Independent assurance statement

 

To the Board and stakeholders of Sun International:

SustainabilityServices.co.za (SS) was commissioned by Sun International to provide independent third party assurance (ITPA) over the sustainability information within this Integrated Annual Report (hereafter, 'the Report'), covering the period 1 July 2010 to 30 June 2011. The assurance team comprised primarily of Michael H. Rea, our principal Sustainability Assurance Practitioner, with 12 years' experience in environmental and social performance measurement in over 35 assurance engagements in Sudan, Kenya, the DRC, Nigeria, Cameroon, Swaziland, Zimbabwe, Namibia, South Africa, Peru and Canada: working either as part of a team (while in the employ of PwC and KPMG), or as an Independent Sustainability Consultant. 
 

AccountAbility AA1000S (revised, 2008)

To the best of our ability, this assurance 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. 
 

Independence

SS was not responsible for the preparation of any part of this Report and has not undertaken any commissions for Sun International in the reporting period. SS did, however, conduct an assurance engagement for Sun International's 2010 Report, including the identification of reporting gaps that ultimately have been incorporated into their reporting processes. However, this work has not compromised our ability to afford ITPA over this year's Report. SS's responsibility in performing its assurance activities is to the management of Sun International alone and in accordance with the terms of reference agreed with them. 
 

Assurance objectives

The objectives of the assurance process were to provide Sun International's stakeholders an independent 'moderate level assurance' opinion on whether the report meets the AA1000AS (2008) principles of Inclusivity, Materiality and Responsiveness, as well as to assess the degree to which the Report is consistent with the Global Reporting Initiative (GRI) G3 guidelines, with the objective of establishing whether or not the Report has met the B+ level of reporting requirements. In meeting the Type II assurance objectives, SS undertook a review of selected sustainability performance indicators at one of Sun International's operational sites: the Wild Coast Sun
 

Scope of work performed

AA1000AS (2008) Compliance

The process used in arriving at this assurance statement is based on AccountAbility's AA1000AS (2008) guidance, as well as other best practices in assurance. Our approach to assurance included the following: 
A review of sustainability measurement and reporting procedures at Sun International's head offices, via management interviews with the reporting team, as well as through desktop research; 
A review of data collection, collation and reporting procedures at Wild Coast Sun, with specific reference to the following selected sustainability performance indicators: 
 
1. Presence and application of Responsible Gaming policies and procedures 
2. Presence and application of biodiversity management policies and procedures 
3. Quality of systems to report human resource data relative to employment equity targets 
4. Quality of systems to report human resource data relative to Local Employment targets
5. Lost Time Injury Frequency Rate (LTIFR) – LTIs and hours worked 
6. Total Recordable Injury Frequency Rate (TRIFR), including medical treatment cases and first-aid cases 
7. Electricity consumption 
8. Liquid petroleum gas (LPG) consumption 
9. Diesel consumption 
10. Petrol consumption 
11. Water consumption and discharge 
Reviews of drafts of the Report for any significant errors and/or anomalies; and, 
A series of interviews with the individual responsible for collating and writing various parts of the Report in order to ensure selected claims were reported and substantiated. 
 
It should be noted that due to the scope and nature of this AA1000AS (Type II, Moderate) assurance engagement, the site visit undertaken at Wild Coast Sun was designed to test the authenticity of data at the primary source of collection and collation, and this report has been assessed at the point of data aggregation for accuracy of reporting. 
 

GRI compliance

In determining the GRI G3 ‘Application Level’ of the Report, we performed the following exercises: 
A review of the process used to define the content of the Report by looking at materiality of issues included in the Report, stakeholder engagement response to stakeholder issues identified, determination of sustainability context and coverage of material issues; 
A review of the approach of management to addressing topics discussed in the Report; and 
A confirmation that the requisite number of performance indicators had been covered in the Report.
 

Findings 

In general, Sun International's sustainability reporting processes are adequate, and it was noted that: 
 

AA1000AS (Type II) 

Policies, procedures and reporting structures are in place for head office to obtain quantitative data with respect to a variety of material sustainability indicators on a regular basis. 
Sustainability data undergoes a process of internal and/or outsourced assurance reviews to test for the accuracy and/or reliability of data reported by sites to the Group
Certain site-reported data was found to be inaccurate and/or unreliable due to minor systems/process errors. For example: 
 
Systems to record Lost Time Injuries (LTIs) and/or Non-Lost Time Injuries (NLTIs) at the Wild Coast Sun did not necessarily reflect the total number of injuries. Although no additional LTIs were identified, the reliability of the data was deemed 'inadequate' due to the lack of appropriate controls between the first-aid Station and safety office. Also, contractor injuries were not recorded as either LTIs or NLTIs, even though many contractors complete key operational tasks. 
Although total fuels consumption was deemed 'accurate', the systems to record Petrol and Diesel consumption led to minor reporting errors, primarily due to assumptions that all vehicles were 'Petrol'. 
Although the HR data management system - PeopleSoft - can generate the relevant reports, data within the system was not deemed 'accurate enough' to report on 'Local Employment'. However, this is a new indicator, and does not affect the overall quality of Sun International's sustainability reporting. 
Sun International actively engages an array of key stakeholders, as defined within this Report. Although management assertions of engagement were deemed reasonably supportable, based on the evidence reviewed, the assurance process did not allow for additional engagement to confirm or refute Sun International's assertion that the Report adequately reflects the information requirements of their key stakeholders. 
Within the parameters of a 'Moderate Level Type II assurance assessment', the Report - without exception - appears to reflect an accurate accounting of Sun International's performance, including the review of data supplied by the team at the Wild Coast Sun and contained within this Report. 
 

GRI G3

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 this Report, inclusive of the downloadable GRI Indicator Table, 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). However, the reporting of performance against some GRI G3 indicators continues to require either data quality improvements, or further detail in disclosure. 
 

Recommendations 

AA1000AS (Type II) 
Sun International should continue to improve its reporting according to the principles of Inclusivity, Materiality, and Responsiveness, as guided by AA1000AS (2008). 
Sun International should ensure that improvement continues to occur with respect to stakeholder engagement procedures, including an independent assessment of whether or not this Report, and all future Reports, adequately reflects the reporting requirements of key stakeholders. 
Sun International should employ a sustainability reporting cycle that accommodates for AA1000AS (Type II) assurance over key sustainability performance data at selected sites (3 per annum). 
 
GRI G3
Having addressed the requirements of GRI G3 Application Level B (B+ with this assurance statement), it is our recommendation that Sun International review the process followed in compiling its Report and, while making further improvements on the quality of data required for Application Level B, ultimately address the requirements of GRI G3 Application Level A (A+with ITPA). 
 

Conclusions

Based on the information reviewed, SustainabilityServices.co.za is confident that this report provides a comprehensive and balanced account of the environmental, safety and social performance of Sun International during the period under review. The data presented is based on a systematic process and we are satisfied that, aside from the minor exceptions stated above, the reported performance data accurately represents the current environmental, safety and social performance of Sun International, while meeting 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).
 
 
SustainabilityServices.co.za 
Johannesburg 
21 October 2011