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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. |
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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. |
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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. |
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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. |
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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: |
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| 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. |
|
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| 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. |
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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. |
|
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Findings |
| In general, Sun International's sustainability reporting processes are
adequate, and it was noted that: |
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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: |
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| ♣ |
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. |
|
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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. |
|
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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). |
|
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| 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). |
|
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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). |
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SustainabilityServices.co.za |
| Johannesburg |
| 21 October 2011 |
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