Independent Assurance Statement

To the Board and stakeholders of Tongaat Hulett:

Integrated Reporting & Assurance Services (IRAS) was commissioned by Tongaat Hulett to provide independent third party assurance (ITPA) over the sustainability content within the sustainability section of their 2013 Integrated Annual Report (the ‘Report’, covering the period 1 April 2012 to 31 March 2013). The assurance team comprised primarily of Michael H. Rea, our Lead Certified Assurance Practitioner (CSAP), with 14 years’ experience in environmental and social performance measurement, including sustainability reporting and assurance, and Lauren Stirling, an Associate CSAP with over two years of assurance engagement experience.

AccountAbility AA1000S (revised, 2008)

To the best of our ability and significant experience in sustainability report assurance, this engagement has been managed in accordance with AccountAbility’s AA1000AS (2008) assurance standard, where the format of the engagement was structured to meet the AA1000AS Type II (Moderate) requirements.


Previously, IRAS provided ITPA over Tongaat Hulett’s 2010 through 2012 Annual Reports, but has not undertaken any other commissions that would compromise our independence, nor has IRAS been responsible for the preparation of any part of this Report. Responsibility for producing this report was the responsibility of Tongaat Hulett. Thus IRAS is, and remains, an independent assurer over the content and processes pertaining to this report.

Assurance Objectives

The objective of the assurance process was to provide Tongaat Hulett’s stakeholders an independent ‘moderate level assurance’ opinion on whether the sustainability content within the Corporate Responsibility section of Tongaat Hulett’s Report, in its printed format, meets the AA1000AS (2008) principles of Inclusivity, Materiality and Responsiveness, as well as to assess the degree to which the Report has met the Global Reporting Initiative (GRI) G3 guidelines Application Level B reporting requirements (B+ with this assurance statement).

Assurance Approach and Limitations

The process used in arriving at this assurance statement is based on AccountAbility’s AA1000AS (2008) guidance, the GRI’s G3 Application Level requirements, as well as other best practices in sustainability reporting assurance. Our approach to assurance included the following:

  • A review of sustainability measurement and reporting procedures at Tongaat Hulett’s corporate offices to determine the context and content of sustainability management by the company;
  • A review of the information and/or data collection, collation and reporting procedures undertaken by Tongaat Hulett, to define the content of the Report by looking at the materiality of issues included in the Report, determination of sustainability context and coverage of material issues;
  • A review of Board and Committee meeting minutes, as well as media reports, to assess the accuracy and/or completeness of Tongaat Hulett’s materiality assertions;
  • A review of the approach of management to addressing topics discussed in the Report;
  • A review of drafts of the Report for any significant errors, anomalies and/or potentially unsupportable assertions; and,
  • GRI G3 gap analyses to determine whether the requisite numbers of profile and performance indicators were reasonably covered within the Report to meet Tongaat Hulett’s GRI G3 Application Level assertion (B+).

The process was limited to the content and assertions made within Tongaat Hulett’s printed Report for the period under review, and did not extend to a comprehensive analysis of the accuracy, reliability, completeness and/or consistency of the data presented by Tongaat Hulett, either in the Report or on the internet. Rather, sustainability data presented within the Report was subjected to a series of reasonability tests during final proof editing. The process was further limited to reviewing policies and procedures for stakeholder engagements, and did not extend to physical engagement of any stakeholders to arrive at our assurance opinion.


Based on our review of the Report, as well as the processes employed to collect and collate information reported herein, it is our assertion that:

  • Tongaat Hulett’s 2013 Integrated Annual Report demonstrates year-on-year improvements in the form and function of the policies, procedures and systems deployed to meet reasonable integrated reporting expectations. These include, but are not limited to, significant improvements in the systems employed to collate, collate and report key sustainability performance indicator data.
  • Tongaat Hulett has demonstrated further improvement with respect to adherence to the principal of Inclusivity, and therefore continues to adequately adhere to the AccountAbility principles of Inclusivity, Materiality and Responsiveness. However, the improvements in the formalisation of stakeholder engagement systems and controls are still a work-in-progress, and thus it is predicted that further improvement is yet to occur with respect to both proactive stakeholder engagement (i.e., Inclusivity) and feedback on stakeholder-specific concerns (i.e., Responsiveness).
  • The Report adequately meets the GRI G3’s requirements for Application Level B (responses to all required indicators, as well as no fewer than 20 Core indicators, with at least one from each of Economic, Environment, Human Rights, Labour, Society and Product Responsibility). The reporting of performance against some GRI G3 indicators continues to require either further detail in disclosure, or improvements in the quality and/or quantity of comparable data.

Conclusions and Recommendations

Based on the information reviewed, IRAS is confident that this report provides a reasonably comprehensive and balanced account of Tongaat Hulett’s environmental, safety and social performance for the period under review. The information presented is based on a systematic process and we are satisfied that the content of the Report adequately represents Tongaat Hulett’s adherence to the AA1000AS (2008) principles of Inclusivity, Materiality and Responsiveness. Moreover, and although the quality or quantity of data of some GRI G3 indicators can be improved, this Report appears to meet the GRI G3’s requirements for Application Level B (B+ with this assurance engagement).

The following recommendations have however been identified:

  • Although significant improvement has been noted with respect to adherence to AccountAbility’s principle of Inclusivity, including the presence of more formalised stakeholder engagement systems and controls, Tongaat Hulett should continue to ensure that stakeholder engagement progresses towards the active inclusion of all significant stakeholders, and that systems and controls consolidate stakeholder concerns for consideration at the relevant management and/or board levels. Moreover, the Report should ultimately reflect how engagement is deployed throughout the organisation to affect – where necessary – business decision-making, processes and/or controls.
  • With respect to adherence to AccountAbility’s principle of Responsiveness, Tongaat Hulett should continue to ensure that feedback to stakeholders on sustainability matters occurs in line with King III’s recommendations for ‘Integrated Reporting’, including reasonable discourses regarding Tongaat Hulett’s most material sustainability issues.

For more information about the assurance process employed to assess the sustainability section within the Report email

Integrated Reporting & Assurance Services


6 June 2013