Sun International Sustainability

Independent Assurance Statement

To the board and stakeholders of Sun International

Integrated Reporting & Assurance Services (IRAS) was commissioned to provide independent third party assurance (ITPA) over the sustainability information within Sun International’s 2014 Integrated Annual Report (hereafter, “the Report”), covering the period 1 July 2013 to 30 June 2014. The Report consists of not only the printed document, but also the online supplemental information referenced within the printed document. The assurance team comprised primarily of Michael H Rea, our Lead Certified Sustainability Assurance Practitioner, with 15 years’ experience in environmental and social performance measurement.

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

IRAS was not responsible for the preparation of any part of the Report and has not undertaken any commissions for Sun International in the reporting period. IRAS has, however, conducted assurance engagements for Sun International’s 2010 through 2013 Reports, 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. IRAS’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 with 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) 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, IRAS undertook a review of selected sustainability performance indicators at the following Sun International operational sites: Sibaya, Boardwalk and Carousel.

These site visits were supported by prior learning from prior year visits to:

2013 GrandWest Casino and the Royal Livingstone/Zambezi Sun complex (Zambia)
2012 Meropa, Carnival City and Sun City
2011 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 the selected operational sites, with specific reference to the following selected sustainability performance indicators:
    1. Presence and application of Responsible Gaming policies and procedures
    2. Quality of systems to report Human Resource data relative to Employment Equity targets
    3. Quality of systems to report Human Resource data relative to Local Employment targets
    4. Employee turnover as a percentage of total workforce, by all causes (i.e. retrenchment, retirement, dismissal, abscondment, medical boarding, resignation, etc.)
    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. Total number of Guest Injuries recorded
    8. Electricity consumption
    9. Diesel and petrol consumption
    10. Total volume of water consumed
    11. Total volume of waste generated and sent to landfill
    12. Total volume of waste generated and sent for recycling
    13. Presence and application of human rights training
    14. programmes for employees and all key contractors (e.g. security personnel), including a review of all procedures to monitor compliance
    15. Total number of incidents of human rights infringements (e.g. excessive use of force by security personnel, limits to rights to freedom of association, etc.);
  • 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 visits were 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)
  • The content of the Report does not differ, in any significant way, from an analysis of the material issues discussed within Sun International, or within its sphere of influence, as per our internal and external materiality scans.
  • 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. However, some sites require additional support with respect to understanding and/or applying Group sustainability definitions to ensure consistency of reporting information.
  • Certain site-reported data was found to be inaccurate and/or unreliable due to systems/process errors. For example:
    • Systems to collect and collate Contractor Hours Worked were inadequate to provide “actual data”, leading to the potential for over-reporting injury frequency rates, and thus decreasing the comparability of this data within Sun International and against other companies.
    • A lack of consistent application of groupwide occupational health and safety definitions, particularly at Boardwalk, has led to the incomplete reporting of work-related injuries among contractors.
    • Waste management systems and controls (waste separation and recycling) are in place at all operations, but some – particularly Carousel – could stand to observe the excellent processes employed at Sibaya, where waste management was deemed “excellent”.
  • As per management assertions, Sun International engages key stakeholders, as defined within this Report, based on the evidence reviewed.
  • Within the parameters of a “Moderate Level Type II assurance assessment”, the Report reasonably reflects an accurate accounting of Sun International’s performance, including the review of data supplied by the team (excluding those indicators mentioned above) at the selected sites.
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 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 AA 1000AS (2008).
  • Sun International should continue to improve its sustainability policies, procedures, systems and controls – particularly with respect to the enhancement of Group definitions and reporting guidance, for health and safety and waste management, inclusive of target setting – to ensure that best practices within the Group can be shared between operations for overall group-level improvement.
  • 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 AA1000AS (Type II) assurance over key sustainability performance data at selected sites (three per annum). At bare minimum, this should include an overhaul of guidance around reporting definitions to ensure that data submitted by all sites is both consistent and comparable.
GRI G3
  • Having addressed the requirements of GRI G3 Application Level B (B+ with this assurance statement), it is our recommendation that Sun International continues to make further improvements on the quality of data included in future reports, with due consideration to be given towards applying the GRI’s G4 Guidelines in 2015.

Conclusions

Based on the information reviewed, IRAS 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 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 – inclusive of the supplemental GRI Content Index (available via Sun International’s website) – appears to meet the GRI G3’s requirements for Application Level B (B+ with this assurance engagement).

Integrated Reporting & Assurance Services (IRAS)

Johannesburg

16 October 2014 Sun