Sub-committee will be responsible for considering and monitoring all CSRI projects, programmes, and activities in the Company.
• The function of the Sub-committee will include the following:
• The identification of worthy causes for funding or support.
• The assessment of requests received for funding or support.
• Approval and funding of social responsibility projects.
• Follow-up and monitoring of projects or initiatives that have been funded.
• Reporting to Letšeng Board.

CSR Funding Process

Through a consultative process with the communities, a needs analysis exercise will be undertaken to identify viable investment projects and opportunities.

• The budget will be submitted to the CSRI Sub-committee for approval.
• The identified needs will be matched with the approved funding.
• A detailed annual plan will be developed based on the identified needs and the approved budget. The plan will indicate milestones to be achieved within specific time frames.
• On a daily, weekly and monthly basis implement the plan and make sure that it actually happens.
• The checks and balances are to be put in place to monitor projects’ progress on a monthly basis, and the production of monthly HSSE reports and quarterly CSRI Sub-committee reports should be done.
• Proposals received from communities, individuals or organisations will go through the following process:
• The CSRI Administrator will acknowledge receipt of the proposal.
• The CSRI Administrator will prepare the funding proposal for submission to the CSRI Sub-committee for consideration
• The CSRI Sub-committee will approve or reject the proposal.
• If a proposal is rejected, the CSRI Sub-committee will record the reasons for rejection
• If a proposal is approved, the CSRI Sub-committee will allocate funds to the project after the necessary agreements have been signed with the relevant beneficiary organisation.
• The CSRI Administrator will make arrangements for the disbursement of the funds to the project and be responsible for the monitoring and reconciliation of all funds disbursed.
• The CSRI Sub-committee will continuously monitor projects that are funded by the Company
• The CSRI Administrator will ensure that proper reporting on the CSRI projects and programmes is made to the CSRI Sub-committee at every meeting of the Sub-committee.

Evaluation, Monitoring and Reporting

Continuous evaluation, monitoring, and reporting will provide evidence of performance, success stories and areas requiring attention. Reporting on CSI activities will demonstrate to the Company’s shareholders and other interested parties the progress the Company has made with respect to CSI to make the Company a good corporate citizen, and to comply with relevant mining legislation. This will also allow feedback and continuous improvement. The company will assist in the management of the projects at the beginning and handover once convinced that adequate capacity to manage such projects would have been acquired. Project beneficiaries will be expected to provide quarterly reports on overall CSRI project management and implementation. A stakeholder management approach will be followed in the implementation of the Company’s CSRI programme.

Letšeng Diamonds CSRI Policy