1. We respect, care and deliver Presentation by Impala Platinum Holdings Ltd (“Implats”) to the Parliamentary Portfolio Committee of Mineral Resources on The Mineral and Petroleum Resources Development Bill [B15-2013 ] 18 September 2013

2. We respect, care and deliver Presentation Introducing Implats Submissions of Comments to the Mineral and Petroleum Resources Development Amendment Bill (“the Bill”) Focus of Implats’ comments and concerns: o Beneficiation o Concentration of Rights o Processing of Tailings Dams and Dumps (Reclamation permit and definition of “residue stockpile”) Conclusion 2

3. We respect, care and deliver Introducing Implats

4. We respect, care and deliver Introducing Implats (cont) Implats is in the business of mining, refining and marketing platinum group metals and associated base metals Produced 1.58 million ounces of platinum in FY2013 equivalent to approximately 20% of global supply Employs around 57 000 people (including contractors) Generated sales revenue of R30 billion in FY2013 Employee wages and benefits: R8.5 billion FY2013 Skills and training R430 million FY2013 Taxation and Royalty R1.9 billion FY2013 Socio-economic initiatives in communities R100 million FY2013 (RSA only, including labour sending areas) 4

5. We respect, care and deliver Introducing Implats (cont) Operations are located on the two prime platinum deposits The Bushveld Complex in South Africa The Great Dyke in Zimbabwe 5

6. We respect, care and deliver Introducing Implats (cont) South African operations Afplats 6

7. We respect, care and deliver Introducing Implats (cont) Implats Group structure SA Mine-to-market operations Impala Refining Services 100% Marula 73% Afplats 74% Two Rivers 45% Royal Bafokeng Nation / Morokotso Trust (ESOP) BEE 26% BEE 27% BEE 55% Impala 100% * BEE 24.4% (26.4%) Effective Zimplats 87% Mimosa 50% Implats * The Morokotso Trust BEE shareholding was reduced from 26.4% to 24.4% primarily due to employees selling 40% shares for cash after July 2011. All Bee partners are 100% HDSA owned 7

8. We respect, care and deliver Introducing Implats (cont) Operational Mining Companies: o Impala Platinum Ltd – Impala Rustenburg Mine, NW Region near Rustenburg / Phokeng 24.4% (26.4%) BEE partner – 21.9% Royal Bafokeng Nation 2.5% (4.5%) Morokotso Trust (ESOP) o Marula Platinum Limited – Marula Platinum Mine, Limpopo Region near Burgersfort 27% BEE partner – 9% Mmakau Mining 9% Tubatse Platinum 9% Marula Community Trust 8

9. We respect, care and deliver Introducing Implats (cont) Operational Mining Companies (cont): o Two Rivers Platinum (Pty) Ltd – Two Rivers Mine, Limpopo Region near Steelpoort BEE partner – 55% ARM Mine Project: o Afplats (Pty) Limited – Afplats Leeuwkop Mine Project, NW Region near Brits BEE partner – 26% Bakwena Ba-Mogopa Community 9

10. We respect, care and deliver Impala Platinum Ltd Mining Charter Scorecard CY 2012 Reporting CriteriaDescription Target 2014Target 2012Impala 2012 performance Comment OwnershipMeaningful economic participation of HDSA's 26%15%26%As at June 2013 RBN have 13.15% at Implats Group Level Full shareholder rights of HDSA26%15%26% Housing and Living ConditionsConversion and upgrade of hostels to attain the occupancy rate of one person per room 100%50% improvement 79% improvement As at June 2013 100% occupancy of 1 per room. Over 5000 units produced Conversion and upgrade of hostels in family units towards 2014 target N/A 100%As at June 2013 264 family units produced Facilitate home ownership options of A, B and C level band employees in consultation with organised labour towards 2014 target N/A No target, however 1717 units have been delivered at these Rustenburg operations As at June 2013, 1717 units delivered. An additional 2420 planned at Platinum Village 10

11. We respect, care and deliver Impala Platinum Ltd Mining Charter Scorecard CY 2012 (cont) Reporting Criteria DescriptionTarget 2014Target 2012Impala 2012 performance Comment Procurement and Enterprise Development with HDSA's Capital Goods40%20%37%As at June 2013 55% of Group Discretionary spent was with HDSA's amounting to R 5.5 billion. (27% spent with Local companies) Consumables50%25%62% Services70%50%63% Employment Equity Top Management40%30%31% Senior Management40%30%46% Middle Management40% 42% Junior Management40% 55% Core and Critical Skills40%30%75% Human Resources Development Human resources development spend as percentage of payroll for HDSA 5%4%6% Mine Community Development Expenditure on mine community development projects as per the agree SLP for 2012 100%As per SLP>100% 11

12. We respect, care and deliver Impala Platinum Ltd Mining Charter Scorecard CY 2012 (cont) Reporting Criteria DescriptionTarget 2014Target 2012Impala 2012 performance Comment Sustainable Development and growth Implementation of Approved EMP100% 90% Implementation of approved environmental plans 100% Progress towards implementation of closure plans 100% FFR per million man hours - ultimately a target of Zero Continuous improvement in line with international best practice 0.030.104As at June 2013 FIFR 0.085 a 25% improvement Silicosis - zero new cases in previously unexposed individuals 100% 95% of all exposure results below 0.1 mg/m3 of respirable silica 100% compliance No risk of exposure within the Merensky and UG2 reef NIHL - each individual equipment must not emit sound above 110dB 100% silencing of equipment to below 110dB 100%99% achieved 12

13. We respect, care and deliver Impala Platinum Ltd Mining Charter Scorecard CY2012 (cont) Reporting Criteria DescripionTarget 2014Target 1012Impala 2012 Performance Comment Sustainable Development and growth Implementation of the Cultural Transformation Framework 100%50% Percentage of employee embarking on OHS representative training 8%4%1.6% Percentage of leading practices from MOSH learning hub investigated for implementation 100% Health - Percentage of mandatory occupational health reports submitted 100% Health - Adherence to HIV/AIDS and TB guidelines 100% Beneficiation Added production volume contributory to local value addition above the baseline Baseline established at 10% Group at 22% local beneficiation 13

14. We respect, care and deliver Marula Platinum Ltd Mining Charter Scorecard CY2012 Reporting Criteria DescriptionTarget 2014Target 2012Marula 2012 performance Comment Ownership Meaningful economic participation of HDSA's 26%15%27%BEE partners, 9% Tubatse Platinum, 9% Makau Mining, 9% Marula Community Trust Full shareholder rights of HDSA26%15%27% Housing and Living Conditions Conversion and upgrade of hostels to attain the occupancy rate of one person per room 100%50% improvement on 2011 N/ANo hostels at the operations Conversion and upgrade of hostels in family units towards 2014 target N/A No hostels at the operations Facilitate home ownership options of A, B and C level band employees in consultation with organised labour towards 2014 target N/A No target122 units currently under construction at the operation 14

15. We respect, care and deliver Marula Platinum Ltd Mining Charter Scorecard CY2012 (cont) Reporting Criteria DescriptionTarget 2014Target 2012Marula 2012 performance Comment Procurement and Enterprise Development with HDSA's Capital Goods40%20%62%As at June 2013 55% of Group Discretionary spent was with HDSA's (22% spent with local companies) Consumables50%25%59% Services70%50%70% Employment Equity Top Management40%30%100% Senior Management40%30%50% Middle Management40% 58% Junior Management40% 58% Core and Critical Skills40%30%67% Human Resources Development Human resources development spend as percentage of payroll for HDSA 5%4%3% Mine Community Development Expenditure on mine community development projects as per the agree SLP for 2012 100%As per SLP>100% 15

16. We respect, care and deliver Marula Platinum Ltd Mining Charter Scorecard CY2012 (cont) Reporting Criteria DescriptionTarget 2014Target 2012 Marula 2012 performance Comment Sustainable Development and growth Implementation of Approved EMP100% Implementation of approved environmental plans 100% Progress towards implementation of closure plans 100% FFR per million man hours - ultimately a target of Zero Continuous improvement in line with international best practice 0.030.00 As at June 2013 FIFR = 0.00 Silicosis - zero new cases in previously unexposed individuals 100% 95% of all exposure results below 0.1 mg/m3 of respirable silic 10o% compliance No risk of exposure within the Merensky and UG2 reef NIHL - each individual equipment must not emit sound above 110dB 100% silencing of equipment to below 110dB 97%67% 16

17. We respect, care and deliver Marula Platinum Ltd Mining Charter Scorecard CY2012 (cont) Reporting Criteria DescriptionTarget 2014Target 2012Marula 2012 performance Comment Sustainable Development and growth Implementation of the Cultural Transformation Framework 100%50%100% Percentage of employee embarking on OHS representative training 8%4%9.5% Percentage of leading practices from MOSH learning hub investigated for implementation 100% Health - Percentage of mandatory occupational health reports submitted 100% Health - Adherence to HIV/AIDS and TB guidelines 100% Beneficiation Added production volume contributing to local value addition beyond the baseline Per beneficiation strategy Beneficiation done through Impala Platinum Limited 17

18. We respect, care and deliver Submission of Comments on the Mineral and Petroleum Resources Development Amendment Bill [B15-2013]

19. We respect, care and deliver Implats written submission Implats’ written submission dated 10 September 2013 focused on its critical concerns and comments on the Bill, in addition to, and in further support of the comments submitted and presentations made by the Chamber of Mines. Implats supports and acknowledge the fundamental principles and objectives which underpin the Bill. 19

20. We respect, care and deliver Focus of Implats’ Comments and Concerns

21. We respect, care and deliver Implats’ Comments and Concerns Implats’ 3 critical areas of concerns: o Beneficiation o Concentration of Rights o Processing of Tailings Dams and Dumps (Reclamation permit and definition of “residue stockpile”) 21

22. We respect, care and deliver Implats’ Comments and Concerns BENEFICIATION Beneficiation Initiatives Implats supports the Government’s beneficiation objective and remain committed to assist government to encourage upstream beneficiation. Established Marula Mine Community Chrome Company, together with its BEE partners - processing chrome from the PGM arisings and in the process of investigating options for local communities to participate in the existing Impala Chrome Company at the Rustenburg operation. Implats – smelting, refining its PGM's and associated base metals to final product since December 1969 through Mineral Processes and Refineries Ore is beneficiated to concentrate – to matte – to refined product. The Bill and the Act is not clear on: o What constitutes beneficiation o Will the Implats activities of substantial value add qualify as “beneficiation” in terms of the Bill? 22

23. We respect, care and deliver Implats’ Comments and Concerns BENEFICIATION (cont) Beneficiation Initiatives Implats’ Silplats Jewellery beneficiation project o Silplats had no success to obtain a small duty free allocation of Platinum chain into China – DMR undertaking with China o Silplats beneficiation project failed even with support of Implats 23

24. We respect, care and deliver Implats’ Comments and Concerns BENEFICIATION (cont) Proposed Pricing and Availability of PMGs for local beneficiation Negative impact on pricing and availability of Implats Group’s PGM's to be marketed and exported (locally as well as globally) Unfettered Discretionary Powers by Minister of Mineral Resources o Prescribe (by regulation) levels of beneficiation o Determine by notice in GG (not by regulation)  such % of mineral commodity, as well as  developmental pricing conditions o Producers to offer % of raw mineral production as prescribed (by regulation) to local beneficiators Implats sells at free market prices Implats supports to make metal available, but at commercial prices and competitive payment terms Limitation on exports – breach of long term supply agreements with existing customers in Japan and the USA 24

25. We respect, care and deliver Implats’ Comments and Concerns BENEFICIATION (cont) Implats Concerns Beneficiation has been a debated topic in various committees, Precious Metals Act, forums, of which Implats has been party to since 2004 Latest – Beneficiation Strategy 2011 The unfettered discretionary powers of the Minister – Section 26(2B) and 26(2C) critical concern We propose: Alignment of proposals in the Bill, the 2011 Beneficiation Strategy and the existing Precious Metals Act DTI, the DMR and mining industry to agree on the levels, pricing and forms of beneficiation – economic balance 25

26. We respect, care and deliver Implats’ Comments and Concerns BENEFICIATION (cont) Implats Proposed Way forward Differential prices: o Implats in favour of incentive to local beneficiators o Extended payment terms or leased metal o Producers to determine themselves in arms-length commercial transactions Closing thought: MIDP vs APDP o Historically the successful automotive component industry was created through the MIDP, without pricing support from miners o New APDP by DTI is rendering this industry less competitive - benefit to OEMs (offshore companies) o If SA mines need to further subsidise this sector at the expense of the already under pressure SA mines, all this will do is transfer automotive company dividends out of SA o Negative impact on Implats profitability and the effect it will have on SA pension funds such as the PIC etc. 26

27. We respect, care and deliver Implats’ Comments and Concerns BENEFICIATION (cont) Implats Current Platinum Commitment Attached to Implats written submission – Letter dated 2006 as Annex “A” Platinum Beneficiation Committee findings and commitment Reserve up to 10% of local production for SA delivery in support of beneficiation initiatives Currently, Implats have doubled the 10% commitment Implats local deliveries now exceed 20% of its local production Implats continue to encourage its customers to beneficiate in SA, including automotive customers to produce catalysts. However, this require Government support and initiatives, as being discussed with DDG, Mr Mosa Mabuza via the Platinum Beneficiation committee. 27

28. We respect, care and deliver Implats’ Comments and Concerns CONCENTRATION OF RIGHTS New definition – “concentration of rights” Minister must refuse granting of applications for Prospecting and Mining Rights, if it will result in: o “Concentration of rights under the control of the applicant and its associated companies”, and o “granting of right will defeat objects of section 2(d) of the MPRDA” Unfettered Discretionary powers of Minister of Mineral Resources No clarity on what will constitute “concentration of rights” or “defeat objects of section 2(d)” 28

29. We respect, care and deliver Implats’ Comments and Concerns CONCENTRATION OF RIGHTS (cont) Implication for Implats Linking of applicant and its associated companies Regardless of BEE status of applicant Implats is second largest platinum producer in world Holder of mining rights of single biggest PGM mine Local growth might be negatively impacted Two hurdles to cross – by application for prospecting right and again by application for a mining right Breach of security of tenure if one has prospecting right with exclusive right to apply for mining right Also impacts Section 102 extension of rights / Section 11 transfers 29

30. We respect, care and deliver Implats’ Comments and Concerns CONCENTRATION OF RIGHTS (cont) Implats Proposed Way Forward Deletion of automatic disqualification criteria in the Bill Second prize, clarification in the Bill on what is meant with “concentration of rights” and “defeat objects of section 2(d)” IMPLATS as a fully transformed group of companies are extremely concerned of these provisions in the Bill, which will also negatively impact on BEE companies that dominate a specific mineral industry. Closing thought: Compulsory sterilization of existing reserves which are located down dip of exiting mining operations and which can only be mined profitably via existing infrastructure. 30

31. We respect, care and deliver Implats’ Comments and Concerns Processing of Tailings Dams and Dumps Amendment of definition of “Residue Stockpile”: now includes historic tailings dams and dumps not created in terms of the MPRDA Reclamation permit (new) require owners to process: o historic tailings dams and dumps (created prior to 1 May 2004 – MPRDA commencement date), and o Residue Stockpiles (created after 1 May 2004)  Notwithstanding if these dams or dumps are situated on land currently covered by Mining Rights granted or converted in terms of the MPRDA  Notwithstanding if these dams or dumps are covered by approved MWPs, EMPs as part of a mines’ Mining Rights 31

32. We respect, care and deliver Implats’ Comments and Concerns Processing of Tailings Dams and Dumps (cont ) Impala Rustenburg Mine – No 1 & 2 Tailings Dam Dormant; historic dump, created prior to MPRDA under the former Mining Rights Act and Minerals Act Part of Impala’s converted mining right in our approved MWP to process No 1 & 2 Tailings Dam over life of mine with existing capacity Approval of EMP is being awaited to include this activity Earmarked for future processing of PGM's Impala Rustenburg Mine – No 3 & 4 Tailings Dam “Live” tailings dam; partly a historic dump and a current dump; created partly under the former Mining Rights Act and Minerals Act, and expanded under the MPRDA since 1 May 2004 Situated on Impala’s converted mining right area Earmarked for future processing of PGM's, but only once this tailings dam is dormant 32

33. We respect, care and deliver Tailings dam 1&2 Tailings dam 3&4 33

34. We respect, care and deliver Top of tailings dam 1&2

35. We respect, care and deliver Tailings dam 1&2 35

36. We respect, care and deliver Implats’ Comments and Concerns Processing of Tailings Dams and Dumps (cont) Marula Platinum Mine – Tailings Dam “Live” tailings dam; partly a historic dump and a current dump; created partly under the former Mining Rights Act and Minerals Act, and expanded under the MPRDA since 1 May 2004 Situated on Marula’s converted mining right area Earmarked for future processing of PGM's, and chrome, but only once this tailings dam is dormant Afplats Leeukop Mine Project No tailings dam – mine in project phase 36

37. We respect, care and deliver Implats’ Comments and Concerns Processing of Tailings Dams and Dumps (cont) Impact of new Reclamation Permit and amendment of definition of “Residue Stockpile” All of the Implats Group’s operational mines will require a reclamation permit to process its tailings dams, notwithstanding that it forms part of its converted mining rights (including historic dumps). Limitation of property rights o Impala and Marula will have an exclusive right to apply, within 2 years from the enactment of the Bill into law, to process its tailings dams in terms of reclamation permits o Once granted, these operations will have a maximum period of 6 years to process these dumps, where after it will be open for third parties to apply o To meet the 6 year requirement in the Bill: Impala Rustenburg’s Tailings No 1 & 2 will require a new concentrator to be built; estimated capital expenditure of R1.5bn 37

38. We respect, care and deliver Implats’ Comments and Concerns Processing of Tailings Dams and Dumps (cont) Impact of new Reclamation Permit and amendment of definition of “Residue Stockpile” (cont) Processing of “live” tailings dams (Impala’s Tailings Dam No 3 & 4 and Marula’s Tailings Dam) Great risk on stability of tailings dams’ structure From Safety and Health perspective, Implats decision not to process “live” tailings On 11 November 1974 – Tailings Dam disaster at Impala Rustenburg Mine (No1 & 2 tailings dam) o Part of the 20m high embarkments of tailings dam broke o Tide of slurry swept across Impala mine property o Flooded No 4 shaft, situated across tailings dam o 13 Men DIED o Substantial surface, environmental and infrastructure damages o Caused by excessive rainfall THUS: Implats cautious re any risks that may impact stability of dams 38

39. We respect, care and deliver Implats’ Comments and Concerns Processing of Tailings Dams and Dumps (cont) Implats Proposed Way Forward Definition of “residue stockpile” to be amended to exclude historic dumps (created prior to 1 May 2004) Reclamation permit provisions be amended – tailings dams and dumps that forms part of a mining right (including converted mining rights) be excluded from reclamation permitting requirements 39

40. We respect, care and deliver Conclusion

41. Conclusion Implats requests Parliamentary Portfolio Committee to address these critical operational concerns in the Bill Ensure stability and security of tenure of mining industry in SA Implats wishes to thank: o the Minister of Mineral Resources o The Parliamentary Portfolio Committee of Mineral Resources o Officials of the DMR for their commitment to bilateral discussions and consultation with the Mining Industry and affected parties in respect of the Bill, to develop and enhance the mining industry and beneficiation in SA. 41